ML22013A295

Trp 47 St. Lucie SLRA - Breakout Questions

ML22013A295
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: ML22013A295 (8)

Text

St. Lucie SLRA: Breakout Questions SLRA Section B2.1.34, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP TRP: 047 Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.

Technical Reviewer George Wang 12/13/2021 Technical Branch Chief Joseph Colaccino 12/20/2021 Breakout Session Date/Time To be filled in by PM Applicant Staff NRC staff To be filled out by PM during breakout Question SLRA Section SLRA Background / Issue Discussion Question / Outcome of Discussion Number Page (As applicable/needed) Request 1 ADM-17.32 13 OF SLRA AMP basis document Sections 1. Clarify what is the 78 4.4 and 4.5 state that one intake well is inspection frequency of dewatered and inspected every submerged areas of the refueling outage on the rolling basis, intake wells.

which is a frequency of one inspection per unit every 18 months. However, 2. Clarify whether the plant procedure ADM-17.32, Revision Inspection of Water-Control 7, Structures Monitoring Program, Structures program or states that normally submerged areas Structures Monitoring of the intake wells will be completed on program has an exception to once every 4th refueling frequency NUREG-2191 guidance.

(approximately 6 years) when individual wells are dewatered for maintenance.

GALL-SLR report states that submerged structural elements are

visually inspected (e.g., dewatering, divers) at least once every 5 years for plants with aggressive raw water.

2 B.2.3.34 B-254 GALL-SLR report states that the 1. Clarify whether additional preventive actions emphasize proper enhancements for preventive selection of bolting material and actions are needed to ensure lubricants, and appropriate installation bolting integrity.

torque or tension to prevent or minimize loss of bolting preload and cracking of 2. Check preventive actions high-strength bolting. If the structural enhancements for different bolting consists of ASTM A325 and/or AMPs (B.2.3.29 and B.2.3.33)

ASTM A490 bolts (including respective to ensure the consistency.

equivalent twist-off type ASTM F1852 and/or ASTM F2280 bolts), the preventive actions for storage, lubricant selection, and bolting and coating material selection discussed in Section 2 of Research Council for Structural Connections publication, need to be used.

SLRA Section B.2.3.34, Element 2 enhancement, states that revising the implementing procedure to specify the use of high-strength bolt storage requirements discussed in Section 2 of the RCSC publication for structural bolting consisting of ASTM A325, ASTM A490, and equivalent bolts.

3 A19.2.2.34 A1-35 SLRA Section A19.2.2.34, Section 1. Provide the layout of water-A19.2.2.34 A2-35 B.2.3.34, and its AMP basis document control structures in the B.2.3.34 B-253 state that the scope of the PSL Water- drawing and clarify the scope 2.4.8 2.4-18 Control Structures AMP includes the of Inspection of Water-Control 2.4.9 2.4-19 Intake Cooling Water Canal,

2.4.14 2.4-29 Emergency Cooling Canal, Unit 1 and Structures program for each Unit 2 Intake Structures, and Ultimate structure.

Heat Sink Dam.

2. Clarify where Table 1 and SLRA Sections 2.4.8, 2.4.9, and 2.4.14 2 AMR items of the intake include Intake, Discharge, and cooling water canal are Emergency Cooling Canals; Earthen located in the SLRA.

Canal Dikes; Intake Structures; and Ultimate Heat Sink Dam, respectively. 3. Clarify whether PSL has miscellaneous steel such as With different names of Water-Control sluice gates and trash racks Structures called out in SLRA, it is at site. If they are within the unclear what structures will be within scope of SLR, provide Table the scope of Water-Control Structures 1 and 2 AMR items.

managed by the Inspection of Water-Control Structures program. 4. Discuss the plan to update the SLRA, UFSAR GALL-SLR report also includes supplement, and its AMP miscellaneous steel, such as sluice basis document to ensure the gates and trash racks within the scope consistency.

of Water-Control Structures. However, the staff could not locate miscellaneous steel such as sluice gates and trash racks in SLRA.

4 B.2.3.34 B-253 GALL-SLR report states that the water- 1. Clarify flood protection control structures included in the features and their associated program are concrete structures, SSCs.

embankment structures, spillway structures and outlet works, reservoirs, 2. List AMR items for the cooling water channels and canals, associated SSCs with flood flood protection walls and gates, and protection features managed intake and discharge structures. by the Structures Monitoring (Emphasis added) program.

SLRA Section B.2.3.34 states that flood protection features are managed by the Structures Monitoring AMP. However, it is not clear what SSCs associated flood protection features are managed by the Structures Monitoring program.

5 2.4.14 2.4-29 SLRA Section 2.4.14, Ultimate Heat 1. Clarify whether the Sink Dam, states the adjacent adjacent hurricane protection hurricane protection sheet piles are sheet piles are within the also considered within the evaluation scope of SLR and subject to boundary. It is unclear whether AMR. If they are within the adjacent hurricane protection sheet scope, provide AMR items in piles are within the scope of SLR and SLRA.

subject to AMR.

2. Clarify whether steel sheet SLRA Section 2.4.14 states that the piling or concrete compaction concrete compaction piles located in piles are located beneath the underlying soil are design features ultimate heat sink dam.

of soil, and thus do not require screening as unique components. But SLRA Table 2.4-14 includes steel sheet piling (beneath dam). It is unclear what piles are used beneath the Ultimate Heat Sink Dam.

6 NEESL00008- 8 of 26 GALL-SLR report under Element 3 1. Clarify whether there are REPT-073 states that accessible sliding surfaces accessible sliding surfaces are monitored for indication of loss of requiring aging management material due to wear or corrosion, and for Group 6 structures.

accumulation of debris or dirt. The staff does not find accessible sliding 2. Clarify parameters surfaces being managed by the monitored or inspected for Inspection of Water-Control Structures cooling canals, earthen canal program in SLRA. It is unclear whether dikes, and steel sheet piles.

there are accessible sliding surfaces for Group 6 structures. 3. Clarify whether procedure ADM-17.32 needs to be

SLRA AMP basis document Section modified to include missing 4.3 list parameters monitored or parameters monitored or inspected for concrete structures, inspected and clarify whether structural steel, electrical panels, and additional enhancements are miscellaneous steel. But it does not needed for Element 3.

provide parameters monitored or inspected for cooling canals, earthen canal dikes, and steel sheet piles.

GALL-SLR states that parameters to be monitored and inspected for earthen embankment structures include settlement, depressions, sink holes, slope stability (e.g., irregularities in alignment and variances from originally constructed slopes), seepage, proper functioning of drainage systems, and degradation of slope protection features. Parameters monitored for channels and canals include erosion or degradation that may impose constraints on the function of the cooling system and present a potential hazard to the safety of the plant.

Submerged emergency canals (e.g.,

artificially dredged canals at the river bed or the bottom of the reservoir) are monitored for sedimentation, debris, or instability of slopes that may impair the function of the canals under extreme low flow conditions.

7 NEESL00008- 12 of SLRA AMP basis document Section 4.6 1. Clarify acceptance criteria REPT-073 26 states that the PSL Water-Control for cooling canals, earthen Structures AMP acceptance criteria and canal dikes, steel sheet piles.

guidelines for structural inspections are documented in procedure ADM-17.32,

Revision 7, Structures Monitoring 2. Clarify whether procedure Program. ADM-17.32 needs to be modified to include missing Procedure ADM-17.32, Revision 7, acceptance criteria and clarify Section 2.2.1 in Attachment 2, states whether additional that inspection findings should be enhancements are needed based on relevant codes and standards for Element 6.

in addition to the judge of qualified individuals performing the inspections.

Each inspection shall be evaluated based on the following three criteria:

Acceptable, Acceptance with Deficiencies, and Unacceptance.

GALL-SLR report states that acceptance criteria for earthen structures, such as canals and embankments, are consistent with programs falling within the regulatory jurisdiction of the FERC or the USACE.

Loose bolts and nuts, and degradation of piles and sheeting are accepted by engineering evaluation or subject to corrective actions.

It is unclear what acceptance criteria is used for cooling canals, earthen canal dikes, and steel sheet piles.

8 B.2.3.34 B-255 During the St. Lucie onsite audit, the 1. Provide AR and WO staff identified spalling, cracking, and associated with OE item of corrosion on the top of concrete walls in discharge concrete submerged discharge concrete structures.

structures. However, OE in SLRA Section B.2.3.34 does not include this 2. Discuss how discharge OE item. concrete structures can

maintain their intended functions due to deterioration during the SPEO.

3. Clarify where SLRA Tables 1 and 2 items of discharge concrete structures are located.

4. Discuss the plan to update SLRA OE Section as necessary.

9 B.2.3.34 B-253 The GALL-SLR report states that for 1. Clarify whether the plants with aggressive groundwater/soil Structures Monitoring (pH < 5.5, chlorides > 500 ppm, or program Enhancement No.

sulfates > 1,500 ppm) and/or where the 4(c) shall apply to the concrete structural elements have Inspection of Water-Control experienced degradation, a plant- Structures program.

specific AMP accounting for the extent of the degradation experienced should 2. Describe what plant-be implemented to manage the specific actions will be concrete aging during the subsequent implemented within the AMP period of extended operation. The to ensure and demonstrate GALL Report further notes that this that the AMP will adequately plant-specific AMP may include manage degradations for evaluations, destructive testing, and/or inaccessible areas exposed focused inspections of representative to an aggressive water/soil accessible (leading indicator) or below- environment.

grade, inaccessible concrete structural elements exposed to aggressive Note: it is noted that the groundwater/soil, on an interval not to provided enhancement in exceed 5 years. Structures Monitoring program does not clearly SLRA Structures Monitoring program state the plant-specific Enhancement No. 4(c) provides for

updating the existing procedure and actions that will be other applicable procedure to address implemented.

the aggressive groundwater/soil environment and lists the same action that the GALL-SLR Report recommended for the AMP.

It is also noted that plant-specific program or program actions needs to satisfy the criteria of BTP RLSB-1 (Appendix A.1 of this SRP-SLR).

SLRA B.2.3.34 states that the PSL Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP, with enhancements will be consistent without exception to the 10 elements of NUREG-2191,Section XI.S7. It is unclear how the Inspection of Water-Control program addresses aging effects in the aggressive groundwater/soil environment in order to be consistent with the GALL-SLR report.