ML22010A096

Trp 010 St Lucie SLRA - Boricacidcorrbreakoutq - Makar

ML22010A096
Person / Time
Site:	Saint Lucie
Issue date:	01/05/2022
From:	Florida Power & Light Co
To:	Office of Nuclear Reactor Regulation
Rodriguez-Luccioni H
References
EPID L-2021-SLR-0002
Download: ML22010A096 (4)

Text

St. Lucie Nuclear Plant, Units 1 and 2, Subsequent License Renewal Application (SLRA)

Breakout Audit Questions Technical Reviewer Gregory Makar 1/ 5 /202 2 Technical Branch Chief Steven Bloom 1/ 5 /202 2

TRP 010: Boric Acid Corrosion

1. SLRA SLRA Page Background/Issue Discussion Question/Request Outcome of Discussion Section 1 Appendix A1-66 The Boric Acid Corrosion Aging Management Please describe the process and A1, Table Program, B.2.3.4, includes enhancements to timing for incorporating the 19-3 the P arameters Monitored or Inspected monitoring and inspection element. The enhancements include enhancements for borated water Appendix B-54, B-55 methods for detecting borated water leaks leak detection and boric acid B, Section inside containment and a new requirement in residue detection into the B.2.3.4 the Inspection of Internal Surfaces of existing procedures, and the Miscellaneous Piping and Ducting extent to which this has been Components AMP to document evidence of completed.

boric acid residue inside containment cooler housings and similar locations.

The SLRA states that the enhancements will be implemented no later than six months prior to entering the SPEO. Since the enhancements describe activities relevant to the current operating period, the staff seeks to understand the process and timing for incorporating these activities into the plant procedures.

2 Appendix B-52 to B-56 Most documents related to the Boric Acid If inspection walkdowns are B, Section Corrosion program emphasize the high stopped before determining the B.2.3.4 priority of identifying and evaluating potential condition of the other train pump, pressure boundary leakage. However, then the actual overall condition documents related to the identification in of the plant might not be 2019 of pressure boundary leakage in a boric considered in a risk assessment

1. SLRA SLRA Page Background/Issue Discussion Question/Request Outcome of Discussion Section acid makeup pump casing state that walk-of the identified pressure downs are stopped when potential pressure boundary leakage.

boundary leakage is discovered.

Please explain why it is For example, the file AR 2323757, for an appropriate to stop walkdowns AR document titled, Adverse Trend in until potential pressure boundary Through Wall Boric Acid Leaks, addresses leakage is evaluated and through-wall leaks on pressure boundary repaired.

piping and pumps in 2019. It has completion notes stating walkdown will stop upon discovery of any potential pressure boundary leakage from the piping system, and walkdown will not continue until potential pressure boundary is eliminated or repaired.

The file, AR 02323757 ADVERSE TREND IN THROUGH WALL BORIC (002), has similar statements about stopping walk-downs, and also states, St Lucie could have avoided entering an action statement if personnel performing the walk-down had stopped upon identification of pressure boundary leakage on the first pump.

Continuing on to the opposite train component lead to having both A and B trains of Boric Acid Make up declared out of service.

3 Appendix B-55 It is not clear to the staff how monitoring and a) Please describe the process B, Section trending of active borated water leaks, boric and documents used for B.2.3.4 acid deposits, and other related condi tionstracking the resolution of are performed. boric acid leaks at St. Lucie.

The plant - specific operating experience b) What is the Station Seal Pro description in SLRA Section B.2.3.4, Boric Database mentioned in the Acid Corrosion, states, With timely condition 2019 AMP Effectiveness screening and evaluation, the significance Review, Level 1 AR and total number of boric acid leakage #02310112- 08, Aging Management Program (AMP)

1. SLRA SLRA Page Background/Issue Discussion Question/Request Outcome of Discussion Section conditions are trended to ensure the program Effectiveness Review and health remains green. Assessment Worksheet, and what role does it have in the In the Boric Acid Corrosion AMP basis boric acid leak tracking?

document, NEESL00008-REPT-043, Element

1. 5 (Monitoring and Trending) states, The program maintains a list of all active borated water leaks, excessive boric acid deposits, discoloration caused by corrosion, and affected targets susceptible to corrosion to track the condition of components in the vicinity of leaks and to identify locations with repeat leakage.

WCAP-15988-NP, Rev. 2, Section 7.9, Paragraph 6, states an account of active leakage is maintained, including identification, screening, evaluation, disposition, and tracking the resolution of boric acid leakage.

4 N/A N/A The effectiveness review document, Level 1 Please explain how Gap #2 for Assessment Effectiveness Review, AR containment walkdowns 02381822, identifies Gap #2 as Boric Acid identified in AR 02381822 is Corrosion Control containment walkdown being addressed, including the PMRQs not being included in the required document revisions and implementing documents section of PSL-status.

ENG - LRAM- 00- 090 and implementing procedure ER - AP-116-1000. It also states PMRQs 83810- 10 and 83811- 08 were not flagged with the License Renewal Attribute.

This suggests that 83810- 10 and 83811- 08 should be listed with Procedure ER - AP-116-1000 in Table 9-2 of PSL-ENG - LRAM - 00-090. However, Revision 7 of PSL-ENG -

1. SLRA SLRA Page Background/Issue Discussion Question/Request Outcome of Discussion Section LRAM-00-090 does not have these PMRQ items listed in Table 9-2.

5 N/A N/A AR 02140203, Majority of Boric Acid Leaks Please describe the progress Identified by Engineering, refers to a self-toward meeting industry assessment in 2016 that found 92 percent of standards and expectations for boric acid leaks at St. Lucie are identified by line organizations identifying Engineering. It notes that the best boric acid leaks.

performing plants have greater than 60 percent of boric acid leaks identified by line organizations.

The st ated purpose of the AR is to document the gap and drive better site engagement in identification of boric acid leaks.

6 N/A N/A The staff notes there are apparent editorial N/A errors in the Desktop Instruction, ER - AP-116-1000- 10000, Boric Acid Corrosion Control Program Implementation, Rev. 000. The cross-function activities listed in Section 8.2 include four elements (e, f, g, h) that are identical to elements a, b, c, d.