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Category:E-Mail
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[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML23187A1122023-07-0606 July 2023 TSC Relocation LAR RAIs ML23171B0522023-06-20020 June 2023 NRR E-mail Capture - RAI for Review of Appendix F to DOM-NAF-2-P (Redacted) ML23068A0242023-03-0808 March 2023 RAI Issuance Fuel Handling Trolley LAR ML23054A2412023-02-23023 February 2023 NRR E-mail Capture - Formal Issuance of RAIs for Surry Turbine Building Tornado Reclassification ML23046A1172023-02-0202 February 2023 002 Radiation Safety Baseline Inspection Information Request ML23018A1642023-01-17017 January 2023 Formal Issuance of RAIs for Surry ISI Alternative for SG Welds, 30 Day Calendar Response Period (Email) ML22349A2102022-12-15015 December 2022 Formal 43-day Request for Additional Information Issuance for Surry Turbine Building License Amendment Request ML22339A1582022-11-30030 November 2022 Requalification Inspection Notification Letter ML22258A2202022-09-13013 September 2022 FFD RFI ML22251A1292022-09-0909 September 2022 Request for Additional Information Related to Response to Generic Letter 2004-04 ML22242A0452022-08-23023 August 2022 NRR E-mail Capture - Dominion GL 04-02 Response Draft RAIs (L-2017-LRC-0000) ML22223A1192022-08-14014 August 2022 RP Inspection Document Request Letter Final ML22110A2052022-04-19019 April 2022 Formal Issuance of RAIs for Post LOCA Buffer Change LAR ML22067A1622022-03-0909 March 2022 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML22012A0572022-01-11011 January 2022 Issuance of RAIs for Surry Unit 1, Spring 2021 Steam Generator Tube Inspection ML21225A5022021-08-13013 August 2021 Request for Additional Information for North Anna Power Station, Units 1 and 2, Surry Power Station, Units 1 and 2, and Millstone Power Station, Units 2 and 3, Appendix E of Fleet Report Com-Naf-2 (EPID:L02021-LLT-0000) Public Version ML21196A1012021-07-15015 July 2021 Notification of an NRC Fire Protection Team Inspection (FPTI) (NRC Inspection Report 05000280/2021011 and 05000281/2021011) and Request for Information (RFI) ML21195A2442021-07-13013 July 2021 NRR E-mail Capture - Draft RAI Appendix E to Topical Report DOM-NAF-2 Qualification of the Framatome BWU-I CHF Correlation in the Dominion Energy VIPRE-D Computer Code ML21102A3122021-04-12012 April 2021 NRR E-mail Capture - Surry, Units 1 & 2 - Final RAI for the LOCA AST LAR ML21076A4622021-03-17017 March 2021 NRR E-mail Capture - Draft RAI for Versatile Internals and Component Program for Reactors Vipre Code Review (L-2021-LLT-0000) ML21061A0292021-03-0101 March 2021 2021 Sur - POV Inspection Information Request ML21049A2662021-02-16016 February 2021 NRR E-mail Capture - Surry, Units 1 and 2 - Final RAI Concerning the Leak-Before-Break (LBB) LAR ML21049A2672021-02-11011 February 2021 NRR E-mail Capture - Surry, Units 1 & 2 - Draft RAI for the LBB LAR ML21020A1322021-01-19019 January 2021 NRR E-mail Capture - RAIs for Surry'S Request for Proposed Alternative S1-I5-ISl-05 and S2-I5-ISl-06 (ML20296A680) ML21020A1332021-01-13013 January 2021 NRR E-mail Capture - Draft RAIs for Surry'S Request for Proposed Alternative S1-I5-ISl-05 and S2-I5-ISl-06 (ML20296A680) ML20315A3972020-11-10010 November 2020 Notification of NRC Supplemental Inspection (95001) and Request for Information - RA ML20156A0652020-06-0404 June 2020 NRR E-mail Capture - Final RAIs for Surry U1 Fall 2019 Sgtir Application ML20136A0102020-05-14014 May 2020 NRR E-mail Capture - Final RAIs Regarding Surry Units 1 & 2 LAR to Adopt 10 CFR 50.69 ML20134J1382020-05-0606 May 2020 Notification of Inspection and Request for Information for NRC Problem Identification and Resolution Inspection ML20106E9552020-04-15015 April 2020 Program Inspection RFI ML20029D8382020-02-0505 February 2020 Email from T. 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From: Wu, Angela To: Paul Aitken; Tony Banks; Eric A Blocher
Subject:
Surry SLRA - Draft 3rd Round RAI - Selective Leaching (TRP 33)
Date: Thursday, September 19, 2019 2:34:00 PM Attachments: 033 - Selective Leaching 2nd RAI- Gardner WCH comments.docx Hello Tony, Please see attached the draft 3rd round RAI for TRP 33 - Selective Leaching for next Tuesdays clarification call.
Thanks!
Angela Angela Wu, Project Manager NRR/DMLR/MRPB Office: OWFN 11-G3 l Phone: 301-415-2995
SURRY TRP 033 Selective Leaching RAI - Gardner Regulatory Basis 10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.
RAI B2.1.21-1a
Background:
GALL-SLR Report AMP XI.M33, Selective Leaching, recommends that the external surfaces of buried components may be excluded for the scope of the program if they are externally coated in accordance with Table XI.M41-1, Preventive Actions for Buried and Underground Piping and Tanks, of GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks, and where direct visual examinations of buried piping in the scope of license renewal have not revealed any coating damage.
SLRA Section B2.1.21, Selective Leaching, states that external surfaces of buried components that are coated consistent with GALL-SLR Report AMP XI.M41, Buried and Underground Piping and Tanks, may be excluded from the sample population.
During its audit (ADAMS Accession No. ML19128A079), the staff made the following observations related to external corrosion and coating degradation of buried piping:
- The staff reviewed Condition Report (CR) 006624 and noted that buried auxiliary feedwater piping was found to be leaking in 2004 and that the cause of the degradation was lack of a protective wrap on the affected line.
- The staff reviewed CR 105973 and noted that during inspection of buried piping, several pipelines associated with the containment spray and chemical volume and control systems indicated coating failure where the felt wrap had separated from the coal tar coating.
- The staff reviewed CR 386494 and noted that during an excavation to support guided wave examinations, areas of pitting were identified on the exterior surfaces of the pipe.
The lowest remaining wall thickness was 0.122 inches compared to a nominal pipe thickness of 0.245 inches.
- The staff reviewed CR 441171 and noted that a 1 inch diameter through wall hole was identified on a buried fire protection line. It is unclear to the staff if this through wall hole was due to internal or external corrosion.
- The staff reviewed CR 497540 and noted that two pin hole leaks were identified on a buried condensate line. It is unclear to the staff if the pin hole leaks were due to internal or external corrosion.
- The staff reviewed CR 1068384 and noted that a few areas of missing coating were found on buried stainless steel containment spray piping.
SURRY TRP 033 Selective Leaching RAI - Gardner
- The staff reviewed CA 126782 and noted that operating experience documents corrosion damage and failures resulting from damaged or poorly applied coatings.
- The staff reviewed ETE-SU-2014-0080 and noted that (a) for buried stainless steel piping, there have been sporadic cases where poor coating adhesion or existing coating damage was identified and cases where certain systems were essentially uncoated; and (b) for buried steel piping, there have been sporadic cases where poor coating adhesion or existing coating damage has been identified.
The staff also noted that in October 2008, degraded coatings were detected on a 10-inch fire protection line. Although intact coatings were on exposed portions of the piping, other areas with backfill material imbedded in the coating were easily removed by hand tools.
Issue:
Given the adverse plant-specific operating experience regarding degraded coatings, the basis provided for excluding the gray cast iron piping and components in the FP system from the scope of the Selective Leaching program is not adequate. Given the degradation of the coatings, graphitic corrosion could occur on the external surfaces of the FP piping. The staff recognizes that plug like loss of material would not necessarily be safety significant because it could be identified by leakage detectable with jockey pump monitoring. However, graphitic corrosion can also proceed in a layer like mechanism. This mechanism could result in structural collapse of the piping with resulting loss of intended function of the system.
Based on a review of Protecting a Pipeline When Its Coating Has Aged, the expected life of coal tar enamel or asphalt enamel coatings for buried pipelines is 20 to 30 years. The staff notes that the bituminous coatings used on the external surfaces of buried fire water system piping are similar to coal tar/asphalt enamel coatings. The staff recognizes that there will be variability in the actual rate of degradation of these coatings; however, over an 80-year period, it would be expected that some degree of loss of coating integrity will occur.
Request:
Given the plant-specific operating experience to date and the potential for further coating degradation, state the basis for excluding managing loss of material due to selective leaching for the buried FP piping.
Reference.
Protecting a Pipeline When Its Coating Has Aged. Materials Performance Magazine. Larsen, Kathy Riggs. January 2017 Edition, page 24.