ML19168A066
| ML19168A066 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/15/2019 |
| From: | Sayoc E NRC/NRR/DMLR/MRPB |
| To: | Aitken P, Blocher E Dominion Energy Co |
| Sayoc E | |
| References | |
| Download: ML19168A066 (4) | |
Text
From:
Sayoc, Emmanuel To:
Paul Aitken; Eric A Blocher Cc:
Wu, Angela
Subject:
RE: Next Batch of Surry Draft RAIs Date:
Wednesday, May 15, 2019 3:56:00 PM Attachments:
074 and 075 SPS AMR RAI Concrete and Inaccessible areas - Wang Thomas Lopez (1 RAI) 05-01-19.docx And here is one more.
Thanks Manny
Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084
From: Sayoc, Emmanuel Sent: Wednesday, May 15, 2019 3:55 PM To: Paul Aitken <paul.aitken@dominionenergy.com>; Eric A Blocher
<Eric.A.Blocher@dominionenergy.com>
Cc: Wu, Angela <Angela.Wu@nrc.gov>
Subject:
Next Batch of Surry Draft RAIs Importance: High
Paul Eric, here is the next batch of draft RAIs, I is actually 9 not 11. The other 2 were not ready to go yet.
Angela will be scheduling clarification calls shortly. Please send us black out days if any over the next two weeks.
Thank You Manny
TRP RAI Number Issue Branch Reviewer 141 4.1-1 Time-Limited Aging Analyses (and Exemptions)
MVIB Medoff 147.6 4.7.6-1 Reactor Coolant Pump Code Case N-481 MPHB Davis 147.6 4.7.6-2 Reactor Coolant Pump Code Case N-481 MPHB Davis 12 B.2.1.6-1 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
MPHB Cheruvenki
12 B.2.1.6-2 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)
MPHB Cheruvenki 19 B.2.1.10-1 Steam Generator MCCB Chereskin, Huynh 19 B.2.1.10-2 Steam Generator MCCB Chereskin, Huynh 48 B.2.1.36-1 Protective Coating Monitoring and Maintenance MCCB Chereskin 48 B.2.1.36-2 Protective Coating Monitoring and Maintenance MCCB Chereskin
Emmanuel Manny Sayoc Safety Project Manager NRR/DLR 301-415-4084
074 and 075 SPS RAI Concrete and Inaccessible areas Regulatory Basis:
10 CFR 54.21(a)(3) requires an applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. One of the findings that the staff must make to issue a renewed license (10 CFR 54.29(a)) is that actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis. In order to complete its review and enable making a finding under 10 CFR 54.29(a), the staff requires additional information in regard to the matters described below.
DRAFT-RAIs 3.5.2.2.1.9-1
=
Background===
This RAI applies to SLRA Sections 3.5.2.2.1.9, 3.5.2.2.2.1(4), and 3.5.2.2.2.3(3). Increase in porosity and permeability due to leaching of calcium hydroxide and carbonation could occur in inaccessible areas of PWR concrete containment, and in below-grade inaccessible concrete areas of Groups 1-5, 7-9 structures, and Group 6 structures.
SRP-SLR Sections 3.5.2.2.1.9, 3.5.2.2.2.1.4 and 3.5.2.2.2.3.3 associated with SRP-SLR Table 3.5-1, Items -014, -047 and -051, respectively, recommend further evaluation of this aging effect in inaccessible areas of PWR concrete containment, and in below-grade inaccessible concrete areas of Groups 1-5, 7-9 structures, and Group 6 structures. The corresponding SRP-SLR review procedures state, in part, that a plant-specific program is not required for the reinforced concrete structures exposed to flowing water if (1) there is evidence in the accessible areas that the flowing water has not caused leaching and carbonation, or (2) evaluation determined that the observed leaching of calcium hydroxide and carbonation in accessible areas has no impact on the intended function of the concrete structure.
Table IX.D Use of Terms for Environments of GALL-SLR defines water-flowing environment as water that is refreshed; thus, it has a greater impact on leaching and can include rainwater, raw water, ground water, or water-flowing under a foundation.
Issue The respective further evaluations in SLRA Sections 3.5.2.2.1.9, 3.5.2.2.2.1(4) and 3.5.2.2.2.3(3) associated with SLRA Table 3.5.1, items 3.5.1-014, -047, and -051 related to increase in porosity and permeability due to leaching of calcium hydroxide and carbonation, state that plant operating experience has not identified any aging effects related to increase in porosity and permeability due to leaching of calcium hydroxide and carbonation; and therefore a plant-specific aging management program to manage the aging effects is not required.
However, during the audits the staff found that there were operating experience of leaching identified in CR 434317, CR 485546 and CR 546721, and efflorescence identified in the document ET-S-07-0071, Condition Assessment of Plant Structures - Second-Five Year Inspection Interval, Revision 0.
074 and 075 SPS RAI Concrete and Inaccessible areas Therefore, it appears that the first option of the SRP-SLR further evaluation criteria for leaching aging effects in a water-flowing environment may not have been satisfied and that Dominions claim of non-applicability/not requiring an aging management program of the associated AMR line items is not adequately justified.
Request Provide evaluation to demonstrate that the observed leaching of calcium hydroxide and carbonation in accessible areas at Surry has no impact on the intended function of the concrete structure and update the SLRA accordingly.
OR Provide information that would demonstrate, pursuant to 10 CFR 54.21(a)(3), that the aging effects of increase in porosity and permeability due to leaching of calcium hydroxide and carbonation will be adequately managed for inaccessible concrete areas of the PWR concrete containment, and below-grade inaccessible concrete areas of other applicable Groups 1-5, 7-9 structures and Group 6 structures, and update the SLRA accordingly.