ML22013A292
| ML22013A292 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/21/2021 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Rodriguez-Luccioni H | |
| References | |
| EPID L-2021-SLR-0002, L-2021-SLR-0002 | |
| Download: ML22013A292 (10) | |
Text
St. Lucie SLRA: Breakout Questions SLRA Section B2.1.28, ASME XI, Subsection IWE AMP TRP: 041 Note: Breakout Questions are provided to the applicant and will be incorporated into the publicly-available audit report.
Technical Reviewer George Wang 12/15/2021 Technical Branch Chief Joseph Colaccino 12/20/2021 Breakout Session Date/Time To be filled in by PM Applicant Staff NRC staff To be filled out by PM during breakout Question SLRA SLRA Background / Issue Discussion Question / Request Outcome of Discussion Number Section Page (As applicable/needed) 1 3.5.2.2.1.3 3.5-22 SRP-SLR Section 3.5.3.2.1.3 guidance 1. Clarify whether the says a plant-specific program is not concrete meets the recommended if the following, in part, requirements of ACI 318 or are satisfied: ACI 349 (low water-to-cement ratio, low permeability, and
- 1. The concrete meets the requirements adequate air entrainment) as of ACI 318 or ACI 349 (low water-to- cited in NUREG-1557 and cement ratio, low permeability, and guidance of ACI 201.2R, as adequate air entrainment) as cited in applicable.
NUREG-1557 and guidance of ACI 201.2R, as applicable. 2. Clarify how the concrete is monitored to ensure that it is
- 2. Whether the concrete is monitored to free of penetration cracks that ensure that it is free of penetration provide a path for water cracks that provide a path for water seepage to the surface of the containment shell or liner.
seepage to the surface of the containment shell or liner. 3. Clarify how OE (the borated water spills and water ponding
- 3. Whether borated water spills and on the concrete floor) is water ponding on the concrete floor are addressed.
common and when detected are cleaned up or diverted to a sump in a timely 4. Discuss the plan to update manner. SLRA as necessary.
SLRA Section 3.5.2.2.1.3 lacks information of the above mentioned items.
2 3.5.2.2.1.6 3.5-25 SLRA AMR item 3.5.1-010 in Table 3.5- 1. Clarify and address the Table 3.5-1 3.5-51 1, associated with aging management of discrepancy of aging cracking due to SCC, states that the management program ASME Section XI, Subsection IWE AMP between AMR item 3.5.1-010 and 10 CFR Part 50, Appendix J AMP and SLRA Section 3.5.2.2.1.6, manage cracking of Type III (semi-hot) and revise SLRA as stainless steel and dissimilar metal weld necessary penetration assemblies exposed to an uncontrolled indoor air environment. 2. Provide Unit 1 UFSAR However, SLRA Section 3.5.2.2.1.6, [Figure 3.8-9] and Unit 2 associated with AMR item 3.5.1-010, UFSAR [Figure 3.8-7] on the states that cracking of SS penetration ePortal for staffs review.
components, and any DMWs, for nine (9) penetrations per Unit will be managed by In addition, it appears that the ASME Section XI, Subsection IWE there is an error in the AMP, which includes enhancement for following statement:
surface, or enhanced visual, examination determined not to require to detect evidence of cracking in a management for containment representative sample of the steel in air structural penetrations. There is discrepancy of components, located in aging management program between SLRA Section 3.5.2.2.1.6.
AMR item 3.5.1-010 and SLRA Section 3.5.2.2.1.6.
SLRA Section 3.5.2.2.1.6 states that cracking due to SCC was also addressed as part of the current renewed licenses and determined not to require management for containment steel in air structural components.
Typical details for containment piping and fuel transfer penetrations are provided in the Unit 1 UFSAR Figure 3.8-9 and Unit 2 UFSAR Figure 3.8-7.
The staff could not locate the Unit 1 Figure 3.8-9 and Unit 2 Figure 3.8-7 in the UFSAR.
3 B.2.3.29 B-228 SLRA Section B.2.3.29 Enhancement to 1. Clarify what enhancements Element 2, states that procedures will be for preventive actions are revised that for structural bolting needed to ensure bolting consisting of ASTM A325, ASTM A490, integrity.
and equivalent materials, the preventive actions for storage, lubricants, and 2. Ensure the consistency of stress corrosion cracking potential preventive actions for bolting discussed in Section 2 of integrity between different RCSC publication Specification for AMPs.
Structural Joints Using ASTM A325 or A490 Bolts, will be used.
However, it does not appear that AMP enhancement for Element 2 includes an enhancement for bolting and coating material selection discussed in Section 2 of the RCSC publication.
GALL-SLR report states that the preventive actions emphasize proper selection of bolting material and
lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high-strength bolting. If the structural bolting consists of ASTM A325 and/or ASTM A490 bolts (including respective equivalent twist-off type ASTM F1852 and/or ASTM F2280 bolts), the preventive actions for storage, lubricant selection, and bolting and coating material selection discussed in Section 2 of Research Council for Structural Connections publication, need to be used.
4 B.2.3.29 B-229 SLRA Section B.2.3.29 Enhancement to 1. Clarify what AMP, or Element 4, states that procedures will be periodic supplemental surface revised to perform periodic supplemental or enhanced visual surface or enhanced visual examinations examinations are used to at intervals no greater than 10 years to manage cyclic loading but detect cracking due to cyclic loading of have no current licensing all non-piping penetrations (hatches, bases fatigue analysis.
electrical penetrations, etc.) that are subject to cyclic loading but have no 2. Clarify whether all the current licensing bases fatigue analysis dissimilar metal welds are and are not subject to local leak rate subject to Type B local leak testing. rate tests that are capable of detecting cracking due to SLRA Section B.2.3.29 also states SCC.
cracking due to cyclic loading of all non-piping penetrations (equipment 3. Discuss the plan to update hatch, personnel locks, electrical SLRA as necessary.
penetrations, etc.) that are subject to cyclic loading but have no current licensing bases fatigue analysis will be managed by the 10 CFR Part 50,
Appendix J AMP or by periodic supplemental surface or enhanced visual examinations incorporated into and consistent with the frequency of this AMP.
SLRA AMR item 3.5.1-027 in Table 3.5-1, associated with aging management of cracking due to cyclic loading (CLB fatigue analysis does not exist), claims to be consistent with NUREG-2191, and states that a fatigue analysis was not performed for the Containment Vessel and a fatigue waiver could not be located for airlock, hatch and electrical penetration assemblies. As such, the ASME Section XI, Subsection IWE AMP and 10 CFR Part 50, Appendix J AMP manage cyclic loading of air lock, hatch, and electrical penetration assemblies and accessories, exposed to uncontrolled indoor air.
Based on the statements above, it is unclear what AMP, or periodic supplemental surface or enhanced visual examinations are used to manage cyclic loading but have no current licensing bases fatigue analysis.
It is unclear whether all the dissimilar metal welds are subject to Type B local leak rate tests that are capable of detecting cracking due to SCC.
GALL-SLR report states the requirements of ASME Code Section XI, Subsection IWE and 10 CFR 50.55a are supplemented to perform surface examination (or other applicable technique) in addition to visual examinations, to detect cracking in steel, SS, and dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no CLB fatigue analysis (i.e., components covered by SRP-SLR Table 3.5-1, items 27 and 40, and corresponding GALL-SLR items; as applicable to the plant).
Where feasible, appropriate Appendix J leak rate tests capable of detection of cracking may be performed or credited in lieu of the supplemental surface examination; the type of leak test determined to be appropriate is identified with the basis for components for which this option is used.
5 B.2.3.29 B-229 GALL-SLR report states that IWE-2500-1 Clarify the methods used for and the requirements of 10 CFR 50.55a detecting cracking and explain provide information regarding the how they can detect cracking examination categories, parts examined, in steel, SS, and dissimilar and examination methods to be used to metal weld pressure-retaining detect aging. components that are subject to cyclic loading but have no SLRA Section B.2.3.29 Enhancement to CLB fatigue analysis.
Element 4, states that procedures will be revised to implement supplemental one-time surface or enhanced visual examinations, performed by qualified personnel using methods capable of detecting cracking, comprising (a) a
representative sample (two) of the SS penetrations or dissimilar metal welds associated with high-temperature (temperatures above 140°F) SS piping systems in frequent use on each unit; and (b) the SS fuel transfer tube on each unit. These inspections are intended to confirm the absence of SCC aging effects.
From the sentence cited above, with regard to methods capable of detecting Cracking, it is unclear whatre the methods used and how they can detect cracking in steel, SS, and dissimilar metal weld pressure-retaining components that are subject to cyclic loading but have no CLB fatigue analysis.
6 B.2.3.29 B-229 SLRA Section B.2.3.29 Enhancement to 1. Clarify whether Element 4 states that if SCC is identified supplemental one-time as a result of the supplemental one-time inspections in this inspections, additional inspections will be Enhancement refer to conducted in accordance with the sites supplemental one-time corrective action process. This will surface or enhanced visual include one additional penetration with examinations, or one-time dissimilar metal welds associated with volumetric examination of greater than 140°F SS piping systems metal shell surfaces if for each Unit until cracking is no longer triggered by plant-specific OE, detected. Periodic inspection of subject or both.
penetrations with dissimilar metal welds for cracking will be added to the PSL 2. Clarify what type of periodic ASME Section XI, Subsection IWE inspection of subject AMP if necessary, depending on the penetrations with dissimilar inspection results. metal welds for cracking is,
Based on SLRA Section B.2.3.29 and whats the inspection enhancements, there are supplemental frequency.
one-time surface or enhanced visual examinations, and one-time volumetric examination of metal shell surfaces if triggered by plant-specific OE. It is unclear whether supplemental one-time inspections refer to one of them or both.
It is also unclear what type of periodic inspection of subject penetrations with dissimilar metal welds for cracking is, and whats the inspection frequency.
7 B.2.3.29 B-229 SLRA Section B.2.3.29 enhancement to 1. Clarify whether each unit Element 4, related to supplemental will be subject to the volumetric examination states, in part: volumetric examination if the Procedures will be revised to specify a triggering OE occurs in any one-time volumetric examination of metal one unit, or will the shell surfaces that are inaccessible from examination be conducted in one side if triggered by plant-specific OE the unit in which the triggering identified after the date of issuance of OE occurred, or some other the first renewed license for each unit. If treatment? If not the former triggered, this inspection will be case, explain and provide a performed by sampling randomly justification of the intended selected, as well as focused, metal shell treatment of the 2 units for the locations susceptible to corrosion that one-time supplemental are inaccessible from one side. volumetric examination if the triggering OE occurs in any From the sentence cited above, with one unit.
regard to the conduct of the supplemental volumetric examination, 2. Clarify whether this there is a lack of clarity of the treatment supplemental volumetric of the 2 PSL units if the triggering OE examination consists of a occurs in one of the units. It is not clear sample of one-foot square from the SLRA whether the triggering OE locations that include both randomly-selected and
has occurred to date since the issuance focused areas most likely to of the first renewed license. experience degradation based on OE and/or other relevant GALL-SLR report states that this considerations such as supplemental volumetric examination environment.
consists of a sample of one-foot square locations that include both randomly- 3. Discuss the plan to update selected and focused areas most likely SLRA as necessary.
to experience degradation based on OE and/or other relevant considerations such as environment.
It is unclear whether this supplemental volumetric examination consists of a sample of one-foot square locations that include both randomly-selected and focused areas most likely to experience degradation based on OE and/or other relevant considerations such as environment.
8 B.2.3.29 B-229 SLRA Section B.2.3.29 states that Clarify whether an acceptability of inaccessible areas of enhancement to IWE program steel containment vessel is evaluated is needed for acceptability of when conditions found in accessible inaccessible areas of steel areas indicate the presence of, or could containment vessel.
result in, flaws or degradation in inaccessible areas. However, the staff could not locate acceptability of inaccessible areas of steel containment vessel in the procedure NDE-4.7, Revision 5, but the staff noticed that an enhancement to IWF program is provided for acceptability of
inaccessible areas. It is unclear whether the same enhancement will be included in IWE program.