SBK-L-16207, 1 - Clarification of Supplement 50 - Changes to Buried and Underground Piping and Tank Recommendations

1 - Clarification of Supplement 50 - Changes to Buried and Underground Piping and Tank Recommendations

ML17006A399
Person / Time
Site:	Seabrook
Issue date:	01/03/2017
From:	Mccartney E NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-16207
Download: ML17006A399 (6)

Text

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station NEXTera ENERGY~

SEABROOK January 3, 2017 10 CFR 54 SBK-L-16207 Docket No. 50-443 Supplement 51 - Clarification of Supplement 50 - Changes to Buried and Underground Piping and Tank Recommendations

References:

1. NextEra Energy Seabrook LLC, letter SBK-L-10077, "Seabrook Station Application for Renewed Operating License," May 25, 2010 (Accession Number ML101590099).

2. License Renewal Interim Staff Guidance, LR-ISG-2015-01 "Changes to Buried and Underground Piping and Tank Recommendations."

3. NextEra Energy Seabrook, LLC letter SBK-L-16156, "Response to Issuance of LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations,"

October 07, 2016 (Accession Number ML16286A631).

4. NRC, "Requests for Additional Information for the Review of the Seabrook Station License Renewal Application (CAC NO. ME4028)," November 14, 2016 (Accession Number ML16301A428).

5. NextEra Energy Seabrook, LLC letter SBK-L-16186, "Supplement 50 - Response to Requests for Additional Information for the Review of the Seabrook Station License Renewal Application (CAC NO. ME4028) - Changes to Buried and Underground Piping and Tank Recommendations," November 23, 2016 (Accession Number ML16333A407).

In Reference 1, NextEra Energy Seabrook, LLC (NextEra Energy Seabrook) submitted an application for a renewed facility operating license for Seabrook Station Unit 1 in accordance with the Code of Federal Regulations, Title 10, Parts 50, 51, and 54.

In Reference 2, the NRC issued License Renewal Interim Staff Guidance, LR-ISG-2015 Changes to Buried and Underground Piping and Tank Recommendations. The guidance NextEra Energy Seabrook, LLC PO Box 300, Seabrook, NH 03874

U.S. Nuclear Regulatory Commission SBK-L-16207 I Page 2 provided within this ISG was utilized to develop NextEra Energy Seabrook's Buried Piping and Tanks Inspection Aging Management Program.

In Reference 3, NextEra Energy Seabrook provided the Staff with letter SBK:-L-16156, "Response to Issuance of LR-ISG-2015-01, Changes to Buried and Underground Piping and Tank Recommendations."

In Reference 4, the NRC requested additional information related to the Buried and Underground Piping and Tank Aging Management Program submittal (Reference 3).

In Reference 5, NextEra Energy Seabrook provided the Staff with letter SBK-16186, "Supplement 50 - Response to Requests for Additional Information for the Review of the Seabrook Station License Renewal Application (CAC_NO. ME4028) - Changes to Buried and Underground Piping and Tank Recommendations."

• On December 6, 2016, the NRC staff and Seabrook Station License Renewal team conducted a conference call to clarify portions of the previous request for additional information response (Reference 5) from Seabrook Station.

The Enclosure includes changes to the LRA. To facilitate understanding, the changes are explained, and where appropriate, portions of the LRA are repeated with the change highlighted by strikethroughs for deleted text and balded italics for inserted text.

There are no new or revised regulatory commitments contained in this letter.

~-..

If there are any questions or additional information is needed, please contact Mr. Edward J.

Carley, Engineering Supervisor - License Renewal, at (603) 773-7957.

If you have any questions regarding this correspondence, please contact Mr. Kenneth Browne, Licensing Manager, at (603) 773-7932.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on January 3, 2017.

Sincerely, NextEra Energy Seabrook, LLC r~w~r ric McCartney-Site Vice President

U.S. Nuclear Regulatory Commission SBK-L-16207 I Page 3

Enclosure:

Supplement 51 - Clarification of Supplement 50 - Changes to Buried and Underground Piping and Tank Recommendations.

cc:

D. H. Dorman J.C. Poole P. C. Cataldo T. M. Tran L. M. James Mr. Perry Plummer NRC Region I Administrator NRC Project Manager NRC Senior Resident Inspector NRC Project Manager, License Renewal NRC Project Manager, License Renewal Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 perry.plummer@dos.nh.gov Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 John. Giarrusso@massmail.state. ma. us

Enclosure to SBK-L-16207 Supplement 51 - Clarification of Supplement 50 -

Changes to Buried and Underground Piping and Tank Recommendations.

U.S. Nuclear Regulatory Commission

.SBK-L-16207 /Enclosure/Page 2 On 12/06/2016, the NRC staff and NextEra Energy Seabrook license renewal team members conducted a discussion of components that are copper alloy > 15% zinc, and the dependence of cathodic protection and inspection frequency on these components that are within scope of the Buried Piping and Tanks Inspection Aging Management Program. The following changes within the LRA, section B.2.1.22, are shown below. Table 2 has been formatted to ensure clear understanding between buried, underground, and inaccessible submerged piping inspections.

2nd Paragraph of ELEMENT 4 - Detection of Aging Effects Pipe to soil potential and the cathodic protection current are monitored for steel piping in contact with soil to determine the effectiveness of cathodic protection systems and, thereby, the effectiveness of corrosion mitigation. There is no cathodic protection for in scope copper alloy (>15% zinc) material as there are only in scope components, not piping. TM A single drain valves on the spools in within the Service Water vault and valve pit ara is constructed of aluminum bronze (categorized as "copper alloy >15%

zinc") with aluminum bronze body to bonnet bolting.

These components will be inspected for loss of material and any leakage caused by loss of pre-load with the body to bonnet bolting when the associated pipe segment is inspected by this program as shown in Table 2.

Directed Inspections - Inaccessible Submerged Pipe The number of inspections required during each 1 O year interval -is are shown in tRe Tables 2 below. With the exception of backfill and soil resistivity criteria, inaccessible submerged piping will be inspected to the same extent as buried piping. The aluminum bronze drain valves attached to these steel SW piping segments will also be inspected for loss of material, and any leakage caused by loss of pre-load with the body to bonnet bolting when the associated pipe segment is inspected.

Table 2 - Inspections of Buried, Underground, Piping and Inaccessible Submerged Piping Buried Pioina lnsoections Prevention Preventive Inspections 1*2 Systems Currently in Material Action Categories Category Stainless Steel 1 Inspection CO, DG Backfill is in accordance with preventive actions program 1 Inspection Polymeric element 3 FP5 Backfill is not in accordance The smaller of 1 %

with preventive actions of the length of pipe program category 3 or 2 inspections The smaller of c

0.5% of the piping CBA, IA, FP 5

, SW 6, AB 4, Steel length or 1 CO, DF, DG, FW, inspection ASC,ASH D

N/A

U.S. Nuclear Regulatory Commission

.SBK-L-16207 /Enclosure/Page 3 The smaller of 5%

E of the piping length or 3 inspections The smaller of 10%

F of the piping length or 6 inspections

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ef the i;iii;iiRQ leRQth er i iRsi;iectieRs Underaround Pioina lnsoections Material Inspections Steel The smaller of 2% of the piping length or 2 inspections SW-+

Systems Currently in Category ASC,ASH Inaccessible Submeraed Pi1Jina Inspections Steel The smaller of 2% of the piping length or 2 SW 6

inspections Copper Alloy 2 inspections sw 1

>15% Zinc GENERAL NOTES:

I.

When the inspections are based on the number of inspections in lieu of percentage of piping length, 10 feet of piping is exposed for each inspection.

2.

When the percentage of inspections for a given material type results in an inspection quantity of less than 10 feet, then 10 feet of piping is inspected. If the entire run of piping of that material type is less than 10 feet in total length, then the entire run of piping is inspected.

3.

The adequacy of backfill will be determined by the condition of coatings and base materials noted during inspections. If damage to the coatings or base materials is determined to have been caused by the backfill, the backfill will be considered to be "inadequate" (for the purpose of this program).

4.

This line is not in use. It has been drained and flushed and is awaiting replacement. The inspection criteria for the replacement piping will be determined based material selection, coating, cathodic protection, and quality of backfill.

5.

If Fire Protection piping is inspected by excavation in lieu of by alternative testing (e.g., flow test, jockey pump monitoring), and the extent of examinations is not based on the percentage of piping in the material group, the Not-to-Exceed (NTE) value will be increased by 1 inspection, ifnormally less than 10, or 2 inspections, if normally 10 or greater.

6.

The Service Water vault located north of the cooling tower contains four 24" lines approximately 15' long. The valve pit located north of the cooling tower contains one 32" line less than 10' long.

7.

Tlte drain valves on the spools in wit/tin the Service Water Yault and valve pit are is constructed of aluminum bronze (categorized as "copper alloy> 15% zinc") with aluminum bronze body to bonnet bolting. These components will be inspected for loss of material when the respective Service Water spool piping is inspected by this program. There is no copper alloy> 15% zinc piping within scope of this program.