ML11293A476

Lr - Davis-Besse Draft RAI

ML11293A476
Person / Time
Site:	Davis Besse
Issue date:	09/20/2011
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML11293A476 (3)

Text

Davis-BesseNPEm Resource From: CuadradoDeJesus, Samuel Sent: Tuesday, September 20, 2011 9:51 AM To: dorts@firstenergycorp.com Cc: Davis-BesseHearingFile Resource

Subject:

Davis-Besse Draft RAI Attachments: DBNPS AMR RAI TRP 40 Lube Oil 3.3.2.2.10.4-1 Kichline 9-12-11.docx Steve:

Attached is a new Draft RAI Ill be adding to the RAI letter Im working on. Ill be sending this one out this week. The final letter will have 3 RAIs.

Regards, Samuel Cuadrado de Jesús Project Manager Projects Branch1 Division of License Renewal U.S. Nuclear Regulatory Commission Phone: 301-415-2946 Samuel.CuadradoDeJesus@nrc.gov 1

Hearing Identifier: Davis_BesseLicenseRenewal_Saf_NonPublic Email Number: 1515 Mail Envelope Properties (377CB97DD54F0F4FAAC7E9FD88BCA6D0804FCD64F4)

Subject:

Davis-Besse Draft RAI Sent Date: 9/20/2011 9:51:09 AM Received Date: 9/20/2011 9:51:11 AM From: CuadradoDeJesus, Samuel Created By: Samuel.CuadradoDeJesus@nrc.gov Recipients:

"Davis-BesseHearingFile Resource" <Davis-BesseHearingFile.Resource@nrc.gov>

Tracking Status: None "dorts@firstenergycorp.com" <dorts@firstenergycorp.com>

Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 437 9/20/2011 9:51:11 AM DBNPS AMR RAI TRP 40 Lube Oil 3.3.2.2.10.4-1 Kichline 9-12-11.docx 34705 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Davis Besse RAI 3.3.2.2.10.4-1

Background:

SRP-LR Table 3.3-1, item 26 and states that loss of material due to pitting and crevice corrosion could occur for copper alloy piping, piping components, and piping elements exposed to lubricating oil. The SRP-LR recommends GALL AMP XI.M39, Lubricating Oil Analysis, to manage the aging effect and further evaluation of a program to verify the effectiveness of the Lubricating Oil Analysis Program, such as XI.M32, One-Time Inspection, because control of contaminants within the lubricating oil may not have always been adequate to preclude corrosion.

In LRA Tables 3.3.2-14, 3.3.2-18, 3.3.2-30, 3.4.2-1, and 3.4.2-4, the applicant referenced LRA Table 3.3.1, item 3.3.1-26 and generic note I for copper alloy components exposed to fuel oil and stated that the components have no aging effects requiring management. For these items, the applicant further cited plant-specific notes which state that the components are made of copper alloy with less than 15 percent zinc and are not in contact with a more cathodic metal; therefore, the components have no aging effects requiring management.

Issue:

It is unclear to the staff why the applicant claims that copper alloy with less than 15 percent zinc components exposed to lubricating oil have no aging effects requiring management. The staff noted that copper alloy with less than 15 percent zinc components are less susceptible to loss of material than other copper alloys, but that the presence of contaminants (e.g., water) in lubricating oil can create an environment conducive to loss of material, regardless of whether or not the component is in contact with a more cathodic metal.

Request:

Explain why copper alloy with less than 15 percent zinc components exposed to lubricating oil have no aging effects requiring management or provide an appropriate AMP to manage loss of material.