ML11307A160
| ML11307A160 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 02/23/2011 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML11307A160 (4) | |
Text
1 SeabrookNPEm Resource From:
Plasse, Richard Sent:
Wednesday, February 23, 2011 12:17 PM To:
Cliche, Richard
Subject:
FW: Followup buried pipe RAI for Seabrook Attachments:
Seabrook BP Followup RAI Feb 2011.docx Draft RAIs
Hearing Identifier:
Seabrook_License_Renewal_NonPublic Email Number:
2247 Mail Envelope Properties (Richard.Plasse@nrc.gov20110223121700)
Subject:
FW: Followup buried pipe RAI for Seabrook Sent Date:
2/23/2011 12:17:28 PM Received Date:
2/23/2011 12:17:00 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 2/23/2011 12:17:00 PM Seabrook BP Followup RAI Feb 2011.docx 17793 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
RAI B.2.1.22-1A
=
Background===
The applicants response to RAI B.2.1.22-1 was not sufficient to resolve all of the staffs questions.
Issues
- a. Although the applicant will be sampling for several different factors (e.g., soil resistivity, water samples) it is not clear to the staff that the stated parameters are sufficient, nor how the results will be combined to determine the level of soil corrosivity such as can be determined by using American Water Works Association C105/A2.15-10 Table A.1.
- b. The applicants program only increases the number of planned inspections based on the quality of backfill in the vicinity of the buried pipe. Given that portions of buried in-scope steel piping are not provided with cathodic protection, the staff believes that the number of inspections of this piping should also be informed by localized soil conditions.
- c. Given that localized soil conditions can vary, the applicants response was not clear enough for the staff to conclude that soil samples will be obtained in the vicinity of each buried in-scope steel piping system (excluding fire protection) that is not provided cathodic protection.
- d. It is not clear to the staff how often soil samples will be obtained during the period of extended operation.
Request
- a. State what soil parameters will be utilized and how their aggregate impact will be evaluated to determine localized soil corrosivity.
- b. State whether localized soil conditions will be utilized to increase the number of inspections or state how there will be reasonable assurance that the piping systems CLB function(s) will be maintained without increasing the number of samples in the absence of localized soil data or with results that indicate that the soil is corrosive.
- c. State if soil samples will be obtained in the local vicinity of all buried in-scope steel piping systems (excluding fire protection) that are not provided with cathodic protection.
- d. State how often soil sampling will be conducted during the period of extended operation, or if soil samples will not be collected during the period of extended operation, state how it is known that localized soil conditions will not vary with time.
RAI B.2.1.22-3A
=
Background===
The applicants response to RAI B.2.1.22-3 was not sufficient to resolve all of the staffs questions.
Isssue:
The applicant stated that it utilized a Keeler and Long 1000 Kolormastic system and Tapecoat 20 primer and wrap when installing flanges to allow access to the underground service water piping that is exposed to raw water. The applicant also stated that the painting system chosen for the piping is designed to protect the pipe from long term external corrosion when exposed to continuous immersion in brackish stagnant water. The staff does not have sufficient information related to this coating to independently determine that it will provide protection to the piping when exposed to long term immersion.
Request:
Provide copies of the vendor technical data that demonstrated that the coating system was acceptable for long term immersion in a brackish water environment. Alternatively, if the vendor information is proprietary, provide a copy of the applicable portions of the engineering evaluation of the coating system.
RAI RAI B.2.1.22-5
=
Background===
In LRA Supplement 2 dated November 15, 2010, the applicant revised LRA Table 3.3.2-37 was revised to include copper alloy with > 15% zinc valves and bolting exposed to raw water in the submerged underground vault for service water piping. The applicant stated that the components will be managed for aging by the Buried Piping and Tanks Inspection Program.
Issue The applicant did not revise LRA Section B.2.1.22 to reflect inclusion of this material nor provide inspection frequencies.
Request Revise LRA Section B.2.1.22 to reflect inclusion of copper alloy >15% zinc and state the number of planned inspections of these components.