ML21351A241

Trp 15 St. Lucie SLRA - Internal Coatings Breakout Questions - Allik

ML21351A241
Person / Time
Site:	Saint Lucie
Issue date:	12/17/2021
From:	Office of Nuclear Reactor Regulation
To:
Rodriguez-Luccioni H
References
EPIP L-2021-SLR-0002
Download: ML21351A241 (3)

Text

St. Lucie SLRA: Breakout Questions SLRA Section AMP B.2.3.28: Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks TRP: 15 Technical Reviewer Allik 12/15/2021 Technical Branch Chief Bloom 12/15/2021 Breakout Session Date/Time To be filled in by PM Applicant Staff NRC staff To be filled out by PM during breakout Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) 1 B.2.3.28 B-221 GALL-SLR Report AMP XI.M42 (as The staff requests a discussion modified by SLR-ISG-2021 with respect to why concrete MECHANICAL) states opportunistic linings in the fire protection inspections, in lieu of periodic system are not representative inspections, are an acceptable alternative of concrete linings in the intake for buried internally lined/coated fire cooling water system (where water system piping provided certain leaks occurred due to conditions are met. One of these degradation of the cement conditions is plant-specific operating liner).

experience is acceptable (i.e., no leaks due to age-related degradation of representative internal coatings/linings used in buried in-scope fire water system components).

SLRA Section B.2.3.28 states

[o]pportunistic inspections, in lieu of

periodic inspections, will be performed for the buried concrete lined fire protection piping... PSL does not have plant-specific OE [operating experience] regarding buried fire main leaks due to age-related degradation in the coated/lined portions of the piping.

During its review of SLRA Section B.2.3.27, Buried and Underground Piping and Tanks, (specifically operating experience example No. 2) the staff noted (a) thru-wall degradation and pitted areas in the intake cooling water system; and (b) a root-cause analysis determined the failure was due to the damaged cement liner and failed internal coating that exceeded service life.

2 Table 3.2-32 SLRA Table 3.2-1 (item 073) states Not The staff requests a discussion 3.2-1 applicable. The Engineered Safety with respect to whether the Features Systems do not include any engineered safety features material piping, piping components, heat systems include internally exchangers, or tanks with internal coated/lined components.

coatings/linings exposed to closed-cycle cooling water, raw water, treated water, treated borated water, or condensation.

SLRA Table 3.2.2-2 states the Unit 1 refueling water storage tank will be managed for loss of coating integrity.

3 N/A N/A Unit 1 UFSAR Table 9.2-17, Design The staff requests a discussion Data For Steam Generator Blowdown with respect to whether (a) the Cooling System, states the Open subject components are within Blowdown Heat Exchanger Channel is the scope of SLR; and (b) if so, carbon steel with w/ epoxy lining. how they are accounted for in the SLRA.

Unit 2 UFSAR Table 10.4-1, Component Design Parameters, states the Steam Generator Blowdown System Monitor-Storage Tanks are carbon steel w/ epoxy lining.