ML12335A405

Official Exhibit - RIV000014-00-BD01 - Aging Management Program Evaluation Report - Non-Class 1 Mechanical, IP-RPT-06-LRD07, Revision 5, March 18, 2009 (AMP Eval Report Rev 5)

ML12335A405
Person / Time
Site:	Indian Point
Issue date:	03/18/2009
From:	Fronabarger D Entergy Nuclear Operations
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 21600, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12335A405 (10)

Text

United States Nuclear Regulatory Commission Official Hearing Exhibit RIV000014 Entergy Nuclear Operations, Inc. Submitted: December 22, 2011 In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3) EXCERPT ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: RIV000014-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

IPEC00203674

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 7 of 204 TABLE OF CONTENTS 1.0 Introduction .......... ... .... .. .. .. ......... ... .... .. ......... ... ... ..... ........... ... ...... ........... .. ....... ...... 8 2.0 Background ... ..... .. ..... ... ....... .. ... .. ... ... .. .. ...... ... ..... ... ... .... ...... ... .... .... ... .. .... ...... ...... .. 9 3.0 New Programs or Activities Credited in the AMRRs ........... .. ..... ...... ..... .... .... .. .... 12 3.1 Buried Piping and Tanks Inspection Program ...... ...... .... ....... ..... .... ...... .... 12 3.2 One-Time Inspection Program .. ...... ... .. ...... ..... ... ..... .. .... .. ... ... ... ..... ...... ..... 19 3.3 Selective Leaching Program ......... .. .... ..... ...... .. .. ... .... ....... ...... .... .. .... ....... . 26 4.0 Existing Programs or Activities Credited in the AMRRs ....... ............ ................... 33 4.1 Aboveground Steel Tanks .. ....... .......... ... .. ............ .. ... .......... ............... ...... 33 4.2 Bolting Integrity Program ..... .... .. ... .. ... ........... .... ..... .. .... ... .. .... ....... ..... ... .... 40 4.3 Boraflex Monitoring Program ............. ....... .. .......... ..... ..... ..... ..... .... .... ... .... 48 4.4 Boric Acid Corrosion Prevention ......... ..... ............. .. ......... ........... ... .... ...... 55 4.5 Diesel Fuel Monitoring Program ........ .. ..................... ...... .............. ... ........ 62 4.6 External Surfaces Monitoring ... ... ..... ...... ..... .. .. ... .. ..... ....... ..... ..... ..;.... ... .... 75 4.7 Fire Protection Program .. ..... ..... ..... ... ...... ....... .... ... .. ..... ... .... .... ... .. ... ..... .. .. 83 4.8 Fire Water System Program ..................... ... .... ..... .. .... .... .......... .. ..... ........ 96 4.9 Flow-Accelerated Corrosion Program ..... ...... ......... ........ .......... ....... ... .... 106 4.10 Oil Analysis Program ..... ... .... ... ....... .. .. .... ..... ..... ....... ... ....... .. .............. .... 114 4.11 Periodic Surveillance and Preventive Maintenance Program .... ... .. ....... 125 4.12 Service Water Integrity Program ....... ...... ... ............. ... .. ... .......... .. ..... .. .... 132 4.13 Water Chemistry Control - Auxiliary Systems Program .... .......... .. ... ...... 138 4.14 Water Chemistry Control- Primary and Secondary Program ..... .. .... .. ... 143 4.15 Water Chemistry Control- Closed Cooling Water Program ...... ...... .. .... 152 4.16 Boral Surveillance Program ................ ..... .. ........... ...... .............. .. ........ ... 163 4.17 Heat Exchanger Monitoring Program .......... ..... .. ... ....... ... .... .. .. .... .... ....... 168 5.0 Summary and Conclusions .. ... ... ...... .... ... ...... ... ... .. .... ......... .. ....... ... ... ... ... .. ........ 176 Attachment 1 - One-Time Inspection Activities .............. ............... .. ................. ........... 177 Attachment 2 - Periodic Surveillance and Preventive Maintenance Activities ......... .... 186 IPEC00203680

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 106 of 204 Flow-Accelerated Corrosion Program 4.9 Flow-Accelerated Corrosion Program A. Program Description The Flow-Accelerated Corrosion (FAC) Program is compared to the program described in NUREG-1801,Section XI.M17, Flow-Accelerated Corrosion.

The Flow-Accelerated Corrosion Program is an existing program that applies to safety-related and nonsafety-related carbon and low alloy steel components in systems containing high-energy fluids carrying two-phase or single-phase high-energy fluid 2:. 2% of plant operating time.

The program, based on EPRI guidelines in the Nuclear Safety Analysis Center (NSAC)-202L-R3 for an effective flow-accelerated corrosion program, predicts, detects, and monitors FAC in plant piping and other pressure retaining components.

This program includes (a) an evaluation to determine critical locations, (b) limited baseline inspections to determine the extent of thinning at these locations, and (c) follow-up inspections to confirm predictions, or repair or replace components as necessary. The aging effect of loss of material managed by the Flow Accelerated Corrosion Program is equivalent to the aging effect of wall thinning as defined in NUREG-1801 Volume 2 Table IX.E.

This program is credited in the following .

• AMM23, Main Steam Systems

• AMM24, Auxiliary Feedwater Systems

• AMM25, Slowdown Systems

• AMM27, Main Feedwater Systems

• AMM30, Nonsafety-related Systems and Components Affecting Safety-related Systems B. Evaluation

1. Scope of Program

a. NUREG-1801, Scope of Program "The FAC program, described by the EPRI guidelines in NSAC-202L-R2, includes procedures or administrative controls to assure that the structural integrity of all carbon steel lines containing high-energy fluids (two phase as well as single phase) is maintained. Valve bodies retaining pressure in these high-energy systems are also covered by the program. The FAC program was originally outlined in NUREG-1344 and was further described through the Nuclear Regulatory Commission (NRC) Generic Letter (GL) 89-08. A program implemented in accordance with the EPRI guidelines predicts, detects, and monitors FAC in plant piping and other components, such as valve bodies, elbows and expanders. Such a program includes the following IPEC00203779

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 107 of 204 Flow-Accelerated Corrosion Program recommendations: (a) conducting an analysis to determine critical locations, (b) performing limited baseline inspections to determine the extent of thinning at these locations, and (c) performing follow-up inspections to confirm the predictions, or repairing or replacing components as necessary. NSAC-202L-R2 (April 1999) provides general guidelines for the FAC program. To ensure that all the aging effects caused by FAC are properly managed, the program includes the use of a predictive code, such as CHECWORKS, that uses the implementation guidance of NSAC-202L-R2 to satiSfy the criteria specified in 10 CFR Part 50, Appendix B, criteria for development of procedures and control of special processes."

b. Comparison to IPEC Scope of Program This program applies to safety-related and nonsafety-related carbon steel components carrying two-phase or single-phase high-energy fluid ~ 2% of plant operating time. The program, based on the recommendations of the most current revision of EPRI Report NSAC-202L, predicts, detects, and monitors FAC in plant piping and other pressure retaining components. The program includes an evaluation to determine critical locations, baseline inspections to determine the extent of thinning at these locations, and follow-up inspections.

(Ref. Section 5.0, ENN-DC-315)

CHECWORKS, a predictive code that uses the implementation guidance of NSAC-202L-R3 to satisfy the criteria specified in 10 CFR Part 50, Appendix B, is used in this program . Parameter changes due to power uprate are included in the CHECKWORKS model.

(Ref. Section 2.0[5J, ENN-DC-315)

(IP2 Ref. Section 5.1.2,0507148-01; 040711-02)

(IP3 Ref. IP-RPT-05-00407; 040711-01)

IPEC scope is not consistent with NUREG-1801 because IPEC utilizes Rev.

3 of NSAC-202L The differences of Section 4.2 of NSAC-202L, Identifying Susceptible Systems, between Revision 2 and Revision 3 include the following. The guidance of prioritizing the system for evaluation in Section 4.2 .3 of Revision 2 is addressed in Section 4.9 of Revision 3. Section 4.4, Selecting and Scheduling Components for Inspection, of Revision 2 was re-organized in Revision 3. Sample selection for modeled lines and non-modeled lines of Revision 2 was enhanced with more clarification and more details in Revision 3. Guidance for using plant experience and industry experience in selecting inspection locations was added in Revision 3. The basis for sample expansion was clarified in Revision 3. Instead of dividing into selection of initial inspection and follow-up inspections in Revision 2, the guidance in Revision 3 is provided for a given outage including the recommendations for locations of re-inspection.

IPEC00203780

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 108 of 204 Flow-Accelerated Corrosion Program

2. Preventive Actions

a. NUREG-1801. Preventive Actions "The FAC program is an analysis, inspection, and verification program; thus, there is no preventive action. However, it is noted that monitoring of water chemistry to control pH and dissolved oxygen content, and selection of appropriate piping material, geometry, and hydrodynamic conditions, are effective in reducing FAC."

b. Comparison to IPEC Preventive Actions As stated in NUREG-1801 , the FAC program is an analysis, inspection, and verification program; thus, there is no preventive action. Monitoring of water chemistry to control pH and dissolved oxygen content is part of the Water Chemistry Control - Primary and Secondary Program, Section 4.14.

Development of appropriate design changes incorporating improved piping material, geometry, and hydrodynamic conditions are part of the long-term strategy for reduced FAC rates.

(Ret Section 5.15, ENN-DC-315)

IPEC preventive actions are consistent with NUREG-1801 .

3. Parameters Monitored or Inspected

a. NUREG-1801 , Parameters Monitored or Inspected "The aging management program (AMP) monitors the effects of FAC on the intended function of piping and components by measuring wall thickness."

b. Comparison to IPEC Parameters Monitored or Inspected The IPEC program monitors wall thickness to ensure that FAC does not lead to loss of intended function of piping and components.

(Ref. Section 5.5, ENN-DC-315)

IPEC parameters monitored and inspected are consistent with NUREG-1801 .

4. Detection of Aging Effects

a. NUREG-1801, Detection of Aging Effects "Degradation of piping and components occurs by wall thinning. The inspection program delineated in NSAC-202L-R2 consists of identification of susceptible locations as indicated by operating conditions or special considerations. Ultrasonic and radiographic testing is used to detect wall thinning. The extent and schedule of the inspections assure detection of wall thinning before the loss of intended function ."

IPEC00203781

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 109 of 204 Flow-Accelerated Corrosion Program

b. Comparison to IPEC Detection of Aging Effects Non-destructive examinations (e.g. ultrasonic testing and radiography) are used to detect wall thinning at susceptible locations. The extent and schedule of inspections provide reasonable assurance of detection of wall thinning before loss of intended function.

(Ref. Section 5.4, ENN-DC-315)

This program is credited with managing the following aging effects.

• loss of material from internal surfaces of selected carbon steel components (AMM23, 24, 25,27, 30)

IPEC detection of aging effects is not consistent with NUREG-1801 because IPEC utilizes Rev. 3 of NSAC-202L. Clarification of the inspection techniques of UT and RT was added in Section 4.5.1 of Revision 3. There are no changes of the guidance for UT grid. Appendix B was added in Revision 3 to provide guidance for inspection of vessels and tanks. This is beyond the level of detail provided in Revision 2 and in the GALL report. The guidance for inspection of small-bore piping in Appendix A of Revision 2 and of Revision 3 are essentially identical. The guidance for inspection of valves, orifices, and equipment nozzles was enhanced in Section 4.5.2 of Revision 3.

Also, Section 4.5.4 was added for use of RT to inspect large-bore piping, Section 4.5.5 was added for inspection of turbine cross-around piping, and Section 4.5.6 was added for inspection of valves.

5. Monitoring and Trending

a. NUREG-1801, Monitoring and Trending "CHECWORKS or a similar predictive code is used to predict component degradation in the systems conducive to FAC, as indicated by specific plant data, including material, hydrodynamic, and operating conditions.

CHECWORKS is acceptable because it provides a bounding analysis for FAC. CHECWORKS was developed and benchmarked by using data obtained from many plants. The inspection schedule developed by the licensee on the basis of the results of such a predictive code provides reasonable assurance that structural integrity will be maintained between inspections. Inspection results are evaluated to determine if additional inspections are needed to assure that the extent of wall thinning is adequately determined, assure that intended function will not be lost, and identify corrective actions. "

b. Comparison to IPEC Monitoring and Trending The EPRI software program, "CHECWORKS," is used to predict component degradation in FAC susceptible piping . The inspection schedule assures that structural integrity will be maintained between inspections. If degradation is detected such that the measured wall thickness is less than the screening IPEC00203782

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 110 of 204 Flow-Accelerated Corrosion Program criteria wall thickness, additional examinations are performed in adjacent areas to determine extent of degradation. Screening criteria wall thickness is the minimum wall thickness allowed which, based on wear projection, will exceed the minimum acceptable wall thickness at the next inspection. If degradation is detected such that the measured wall thickness is less than the screening criteria wall thickness, additional evaluations or examinations are performed to assure the component's intended function will not be lost and to identify corrective actions.

(Ref. Section 5.8, ENN-NDE-9.05; Section 5.0, ENN-DC-315)

IPEC monitoring and trending are consistent with NUREG-1801 .

6. Acceptance Criteria

a. NUREG-1801. Acceptance Criteria "Inspection results are input for a predictive computer code, such as CHECWORKS, to calculate the number of refueling or operating cycles remaining before the component reaches the minimum allowable wall thickness. If calculations indicate that an area will reach the minimum allowed wall thickness before the next scheduled outage, the component is to be repaired, replaced, or reevaluated."

b. Comparison to IPEC Acceptance Criteria Based on inspection results, CHECWORKS can calculate the wear rate and remaining service life (RSL). RSL is the amount of time remaining based upon an established rate of wear at which time the comoponent is anticipated to reach minimum allowable wall thickness. If RSL calculations indicate that an area will reach minimum allowed thickness before the next scheduled outage, the component is repaired or replaced, inspected more frequently (online inspection is possible) , or reevaluated.

(Ref. Section 5.0, ENN-DC-315)

Screening criteria wall thickness is the minimum wall thickness allowed which, based on wear projection, exceeds the minimum acceptable wall thickness at the next inspection. If degradation is detected such that the measured wall thickness is less than the screening criteria wall thickness, additional evaluations or examinations are performed to assure the component's intended function will not be lost and identify corrective actions.

(Ref. Section 5.0, ENN-DC-315; and ENN-CS-S-008)

IPEC acceptance criteria are consistent with NUREG-1801 .

IPEC00203783

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 111 of 204 Flow-Accelerated Corrosion Program

7. Corrective Actions

a. NUREG-1801. Corrective Actions "Prior to service, components for which the acceptance criteria are not satisfied are reevaluated, repaired, or replaced . Long-term corrective actions could include adjusting operating parameters or selecting materials resistant to FAC. As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address the corrective actions."

b. Comparison to IPEC Corrective Actions If acceptance criteria are not satisfied for particular components, they are repaired, replaced or reevaluated prior to returning to service. Use of improved materials for replaced components and other design changes are part of the IPEC long-term strategy to mitigate FAC.

(Ref. Section 5.0, ENN-DC-315; ENN-CS-S-008)

IPEC corrective actions are consistent with those discussed in NUREG-1801 .

8. Confirmation Process This attribute is discussed in Section 2.0, Background.

9. Administrative Controls This attribute is discussed in Section 2.0, Background.

10. Operating Experience

a. NUREG-1801. Operating Experience "Wall-thinning problems in single-phase systems have occurred in feedwater and condensate systems (NRC IE Bulletin No. 87-01; NRC Information Notices [Ins] 81 -28, 92-35, 95-11) and in two-phase piping in extraction steam lines (NRC Ins 89-53, 97-84) and moisture separation reheater and feedwater heater drains (NRC Ins 89-53, 91-18, 93-21, 97-84). Operating experience shows that the present program, when properly implemented, is effective in managing FAC in high-energy carbon steel piping and components."

b. Comparison to IPEC Operating Experience Operating experience shows that this program has been effective in managing aging effects. Therefore, continued implementation of the program assures that effects of aging are managed so that components crediting this program can perform their intended function consistent with the current licensing basis during the period of extended operation. For more information IPEC00203784

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 112 of 204 Flow-Accelerated Corrosion Program on applicable operating experience, see IPEC Report IP-RPT-06-LRD05, Operating Experience Review Results.

C. References IPEC ENN-DC-315, Rev. 0, Flow Accelerated Corrosion Program ENN-CS-S-008 , Rev. 0, Pipe Wall Thinning Structural Evaluation ENN-NDE-9.05, Rev. 0, Ultrasonic Thickness Examination IP2 050714b-01, Rev. 1, IP2 CHECKWORKS FAC Model 040711-02, Rev. 0, Indian Point Unit 2 CHECKWORKS Power Uprate Analysis IP-RPT-05-00407, Rev. 0, IPEC Snapshot Self-Assessment Report for IPEC 2R18 FAC Scope Review, condition report LO-IP3LO-2006-0324 IP3 IP-RPT-05-00407, Rev. 0, IPEC Snapshot Self-Assessment Report for condition report LO-IP3LO-2005-0328 94-10.1-05, Rev. 2, CHECKWORKS Global Input 040711 -01, Rev. 0, Indian Point Unit 3 CHECKWORKS Power Uprate Analysis D. Summary The FAC Program has been effective at managing aging effects. The FAC Program assures that effects of aging are managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation .

The FAC Program is consistent with the program described in NUREG-1801,Section XI.M17, Flow-Accelerated Corrosion, with the following exceptions.

Attributes Affected Exception

1. Scope of Program IPEC utilizes EPRI NSAC-202L-R3, while NUREG-1801,Section XI., M17 references EPRI NSAC-202L-R2. 1

4. Detection of Aging Effects IPEC utilizes EPRI NSAC-202L-R3, while NUREG-1801 ,Section XI, M17 references EPRI NSAC-202L-R2. 2 Exception Notes

1. The differences of Section 4.2, Identifying Susceptible Systems, between IPEC00203785

IPEC License Renewal Project IP-RPT-06-LRD07 Aging Management Program Evaluation Report - Non-Class 1 Revision 5 Mechanical Page 113 of 204 Flow-Accelerated Corrosion Program Revision 2 and Revision 3 include the following. The guidance of prioritizing the system for evaluation in Section 4.2.3 of Revision 2 is addressed in Section 4.9 of Revision 3. Section 4.4, Selecting and Scheduling Components for Inspection, of Revision 2 was re-organized in Revision 3. Sample selection for modeled lines and non-modeled lines of Revision 2 was enhanced with more clarification and more details in Revision 3. Guidance for using plant experience and industry experience in selecting inspection locations was added in Revision 3. The basis for sample expansion was clarified in Revision 3. Instead of dividing into selection of initial inspection and follow-up inspections in Revision 2, the guidance in Revision 3 is provided for a given outage including the recommendations for locations of re-inspection.

2. Clarification of the inspection techniques of UT and RT was added in Section 4.5.1 of Revision 3. There are no changes of the guidance for UT grid.

Appendix B was added in Revision 3 to provide guidance for inspection of vessels and tanks. This is beyond the level of detail provided in Revision 2 and in the GALL report. The guidance for inspection of small-bore piping in Appendix A of Revision 2 and of Revision 3 are essentially identical. The guidance for inspection of valves, orifices, and equipment nozzles was enhanced in Section 4.5.2 of Revision 3. Also, Section 4.5.4 was added for use of RT to inspect large-bore piping, Section 4.5.5 was added for inspection of turbine cross-around piping, and Section 4.5.6 was added for inspection of valves.

IPEC00203786