ML20114E275

(ANO) Carbon Fiber Reinforced Polymer (Cfrp) Relief Request Pre-Submittal Meeting with NRC - April 29, 2020

ML20114E275
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/29/2020
From:	Entergy Operations
To:	Office of Nuclear Reactor Regulation
Wengert T
References
Download: ML20114E275 (15)

Text

Arkansas Nuclear One (ANO)

Carbon Fiber Reinforced Polymer (CFRP)

Relief Request PreSubmittal Meeting with NRC April 29, 2020 1

Agenda Topic Speaker Introductions NRC/ENTERGY/PUBLIC Licensee Presentation Reason for Relief Request Overview of CFRP Technology Affected Service Water Piping ENTERGY ANOSurrySTP Comparison Proposed Submittal Schedule Relief Request Content Precedent NRC Discussion NRC Opportunity for Public Comment PUBLIC Meeting Adjournment NRC 2

Introductions

• Licensee Attendees

- ENTERGY/Arkansas Nuclear One (ANO) - Licensee

• Riley Keele, David Bice (Regulatory Assurance)

• Terry Freeman, Vince Bond, Bob Thweatt, Dan Sojka, Mike Hedgecock, Ryan Brumwell, Joel Cummins, Rocky Jones, James Reece (Projects)

• Bryan Daiber, Tom Hatfield, Grant Flynn (Engineering)

• Scott Thessing (Operations)

- Structural Technologies, LLC - CFRP Composite System

• Anna Pridmore, Emily Cernic, Leo Nadeau, Chris Burton

- Simpson Gumpertz & Heger (SGH) - CFRP Designer

• Rasko Ojdrovic 3

Reason for the Relief Request

• Piping systems constructed of similar materials and transporting similar water have experienced degradation due to Microbiologically Influenced Corrosion (MIC).

• ASME B&PVC Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, Article IWA-4000, subparagraph IWA-4221(b)(1) states:

An item to be used for repair/replacement activitiesshall meet the Construction Code to which the original item was constructed.

• ANO is submitting a relief request in accordance with 10 CFR 50.55a(z)(1) requesting approval to proactively use a CFRP Composite System because CFRP was not a material available for use in the original construction codes.

4

Overview of CFRP Technology

• CFRP Composite Repair System Carbon Fiber Fabric o Carbon fiber fabric layers for strength and glass fiber layers for watertightness and dielectric barrier.

Glass Fiber Fabric o Fabrics are saturated with a twopart epoxy and manually applied to the pipe wall o Once cured, the CFRP lining takes the place of the host pipe for resisting all loads

• Quality Assurance/Quality Control 96 inch o 3rd Party inspection piping o Owner and Design Reps oversight

• CFRP Operational Experience o Multiple safety and nonsafety related CFRP piping repair projects successfully completed on numerous large pipeline diameters 5

Affected Service Water Piping

• Emergency Cooling Pond supply piping to each units Service Water system

• ANO1 36 diameter, ANO2 42 diameter

• Approximately 4,800 linear feet total

• Both ANO pipes are carbon steel and installed in soil

• ANO is considering two options for use of CFRP (dependent on installation time required and cost):

1) install CFRP on entire pipe length and, 2) install new pipe on an alternate route while installing CFRP from the tiein locations to the Intake Structures.

In all cases, the CFRP will terminate on sound ASME Section III piping. 6

ANOSurrySTP Comparison

• Similarities between Entergy ANO, Surry, and South Texas Project (STP)

- All subject piping is installed below grade

- All three applications propose use of the same CFRP materials, design engineer, installation team, and Quality Assurance / Quality Control team

• Differences between Entergy ANO, Surry, and STP

- Surry piping is carbon steel pipe encased in reinforced concrete

- STP piping is AluminumBronze

- Entergy ANO piping is carbon steel 7

ANOSurrySTP Comparison

• In addition to pressure and other loads considered at Surry, the ANO analysis will consider external soil, surface live load, surcharge loads, and seismic loads that were not considered for Surry because of reinforced concrete encasement surrounding the pipe

• Similar to STP, ANO analysis will consider:

- Stress due to bending of the buried pipe due to gravity loads, e.g., soil and live loads

- Stress due to combined internal pressure and gravity loads

- Buckling resistance of flexible pipe buried in soil

- Longitudinal stress due to seismic, hydraulic and thermal loads for a pipeline buried in soil 8

Proposed Relief Request Schedule

• Estimated Submittal to NRC: July 2020

• Estimated Requested NRC Approval Date: August 2021

• Construction Timeframe: Construction is estimated to begin as early as 2022.

9

Relief Request Content

• Summary - Relief Request

• Scope and Schedule

• Definitions and Acronyms

• Materials

• Design

• Installation Methods

• Training

• Failure Modes and Effects Analysis

• Operating Experience

• Proprietary Affidavits 10

Precedents Surry Unit 1 & 2 11

Precedents Surry Units 1 & 2 12

Precedents Surry Units 1 & 2 13

Precedents Surry Units 1 & 2 14

NRC Discussion 15