ML15056A705
Text
Pacific Gas and Electric Company Barry S. Allen Diablo Canyon Power Plant Vice President, Nuclear Services Mail Code 104/6 P. 0. Box 56 Avila Beach, CA 93424 February 25, 2015 805.545.4888 Internal: 691.4888 Fax: 805.545.6445 PG&E Letter DCL-15-027 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Docket No. 50-275, OL-DPR-80 Docket No. 50-323, OL-DPR-82 Diablo Canyon Units 1 and 2 Update to the Diablo Canyon Power Plant License Renewal Application (LRA). Amendment 49 and LRA Appendix E. "Applicant's Environmental Report- Operating License Renewal Stage." Amendment 2
Dear Commissioners and Staff:
By Pacific Gas and Electric Company (PG&E) Letter DCL-09-079, "License Renewal Application," dated November 23, 2009, PG&E submitted an application to the U.S. Nuclear Regulatory Commission (NRC) for the renewal of Facility Operating Licenses DPR-80 and DPR-82, for Diablo Canyon Power Plant (DCPP) Units 1 and 2, respectively. The application included the LRA and LRA Appendix E, "Applicant's Environmental Report- Operating License Renewal Stage."
By PG&E Letter DCL-14-103, "10 CFR 54.21(b) Annual Update to the Diablo Canyon Power Plant License Renewal Application (LRA), Amendment 48 and LRA Appendix E, Applican,t's Environmental Report - Operating License Renewal Stage, Amendment 1,"dated December 22, 2014, PG&E provided the Staff with its evaluation of draft LR-ISG-2013-01, "Aging Management of Loss of Coating Integrity for Internal Service Levell II (Augmented) Coatings" and related LRA mark-ups.
As committed to in PG&E Letter DCL-14-103, Enclosure 1 of this letter provides PG&E's updated evaluation of the final LR-ISG-2013-01, "Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers and Tanks." Enclosure 1 completely supersedes the PG&E evaluation portion of draft LR-ISG-2013-01 that was provided in PG&E Letter DCL-14-103, Enclosure 1, Attachment 8. Enclosure 1 of this letter also provides all LRA sections applicable to the final LR-ISG-2013-01. LRA sections with mark-ups show changes made as a result of PG&E's updated evaluation.
A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk PG&E Letter DCL-15-027 February 25, 2015 Page 2 As committed to in PG&E Letter DCL-14-103, Enclosure 2 to this letter provides updates to LRA Appendix E, Chapter 7, "Alternatives to the Proposed Action," Chapter 8, "Comparison of Environmental Impacts of License Renewal With the Alternatives," Section 9.2, "Alternatives," and Attachment F, "Severe Accident Mitigation Alternatives" (SAMA). Currently, an update of the DCPP seismic hazard is scheduled to be submitted to the NRC in March 2015 in response to NRC letter dated March 12, 2012, regarding 10 CFR 50.54(f) request for information pursuant to the post-Fukushima Near-Term Task Force Recommendation 2.1 seismic hazards reevaluation. PG&E is currently scheduled to complete an evaluation of the 2015 seismic hazard results on the SAMA analysis by June 2015. to this letter provides corrections to identified errata in the LRA.
The affected LRA pages contain changes shown as electronic markups (deletions crossed out and insertions italicized). to this letter provides corrections to identified errata in the Environmental Report. The affected Environmental Report pages contain changes shown as electronic markups (deletions crossed out and insertions italicized).
PG&E is in the process of addressing Coastal Consistency Certification comments on the original Coastal Consistency Certification (Environmental Report, Attachment E). A schedule for potential coastal consistency review will be established upon determining whether to proceed with license renewal.
PG&E will inform the NRC when the schedule has been established.
PG&E makes new regulatory commitments and changes to existing commitments (as defined by NEI 99-04) in this letter. Revised commitments are contained in Enclosure 1 in the LRA Table A4-1 markup. A new regulatory commitment is provided in Enclosure 5.
If you have any questions regarding this response, please contact Mr. Terence L. Grebel, License Renewal Project Manager, at (805) 458-0534.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on February 25, 2015.
Sincerely,
~~n~. AtL-Vice President Nuclear Services A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Document Control Desk PG&E Letter DCL-15-027 February 25, 2015 Page 3 gwh/50638280 Enclosures cc: Diablo Distribution cc/enc: Marc L. Dapas, NRC Region IV Administrator Thomas R. Hipschman, NRC, Senior Resident Inspector Elaine M. Keegan, NRC/NRR Siva P. Ling am, NRC Project Manager Richard A. Plasse, NRC Project Manager, License Renewal A member of the STARS (Strategic Teaming and Resource Sharing) Alliance Callaway
- Diablo Canyon
- Palo Verde
- Wolf Creek
Enclosure 1 PG&E Letter DCL-15-027 Page 1 of 42 Diablo Canyon Power Plant LRA Changes Reflected in the LRA Update Amendment 49 LRA Section Subject Section 2.1.5.15 LR-ISG-2013-01, "Aging Management of Loss of Coating Table 2.1-2 Integrity for Internal Coatings/Linings on In-Scope Piping, Section 3.1.2.1.2 Piping Components, Heat Exchangers, and Tanks" Table 3.1.2-2 Section 3.3.2.1.3 Section 3.3.2.1.4 Section 3.3.2.1.5 Section 3.3.2.1.8 Section 3.3.2.1.12 Section 3.3.2.1.13 Section 3.3.2.1.17 Section 3.3.2.1.19 Table 3.3.2-3 Table 3.3.2-4 Table 3.3.2-5 Table 3.3.2-8 Table 3.3.2-12 Table 3.3.2-13 Table 3.3.2-17 Table 3.3.2-19 Section 3.4.2.1.1 Section 3.4.2.1.4 Table 3.4.2-1 Table 3.4.2-4 Section A 1.9 Section A 1.1 0 Section A 1.13 I Section A 1.22 Section A 1.40 Section A 1.42 Table A4-1 (3, 9, &
74)
Section 81.5 Section 82 Section 82.1.42
Enclosure 1 PG&E Letter DCL-15-027 Page 2 of 42 LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks In Pacific Gas and Electric Company (PG&E) Letter DCL-14-1 03, "1 0 CFR 54.21 (b)
Annual Update to the Diablo Canyon Power Plant License Renewal Application (LRA),
Amendment 48 and LRA Appendix E, Applicant's Environmental Report- Operating License Renewal Stage, Amendment 1,"dated December 22, 2014, PG&E provided a response to draft LR-ISG-2013-01 and committed to providing a response to the final LR-ISG-2013-01, issued on November 14, 2014, to Nuclear Regulatory Commission by February 2015. This enclosure provides PG&E's updated evaluation of the final LR-ISG-2013-01, which completely supersedes the PG&E evaluation portion of Draft LR-ISG-20 13-01 that was provided in PG&E Letter DCL-14-1 03, Enclosure 1, . This enclosure also provides all applicable LRA sections related to the final LR-ISG-2013-01. LRA sections with mark-ups show changes made as a result of PG&E's updated evaluation. LRA sections without mark-ups remain unchanged from what was submitted in PG&E Letter DCL-14-1 03, Enclosure 1, Attachment 8.
PG&E performed a review to identify the components with internal coatings that are within the scope of license renewal and the final LR-ISG-2013-01.
Based on this review, the in-scope components with internal coatings include:
(1) Condensate polisher demineralizer (2) Component cooling water (CCW) system heat exchanger waterboxes (3) CCW butterfly valves (4) Makeup water system asbestos concrete piping (ACP)
(5) Condensate storage tank (6) Raw water storage reservoir (7) Transfer tank (8) Auxiliary salt water system piping and pipe components (9) Fire water system ACP (1 0) Fire water storage tank (11) Fire water system sprinkler piping with galvanized coating (12) Demineralizer regenerant receiver tanks (DRRT)
(13) DRRT piping (14) Hot laundry and shower drain tanks (15) Diesel fuel oil storage tank manway (16) Centrifugal charging pump gear oil cooler shell (17) Steam generator blowdown demineralizer regeneration system piping and pipe components (18) Pressurizer relief tank (19) Oily water and turbine sump system piping and piping components
Enclosure 1 PG&E Letter DCL-15-027 Page 3 of 42 The aging effects associated with the fire water storage tank internal coatings (item 10) are managed by the Fire Water System program as described in PG&E's evaluation of LR-ISG-2012-02 in PG&E Letter DCL-14-1 03, Enclosure 1, Attachment 7C. The Fire Water System program will be enhanced to include the relevant recommendations associated with training and qualification of personnel, acceptance criteria, and corrective actions from LR-ISG-2013-01, Appendix C. LRA Section A 1.13, "Fire Water System," is revised as shown later in this Enclosure, to incorporate the recommendations associated with training and qualification of personnel, acceptance criteria, and corrective actions from LR-ISG-2013-01, Appendix A, Table 3.0-1.
For the remaining piping, piping components, heat exchangers, and tanks with internal coatings in the scope of license renewal a new aging management program (AMP) was developed to manage aging of these coatings consistent with LR-ISG-2013-01. The new program will include the following elements for the management of internal coatings:
Scope of Program The scope of program is internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks exposed to closed cycle cooling water, fuel oil, lubricating oil, raw water, treated borated water, and demineralized water where loss of coating or lining integrity could prevent satisfactory accomplishment of any of the component's or downstream component's current licensing basis (CLB) intended functions identified under 10 CFR 54.4(a)(1 ),
(a)(2), or (a)(3). There are no cementitious linings within the scope of the program. The aging effects associated with fire water tank internal lining are managed by the Fire Water System program (DCPP LRA Appendix 82 .1.13) instead of the Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program.
If a coating/lining has a qualified life, and it will be replaced prior to the end of its qualified life without consideration of extending the life through condition monitoring, it will not be considered long-lived. Coatings that are not considered to be long lived may be removed from the scope of this program.
Inspection Method and Parameters Inspected Visual inspections are intended to identify coatings that do not meet acceptance criteria, such as peeling and delamination.
Aging Mechanisms associated with coatings/lining are described as follows:
Blistering Formation of bubbles in a coating/lining.
- Cracking Formation of breaks in coating/lining that extend through the underlying surface.
Enclosure 1 PG&E Letter DCL-15-027 Page 4 of 42 Flaking Detachment of pieces of the coating/lining itself either from its substrate or from previously applied layers.
Peeling Separation of one or more coats or layers of a coating/lining from the substrate.
Delamination Separation of one coat or layer form another coat or layer, or from the substrate.
Rusting Corrosion of the substrate that occurs beneath or through the applied coating/lining.
Spalling A fragment, usually in the shape of a flake, detached from a concrete member.
Physical damage consists of removal or reduction of the thickness of a coating/lining by mechanical damage. For the purpose of this program, physical damage includes damage which could occur downstream of a throttled valve as a result of cavitation or erosion. It does not include physical damage caused by actions such as installing scaffolding or assembly and disassembly of flanged joints.
Physical testing is intended to identify the extent of potential degradation of the coating/lining.
Inspection Scope Baseline internal coating/linings inspections will be conducted in the ten-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation by a coating specialist of the effect of a coating/lining failure on the in-scope component's intended function, potential problems identified during prior inspections, and known service life history. However, inspection intervals should not exceed those in the final LR-ISG-2013-01, Appendix C, Table 4a, "Inspection Intervals for Internal Coatings/Linings for Tanks, Piping, Piping Components, and Heat Exchangers."
Extent of Inspections The extent of baseline and periodic inspections is based on an evaluation of the effect of a coating/lining failure on the in-scope component's intended function(s),
potential problems identified during prior inspections, and known service life history; however, the extent of inspection is not any less than the following for each coating/lining material and environment combination.
(1) Tanks- all accessible internal surfaces (2) Heat exchangers - all accessible internal surfaces
Enclosure 1 PG&E Letter DCL-15-027 Page 5 of 42 (3) Piping - either inspect a representative sample of 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating/lining material and environment combination, whichever is less. The inspection surface includes the entire inside surface of the 1-foot sample. If geometric limitations impede movement of remote or robotic inspection tools, the number of inspection segments is increased in order to cover an equivalent of 73 1-foot axial length sections. For example, if the remote tool can only be maneuvered to view one-third of the inside surface, 219 feet of pipe is inspected.
Where documentation exists that manufacturer recommendations and industry consensus documents (i.e., those recommended in Regulatory Guide (RG) 1.54, or earlier versions of those standards) were complied with during installation, the extent of piping inspections may be reduced to the lesser of 25 1-foot axial length circumferential segments of piping or 20 percent of the total length of each coating/lining material and environment combination.
The coating/lining environment includes both the environment inside the component and the metal to which the coating/lining is attached. Inspection locations are selected based on susceptibility to degradation and consequences of failure.
Coating/lining surfaces captured between interlocking surfaces (e.g., flange faces) are not required to be inspected unless the joint has been disassembled to allow access for an internal coating inspection or other reasons. For areas not readily accessible for direct inspection, such as small pipelines, heat exchangers, and other equipment, consideration is given to the use of remote or robotic inspection tools.
Either of the following (i.e., item (a) or (b)) is an acceptable alternative to the inspections in this AMP when:
(1) loss of coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction in heat transfer for in-scope components, (2) the component's only CLB intended function is leakage boundary (spatial) or structural integrity (attached) as defined in SRP-LR, Table 2.1-4(b) ,
(3) the internal environment does not contain chemical compounds that could cause accelerated corrosion of the base material if coating/lining degradation resulted in exposure of the base metal,
Enclosure 1 PG&E Letter DCL-15-027 Page 6 of 42 (4) the internal environment would not promote microbiologically-influenced corrosion of the base metal, (5) the coated/lined components are not located in the vicinity of uncoated components that could cause a galvanic couple to exist, and (6) the design for the component did not credit the coating/lining (e.g., the corrosion allowance was not zero).
If the above 6 criteria are met, then either of the following (i.e., item (a) or (b)) is an acceptable alternative to the inspections recommended in this AMP:
(a) A representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the period of extended operation to confirm the acceptability of the corrosion rate of the base metal. For heat exchangers and tanks, a representative sample includes 25 percent coverage of the accessible external surfaces. For piping, a representative sample size is defined above.
The grid dimensions for the representative sample should be consistent with those for inspections for flow-accelerated corrosion.
(b) In lieu of external wall thickness measurements, use GALL Report AMP XI.M36, "External Surfaces Monitoring of Mechanical Components," and AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components," or other appropriate internal surfaces inspection program (e.g., AMP XI.M20 ,
AMP XI.M21A) to manage loss of coating or lining integrity.
In addition, where loss of coating or lining integrity cannot result in downstream effects such as reduction in flow, drop in pressure, or reduction in heat transfer for in-scope components, a representative sample of external wall thickness measurements can be performed every 10 years commencing 10 years prior to the period of extended operation to confirm the acceptability of the corrosion rate of the base metal in lieu of visual inspections of the coatings/linings. A representative sample size is described above with grid dimensions being those consistent with inspections for flow-accelerated corrosion.
Coating Specialist Qualification The training and qualification of individuals involved in coating/lining inspections and evaluating degraded conditions is conducted in accordance with an American Society for Testing and Materials (ASTM) International standard endorsed in RG 1.54 including staff limitations associated with a particular standard.
Enclosure 1 PG&E Letter DCL-15-027 Page 7 of 42 Monitoring and Trending of Coating Degradation A pre-inspection review of the previous two inspections, when available (i.e., two sets of inspection results may not be available to review for the baseline and first subsequent inspection of a particular coating/lining location), is conducted that includes reviewing the results of inspections and any subsequent repair activities.
A coatings specialist prepares the post-inspection report to include: a list and location of all areas evidencing deterioration, a prioritization of the repair areas into areas that must be repaired before returning the system to service and areas where repair can be postponed to the next refueling outage, and where possible, photographic documentation indexed to inspection locations. When corrosion of the base material is the only issue related to coating degradation of the component and external wall thickness measurements are used in lieu of internal visual inspections of the coating, the corrosion rate of the base metal will be trended.
Acceptance Criteria (1) Indications of peeling and delamination are not acceptable.
(2) Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including staff limitations associated with use of a particular standard. Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g., reference ASTM D714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints").
(3) Indications such as cracking, flaking and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including NRC Staff limitations associated with use of a particular standard.
(4) Minor cracking and spalling of cementitious coatings is acceptable provided there is no evidence that the coating is debonding from the base material.
(5) As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.
(6) Adhesion testing results, when conducted, meet or exceed the degree of adhesion recommended in engineering documents specific to the coating and substrate.
Enclosure 1 PG&E Letter DCL-15-027 Page 8 of 42 Corrective Actions Indications noted will be entered into the DCPP Corrective Action Program for appropriate evaluation or disposition.
Coatings that do not meet acceptance criteria are repaired, replaced, or removed. Testing or examination is conducted to ensure that the extent of repaired or replaced coatings/linings encompasses sound coating/lining material.
As an alternative, coatings exhibiting indications of peeling and delamination may be returned to service if:
(1) physical testing is conducted to ensure that the remaining coating is tightly bonded to the base metal, (2) the potential for further degradation of the coating is minimized, (i.e., any loose coating is removed, the edge of the remaining coating is feathered);
(3) adhesion testing using ASTM International standards endorsed in RG 1.54 is conducted at a minimum of three sample points adjacent to the defective area; (4) an evaluation is conducted of the potential impact on the system, including degraded performance of downstream components due to flow blockage and loss of material of the coated component; and (5) follow-up visual inspections of the degraded coating are conducted within two years from detection of the degraded condition, with a re-inspection within an additional two years, or until the degraded coating is repaired or replaced .
If coatings/linings are credited for corrosion prevention (e.g., corrosion allowance in design calculations is zero) and the base metal has been exposed or it is beneath a blister, the component's base material in the vicinity of the degraded coating/lining is examined to determine if the minimum wall thickness is met and will be met until the next inspection .
If a blister is not repaired, physical testing is conducted to ensure that the blister is completely surrounded by sound coating/lining bonded to the surface.
Physical testing consists of adhesion testing using ASTM International standards endorsed in RG 1.54. Where adhesion testing is not possible due to physical constraints, another means of determining that the remaining coating/lining is tightly bonded to the base metal is conducted such as lightly tapping the coating/lining. Acceptance of a blister to remain in-service should be based both
Enclosure 1 PG&E Letter DCL-15-027 Page 9 of 42 on the potential effects of flow blockage and degradation of the base material beneath the blister.
LRA Sections 2.1.5.15, 3.1.2.1.2, 3.3.2.1.3, 3.3.2.1.4, 3.3 :2.1 .5, 3.3.2.1.8, 3.3.2.1.12, 3.3.2.1.13, 3.3.2.1.17, 3.3.2.-1.19, 3.4.2.1 .1, and 3.4.2.1.4, and Tables 2.1-2, 3.1.2-2, 3.3.2-3, 3.3.2-4, 3.3.2-5, 3.3.2-8, 3.3.2-12, 3.3.2-13, 3.3.2-17, 3.3.2-19, 3.4.2-1, and 3.4.2-4 are revised as shown in this Enclosure to identify systems and components with internal coatings. LRA Sections A 1.9, A 1.1 0, A 1.13, A 1.22, and A 1.40, LRA Table A4-1, Items 3, 9, and 74, 8 1.5, and 82, and new LRA Sections A 1.42 and 82.1.42 are included in this Enclosure to identify aging management activities that will be performed to manage loss of coating integrity for in scope components with internal coatings.
Section 2.1 PG&E Letter DCL-15-027 SCOPING AND SCREENING METHODOLOGY Page 10 of 42 2.1.5.15 (LR-ISG-2013-01) Aging Management of Loss of Coating or Lining Integrity for Internal Service bevel Ill (Augmented) Coatings/Linings on In-Scope Piping, Piping components, Heat Exchangers, and Tanks This draft LR ISG vvas issued in draft for public comment. Th e staff issued this Gfa#-LR-ISG to provides an acceptable approach for managing loss of coating or lining integrity in service Ieveii II (augmented) internal coatings/linings for components within the scope of the License Renewal Rule. This draft LR ISG is discussed PG&E Letter DCL 14 103. This LR-ISG is discussed in PG&E Letter DCL-15-027.
Table 2.1-2 NRC Interim Staff Guidance Associated with License Renewal Issue Number Purpose Discussion Status LR-ISG-2013-01 Aging Management of Loss of The staff has issued for public Coating or Lining Integrity for Internal comment draft LR-ISG-2013-01 Service Level Ill (Augmented)
Coatings/Lining on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Section 3.4 PG&E Letter DCL-15-027 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEMS Page 11 of 42 3.1.2.1.2 Reactor Coolant System Materials The materials of construction for the reactor coolant system component types are:
- Metallic with Internal Coating/Lining Aging Effects Requiring Management The follo.wing reactor coolant system aging effects require management:
- Loss of coating integrity Section 3.2 PG&E Letter DCL-15-027 AGING MANAGEMENT OF REACTOR VESSEL, INTERNALS, AND REACTOR COOLANT SYSTEM Page 12 of 42 Table 3.1.2-2 Reactor Vessel, Internals, and Reactor Coolant System - Summary of Aging Management Evaluation -
Reactor Coolant System (Continued)
Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem Tank JLBS Carbon Steel j Treated Borated J Loss of coating !Internal
- INone INone H, 5 (with coating IWater (lnt) 1 integrity ICoatings/Linings for In- j I or lining) Scope Piping, Piping I . I IComponents, Heat I Exchangers, and Tanks 1
l II I I I(B2.1.42J i Plant Specific Notes:
5 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42) program is used to monitor tanks fabricated from carbon steel (with internal coating or lining) with an internal environment of treated borated water for loss of coating integrity. Reference DCL-15-027, Enclosure 1 in response to LR-ISG-2013-01, Appendix B, Table V.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 13 of 42 3.3.2.1.3 Saltwater and Chlorination System Materials The materials of construction for the saltwater and chlorination system component types are:
- Metallic with Service Levell II (augmented) Internal Coating/Lining Aging Effects Requiring Management The following saltwater and chlorination system aging effects require management:
- Loss of coating integrity 3.3.2.1.4 Component Cooling Water System Materials The materials of construction for the component cooling water system component types are:
- Metallic with Service Levell II (augmented) Internal Coating/Lining Aging Effects Requiring Management The following component cooling water system aging effects require management:
- Loss of coating integrity 3.3.2.1.5 Makeup Water System Materials The materials of construction for the makeup water system component types are:
- Concrete with Internal Coating/Lining
- Metallic with Service Level Ill (augmented) Internal Coating/Lining Aging Effects Requiring Management The following makeup water system aging effects require management:
- Loss of coating integrity Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 14 of 42 3.3.2.1.8 Chemical and Volume Control System Materials The materials of construction for the chemical and volume control system component types are:
- Metallic with Service Levell II (augmented) Internal Coating/Lining Aging Effects Requiring Management The following chemical and volume control system aging effects require management:
- Loss of coating integrity 3.3.2.1.12 Fire Protection System Materials The materials of construction for the fire protection system component types are:
- Concrete with Internal Coating/Lining
- Metallic with Service Levell II (augmented) Internal Coating/Lining Aging Effects Requiring Management The following fire protection system aging effects require management:
- Loss of coating integrity 3.3.2.1.13 Diesel Generator Fuel Oil System Materials The materials of construction for the diesel generator fuel oil system component types are:
- Metallic with Service Levell II (augmented) Internal Coating/Lining Aging Effects Requiring Management The following diesel generator fuel oil system aging effects require management:
- Loss of coating integrity Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 15 of 42 3.3.2.1.17 Liquid Radwaste System Materials The materials of construction for the liquid radwaste system component types are:
- Metallic with Internal Coating/Lining Aging Effects Requiring Management The following liquid radwaste system aging effects require management:
- Loss of coating integrity 3.3.2.1.19 Oily Water and Turbine Sump System Materials The materials of construction for the oily water and turbine sump system component types are:
- Metallic with Internal Coating/Lining Aging Effects Requiring Management The following oily water and turbine sump system aging effects require management:
- Loss of coating integrity Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 16 of 42 Table 3.3.2-3 Auxiliary Systems- Summary of Aging Management Evaluation - Saltwater and Chlorination System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Piping LBS,PB Carbon Steel Raw Water (lnt) Loss of coating Internal None None H,3 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1. 42)0pen Cycle Ceelin~ lAlateF ~ysteFA
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Valves LBS, PB Carbon Steel Raw Water (lnt) Loss of coating Internal None None H,3 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1. 42) 0pen Cycle Ceelin~ WateF ~ysteFA Plant Specific Notes:
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3 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1.42)0pen Cycle Ceelin~ \NateF
~ysteFA (82.1.9) program is used to monitor piping and valves fabricated of carbon steel (with internal coating or lining) with an internal environment of raw water (lnt) for loss of coating integrity. Reference PG&E Letter DCL- 15-02714 103, Enclosure 1. AUachFAent 8 in response to Eifa.ft...LR-ISG-2013-01, Appendix B, Table VII.
Enclosure 1 Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 17 of 42 ITable 3.3.2-4 Auxiliary Systems- Summary of Aging Management Evaluation- Component Cooling Water System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem Heat PB Nickel-Alloys Raw Water (lnt) Loss of coating Internal None None H,6 Exchanger (with coating integrity Coatings/Linings for In-(CCW Heat or lining) Scope Piping, Piping Exchanger) Components, Heat Exchangers, and Tanks (82. 1. 42) Q~eA Gyele GooliAg '/Vater System
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Heat PB Copper Alloy Raw Water(lnt) Loss of coating Internal . None None H, 6 Exchanger (with coating integrity Coatings/Linings for In-(CCW Heat or lining) Scope Piping, Piping Exchanger) Components, Heat Exchangers, and Tanks (82. 1. 42) Q~eA Gyele GooliAg }/Vater System
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Valve LBS, PB, Carbon Steel Closed Cycle Loss of coating Internal None None H, 7 SIA (with coating Cooling Water (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1.42)Giosed Cyele GooliAg }/Vater System
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Enclosure 1 Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 18 of 42 I Table 3.3.2-4 Auxiliary Systems ~-S-ummaiy-()fAgingManagement Evaluation- Component Cooling Water System 1 I I Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem Valve PB Carbon Steel Demineralized Loss of coating Internal None None H,8 (with coating Water (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42Jinspection of lntemal S~;~Ffaces in Miscellaneo~;~s Pipin~
ana Q~;~ctin~
r-,.....,.., .4. /0') "' ')')\
~~ 'I""~ ~ *~ .--* *--
Valve PB Copper Alloy Closed Cycle Loss of coating Internal None None H, 7 (with coating Cooling Water (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42)Giosee Gycle Goolin~ 'NateF System Valve PB Stainless Closed Cycle Loss of coating
.--* .
{Q')
Internal 1 1(\\
'""
None None H, 7 Steel (with Cooling Water (lnt) integrity Coatings/Linings for In-coating or Scope Piping, Piping lining) Components, Heat Exchangers, and Tanks (82. 1.42)GIosee Gycle Goolin~ VVateF System
/0') "' "'{"\\
\-- * . "I Plant Specific Notes:
6 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42) 0pen Gycle Goolin~ VVateF System (B2.1.9) program is used to monitor components of the CCW Heat Exchanger fabricated from nickel-alloys or copper alloys (with internal coating or lining) with an internal environment of raw water (lnt) for loss of coating integrity. Reference QGL 14 103. Enclos~;~Fe 1.
Attachment B PG&E Letter DCL-15-027, Enclosure 1 in response to Gfaft..-LR-ISG-2013-01, Appendix B, Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 19 of 42 7 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42)Ciosed Cycle Cooling \'Vater System (82.1.1 0) program is used to monitor valves fabricated of carbon steel, copper alloy, and stainless steel (with internal coating or lining) closed cycle cooling water (lnt) for loss of coating integrity. Reference DCL 14 103, Enclosure 1, Attachment 8 PG&E Letter DCL-15-027, Enclosure 1 in response to Gfa.ft.-LR-ISG-2013-01, Appendix B, Table VII.
8 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2. 1.42Jinspection of Internal Surfaces in Miscellaneous Piping and Ducting (82.1.22) program is used to monitor carbon steel (with internal coating or lining) with an internal environment of demineralized water (lnt) for loss of coating integrity. Reference DCL 14 103. Enclosure 1. Attachment 8 PG&E Letter DCL-15-027, Enclosure 1 in response to Gfa.ft.-LR-ISG-2013-01, Appendix B, Table VII.
Enclosure 1 Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 20 of 42 ITable 3.3.2-5 Auxiliary Systems- Summary of Aging Management Evaluation- Makeup Water System j I i Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem Piping PB Asbestos Raw Water (lnt) Loss of coating Internal None None H,6 Cement integrity Coatings/Linings for In-(with coating Scope Piping, Piping or lining) Components, Heat Exchangers, and Tanks (B2.1.42)1nspection of lntemal S~:JFfaces in Miscellaneoi:Js Pipin~
ana (;}I:Jctin~
("', 1 ')')\
.....,..., ...... ..., '"' ....... {Q')
, .......... . .........
Tank LBS,PB Carbon Steel Demineralized Loss of coating Internal None None H,6 (with coating Water (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42) 1nspection of lntemal S~:JFfaces in Miscellaneoi:Js Pipin~
ana Q~:Jctin~
Raw Water (lnt) Loss of coating
-- - -
{"',
Internal
- -
{Q')
- -
- 1 ')')\
- --
None None H, 6 Tank PB Concrete (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1 .42)1nspection of lntemal S~:JFfaces in Miscellaneoi:Js Pipin~
ana QI:Jctin~
r-,...r'V\ ,4- /0') -1 ')')\
.....,_ 'I"'- - ,._ --* *--
Enclosure 1 Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 21 of 42 ITable 3.3.2-5 Auxiliary Systems- Summary of A[iin[TiVlan-agement Evaluation- Makeup Water System I
! Ii Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem
+aAk PB Fiberglass geFRiAeralize9 Loss of coatiAg IAspectioA of IAtemal WeRe- NeAe ~
'/Vater (IAt) iAtegrity Surfaces iA MiscellaAeous PipiAg aA9 guctiAg GOFRPOAeAts (B~. ~ -~~}
Plant Specific Notes:
6 The IAspectioA of IAtemal Surfaces iA MiscellaAeous PipiAg aA9 guctiAg (B~. ~-~~) Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42) program is used to monitor tanks fabricated from concrete, fiberglass, and carbon steel (with coating or lining), and piping fabricated from asbestos cement (with internal coating or lining) for loss of coatiAg iAtegrity with an internal environment of demineralized water (lnt) or raw water (lnt) for loss of coating integrity. Reference DGL ~ 4 ~ 03 . EAclosure ~. AttachFReAt 8.
PG&E Letter DCL-15-027, Enclosure 1 in response to Gfa.ft.-LR-ISG-2013-01, Appendix B, Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 22 of 42 Table 3. 3. 2-8 Auxiliary Systems- Summary of Aging Management Evaluation - Chemical and Volume Control System Component Intended Material Environment Aging Effect Aging Management Program NUREG- Table 1 Notes Type Function Requiring 1801 Vol. Item Management 21tem P~::~lsatieR h-SS Elastemer SeeeReary Less ef eeati Rg IRSf3eetieR ef IRteFRal S~::~rfaees Nooe Nooe M,-W Damf3eRer 'Nater (IRt) iRtegrity iR MiseellaRee~::~s Pi13iRg aRe n ll"'+inro ("',...rY"I {0') 1 ')')\
Heat PB Carbon Lubricating Oil Loss of coating Internal Coatings/Linings for In- None None H, 10 Exchanger Steel (lnt) integrity Scope Piping, Piping (Centrifugal (Galvanize Components, Heat Charging) d) Exchangers, and Tanks (82. 1.42)1RSf3eetieR ef IRteFRal S~::~rfaees iR MiseellaRee~::~s Pi13iRg aRe D~::~etiRg r'.
~~ ....... ~ ~ **~
{0')
.~-. *--
1 ')')\
Plant Specific Notes:
10 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1.42)1RSf3eetieR ef IRteFRal S~::~rfaees iR MiseellaRee~::~s Pif3iRg aRe D~::~etiRg (82.1.22) program is used to monitor f3l::llsatieR eam13ers (with iRteFRal eeatiRg er liRiRg) 'Nith aR iRteFRal eRvireRmeRt ef seceReary water (IRt) aRe centrifugal charging heat exchangers (with internal coating or lining) with an internal environment of lubricating oil for loss of coating integrity . Reference PG&E Letter DCL-15-027, Enclosure 1DCL 14 103. ERcles~::~re 1. AttachmeRt 8. in response to GFaft.-LR-ISG-2013-01, Appendix B, Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 23 of 42 Table 3.3.2-12 Auxiliary Systems- Summary of Aging Management Evaluation- Fire Protection System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Piping P8 Asbestos Raw Water (lnt) Loss of coating Internal None None H,5 Cement (with integrity Coatings/Linings for In-coating or Scope Piping, Piping lining) Components, Heat Exchangers, and Tanks (82.1.42)1nspection of lntemal S~Ffaces in Miscellaneo~s Pipin§ and Q~ctinJ r' . /0') -1 ')')\
-- *r-- - *- .--* *--
Piping P8 Carbon Steel Raw Water (lnt) Loss of coating Internal None None H,e5 (Galvanized) integrity Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1 .42J inspection of lntemal S~Ffaces in Miscellaneo~s PipinJ and Q~ctin§ r' . .4- /0') -1 ')')\
-- *r-- - *- .--* *- -
Tank P8 Carbon Steel Raw Water (lnt) Loss of coating Fire Water System None None H, 6 (with coating integrity (82.1.13) or lining) ------ --
Plant Specific Notes:
5 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82. 1.42Jinspection of lntemal S~rfaces in Miscellaneo~s Pi pin§ and Q~ctin§ (B2 .1.22) program is used to monitor asbestos concrete piping (with internal coating or lining) and piping fabricated from carbon steel (with internal coating or lining) with an internal environment of raw water for loss of coating integrity . Reference QCL 14 103 PG&E Letter DCL-15-027, Enclosure 1, Attachment 8, in response to Gfa.ft-LR-ISG-2013-01, Appendix 8, Table VII.
6 The Fire Water System (82.1.13) program is used to monitor pi pin§ fabricated from carbon steel (with intemal coatin§ or linin§) and tanks fabricated from carbon steel (with internal coating or lining) with an internal environment of raw water for loss of coating integrity. Reference QCL 14 103 PG&E Letter DCL-15-027, Enclosure 1, Attachment 8, in response to Gfa.ft-LR-ISG-2013-01, Appendix 8, Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 24 of 42 Table 3.3.2-13 Auxiliary Systems- Summary of Aging Management Evaluation- Diesel Generator Fuel Oil System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Tank PB Carbon Steel Fuel Oil (lnt) Loss of coating Internal None None H,2 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2. 1.42)1nspection of lnteFAal S1:1Ffaces in Miscellaneo1:1s Pipin§J anEI Q~:~ctin§J r'. /Q'J ~ 'J'J\
~~ 'I"'~ ~ .. ~ .~--* *----
Plant Specific Notes:
2 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2.1.42) 1nspection of lnteFAal S1:1rfaces in Miscellaneo1:1s Pipin§J anEI Q~:~ctin§J (82 .1.22) program is used to monitor tanks fabricated from carbon steel (with internal coating or lining) with an internal environment of fuel oil for loss of coating integrity. Reference DCL 14 103 PG&E Letter DCL-15-027, Enclosure 1. Attachment g, in response to Graft.-LR-ISG-2013-01, Appendix B, Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 25 of 42 Table 3.3.2-17 Auxiliary Systems- Summary of Aging Management Evaluation- Liquid Radwaste System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Piping L8S Carbon Steel Raw Water (lnt) Loss of coating Internal None None H, 9 with integrity Coatings/Linings for In-Elastomer Scope Piping, Piping Lining Components, Heat Exchangers, and Tanks (82.1.42)
Tank L8S Carbon Steel Raw Water (lnt) Loss of coating Internal None None H, 9 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Valve L8S Carbon Steel Raw Water (lnt) Loss of coating Internal None None H, 9 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Plant Specific Notes:
9 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42) program is used to monitor piping, tanks, and valves fabricated from carbon steel (with internal coating or lining) with an internal environment of raw water for loss of coating integrity. Reference PG&E Letter DCL-15-027, Enclosure 1 in response to LR-ISG-2013-01, Appendix 8 , Table VII.
Section 3.3 PG&E Letter DCL-15-027 AGING MANAGEMENT OF AUXILIARY SYSTEMS Page 26 of 42 Table 3.3.2-19 Auxil~* Svst~ s f Aaina M, t Eva/uat: Oilv Wat~ d TurbineS Svst~
Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Piping LBS Carbon Steel Raw Water (lnt) Loss of coating Internal Coatings/Linings None None H, 4 (Galvanized) integrity for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Plant Specific Notes:
4 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42) program is used to monitor piping fabricated from carbon steel (with internal coating or lining) with an internal environment of raw water for loss of coating integrity.
Reference PG&E Letter DCL-15-027, Enclosure 1 in response to LR-ISG-2013-01, Appendix B, Table VII.
Section 3.4 PG&E Letter DCL-15-027 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEMS Page 27 of 42 3.4.2.1.1 Turbine Steam Supply System Materials The materials of construction for the turbine steam supply system component types are:
- Metallic with Internal Coating/Lining Aging Effects Requiring Management The following turbine steam supply system aging effects require management:
- Loss of coating integrity 3.4.2.1.4 Condensate System Materials The materials of construction for the condensate system component types are:
- Metallic with Service Level Ill (augmented) Internal Coating/Lining Aging Effects Requiring Management The following condensate system aging effects require management:
- Loss of coating integrity Section 3.4 PG&E Letter DCL-15-027 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEMS Page 28 of 42 Table 3.4.2-1 Steam and Power Conversion System- Summary of Aging Management Evaluation- Turbine Steam Supply System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring ' Program 1801 Vol.
Management 21tem Demineralizer L8S Carbon Steel Secondary Water Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Piping L8S Carbon Steel Secondary Water Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1 .42)
Piping L8S Carbon Steel Sodium Hydroxide Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1 .42)
Piping L8S Carbon Steel Sulfuric Acid (lnt) Loss of coating Internal None None H, 9 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1 .42)
Tank L8S Carbon Steel Sodium Hydroxide Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Section 3.4 PG&E Letter DCL-15-027 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEMS Page 29 of 42 Table 3.4.2-1 Steam and Power Conversion System- Summary of Aging Management Evaluation- Turbine Steam Supply System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 11tem Notes Type Function Requiring Program 1801 Vol.
Management 21tem Tank L8S Carbon Steel Sulfuric Acid (lnt) Loss of coating Internal None None H, 9 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Valve L8S Carbon Steel Secondary Water Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Valve L8S Carbon Steel Sodium Hydroxide Loss of coating Internal None None H, 9 (with coating (lnt) integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1 .42)
Valve L8S Carbon Steel Sulfuric Acid (lnt) Loss of coating Internal None None H, 9 (with coating integrity Coatings/Linings for In-or lining) Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42)
Plant Specific Notes:
9 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (82.1.42) program is used to monitor demineralizers, piping, tanks and valves fabricated from carbon steel (with internal coating or lining) with an internal environment of secondary water, sodium hydroxide, or sulfuric acid for loss of coating integrity. Reference PG&E Letter DCL-15-027, Enclosure 1 in response to LR-ISG-2013-01, Appendix 8 , Table VIII.
Section 3.4 PG&E Letter DCL-15-027 AGING MANAGEMENT OF STEAM AND POWER CONVERSION SYSTEMS Page 30 of 42 Table 3.4.2-4 Steam and Power Conversion System - Summary of Aging Management Evaluation - Condensate System Component Intended Material Environment Aging Effect Aging Management NUREG- Table 1 Item Notes Type Function Requiring Program 1801 Vol.
Management 21tem Demineralizer LBS Carbon Steel Secondary Water Loss of coating Internal None None H,5 (with coating (lnt) integrity Coatings/Linings for In-or lining ) Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2. 1.42) 1nspection of lntemal S~Ffaces in Miscellaneo~s Pipin§ ane Q~ctin§
(',.... ........
~~ ,,....~ ~ -~
/Q')
.~- * *--
1 ')')\
Plant Specific Notes:
5 The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (B2. 1.42)1nspection of lntemal S~Ffaces in Miscellaneo~s Pipin§ ane Q~ctin§ (B2.1.22) program is used to monitor condensate polisher demineralizers fabricated from carbon steel (with internal coating or lining) with an internal environment of secondary water for loss of coating integrity. Reference PG&E Letter DCL 14
+WDCL-15-027, Enclosure 1, Attachment 8 in response to ffi:aft.-LR-ISG-2013-01, Appendix B, Table VIII.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 31 of 42 A1.9 OPEN CYCLE COOLING WATER SYSTEM The Open-Cycle Cooling Water System program manages cracking, loss of material, and reduction of heat transfer for components , and loss of integrity for Service Levell II (augmented) internal coatings that are exposed to the raw water of the DCPP OCCW system. The DCPP OCCW system is the auxiliary saltwater (ASW) system.
Components within the scope of the OCCW System program are components of the ASW system and the component cooling water heat exchangers that are cooled by the ASW system. The program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in components of the ASW system or structures and components serviced by the ASW system that are within the scope of license renewal. The program also includes periodic visual inspections and non-destructive examinations to detect biofouling, defective coatings, and degraded piping and components of, systems and components.
The program also currently performs periodic CCW heat exchanger performance testing to ensure that the effects of aging on components are adequately managed for the period of extended operation. The program is consistent with commitments as established in PG&E Letters DCL-90-027, dated January 26, 1990, and DCL-91-286, dated November 25, 1991, in response to NRC Generic Letter 89-13, Se!Vice Water System Problems Affecting Safety-Related Components, including Supplement 1.
As discussed in PG&E Letter DCL 14 103, Enclosure 1, Attachment 8, in response to draft LR ISG 2013 01, the program includes visual inspections of Service Levell II (augmented) internal coatings. For coated surfaces determined to not meet the acceptance criteria, physical testing is performed 'Nhere physically possible (i.e.,
sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, "Service Levell, II, and Ill Protective Coatings Applied to Nuclear Plants." The training and qualification of individuals involved in coating inspections are conducted in accordance
\Vith ASTM International Standards endorsed in RG 1.54 including guidance from the NRC associated 'Nith a particular standard.
Enclosure 1 Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 32 of 42 A1.10 CLOSED-CYCLE COOLING WATER SYSTEM The Closed-Cycle Cooling Water System program manages loss of material, cracking, and reduction in heat transfer, and loss of integrity for Service Levell II (augmented) internal coatings for components within the scope of license renewal in closed-cycle cooling water systems. The program includes maintenance of system chemistry parameters following the guidance of EPRI TR-1 07396, Revision 1, Closed Cooling Water Chemistry Guidelines (EPRI-1007820) to minimize aging. The program provides for: (1) preventive measures to minimize corrosion including maintenance of corrosion inhibitor, pH buffering agent, and biocide concentrations, and (2) periodic system and component performance testing and inspection. Periodic inspection and testing to confirm function and monitor corrosion is performed in accordance with EPRI TR 107396, Revision 1 (EPRI 1007820), and industry and plant operating experience.
As discussed in PG&E Letter DGL 14 103, Enclosure 1, Attachment 8, in response to draft LR ISG 2013 01, the program includes visual inspections of Service Level Ill (augmented) internal coatings. For coated surfaces determined to not meet the acceptance criteria, physical testing is performed \Vhere physically possible (i.e.,
sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, "Service Levell, II, and Ill Protective Coatings Applied to Nuclear Plants." The training and qualification of individuals involved in coating inspections are conducted in accordance
'Nith ASTM International Standards endorsed in RG 1.54 including guidance from the NRC associated v1ith a particular standard.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 33 of 42
- A1.13 FIRE WATER SYSTEM The Fire Water System program manages loss of material due to corrosion, including MIC, fouling, flow blockage because of fouling, and loss of integrity for water-based fire protection systems and Service Level Ill (augmented) internal coatings/linings for vlater based fire protection systemsthe fire water storage tank within the scope of license renewal. Internal and external inspections and tests of fire protection equipment are performed consistent, with exceptions identified in PG&E Letter DCL-14-1 03, Enclosure 1, Attachment 7C, with NFPA-25 (2011 edition). Testing or replacement of sprinklers that have been in place for 50 years is performed in accordance with NFPA-25 (2011 edition). Portions of the deluge systems that are normally dry but periodically subjected to flow and cannot be drained or allow water to collect will undergo augmented testing beyond that in NFPA-25 consisting of volumetric wall thickness examinations. The fire water system is managed by performing routine preventive maintenance, inspections and testing; operator rounds, performance monitoring, and reliance on the corrective action program; and system improvements to address aging and obsolescence issues.
The Fire Water System program will conduct a flow test with air, water, or other medium through each open spray nozzle to verify that deluge systems nozzles are unobstructed.
Water flow tests will verify that the deluge system provide full coverage of the equipment it protects. Visual inspections will be performed on firewater piping. Non-intrusive follow-up volumetric examinations will be performed if internal visual inspections detect surface irregularities to determine if wall thickness is within acceptable limits. Visual inspections will evaluate for the presence of sufficient foreign material to obstruct fire water pipe or sprinklers.
Inspections of the firewater tank will be performed to detect loss of material.
As discussed in PG&E Letter DCL-1 54-027400, Enclosure 1, Attachment Bx, in response to Gfa#-LR-ISG-2013-01, the program includes consists of periodic visual inspections of theService Level Ill (augmented) internal coatingsliner of the fire water storage tank exposed to raw water where loss of lining integrity could impact the components' and downstream components' current licensing basis intended function(s) .
For coated surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing) in conjunction with repair, replacement, or removal of the lining. The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, "Service Levell, II, and Ill Protective Coatings Applied to Nuclear Plants." The training and qualification of individuals involved in coating inspections are conducted in accordance with ASTM International Standards endorsed in RG 1.54 including guidance from the NRC associated with a particular standard.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 34 of 42 The Fire Water program implements the recommendations in LR-ISG-2012-02, as discussed in PG&E Letter DCL-14-1 03, Enclosure 1, Attachments 7C and 8 and the recommendations in LR-/SG-2013-01, as discussed in PG&E Letter DCL-15-027.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 35 of 42 A1.22 INSPECTION OF INTERNAL SURFACES IN MISCELLANEOUS PIPING AND DUCTING COMPONENTS The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program manages cracking, loss of material, change in material properties, hardening, shrinkage, loss of sealing, crazing, dimensional change, and loss of strength of the internal surfaces , and loss of integrity for Service Level Ill (augmented) internal coatings of piping, piping components, and piping elements, ducting, heat exchanger components, polymeric and elastomeric components, tanks, and other components that are not within the scope of other aging management programs (i.e. exposed to environments of plant indoor air; atmosphere/weather; borated water leakage; diesel exhaust; and any water environment other than open-cycle cooling water, treated borated water, and fire water). The program addresses the management of aging internal surfaces of miscellaneous piping and ducting components that are inaccessible during both normal operations and refueling. The program allows internal inspections to be credited if the internal and external material and environment conditions are similar.
If inspections of the interior surfaces of accessible components with material, environment, and aging effects similar to those of the interior surfaces of buried or underground components are not conducted, internal visual or external volumetric inspections capable of detecting loss of material on the internal surfaces will be conducted.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program uses the work control process to conduct and document inspections. The program performs visual inspections to detect aging effects that could result in a loss of component intended function. Visual inspections of internal surfaces of plant components are performed opportunistically during the conduct of periodic maintenance, predictive maintenance, surveillance testing and corrective maintenance.
Additionally, visual inspections may be augmented by physical manipulation to detect hardening and loss of strength of both internal and external surfaces of elastomers or by sufficient pressurization of the elastomer material to expand the surface in such a way that cracks or crazing is evident. The program also includes volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless steel components exposed to diesel exhaust.
At a minimum, in each ten-year period during the period of extended operation, a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect), or a maximum of 25 components per population is inspected. Where practical, inspections focus on the bounding or lead components most susceptible to aging because of time in service and severity of operating conditions. Opportunistic inspections continue in each period despite meeting the sampling limit. Inspections (other than opportunistic inspections) will be based on assessments of the potential degradation which could lead to loss of intended function, and on current industry and plant-specific operating experience.
Enclosure 1 Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 36 of 42 Opportunistic inspections will be based on assessments of the potential degradation which could lead to loss of intended function, and on current industry and plant-specific operating experience.
In accordance with LR-ISG-2012-02, Appendix E, Table 4a, volumetric examination of the refueling water storage tanks, condensate storage tanks, and transfer tanks bottoms from the .inside will be performed for each ten-year period starting 10 years before entering the period of extended operation to confirm the absence of loss of material due to corrosion.
In response to draft LR ISG 2013 01, the program includes visual inspections of Service Levell II (augmented) internal coatings. For coated surfaces determined to not meet the acceptance criteria, physical testing is performed 'vvhere physically possible (i.e.,
sufficient room to conduct testing). The test consists of destructive or nondestructive adhesion testing using ASTM International Standards endorsed in RG 1.54, "Service Levell, II, and Ill Protective Coatings Applied to Nuclear Plants." The training and qualification of individuals involved in coating inspections are conducted in accordance
'Nith ASTM International Standards endorsed in RG 1.54 including guidance from the NRC associated vvith a particular standard.
This program is not intended for use on piping and ducts where repetitive failures have occurred from loss of material that resulted in loss of intended function. However, if the criteria for recurring internal corrosion, as described in LR-ISG-2012-02, Section A are met, the use of this program is allowed if it includes augmented requirements to ensure that any recurring aging effects are adequately managed.
The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program is a new program that will be implemented six months prior to the period of extended operation, except for the volumetric tank inspections, which will begin ten years prior to the PEO in accordance with LR-ISG-2012-02, Appendix E, Table 4a. The Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program implements the recommendations in LR-ISG-2012-02 and LR ISG 2013 01 , as discussed in PG&E Letter DCL-14-103, Enclosure 1, Attachments 7A, 78, 70, 7F, 7G, and 7H , and 8.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 37 of 42 A1.40 PROTECTIVE COATING MONITORING AND MAINTENANCE PROGRAM The Protective Coating Monitoring and Maintenance program is an existing program that manages the condition of Service Levell coatings, including cracking, blistering, flaking, peeling, rusting, and delamination , subjected to indoor air in the containment structure. The Diablo Canyon Protective Coating Monitoring and Maintenance Program monitors the conditions of the Service Level I coatings during refueling outages and uses the corrective action program to resolve non-conforming coatings and those experiencing degradation.
The Protective Coating Monitoring and Maintenance Program, establishes qualifications for individuals responsible for inspecting, coordinating, and evaluating the conditions of the coatings. The Protective Coating Monitoring and maintenance Program requires that all accessible areas of containment are planned for inspections. During every refueling outage, a walkdown is performed by qualified individuals knowledgeable in nuclear coatings to conduct visual examinations and perform physical testing as necessary on the coatings to monitor their condition over time.
The Protective Coating Monitoring and Maintenance program is a condition monitoring program and the monitoring methods are effective in detecting the applicable aging effects and the frequency of monitoring is adequate to prevent significant degradation.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 38 of 42 A1.42 INTERNAL COATINGS/LININGS FOR IN-SCOPE PIPING, PIPING COMPONENTS, HEAT EXCHANGERS, AND TANKS The program consists of periodic visual inspections of all coatings/linings applied to the internal surfaces of in-scope components exposed to closed-cycle cooling water, raw water, secondary water, sulfuric acid, sodium hydroxide, treated borated water, lubricating oil, or fuel oil where loss of coating or lining integrity could impact the component's and downstream component's current licensing basis intended function(s).
For coated/lined surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing) in conjunction with repair or replacement of the coating/lining. The training and qualification of individuals involved in coating/lining inspections of non-cementitious coatings/linings are conducted in accordance with ASTM International Standards endorsed in Regulatory Guide 1.54 including guidance from the staff associated with a particular standard. For cementitious coatings, training and qualifications are based on an appropriate combination of education and experience related to inspecting concrete surfaces.
The internal fire water storage tank liner will be managed using the Fire Water System program (A 1.13).
The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program is a new program that will be implemented no later than six months prior to the period of extended operation with inspections beginning no later than the last refueling outage before the period of extended operation. The Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program implements the recommendations in LR-ISG-2013-01, as discussed in PG&E Letter DCL-15-027, Enclosure 1.
Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 39 of 42 Table A4-1 License Renewal Commitments LRA Implementation Item# Commitment Section Schedule 3 Enhance the Fire Water System program: 82.1 .13 Program is (a) Sprinkler heads in service for 50 years will be -replaced or representative samples from implemented 5 one or more sample areas will be tested consistent with NFPA 25, Inspection, Testing years before the and Maintenance of Water-Based Fire Protection Systems, 2011 Edition guidance. period of extended Test procedures will be repeated at 10-year intervals during the period of extended operation.
operation, for sprinkler heads that were not replaced prior to being in service for 50 Inspections of years, to ensure that signs of degradation, such as corrosion, are detected prior to the wetted normally loss of intended function, and dry piping (b) To perform non-intrusive follow-up volumetric examinations if internal visual segments that inspections detect surface irregularities to determine if wall thickness is within cannot be drained acceptable limits. Visual inspections will evaluate for the presence of sufficient foreign or that allow water material to obstruct fire water pipe or sprinklers to collect begin 5 (c) To be in conformance with LR-ISG-2012-02, Section Cas discussed in PG&E Letter years before the DCL-14-1 03, Enclosure 1, Attachment 7C. period of extended fsf (d) To be in conformance with LR-ISG-2013-01 as discussed in PG&E Letter operation . Internal DCL-15-027, Enclosure 1. linings inspections begin no later than the last refueling outage before the period of extended operation. The program's remaining inspections begin during the period of extended operation 9 Implement the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting 82.1.22 Six months prior to Components program as described in LRA Section 82 .1.22 and to be in conformance with the period of LR-ISG-2012-02 and Draft LR ISG 2013 01 as discussed in PG&E Letter DCL-14-1 03, extended operation Enclosure 1, Attachments 7A, 78, 70, 7F, 7G, and 7H, aAti--8-respectively.,.
~ No later than six 74 PG&E will conform to Draft LR ISG 2013 01 1mplement the Internal Coatings/Linings for In- B2.1.10 months before the
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Appendix A PG&E Letter DCL-15-027 FINAL SAFETY ANALYSIS REPORT SUPPLEMENT Page 40 of 42 Table A4-1 License Renewal Commitments LRA Implementation Item# Commitment Section Schedule Scope Piping, Piping Components, Heat Exchangers, and Tanks program in conformance B2.1.13 period of extended with LR-/SG-2013-01 as discussed in PG&E Letter DCL- 15-02714 103, Enclosure 1,- s2.1. e 2 operation and Attachment 8. inspections begin no later than the last refueling outage before the period of extended operation
Enclosure 1 Appendix B PG&E Letter DCL-15-027 AGING MANAGEMENT PROGRAMS Page 41 of 42 81.5 AGING MANAGEMENT PROGRAMS
- Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks (Section 82.1.42) 82 AGING MANAGEMENT PROGRAMS NUREG-NUREG-1801 EXISTING APPENDIX 8 1801 PLANT PROGRAM PROGRAM OR NEW REFERENCE NUMBER Internal Internal Coatings/Linings on Coatings/Linings on In-Scope Piping, In-Scope Piping, XI.M42 New 82.1.42 Piping Components, Piping Components, Heat Exchangers, Heat Exchangers, and Tanks and Tanks 82.1.42 Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program Description Proper maintenance of internal coatings/linings is essential to ensure that the intended
, functions of in-scope components are met.
Degradation of coatings/linings can lead to loss of material, of base materials and downstream effects such as reduction in flow, reduction in pressure or reduction in heat transfer when coatings/linings become debris. This program manages loss of coating integrity for piping, tanks, and heat exchangers fabricated from concrete, nickel alloy, carbon steel, and stainless steel with an internal coating/lining. The program consists of periodic visual inspections of internal coatings/linings exposed to closed-cycle cooling water, raw water, secondary water, sulfuric acid, sodium hydroxide, treated borated water, fuel oil, and lubricating oil. If certain criteria are met, alternatives to these visual inspections are available. Where the visual inspection of the coated/lined surfaces determines that the coating/lining is deficient or degraded, physical tests are performed, where physically possible, in conjunction with the visual inspection. EPRI Report 1019157, "Guideline on Safety-Related Coatings," provides information on the ASTM standard guidelines and coatings. American Concrete Institute (ACI) Standard 201.1 R-Appendix 8 PG&E Letter DCL-15-027 AGING MANAGEMENT PROGRAMS Page 42 of 42 08, I(Guide for Conducting a Visual Inspection of Concrete in SetVice," provides guidelines for inspecting concrete. Coating inspections and evaluations will be conducted by coating specialists qualified in accordance with an ASTM International standard endorsed in RG 1. 54.
The Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program is a new program that will be implemented no later than six months prior to the period of extended operation. Baseline internal coating/linings inspections will be conducted in the ten-year period prior to the period of extended operation. Subsequent inspections are based on an evaluation by a coating specialist of the effect of a coating/lining failure on the in-scope component's intended function, potential problems identified during prior inspections, and known setVice life history. Previous inspection results are reviewed prior to conducting subsequent inspections, and a post inspection report is prepared after inspections have been completed.
LR-/SG-2013-01 Consistency The Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program is a new program that, when implemented, will be consistent with the recommendations of LR-ISG-2013-01.
Exceptions to LR-/SG-2013-01 None Enhancements None Operating Experience The DCPP Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program is a new program; therefore, plant-specific operating experience to verify the effectiveness of the program is not available. Industry operating experience that forms the basis for this program is included in the operating experience element of LR-ISG-2013-01.
Conclusion The implementation of the Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks program will provide reasonable assurance that aging effects will be managed such that the systems and components within the scope of this program will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.