ML13294A500

Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station License Renewal Application

ML13294A500
Person / Time
Site:	Davis Besse
Issue date:	11/26/2013
From:	Uribe T License Renewal Projects Branch 1
To:	Lieb R FirstEnergy Nuclear Operating Co
Uribe J, 415-3809
References
TAC ME4640
Download: ML13294A500 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 26. 2013 Mr. Raymond A. Ueb, Vice President Davis-Besse Nuclear Power Station FirstEnergy Nuclear Operating Company 5501 North Slate Route 2 Oak Harbor, OH 43449

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)

Dear Mr. Lieb:

By letter dated August 27, 2010, FirstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station. The staff of the U.S. Nuclear Regulatory Commission is reviewing this application in accordance with the guidance in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants." During its review. the staff has identified areas where additional information is needed to complete the review. The staff's requests for additional information are included in the enclosure. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Cliff Custer, of your staff, and a mutually agreeable date for the response is within 60 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-3809 or by e-mail at Juan.Uribe@nrc.gov.

Sincerely,

~i/(7rP~-;~

,/Juan Uribe, Project Manage;/*

Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-346

Enclosure:

As stated cc w/encl. Listserv

..*ML13294A500 "concurred via email OFFICE LA:DLR/RPB2* PM:DLR/RPB1 BC:DLR/RPB1 PM:DLR/RPB1 NAME IKing JUri be YDiaz-Sanabria JUri be (SCuadrado for)

DATE 11/25/13 11/25/13 11/26/13 11/26/13

DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION SUPPLEMENTAL REQUEST FOR ADDITIONAL INFORMATION RAI 3.0.3-3 Issue: Loss of coating integrity for Service Levell II and Other coatings Industry operating experience (OE) indicates that degraded coatings have resulted in unanticipated or accelerated corrosion of the base metal and degraded performance of downstream equipment (e.g., reduction in flow, drop in pressure, reduction in heat transfer) due to flow blockage. Based on these industry OE examples, the staff has questions related to how the aging effect, loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage, would be managed for Service Levellll and Other coatings.

For purposes of this request for additional information (RAI):

a. Service Levell II coatings are those installed on the interior of in-scope piping, heat exchanges, and tanks which support functions identified under Title 10 of the Code of Federal Regulations (CFR) 54.4(a)(1) and (a)(2).

b. "Other coatings," include coatings installed on the interior of in-scope piping, heat exchangers, and tanks whose failure could prevent satisfactory accomplishment of any of the functions identilied under 10 CFR 54.4(a)(3).

c. The term "coating" includes morganic (e.g., zinc-based) or organic (e.g., elastomeric or polymeric) coatings, linings (e.g., rubber, cementitious), and concrete surfacers that are designed to adhere to a component to protect its surface.

d. The terms "paint" and "linings" should be considered as coatings.

The staff believes that to effectively manage loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage of Service Levell II and Other coatings an aging management program should include:

a. Baseline visual inspections of coatings installed on the interior surfaces of in-scope components should be conducted in the 10-year period prior to the period of extended operation

b. Subsequent periodic inspections where the interval is based on the baseline inspection results. For example:

1. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking have been found acceptable, subsequent inspections could be conducted after multiple refueling outage intervals (e.g., for example six years, or more if the same coatings are in redundant trains}.

ii. If the inspection results do not meet the above; but, a coating specialist has determined that no remediation is required, subsequent inspections could be conducted every other refueling outage interval.

111. If coating degradation is observed that required repair or replacement, or for newly installed coatings, subsequent inspections should occur over the next two refueling outage intervals to establish a performance trend on the coatings.

ENCLOSURE

c. All accessible internal surfaces for tanks and heat exchangers should be inspected. A representative sample of internally coated piping components not less than 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination should be inspected.

d. Coatings specialists and inspectors should be qualified in accordance with an ASTM International standard endorsed in RG 1.54, "Service Levell, II, and Ill Protective Coatings Applied to Nuclear Power Plants," including staff guidance associated with a particular standard.

e. Monitoring and trending should include pre-inspection reviews of previous inspection results.

f. The acceptance criteria should include that indications of peeling and delamination are not acceptable. Blistering can be evaluated by a coating specialist; however, physical testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface.

Request:

If coatings have been installed on the internal surfaces of in-scope components (i.e., piping, piping subcomponents, heat exchangers, and tanks), state how loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage will be managed, including:

a. for each installed coating application, whether installation records used to apply the coating included material manufacturer installation specifications

b. the inspection method

c. the parameters to be inspected

d. when inspections will commence and the frequency of subsequent inspections

e. the extent of inspections and the basis for the extent of inspections if it is not consistent with.

item c above

f. the training and qualification of individuals involved in coating inspections

g. how trending of coating degradation will be conducted

h. acceptance criteria

1. corrective actions for coatings that do not meet acceptance criteria the program(s) that wiH be augmented to include the above requirements If necessary, provide revisions to license renewal application Section 3 Table 2s, Appendix A, and Appendix B.

Letter to Raymond A Lieb from Juan Uribe dated November 26, 2013

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE DAVIS-BESSE NUCLEAR POWER STATION LICENSE RENEWAL APPLICATION (TAC NO. ME4640)

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