ML18115A072

Draft Response on RAI B.1.25-1(Internal Surfaces in Miscellaneous Piping and Ducting Components)

ML18115A072
Person / Time
Site:	River Bend
Issue date:	04/25/2018
From:	Entergy Operations
To:	Wong A NRC/NRR/DMLR/MRPB
Wong A, NRR-DMLR 415-3081
References
Download: ML18115A072 (21)

Text

DRAFT - UNCERTIFIED INFORMATION Question RAI B.1.25 1 (Internal Surfaces in Miscellaneous Piping and Ducting Components)

Background

GALL Report AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR ISG 2012 02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion under Insulation," states parameters monitored or inspected include visible evidence of loss of material in metallic components.

LRA Section B.1.25, Internal Surfaces in Miscellaneous Piping and Ducting Components, states [f]or metallic components, visual inspection will be used to detect evidence of loss of material and reduction of heat transfer and that this new program will be consistent with GALL Report AMP XI.M38, as modified by LR ISG 2012 02.

The LRA (e.g., Table 3.3.2 9, Combustible Gas Control) states that metallic components will be managed for cracking and reduction of heat transfer using the Internal Surfaces in Miscellaneous Piping and Ducting Components program.

Issue It is not clear to the staff that the new Internal Surfaces in Miscellaneous Piping and Ducting Components program will be consistent with GALL Report AMP XI.M38 because GALL Report AMP XI.M38 does not include reduction of heat transfer or cracking in metallic components as aging effects. As a result of these apparent inconsistencies, it appears that the LRA has not included sufficient information with regard to various aging management program elements (e.g., parameters monitored or inspected, detection of aging effects, acceptance criteria) to demonstrate that the reduction of heat transfer and cracking for metallic components will be adequately managed by the new Internal Surfaces in Miscellaneous Piping and Ducting Components program.

Request Clarify whether the new Internal Surfaces in Miscellaneous Piping and Ducting Components program either:

a) will be consistent with the GALL Report AMP XI.M38 and then provide an alternate aging management program to manage reduction of heat transfer and cracking of metallic components, or b) will not be consistent with the GALL Report AMP XI.M38 and then provide the additional information for changes to applicable program elements that demonstrate reduction of heat transfer and cracking of metallic components will be adequately managed Response (revised)

Note: A previous response to RAI B.1.25-1 was submitted by letter RBG-47835, dated March 26, 2018.

The following response compared to the previously submitted response in letter RBG-47835 is verbatim with the exception of a deleted line item in LRA Table 3.3.2-13. The deleted line item addressed stainless steel manifolds managed for cracking using the Internal Surfaces in Miscellaneous Piping and Ducting Components Program. This line item was previously deleted in response to RAI B.1.17-2 by letter RBG-47834, dated March 8, 2018 and was inadvertently included in the original response to this DRAFT - UNCERTIFIED INFORMATION Page 1 of 21

DRAFT - UNCERTIFIED INFORMATION RAI. The following response supersedes the previous response submitted by letter RBG-47835.

The River Bend Station (RBS) Internal Surfaces in Miscellaneous Piping and Ducting Components (ISMPDC)

Program will be consistent with the GALL Report AMP XI.M38 as stated in LRA Section B.1.25. Line items in LRA Section 3 tables specifying aging effects of reduction of heat transfer and cracking of metallic components managed by the ISPMDC program are changed to specify that aging effects will be managed by the Periodic Surveillance and Preventive Maintenance Program described in LRA Section B.1.34. In addition, LRA Section A.1.25 and Section B.1.25 are revised to remove reduction of heat transfer and cracking as applicable aging effects for the ISMPDC program.

Changes to LRA Section 3 and Appendix A and B programs follow with additions underlined and deletions lined through.

3.3.2.1.7 Fire Protection - Water System Aging Management Programs The following aging management programs manage the aging effects for the fire protection - water system components.

• Bolting Integrity

• Buried and Underground Piping and Tanks Inspection

• Coating Integrity

• Diesel Fuel Monitoring

• External Surfaces Monitoring

• Fire Water System

• Internal Surfaces in Miscellaneous Piping and Ducting Components

• One-Time Inspection

• Periodic Surveillance and Preventive Maintenance

• Selective Leaching

• Water Chemistry Control - Closed Treated Water Systems 3.3.2.1.9 Combustible Gas Control System Aging Management Programs The following aging management programs manage the aging effects for the combustible gas control system components.

• Bolting Integrity

• External Surfaces Monitoring

• Internal Surfaces in Miscellaneous Piping and Ducting Components

• Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 2 of 21

DRAFT - UNCERTIFIED INFORMATION 3.3.2.1.11 HPCS Diesel Generator System Aging Management Programs The following aging management programs manage the aging effects for the HPCS diesel generator system components.

• Bolting Integrity

• External Surfaces Monitoring

• Internal Surfaces in Miscellaneous Piping and Ducting Components

• Oil Analysis

• One-Time Inspection

• Periodic Surveillance and Preventive Maintenance

• Selective Leaching

• Water Chemistry Control - Closed Treated Water Systems 3.3.2.1.12 Control Building HVAC System Aging Management Programs The following aging management programs manage the aging effects for the control building HVAC system components.

• Bolting Integrity

• Buried and Underground Piping and Tanks Inspection

• External Surfaces Monitoring

• Internal Surfaces in Miscellaneous Piping and Ducting Components

• Periodic Surveillance and Preventive Maintenance

• Water Chemistry Control - Closed Treated Water Systems 3.3.2.1.13 Miscellaneous HVAC Systems Aging Management Programs The following aging management programs manage the aging effects for the miscellaneous HVAC systems components.

• Bolting Integrity

• External Surfaces Monitoring

• Internal Surfaces in Miscellaneous Piping and Ducting Components

• Periodic Surveillance and Preventive Maintenance

• Service Water Integrity

• Water Chemistry Control - Closed Treated Water Systems DRAFT - UNCERTIFIED INFORMATION Page 3 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.1 Summary of Aging Management Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Table 3.3.1: Auxiliary Systems Further Item Aging Effect/ Aging Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.3.1-42 Copper alloy, Reduction of heat Chapter XI.M20, Open-Cycle No The heat exchangers of the RBS titanium, stainless transfer due to Cooling Water System service water system covered by NRC steel heat exchanger fouling GL 89-13 use closed cycle cooling tubes exposed to water rather than raw water.

raw water Reduction of heat transfer for stainless steel and copper alloy heat exchanger tubes in the fire protection system and stainless steel heat exchanger plates in portionsof the service water system not covered by NRC GL 89-13 is managed by the Internal Surfaces in Miscellaneous Piping and Ducting ComponentsPeriodic Surveillance and Preventive Maintenance Program.

There are no titanium heat exchanger tubes exposed to raw water in the auxiliary systems in the scope of license renewal.

DRAFT - UNCERTIFIED INFORMATION Page 4 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.1: Auxiliary Systems Further Item Aging Effect/ Aging Management Evaluation Number Component Mechanism Programs Recommended Discussion 3.3.1-83 Stainless steel diesel Cracking due to Chapter XI.M38, "Inspection of No Consistent with NUREG-1801.

engine exhaust stress corrosion Internal Surfaces in Cracking of stainless steel diesel piping, piping cracking Miscellaneous Piping and engine exhaust components is components, and Ducting Components" managed by the Internal Surfaces in piping elements Miscellaneous Piping and Ducting exposed to diesel ComponentsPeriodic Surveillance and exhaust Preventive Maintenance Program.

DRAFT - UNCERTIFIED INFORMATION Page 5 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-3 Service Water System Summary of Aging Management Evaluation Table 3.3.2-3: Service Water System Aging Effect Aging Component Intended Requiring Management NUREG-1801 Table 1 Type Function Material Environment Management Programs Item Item Notes Heat exchanger Heat transfer Stainless steel Raw water (int) Reduction of heat Internal Surfaces VII.C1.AP-187 3.3.1-42 E (plates) transfer in Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 6 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-7 Fire Protection - Water System Summary of Aging Management Evaluation Table 3.3.2-7: Fire Protection - Water System Aging Effect Aging Component Intended Requiring Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Heat Heat transfer Copper alloy Raw water Reduction of heat Internal Surfaces VII.C1.A-72 3.3.1-42 E exchanger (ext) transfer in Miscellaneous (tubes) Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 7 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-9 Combustible Gas Control System Summary of Aging Management Evaluation Table 3.3.2-9: Combustible Gas Control System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Coil Heat transfer Stainless Air - indoor Reduction of heat Internal Surfaces in -- -- G steel (ext) transfer Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Piping Pressure Stainless Condensation Cracking Internal Surfaces in -- -- H boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Tubing Pressure Stainless Condensation Cracking Internal Surfaces in -- -- H boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 8 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-9: Combustible Gas Control System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Valve body Pressure Stainless Condensation Cracking Internal Surfaces in -- -- H boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Table 3.3.2-10 Standby Diesel Generator System Summary of Aging Management Evaluation Table 3.3.2-10: Standby Diesel Generator System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Expansion joint Pressure Stainless Exhaust gas Cracking Internal Surfaces in VII.H2.AP-128 3.3.1-83 AE boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 9 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-10: Standby Diesel Generator System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Heat exchanger Heat transfer Copper Air - indoor Reduction of Internal Surfaces in -- -- G (tubes) alloy (ext) heat transfer Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Piping Pressure Stainless Exhaust gas Cracking Internal Surfaces in VII.H2.AP-128 3.3.1-83 AE boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 10 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-11 HPCS Diesel Generator System Summary of Aging Management Evaluation Table 3.3.2-11: HPCS Diesel Generator System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Expansion joint Pressure Stainless Exhaust gas Cracking Internal Surfaces in VII.H2.AP-128 3.3.1-83 AE boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Heat exchanger Heat transfer Aluminum Air - indoor Reduction of Internal Surfaces in -- -- G (fins) (ext) heat transfer Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Heat exchanger Heat transfer Copper alloy Air - indoor Reduction of Internal Surfaces in -- -- G (tubes) (ext) heat transfer Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 11 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-11: HPCS Diesel Generator System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Piping Pressure Stainless Exhaust gas Cracking Internal Surfaces in VII.H2.AP-128 3.3.1-83 AE boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Table 3.3.2-12 Control Building HVAC System Summary of Aging Management Evaluation Table 3.3.2-12: Control Building HVAC System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Accumulator Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 12 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-12: Control Building HVAC System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Filter housing Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Flex hose Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Heat Heat transfer Aluminum Condensation Reduction of Internal Surfaces in -- -- G exchanger (ext) heat transfer Miscellaneous Piping (fins) and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 13 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-12: Control Building HVAC System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Heat Heat transfer Copper alloy Condensation Reduction of Internal Surfaces in -- -- G exchanger (ext) heat transfer Miscellaneous Piping (tubes) and Ducting Components Periodic Surveillance and Preventive Maintenance Sight glass Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Tubing Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 14 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-12: Control Building HVAC System Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Valve body Pressure Stainless Air - outdoor Cracking Internal Surfaces in -- -- G boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Table 3.3.2-13 Miscellaneous HVAC System Summary of Aging Management Evaluation Table 3.3.2-13: Miscellaneous HVAC Systems Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Heat Heat transfer Aluminum Air - outdoor Reduction of Internal Surfaces in -- -- H exchanger (ext) heat transfer Miscellaneous Piping and (fins) Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 15 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-13: Miscellaneous HVAC Systems Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Heat Heat transfer Aluminum Condensation Reduction of Internal Surfaces in -- -- G exchanger (ext) heat transfer Miscellaneous Piping and (fins) Ducting Components Periodic Surveillance and Preventive Maintenance Heat Heat transfer Copper alloy Air - outdoor Reduction of Internal Surfaces in -- -- G exchanger (ext) heat transfer Miscellaneous Piping and (tubes) Ducting Components Periodic Surveillance and Preventive Maintenance Heat Heat transfer Copper alloy Condensation Reduction of Internal Surfaces in -- -- G exchanger (ext) heat transfer Miscellaneous Piping and (tubes) Ducting Components Periodic Surveillance and Preventive Maintenance Heat Heat transfer Stainless Air - indoor Reduction of Internal Surfaces in -- -- G exchanger steel (int) heat transfer Miscellaneous Piping and (tubes) Ducting Components Periodic Surveillance and Preventive Maintenance Table 3.3.2-16 Plant Drains Summary of Aging Management Evaluation DRAFT - UNCERTIFIED INFORMATION Page 16 of 21

DRAFT - UNCERTIFIED INFORMATION Table 3.3.2-16: Plant Drains Aging Effect Component Intended Requiring Aging Management NUREG-1801 Table 1 Type Function Material Environment Management Program Item Item Notes Piping Pressure Stainless Waste water Cracking Internal Surfaces in -- -- H boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance Valve body Pressure Stainless Waste water Cracking Internal Surfaces in -- -- H boundary steel (int) Miscellaneous Piping and Ducting Components Periodic Surveillance and Preventive Maintenance DRAFT - UNCERTIFIED INFORMATION Page 17 of 21

DRAFT - UNCERTIFIED INFORMATION A.1.25 Internal Surfaces in Miscellaneous Piping and Ducting Components The Internal Surfaces in Miscellaneous Piping and Ducting Components Program manages cracking, loss of material, reduction of heat transfer, and change in material properties using representative sampling and opportunistic visual inspections of the internal surfaces of metallic and elastomeric components in environments of air - indoor, air - outdoor, condensation, exhaust gas, raw water, and waste water. Internal inspections will be performed during periodic system and component surveillances or during the performance of maintenance activities when the surfaces are accessible for visual inspection.

Where practical, the inspections will focus on the bounding or leading components most susceptible to aging because of time in service and severity of operating conditions. At a minimum, in each 10-year period during the period of extended operation, a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population will be inspected. Opportunistic inspections will continue in each period even if the minimum sample size has been inspected.

For metallic components, visual inspection will be used to detect evidence of loss of material and reduction of heat transfer. For non-metallic components, visual inspections will be used to detect surface irregularities.

Visual examinations of elastomeric components will be accompanied by physical manipulation or pressurization such that changes in material properties are readily observable. The sample size for physical manipulation will be at least 10 percent of accessible surface area.

A.1.34 Periodic Surveillance and Preventive Maintenance Credit for program activities has been taken in the aging management review for the following components.

• Inspect the internal surfaces of abandoned equipment in the following nonsafety-related systems affecting safety-related systems to manage loss of material:

Leak detection system (system code 207)

Makeup water system (system code 659)

Fuel pool cooling system (system code 602)

Reactor water cleanup system (system code 601)

Standby service water system (system code 256)

Process radiation monitoring system (system code 511)

Floor and equipment drains system (system code 609)

• For metallic components, visually inspect components in the following systems to detect evidence of reduction of heat transfer.

Service water system DRAFT - UNCERTIFIED INFORMATION Page 18 of 21

DRAFT - UNCERTIFIED INFORMATION Fire protection - water system Combustible gas control system Standby diesel generator system HPCS diesel generator system Control building HVAC system Miscellaneous HVAC systems

• For metallic components, visually inspect components in the following systems, and when appropriate, perform surface examinations, to detect evidence of cracking.

Combustible gas control system Standby diesel generator system HPCS diesel generator system Control building HVAC system Plant drains system B.1.25 Internal Surfaces in Miscellaneous Piping and Ducting Components Program Description The Internal Surfaces in Miscellaneous Piping and Ducting Components Program is a new program that will manage cracking, loss of material, reduction of heat transfer, and change in material properties using representative sampling and opportunistic visual inspections of the internal surfaces of metallic and elastomeric components in environments of air - indoor, air - outdoor, condensation, exhaust gas, raw water, and waste water. Internal inspections will be performed during periodic system and component surveillances or during the performance of maintenance activities when the surfaces are accessible for visual inspection.

Where practical, the inspections will focus on the bounding or leading components most susceptible to aging because of time in service and severity of operating conditions. At a minimum, in each 10-year period during the period of extended operation, a representative sample of 20 percent of the population (defined as components having the same combination of material, environment, and aging effect) or a maximum of 25 components per population will be inspected. Opportunistic inspections will continue in each period even if the minimum sample size has been inspected.

For metallic components, visual inspection will be used to detect evidence of loss of material and reduction of heat transfer. For non-metallic components, visual inspections will be used to detect surface irregularities.

Visual examinations of elastomeric components will be accompanied by physical manipulation or DRAFT - UNCERTIFIED INFORMATION Page 19 of 21

DRAFT - UNCERTIFIED INFORMATION pressurization such that changes in material properties are readily observable. The sample size for physical manipulation will be at least 10 percent of accessible surface area.

B.1.34 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE Credit for program activities has been taken in the aging management review for the following systems and structures.

Nonsafety-related Visually inspect the internal surfaces of floor and equipment systems affecting drains system (system code 609) abandoned piping safety-related components to manage loss of material.

systems (continued)

Service water For metallic components, visually inspect components to system detect evidence of reduction of heat transfer.

Fire protection -

water system Combustible gas control system Standby diesel generator system HPCS diesel generator system Control building HVAC system Miscellaneous HVAC systems Combustible gas For metallic components, visually inspect components, and control system when appropriate, perform surface examinations, to detect Standby diesel evidence of cracking.

generator system HPCS diesel generator system Control building HVAC system Plant drains system Evaluation

4. Detection of Aging Effects DRAFT - UNCERTIFIED INFORMATION Page 20 of 21

DRAFT - UNCERTIFIED INFORMATION Periodic surveillances and preventive maintenance activities provide for component inspections to detect aging effects. Inspection intervals provide timely detection of degradation prior to loss of intended functions. Established inspection methods to detect aging effects of loss of material, and cracking, and reduction of heat transfer include visual inspections, and when appropriate, surface examinations for metallic components. Inspection of elastomeric materials to detect cracking and change in material properties includes visual inspections while manually flexing the component. Manipulation of any specific elastomeric component includes at least 10 percent of available surface area, including visually identified suspect areas.

DRAFT - UNCERTIFIED INFORMATION Page 21 of 21