ML11307A141
| ML11307A141 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/03/2010 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11307A141 (15) | |
Text
SeabrookNPEm Resource From: Plasse, Richard Sent: Wednesday, November 03, 2010 2:12 PM To: Cliche, Richard
Subject:
Draft Seabrook AMP Audit RAIs...
Attachments: SBK AMP RAIs Water Chemistry (TRP 2) - Mintz Klos.docx; SBK AMP RAIs Aboveground Steel Tanks (TRP 30) - Pan Holston.docx; SBK AMP RAIs Bolting Integrity (TRP 19) - Axler Sun.docx; SBK AMP RAIs Compressed Air (TRP 25) - Axler Sun.docx; SBK AMP RAIs External Surfaces (TRP 37) - Axler_Wong_rev2.docx; SBK AMP RAIs Fire Water (TRP 28) -
Mintz, Kichline.docx; SBK AMP RAIs Internal Surfaces (TRP 39) - Axler Klos.docx; SBK AMP RAIs Selective Leaching of Materials (TRP 34) - Pan- Wong.docx Draft RAIs 1
Hearing Identifier: Seabrook_License_Renewal_NonPublic Email Number: 2228 Mail Envelope Properties (Richard.Plasse@nrc.gov20101103141100)
Subject:
Draft Seabrook AMP Audit RAIs...
Sent Date: 11/3/2010 2:11:38 PM Received Date: 11/3/2010 2:11:00 PM From: Plasse, Richard Created By: Richard.Plasse@nrc.gov Recipients:
"Cliche, Richard" <Richard.Cliche@fpl.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 12 11/3/2010 2:11:00 PM SBK AMP RAIs Water Chemistry (TRP 2) - Mintz Klos.docx 19340 SBK AMP RAIs Aboveground Steel Tanks (TRP 30) - Pan Holston.docx 18613 SBK AMP RAIs Bolting Integrity (TRP 19) - Axler Sun.docx 15858 SBK AMP RAIs Compressed Air (TRP 25) - Axler Sun.docx 15706 SBK AMP RAIs External Surfaces (TRP 37) - Axler_Wong_rev2.docx 18312 SBK AMP RAIs Fire Water (TRP 28) - Mintz, Kichline.docx 21477 SBK AMP RAIs Internal Surfaces (TRP 39) - Axler Klos.docx 21554 SBK AMP RAIs Selective Leaching of Materials (TRP 34) - Pan- Wong.docx 19283 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
DRAFT Seabrook Station RAI
- TRP 2- Water Chemistry (TRP 2)
Water Chemistry Questions RAI B.2.1.2-1 Formatted: Font: Bold Formatted: Font: Bold
Background
The GALL Report AMP XI.M2, Water Chemistry Program element 5, Monitoring monitoring and Trendingtrending states that whenever corrective actions are taken to address an abnormal chemistry condition, increased sampling is utilized to verify the effectiveness of these actions. The applicants Aging Management Program Basis Document for Water Chemistry stated that its program specifies the frequency of sampling. This document also stated that routine primary and secondary system sampling frequencies are specified in station procedures in accordance with EPRI water chemistry guidelines. The applicant further stated that its Primary Chemistry Control Program document states that the Water Chemistry Program contains guidance on increasing sampling frequency to address an abnormal chemistry condition.
Issue The staff reviewed the applicants chemistry guidelines and could not identify any statements that indicated that under abnormal chemistry conditions the sampling frequency should be increased.
Request Describe how the Water Chemistry Program will verify the effectiveness of corrective actions when an abnormal chemistry conditions occurs.
RAI B.2.1.2-2 Formatted: Font: Bold Formatted: Font: Bold
Background
The SRP-LR states that past operating experience would not necessarily invalidate an aging management program because the feedback from operating experience should have resulted in appropriate program enhancements or new programs. A review of past operating experience has indicated a reoccurring condition in the condensate storage tank (CST) where the specific conductivity is high and out of specification. This type of occurrence was observed in 2005 (CR 05-12035), early 2007 (CR 07-02531), and late 2007 (CR 07-15493).
Issue It was not clear to the staff if the applicant has evaluated these incidents to determine if the cause of these conductivity spikes were related. If the causes were determined to be the same, it is not clear how the applicant has incorporated enhancements into its Water Chemistry Program to reduce the occurrence of any future CST conductivity excursions.
Request Provide additional information if the CST conductivity excursions were evaluated for similar root causes. If the root cause is the same for the three instances reference previously, provide additional information on what steps have been taken to reduce the occurrence of any future CST conductivity excursions.
Seabrook Aboveground Steel Tanks Program RAI B.2.1.17-1
Background
The program description of GALL AMP XI.M29 Aboveground Steel Tanks states that the program relies on periodic system walkdowns to monitor degradation of the protective paint or coating. LRA Section B.2.1.17 states that visual inspection of the external surface of the protective coatings on exterior surface of the in-scope tanks will be conducted in accordance with its Structural Monitoring Program.
Issue LRA AMP B.2.1.31, Seabrook Structural Monitoring Program, does not state that coating inspections of aboveground steel tanks is within its scope.
Request Confirm that the Seabrook Structural Monitoring Program includes coating inspection of aboveground steel tanks.
RAI B.2.1.17-2
Background
Standard Review Plan Table 3.3-2, FSAR Supplement for Aging Management of Auxiliary Systems, states that the applicants FSAR supplement for the Aboveground Steel Tanks Program should include a statement that visual inspections of sealant and caulking inspections are included in the program.
Issue The Seabrook UFSAR Supplement does not include a statement that visual inspections of sealant and caulking are in the scope of the Aboveground Steel Tanks Program.
Request Revise the Aboveground Steel Tanks Program UFSAR Supplement, Section A.2.1.17 to include a statement that visual inspections of sealant and caulking are in the scope of the program.
RAI B.2.1.17-3
Background
The detection of aging effects program element of GALL AMP XI.M29 Aboveground Steel Tanks states that periodic system walkdowns confirm that the sealant, and caulking are intact and they are an effective method to manage the effects of corrosion on the external surface of tanks. LRA Section B.2.1.17 states that visual inspection will be performed to detect drying, cracking, or missing sealant and caulking applied along the tank and ground interface.
Issue In order to detect hardening and loss of strength in elastomeric materials it is necessary to supplement the visual inspection with physical manipulation of the sealant and caulking.
Request Confirm that the Seabrook Aboveground Steel Tanks Program includes manual manipulation of elastomeric sealant and caulking material to detect hardening and loss of strength.
RAI B.2.1.17-4
Background
The acceptance criteria program element of the GALL AMP XI.M29 Aboveground Steel Tanks states that, Any degradation of paint, coating, sealant, and caulking is reported and will require further evaluation. Degradation consists of cracking, flaking, or peeling of paint or coatings, and drying, cracking or missing sealant and caulking.
LRA Section B.2.1.17 states an enhancement to the Aboveground Steel tanks Program by adding paint flaking and drying, cracking, or missing sealant and caulking as examples of minor structural deficiencies.
Issue The staff requires clarification of the meaning of the term minor structural deficiencies.
Request Does the term minor structural deficiency imply that no further evaluation of the degraded condition will occur? If no further evaluation will occur, justify this as an exception to GALL AMP XI.M29.
RAI B.2.1.17-5
Background
The monitoring and trending program element of GALL AMP XI.M29 Aboveground Steel Tanks states, The effects of corrosion of the underground external surface are detectable by thickness measurement of the tank bottom and are monitored and trended if significant material loss is detected. LRA Section B.2.1.17, Enhancement No. 2 states that for the two fire protection water storage tanks, the program will be enhanced to include the performance of an UT examination of the internal tank bottom surface within 10 years prior to the period of extended operation.
Issue The staff is not clear whether the UT examination is a one-time or periodic inspection.
Request Clarify whether the UT examination specified in LRA Section B.2.1.17, Enhancement No. 2 is a one-time measurement or periodic inspection. If it is a one-time UT inspection, justify how the one-time measurement can be used for monitoring and trending of aging effects.
Seabrook Station AMP B.2.1.9, Bolting Integrity RAI B.2.1.9-1
Background
Program element 3, Parameters Monitored/Inspected, of GALL AMP XI.M18, Bolting Integrity, states that the program monitors the effects of aging on the intended function of bolting.
Specifically, bolting for safety-related pressure retaining components is inspected for leakage, loss of material, cracking, and loss of preload/loss of prestress. Bolting for other pressure retaining components is inspected for signs of leakage.
LRA section B.2.1.9 states The program includes periodic inspection of closure bolting assemblies to detect signs of leakage that may be indicative of loss of preload, loss of material, or crack initiation. Periodic inspection of bolted closures in conjunction with the Seabrook Station Inservice Inspection Program and Seabrook Station External Surfaces Monitoring Program will detect the aging effects and joint leakage. Operator rounds and system walkdowns will also identify joint leakage.
Issue There are in-scope components in the applicants Fire Protection System, Service Water System, and Spent Fuel Pool Cooling System that are in wet or submerged environments.
Visual inspections conducted during operator rounds and system walkdowns to detect leakage which indicate a loss of preload may not be feasible due to these environmental conditions.
Request Explain how the in-scope bolting components in wet or submerged environments will be inspected to effectively manage the loss of preload aging effect.
Seabrook Station AMP B.2.1.14, Compressed Air Monitoring RAI B.2.1.14-1
Background
Program element 5, Monitoring and Trending, of the GALL AMP XI.M24, Compressed Air Monitoring, states that the effects of corrosion and the presence of contaminants are monitored by visual inspection and periodic system and component tests.
LRA section B.2.1.14 describes the inspection criteria as being set by New Hampshire state inspection requirements. The inspection methods to be used are not specified in the LRA.
Furthermore, the LRA does not clarify whether there are additional visual inspections credited by this AMP which monitor the effects of corrosion and the presence of contaminants.
Issue The inspections conducted in accordance with the New Hampshire state inspection requirements may or may not be equivalent to the specifications for inspection stated in GALL.
Furthermore, even if the current New Hampshire state inspection requirements are equivalent to those recommendations stated in GALL, there is no assurance that they will not become divergent in the period of extended operations.
Request Provide an explanation of how the in-scope components in the compressed air system will be inspected, consistent with the recommendations defined in GALL AMP XI.M24.
DRAFT RAIs Seabrook Station AMP AMP B.2.1.24, External Surfaces Monitoring RAI B.2.1.24-1
Background
The GALL Report XI.M36, External Surfaces Monitoring states that for program element 5, monitoring and trending, Vvisual inspection activities are performed and associated personnel are qualified in accordance with site controlled procedures and processes. LRA section B.2.1.24 states that Tthe program inspects for hardening and loss of strength in components made from elastomers by visual examinations to detect discontinuities and imperfections of the surface of the component, and non-visual examinations such as tactile techniques, which include scratching, bending, folding, stretching and pressing in conjunction with the visual examinations.
Issue The applicants AMP has in-scope components that can not be reached for hands-on inspection and are therefore are not accessible for the tactile inspection described in the LRA AMP.
Request Provide details describing how the inspections tactile techniques would be applied for the in-scope elastomeric components that are inaccessible for physical manipulation.
RAI B.2.1.24-2
Background
The program description in GALL Report XI.M36, External Surfaces Monitoring, states that Tthe his program consists of periodic visual inspections of steel components such as piping, piping components, ducting, and other components within the scope of license renewal and subject to AMR in order to manage aging effects. The program manages aging effects through visual inspection of external surfaces for evidence of material loss. LRA section B.2.1.24 states that in addition to steel, components of other construction materials will be covered. Specifically, LRA section B.2.1.24 states The Seabrook Station program will also apply to components made from other materials such as aluminum, cast austenitic stainless steel, copper alloy, copper alloy
>15% Zn, elastomer, galvanized steel, gray cast iron, nickel alloy, and stainless steel.
Issue The applicants AMP is being applied to materials beyond steel, which is the material specified in GALL for this AMP. The additional materials exhibit different aging
mechanisms than steel, and the observable indications of corrosion are substantially different from those of steel. For example, the oxidation of in-scope aluminum components can not be identified by the discoloration and appearance of rust which is the visual indicator of corrosion on steel. Therefore the inspections must be adapted to address detection of aging for the additional in-scope materials.
Request Provide details on the additional inspection methods to be used to ensure that the AMP will adequately address potential aging effects on the additional in-scope materials.
DRAFT Seabrook Station - Fire Water System Program (TRP 28)
Fire Water System Break Out Questions RAI B.2.1.16-1
Background
GALL AMP XI.M27, Fire Water System Program description states that the fire protection system piping is to be subjected to required flow testing in accordance with guidance in NFPA 25 to verify design pressure or evaluated for wall thickness (e.g., nonintrusive volumetric testing or plant maintenance visual inspections) to ensure that aging effects are managed and that wall thickness is within acceptable limits. The GALL Report also states that these inspections are performed before the end of the current operating term and at plant-specific intervals thereafter during the period of extended operation.
LRA section B2.1.16 states that the Fire Water System Program will be enhanced to perform periodic visual inspection or volumetric inspection, as required, of the internal surface of the fire protection system and that this inspection will be performed no earlier than 10 years before the period of extended operation.
Issue The LRA only indicates when the inspections will not be conducted and does not indicate whether the visual inspection or volumetric inspection will be implemented prior to the period of extended operation. It is not clear to the staff if the intent of the enhancement is to have the inspections conducted prior to the period of extended operation, as recommended by the GALL Report.
Request Confirm whether the inspection activities are planned to start before or after the period of extended operations. If inspections will be not be conducted prior to entering the period of extended operation, provide technical justification for not conducting the inspections until after entering the period of extended operation.
RAI B.2.1.16-2
Background
SRP Table 3.3-2, FSAR Supplement for Aging Management of Auxiliary Systems states that the Fire Water System Program FSAR Supplement should include periodic full flow flush tests and system performance testing to prevent corrosion due to biofouling. The SRP also states that portions of the fire protection system exposed to water should be visually inspected.
GALL AMP XI.M27, Fire Water System Program, element 4, detection of aging effects states that as an alternative to non-intrusive testing, the plant maintenance process may include a visual inspection of the internal surface of the fire protection piping upon each entry to the system for routine or corrective maintenance, as long as it can be demonstrated that inspections are performed on a representative number of locations on a reasonable basis. The GALL Report also states that these inspections must be capable of evaluating (1) wall thickness to ensure against catastrophic failure and (2) the inner diameter of the piping as it applies to the design flow of the fire protection system.
The applicants FSAR Supplement states that the Fire Water System Program manages loss of material and reduction of heat transfer due to fouling of the Fire Water System components through detailed inspections via the Seabrook Station Surveillance Test Procedures.
DRAFT Seabrook Station - Fire Water System Program (TRP 28)
Issue The applicants FSAR supplement for the Fire Water System Program does not indicate that periodic full flow flush tests and system performance testing are performed or that the visual inspections included in the program will be able to detect wall thickness and the inner diameter of the piping.
Request Modify the FSAR supplement to indicate that periodic full flow flush tests and system performance testing are performed and that the visual inspections in the program will be able to detect wall thickness and the inner diameter of the piping.
RAI B.2.1.16-3
Background
GALL AMP XI.M27, Fire Water System Program, element 4, detection of aging effects states that as an alternative to non-intrusive testing, the plant maintenance process may include a visual inspection of the internal surface of the fire protection piping upon each entry to the system for routine or corrective maintenance, as long as it can be demonstrated that inspections are performed on a representative number of locations on a reasonable basis.
Issue Neither the applicants Fire Water System Program description in LRA Section B2.1.16 nor the program basis documentation provide any indication of how the inspections will be conducted on a representative number of locations on a reasonable basis.
Request Provide information on how the Fire Water System Program inspects a representative number of locations on a reasonable basis, including both opportunistic and directed inspections.
DRAFT RAIs Seabrook Station RAI Formatted: Centered TRP 39- AMP B.2.1.25, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components RAI B.2.1.25-1 Formatted: Justified, Line spacing: Multiple 1.15 li
Background
The GALL Report XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components states in Program element 4, that for detection of aging effects,, the applicant Formatted: Font: 11 pt should justify the inspection technique used for detecting the aging effects of concern. The applicants AMP states that The program will be used to detect hardening and loss of strength in components made from elastomers by visual examinations and non-visual examinations such as tactile techniques, which include scratching, bending, folding, stretching and pressing in conjunction with the visual examinations.
Issue The management of aging effects of elastomers is covered by this AMP with the addition of non-visual examinations such as tactile techniques. However, there are instances of in-scope components that are not accessible for physical manipulations.
Request Provide an explanation of how the tactile examinations described in the AMP will be applied to in-scope components that are not accessible for physical manipulations.
RAI B.2.1.25-2
Background
The GALL Report XI.M38, , Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components states that the acceptance criteria are established in the maintenance Formatted: Font: 11 pt and surveillance procedures or other established plant procedures. In LRA section B.2.1.25, it states Visual inspection will monitor parameters such as corrosion, corrosion byproducts, coating degradation, discoloration on the surface, scale/deposits, pits and surface discontinuities. In LRA section B.2.1.25, it also states that The degree to which these conditions exist will be used to establish baseline acceptance criteria for future inspections.
Issue The statement in LRA section B.2.1.25 indicates that the results of the applicants inspections will be used to establish acceptance criteria.
Request Provide details on the process to be used for establishing new acceptance criteria based on the results of the inspections. Details should include how the establishment of new acceptance
criteria will be done in a manner that will assure the applicants AMP is effective to detect aging effects prior to loss of component function.
Formatted: Justified
Formatted: Justified, Line spacing: Multiple 1.15 li RAI B.2.1.25-3
Background
The GALL Report XI.M38, , Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Pprogram element 3, parameters monitored/inspected, states that visible evidence of corrosion may indicate possible loss of materials. In LRA section B.2.1.25, it states A thin, light, even layer of oxidation provides protection against further corrosion.
Issue The statement in LRA section B.2.1.25 regarding a layer of oxidation proving protection against further corrosion is not accurate for most of the in-scope materials. Therefore, taken in the general context as it appears in the applicants AMP, the statement is not accurate.
Request Provide technical clarification on the specific in-scope materials to which the subject statement is intended to describe. Also, provide an explanation of how this statement pertains to monitoring of oxidation by the inspections in this program.
DRAFT Seabrook Selective Leaching of Materials Program RAI B.2.1.21-1 (#224)
Background
The parameters monitored or inspected element of the GALL AMP XI.M33 Selective Leaching of Materials recommends a possible expansion of the inspection sample size and location if selective leaching has occurred. The detection of aging effects element recommends the initiation of an engineering evaluation to determine the acceptability of the affected components if selective leaching has occurred. LRA Section B.2.1.21 states that if it is determined that selective leaching is occurring, then an engineering evaluation will be initiated to determine acceptability of the affected components for continued service. Follow-up of unacceptable inspection findings will include an expansion of the inspection sample size and location. LRA Section B.2.1.21 also states that Seabrook Station has experienced instances of de-aluminization of aluminum bronze components having an internal environment of raw sea water.
Issue Given that selective leaching of aluminum bronze components has occurred, it is unclear how an expansion of the inspection sample sizes and locations are being implemented at Seabrook.
Request
- 1) Clarify if the Selective Leaching of Materials Program has implemented an expansion of the inspection sample size and location given selective leaching has occurred. If so, describe the methodology and criteria for selecting a representative sample population that envelop all plant systems and working conditions at locations most susceptible to selective leaching. If not, describe any planned inspection and associated activities ahead.
- 2) Provide justification for the methodology, sample size and location used for selecting components with different material and environment combinations for selective leaching inspections.