ML23355A268

NRC Comments - Comanche Peak LRA Supplement 3 (1)

ML23355A268
Person / Time
Site:	Comanche Peak
Issue date:	12/21/2023
From:	Mark Yoo NRC/NRR/DNRL/NLRP
To:
References
Download: ML23355A268 (2)

Text

NRR/DEX/ESEBs Comments on Comanche Peak LRA Supplement 3 - Enh ancements to the Structures Monitoring program by George Wang

Element 3: Parameters Monitored or Inspected.

• Require periodic inspection and cleaning, including blockage re moval, of the Fuel Transfer Canal and Refueling Cavity tell-tale drains.

Question 1: Explain why the SFP is not included.

• Sample and analyze discharge from the leak chase system for, a t a minimum, flow (drip) rate and the following chemistry parameters: pH, boron concentr ation, and iron content.

Question 2: Clarify how often will the sample be collected. It should be same as inspection frequency per EPRI 2016 technical report. In additio n, clarify whether the sample will be taken for analyses from the boric acid white dep osit on concrete surface, include the following chemistry parameters: pH, boron concentra tion, and iron content if leakage through concrete structure is identified from the SFPs, Fuel Transfer Canals, and Refueling Cavities.

Question 3: Clarify whether an enhancement is needed to perform periodic video probe inspection of tell-tales to check for development of blockages per EPRI 2016 technical report.

Element 4: Detection of Aging Effects

• Inspect for evidence of leakage from the SFP or Fuel Transfer Canal, such as the formation of deposits or wet areas on SFP or Fuel Transfer Cana l structures.

Question 4: Explain why the Refueling Cavities are not included.

• Assess the frequency of inspection and cleaning of the tell-ta le drains to confirm the absence of any blockages.

Question 5: What is the inspection frequency of the tell-tale d rains? The cleaning depends on inspection results.

Question 6: Clarify whether an enhancement is needed per EPRI 2 016 technical report to obtain samples from [describe system configuration that enab les samplingfor example, from each telltale] at least every [inspection frequen cy]. Data for leak rates will be obtained by [describe methodology, for example, collecting d rips from a telltale for a specific time]. Chemistry data will be obtained by [describe an alysis methods; consider expanding to multiple sentences if many parameters are obtained ]

Element 6: Acceptance Criteria

• Develop appropriate acceptance criteria for the parameters tha t are monitored for the SFP leak detection system, including, at a minimum, leak chase system discharge flow (drip) rate, pH, boron concentration, and iron content. Any ind ications of new or increased leakage from the SFP (formation of white crystal depo sits or wet areas) will be documented and evaluated via the CAP.

Question 7: What are acceptance criteria?

Element 7: Corrective Actions

• Clean the Fuel Transfer Canal and Refueling Cavity tell-tale d rains using a rod or brush or by high-pressure cleaning (hydrolasing) if inspection result s indicate that cleaning is necessary.

Question 8: (a). Explain why the SFP is not included; and (b) I f the blockage is found inside the leak chase channel of the SFP, the Fuel Transfer Can al and Refueling Cavity, cleaning tell-tale drains only is not enough, evaluate the enha ncement and revise accordingly.