ML021920518
| ML021920518 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 07/11/2002 |
| From: | Kuo P Division of Regulatory Improvement Programs |
| To: | Alexis Nelson Nuclear Energy Institute |
| Kang P, NRR-RLEP, 415-2279 | |
| References | |
| Download: ML021920518 (6) | |
Text
July 11, 2002Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
STAFF COMMENTS TO INDUSTRY RESPONSE ON "PROPOSED STAFFGUIDANCE ON AGING MANAGEMENT OF FIRE PROTECTION SYSTEMS FOR LICENSE RENEWAL"
Dear Mr. Nelson:
By letter dated June 17, 2002, the Nuclear Energy Institute's (NEI) provided the industryresponse to the proposed staff guidance on aging management of fire protection systems for license renewal. The Nuclear Regulatory Commission staff has reviewed the NEI's response.
The staff has enclosed their comments and questions to the NEI's response. For each NEI's proposed revision shown in bold letters in the enclosure, the staff provided their comments and questions. The staff would like to discuss the enclosed staff comments during the upcoming public meeting, that is scheduled on July 25, 2002, as a meeting agenda item.Once the enclosed comments are resolved for the subject fire protection systems, it is alsopossible that comparable changes might need to be made to NEI 95-10, Revision 3, "Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule."
If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.Sincerely, Original Signed By: SSLeeforPao-Tsin Kuo, Program DirectorLicense Renewal and Environmental ImpactsDivision of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690
Enclosure:
As stated cc w/encl: See next page July 11, 2002Mr. Alan Nelson Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
STAFF COMMENTS TO INDUSTRY RESPONSE ON "PROPOSED STAFFGUIDANCE ON AGING MANAGEMENT OF FIRE PROTECTION SYSTEMS FOR LICENSE RENEWAL
"
Dear Mr. Nelson:
By letter dated June 17, 2002, the Nuclear Energy Institute
's (NEI) provided the industryresponse to the proposed staff guidance on aging management of fire protection systems for license renewal. The Nuclear Regulatory Commission staff has reviewed the NEI
's response. The staff has enclosed their comments and questions to the NEI
's response. For each NEI
'sproposed revision shown in bold letters in the enclosure, the staff provided their comments and questions. The staff would like to discuss the enclosed staff comments during the upcoming public meeting, that is scheduled on July 25, 2002, as a meeting agenda item.Once the enclosed comments are resolved for the subject fire protection systems, it is alsopossible that comparable changes might need to be made to NEI 95-10, Revision 3, "IndustryGuidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule.
" If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.Sincerely, Original Signed By: SSLeeforPao-Tsin Kuo, Program DirectorLicense Renewal and Environmental ImpactsDivision of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690
Enclosure:
As stated cc w/encl: See next pageDISTRIBUTION
- See next page Accession no: ML021920518*See previous concurrenceC:\ORPCheckout\FileNET\ML021920518.wpd *see previous concurrenceOFFICENSE:RLEP:DRIPLASC:RLEP:DRIPPD:RLEP:DRIPNAMEPKang*EHylton*SLee*PTKuo*(SSLee for)DATE 7/9/02 7/8/02 7/8/02 7/11/02OFFICIAL RECORD COPY A. Nelson3DISTRIBUTION
- HARD COPY RLEP RFE. HyltonE-MAIL:PUBLICJ. Johnson W. Borchardt D. Matthews F. Gillespie RidsNrrDe R. Barrett E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski H. Nieh G. Holahan H. Walker S. Black B. Boger D. Thatcher G. Galletti C. Li J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis T. Kobetz RLEP Staff
A. ThadaniC. Julian R. Gardner M. Farber M. Modes J. Vora Enclosure Staff Comments and Questions1. NRC Staff Position on Aging Management of Fire Protection SystemsTherefore, the staff recommends that a non-intrusive means of evaluating wall thickness,such as a volumetric inspection, or plant maintenance visual inspections may be used to detect this aging effect. Are plant maintenance visual inspections the same as work control programs that would requirethe licensee to visually look internally into the pipe, and evaluate and track pipe thickness/conditions? How are these plant maintenance visual inspections comparable to thevolumetric inspections recommended by the NRC staff?National Fire Protection Association (NFPA) 25, 1999 Edition, Section 2.3.3.1, "Sprinklers,"states that "where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing." NFPA 25 also contains guidance to perform this sampling every 10 years after the initial field service testing. This part of the sentence needs to also be moved to NEI
's proposed revision section "2. StaffPosition for Testing Period of Sprinkler Heads
" so that it remains consistent. Therefore, the staff is recommending that in addition to a baseline wall thicknessevaluation/inspection of the fire protection piping before exceeding the current license term, the applicant shall perform pipe wall thickness evaluations/inspections at 10-year intervals during the period of extended operation.Now that the sprinkler head examination has been decoupled from the piping inspection, what isthe basis of the 10 year intervals? Initially, the staff based the 10 year UT inspections on the frequency of the sprinkler head inspections since the piping would be opened up. More frequent inspections (i.e., less than 10 years) may be needed based on the specific plant operating experience with regard to the fire protection piping. According to NFPA 25, 2002, edition, Chapter 13, conditions such as pinhole leaks, and plugged sprinklers may necessitate more frequent inspections and UT inspections as a part of corrective actions.As part of these inspections, applicants need to be sensitive to wall thickness to ensureagainst catastrophic failure and the inner diameter...The last part of this sentence should remain. The interior surface of the pipe is important to theflow characteristics of the pipe. The inspections will not manage flow, but ensure that the interior condition of the pipe has not been degraded by MIC, corrosion, or biofouling, which could ultimately prevent sprinkler actuation.
- 22. XI.M26 FIRE PROTECTIONParameters Monitored/Inspected:
Typically, hollow metal fire doors are visually inspected to verify integrity of door surfacesand for clearances. These inspections of fire doors are performed daily, weekly, and/or semiannually (which may be plant specific). This was not discussed during the public meeting and no justification is provided for removal of thefrequencies and functional testing of fire door in this section. Detection of Aging Effects: Visual inspection of penetration seals detects cracking, sealseparation from walls and components, and rupture and puncture of seals. Visual inspection (VT-1 or equivalent) of approximately 10% of each type of seal in walkdowns is performed at least once every refueling outage. If any sign of degradation is detected within that sample, the scope of the inspection is expanded to include additional seals.The NEI revision only includes discussion to expand the scope of the inspection and eliminates theincrease in "frequency," as originally stated in GALL. This was not discussed in the public meetingas an issue that needed to be changed. Also the sentence stating...
"to ensure the timely detectionof increased hardness and shrinkage....
", which NEI deleted, should remain. The staff finds that the actions described in the fire barrier inspection, as presented in GALL,should be routinely performed to provide reasonable assurance that penetration seals will be monitored for aging in accordance with GALL during the license renewal period. In NUREG-1552, "Fire Barrier Penetration Seals in Nuclear Power Plants," (which incorporates the findings fromSECY-96-146) it discusses how some shrinkage is normal and acceptable for fire protection based on Dow Corning guidelines, who is a major manufacturer of silicone-based materials. The staffconcluded that normal shrinkage does not have a significant impact on the function and capabilitiesof silicone foam or elastomer as a fire barrier penetration seal material. However, shrinkage could be considered abnormal if it exceeds what is acceptable for fire protection purposes. Furthermore, the AMP is specifically designed to look at several aging effects; including shrinkage which could lead to cracking and separation of seals. Corrective Actions:
All wording under the "corrective actions
" section should remain unchanged. Not all licensee
'sinclude FP in their Appendix B program and would need to include or expand the Appendix Bprogram as a result for FP components. Therefore, the wording should not be revised.
- 33. XI.M27 FIRE WATER SYSTEM Program DescriptionIt is not evident to the NRC staff, why NEI is requesting deletion of the full flow tests from GALL.This was not raised as an issue in the public meeting and no basis is given for the deletion.
Guidance on how to conduct full flow tests is provided in Annexes A and D of Chapter 13 in NFPA 25 (2002 edition). The purpose of the full flow testing and the wall thickness evaluations is to ensure that lossof material and flow blockage aging effects are managed such that the system function is maintained. NEI revised this sentence to include flow blockage and to delete "MIC, corrosion, and biofouling.
"Flow blockage is not an aging effect. The sentence should not be changed. Preventive Actions: To ensure no significant corrosion, MIC, or biofouling has occurred inwater-based fire protection systems, periodic flushing, system performance testing, inspections and/or chemical analysis may be conducted. The wording of the NEI revision implies that chemical analysis may be used in place of inspections.The NRC staff does not agree with this change. Detection of Aging Effects: Fire protection system testing is performed to assure requiredpressures. Wall thickness evaluations of fire protection piping The smaller diameter piping was deleted and should remain. The range of volumetric methods andplant maintenance procedures allow each applicant a range of methods to accommodate for inspections of the smaller "branchline
" diameter piping. There is no technical reason to excludesmaller diameter (branchline) piping from an AMR.Acceptance Criteria: The acceptance criteria are (a) the ability of a fire protection systemto maintain required pressure, (b) no unacceptable signs of degradation observed during non-intrusive or visual assessment of internal system conditions, and (c) that no biofouling exists in the sprinkler systems that could cause flow blockage The NEI revision includes flow blockage and deleted corrosion. GALL does not address flowblockage as an aging effect. Corrosion should remain and flow blockage should be taken out. Corrective Actions: All wording under the "corrective actions
" section should remain unchanged. Not all licensee
'sinclude FP in their Appendix B program and would need to include or expand the Appendix Bprogram as a result for FP components. Therefore, the wording should not be revised.
NUCLEAR ENERGY INSTITUTE Project No. 690
cc:Mr. Joe BartellU.S. Department of Energy NE-42 Washington, DC 20585Ms. Christine S. Salembier,Commissioner State Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601Mr. Stephen T. HaleFlorida Power & Light Company 9760 S.W. 344 Street Florida City, Florida 33035Mr. William CorbinVirginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348George WrobelManager, License Renewal R.E.Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519Ronald B. ClaryManager, Plant Life Extension V.C. Summer Nuclear Station Bradham Blvd.
PO Box 88 Jenkinsville, SC 29065Mr. Robert GillDuke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006Mr. Joseph GasperManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, NE 68023-0399Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service
1424 16 th Street, NW, Suite 404Washington, DC 20036Mr. Hugh JacksonPublic Citizen
's Critical Mass Energy &Environment Program 215 Pennsylvania Ave. SE Washington DC 20003Mary OlsonNuclear Information & Resource Service, Southeast Office P.O. Box 7586 Asheville, North Carolina 28802 Talmage ClementsManger - License Renewal Nuclear Engineering Services
CP&L 410 South Wilmington Street Raleigh, NC 27602Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW., Suite 600 Washington, DC 20006-3919