ML22013A294

Trp 46 St. Lucie SLRA - Breakout Questions Structures Monitoring

ML22013A294
Person / Time
Site:	Saint Lucie
Issue date:	12/21/2021
From:	Office of Nuclear Reactor Regulation
To:
Rodriguez-Luccioni H
References
EPID L-2021-SLR-0002, L-2021-SLR-0002
Download: ML22013A294 (9)

Text

St. Lucie SLRA: Breakout Questions SLRA Section B.2.3.33: Structures Monitoring TRP: 046 Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.

Technical Reviewer Juan Lopez 12/15/2021 Technical Branch Chief Joseph Colaccino 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 2.1.4.2.1 2-1-13 The GALL-SLR XI.S6 states that the Scope of the Program:

2.4 2.4-1 scope of the program includes all SCs, 1. Clarify how the SLRA B.2.3.33 B-248 component supports, and structural addresses the components commodities in the scope of license described in SLRA renewal (e.g., pipe whip restraints, jet Section 2.1.4.2.1, and if jet impingement shields, etc.) that are not impingement shields are covered by other structural aging within the scope of the management programs. structures monitoring program, or if they need to SLRA Section 2.1.4.2.1 states that NNS be address within SLRA whip restraints, jet impingement Sections 2.4 and 3.5.

shields, blowout panels, etc. that are designed and installed to protect SR equipment from the effects of a HELB are within the scope of SLR per 10 CFR 54.4(a)(2). However, it is not

clear how St. Lucie addresses some of these components for the subsequent period of extended operation and if the structures monitoring program will manage them. It is noted that Attachment 1 of the structures monitoring program procedure (ADM-17.32) seems to include whip restraints into the scope of components to be monitored/inspected, however it is not clear if jet impingement shields are within the scope of the structures monitoring program.

2 B.2.3.33 B-248 The GALL-SLR XI.S6 states that: Parameters Monitored or

• Elastomeric vibration isolators, Inspected:

structural sealants, and seismic joint 1. Clarify how loss of strength fillers are monitored for cracking, loss will be managed for of material, and hardening. elastomers during the visual inspections.

• Elastomeric vibration isolation elements are acceptable if there is no 2. Is cracking also being loss of material, cracking, or monitored during inspection?

hardening that could lead to the How it is specified in the reduction or loss of isolation function. current AMP?

The SLRA enhancement No 3(b) adds to Acceptance Criteria:

the AMP the inspection of elastomers for 3. Clarify how the existing AMP loss of material and loss of strength. is consistent with the However, it is not clear how loss of GALL-SLR Report strength will be monitored using visual recommendation for inspections by the AMP and if cracking ensuring that elastomeric will be a parameter to be monitored. It is vibration isolation elements noted that Section 4.13 of ADM-17.32 do are only acceptable if there not include cracking as a parameter to be is no loss of material, monitored and the Tables in cracking, or hardening that

Attachment 1 only lists loss of seal as could lead to the reduction or the applicable aging effect to be loss of isolation function.

monitored using visual inspection. The staff also notes that Enhancement No. 4 will provide for tactile inspection in addition to visual inspection of elastomeric elements to detect hardening.

Furthermore, it is not clear what acceptance criteria the current program includes for elastomeric vibration isolation elements.

3 B.2.3.33 B-248 The GALL-SLR XI.S6 states that: Parameters Monitored or

• Bolting within the scope of the Inspected:

program is monitored for loss of 1. Clarify how the existing AMP material, loose bolts, missing or loose is being consistent with the nuts, and other conditions indicative GALL-SLR Report of loss of preload. recommendation for monitoring the different

• Loose bolts and nuts are not parameters associated with acceptable unless accepted by bolting degradations.

engineering evaluation.

Acceptance Criteria:

It is not clear if the current program 2. Clarify how the existing AMP defines the parameters to be monitored is consistent with the or inspected for structural bolting, to GALL-SLR Report demonstrate consistency with the recommendation for GALL-SLR Report. The following was ensuring that loose bolts and generally identified within ADM-17.32: nuts are not acceptable

• Section 4.3 for structural and unless accepted by miscellaneous steel looks for "anchor engineering evaluation.

bolt deficiencies" (might be too general)

• Attachment 2 Sections 4.9 and 4.10, looks for missing/loose bolts or nuts specifically at equipment mounting and tanks,

• Attachment 2, Section 5.1.3 looks for no detached embedment or loose bolts.

4 B.2.3.33 B-248 The GALL-SLR XI.S6 states that: Detection of Aging Effects:

• In general, all structures are This issue/question is being monitored on an interval not to address under TRP-047 for the exceed 5 years water controlled-structures.

Item is kept here (as well) for SLRA Enhancement no. 9(d) states that tracking purposes as it also procedures will be updated to require the affects the Structures Monitoring inspection of the CST and AFW Program. No further discuss is structures and piping inspection in necessary at this point.

trenched every third refueling outage, which will ensure that these inspections are performed at least once per 5 years, SLRA AMP basis document Sections 4.4 and 4.5 (for water control structures) state that one intake well is dewatered and inspected every refueling outage on the rolling basis, which is a frequency of one inspection per unit every 18 months.

However, ADM-17.32 Section 3.2(1)(E) states that normally submerged areas of the intake wells will be completed on a once every 4th refueling frequency (approximately 6 years) when the wells are dewatered for maintenance.

5 B.2.3.33 B-249 The GALL-SLR XI.S6 states that: Detection of Aging Effects:

• For plants with aggressive 1. Describe the plant-specific groundwater/soil (pH < 5.5, chlorides actions that will be

> 500 ppm, or sulfates > 1,500 ppm) implemented within the AMP and/or where the concrete structural to ensure and demonstrate elements have experienced that the AMP will adequately degradation, a plant-specific AMP manage degradations for accounting for the extent of the inaccessible areas exposed degradation experienced should be to an aggressive water/soil implemented to manage the concrete environment.

aging during the subsequent period of extended operation. Notes:

• The SLRA needs to define

• The GALL Report further states that the proposed plant-specific this plant-specific AMP may include actions/program elements in evaluations, destructive testing, sufficient details so they can and/or focused inspections of be evaluated. Therefore, representative accessible (leading plant-specific program or indicator) or below-grade, program actions needs to inaccessible concrete structural align with the criteria elements exposed to aggressive specified in the Branch groundwater/soil, on an interval not to Technical Position RLSB-1 exceed 5 years. (Appendix A.1 of the SRP-SLR).

SLRA Enhancement No. 4(c) provides

• Any plant-specific for updating the existing procedure and action/enhancement (not other applicable procedure to address generically address by the the aggressive groundwater/soil GALL) should be considered environment and lists the same general for inclusion in the UFSAR actions that the GALL-SLR Report Supplement. SLRA recommended for the plant-specific AMP. Section 19.2.2.33 did However, the enhancement does not provided some.

provide sufficient detail to clearly understand the what/when/where/how of the plant-specific actions that will be implemented to demonstrate that the

aging effects will be adequately managed.

6 B.2.3.33 B-249 SLRA Enhancement No. 4(d) provides Monitoring and Trending:

for updating the existing procedure and 1. Clarify if these SCs are new other applicable procedures to require to the scope of the program.

the inspection of the condensate storage Is so, is there any plan to tank, auxiliary feedwater structures and inspect these structures prior piping inspections in the trenches every to entering the period of third refueling outage which will ensure extended operations.to that these inspections are performed at ensure that quantitative once per 5 years. However, this baseline inspection data is enhancement appears to add these established prior to entering structures/components (SC) as new SCs the period of extended to the scope of the program and operations.

additional clarification is necessary.

Detection of Aging Effects:

2. Clarify what is the refueling outage frequency at St.

Lucie and how using a third outage interval will ensure that inspections are being performed at least once every 5 years.

7 Table 3.3-46 SLRA Table 3.3-1, AMR line AMR Line Item:

3.3-1 item 3.3-1, 111 states that it is consistent with the GALL-SLR Report and the Clarify the discrepancy in the Structures Monitoring AMP (B.2.3.33) is SLRA for the AMR line used to manage loss of material in item 3.3-1, 111. Also, state structural steel exposed to uncontrolled what material the new fuel indoor air. This line item is used to storage racks are made of.

evaluate structural items in Section 3.5.

It is noted that, the GALL-SLRA However, during the review of SLRA Report uses AMR line Table 3.5-2, no AMR line item evaluating item 3.3-1, 111 to evaluate new

the components associated with AMR fuel storage (racks) made of line item 3.3-1, 111 was identified. SLRA steel that are exposed to an air-Section 2.4.7 also stated that the fuel indoor environment.

handling building provides an area for cask loading and space for the storage of new fuel.

8 Table 3.5-107 In SLRA Table 3.5.2-7, an AMR line item AMR Line Item:

3.5.2-7 associated with 3.5-1, 088 cited a note E to stated that loss of preload in structural Clarify how the Water Chemistry supports for fuel handling building will be and the One-Time Inspection manage by the one-time inspection AMP's will be used to program and the water chemistry adequately manage the loss of program. Plant-specific note 5 states preload aging effects for these that connections associated with the components.

spent fuel pool will be managed under the Water Chemistry and the One-Time Inspection AMP's. However, it is not clear how the aging effects of loss of preload will be adequately manage by these programs.

9 Table 3.5-143 In SLRA Table 3.5.2-17, an AMR line AMR Line Item:

3.5.2-17 item associated with 3.5-1, 092 cited a note E to stated that loss of material in Clarify why item 3.5-1, 092 was carbon steel plates used as fire barriers used to address this will be manage by the fire protection material/aging effects program. Plant-specific note 1 states combination associated with fire that metal components of fire barrier barriers. Were other AMR line assemblies will be managed by the Fire items associated with the fire Protection AMP. protection program considered?

(e.g., 3.3-1, 058 / 059 or 255 as a different component with same material and aging effects)

10 Table 3.5-143 During the review of SLRA AMR Line Item:

3.5.2-16 Table 3.5.2-16, it was noted that several AMR line items associated with 1. Clarify why the listed 3.5-1, 055 addresses the reduction in components, associated with anchor capacity for components support AMR line time 3.5-1, 055, commodities. However, based on the were not addressed in the line items in the SLRA, and considering SLRA.

the line items evaluated in the GALL-SLR Report, it is not clear why the following 2. Clarify why the listed associated components were not component, associated with addressed in the SLRA: AMR line time 3.5-1, 093,

• Class 1, II, III and MC supports was not addressed in the (i.e., III.B1.1.TP-42, III.B1.2.TP-42, SLRA.

III.B1.3.TP-42),

• anchorage of Racks, Panels, Cabinets, and Enclosures for Electrical Equipment (i.e., III.B3.TP-42),

• Supports for Emergency Diesel Generator, HVAC System Components (i.e., III.B4.TP-42) was excluded.

It was also noted that the Table 1 AMR line item did not described any partial applicability for AMR 3.5-1, 055.

Similarly, for items associated with 3.5-1, 093 addressing the Loss of material due to pitting, crevice corrosion for support members, it is not clear why the following associated component was not addressed in the SLRA:

• Supports for Emergency Diesel Generator, HVAC System Components, and Other

Miscellaneous Mechanical Equipment (i.e., III.B4.TP-6) 11 2.1.4.2.1 2.1-14 SLRA Section 2.1.4.2.1 states that NNS Scope of Program whip restraints, jet impingement shields, Clarify how the jet impingement blowout panels, etc. that are designed shields was addressed by the and installed to protect SR equipment SLRA.

from the effects of a HELB are within the scope of SLR per 10 CFR 54.4(a)(2).

However, it is not clear where the jet impingement shields were addressed in the SLRA.

12 19.2.2.33 A1-35 SLRA Section 19.2.2.33 states, in part, UFSAR Supplement:

A2-34 that [t]he PSL Structures Monitoring Clarify why the program AMP is an existing AMP that consists of description do not clearly define periodic inspection and monitoring of the the type of inspection that will be condition of concrete and steel performed (e.g., visual) structures, structural components, components supports, and structural commodities to ensure that aging degradation GALL-SLR Table XI-01 provides a FSAR Supplement Summary for the Structures Monitoring Program as generically evaluated in the GALL-SLR Report.