ML14034A060

RAI ISG Coatings RAI 0214

ML14034A060
Person / Time
Site:	Limerick
Issue date:	02/10/2014
From:	Richard Plasse License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
References
TAC ME6555, TAC ME6556
Download: ML14034A060 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 10, 2014 Mr. Michael P. Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME6555 AND ME6556)

Dear Mr. Gallagher:

By letter dated June 22, 2011, Exelon Generation Company, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations (CFR) Part 54, to renew the operating license NPF-39 and NPF-85 for Limerick Generating Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC) staff. The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information, outlined in the enclosure, were discussed with Christopher Wilson, and a mutually agreeable date for the response is within 35 days from the date of this letter. If you have any questions, please contact me at 301-415-1427 or by e-mail at Richard. Plasse@nrc.gov.

Docket Nos. 50-352 and 50-353

Enclosure:

Requests for Additional Information cc: Listserv Sincerely, Richard A. Plasse, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

ML14034A060

• concurred via email OFFICE LA:DLR PM:RPB1 :DLR BC:RPB1 :DLR PM: RPB1 :DLR NAME YEdmonds R Plasse Y Diaz-Sanabria R Plasse DATE 2/3/2014 2/4/2014 2/4/2014 2/10/2014

Letter to M. Gallagher from Richard A. Plasse dated February 10, 2014

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME6555 AND ME6556).

DISTRIBUTION:

HARD COPY:

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RAI3.0.3-1

Background:

LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION The staff has noted several recent industry operating experience (OE) events related to loss of coating integrity of internal coatings. This has resulted in the staff concluding that several Aging Management Programs (AMP) and Aging Management Review (AMR) items in the License Renewal Application (LRA) may not or do not account for this OE.

Issue:

Loss of coating integrity for Service Levell II (augmented) coatings:

Industry 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 (e.g., cavitation damage downstream of a control valve), would be managed for Service Levell II (augmented) coatings.

For purposes of this RAI, Service Level Ill (augmented) coatings include:

1. Those installed on the interior of in-scope piping, heat exchangers, and tanks which support functions identified under 10 CFR 54.4(a)(1) and (a)(2).

2. Coatings installed on the interior of in-scope piping, heat exchangers, and tanks whose failure could prevent satisfactory accomplishment of any of the functions identified under 10 CFR 54.4(a)(3).

The term "coating" includes inorganic (e.g., zinc-based) or organic (e.g., elastomeric or polymeric) coatings, linings (e.g., rubber, cementitious), and concrete surfacers (e.g.,

concrete-lined fire water system piping. 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 (augmented) coatings an AMP should include:

1. Baseline visual inspections of coatings installed on the interior surfaces of in-scope components should be conducted in the 1 0-year period prior to the period of extended operation.

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

a. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections could be conducted after multiple refueling outage intervals (e.g., for example six years, or ENCLOSURE more if the same coatings are in redundant trains and turbulent flow is not a concern).

b. 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.

c.

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

3. 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.

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

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

6. 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 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:

1. the inspection method

2. the parameters to be inspected

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

4. the extent of inspections and the basis for the extent of inspections if it is not 100 percent

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

6. how trending of coating degradation will be conducted

7. acceptance criteria

8. corrective actions for coatings that do not meet acceptance criteria, and

9. the program(s) that will be augmented to include the above activities.

If necessary, provide revisions to LRA Section 3 Table 2s, Appendix A, and Appendix B.