ML090090161
| ML090090161 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/08/2008 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML090090161 (5) | |
Text
1 PrairieIslandNPEm Resource From:
Richard Plasse Sent:
Wednesday, October 08, 2008 12:39 PM To:
Eckholt, Gene F.
Subject:
Copy of On Yee - PINGP AMP RAI 01-08dozier - Changed as of 10-1-08dozier.doc Attachments:
Copy of On Yee - PINGP AMP RAI 01-08dozier - Changed as of 10-1-08dozier.doc draft rai
Hearing Identifier:
Prairie_Island_NonPublic Email Number:
277 Mail Envelope Properties (Richard.Plasse@nrc.gov20081008123800)
Subject:
Copy of On Yee - PINGP AMP RAI 01-08dozier - Changed as of 10-1-08dozier.doc Sent Date:
10/8/2008 12:38:34 PM Received Date:
10/8/2008 12:38:00 PM From:
Richard Plasse Created By:
Richard.Plasse@nrc.gov Recipients:
"Eckholt, Gene F." <Gene.Eckholt@nmcco.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 11 10/8/2008 12:38:00 PM Copy of On Yee - PINGP AMP RAI 01-08dozier - Changed as of 10-1-08dozier.doc 38510 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
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Recipients Received:
Draft RAI B2.1.14-1 GALL recommends that XI.M36 External Surfaces Monitoring is only applicable to detect loss of material due to general, pitting and crevice corrosion for steel (carbon steel) components. However based on the review of the LRA and the applicants program basis document, the staff noted that the scope of this program will be expanded to include other metallic and non-metallic materials and additional aging effects that include cracking or change in material properties due to ozone, ultra violet or thermal exposure, loss of material due to wear and galvanic corrosion, heat transfer degradation due to fouling. The proposed expansion of AMP B2.1.14 is beyond the scope of GALL XI.M36, which was meant for steel components and loss of material only.
Please provide a separate program to manage the non-metallic components and their associated aging effects.
Please justify why the aging effect of heat transfer degradation due to fouling, as it applies to the additional metallic components added to the scope of this program, is not considered an enhancement to the program element, scope of program, of GALL AMP XI.M36.
Please justify how this program will adequately manage the aging effects of loss of material and heat transfer degradation and their applicable aging mechanism, as it applies to the additional metallic components added to the scope of this program.
Draft RAI B2.1.22-1 GALL recommends that XI.M38 Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components is only applicable for steel (carbon steel) components to detect loss of material with the use of visual inspections. However based on the applicants program basis documents and AMR line Items the staff noted that the applicant has expanded the scope of materials to include aluminum, brass and bronze, cast austenitic stainless steel, copper alloy, copper-nickel and stainless steel; and has expanded the scope of aging effects to include cracking due to stress corrosion cracking. The proposed expansion of AMP B2.1.22 is beyond the scope of GALL XI.M38, which was meant for steel components and loss of material.
Please justify why the expansion in the scope of materials to include additional metallic components and in the scope of aging effects to include cracking due to stress corrosion cracking are not considered enhancements to GALL AMP XI.M38.
Please justify how this program will adequately manage the aging effect of loss of material and their associated aging mechanisms, as it applies to the additional metallic components added to the scope of this program.
Identify and justify the inspection techniques used by this program that will be capable of detecting stress corrosion cracking for stainless steel components added to the scope of this program or please provide an appropriate program to manage cracking due to stress corrosion cracking for stainless steel components.
Draft RAI B2.1.2-1 GALL AMP XI.M29 Aboveground Steel Tanks recommends that based on operating experience, plant system walkdowns each outage will provide for timely detection of aging effects. However, the staff noted from the applicants program basis document that external visual inspections will be performed at least once per refueling cycle and inspection scope/frequency will be adjusted based on the results of the previous inspections and operating experience. The applicant further states that sample selections of insulation near the bottom of each insulated tank will be removed periodically to directly examine the tank exterior. The staff noted that the frequency of inspections for the tank bottoms and exterior tank surfaces of insulated tanks were not specified.
Clarify the inspection frequency for the inaccessible surfaces (tank bottoms) of the tanks in the scope of this program.
Clarify the inspection frequency for the tank exterior of the insulated tanks that require the periodic removal of the insulation near the bottom of the tanks.
Clarify and justify the number of inspections that will be performed on the external (accessible) surfaces, the inaccessible surfaces (tank bottoms), and the tank exteriors that require removal of insulation in scope of this program, before the inspection scope/frequency will be adjusted.