ML22024A023
| ML22024A023 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/20/2022 |
| From: | Angela Wu NRC/NRR/DNRL/NLRP |
| To: | |
| Wu A, 301-415-2995 | |
| Shared Package | |
| ML22024A002 | List:
|
| References | |
| Download: ML22024A023 (10) | |
Text
Oconee Nuclear Station, Units 1, 2, and 3, Subsequent License Renewal Application (SLRA)
Breakout Audit Questions TRP 027: Fire Water System
Section Page 1 3.3 3-726 SLRA Table 3.3.2-4 cites AMR item The NRC staff is seeking VII.G.AP-197, 3.3.1-064 for managing loss clarification on the use of of material and flow blockage of the copper industry standard Note B.
alloy greater than 15 percent zinc valve body exposed internally to raw water by the Fire Water System program. Industry standard Note B is cited. However, this AMR item is for copper alloy piping and piping components exposed to raw water.
Please discuss use of industry standard Note B.
2 A2.16, A-17, Table XI.M27-1 of NUREG-2191 The NRC staff is seeking A6.0, A-82, recommends that the exterior inspections of clarification on the frequency of B2.1.16, B-123, water storage tanks follow NFPA 25 Section the exterior inspections of the 3.3 3-725 9.2.5.5. Section 9.2.5.5 of NFPA 25 water storage tank.
requires the exterior surfaces of water storage tanks and supporting structure be inspected annually for signs of degradation. Note 10 to Table XI.M27-1 states that the testing and inspections can be conducted on a refueling outage interval if plant-specific OE has shown no loss of intended function of the in-scope SSC due to aging effects being managed for the specific component (e.g., loss of material, flow blockage due to fouling).
Enhancement 7 states, Perform external visual inspections of the elevated water
storage tank consistent with Section 9.2.5.5 of NFPA 25, 2011 Edition at least once every two years.
Please discuss the basis for the 2-year frequency of the external visual inspections of the elevated water storage tank.
3 A2.16, A-17, Table XI.M27-1 of NUREG-2191, Volume 2, The NRC staff is seeking A6.0, A-82, recommends that main drain tests follow clarification on the frequency of B2.1.16 B-123 Section 13.2.5 of NFPA 25. Note 10 to the main drain testing and the Table XI.M27-1 of NUREG-2191, Volume 2, additional tests performed when states, testing and inspections can be acceptance criteria not met. The conducted on a refueling outage interval if staff is seeking clarification on plant-specific OE has shown no loss of whether the test-to-test pressure intended function of the in-scope SSC due to monitoring associated with the aging effects being managed for the specific periodic main drain testing will component (e.g., loss of material, flow be compared to the original blockage due to fouling). Section 13.2.5 of acceptance test (or comparable NFPA 25 requires main drain tests to be test result) or will only use the conducted annually at each water-based fire immediately prior test results. In protection system riser to determine whether addition, the staff is seeking there has been a change in the condition of clarification on the basis for not the water supply piping and control valves. currently performing main drain It also states, When there is a 10 percent testing.
reduction in full flow pressure when compared to the original acceptance test or previously performed tests, the cause of the reduction shall be identified and corrected if necessary.
Enhancement 9 states, in part, Perform main drain testing of the deluge system risers at least once every two years. Main drain testing of deluge systems will be performed consistent with the procedure described in Sections 13.2.5 and A.13.2.5 of
NFPA 25, 2011 Edition. When there is a ten percent reduction in full flow pressure when compared to the original acceptance test or previously performed tests, the cause of the reduction shall be identified and corrected if necessary. It also states, If acceptance criteria are not met, at least two additional tests shall be performed within two years.
The NRC staff notes that AMP XI.M27 in GALL-SLR states, The additional inspections are completed within the interval (i.e., 5 years, annual) in which the original tests were conducted.
It is unclear whether the 10 percent pressure reduction criteria for the test-to-test pressure monitoring will be compared to the original acceptance test (or comparable test results) as provided in NFPA 25. The NRC staff notes that if the test-to-test pressure monitoring only uses the immediately prior test result, significant degradation of the fire water system supply over several years would not be identified while still being less than a 10 percent reduction from the previous test.
Section 4.4 of Revision 1 of SLR-ONS-AMPR-XI.M27 states, Main drain testing consistent with Section 13.2.5 of NFPA 25, 2011 Edition is not currently performed at Oconee.
Please discuss the basis for the 2-year frequency of the main drain testing and the additional tests performed when acceptance
criteria are not met. Please clarify whether the test-to-test pressure monitoring associated with the periodic main drain testing will be compared to the original acceptance test (or comparable test result) or will only use the immediately prior test results. In addition, please discuss the basis for not currently performing main drain testing.
4 A2.16, A-17, AMP XI.M42 of GALL-SLR, Internal The NRC staff is seeking B2.1.16 B-123 Coatings/Linings for In-Scope Piping, Piping clarification on whether the Fire Components, Heat Exchangers, and Tanks, Water System program will states when the fire water storage tank include the recommendations on internals are coated, the Fire Water System training and qualification of program and the FSAR Summary personnel from XI.M42 with Description of the Fire Water System regards to managing loss of program should be enhanced to include coating integrity of the internal recommendations from XI.M42 on training coating of the elevated water and qualification of personnel and the storage tank.
corrective actions and acceptance criteria program elements.
SLRA Section A2.16 is the UFSAR Summary Description of the Fire Water System program. Enhancement 10 states that the acceptance criteria and corrective actions for internal inspections of the elevated water storage tank will be in accordance with AMP XI.M42. However, SLRA Section A2.16 does not appear to include the recommendations on training and qualification of personnel. In addition, the NRC staff notes that SLRA Section B2.1.16 and Revision 1 of SLR-ONS-AMPR-XI.M27 do not appear to include the
recommendations on training and qualification of personnel.
Please confirm that the Fire Water System program will include the recommendations on training and qualification of personnel from XI.M42 with regards to managing loss of coating integrity of the internal coating of the elevated water storage tank.
5 A6.0 A-82 The implementation schedule for the Fire The NRC staff is seeking Water System program in Table XI-01 of clarification on the GALL-SLR states, Program is implemented implementation schedule for the and inspections or tests begin 5 years Fire Water System program before the subsequent period of extended commitments.
operation. Inspections or tests that are to be completed prior to the subsequent period of extended operation are completed 6 months prior to the subsequent period of extended operation or no later than the last refueling outage prior to the subsequent period of extended operation.
SLRA Table A6.0-1 states, Program enhancements for SLR will be implemented 6 months prior to the SPEO. Inspections or tests that are to be completed prior to SPEO are completed 6 months prior to the SPEO or no later than the last refueling outage prior to the SPEO.
Please discuss the basis for implementing the program enhancements 6 months prior to SPEO rather than implementing the program and beginning inspections and tests 5 years before the SPEO.
6 B2.1.16 B-123 AMP XI.M27 in GALL-SLR states that The NRC staff is seeking results of flow testing, flushes, and wall clarification on whether results of thickness measurements are monitored and flushes are trended and whether trended. inspection results not entered into the corrective action SLRA Section B2.1.16 states, Flow testing program are trended.
results are reviewed and trended to identify degrading trends prior to loss of system function. Revision 1 of SLR-ONS-AMPR-XI.M27 states that results of flow testing and ultrasonic testing are provided to engineering for evaluation and trending.
However, the NRC staff did not identify information related to trending results of flushes.
The staff also noted that Section 4.5 in Revision 1 of SLR-ONS-AMPR-XI.M27 states, in part, Unacceptable results are documented in the Corrective Action for trending Given this is different from statements related to trending of flow testing and ultrasonic testing results, it is unclear to the NRC staff if trending of inspection results is performed outside of the corrective action program for instances where results are not entered into the corrective action program.
Please clarify whether results of flushes are trended. In addition, please clarify whether inspection results not entered into the corrective action program are trended.
7 3.3 3-715, SLRA Tables 3.3.2-24 and 3.3.2-26 cite The NRC staff is seeking 3-736 AMR items for managing aging effects of fire clarification on the applicable hydrants exposed to raw water, soil, and air. environments the fire hydrants are exposed to.
Please confirm that the fire hydrants in the High Pressure Service Water System and the Keowee Fire Detection/Protection System are not exposed to concrete.
8 B2.1.16 B-127 Table XI.M27-1 of NUREG-2191, Volume 2, The NRC staff is seeking recommends that interior inspections of clarification on vacuum box water storage tanks follow Sections 9.2.6 testing of the elevated water and 9.2.7 of NFPA 25, Standard for the storage tank.
Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems.
Note 4 to Table XI.M27-1 of NUREG-2191, Volume 2, states, Vacuum box testing as stated in Section 9.2.7 (6) is conducted when pitting, cracks, or loss of material is detected in the immediate vicinity of welds.
However, Enhancement 10 does not state whether vacuum box testing will be conducted.
Please clarify whether the elevated water storage tank requires vacuum box testing when pitting, cracks, or loss of material is detected in the immediate vicinity of welds.
9 B2.1.16 B-124 SLRA Section B2.1.16 includes Exception 1 The NRC staff is seeking to the detection of aging effects, related to clarification on when flow testing allowing flow testing at hose connections of other than the hydraulically other than the hydraulically most remote most remote hose station would location. Enhancements 1 and 6 are related be performed.
to flow testing at the hydraulically most remote hose station.
Based on the description of Exception 1 and Enhancements 1 and 6, it appears that the intent of the Fire Water System program is to normally perform flow testing of the hydraulically most remote hose connection.
If the NRC staffs understanding of the intent is correct, then discuss when flow testing of other than the hydraulically most remote hose station would be performed.
10 B2.1.16 B-126 Enhancement 3 in SLRA Section B2.1.16 The NRC staff is seeking states, Perform a one-time volumetric wall clarification on whether the thickness inspection on a representative protocols established in the One-sample deluge system supply piping that is Time Inspection program will be periodically subjected to flow during applicable to the one-time functional testing. The NRC staff did not volumetric wall thickness identify additional details related to the one- inspection on a representative time volumetric wall thickness inspection, sample deluge system supply such as sample size, acceptance criteria, piping that is periodically corrective actions, etc. In addition, the staff subjected to flow during notes that this one-time volumetric wall functional testing.
thickness inspection is not addressed in the Oconee One-Time Inspection program (SLRA Section B2.1.20).
Consistent with AMP XI.M32 in the GALL-SLR, SLRA Section B2.1.20 states that the Oconee One-Time Inspection program includes determination of sample sizes; identification of inspection locations; determination of examination technique, including acceptance criteria; and evaluation of the need for follow-up examinations.
The staff is seeking clarification on whether the protocols established in the One-Time Inspection program will be applicable to the one-time volumetric wall thickness inspection on a representative sample deluge system supply piping that is periodically subjected to flow during functional testing.
11 2.3.3.4.3 2-148 SLRA Section 2.3.3.4.3 states that the The NRC staff is seeking Keowee Fire Detection/Protection System clarification on hose racks and includes hose racks, however, they are not hose reels.
included in SLRA Tables 2.3.3.4-3 and 3.3.2-26. Note 3 to Table 3.1-1, High Pressure Service Water System, and Note 2 to Table 3.3-1, Keowee Fire Detection/Protection System, of SLR-ONS-IPAR-M304 points to SLR-ONS-IPAR-S509 for evaluation of hose racks. The NRC staff notes that the SLRA does not indicate whether the High Pressure Service Water System includes hose racks. SLR-ONS-IPAR-S509 does not appear to explicitly address hose racks.
Section 3.2.23 of OSS0254.00.00-1002 states hose reels are used at Oconee.
However, the SLRA does not include discussion of hose reels.
Please clarify whether the High Pressure Service Water System includes hose racks.
Please clarify what material(s) the hose racks are and where they are addressed in the SLRA? In addition, discuss whether hose reels are used at Oconee, including what material(s) they are and where they are addressed in the SLRA.
12 B2.1.16 B-126 SLRA Section B2.1.16 includes 10 The NRC staff is seeking enhancements to the Fire Water System. clarification on revised or new Only Enhancement 5 notes that inspection procedures related to the procedures are being revised. enhancements.
Please clarify existing procedures will be revised or new procedures developed to
incorporate the enhancements into the program.