ML16015A435
| ML16015A435 | |
| Person / Time | |
|---|---|
| Site: | Ginna |
| Issue date: | 01/14/2016 |
| From: | Everett R Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| WPLNRC-1003047 | |
| Download: ML16015A435 (19) | |
Text
SExe!.on Generationm R.E. Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519 www.exeloncorp.com January 14, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 2055-0001 R.E. Ginna Nuclear Power Plant Facility Operating License No. DPR-18 NRC Docket No. 05000244
Subject:
Transmittal of 2015 Owner's Activity Report for the R. E. Ginna Nuclear Power Plant Enclosed is a copy of the R. E. Ginna Nuclear Power Plant Owner's Activity Report for the refueling outage conducted in 2015. This report is submitted as specified by ASME Code Section Xl.
There are no regulatory commitments contained in this letter.
If you have any questions, please contact Thomas Harding at (315) 791-5219.
Respectfully, Rick Everett Director, Engineering Exelon Generation Company, LLC
Attachment:
FIFTH INSERVICE INSPECTION (ISI)
INTERVAL and SECOND CONTAINMENT INSPECTION
- INTERVAL, SECOND INSPECTION PERIOD, 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015) cc:
NRC Regional Administrator, Region 1 NRC Project Manager, Ginna NRC Resident Inspector, Ginna
/ 0z/1 VJPL/o LlJ
-103 bOf
January 14, 2016 Page 2 boo:
D. Blankenship T. Harding F. Klepacki D. Ferraro C. Siverd B. Rudell J. Barstow
ATTACHMENT 1 FIFTH INSERVICE INSPECTION (ISI) INTERVAL and SECOND CONTAINMENT INSPECTION INTERVAL SECOND INSPECTION PERIOD 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015)
R.E. Ginna Nuclear Power Plant, LLC January 14, 2016
-- Exeton Generatiorn FIFTH INSERVICE INSPECTION (ISI) INTERVAL and SECOND CONTAINMENT INSPECTION INTERVAL SECOND INSPECTION PERIOD 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015)
For R. E. Ginna Nuclear Power Plant 1503 Lake Road Ontario, NY 14519 Commercial Service Date:
NRC Docket Number:
Revision Number:
June 1,1970 50-244 00 Date:
January 7, 2016 Frank A. Kiepacki - Site I1 Program qner in Prepared by:
Approved by Francis Peter o ngi*'neering Manager Programs - R E Ginna
R. E. Ginna Nuclear Power Plant, Unit 1
' xetn~eera on 5 th Interval Inservice Inspection and Rev.
00
~ Exeon F~IU~h 2 nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i - 2 of i - 8 FOR
_________________INSERVICEEXAMINATIONS TABLE OF CONTENTS Table of Contents.................................................................................... i-2 Abstract.........................................................................................................
i-3 Form OAR-i Owner's Activity Report for Fifth Interval Inservice Inspection Plan......................i-4 Form OAR-i Owner's Activity Report for Containment Second Interval Inservice Inspection Plan... i-5 Table 1 Items with Flaws or Relevant Conditions that Require Evaluation for Continued Service....i-6 Table 2 Abstract of Repair/Replacement Activities Required for Continued Service...................
i-7, 10OCFR50.55a (ix)(A)(1), ECP-1 5-000715 Evaluation of Acceptability of Inaccessible Areas of Ginna Station Containment Metal Liner.......................................................... i-8
R. E. Ginna Nuclear Power Plant, Unit 1 Exe~n~n 5
rtih Interval Inservice Inspection and Rev.
00
~ ExtoP~~er~~on, 2fld Interval Containment Inservice Inspection Date: 1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -3 of i - 8 FOR
_________________INSERVICE EXAMINATIONS ABSTRACT This Owner's Activity Report (OAR) summarizes the results of the R. E. Ginna Nuclear Power Plant (GNPP),
Unit 1, American Society of Mechanical Engineers (ASME) Section Xl Inservice Inspection (ISI)
Examinations and Repair/Replacement activities performed during this reporting cycle from June 04, 2Q14 through November 6, 2015. The 2015 Refueling Outage (RFO) started October 19, 2015 and ended November 6, 2015. This OAR is for the Fifth Interval Inservice Inspection Program, Second Period and the Second Interval Containment Inservice Inspection Program, Second Period. Associated 181 examinations were performed in accordance with ASME Section XI Code, 2004 Edition, No Addenda. The First Interval Containment Inservice Inspection Program was extended to align with the 151 Program lnterval in accordance with the Fourth Interval Inservice Inspection Program Relief Request Number 22. The 5t Interval Inservice Inspection and the 2r* Interval Containment Inservice Inspection Interval are aligned.
As an alternate to the requirements of the ASME, Boiler and Pressure Vessel Code (B&PVC),Section XI, Article IWA-6000, GNPP has implemented ASME Code Case N-532-4, "Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1". ASME Code Case N-532-4 is approved for use in Regulatory Guide 1.147. This Report complies with the requirements of Code Case N-532-4.
OWNER'S ACTIVITY REPORTS - FORM OAR-i Owner's Activity Reports Form OAR-i's were prepared and certified upon completion of the GNPP Unit 1, 2015 refueling outage RFO-39 examination activity in accordance with the following inspection plans and schedules:
Inservice Inspection Program Plan(s) for the Fifth Inspection Interval for GNPP Unit 1 Long Term Plan for GNPP, Unit 1 181 Program Plan ASME Xl, IWE/IWL Second Inspection Interval In addition to the Owner's Activity Report, Form OAR-i, the following Tables are also included:
- a.
Items with Flaws or Relevant Conditions that Require Evaluation for Continued Service, Table 1, provides a listing of item(s) with inservice flaws or relevant conditions that required evaluation to determine acceptability for continued service, whether or not the flaw or relevant condition was discovered during a scheduled examination or test, and provides such information as Examination Category, Examination Item Number, Item Description, Flaw Characterization (as required by IWA-3300).
- b.
Abstract of Repairs, Replacements or Corrective Measures Required for Continued Service, Table 2, identifies those items containing flaws or relevant conditions that exceeded the ASME Section Xl acceptance criteria (IWX-3000) or in the case of supports IWF-3000 acceptance criteria; even though the discovery of the flaw or relevant condition that necessitated the repair, replacement or corrective measure, may not have resulted from an examination or test required by Section Xl, and provides such information as Code Class, whether the item is a repair, replacement or corrective action, item description, description of work, if the flaw or relevant condition was found during a scheduled Section XI Examination or test, date completed and the repair replacement plan number. (ECP-15-000715) is included to address the requirement of 10CFR50.55a (ix)(A)(1), Evaluation of Acceptability of Inaccessible Areas of Ginna Station Containment Liner.
R. E. Ginna Nuclear Power Plant, Unit 1 Exe~nenra~n 5,h Interval Inservice Inspection and Rev.
00
~ E~ton~neF~~n~
2 nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -4 of i - 8 FOR
__________________INSERVICE EXAMINATIONS FORM OAR-i OWNER'S ACTIVITY REPORT As reqruired by the provisions of the ASME Code Case N-532-4 Report Number GNPP-OAR-!SI-2015 Plant R. E. Ginna Nuclear Power Plant. 1503 Lake Road, Ontario, New York 14519 (Name and Address of Plant)
Unit No.
1 Commercial Service Date June 1, 1970 Refueling Outage Number RFO-39 Current Inspection Interval Fifth Inservice Inspection Interval
- January 1, 2010 to December 31.,2019.
(1st, 2nd, 3rd, 4th, Other)
Current Inspection Period Second Inservice Inspection Period -
January 1, 2013 to December 31. 2016 (1st, 2nid, 3rd)
Edition and Addenda of Section Xl applicable to the Inspection Plan 204Edition, No Addenda Date and Revision of Inspection Plan 25 February 2015. Revision 4 Edition and Addenda of ASME Section Xl applicable to repairs/replacements, if different than the Inspection Plan N/A Code Cases used:
N-532-4, N-706, N-716, N-722, CERTIFICATE OF CONFORMANCE I certify that (a) the statements made in this report are correct; (b) the examinations and tests meet the Inspection Plan as required by the ASME Code, Section Xl; and (c) the repair/replacement activities and evaluations supporting completion of _2015 REQ (RFO-39)_
conform to the requirements of Section Xl.
Certificate of Authorization No.
signed Frank A Klepacki N/A j~lic~
Expiration Date N/A Date
/ /7/,*LO /4, N/A (Site IS1 Program Owner )
/
CERTIFICATE OF INSERVICE INSPECTION I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of New York and employed by HSB Global Standard s of Hartford, Connecticut have inspected the items described in this Owner's Activity Report, and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section Xl.
By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the repair/replacement activities and evaluation described in this report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any rsonal injury ~property damage or a loss ot any kind arising from or connected with this inspection./
Bruce Sawyer
,*1 eV'tL.9 44,-
Commissions NB1 0496. A. N, I; New York 4077 Inspector's Signature
/National Board, State, Province, and Endorsements Date____________________
R. E. Ginna Nuclear Power Plant, Unit 1 Exe0n~neth nInterval Inservice Inspection and Rev.
00
~ Exeto~enerat.p 2 nd Interval Containment Inservice Dae1/726 InspectionDae10/2 6
2015 OWNER'S ACTIVITY REPORT Page i - 5 of i - 8 FOR INSERVICE EXAMINATIONS FORM OAR-i OWNER'S ACTIVITY REPORT As required by, the provisions of the ASME Code Case N-532-4 Report Number GNPP-OAR-IWEJL-2015 Plant R E Ginna Nuclear Power Plant, 1503 Lake Road, Ont~ario, New York 14519 (Name and Address of Plant)
Unit No.
1 Commercial Service Date June 1, 1970 Refueling Outage Number RFO-39 Current Inspection Interval Second Containment Inspection Interval -January 1, 2010 to December 31. 2019 (1st, 2nd, 3rd, 4th, Other)
Current Inspection Period Second Inservice Inspection Period -January 1, 2013 to December 31, 2016 (1st, 2nd, 3rd)
Edition and Addenda of Section XI applicable to the Inspection Plans 2004 Edition, No Addenda Date and Revision of Inspection Plans 25 February 2015, Revision 1 Edition and Addenda of ASME Section Xl applicable to repairs/replacements, if different than the Inspection Plan N/A Code Cases used:
N-532-4, N-686, N-739, N-753, (if applicable)
CERTIFICATE OF CONFORMANCE I certify that (a) the statements made in this report are correct; (b) the examinations and tests meet the Inspection Plan as required by the ASME Code, Section Xl; and (c) the repair/replacement activities and evaluations supporting completion of 2015 RFO (RFO-39) conform to the requirements of Section Xl.
Certificate of Authorization No.
N/A applicable)
Expiration Date N/A Date J/7I2.O/*
Signed Frank A Klepacki (Site 1S1 Program Owner )
1./
/
CERTIFICATE OF INSER VICE INSPECTION I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of New York and employed by HSB Global Standard s of Hartford. Connecticut have inspected the items described in this Owner's Activity Report, and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section Xl.
By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the repair/replacement activities and evaluation described in this report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any per onal injury or pr~oerty damage or a loss of any kind arising from or connected with this inspection.
Bruce Sawyer v<J*
Commissions NB1 0496, A. N, I; New York 4077 Inspector's Signature National Board, State, Province, and Endorsements Dae /7b/,*c /__
R. E. Ginna Nuclear Power Plant, Unit 1
Exe0n~eeraihnInterval Inservice Inspection and Rev.
00
~' Ee~oner~~n~
2nd Interval Containment Inservice Inspection Date: 110712016 2015 OWNER'S ACTIVITY REPORT Page i - 6 of i - 8 FOR
_________________INSERVICE EXAMINATIONS TABLE 1 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRE EVALUATION FOR CONTINUED SERVICE As reauired bv the orovisions of the ASME Code Case N-532-4 EXAMINATION ITEM EVALUATION DESCCRIPTION CATEGORY AND ITEM NUMBER DESCRIPTION There were no items with N/A N/A flaws or relevant conditions that require evaluation for continued service.
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R. E. Ginna Nuclear Power Plant, Unit 1 Exet~~enertth Interval Inservice Inspection and Rev.
00
~' Exto~G~era~on~
2nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -7 of i - 8 FOR
_________________INSERVICE EXAMINATIONS TABLE 2 ABSTRACT OF REPAIR/REPLACEMENT ACTIVITIES REQUIRED FOR CONTINUED SERVICE As req*uired by, the provisions of the ASME Code Case N-532-4 CODE ITEM DESCRIPTION DATE REPAIR/REPLACEMENT CLASS DESCRiPTION OF WORK COMPLETED PLAN NUMBER N/A There were no Repair!
N/A N/A N/A Replacement activities required for Continued Service
R. E. Ginna Nuclear Power Plant, Unit 1
--
- Exl~ne~rat0*
5th Interval Inservice Inspection and Rev.
00
~' Exeon~eneatbn~2nd Interval Containment Inservice Dae1/726 Inspection 2015 OWNER'S ACTIVITY REPORT Page i - 8 of i - 8 FOR
__________________INSERVICE EXAMINATIONS
__________ (ECP-15-000715) was developed to address the requirement of 10CFR 50.55a (ix)(A)(1), Evaluation of Acceptability of Inaccessible areas of the Containment Metal Liner.
Ginna Station Containment Metal Liner is Inaccessible due to sealed insulation by design.
Technical Evaluation ECP-15-000715 Page 1 of 8 R~eason for Evaluation/Scope:
During the Ginna Station 2015 refueling outage, while performing the inspection of the containment liner moisture barrier in the containment building basement, in one area degraded caulking and signs of discoloration on the concrete floor were observed. In accordance with Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROG PLAN-200090501-00003), Section 5.3 req uires insulation removal at any location where the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal. The moisture barrier and associated sealed insulation were removed from this area (approximately 18 inches high by 7 feet long) in order allow examination of the containment metal liner and concrete floor to liner moisture barrier region. Rust was observed on the carbon steel containment liner plate.
ASME Section Xl, IWE-3510.2 requires that visual examination areas that have suspect degradation be accepted by engineering evaluation or corrected by repair/replacement or by corrective measures. 10 CFR 50.55a(b)(2)(ix)(A) requires:
(A) Metal containment examinations: First provision. For Class MC applications, the following apply to inaccessible areas.
(1) The applicant or licensee must evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas.
(2) For each inaccessible area identified for evaluation, the applicant or licensee must provide the following in the ISI Summary Report as required by IWA-6000:
(i) A description of the type and estimated extent of degradation, and the conditions that led to the degradation (ii) An evaluation of each area, and the result of the evaluation; and (iii) A description of necessary corrective actions This Engineering Evaluation completes required evaluations of the containment liner and associated moisture barrier observed conditions.
Technical Evaluation ECP-15-000715 Page 2 of 8 Detailed Evaluation:
Issue Report 02576330 documents an area of moisture barrier degradation at the reactor building inside containment liner sealed insulation stainless steel facing to the reactor building floor. The removal of the stainless steel sheathing and sealed insulation panels was required in the area of the degraded moisture barrier in order to evaluate the containment liner area that are inaccessible due to installed sealed insulation. Ginna Station License Renewal commitment requires that insulation be removed to expose the metal liner when the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal. Subsequent inspections performed with the sealed insulation removed identified areas of liner corrosion requiring further examination and evaluation.
The function of the liner insulation is to limit the mean temperature rise of the liner post-accident. The liner insulation is covered with astainless steel facing to permit washing down the surface during maintenance periods. The liner insulation and stainless steel facing are held into place through the use of studs that are welded to the containment liner and a neoprene washer, stainless steel washer, and a self-locking stainless steel hex nut.
Ginna Station Containment metal liner is covered by sealed insulation and coated with a layer of zinc-rich paint during construction. The containment metal liner is exposed in some areas and not covered by sealed insulation. These areas include the dome and all penetrations. The Moisture Barrier (caulk) encompass the entire length of the interface between the sealed insulation over the metal liner and the containment basement concrete floor. This configuration makes the metal liner inaccessible. The purpose of this document is to evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas. Figure 1 below shows the Containment Metal Liner Configuration (oth~erwise known as the moisture barrier).
C$ LIER PLTE*
RIGID INSULATION ECTEND $.S. SHEET METAL FACING
~1/8" INTO CAULKING BED ONRTwALL AND FLOOR CAULKING TO BE DOW-CORNING 795 CUKFULL DEPTH DETAIL 1 QC To WITES
'PuCATIoN ORIGINAL DESIGN DETAIL PIECNRT iS IHPIE Figure 1: Containment Metal Liner Configuration Technical Evaluation ECP-15-000715 Page 3 of 8 The entire Ginna Station Moisture Barrier Examinations were performed in 2012 and found acceptable.
The 2012 examinations covered the full length of the containment moisture barrier.
Ginna Station has identified one suspect area (Penetration 29) and examinations were performed in this area every period (every 3 to 4 years) since 2005. This suspect area is located at Penetration 29 and the basement floor to the sealed insulation lower panel at 35 Feet West of Penetration 29 and 30 Feet East of Penetration 29. The caulk and lower panels of sealed insulation are removed and associated VT-3, VT-1 and UT thickness examinations performed. Upon acceptable completion, the sealed insulation was re-installed, the Moisture Barrier re-installed and VT-3 re-examined. The associated examinations were acceptable.
The most recent Moisture Barrier Examinations were performed in 2014 and 2015. The result of the 2015 RFO Moisture Barrier examination was acceptable except for one location. The 2015 RFO examinations covered all moisture barriers except for Penetration 29 area. The 2014 RFO examination was associated with Penetration 29 area and all examinations associated with this area were found acceptable.
In the past, Ginna Station has performed examinations to the Containment Liner before ASME Section Xl Code IWE/IWL was made mandatory by 10CFR5O.55a. These examinations are identified within the Ginna Station License Renewal ProJect "ASME Section XI, Subsection IWE & IWL Inservice Inspection Program, Section 5.10, SRP Element 10 -Operating Experience. They include the following:
During the 1999 Refueling Outage, a one-third of the Moisture Barrier was examined and one area was identified that the caulking design detail did not conform to the "as built" drawing (CR 1999-0516). As a result of this discovery, the inspection scope was increased to include the entire circumference of the Moisture Barrier. The caulking was found to be continuous with no visible gaps or discontinuities. As a result of this non-conformance caulk detail issue, the sealed insulation was removed in two areas (one on the north side and one on the west side). Six to eight feet of the metal liner was exposed and visually examined. On the North end, evidence of minor surface corrosion was visible. UT Thickness readings were taken and ranged from 0.346" to 0.404" on the North side and 0.388" to 0.404" on the West side. The nominal thickness of the Containment Liner is 0.375". The minimum required thickness was determined by engineering analysis and documented in EWR 5190 to be 0.281". The area was recoated and the sealed insulation re-installed. The Moisture Barrier was replaced and baseline examination performed and acceptable.
- During the 2002 Refueling Outage, approximately 70 linear feet of Containment Liner was exposed for visual inspection on the south-east side of Containment. In four (4) different areas, the concrete floor was excavated to a depth of 1 1/2A" below the floor level over a length of 12".
Ultrasonic Thickness measurements were taken in these areas. The minimum thickness reading for these locations were 0.402", 0.412", 0.395" and 0.402". Visual evidence of superficial surface corrosion was present at various areas along the exposed portion of the liner. As a result, the liner was cleaned and restored with new coating of zinc-rich paint. Insulation was restored and the Moisture Barrier installed.
Technical Evaluation ECP-15-O00715 Page 4 of 8
-In response to License Renewal RAI B2.1.3-3(1) in July 2003, the containment liner shall be restored if the liner thickness is at or below 0.300". This new value provides margin with respect to Engineering Analysis EWR 5190 that determined the minimum liner wall thickness to be 0.281". The nominal wall thickness of the containment liner is 0.375".
-During the 2006 Refueling Outage, a twenty (20) foot section of the Metal Liner was exposed in the North-west quadrant of containment for a License Renewal Examination. Visual and UT thickness examinations were performed and acceptable. The lowest thickness reading was 0.382" and above the License Renewal commitment of 0.300" threshold for restoring the liner.
During the 2015 RFO, a containment liner moisture barrier at the 235'-8" elevation was examined per work order C92972823 (from 0 degrees to 120 degrees under SIl Summary Number 1900932), and only one localized area was identified for follow-up inspection in the North-East section of containment. The degraded area, around 50 degrees of North, Six (6) foot in length, was noted with rust stains running out from under the caulking/insulation and onto the floor. In accordance with Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROGPLAN-200090501-00003), Section 5.3 requires insulation removal at any location where the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal.
The degraded Moisture Barrier and associated sealed insulation were removed from this area (approximately 18 inches high by 7 feet long) in order to allow examination of the containment metal liner. Rust and pitting was observed on the carbon steel containment liner plate in a band within two to three inches above the concrete basement floor. Light residual dry boric acid was identified. Ultrasonic (UT) thickness measurements of the liner plate show the actual thickness of the 3/8" plate to be 0.405 inches. The mechanical measurement of the depth of the worst case pitting was 1/16 or 0.063 inches, resulting in a measured degraded thickness of 0.342 inches. The minimum allowable thickness, based on License Renewal commitment is 0.300 inches.
Additional insulation panels were removed to identify extent of condition. A total of 500 inches of metal liner was exposed. The two to three inch band area was conditioned, cleaned, boric acid residue removed, visually examined and acceptable. Ultrasonic thickness readings were also performed on the expanded area, the lowest reading obtained was 0.387". This reading is acceptable and above license renewal commitment of 0.300 inches. The area was recoated (painted) and a pre-service visual examination was performed and acceptable. The area was recovered with sealed insulation and the moisture barrier reapplied. A pre-service visual examination was performed on the new moisture barrier and acceptable.
Technical Evaluation ECP-15-000715 Page 5 of 8 it is postulated that the degraded section of Moisture Barrier (caulk) allowed standing floor water to penetrate into the insulation. The insulation became wet by wicking that resulted in a band of corrosion within two to three inches along the floor. The floor water was caused by normal outage and refueling activities such as Reactor Cavity Leakage. As a result of cavity leakage, Penetration 29 area has been identified as a Section Xl Code Suspect Area since 2005 and is located roughly 180 degrees from North (0 degree). This suspect area experience continuous wetting and is located along the basement floor to the sealed insulation and moisture barrier at Penetration 29, 35 Feet West of Penetration 29 and 30 Feet East of Penetration 29. The lower panels of sealed insulation are removed and associated VT-3, VT-i and UT thickness examinations performed. Upon acceptable completion, the sealed insulation and moisture barrier was re-installed, VT-3 re-examined and acceptable. The 2015 RFO area was between 10 to 70 degrees and away from the Penetration 29 suspect area located at 180 degrees.
The following statements are facts:
- 1. The function of the liner insulation is to limit the mean temperature rise of the liner post-accident. The liner insulation is covered with a stainless steel facing to permit washing down the surface during maintenance periods. The liner insulation and stainless steel facing are held into place through the use of studs that are welded to the containment liner and a neoprene washer, stainless steel washer, and a self-locking stainless steel hex nut.
- 2. A license renewal containment liner stainless steel facing inspection was performed at the beginning of the 2015 RFO per work order C92594552 and no unacceptable areas were identified. Also, the dome metal liner was examined under WO C92999194 and found acceptable. All Penetration metal liners were examined under Work Orders C92994282 &
C92972819 and found acceptable.
- 3. The visual inspection of the containment liner Moisture Barrier at the 235'-8" elevation was performed per work order C92972823 (from 0 degrees to 120 degrees under I51 Summary Number 1900932), and only one localized area was identified for follow-up inspection in the North-East section of containment. The area was noted with rust stains running out from under the insulation and onto the floor. The moisture barrier insulation was removed and some rust and pitting identified on the carbon steel containment liner plate in a band within two to three inches above the floor. The moisture barrier (caulk) degraded in a section that allowed containment standing floor water to penetrate the degraded moisture barrier and wet the insulation by a wicking action. UT thickness measurements of the base material show the actual thickness of the 3/8" plate to be 0.405 inches. The mechanical measurement of the depth of the worst case pitting was 1/16 or 0.063 inches, resulting in a measured degraded thickness of 0.342 inches. The minimum allowable thickness, based on License Renewal commitment (RAI B2.1.3-3(1)), is 0.300 inches.
Technical Evaluation ECP-15-O00715 Page 6 of 8
- 4.
Besides the original 7 foot section of sealed insulation panel removed, as an extent of condition, a total of five (5) additional 7 foot sections of sealed insulation panels have been removed for inspection of the adjacent areas in accordance with work order C93225184. The total length of exposed metal liner equates to 500 inches. Based on the VT-3 visual inspections and mechanical measurements, the original area of degradation was the most severe and had the most material loss, therefore bounding all other inspected areas.
- 5.
The liner rusted surface was in a band within two to three inches above the floor. This area was prepped for a VT-i and UT inspection in order to determine remaining wall thickness of the containment liner. Associated visual examinations and thickness readings were acceptable. The liner areas were cleaned, recoated, VT-3 examined and acceptable. The Moisture Barrier was re-installed, examined and acceptable.
- 6.
Currently, one suspect area (Penetration 29) has been identified since 2005 and is located roughly 180 degrees of North. This suspect area is at the basement floor to the sealed insulation at 35 Feet West of Penetration 29, 30 Feet East of Penetration 29 and Penetration 29. The caulk and lower panels of sealed insulation are removed and associated VT-3, VT-i and UT thickness examinations are performed. Upon acceptable completion of examinations, the sealed insulation is re-installed, the Moisture Barrier reinstalled and VT-3 re-examined. This area is on an increased inspection frequency as required by ASME Section Xl Code, 2004 Edition, No Addenda. The increased frequency of examination on this area is every Period. The degraded areas identified during the 2015 RFO are not associated with this area.
- 7.
During the 2015 and 2014 Refueling Outages, the Moisture Barrier was 100% examined. The only unacceptable condition was identified during the 2015 Refueling Outage as identified above. Based on these facts it can be concluded that Moisture Barrier examinations is successful at identifying unacceptable degraded conditions. There is currently no evidence to indicate that other acceptable areas would have equal or greater material loss.
- 8.
The most likely cause for the observed degradation is the exposure to borated water from leakage of the reactor cavity during refueling activities. This degradation mechanism is a long term issue, potentially corroding the liner over the life of the plant only when the Moisture Barrier does not perform its intended function. Refueling activities have been concluded for the 2015 RFO and the cavity has been drained. Based on this, it is not expected that the degradation will propagate. The identified degradation of the metal liner has been stopped by recoating the metal liner and re-caulking of the Moisture Barrier.
Technical Evaluation ECP-15-O00715 Page 7 of 8 Conclusions/Findinl~s:
- 1. The identified degraded containment metal liner surface was cleaned and prepped to accommodate the VT-i and UT examinations. These examinations are acceptable and documented within 15I Summary Reports 1901000 and 1901500.
- 2.
Corrective measures shall be used on the extent of condition. The metal liner was cleaned and re-coated on the exposed 500 inches (North-East section between 10 to 70 degrees) and examined. The 2015 RFO VT-3 baseline examination was performed and acceptable.
- 3.
Engineering recommends a follow-up inspection on the 500 inch restored section of the metal liner identified during the Containment 1SI Examinations performed on the Moisture Barrier during the 2015RF0. This follow-up examination should be scheduled for the Third Period (2017 RFO or 2018 RFO).
- 4.
There are no other areas of degradation worse than the one 500 inch section that was identified during the 2015 RFO. During the 2014 and 2015 timeframe, all Moisture Barriers have been examined and only one area was degraded. The area that was degraded (unacceptable) was corrected during the 2015 RFO.
- 5.
Moisture Barrier Visual Examinations is successful in discovering Metal Liner degraded conditions.
References:
- 1.
ASME Section Xl Code, 2004 Edition, No Addenda.
- 2.
Second Ten-Year Containment Inservice Inspection Plan (January 1, 2010 to December 31, 2019)
[ISIM-2015-0002 15.22.12].
- 3.
UFSAR 18.2.1.3; ASME, Section Xl, Subsections IWE & IWL Inservice Inspection.
- 4.
2015 RFO NDE examinations reports under ISI Summary Numbers 1900932, 1901000 and 1901500
- 5.
Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROGPLAN-200090501-00003.
- 6.
Drawing 21489-0700 Rev 2, Examinations and Modifications to the Containment Moisture Barrier.
- 7.
ECP-15-000632, "Evaluate Containment Liner Plate Conditions" (Technical Evaluation).
Technical Evaluation ECP-15-000715 Page 8 of 8 Prepared By:
Date:
Frank A. Klep'acki - 151 Engineer Independent Reviewer:
FI17*S,,lmfloA5 Pe*
E-A'4,/ L)47,ec I't/z//IS" Date:
Mark B. Fitzsimmons - RPE 1/~ /w/~,
Manager Approval:.¶*/*_,Uf, n* sSe-'__*
Date:
t Francis D. Peterson - Engineeri n~JK ger Programs Review:
Bruce Sawyer - Authorizec/Nuclear Inservice Inspector Date: __/_______
SExe!.on Generationm R.E. Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519 www.exeloncorp.com January 14, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 2055-0001 R.E. Ginna Nuclear Power Plant Facility Operating License No. DPR-18 NRC Docket No. 05000244
Subject:
Transmittal of 2015 Owner's Activity Report for the R. E. Ginna Nuclear Power Plant Enclosed is a copy of the R. E. Ginna Nuclear Power Plant Owner's Activity Report for the refueling outage conducted in 2015. This report is submitted as specified by ASME Code Section Xl.
There are no regulatory commitments contained in this letter.
If you have any questions, please contact Thomas Harding at (315) 791-5219.
Respectfully, Rick Everett Director, Engineering Exelon Generation Company, LLC
Attachment:
FIFTH INSERVICE INSPECTION (ISI)
INTERVAL and SECOND CONTAINMENT INSPECTION
- INTERVAL, SECOND INSPECTION PERIOD, 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015) cc:
NRC Regional Administrator, Region 1 NRC Project Manager, Ginna NRC Resident Inspector, Ginna
/ 0z/1 VJPL/o LlJ
-103 bOf
January 14, 2016 Page 2 boo:
D. Blankenship T. Harding F. Klepacki D. Ferraro C. Siverd B. Rudell J. Barstow
ATTACHMENT 1 FIFTH INSERVICE INSPECTION (ISI) INTERVAL and SECOND CONTAINMENT INSPECTION INTERVAL SECOND INSPECTION PERIOD 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015)
R.E. Ginna Nuclear Power Plant, LLC January 14, 2016
-- Exeton Generatiorn FIFTH INSERVICE INSPECTION (ISI) INTERVAL and SECOND CONTAINMENT INSPECTION INTERVAL SECOND INSPECTION PERIOD 2015 OWNER'S ACTIVITY REPORT FOR RFO-39 INSERVICE EXAMINATIONS (October 19, 2015 through November 6, 2015)
For R. E. Ginna Nuclear Power Plant 1503 Lake Road Ontario, NY 14519 Commercial Service Date:
NRC Docket Number:
Revision Number:
June 1,1970 50-244 00 Date:
January 7, 2016 Frank A. Kiepacki - Site I1 Program qner in Prepared by:
Approved by Francis Peter o ngi*'neering Manager Programs - R E Ginna
R. E. Ginna Nuclear Power Plant, Unit 1
' xetn~eera on 5 th Interval Inservice Inspection and Rev.
00
~ Exeon F~IU~h 2 nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i - 2 of i - 8 FOR
_________________INSERVICEEXAMINATIONS TABLE OF CONTENTS Table of Contents.................................................................................... i-2 Abstract.........................................................................................................
i-3 Form OAR-i Owner's Activity Report for Fifth Interval Inservice Inspection Plan......................i-4 Form OAR-i Owner's Activity Report for Containment Second Interval Inservice Inspection Plan... i-5 Table 1 Items with Flaws or Relevant Conditions that Require Evaluation for Continued Service....i-6 Table 2 Abstract of Repair/Replacement Activities Required for Continued Service...................
i-7, 10OCFR50.55a (ix)(A)(1), ECP-1 5-000715 Evaluation of Acceptability of Inaccessible Areas of Ginna Station Containment Metal Liner.......................................................... i-8
R. E. Ginna Nuclear Power Plant, Unit 1 Exe~n~n 5
rtih Interval Inservice Inspection and Rev.
00
~ ExtoP~~er~~on, 2fld Interval Containment Inservice Inspection Date: 1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -3 of i - 8 FOR
_________________INSERVICE EXAMINATIONS ABSTRACT This Owner's Activity Report (OAR) summarizes the results of the R. E. Ginna Nuclear Power Plant (GNPP),
Unit 1, American Society of Mechanical Engineers (ASME) Section Xl Inservice Inspection (ISI)
Examinations and Repair/Replacement activities performed during this reporting cycle from June 04, 2Q14 through November 6, 2015. The 2015 Refueling Outage (RFO) started October 19, 2015 and ended November 6, 2015. This OAR is for the Fifth Interval Inservice Inspection Program, Second Period and the Second Interval Containment Inservice Inspection Program, Second Period. Associated 181 examinations were performed in accordance with ASME Section XI Code, 2004 Edition, No Addenda. The First Interval Containment Inservice Inspection Program was extended to align with the 151 Program lnterval in accordance with the Fourth Interval Inservice Inspection Program Relief Request Number 22. The 5t Interval Inservice Inspection and the 2r* Interval Containment Inservice Inspection Interval are aligned.
As an alternate to the requirements of the ASME, Boiler and Pressure Vessel Code (B&PVC),Section XI, Article IWA-6000, GNPP has implemented ASME Code Case N-532-4, "Alternative Requirements to Repair and Replacement Documentation Requirements and Inservice Summary Report Preparation and Submission as Required by IWA-4000 and IWA-6000,Section XI, Division 1". ASME Code Case N-532-4 is approved for use in Regulatory Guide 1.147. This Report complies with the requirements of Code Case N-532-4.
OWNER'S ACTIVITY REPORTS - FORM OAR-i Owner's Activity Reports Form OAR-i's were prepared and certified upon completion of the GNPP Unit 1, 2015 refueling outage RFO-39 examination activity in accordance with the following inspection plans and schedules:
Inservice Inspection Program Plan(s) for the Fifth Inspection Interval for GNPP Unit 1 Long Term Plan for GNPP, Unit 1 181 Program Plan ASME Xl, IWE/IWL Second Inspection Interval In addition to the Owner's Activity Report, Form OAR-i, the following Tables are also included:
- a.
Items with Flaws or Relevant Conditions that Require Evaluation for Continued Service, Table 1, provides a listing of item(s) with inservice flaws or relevant conditions that required evaluation to determine acceptability for continued service, whether or not the flaw or relevant condition was discovered during a scheduled examination or test, and provides such information as Examination Category, Examination Item Number, Item Description, Flaw Characterization (as required by IWA-3300).
- b.
Abstract of Repairs, Replacements or Corrective Measures Required for Continued Service, Table 2, identifies those items containing flaws or relevant conditions that exceeded the ASME Section Xl acceptance criteria (IWX-3000) or in the case of supports IWF-3000 acceptance criteria; even though the discovery of the flaw or relevant condition that necessitated the repair, replacement or corrective measure, may not have resulted from an examination or test required by Section Xl, and provides such information as Code Class, whether the item is a repair, replacement or corrective action, item description, description of work, if the flaw or relevant condition was found during a scheduled Section XI Examination or test, date completed and the repair replacement plan number. (ECP-15-000715) is included to address the requirement of 10CFR50.55a (ix)(A)(1), Evaluation of Acceptability of Inaccessible Areas of Ginna Station Containment Liner.
R. E. Ginna Nuclear Power Plant, Unit 1 Exe~nenra~n 5,h Interval Inservice Inspection and Rev.
00
~ E~ton~neF~~n~
2 nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -4 of i - 8 FOR
__________________INSERVICE EXAMINATIONS FORM OAR-i OWNER'S ACTIVITY REPORT As reqruired by the provisions of the ASME Code Case N-532-4 Report Number GNPP-OAR-!SI-2015 Plant R. E. Ginna Nuclear Power Plant. 1503 Lake Road, Ontario, New York 14519 (Name and Address of Plant)
Unit No.
1 Commercial Service Date June 1, 1970 Refueling Outage Number RFO-39 Current Inspection Interval Fifth Inservice Inspection Interval
- January 1, 2010 to December 31.,2019.
(1st, 2nd, 3rd, 4th, Other)
Current Inspection Period Second Inservice Inspection Period -
January 1, 2013 to December 31. 2016 (1st, 2nid, 3rd)
Edition and Addenda of Section Xl applicable to the Inspection Plan 204Edition, No Addenda Date and Revision of Inspection Plan 25 February 2015. Revision 4 Edition and Addenda of ASME Section Xl applicable to repairs/replacements, if different than the Inspection Plan N/A Code Cases used:
N-532-4, N-706, N-716, N-722, CERTIFICATE OF CONFORMANCE I certify that (a) the statements made in this report are correct; (b) the examinations and tests meet the Inspection Plan as required by the ASME Code, Section Xl; and (c) the repair/replacement activities and evaluations supporting completion of _2015 REQ (RFO-39)_
conform to the requirements of Section Xl.
Certificate of Authorization No.
signed Frank A Klepacki N/A j~lic~
Expiration Date N/A Date
/ /7/,*LO /4, N/A (Site IS1 Program Owner )
/
CERTIFICATE OF INSERVICE INSPECTION I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of New York and employed by HSB Global Standard s of Hartford, Connecticut have inspected the items described in this Owner's Activity Report, and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section Xl.
By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the repair/replacement activities and evaluation described in this report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any rsonal injury ~property damage or a loss ot any kind arising from or connected with this inspection./
Bruce Sawyer
,*1 eV'tL.9 44,-
Commissions NB1 0496. A. N, I; New York 4077 Inspector's Signature
/National Board, State, Province, and Endorsements Date____________________
R. E. Ginna Nuclear Power Plant, Unit 1 Exe0n~neth nInterval Inservice Inspection and Rev.
00
~ Exeto~enerat.p 2 nd Interval Containment Inservice Dae1/726 InspectionDae10/2 6
2015 OWNER'S ACTIVITY REPORT Page i - 5 of i - 8 FOR INSERVICE EXAMINATIONS FORM OAR-i OWNER'S ACTIVITY REPORT As required by, the provisions of the ASME Code Case N-532-4 Report Number GNPP-OAR-IWEJL-2015 Plant R E Ginna Nuclear Power Plant, 1503 Lake Road, Ont~ario, New York 14519 (Name and Address of Plant)
Unit No.
1 Commercial Service Date June 1, 1970 Refueling Outage Number RFO-39 Current Inspection Interval Second Containment Inspection Interval -January 1, 2010 to December 31. 2019 (1st, 2nd, 3rd, 4th, Other)
Current Inspection Period Second Inservice Inspection Period -January 1, 2013 to December 31, 2016 (1st, 2nd, 3rd)
Edition and Addenda of Section XI applicable to the Inspection Plans 2004 Edition, No Addenda Date and Revision of Inspection Plans 25 February 2015, Revision 1 Edition and Addenda of ASME Section Xl applicable to repairs/replacements, if different than the Inspection Plan N/A Code Cases used:
N-532-4, N-686, N-739, N-753, (if applicable)
CERTIFICATE OF CONFORMANCE I certify that (a) the statements made in this report are correct; (b) the examinations and tests meet the Inspection Plan as required by the ASME Code, Section Xl; and (c) the repair/replacement activities and evaluations supporting completion of 2015 RFO (RFO-39) conform to the requirements of Section Xl.
Certificate of Authorization No.
N/A applicable)
Expiration Date N/A Date J/7I2.O/*
Signed Frank A Klepacki (Site 1S1 Program Owner )
1./
/
CERTIFICATE OF INSER VICE INSPECTION I, the undersigned, holding a valid commission issued by the National Board of Boiler and Pressure Vessel Inspectors and the State or Province of New York and employed by HSB Global Standard s of Hartford. Connecticut have inspected the items described in this Owner's Activity Report, and state that to the best of my knowledge and belief, the Owner has performed all activities represented by this report in accordance with the requirements of Section Xl.
By signing this certificate neither the Inspector nor his employer makes any warranty, expressed or implied, concerning the repair/replacement activities and evaluation described in this report. Furthermore, neither the Inspector nor his employer shall be liable in any manner for any per onal injury or pr~oerty damage or a loss of any kind arising from or connected with this inspection.
Bruce Sawyer v<J*
Commissions NB1 0496, A. N, I; New York 4077 Inspector's Signature National Board, State, Province, and Endorsements Dae /7b/,*c /__
R. E. Ginna Nuclear Power Plant, Unit 1
Exe0n~eeraihnInterval Inservice Inspection and Rev.
00
~' Ee~oner~~n~
2nd Interval Containment Inservice Inspection Date: 110712016 2015 OWNER'S ACTIVITY REPORT Page i - 6 of i - 8 FOR
_________________INSERVICE EXAMINATIONS TABLE 1 ITEMS WITH FLAWS OR RELEVANT CONDITIONS THAT REQUIRE EVALUATION FOR CONTINUED SERVICE As reauired bv the orovisions of the ASME Code Case N-532-4 EXAMINATION ITEM EVALUATION DESCCRIPTION CATEGORY AND ITEM NUMBER DESCRIPTION There were no items with N/A N/A flaws or relevant conditions that require evaluation for continued service.
+
t.
1~
1-t
+
t
+
t
.4.
4
+
4
-+
4
R. E. Ginna Nuclear Power Plant, Unit 1 Exet~~enertth Interval Inservice Inspection and Rev.
00
~' Exto~G~era~on~
2nd Interval Containment Inservice InspetionDate:
1/07/2016 2015 OWNER'S ACTIVITY REPORT Page i -7 of i - 8 FOR
_________________INSERVICE EXAMINATIONS TABLE 2 ABSTRACT OF REPAIR/REPLACEMENT ACTIVITIES REQUIRED FOR CONTINUED SERVICE As req*uired by, the provisions of the ASME Code Case N-532-4 CODE ITEM DESCRIPTION DATE REPAIR/REPLACEMENT CLASS DESCRiPTION OF WORK COMPLETED PLAN NUMBER N/A There were no Repair!
N/A N/A N/A Replacement activities required for Continued Service
R. E. Ginna Nuclear Power Plant, Unit 1
--
- Exl~ne~rat0*
5th Interval Inservice Inspection and Rev.
00
~' Exeon~eneatbn~2nd Interval Containment Inservice Dae1/726 Inspection 2015 OWNER'S ACTIVITY REPORT Page i - 8 of i - 8 FOR
__________________INSERVICE EXAMINATIONS
__________ (ECP-15-000715) was developed to address the requirement of 10CFR 50.55a (ix)(A)(1), Evaluation of Acceptability of Inaccessible areas of the Containment Metal Liner.
Ginna Station Containment Metal Liner is Inaccessible due to sealed insulation by design.
Technical Evaluation ECP-15-000715 Page 1 of 8 R~eason for Evaluation/Scope:
During the Ginna Station 2015 refueling outage, while performing the inspection of the containment liner moisture barrier in the containment building basement, in one area degraded caulking and signs of discoloration on the concrete floor were observed. In accordance with Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROG PLAN-200090501-00003), Section 5.3 req uires insulation removal at any location where the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal. The moisture barrier and associated sealed insulation were removed from this area (approximately 18 inches high by 7 feet long) in order allow examination of the containment metal liner and concrete floor to liner moisture barrier region. Rust was observed on the carbon steel containment liner plate.
ASME Section Xl, IWE-3510.2 requires that visual examination areas that have suspect degradation be accepted by engineering evaluation or corrected by repair/replacement or by corrective measures. 10 CFR 50.55a(b)(2)(ix)(A) requires:
(A) Metal containment examinations: First provision. For Class MC applications, the following apply to inaccessible areas.
(1) The applicant or licensee must evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas.
(2) For each inaccessible area identified for evaluation, the applicant or licensee must provide the following in the ISI Summary Report as required by IWA-6000:
(i) A description of the type and estimated extent of degradation, and the conditions that led to the degradation (ii) An evaluation of each area, and the result of the evaluation; and (iii) A description of necessary corrective actions This Engineering Evaluation completes required evaluations of the containment liner and associated moisture barrier observed conditions.
Technical Evaluation ECP-15-000715 Page 2 of 8 Detailed Evaluation:
Issue Report 02576330 documents an area of moisture barrier degradation at the reactor building inside containment liner sealed insulation stainless steel facing to the reactor building floor. The removal of the stainless steel sheathing and sealed insulation panels was required in the area of the degraded moisture barrier in order to evaluate the containment liner area that are inaccessible due to installed sealed insulation. Ginna Station License Renewal commitment requires that insulation be removed to expose the metal liner when the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal. Subsequent inspections performed with the sealed insulation removed identified areas of liner corrosion requiring further examination and evaluation.
The function of the liner insulation is to limit the mean temperature rise of the liner post-accident. The liner insulation is covered with astainless steel facing to permit washing down the surface during maintenance periods. The liner insulation and stainless steel facing are held into place through the use of studs that are welded to the containment liner and a neoprene washer, stainless steel washer, and a self-locking stainless steel hex nut.
Ginna Station Containment metal liner is covered by sealed insulation and coated with a layer of zinc-rich paint during construction. The containment metal liner is exposed in some areas and not covered by sealed insulation. These areas include the dome and all penetrations. The Moisture Barrier (caulk) encompass the entire length of the interface between the sealed insulation over the metal liner and the containment basement concrete floor. This configuration makes the metal liner inaccessible. The purpose of this document is to evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or could result in degradation to such inaccessible areas. Figure 1 below shows the Containment Metal Liner Configuration (oth~erwise known as the moisture barrier).
C$ LIER PLTE*
RIGID INSULATION ECTEND $.S. SHEET METAL FACING
~1/8" INTO CAULKING BED ONRTwALL AND FLOOR CAULKING TO BE DOW-CORNING 795 CUKFULL DEPTH DETAIL 1 QC To WITES
'PuCATIoN ORIGINAL DESIGN DETAIL PIECNRT iS IHPIE Figure 1: Containment Metal Liner Configuration Technical Evaluation ECP-15-000715 Page 3 of 8 The entire Ginna Station Moisture Barrier Examinations were performed in 2012 and found acceptable.
The 2012 examinations covered the full length of the containment moisture barrier.
Ginna Station has identified one suspect area (Penetration 29) and examinations were performed in this area every period (every 3 to 4 years) since 2005. This suspect area is located at Penetration 29 and the basement floor to the sealed insulation lower panel at 35 Feet West of Penetration 29 and 30 Feet East of Penetration 29. The caulk and lower panels of sealed insulation are removed and associated VT-3, VT-1 and UT thickness examinations performed. Upon acceptable completion, the sealed insulation was re-installed, the Moisture Barrier re-installed and VT-3 re-examined. The associated examinations were acceptable.
The most recent Moisture Barrier Examinations were performed in 2014 and 2015. The result of the 2015 RFO Moisture Barrier examination was acceptable except for one location. The 2015 RFO examinations covered all moisture barriers except for Penetration 29 area. The 2014 RFO examination was associated with Penetration 29 area and all examinations associated with this area were found acceptable.
In the past, Ginna Station has performed examinations to the Containment Liner before ASME Section Xl Code IWE/IWL was made mandatory by 10CFR5O.55a. These examinations are identified within the Ginna Station License Renewal ProJect "ASME Section XI, Subsection IWE & IWL Inservice Inspection Program, Section 5.10, SRP Element 10 -Operating Experience. They include the following:
During the 1999 Refueling Outage, a one-third of the Moisture Barrier was examined and one area was identified that the caulking design detail did not conform to the "as built" drawing (CR 1999-0516). As a result of this discovery, the inspection scope was increased to include the entire circumference of the Moisture Barrier. The caulking was found to be continuous with no visible gaps or discontinuities. As a result of this non-conformance caulk detail issue, the sealed insulation was removed in two areas (one on the north side and one on the west side). Six to eight feet of the metal liner was exposed and visually examined. On the North end, evidence of minor surface corrosion was visible. UT Thickness readings were taken and ranged from 0.346" to 0.404" on the North side and 0.388" to 0.404" on the West side. The nominal thickness of the Containment Liner is 0.375". The minimum required thickness was determined by engineering analysis and documented in EWR 5190 to be 0.281". The area was recoated and the sealed insulation re-installed. The Moisture Barrier was replaced and baseline examination performed and acceptable.
- During the 2002 Refueling Outage, approximately 70 linear feet of Containment Liner was exposed for visual inspection on the south-east side of Containment. In four (4) different areas, the concrete floor was excavated to a depth of 1 1/2A" below the floor level over a length of 12".
Ultrasonic Thickness measurements were taken in these areas. The minimum thickness reading for these locations were 0.402", 0.412", 0.395" and 0.402". Visual evidence of superficial surface corrosion was present at various areas along the exposed portion of the liner. As a result, the liner was cleaned and restored with new coating of zinc-rich paint. Insulation was restored and the Moisture Barrier installed.
Technical Evaluation ECP-15-O00715 Page 4 of 8
-In response to License Renewal RAI B2.1.3-3(1) in July 2003, the containment liner shall be restored if the liner thickness is at or below 0.300". This new value provides margin with respect to Engineering Analysis EWR 5190 that determined the minimum liner wall thickness to be 0.281". The nominal wall thickness of the containment liner is 0.375".
-During the 2006 Refueling Outage, a twenty (20) foot section of the Metal Liner was exposed in the North-west quadrant of containment for a License Renewal Examination. Visual and UT thickness examinations were performed and acceptable. The lowest thickness reading was 0.382" and above the License Renewal commitment of 0.300" threshold for restoring the liner.
During the 2015 RFO, a containment liner moisture barrier at the 235'-8" elevation was examined per work order C92972823 (from 0 degrees to 120 degrees under SIl Summary Number 1900932), and only one localized area was identified for follow-up inspection in the North-East section of containment. The degraded area, around 50 degrees of North, Six (6) foot in length, was noted with rust stains running out from under the caulking/insulation and onto the floor. In accordance with Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROGPLAN-200090501-00003), Section 5.3 requires insulation removal at any location where the moisture barrier exhibits evidence of degradation due to cracking, separation or loss of seal.
The degraded Moisture Barrier and associated sealed insulation were removed from this area (approximately 18 inches high by 7 feet long) in order to allow examination of the containment metal liner. Rust and pitting was observed on the carbon steel containment liner plate in a band within two to three inches above the concrete basement floor. Light residual dry boric acid was identified. Ultrasonic (UT) thickness measurements of the liner plate show the actual thickness of the 3/8" plate to be 0.405 inches. The mechanical measurement of the depth of the worst case pitting was 1/16 or 0.063 inches, resulting in a measured degraded thickness of 0.342 inches. The minimum allowable thickness, based on License Renewal commitment is 0.300 inches.
Additional insulation panels were removed to identify extent of condition. A total of 500 inches of metal liner was exposed. The two to three inch band area was conditioned, cleaned, boric acid residue removed, visually examined and acceptable. Ultrasonic thickness readings were also performed on the expanded area, the lowest reading obtained was 0.387". This reading is acceptable and above license renewal commitment of 0.300 inches. The area was recoated (painted) and a pre-service visual examination was performed and acceptable. The area was recovered with sealed insulation and the moisture barrier reapplied. A pre-service visual examination was performed on the new moisture barrier and acceptable.
Technical Evaluation ECP-15-000715 Page 5 of 8 it is postulated that the degraded section of Moisture Barrier (caulk) allowed standing floor water to penetrate into the insulation. The insulation became wet by wicking that resulted in a band of corrosion within two to three inches along the floor. The floor water was caused by normal outage and refueling activities such as Reactor Cavity Leakage. As a result of cavity leakage, Penetration 29 area has been identified as a Section Xl Code Suspect Area since 2005 and is located roughly 180 degrees from North (0 degree). This suspect area experience continuous wetting and is located along the basement floor to the sealed insulation and moisture barrier at Penetration 29, 35 Feet West of Penetration 29 and 30 Feet East of Penetration 29. The lower panels of sealed insulation are removed and associated VT-3, VT-i and UT thickness examinations performed. Upon acceptable completion, the sealed insulation and moisture barrier was re-installed, VT-3 re-examined and acceptable. The 2015 RFO area was between 10 to 70 degrees and away from the Penetration 29 suspect area located at 180 degrees.
The following statements are facts:
- 1. The function of the liner insulation is to limit the mean temperature rise of the liner post-accident. The liner insulation is covered with a stainless steel facing to permit washing down the surface during maintenance periods. The liner insulation and stainless steel facing are held into place through the use of studs that are welded to the containment liner and a neoprene washer, stainless steel washer, and a self-locking stainless steel hex nut.
- 2. A license renewal containment liner stainless steel facing inspection was performed at the beginning of the 2015 RFO per work order C92594552 and no unacceptable areas were identified. Also, the dome metal liner was examined under WO C92999194 and found acceptable. All Penetration metal liners were examined under Work Orders C92994282 &
C92972819 and found acceptable.
- 3. The visual inspection of the containment liner Moisture Barrier at the 235'-8" elevation was performed per work order C92972823 (from 0 degrees to 120 degrees under I51 Summary Number 1900932), and only one localized area was identified for follow-up inspection in the North-East section of containment. The area was noted with rust stains running out from under the insulation and onto the floor. The moisture barrier insulation was removed and some rust and pitting identified on the carbon steel containment liner plate in a band within two to three inches above the floor. The moisture barrier (caulk) degraded in a section that allowed containment standing floor water to penetrate the degraded moisture barrier and wet the insulation by a wicking action. UT thickness measurements of the base material show the actual thickness of the 3/8" plate to be 0.405 inches. The mechanical measurement of the depth of the worst case pitting was 1/16 or 0.063 inches, resulting in a measured degraded thickness of 0.342 inches. The minimum allowable thickness, based on License Renewal commitment (RAI B2.1.3-3(1)), is 0.300 inches.
Technical Evaluation ECP-15-O00715 Page 6 of 8
- 4.
Besides the original 7 foot section of sealed insulation panel removed, as an extent of condition, a total of five (5) additional 7 foot sections of sealed insulation panels have been removed for inspection of the adjacent areas in accordance with work order C93225184. The total length of exposed metal liner equates to 500 inches. Based on the VT-3 visual inspections and mechanical measurements, the original area of degradation was the most severe and had the most material loss, therefore bounding all other inspected areas.
- 5.
The liner rusted surface was in a band within two to three inches above the floor. This area was prepped for a VT-i and UT inspection in order to determine remaining wall thickness of the containment liner. Associated visual examinations and thickness readings were acceptable. The liner areas were cleaned, recoated, VT-3 examined and acceptable. The Moisture Barrier was re-installed, examined and acceptable.
- 6.
Currently, one suspect area (Penetration 29) has been identified since 2005 and is located roughly 180 degrees of North. This suspect area is at the basement floor to the sealed insulation at 35 Feet West of Penetration 29, 30 Feet East of Penetration 29 and Penetration 29. The caulk and lower panels of sealed insulation are removed and associated VT-3, VT-i and UT thickness examinations are performed. Upon acceptable completion of examinations, the sealed insulation is re-installed, the Moisture Barrier reinstalled and VT-3 re-examined. This area is on an increased inspection frequency as required by ASME Section Xl Code, 2004 Edition, No Addenda. The increased frequency of examination on this area is every Period. The degraded areas identified during the 2015 RFO are not associated with this area.
- 7.
During the 2015 and 2014 Refueling Outages, the Moisture Barrier was 100% examined. The only unacceptable condition was identified during the 2015 Refueling Outage as identified above. Based on these facts it can be concluded that Moisture Barrier examinations is successful at identifying unacceptable degraded conditions. There is currently no evidence to indicate that other acceptable areas would have equal or greater material loss.
- 8.
The most likely cause for the observed degradation is the exposure to borated water from leakage of the reactor cavity during refueling activities. This degradation mechanism is a long term issue, potentially corroding the liner over the life of the plant only when the Moisture Barrier does not perform its intended function. Refueling activities have been concluded for the 2015 RFO and the cavity has been drained. Based on this, it is not expected that the degradation will propagate. The identified degradation of the metal liner has been stopped by recoating the metal liner and re-caulking of the Moisture Barrier.
Technical Evaluation ECP-15-O00715 Page 7 of 8 Conclusions/Findinl~s:
- 1. The identified degraded containment metal liner surface was cleaned and prepped to accommodate the VT-i and UT examinations. These examinations are acceptable and documented within 15I Summary Reports 1901000 and 1901500.
- 2.
Corrective measures shall be used on the extent of condition. The metal liner was cleaned and re-coated on the exposed 500 inches (North-East section between 10 to 70 degrees) and examined. The 2015 RFO VT-3 baseline examination was performed and acceptable.
- 3.
Engineering recommends a follow-up inspection on the 500 inch restored section of the metal liner identified during the Containment 1SI Examinations performed on the Moisture Barrier during the 2015RF0. This follow-up examination should be scheduled for the Third Period (2017 RFO or 2018 RFO).
- 4.
There are no other areas of degradation worse than the one 500 inch section that was identified during the 2015 RFO. During the 2014 and 2015 timeframe, all Moisture Barriers have been examined and only one area was degraded. The area that was degraded (unacceptable) was corrected during the 2015 RFO.
- 5.
Moisture Barrier Visual Examinations is successful in discovering Metal Liner degraded conditions.
References:
- 1.
ASME Section Xl Code, 2004 Edition, No Addenda.
- 2.
Second Ten-Year Containment Inservice Inspection Plan (January 1, 2010 to December 31, 2019)
[ISIM-2015-0002 15.22.12].
- 3.
UFSAR 18.2.1.3; ASME, Section Xl, Subsections IWE & IWL Inservice Inspection.
- 4.
2015 RFO NDE examinations reports under ISI Summary Numbers 1900932, 1901000 and 1901500
- 5.
Ginna Station License Renewal Aging Management Program Basis Document, "ASME Section Xl, Subsections IWE & IWL Inservice Inspection Program, LR-IWEL-PROGPLAN Rev 4 (PROGPLAN-200090501-00003.
- 6.
Drawing 21489-0700 Rev 2, Examinations and Modifications to the Containment Moisture Barrier.
- 7.
ECP-15-000632, "Evaluate Containment Liner Plate Conditions" (Technical Evaluation).
Technical Evaluation ECP-15-000715 Page 8 of 8 Prepared By:
Date:
Frank A. Klep'acki - 151 Engineer Independent Reviewer:
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E-A'4,/ L)47,ec I't/z//IS" Date:
Mark B. Fitzsimmons - RPE 1/~ /w/~,
Manager Approval:.¶*/*_,Uf, n* sSe-'__*
Date:
t Francis D. Peterson - Engineeri n~JK ger Programs Review:
Bruce Sawyer - Authorizec/Nuclear Inservice Inspector Date: __/_______