ML24309A167
| ML24309A167 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/04/2024 |
| From: | Vaughn Thomas NRC/NRR/DNRL/NLRP |
| To: | |
| References | |
| Download: ML24309A167 (1) | |
Text
1 REQUEST FOR CLARIFICATION INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PERRY UNIT 1 LICENSE RENEWAL APPLICATION REVIEW (SAFETY)
ENERGY HARBOR NUCLEAR GENERATION LLC PERRY, UNIT 1 DOCKET NO. 05000440 ISSUE DATE: 11/04/2024 ESEB RCI-10395-R1 Request for Confirmation - Question 1 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.
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Background===
LRA Tables 3.5.2-1 through 3.5.2-4, as modified by LRA Supplement 3 (ML24206A150), provide the results of component, material, environment, and aging effect combinations requiring aging management and associated aging management programs for containments, structures, and component supports. The staff noted that aging mechanisms for non-GALL items citing plant specific notes (i.e., G, H, and J) in LRA Tables 3.5.2-1 through 3.5.2-4 are not provided. The staff reviewed LRPY-CAMP-001, Structural Material/Environment/Aging Effect Bases Report -
Rev.6 on the Portal and EPRI report 1015078, Plant Support Engineering: Aging Effects for Structures and Structural Components (Structural Tools), which describe aging effects/aging mechanisms for the structural aging management review items (AMRs). The staff summarized aging mechanisms for the non-GALL items and noted that their aging effects are managed by the Structures Monitoring program, in the following table.
Component Type Material Environmen t
Aging Effect Requiring Management Aging Management Programs Notes Aging Mechanism Structural bolting 2 (Table 3.5.2-4, item 344)
High strength steel Treated water (Ext)
Cracking Structures Monitoring G, 512 Stress Corrosion Cracking (SCC)
Structural bolting 2 (Table 3.5.2-4, item 345)
High strength steel Treated water (Ext)
Loss of Material Structures Monitoring G, 519 General corrosion/pitting corrosion
2 Structural bolting (Table 3.5.2-4, item 333)
High strength steel Raw water (Ext)
Cracking Structures Monitoring G, 535 SCC Structural bolting (Table 3.5.2-4, item 334)
High strength steel Raw water (Ext)
Loss of Material Structures Monitoring G, 536 MIC, general corrosion, galvanic corrosion
- Culvert, major stream (Table 3.5.2-3, item 15)
Galvanized steel Raw water (Int)
Loss of Material Structures Monitoring G, 539 General corrosion Culvert, major stream (Table 3.5.2-3, item 16)
Galvanized steel Soil (Ext)
Loss of Material Structures Monitoring G, 539 General corrosion/galvanic corrosion/MIC Scupper cover (Roof)
(Table 3.5.2-2, item 193)
Stainless steel Air - outdoor (Ext)
Cracking Structures Monitoring H, 501 SCC Scuppers (Roof)
(Table 3.5.2-2, item 199)
Stainless steel Air - outdoor (Ext)
Cracking Structures Monitoring H, 501 SCC Conduit caps (Table 3.5.2-4, item 77)
Polymer Air - indoor, uncontrolled (Ext)
Loss of Strength Structures Monitoring H, 518 Loss of mechanical rigidity due to high temperature, UV, ozone or ionizing radiation exposure.
Anchorage/embedment s
(Table 3.5.2-4, item 19)
Steel Raw water (Ext)
Cracking Structures Monitoring H, 519 Hydrogen damage Structural bolting (Table 3.5.2-4, item 341)
Steel Raw water (Ext)
Cracking Structures Monitoring H, 519 SCC Penetration Sealant Flood (Table 3.5.2-4, item 267)
Elastomer Raw water (Ext)
Cracking Structures Monitoring H, 524 Delamination/Shri nkage Roof membrane1 (Table 3.5.2-4, item 285)
Elastomer Raw water (Ext)
Cracking Structures Monitoring H, 524 Delamination/Shri nkage Waterproofing Membranes (Table 3.5.2-4, item 354)
Elastomer Soil (Ext)
Cracking Structures Monitoring H, 524 Delamination/Shri nkage Waterproofing Membranes1 (Table 3.5.2-4, item 355)
Elastomer Raw water (Ext)
Cracking Structures Monitoring H, 524 Delamination/Shri nkage Sliding support (Table 3.5.2-4, item 315)
Lubrite/
Fluorogold Air - indoor, uncontrolled (Ext)
Change in Material Properties Structures Monitoring H, 525 Irradiation Waterproofing Membranes (Table 3.5.2-4, item 353)
Elastomer Concrete (Int)
Cracking Structures Monitoring H, 527 Delamination/Shri nkage Storm Drain (Table 3.5.2-4, item 322)
Steel Raw water (Int)
Flow Blockage Structures Monitoring H, 530 Debris accumulation Storm Drain1 (Table 3.5.2-4, item 325)
Polymer Raw water (Int)
Flow Blockage Structures Monitoring H, 530 Debris accumulation Culvert, major stream (Table 3.5.2-3, item 14)
Galvanized steel Raw water (Int)
Flow Blockage Structures Monitoring H, 530 Debris accumulation Storm Drain3 (Table 3.5.2-4, item 326)
Concrete Raw water (Int)
Flow Blockage Structures Monitoring H, 530 Debris accumulation Storm Drain3 (Table 3.5.2-4, item 328)
Concrete Soil (Ext)
Loss of Material Structures Monitoring H, 531 Corrosion of embedded steel reinforcing,
3 reaction with aggregates Storm Drain3 (Table 3.5.2-4, item 327)
Concrete Raw Water (Int)
Loss of Material Structures Monitoring H, 531 Corrosion of embedded steel reinforcing, reaction with aggregates Roof scupper (Table 3.5.2-4, item 286)
Aluminum Air - outdoor (Ext)
Cracking Structures Monitoring H, 534 SCC Upper containment pool gates seals1 (Table 3.5.2-1, item 173)
Elastomer Treated water (Ext)
Cracking Structures Monitoring H, 537 Delamination/Shri nkage Shielding (Table 3.5.2-4, item 314)
Unimpregnate d fiberglass fabric; Fiberglass fabric impregnated with elastomer Air - indoor, uncontrolled (Ext)
Change in Material Properties and Cracking Structures Monitoring J, 523 Ionizing radiation For anchorage/embedments (LRA Table 3.5.2-4, AMR item 19), the staff noted in LRPY-CAMP-001 (page 56) that hydrogen damage is a potential aging mechanism, but it was screened out as hydrogen damage was not an aging mechanism of concern for most structural steel materials of low yield strength.
For sliding support (Table 3.5.2-4, AMR item 315), the staff noted in LRPY-CAMP-001 (page 40) that irradiation is a potential aging mechanism for Lubrite/ Fluorogold but the staff further noted that this aging effect was not applicable to Lubrite.
- 1. Confirm the aging mechanisms identified in the last column of the table above for each Table 2 line item.
- 2. Confirm that hydrogen damage is not an applicable aging mechanism for this material/environment combination of AMR item 19 in LRA Table 3.5.2-4 and no aging effects/aging management program are needed for anchorage/embedments in this line item.
- 3. Confirm that irradiation is not an applicable aging mechanism for Lubrite of AMR item 315 in LRA Table 3.5.2-4 and no aging effects/aging management program are needed for Lubrite sliding support in this line item.
Request for Confirmation - Question 2 Regulatory Basis Part 54 of Title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants, is designed to elicit application information that will enable the NRC staff to perform an adequate safety review and the Commission to make the necessary findings. Reliability of application information is important and advanced by requirements that license applications be submitted in writing under oath or affirmation and that information provided to the NRC by a license renewal applicant or required to be maintained by NRC regulations be complete and accurate in all material respects. Information that must be submitted in writing under oath or affirmation includes the technical information required under 10 CFR 54.21(a) related to assessment of the aging effects on structures, systems, and components subject to an aging management review. Thus, both the general submission requirements for license renewal applications and the specific technical application information
4 requirements require that submission of information material to NRCs safety findings (see 10 CFR 54.29 standards for issuance of a renewed license) be submitted by an applicant as part of the application.
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Background===
SRP-LR Table 1 AMR item 3.5.1-57, states that constant and variable load spring hangers; guides; stops components for loss of mechanical function due to corrosion, distortion, dirt, overload, fatigue due to vibratory and cyclic thermal loads aging effects to be managed by GALL Report AMP XI.S3, ASME Section XI, Subsection IWF. The LRA states that the applicable ASME Code for the current (fourth) 10-year inspection interval for PNPP, which commenced May 18, 2019, and expires on May 17, 2029, is ASME XI, 2013 Edition, as modified by 10 CFR 50.55a or relief granted in accordance with 10 CFR 50.55a.
ASME Section XI, 2013 Code Edition provides requirements in:
IWA-2213, for VT-3 Examination. It states, VT-3 includes examination for conditions that could affect operability or functional adequacy of constant load and spring-type supports.
IWF-2500, for Examination Requirements. It states, The following shall be examined in accordance with Table IWF-2500-1 (F-A): (d) clearances of guides and stops, alignment of supports, and assembly of support items; (e) hot or cold settings of spring supports and constant load supports.
IWF-3410, for Acceptance Standards - Component Support Structural Integrity. It states,
"(a) Component support conditions which are unacceptable for continued service shall include the following: (1) deformations or structural degradations of fasteners, springs, clamps, or other support items; (4) improper hot or cold settings of spring supports and constant load supports; (6) improper clearances of guides and stops.
Mandatory Appendix VI Supplements, for 6.0 Visual Examination of Components Supports includes: (c) Hangers; (d) Variable spring type supports; (e) Restraints; (g) Guides and stops; (h) Vibration control and sway braces.
LRA Section B.2.5, ASME Section XI, Subsection IWF Program discusses Operating Experience related to various types of springs (e.g., variable, hangers, cans). AMP Basis Document discusses in program elements: (a) Parameters Monitored/Inspected, VT-3 Examinations of spring type supports for conditions such aging effects as debris, corrosion, wear that could affect operability or functional adequacy of spring type supports; (b)
Acceptance Criteria, conformance to ASME Section XI, Subsection Code requirements; and (c) Operating Experience OE discussed in LRA Section B.2.5. By letter dated July 24, 2024, Supplement 3 (ML24206A150) PNPP revised the LRA Table 1 AMR Item 3.5.1-57 to state: Not Applicable - Loss of mechanical function in sliding supports is managed by Structures Monitoring Program.
Request Confirm that the Supplement 3 revision to Table 1 AMR Item 3.5.1-57 as not applicable is an oversight and that constant and variable load spring hangers; guides; stops will be age managed consistent with GALL-LR by ASME Section XI, Subsection IWF Program AMP as originally reported in PNPP LRA Table 3.5.1 Summary of Aging Management Evaluations for Containments, Structures and Component Supports, Item Number 3.5.1-57.