ML20198M382
| ML20198M382 | |
| Person / Time | |
|---|---|
| Issue date: | 07/27/2020 |
| From: | David Drucker Office of Nuclear Reactor Regulation |
| To: | |
| Drucker D | |
| References | |
| Download: ML20198M382 (16) | |
Text
ML20198M382 CAC: TM3021 OFFICE PM:DNLR:NLRP PM:DNRL:NLRP PM:DRO:IRSB BC:DNLR:NLRP NAME WBurton DDrucker TGovan OTabatabai DATE 07/22/2020 07/22/2020 07/23/2020 07/23/2020 OFFICE OGC - NLO D:DNRL NAME STurk RCaldwell for ABradford DATE 07/23/2020 07/24/2020 APPENDIX H ERRATA Proposed Revisions to AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Additions to Summary of Proposed Revisions This ISG revises AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks, to recommend opportunistic inspections, in lieu of periodic inspections, as an acceptable alternative for buried internally coated/lined fire water system piping provided: (a) flow tests and internal piping inspections will occur at intervals specified in NFPA 25, Standard for the Inspection, Testing, and Maintenance of Water Based Fire Protection Systems, or as modified by AMP XI.M27, Fire Water System, Table XI.M27-1, Fire Water System Inspection and Testing Recommendations; (b) through-wall flaws in the piping can be detected through continuous system pressure monitoring; and (c) plant-specific operating experience (OE) is acceptable (i.e., no leaks due to the age related degradation of representative internal coatings/linings used in buried in scope fire water system components).
This ISG also revises AMP XI.M42 environments as follows: (a) adds air and condensation environments to the scope of the program; (b) adds soil, concrete, and underground external environments to the FSAR Supplement; and (c) corrects inconsistencies for the lubricating oil environment. In addition, this ISG includes new GALL-SLR Report AMR items for managing loss of coating/lining integrity and loss of material in piping, piping components, heat exchangers, and tanks with internal coatings/linings exposed to air-dry using AMP XI.M42.
Further, this ISG revises SRP-SLR Table 3.3-1 and GALL-SLR Report Volume 1,Section VII tables to include AMR items for managing recurring internal corrosion of metallic components exposed to raw water that are not covered by Generic Letter (GL) 89-13, using the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program. Additionally, this ISG corrects other associated AMR items by including the a, b, or c designation after the AMR item number to distinguish between the various AMPs that are acceptable for managing the cited aging effect, and deletes closed-cycle cooling water from environments listed in the associated AMR item 3.3-1-127.
Additions to Basis for Revisions The staff has accepted opportunistic inspections, in lieu of periodic inspections, as an acceptable alternative for buried internally coated/lined fire water system piping provided:
(a) flow tests and internal piping inspections will occur at intervals specified in NFPA 25, or as modified by AMP XI.M27, Table XI.M27-1; and (b) through-wall flaws in the piping can be detected through continuous system pressure monitoring. Examples of the staffs acceptance of this alternative approach are documented in the Safety Evaluation Report Related to the License Renewal of Fermi 2 Nuclear Power Plant (ADAMS Accession No. ML16190A241) and the Safety Evaluation Report Related to the Subsequent License Renewal of Peach Bottom Atomic Power Station, Units 2 and 3 (ADAMS Accession No. ML20044D902). Based on recent OE involving ruptures of buried fire water system piping due to age-related degradation (ADAMS Accession No. ML19294A044), the staff added a third condition for using this alternative approach related to plant specific operating experience. The staff notes that the subject OE involved degradation of the external surfaces of the piping; however, degradation of
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata Page 2 of 15 internal coatings/linings could also result in significant degradation of buried fire water system piping.
The reason for citing specific AMPs to manage recurring internal corrosion rather than a plant-specific AMP is discussed in GALL-SLR Report section, Explanation of the Use of Multiple Aging Management Programs in Aging Management Review Items. For the associated AMR item in the SRP-SLR (item 3.3-1, 127), the listed environments still include closed-cycle cooling water even though NUREG-2221, Table 2-13, notes that the associated item in Table C2, Closed-Cycle Cooling Water System, was deleted because recurring internal corrosion is not anticipated in this system. This oversight is being corrected in conjunction with the adjustments above for use of multiple AMPs.
Changes to Proposed AMP Revisions Program Description Proper maintenance of internal coatings/linings is essential to provide reasonable assurance that the intended functions of in-scope components are met. Degradation of coatings/linings can lead to loss of material or cracking of base materials and downstream effects such as reduction in flow, reduction in pressure, or reduction of heat transfer when coatings/linings become debris. The program consists of periodic visual inspections of internal coatings/linings exposed to closed-cycle cooling water (CCCW), raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil, air, and condensation. Where the visual inspection of the coated/lined surfaces determines that the coating/lining is deficient or degraded, physical tests are performed, where physically possible, in conjunction with the visual inspection.
Electric Power Research Institute (EPRI) Report 1019157, Guideline on Nuclear Safety-Related Coatings, provides information on the American Society for Testing and Materials (ASTM) standard guidelines and coatings. American Concrete Institute (ACI) Standard 201.1R, Guide for Conducting a Visual Inspection of Concrete in Service, provides guidelines for inspecting concrete. In addition, this program may be used to manage aging effects associated with coatings on external surfaces.
Evaluation and Technical Basis
- 1. Scope of Program: The scope of the program is internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks exposed to CCCW, raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil, air, and condensation where loss of coating or lining integrity could prevent satisfactory accomplishment of any of the components or downstream components current licensing basis (CLB) intended functions identified under Title 10 of the Code of Federal Regulations (10 CFR) 54.4(a)(1), (a)(2), or (a)(3). The aging effects associated with fire water tank internal coatings/linings are managed by Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report aging management program (AMP) XI.M27, Fire Water System, instead of this AMP. However, where the fire water storage tank internals are coated, the Fire Water System Program and Final Safety Analysis Report (FSAR) Summary Description of the Program should be enhanced to include the recommendations associated with training and qualification of personnel and the corrective actions program element. The Fire Water System Program should also be enhanced to include the recommendations from the acceptance criteria program element.
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata Page 3 of 15 If a coating/lining has a qualified life, and it will be replaced prior to the end of its qualified life without consideration of extending the life through condition monitoring, it would not be considered long lived and therefore, it would not be within the scope of this AMP.
Coatings/linings are an integral part of an in-scope component. The CLB-intended function(s) of the component dictates whether the component has an intended function(s) that meets the scoping criteria of 10 CFR 54.4(a). Internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks are not evaluated as standalone components to determine whether they meet the scoping criteria of 10 CFR 54.4(a). It is immaterial whether the coating/lining has an intended function identified in the CLB because it is the CLB-intended function of the component that dictates whether the component is in-scope and thereby the aging effects of the coating/lining integral to the component must be evaluated for potential impact on the components and downstream components intended function(s).
An applicant may elect to manage the aging effects for internal coatings/linings for in-scope piping, piping components, heat exchangers, and tanks in an alternative AMP that is specific to the component or system in which the coatings/linings are installed (e.g.,
GALL-SLR Report AMP XI.M20, Open-Cycle Cooling Water System, for service water coatings/linings) as long as the following are met:
- The recommendations of this AMP are incorporated into the alternative program.
- Exceptions or enhancements associated with the recommendations in this AMP are included in the alternative AMP
- The FSAR supplement for this AMP as shown in the GALL-SLR Report Table XI-01, FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs, is included in the application with a reference to the alternative AMP.
For components where the aging effects of internally coated/lined surfaces are managed by this program, loss of material, cracking, and loss of material due to selective leaching need not be managed for these components by another program.
This program may be used to manage aging effects associated with external surfaces
[e.g., Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR) Section 3.2.2.2.2]. When the external coatings are credited to isolate the external surface of a component from the environment, the following recommendations are met as noted.
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata Page 4 of 15 Changes to Proposed Revisions to FSAR Supplement None Table XI-01. FSAR Supplement Summaries for GALL-SLR Report Chapter XI Aging Management Programs GALL-SLR Implementation AMP Program Description of Program Schedule*
This program is a condition monitoring program that manages degradation of internal coatings/linings exposed to closed-cycle cooling water, raw water, treated water, treated borated water, waste water, lubricating oil or fuel oil, air, or condensation that can lead to loss of material of base materials or downstream effects such as reduction in flow, reduction in pressure or reduction of heat transfer when Program is coatings/linings become debris. This program can also be implemented and used to manage loss of coating integrity for external coatings inspections begin exposed to any air environment or condensation, soil, 10 years before concrete, or underground environment, that are credited with the subsequent isolating the external surface of a component from the period of environmentthese environments (e.g., as discussed in extended SRP-SLR Section 3.2.2.2.2).
operation.
This program manages these aging effects for internal Inspections that coatings by conducting periodic visual inspections of all are to be Internal coatings/linings applied to the internal surfaces of in-scope completed prior to Coatings/ components where loss of coating or lining integrity could the subsequent Linings for In- impact the components or downstream components current period of Scope Piping, licensing basis intended function(s). Visual inspections are extended XI.M42 Piping conducted on external surfaces when applicable.
operation are Components, completed Heat For tanks and heat exchangers, all accessible surfaces are Exchangers, inspected. Piping inspections are sampling-based. The 6 months prior to and Tanks training and qualification of individuals involved in the subsequent coating/lining inspections of non-cementitious coatings/linings period of are conducted in accordance with ASTM International extended Standards endorsed in RG 1.54 including guidance from the operation or no staff associated with a particular standard. For cementitious later than the last coatings, training and qualifications are based on an refueling outage appropriate combination of education and experience related prior to the to inspecting concrete surfaces. Peeling and delamination is subsequent not acceptable. Blisters are evaluated by a coatings period of specialist with the blisters being surrounded by sound extended material and with the size and frequency not increasing.
operation.
Minor cracks in cementitious coatings are acceptable provided there is no evidence of debonding. All other degraded conditions are evaluated by a coatings specialist.
For coated/lined surfaces determined to not meet the acceptance criteria, physical testing is performed where physically possible (i.e., sufficient room to conduct testing) in conjunction with repair or replacement of the coating/lining.
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata Changes to Proposed Revisions to AMR Items None Proposed Revisions to GALL-SLR Report Tables V.A, V.B, V.D1, V.D2, VII.C1, VII.C3, VII.D, VII.E5, and VII.G The following tables provide proposed changes to AMR items related to this ISG, with redline formatting indicating changes from the GALL-SLR Report or SRP-SLR.
V ENGINEERED SAFETY FEATURES Table A Containment Spray System (PWR)
New, Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M V.A.E-401 3.2-1, 072 Piping, piping Any material Treated Loss of coating or AMP XI.M42, No components, with an borated water, lining integrity due to "Internal heat internal lubricating oil blistering, cracking, Coatings/Linings for exchangers, coating/lining flaking, peeling, In-Scope Piping, tanks with delamination, rusting, Piping Components, internal physical damage; loss Heat Exchangers, coatings/linings of material or cracking and Tanks" for cementitious coatings/linings Page 5 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata V ENGINEERED SAFETY FEATURES Table B Standby Gas Treatment System (BWR)
New,
- Modified, Deleted, Structure Aging Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M V.B.E-401 3.2-1, 072 Piping, piping Any material Treated water, Loss of coating or AMP XI.M42, No components, with an raw water, lining integrity due to "Internal heat internal lubricating oil blistering, cracking, Coatings/Linings for exchangers, coating/lining flaking, peeling, In-Scope Piping, tanks with delamination, Piping Components, internal rusting, physical Heat Exchangers, coatings/linings damage; loss of and Tanks" material or cracking for cementitious coatings/linings Page 6 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata V ENGINEERED SAFETY FEATURES Table D1 Emergency Core Cooling System (PWR)
New,
- Modified, Deleted, Structure Edited SRP Item and/or Aging Aging Management Further Item Item (Table, ID) Component Material Environment Effect/Mechanism Program (AMP)/TLAA Evaluation M V.D1.E-401 3.2-1, 072 Piping, piping Any material Treated Loss of coating or AMP XI.M42, "Internal No components, with an borated water, lining integrity due to Coatings/Linings for In-heat internal lubricating oil, blistering, cracking, Scope Piping, Piping exchangers, coating/lining condensation flaking, peeling, Components, Heat tanks with delamination, rusting, Exchangers, and internal physical damage; loss Tanks" coatings/linings of material or cracking for cementitious coatings/linings M V.D1.E-414 3.2-1, 073 Piping, piping Any material Treated Loss of material due AMP XI.M42, "Internal No components, with an borated water, to general, pitting, Coatings/Linings for In-heat internal lubricating oil, crevice corrosion, Scope Piping, Piping exchangers, coating/lining condensation MIC Components, Heat tanks with Exchangers, and internal Tanks" coatings/linings Page 7 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata V ENGINEERED SAFETY FEATURES Table D2 Emergency Core Cooling System (BWR)
New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M V.D2.E-401 3.2-1, 072 Piping, piping Any material Treated water, Loss of coating or AMP XI.M42, No components, with an lubricating oil, lining integrity due to "Internal heat internal condensation blistering, cracking, Coatings/Linings exchangers, coating/lining flaking, peeling, for In-Scope tanks with delamination, rusting, Piping, Piping internal physical damage; Components, coatings/linings loss of material or Heat Exchangers, cracking for and Tanks" cementitious coatings/linings M V.D2.E-414 3.2-1, 073 Piping, piping Any material Treated water, Loss of material due AMP XI.M42, No components, with an lubricating oil, to general, pitting, "Internal heat internal condensation crevice corrosion, Coatings/Linings exchangers, coating/lining MIC for In-Scope tanks with Piping, Piping internal Components, coatings/linings Heat Exchangers, and Tanks" Page 8 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata VII AUXILIARY SYSTEMS Table C1 Open-Cycle Cooling Water System (Service Water System)
New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.C1.A-400a 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M20, Yes components, to recurring internal "Open-Cycle tanks corrosion Cooling Water System" N VII.C1.A-400b 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M38, Yes components, to recurring internal Inspection of tanks (for corrosion Internal Surfaces components not in Miscellaneous covered by NRC Piping and GL 89-13) Ducting Components Page 9 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata VII AUXILIARY SYSTEMS Table C3 Ultimate Heat Sink New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.C3.A-400a 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M20, Yes components, to recurring internal "Open-Cycle tanks corrosion Cooling Water System" N VII.C3.A-400b 3.3-1, 127 Piping, piping Metallic Raw water Loss of material due AMP XI.M38, Yes components, to recurring internal Inspection of tanks (for corrosion Internal Surfaces components not in Miscellaneous covered by NRC Piping and GL 89-13) Ducting Components Page 10 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata VII AUXILIARY SYSTEMS Table D Compressed Air System New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation DN VII.D.A-414 3.3-1, 139 Piping, piping Any material Air-dry, air, Loss of material due AMP XI.M42, No components, with an condensation to general, pitting, "Internal heat internal crevice corrosion, Coatings/Linings exchangers, coating/lining MIC for In-Scope tanks with Piping, Piping internal Components, coatings/linings Heat Exchangers, and Tanks" DN VII.D.A-416 3.3-1, 138 Piping, piping Any material Air-dry, air, Loss of coating or AMP XI.M42, No components, with an condensation lining integrity due to "Internal heat internal blistering, cracking, Coatings/Linings exchangers, coating/lining flaking, peeling, for In-Scope tanks with delamination, Piping, Piping internal rusting, physical Components, coatings/linings damage; loss of Heat Exchangers, material or cracking and Tanks" for cementitious coatings/linings Page 11 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata VII AUXILIARY SYSTEMS Table E5 Waste Water Systems New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.E5.A-400b 3.3-1, 127 Piping, piping Metallic Waste water Loss of material due AMP XI.M38, Yes components, to recurring internal "Inspection of tanks corrosion Internal Surfaces in Miscellaneous Piping and Ducting Components" Page 12 of 15
SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata VII AUXILIARY SYSTEMS Table G Fire Protection New, Modified, Aging Deleted, Structure Management Edited SRP Item and/or Aging Program Further Item Item (Table, ID) Component Material Environment Effect/Mechanism (AMP)/TLAA Evaluation M VII.G.A-400c 3.3-1, 127 Piping, piping Metallic Raw water, Loss of material due AMP XI.M27, "Fire Yes components, raw water to recurring internal Water System" tanks (potable), corrosion treated water Page 13 of 15
Proposed Revisions to SRP-SLR Tables 3.2-1 and 3.3-1 SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata Table 3.2-1 Summary of Aging Management Programs for Engineered Safety Features Evaluated in Chapter V of the GALL-SLR Report New, Modified, Aging Management Deleted, Program Further Evaluation GALL-SLR Edited Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended Item M 072 BWR/PWR Any material piping, Loss of coating or lining AMP XI.M42, No V.A.E-401 piping components, integrity due to blistering, "Internal V.B.E-401 heat exchangers, cracking, flaking, peeling, Coatings/Linings for V.C.E-401 tanks with internal delamination, rusting, or In-Scope Piping, V.D1.E-401 coatings/linings physical damage; loss of Piping Components, V.D2.E-401 exposed to closed- material or cracking for Heat Exchangers, cycle cooling water, cementitious and Tanks" raw water, treated coatings/linings water, treated borated water, lubricating oil, condensation M 073 BWR/PWR Any material piping, Loss of material due to AMP XI.M42, No V.A.E-414 piping components, general, pitting, crevice "Internal V.B.E-414 heat exchangers, corrosion, MIC Coatings/Linings for V.C.E-414 tanks with internal In-Scope Piping, V.D1.E-414 coatings/linings Piping Components, V.D2.E-414 exposed to closed- Heat Exchangers, cycle cooling water, and Tanks" raw water, treated water, treated borated water, lubricating oil, condensation Page 14 of 15
Table 3.3-1 Summary of Aging Management Programs for Auxiliary Systems Evaluated in Chapter VII of the SLR-ISG-MECHANICAL-2020-XX: Appendix H Errata GALL-SLR Report New, Modified, Deleted, Aging Management Edited Program Further Evaluation GALL-SLR Item ID Type Component Aging Effect/Mechanism (AMP)/TLAA Recommended Item M 127 BWR/PWR Metallic piping, piping Loss of material due to AMP XI.M20, Yes (SRP-SLR VII.C1.A-400a components, tanks recurring internal corrosion "Open-Cycle Cooling Section 3.3.2.2.7) VII.C1.A-400b exposed to closed- Water System," VII.C3.A-400a cycle cooling water, AMP XI.M27, "Fire VII.C3.A-400b raw water, raw water Water System," or VII.E5.A-400b (potable), treated AMP XI.M38, VII.G.A-400c water, waste water "Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components" M 138 BWR/PWR Any material piping, Loss of coating or lining AMP XI.M42, No VII.C1.A-416 piping components, integrity due to blistering, "Internal VII.C2.A-416 heat exchangers, cracking, flaking, peeling, Coatings/Linings for VII.C3.A-416 tanks with internal delamination, rusting, or In-Scope Piping, VII.D.A-416 coatings/linings physical damage; loss of Piping Components, VII.E4.A-416 exposed to closed- material or cracking for Heat Exchangers, VII.E5.A-416 cycle cooling water, cementitious and Tanks" VII.F1.A-416 raw water, raw water coatings/linings VII.F2.A-416 (potable), treated VII.F3.A-416 water, treated borated VII.F4.A-416 water, fuel oil, VII.G.A-416 lubricating oil, waste VII.H1.A-416 water VII.H2.A-416 M 139 BWR/PWR Any material piping, Loss of material due to AMP XI.M42, No VII.C1.A-414 piping components, general, pitting, crevice "Internal VII.C2.A-414 heat exchangers, corrosion, MIC Coatings/Linings for VII.C3.A-414 tanks with internal In-Scope Piping, VII.D.A-414 coatings/linings Piping Components, VII.E4.A-414 exposed to closed- Heat Exchangers, VII.E5.A-414 cycle cooling water, and Tanks" VII.F1.A-414 Page 15 of 15 raw water, raw water VII.F2.A-414 (potable), treated VII.F3.A-414 water, treated borated VII.F4.A-414 water, fuel oil, VII.G.A-414 lubricating oil, waste VII.H1.A-414 water VII.H2.A-414