ML21274A417
| ML21274A417 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/05/2021 |
| From: | Jorge Corujo-Sandin NRC/RGN-III/DRS/EB2 |
| To: | Corbin D Entergy Nuclear Operations |
| References | |
| IR 2021004 | |
| Download: ML21274A417 (12) | |
See also: IR 05000255/2021004
Text
Mr. Darrell Corbin
Vice President, Operations
Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant
27780 Blue Star Memorial Highway
Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT - REQUEST FOR INFORMATION FOR AN
NRC TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE
INSPECTION AND REQUEST FOR INFORMATION; INSPECTION
REPORT 05000255/2021004
Dear Mr. Corbin:
On December 6, 2021, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite
portion of the Triennial Heat Exchanger/Sink Performance Inspection at Palisades Nuclear
Plant. This inspection will be performed in accordance with NRC baseline Inspection
Procedure 71111.07.
The Triennial Heat Exchanger/Sink Performance Inspection focuses on service water cooled
heat exchangers, closed loop heat exchangers and the ultimate heat sink (UHS). The
inspection verifies that the selected service water cooled heat exchanger(s), closed loop heat
exchanger(s) and the UHS remain capable of performing their intended safety functions. In
addition, this inspection will perform portions of Inspection Procedure 71003 Section 02.02.d.
(Phase IV). This inspection objective is intended to review the implementation of certain aging
management program elements to ensure the system, structures, and components have
maintained their ability to perform their intended function.
The current inspection schedule is as follows:
Preparation week:
November 29 - December 3, 2021
Onsite week:
December 6 - 10 and 13 - 14, 2021
In order to minimize the impact that the inspection has on the site and to ensure a productive
inspection, a request for documents needed for the inspection is enclosed. The information
request has been divided into three groups:
The first group lists information necessary for the initial inspection scoping activities.
This information should be available to the lead inspector no later than
October 26, 2021. The lead inspector will communicate the initial selected set of
approximately 2-3 risk significant heat exchangers by November 2, 2021.
October 5, 2021
D. Corbin
- 2 -
The second group is needed to support the in-office preparation activities. This set
of documents, including the calculations associated with the selected heat
exchangers, should be available at the Regional Office no later than
November 22, 2021. This information should be separated for each selected
component, especially if provided electronically (e.g., folder with component name
that includes calculations, condition reports, maintenance history, etc.). During the
in-office preparation activities, the inspector may identify additional information
needed to support the inspection.
The last group includes the additional information from above as well as plant
specific reference material. This information should be available to the inspector on
November 29, 2021. It is also requested that corrective action documents and/or
questions developed during the inspection be provided to the inspector as the
documents are generated.
All requested documents are to be for the time period from the onsite inspection period back to
the documents that were provided in response to the previous Heat Sink Performance
Inspection. If no activities were accomplished in that time period, then the request applies to the
last applicable document in the previous time period. It is important that these documents be as
complete as possible, in order to minimize the number of documents requested during the
preparation week or during the onsite inspection.
The lead inspector for this inspection is Jorge Corujo-Sandin. We understand that our licensing
contact for this inspection is Monica Peak of your organization. If there are any questions about
the inspection or the material requested in the enclosure, please contact the lead inspector at
630-829-9741 or via e-mail at jorge.corujo-sandin@nrc.gov.
This letter does not contain new or amended information collection requirements subject to the
Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
requirements were approved by the Office of Management and Budget, Control
Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
respond to, a request for information or an information collection requirement unless the
requesting document displays a currently valid Office of Management and Budget Control
Number.
D. Corbin
- 3 -
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of
this letter and its enclosure will be available electronically for public inspection in the NRC Public
Document Room or from the Publicly Available Records (PARS) component of NRCs
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible
from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic
Reading Room).
Sincerely,
Jorge Corujo-Sandin, Senior Reactor Inspector
Engineering Branch 2
Division of Reactor Safety
Docket No. 50-255
License No. DPR-20
Enclosure:
Triennial Heat Exchanger/Sink Performance
Inspection Document Request
cc: Distribution via LISTSERV
Signed by Corujo-Sandin, Jorge
on 10/05/21
D. Corbin
- 4 -
Letter to Darrell Corbin from Jorge Corujo-Sandin dated October 5, 2021.
SUBJECT:
PALISADES NUCLEAR PLANT - REQUEST FOR INFORMATION FOR AN
NRC TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE
INSPECTION AND REQUEST FOR INFORMATION; INSPECTION
REPORT 05000255/2021004
DISTRIBUTION:
RidsNrrPMPalisades Resource
RidsNrrDorlLpl3
RidsNrrDroIrib Resource
DRPIII
DRSIII
ADAMS Accession Number: ML21274A417
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
OFFICE
RIII
RIII
NAME
MGangewere:mb
JCorujo-Sandin
DATE
10/05/2021
10/05/2021
OFFICIAL RECORD COPY
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
Enclosure
HEAT EXCHANGER/SINK PERFORMANCE
REQUEST FOR INFORMATION
I.
ADMINISTRATIVE INSPECTION INFORMATION
Inspection Report Number:
Onsite Inspection Dates:
December 6 - 10 and 13 - 14, 2021
Inspection Procedure:
IP 71111.07, HEAT EXCHANGER/SINK PERFORMANCE
Lead Inspector:
Jorge Corujo-Sandin, Senior Reactor Inspector
RIII/DRS/Engineering Branch 2
630-829-9741
jorge.corujo-sandin@nrc.gov
II.
Information Requested by: October 26th, 2021
1.
List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting
Safety-Related Equipment, heat exchangers in order of risk significance.
a.
Identify if the heat exchanger is service water cooled or a closed loop heat
exchanger.
b.
Identify if the heat exchanger will continue to be relied upon to perform a safety
function during any portion of decommissioning after the plant permanently shuts
down.
2.
Copy of heat exchanger performance trending data tracked for each GL 89-13 heat
exchanger.
3.
List of corrective action program documents (with a short description) associated
with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or heat
exchanger testing, for the previous three years or since the last corrective action
program document list was sent to the NRC for the previous heat sink performance
inspection. The list should include all corrective action program documents not on
the last corrective action program document list.
4.
Copy of any self-assessment done on any of GL 89-13 heat exchangers.
5.
Last two System Health Report(s) and maintenance rule system notebooks for all the
GL 89-13 heat exchangers.
6.
List of engineering-related operator workarounds (with a short description)
associated with GL 89-13 heat exchangers. The requested documents are to be for
the time period from the onsite inspection period back to the documents that were
provided in response to the previous heat sink performance inspection.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
2
7.
List of permanent and temporary modifications (with a short description) associated
with GL 89-13 heat exchangers. The requested documents are to be for the time
period from the onsite inspection period back to the documents that were provided in
response to the previous heat sink performance inspection.
8.
Provide a list of all corrective action documents, with a short description, associated
with the UHS for the previous three years or since the last corrective action program
document list was sent to the NRC for the previous Triennial Heat Sink Performance
Inspection.
III. Information Requested by: November 22nd, 2021
1.
Copies of the GL 89-13 responses.
2.
Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the
GL 89-13 Heat Exchanger Program.
3.
Copies of procedures developed to implement the recommendations of GL 89-13
(e.g., the GL 89-13 Heat Exchanger Program description).
4.
Copies of the selected corrective action program documents.
5.
Provide copies of corporate and/or site-specific program document/procedure related
to overall aging management program (AMP).
6.
Provide a list of all site AMPs.
7.
For the specific heat exchangers selected:
a.
Copies of the UFSAR sections applicable for each heat exchanger.
b.
Copy of system description and design basis document for the heat exchangers
(as applicable).
c.
Provide a list of calculations (with a short description) which currently apply to
each heat exchanger.
i.
Establish the limiting design basis heat load required to be removed by
each of these heat exchangers;
ii.
Demonstrate the heat exchangers capacity to remove the limiting heat
load;
iii.
Correlate surveillance testing and/or inspection results from these heat
exchangers with design basis heat removal capability (e.g., basis for
surveillance test and/or inspection acceptance criteria);
iv.
Evaluate the potential for water hammer in each heat exchanger or
associated piping; and
v.
Evaluate excessive tube vibration in each heat exchanger.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
3
d.
Copy of any operability determinations or other documentation of degradation
associated with the heat exchangers or the systems that support the operation
for the selected heat exchangers.
e.
Copy of the construction code, design specification, heat exchanger data sheets,
and vendor documents including component drawings applicable for the heat
exchangers.
f.
Copies of normal, abnormal, and emergency operating procedures associated
with the selected heat exchangers.
g.
Provide AMP basis documents and administrative procedures describing key
program attributes such as program objectives, scope, detection and monitoring
methods, administrative controls, acceptance criteria, corrective actions, and
scope expansion requirements.
8.
For the ultimate heat sink (UHS):
a.
Copies of the applicable UFSAR sections.
b.
Copy of system description and design basis document (as applicable).
c.
Copy of any operability determinations or other documentation of degradation
associated with the UHS.
d.
Copy of the document (e.g., UFSAR, Technical Requirements Manual or
procedure) that states the maximum cooling water system inlet temperature limit
that still allows full licensed power operation of the nuclear reactor.
e.
Copy of system description and design basis document (as applicable).
f.
Copy of the construction code and design specification.
g.
Copies of normal, abnormal, and emergency operating procedures associated
with the UHS including procedures for loss of this systems.
h.
Provide a list of calculations (with a short description), which currently apply to
UHS.
i.
Provide a list of instruments (with a short description) associated with automatic
or alarm functions for the UHS.
j.
Provide a list of any design change (with a short description) performed on the
UHS since the last heat sink performance inspection.
k.
Provide AMP basis documents and administrative procedures describing key
program attributes such as program objectives, scope, detection and monitoring
methods, administrative controls, acceptance criteria, corrective actions, and
scope expansion requirements.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
4
9.
A schedule of all inspections, cleanings, maintenance, or testing of any
safety-related plant heat exchanger to be performed during the onsite portion of the
inspection.
IV. Information Requested to be Available for Inspection Preparation by:
November 29th, 2021
1.
For the specific service water cooled heat exchangers selected:
a.
Copy of the calculation which correlates surveillance testing results from these
heat exchangers with design basis heat removal capability (e.g., basis for
surveillance test acceptance criteria).
b.
Copies of the two most recent completed tests and evaluation data confirming
thermal performance for those heat exchangers which are performance tested.
c.
Documentation and procedures that identify the types, accuracy, and location of
any special instrumentation used for the two most recently completed thermal
performance tests for the heat exchangers (e.g., high accuracy ultrasonic flow
instruments or temperature instruments). Include calibration records for the
instruments used during these tests.
d.
Information regarding any alarms which monitor on-line performance.
e.
Copy of the document describing the inspection results of each heat exchanger.
The requested documents are to be for the time period from the onsite inspection
period back to the documents that were provided in response to the previous
heat sink performance inspection.
f.
The cleaning and inspection maintenance schedule for each heat exchanger for
the next 5 years.
g.
Copy of the design specification and heat exchanger data sheets for each heat
exchanger.
h.
Copy of the vendor manuals including component drawings for each heat
exchanger.
i.
Copy of the calculation which establishes the limiting (maximum) design basis
heat load which is required to be removed by each of these heat exchangers.
j.
Copy of the operating procedures that ensure that the maximum cooling water
system inlet temperature limit is not exceeded.
k.
Copy of the calculations or documents which evaluate the potential for water
hammer in each heat exchanger or associated piping.
l.
Copy of the calculations that evaluate excessive tube vibration in each heat
exchanger and the documents that describe the controls that prevent heat
exchanger degradation due to excessive flow induced vibration during operation.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
5
m. Copy of the periodic flow testing at or near maximum design flow. The requested
documents are to be for the time period from the onsite inspection period back to
the documents that were provided in response to the previous heat sink
performance inspection.
n.
Copy of the document which identifies the current number of tubes in service for
each heat exchanger and the supporting calculation which establishes the
maximum number of tubes which can be plugged in each heat exchanger.
o.
Copy of the document establishing the repair criteria (plugging limit) for degraded
tubes which are identified in each heat exchanger.
p.
Copies of the documents that verify the structural integrity of the heat exchanger
(e.g., eddy current summary sheets, ultrasonic testing results, and visual
inspection results).
2.
For the specific closed loop heat exchangers selected:
a.
Copy of the design specification and heat exchanger data sheets for each heat
exchanger.
b.
Copy of the vendor manuals including component drawings for each heat
exchanger.
c.
Copy of the calculation which establishes the limiting (maximum) design basis
heat load which is required to be removed by each of these heat exchangers.
d.
Copy of the operating procedures that ensure that the maximum cooling water
system inlet temperature limit is not exceeded.
e.
Copy of the calculations or documents which evaluate the potential for water
hammer in each heat exchanger or associated piping.
f.
Copy of the calculations that evaluate excessive tube vibration in each heat
exchanger and the documents that describe the controls that prevent heat
exchanger degradation due to excessive flow induced vibration during operation.
g.
Copy of the periodic flow testing at or near maximum design flow. The requested
documents are to be for the time period from the onsite inspection period back to
the documents that were provided in response to the previous heat sink
performance inspection.
h.
Copy of the document which identifies the current number of tubes in service for
each heat exchanger and the supporting calculation which establishes the
maximum number of tubes which can be plugged in each heat exchanger.
i.
Copy of the document establishing the repair criteria (plugging limit) for degraded
tubes which are identified in each heat exchanger.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
6
j.
Copies of the documents that verify the structural integrity of the heat exchanger
(e.g., eddy current summary sheets, ultrasonic testing results, and visual
inspection results).
k.
Copies of those documents that describe the methods taken to control water
chemistry in the heat exchangers.
3.
For the review of the operation of the UHS:
a.
For the review associated with the system walkdown of the selected service
water and/or closed cooling water systems:
i.
Copies of the testing, inspection, or monitoring program procedures for
buried or inaccessible piping and the associated results. The requested
documents are to be for the time period from the onsite inspection
period back to the documents that were provided in response to the
previous heat sink performance inspection.
ii.
Copies of the ultrasonic test results and/or visual inspections that verify
the structural integrity of the piping.
iii.
Copies of the procedures to monitor, assess, and disposition active thru
wall pipe leaks, including structural evaluations and/or planned
corrective actions.
iv.
History of any thru wall pipe leak on the system. The requested
documents are to be for the time period from the onsite inspection
period back to the documents that were provided in response to the
previous heat sink performance inspection.
v.
Copies of the documents associated with the periodic inspection
program used to detect protective coating failure, corrosion, and
erosion.
vi.
Copies of the in-service testing (IST) vibration monitoring results and
operational history for deep draft vertical pumps, if applicable. The
requested documents are to be for the time period from the onsite
inspection period back to the documents that were provided in response
to the previous heat sink performance inspection.
b.
For the review associated with the system walkdown of the service water intake
structure:
i.
Copies of corrective maintenance for the last 6 years associated with
service water strainers, traveling screens and trash racks.
ii.
Copies of the last two inspections and/or surveillances associated with
service water strainers, traveling screens and trash racks.
iii.
List of preventive maintenance, including frequency, associated with
service water strainers, traveling screens and trash racks.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
7
iv.
Copies of abnormal procedures for the traveling screens and service
water strainers.
v.
Copies of the last two inspections and/or surveillances documenting that
component mounts have not excessively degraded (i.e., due to
corrosion). For example, inspections for the mounts for the, Service
water pumps, service water strainers, traveling screens and trash racks.
vi.
Copies of the documents associated with the monitoring, trending, and
remediation of silt accumulation at the service water pump bay.
vii.
Copies of surveillance procedures and testing results performed on the
service water pump bay water level instruments. The requested
documents are to be for the time period from the onsite inspection period
back to the documents that were provided in response to the previous
heat sink performance inspection.
viii.
Copies of procedures associated with operating during adverse weather
conditions (e.g., icing, high temperatures, or low level).
ix.
Copy of the evaluation for the potential effects of low flow/level on
underwater weir walls intended to limit silt or sand intake, if applicable.
4.
For review of the UHS Containment Device or Dam:
a.
Copies of the inspection procedures for the verification of the structural integrity
of underwater UHS and the associated results. The requested documents are to
be for the time period from the onsite inspection period back to the documents
that were provided in response to the previous heat sink performance inspection.
b.
Copies of the maintenance and/or inspection procedures for underwater UHS
sediment intrusion and the associated results including underwater diving
inspections and/or sediment removal activities. The requested documents are to
be for the time period from the onsite inspection period back to the documents
that were provided in response to the previous heat sink performance inspection.
c.
Copies of calculations and surveillances that determine the UHS reservoir
capacity and heat transfer capability.
d.
Copies of surveillance procedures and testing results performed on the
instrumentation relied upon to determine UHS reservoir capability. The
requested documents are to be for the time period from the onsite inspection
period back to the documents that were provided in response to the previous
heat sink performance inspection.
5.
For review of the AMP:
a.
Provide any self-assessments and/or audits related to license renewal program
implementation and/or AMP effectiveness.
TRIENNIAL HEAT EXCHANGER/SINK PERFORMANCE DOCUMENT REQUEST
8
b.
Provide a list of corrective action documents that were initiated as result of
license renewal activities, self-assessments, and/or audits (since entering the
Period of Extended Operation (PEO)).
c.
Provide a summary document listing which implementing procedures are
included in the selected AMP and what are their required performance frequency
for each selected heat exchanger and UHS review.
d.
Copies of implementing procedures for program activities (e.g., visual
examination procedures, ultrasonic examination procedures, maintenance
procedures, system walkdowns, etc.) for each selected heat exchanger and UHS
review.
If the information requested above will not be available, please contact Jorge Corujo-Sandin as
soon as possible at 630-829-9741 or via e-mail at jorge.corujo-sandin@nrc.gov.