Text

Lr Hearing - Background Information for Jul 19, 2016 Meeting on Baffle Former Bolts Is Attached. NRC Staff Needs to Print Their Copy
	ML16201A200
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Site:	Indian Point
Issue date:	07/18/2016
From:	; NRC
To:	; Division of License Renewal
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IPRenewal NPEmails From: Holonich, Joseph Sent: Monday, July 18, 2016 9:04 PM To: Poehler, Jeffrey; Hiser, Allen; Hardies, Robert; Mchale, John; Amberge, Kyle; 'Ostroff, James'; Burgos, Brian; Cheruvenki, Ganesh; Tilton, Caroline; John J. Sipos; Mihir Desai;

'Lisa.Kwong@ag.ny.gov'; 'Bergman, Jana'; Kuhlmann, Jenny Cc: Hsueh, Kevin P; 'Molkenthin, James P'; 'Michael F Marino (Generation - 4)'; 'Demma, Anne'; 'Rudell, Bernie C:(GenCo-Nuc)'; 'Malikowski, Heather M:(GenCo-Nuc)'; 'Glenn A Gardner (Generation - 4)'; 'Wells, Tim G.'; 'Dyle, Robin'; Ross-Lee, MaryJane; Gray, Mel; Dentel, Glenn; Floyd, Niklas; Kulp, Jeffrey; Burket, Elise; Mangan, Kevin; Laur, Steven; Lyons, Sara; Clifford, Paul; Hickey, James; Alley, David; Haagensen, Brian; Ziedonis, Adam; Bower, Fred; Barkley, Richard; Siwy, Andrew; Draxton, Mark; Vadella, Robert; Finney, Patrick; R1DRPBR3CAL RESOURCE; Rudland, David; Nove, Carol; Turk, Sherwin; Wallace, Jay; Butcavage, Alexander; Werner, Greg; Anchondo, Isaac A; Drake, James; Hills, David; Holmberg, Mel; Fernandez, Edison; Schmidt, Colleen; Riemer, Kenneth; Ellegood, John; Taylor, Thomas; Cender, Laura; Domke, Matthew; Neurauter, James; Smith, Laura; Garg, Krishan

Subject:

Background Information for Jul 19, 2016 Meeting on Baffle Former Bolts is attached.

NRC staff needs to print their copy.

Importance: High Below is the background information for the Jul 19, 2016 meeting baffle former bolts.

NRC STAFF PLEASE PRINT AND BRING A HARDCOPY IF YOU WANT A COPY.

THERE WILL BE LIMITED COPIES AVAILABLE IN THE MEETING ROOM AND THOSE ARE FOR STAKEHOLERS.

1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 7475 Mail Envelope Properties (32dc897f00c142a69db50ae12d4df056)

Subject:

Background Information for Jul 19, 2016 Meeting on Baffle Former Bolts is attached. NRC staff needs to print their copy.

Sent Date: 7/18/2016 9:03:42 PM Received Date: 7/18/2016 9:03:55 PM From: Holonich, Joseph Created By: Joseph.Holonich@nrc.gov Recipients:

"Hsueh, Kevin P" <Kevin.Hsueh@nrc.gov>

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"'Molkenthin, James P'" <molkenjp@westinghouse.com>

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"'Michael F Marino (Generation - 4)'" <michael.f.marino@dom.com>

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"'Demma, Anne'" <ademma@epri.com>

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"'Rudell, Bernie C:(GenCo-Nuc)'" <bernie.rudell@exeloncorp.com>

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"'Malikowski, Heather M:(GenCo-Nuc)'" <Heather.Malikowski@exeloncorp.com>

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"'Glenn A Gardner (Generation - 4)'" <glenn.a.gardner@dom.com>

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"'Wells, Tim G.'" <TGWELLS@southernco.com>

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"'Dyle, Robin'" <rdyle@epri.com>

Tracking Status: None "Ross-Lee, MaryJane" <MaryJane.Ross-Lee@nrc.gov>

Tracking Status: None "Gray, Mel" <Mel.Gray@nrc.gov>

Tracking Status: None "Dentel, Glenn" <Glenn.Dentel@nrc.gov>

Tracking Status: None "Floyd, Niklas" <Niklas.Floyd@nrc.gov>

Tracking Status: None "Kulp, Jeffrey" <Jeffrey.Kulp@nrc.gov>

Tracking Status: None "Burket, Elise" <Elise.Burket@nrc.gov>

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"Alley, David" <David.Alley@nrc.gov>

Tracking Status: None "Haagensen, Brian" <Brian.Haagensen@nrc.gov>

Tracking Status: None "Ziedonis, Adam" <Adam.Ziedonis@nrc.gov>

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Tracking Status: None "Rudland, David" <David.Rudland@nrc.gov>

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Tracking Status: None "Turk, Sherwin" <Sherwin.Turk@nrc.gov>

Tracking Status: None "Wallace, Jay" <Jay.Wallace@nrc.gov>

Tracking Status: None "Butcavage, Alexander" <Alexander.Butcavage@nrc.gov>

Tracking Status: None "Werner, Greg" <Greg.Werner@nrc.gov>

Tracking Status: None "Anchondo, Isaac A" <Isaac.Anchondo@nrc.gov>

Tracking Status: None "Drake, James" <James.Drake@nrc.gov>

Tracking Status: None "Hills, David" <David.Hills@nrc.gov>

Tracking Status: None "Holmberg, Mel" <Mel.Holmberg@nrc.gov>

Tracking Status: None "Fernandez, Edison" <Edison.Fernandez@nrc.gov>

Tracking Status: None "Schmidt, Colleen" <Colleen.Schmidt@nrc.gov>

Tracking Status: None "Riemer, Kenneth" <Kenneth.Riemer@nrc.gov>

Tracking Status: None "Ellegood, John" <John.Ellegood@nrc.gov>

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Tracking Status: None "Cender, Laura" <Laura.Cender@nrc.gov>

Tracking Status: None "Domke, Matthew" <Matthew.Domke@nrc.gov>

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"Smith, Laura" <Laura.Smith@nrc.gov>

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Tracking Status: None "Poehler, Jeffrey" <Jeffrey.Poehler@nrc.gov>

Tracking Status: None "Hiser, Allen" <Allen.Hiser@nrc.gov>

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Tracking Status: None "Mchale, John" <John.McHale@nrc.gov>

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"'Ostroff, James'" <james.ostroff@spglobal.com>

Tracking Status: None "Burgos, Brian" <bburgos@epri.com>

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Tracking Status: None "Tilton, Caroline" <Caroline.Tilton@nrc.gov>

Tracking Status: None "John J. Sipos" <John.Sipos@ag.ny.gov>

Tracking Status: None "Mihir Desai" <Mihir.Desai@ag.ny.gov>

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"'Lisa.Kwong@ag.ny.gov'" <Lisa.Kwong@ag.ny.gov>

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"'Bergman, Jana'" <jbergman@curtisswright.com>

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Tracking Status: None Post Office: HQPWMSMRS01.nrc.gov Files Size Date & Time MESSAGE 263 7/18/2016 9:03:55 PM Agenda Jul 19, 2016 BFB Meeting.pdf 57828 1- Summary and Discussion of Recent BFB Inspections.pdf 869624 2- Industry Assessment of BFB Inspection Findings - WEC.pdf 104309 3 - Industry Assessment of BFB Inspection Findings - AREVA.pdf 300185 4 - Charter and Objectives of Industry BFB Focus Group.pdf 751798 5 - Next Industry Steps and Ongoing Related Efforts.pdf 514801 Baffle-Former Bolts Public Meeting July 19 NRC Slides.pptx 324516 Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Agenda for U.S. Nuclear Regulatory Commission (NRC) Staff and Electric Power Research Institute (EPRI) on Recent Inspection/Operating Experience with Baffle-Former-Bolts (BFB) and MRP-227-A, Pressurized Water Reactor Internals Inspection and Evaluation Guidelines July 19, 2016 (Category 1 Public Meeting)

Time Agendum Lead 8:30 a.m. Introduction, Safety, Administration, Opening Remarks NRC Staff/EPRI 8:45 a.m. Summary Recent Inspections of BFBs EPRI/PWROG

- DC Cook 2 (2010)

- Indian Point 2 (2016)

- Salem 1 (2016) 10:15 a.m. Break All 10:30 a.m. Industry Assessments of BFB Inspection Findings EPRI/PWROG

- 2012 Westinghouse Technical Bulletin

- 2016 Westinghouse NSAL 11:15 a.m. Charter and Objectives of Industry BFB Focus Group EPRI/PWROG 12:00 p.m. Next industry steps and on-going related efforts EPRI/PWROG

- Upcoming planned outage inspections (2016-2017)

- Near-term Focus Group actions (6-12 months)

- Longer-term Focus Group and industry actions 12:30 p.m. NRC staff perspectives, questions, discussion NRC 12:45 p.m. Public Comment and Concluding Remarks All

Global Expertise

One Voice Baffle Former Bolt Overview of Industry Experience Heather Malikowski (Exelon), Chair Bryan Wilson (Westinghouse)

PWROG Materials Committee July 19, 2016 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Westinghouse NSSS Internals Vessel Head Upper Support Plate Upper Support Column Hold Down Spring Control Rod Guide Tube Inlet Nozzle Outlet Nozzle Upper Core Plate Pressure Vessel Core Barrel Baffle Plate Thermal Shield Lower Core Plate Former Plate Lower Support Column Body Lower Core Support Plate Bottom-Mounted Instrumentation Column Body 2 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Baffle-Former Assembly Core Barrel Example Baffle-former Bolt Locations Baffle Plate Former Plate Thermal Shield Source: ML15331A264 3 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Baffle-Former Assembly Details Core Barrel Former Core Barrel to Former Bolt Baffle Baffle Plate Edge Bolt Corner Edge Bracket Baffle to Former Bolt Baffle to Former Bolt (Long & Short)

Source: ML15331A179 4 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Coolant Flow Configurations Downflow Upflow Configuration Configuration New Flow Hole Coolant Flow Plug Coolant Flow Core Barrel Baffle Plate Former Plate Coolant Flow Thermal Neutron Shield Source: ML073190376 5 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Timeline Operating Experience Ginna performs first MRP-227 First UT baffle-former bolts First degraded inspections (BFB) inspections in French baffle-former bolts Indian Point 2, PWR CP0 units and first found in U.S. DC Cook finds degraded Salem 1 find cracks found bolts by visual degraded bolts inspection (visual+UT)

WCAP-13266: BFB NRC NRC Program for the Information MRP publishes reviews & Westinghouse Westinghouse Owners Notice 98-11 on MRP publishes Reactor Internals approves Technical Bulletin Group - Plant BFBs assessment of Inspection MRP-227 TB-12-5, related to Categorization French BFB OE Guidelines (MRP- the DC Cook OE Guidance (MRP-03) 227)

Note: UT deployed as it became available and qualified for the various sites 6 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

EDF Experience 1989-Present

Baffle bolt failures reported 1989 - Present

- Limited to CP0 design

3-loop (converted to upflow)

Significant plant-to-plant variability

CPY design (<5 indications over life of plant) 7 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

EDF Response

Safety Case

- LOCA Loads

- Acceptable loads on remaining bolts

- Acceptable loads on fuel assembly grids

- Minimal number of healthy bolts ~30% with limits on distribution

Periodic bolt replacement

- Failed original bolts

- Periodic replacements included previously replaced bolts

- Sufficient number of healthy bolts to push next inspection to 10 years (based on projection model) 8 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Joint Owners Baffle Bolt Program (15-22 EFPY)

Sponsored Inspections of four plants

- Point Beach Unit 2: 2-loop, Upflow (converted) , Type 347SS

8% UT Indications

Partial replacement program

- Farley Unit 1: 3-loop, Upflow (converted), Type 316SS

No UT Indications

Proactive replacement of minimum pattern

- Ginna: 2-loop, Downflow, Type 347SS

9% UT Indications (Of these, 14 were sent for metallurgical examination. Results showed no indications of cracking, so this 9% likely contains a number of false calls)

Partial replacement program

- Farley Unit 2: 3-loop, Converted Upflow (downflow at time of inspection), Type 316SS

No UT Indications

Proactive replacement of minimum pattern 9 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

WEC MRP-227 Baffle-Former Bolt Inspections (25-35 EFPY)

Point Beach Unit 1: 2-Loop, Upflow (converted), Type 347SS

- 1st Inspection: No UT Indications

Point Beach Unit 2: 2-Loop, Upflow (converted), Type 347SS

- 2nd Inspection: 2% Additional UT Indications

Ginna: 2-Loop, Downflow, Type 347SS

- 2nd Inspection (partial inspection of 123 original bolts and 56 replacement bolts):

1 Additional UT Indications (Partial Replacement - 25 bolts)

Prairie Island Unit 1: 2-Loop, Downflow, Type 347SS

- 1st Inspection: 6% UT Indications

Prairie Island Unit 2: 2-Loop, Downflow, Type 347SS

- 1st Inspection: 10% UT Indications 10 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

WEC MRP-227 Baffle-Former Bolt Inspections (25-35 EFPY)

Surry Unit 1: 3-Loop, Downflow, Type 347SS

- 1st Inspection: <1% UT Indications

Surry Unit 2: 3-Loop, Downflow, Type 347SS

- 1st Inspection: <1% UT Indications

Robinson: 3-Loop, Downflow, Type 347SS

- 1st Inspection: <1% UT Indications

Turkey Point Unit 3: 3-Loop, Downflow, Type 347SS

- 1st Inspection: No UT Indications in 305 of 1088 bolts inspected

Indian Point Unit 2: 4-Loop, Downflow, Type 347SS

- Inspection results addressed in detail on a later slide 11 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

International Plants

Doel 1: 2-Loop Downflow, Type 316SS

- 1st Inspection: 2% UT Indications

Doel 2: 2-Loop Downflow, Type 316SS

- 1st Inspection: <1% UT Indications

Krsko: 2-Loop, Downflow (prior to inspection), Type 316SS

- 1st Inspection: <1% UT Indications

Tihange 1: 3-Loop, Upflow (converted), Type 316SS

- 960 of 1088 bolts inspected in each of the following inspections

- 1st Inspection: 4% UT Indications

- 2nd Inspection: 3% UT Indications

- 3rd Inspection: No confirmed UT Indications (5 bolts either not inspectable or not interpretable) 12 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

B&W-Designed RV Internals Baffle-to-Former Bolt Examinations (19-32 EFPY) [1 of 2]

Four baffle-to-former bolt (BFB) UT examinations completed at B&W-designed units to date

- Oconee Unit 1

No relevant UT indications

Four BFBs uninspectable due to large welds on locking bars

- Oconee Unit 2

No relevant UT indications

One BFB uninspectable due to UT probe not seating properly

- Oconee Unit 3

One BFB identified with crack-like indications

One BFB uninspectable due to UT probe not seating properly

- Crystal River Unit 3

No relevant UT indications

UT performed due to visual indication from baffle-to-baffle bolts 13 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

B&W-Designed RV Internals Baffle-to-Former Bolt Examinations (19-32 EFPY) [2 of 2]

All BFBs Type 304 solution annealed stainless steel

B&W design is an upflow configuration

One BFB out of 3,450 BFBs UT examined identified with crack-like indications

VT examination of all 3,456 BFBs identified no relevant indications 14 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Observations from Broader OE

With the exception of the OE at Cook Unit 2, Indian Point Unit 2, and Salem Unit 1 (discussed later in the presentation), the following observations can be made:

- Bolts with UT indications tend to be randomly distributed

- Distributions are consistent with expectations of IASCC failures

- Quantity and distribution of bolts with indications bounded by historical generic safety assessment (WCAP-15328)

- Industry response to replacement of bolts with indications has been positive 15 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Experience with Clustered Bolt Failures

DC Cook Unit 2 (2010 / 22 EFPY) (4-Loop Downflow Configuration)

- Fuel failure in peripheral assembly attributed to wear against broken bolt head

- Bolt heads and lock bars found on lower core plate

- Visual inspections revealed 18 degraded bolts on single plate

Additional bolts removed from plate with visual indications to define extent of localized degradation (approx. 40 bolts in single patch)

Additional test bolts removed from symmetrical locations to evaluate potential for degradation on other plates (all of these test bolts were found to be intact)

- No UT inspections performed in 2010 (at that time UT was not qualified or optimized for the Cook 2 bolt design)

- Degraded and test bolts replaced

- Westinghouse issued Technical Bulletin TB-12-5

- 100% Visual inspection conducted in 2012 with no additional indications 16 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Experience with Clustered Bolt Failures

Indian Point Unit 2 (2016 / 31 EFPY) (4-Loop Downflow Configuration)

- Degraded bolts and lock bars noted in visual exams performed prior to MRP-227 100% UT exams that were planned to occur during this outage

- Markings on periphery of neighboring fuel assembly identified (no fuel failure).

- Inspections identified 227 with visual degradation or UT indications

Includes 14 that were not inspectable

- UT indications were clustered

Spanned various quadrants

Multiple groups of 10+ adjacent failures

At least one cluster of 50+ adjacent failures

- Observed failure pattern exceeds WCAP-17096 acceptance criteria

- Site-specific response:

Performed Acceptable Bolting Pattern Analysis (ABPA)

Performed Replacement Bolting Pattern Analysis

Performed engineering evaluations supporting Unit 3 Extent of Condition Evaluation

Performed engineering evaluations supporting Unit 2 Assessment of Potential Safety Impacts

Performed baffle-former bolt removal and replacement

Quarantined select bolts for potential future testing 17 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Experience with Clustered Bolt Failures

Salem Unit 1 (2016 / 28 EFPY) (4-Loop Downflow Configuration)

- Conduct visual exams every other refueling outage in response to DC Cook Unit 2 OE and TB-12-5; MRP-227 exams were not planned until 2017

- Degraded bolts and lock bars noted in visual exams followed by performance of UT exams

- Loose or protruding bolt heads resulted in fuel fretting and a leaker at one fuel assembly

- Inspections identified 182 with visual degradation or UT indications

Includes 18 that were not inspectable

- UT indications were clustered

Concentrated to a few adjacent octants

Multiple groups of 10+ adjacent failures

At least one cluster of 50+ adjacent failures

- Observed failure pattern exceeds WCAP-17096 acceptance criteria

- Site-specific response:

Performed Acceptable Bolting Pattern Analysis (ABPA)

Performed Replacement Bolting Pattern Analysis

Performed engineering evaluations supporting Unit 1 Justification for Past Operation

Performed engineering evaluations supporting Unit 2 Extent of Condition Evaluation

Performed baffle-former bolt removal and replacement

Quarantined select bolts for potential future testing 18 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Conclusions from Recent OE

These three plants share a common plant design configuration (4-loop downflow) and bolt design

Bolts with visual or UT indications tend to be clustered

Distributions seem to indicate the presence of a mechanism causing adjacent bolts to become more susceptible to failure

Most likely cause is redistribution of a sustained stress resulting in increased IASCC susceptibility

Quantity and distribution of bolts with indications warranted the creation of an industry focus group and the issuing of Westinghouse NSAL-16-1 and AREVA CSB 16-02 19 P R E S S U R I Z E D WAT E R R E A C T O R O W N E R S G R O U P

Global Expertise

One Voice www.pwrog.com

Baffle-Former Bolt NSAL-16-1 John McFadden Westinghouse Baffle Bolt Degradation Engineering Issue Manager July 19, 2016 WAAP-9962 1

Topics

Westinghouse Tech Bulletin TB-12-5

Nuclear Safety Advisory Letter NSAL-16-1 2

Overview of Internals (Westinghouse NSSS)

Vessel Head Upper Support Plate Upper Support Column Hold Down Spring Control Rod Guide Tube Inlet Nozzle Outlet Nozzle Upper Core Plate Core Barrel Baffle Plate Thermal Shield Pressure Vessel Lower Core Plate Former Plate Lower Support Column Body Bottom-Mounted Instrumentation Lower Core Support Plate Column Body 3

Westinghouse Technical Bulletin TB-12-5 4

Westinghouse Technical Bulletin TB-12-5

Tech Bulletin TB-12-5 was issued in March 2012 after the Fall 2010 Cook Unit 2 visual findings of damaged baffle-former bolts

Identified 7 susceptible 4-loop downflow plants being most affected (Cook 1,2; Salem 1,2; Indian Point 2,3; and Diablo Canyon 1)

Also identified twelve 2- and 3-loop plants with susceptible designs similar to Cook Unit 2 (i.e., downflow design, bolt design, bolt loading)

Conclusions of TB still valid 5

Nuclear Safety Advisory Letter NSAL-16-1 6

Nuclear Safety Advisory Letter (NSAL)

NSAL-16-1 released on July 5

- Westinghouse 4-loop downflow plants are most susceptible

- Impact on other CE and Westinghouse plants has been evaluated

Information in TB-12-5, Baffle Bolt Degradation in a Westinghouse NSSS Plant with Downflow Reactor Internal Design remains applicable 7

Extent of Condition Evaluation

Affected plants:

- All Westinghouse designed NSSS plants with baffle-former bolts and CE designed plants with bolted core shrouds are potentially affected by this issue

- The Westinghouse AP1000 plant design does not utilize baffle-former bolts and is not affected by this issue

Factors contributing to degradation:

- reactor coolant design configuration (upflow vs. downflow)

- plant internals design and flowrates

- bolt design

Affected plants broken down into 4 Tiers AP1000 is a trademark or registered trademark of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited.

8 Other names may be trademarks of their respective owners.

NSAL Recommendations

General Recommendations for all Tiers:

- If visually damaged baffle-former bolts or lock bars are detected, it is recommended that the fuel assemblies that were adjacent to the baffle in the previous cycle, and are scheduled for use in the next cycle, be inspected for fretting wear on the face that was adjacent to the baffle

- It is recommended that the plant continues to follow the current MRP-227 guidelines and implement any revisions to the MRP-227 recommendations 9

NSAL Recommendations (contd.)

Tier 1a (4-loop downflow plants with Type 347 bolt design):

Complete a UT volumetric inspection of the baffle-former bolts at the next scheduled refueling outage

- In preparation for this inspection, the plant should consider developing an ABPA and be prepared to replace any baffle-former bolts with visible damage or UT indications

- Long-term mitigation strategies to consider include upflow conversion and preemptive bolt replacements

Tier 1b (4-loop downflow plants with Type 316 bolt design):

Complete a VT3 (visual) inspection of the baffle-former bolts at the next scheduled refueling outage

- If any visual indications are found, it is recommended that the plant completes a UT volumetric inspection of the baffle-former bolts

- If no visual indications are found, it is recommended that the plant completes a UT volumetric inspection of the baffle-former bolts prior to the completion of the second refueling outage after the issuance of this NSAL 10

NSAL Recommendations (contd.)

Tier 2a, 2b, and 2c (2- and 3-loop downflow plants):

- Plants that have previously completed UT inspections should review the inspection records to identify any indication of the onset of clustering before the next scheduled refueling outage

- Clustering is defined as 3 or more adjacent bolts or a total number of failures in a single baffle plate > 40% of the total number of bolts on that baffle plate

- Any indication of clustering should result in the consideration of an accelerated re-inspection schedule

Tier 3 (Converted upflow plants):

loop plants that have operated in a downflow configuration for more than 20 years should evaluate the need to perform a UT volumetric inspection of baffle-former bolts on an accelerated schedule

- All other plants should follow the General Recommendations for all Tiers provided on Slide 9

Tier 4 (Designed upflow plants):

- Follow the General Recommendations for all Tiers provided on Slide 9 11

AREVA Baffle-to-Former Bolt Customer Service Bulletin No. 16-02 S. Fyfitch, AREVA Inc.

B&W-Design Baffle-Former Assembly Core BaBarrel Baffle-to-Baffle Bolt Baffle Plate Locations Former Plate Thermal Shield Baffle-to-Former Bolt Locations (1/8th core)

Core Barrel-to-Former Bolt and Baffle-to-Former Bolt Locations

B&W-Designed RV Internals Operating Experience Four baffle-to-former bolt (BFB) UT examinations completed at B&W-designed units to date One BFB out of 3,450 BFBs UT examined identified with crack-like indications VT examinations of all 3,456 BFBs identified no relevant indications Concluded there is very high probability this was a random failure and not an indication of active degradation mechanism having initiated

AREVA Customer Service Bulletin No. 16-02 (1/4)

Customer Service Bulletin released July 14, 2016

Subject:

Preliminary evaluation of relevance of recent BFB degradation at Westinghouse-designed 4-loop units to B&W-designed 177-FA units Preliminary evaluation relative to risk to safety and operability of B&W-designed 177-FA units

AREVA Customer Service Bulletin No. 16-02 (2/4)

==

Conclusions:==

BFBs and baffle-to-baffle bolts (BBBs), regardless of RV internals design, are potentially susceptible to irradiation-assisted stress corrosion cracking (IASCC) x Two primary factors affect IASCC

- Accumulated fluence

- Stress x Several key stress drivers for IASCC

- Relatively high stress due to reactor coolant design configuration (downflow vs. upflow)

- Bolting installation and design characteristics

- Bolt fabrication process

- Bolt length

- Bolt head-to-shank design

- Initial torque levels

AREVA Customer Service Bulletin No. 16-02 (3/4)

Conclusions (cont.):

Very unlikely that failure rate leading to unacceptable BFB configuration could occur before performing next MRP-227 examinations (initial or subsequent) at any B&W-designed 177-FA unit Risk of observing OE similar to that seen at Westinghouse-designed units to date is low

AREVA Customer Service Bulletin No. 16-02 (4/4)

These recommendations are provided until further evaluation and assessment of current issue is completed through PWROG and industry BFB Focus Group:

It is recommended that B&W-designed 177-FA units continue to follow BFB and BBB (and BFB and BBB locking devices/locking weld) inspection guidelines of MRP-227 and implement any future MRP guidance changes It is also recommended that B&W-designed 177-FA units maintain increased awareness of telltale signs of BFB and BBB degradation through continuation of existing activities:

x Evaluating reactor coolant radioactivity levels during fuel cycle x Performing loose parts monitoring and foreign object search and removal (FOSAR) examinations as part of normal refueling activities x Performing visual examinations of peripheral fuel assemblies currently identified for assessment of fuel performance Additional details are provided in Customer Service Bulletin

QUESTIONS Industry Baffle-Former Bolt Focus Group NRC Update Tim Wells BFB FG Chairman Brian Burgos BFB FG EPRI Project Lead Charter and Objectives 7/19/16

Industry Plans The Industry Baffle to Former Bolt (BFB) Focus Group was formed to support an integrated approach among industry organizations to address recent operating experience

- AREVA

- EPRI Focus Area Lead Organization

- PWROG #1 - /Extent of Condition, Interim

- Utility Staff Guidance, Technical Interfacing with the NRC MRP

- Westinghouse #2 - Plant/Fleet Operating Experience PWROG Assessment

- Others

3 - Repair/Replacement PWROG Six focus areas with

4 - Inspection/NDE MRP key actions defined #5 - Irradiated Testing Support MRP

6 - Aging Management Assessment MRP 2

Industry BFB FG Charter The purpose of the BFB Focus Group is to coordinate industry activities relative to

- understanding issues associated with recent baffle former bolts operating experiences to prevent unnecessary duplication of time and effort

- to coordinate an agreed upon industry approach to resolving issues.

It will act to coordinate industry activities to resolve outstanding issues relative to the potential degradation of baffle former bolts and its impact to plant operations Vendors, MRP, PWROG and utility staff will work together to define a unified approach and will give regular updates to the Joint MRP/PWROG Reactor Vessel Internals Planning Team 3

Industry BFB FG Charter The Focus Group is NOT going to involve itself in other issues related to reactor internal components directly

- The focus will be only dealing with issues related to baffle former bolts

- There may be some actions taken by the team that also facilitate a broader understanding of IASCC mechanisms which will be beneficial to reactor internals as a whole, but this will be a serendipity of the results obtained from activities coordinated by the focus group Primary members of the BFB Focus Group will consist of EPRI staff, PWROG, NSSS Vendor staffs, and utility personnel

- It is desired to have a well-balanced focus group that can provide technical areas of expertise in irradiated materials degradation, structural design probabilistic fracture mechanics, and licensing 4

Industry BFB FG Charter BFB Focus Group Chairman: The BFB Focus Group will be headed by a Chairman appointed by the Joint PWROG and MRP RV Internals Planning Team leadership

- Represent the Industry BFB Focus Group for reporting out activities to key stakeholders

- Act as the industry representative for interactions with the regulator Project Lead: An EPRI staff member will be appointed as project lead to assist the Chairman in tracking and coordinating the activities of the Focus Group and the implementation of the Charter guidelines described here within

- Coordinate all tele-conference and face to face meetings

- Implement the Communication Plan Primary Member: It is expected that primary members will participate in all calls and meetings to the best of their ability and to participate in various focus group activities at a high level 5

Industry BFB FG Charter Communication to BFB Focus Group members will be through a combination of emails, tele-conferences and face to face meetings

- A weekly email will be sent out summarizing team activities accomplished during the week along with upcoming short term activities

- Email updates will also be distributed to members of the Joint PWROG/MRP Reactor Vessel Internals Planning Team to keep them abreast of this specific issue and actions being taken by this team

- Updates will be given to the MRP Assessment/IC TAC and the PWROG MSC (that govern the RV Internals Planning Teams work) at their respective meetings held throughout the year

- Monthly updates will be provided to the PMMP/MAPC EOC Updates will be given to the CNOs upon request 6

Industry BFB Focus Area Objectives Cause and Extent of Condition, Interim Guidance (Focus Area #1)

- Develop BFB OE database and verify data

- Evaluate/trend BFB OE

- Develop Interim Guidance

- Technical interactions with the NRC Plant and Fleet Operating Experience Assessment (Focus Area #2)

- Westinghouse to complete the 10CFR21 evaluation

- Westinghouse to complete an NSAL; AREVA to produce a similar document for B&W plants (Customer Service Bulletin)

Repair and Replacement (Focus Area #3)

- Work with vendors to develop a contingency plan for tooling and bolt inventory for the upcoming outage seasons (Fall 2016 / Spring 2017) 7

Industry BFB Focus Area Objectives Inspection / NDE (Focus Area #4)

- Review bolt inspection protocols to see if lessons learned suggest modifications

- Understand UT Probability of Detection as related to UT-acceptable bolts Irradiated Testing Support (Focus Area #5)

- Establish an integrated testing plan to build upon the Indian Point 2 root cause evaluation/analysis and further advance IASCC susceptibility knowledge

- Evaluate the need to include Salem 1 and Ginna BFBs into the integrated testing program Aging Management Assessment (Focus Area #6)

- Review previous aging management assessments and compare to current OE experiences

- Evaluate prediction models like the Weibull distribution in MRP-03 (which is based on French data)

- Potential revisions to MRP-227 8

Industry Communications Weekly updates to Industry BFB FG members Supported presentation to NSIAC on 5/23/16

- Westinghouse Technical Bulletin TB-12-5 remains valid Provided Industry Alert Letter from the PMMP Chairman on 6/1/16

- We fully expect that NEI 03-08 Interim Guidance will require the 4-loop plants identified in the Westinghouse TB-12-5 bulletin to perform UT inspections of all the BFBs or replace an acceptable pattern of bolts at their next outage.

- Consideration should also be given to proceeding with procurement of replacement bolts prior to issuance of interim guidance due to potentially long manufacturing lead times.

9

TogetherShaping the Future of Electricity 10

Backup slides 11

Industry BFB FG Charter - Org Chart Joint MRP / PWROG Industry BFB FG Team Leads Reactor Internals PMMP / MAPC EOC Planning Team Tim Wells Brian Burgos Industry BFB Focus Industry BFB Focus Overall Program Group Chairman Group Project Lead Updates PWROG MSC US NRC MRP TAC & IC Technical Issues Utility FG MRP PWROG Vendors Members MRP Assessment TAC M&T TAC Inspection TAC MSC Westinghouse AREVA 3rd Party Vendors Provide Guidance Brian Burgos Jean Smith Jack Spanner Jim Molkenthin Patty Paesano Tammy Natour (SIA, DEI, etc) and Oversight Kyle Amberge EOC / Interim Guidance / Irradiated Testing Repair /

Inspection / NDE Regulatory Tech. Support Replacement Interfacing Plant / Fleet Aging Management Operability Industry Baffle-Former Experience Assessment Assessment Bolt Focus Group Organizational Layout US NRC Licensing Issues 12

Industry BFB FG Charter - Participants Focus Area #1 Focus Area #2 Focus Area #3 Focus Area #4 Focus Area #5 Focus Area #6 Cause/Extent of Plant and Fleet Repair and Inspection / NDE Irradiated Testing Aging Condition / Interim Operating Replacement Support Management Guidance Experience Assessment Assessment Leads Tim Wells Heather William Sims Rachel Doss Chris Koehler Glenn Gardner Brian Burgos Malikowski Greg Gontis Jack Spanner Jean Smith Kyle Amberge Bryan Wilson Wade Markham Additional Vendor / Bryan Wilson Kyle Amberge Jim Molkenthin Pat Minogue Mike Burke Josh McKinley EPRI Support Steve Fyfitch Greg Troyer Kyle Amberge David Cislo Steve Fyfitch Greg Troyer Mark Richter (NEI) Jim Andrachek Anne Demma Anne Demma Anne Demma Bruce Montgomery Jim Molkenthin Randy Lott (NEI)

Anne Demma Kyle Amberge Tim Griesbach Chris Lohse Jim Molkenthin Heather Nelson Azevedo Nelson Azevedo William Sims Nelson Azevedo William Sims Malikowski Greg Greg Tom Malota Steve Petro Tom Malota Steve Petro Kammerdeiner Kammerdeiner Glenn Gardner Tom Malota Eric Brackeen Kevin Hacker Jim Cirilli Mo Dingler Ed Maloney / Kris Heather Jim Cirilli Glenn Gardner Dave Mora Garg Malikowski Utility Participation Rachel Doss Tim Wells Tim Wells Mo Dingler Rebecca Siegrist Ed Maloney Heather Malikowski Gay Haliburton Eric Brackeen 13

Industry Baffle-Former Bolt Focus Group NRC Update Tim Wells BFB FG Chairman Brian Burgos BFB FG EPRI Project Lead Next Steps 7/19/16

Upcoming Planned Refueling Outages Upcoming Refueling Outages will help to inform us further on fleet trends Additional OE from upcoming domestic refueling outages will add to our knowledge base

- Fall 2016: 3 planned MRP-227 UT inspections (2 of 3 are Tier 1a plants)

- Spring 2017: 3 planned MRP-227 UT inspections (all Tier 1a plants) and 1 VT-3 inspection (Tier 1b plant)

- Fall 2017: 3 planned MRP-227 UT inspections (1 of 3 is a Tier 1a plant)

- Spring 2018: 1 planned UT re-inspection (Tier 1a plant)

Additional International OE is expected Out year planning will be important for inspection tooling preparation and for potential use of replacement equipment.

2

Extent of Condition / Interim Guidance / NRC Interfacing (Focus Area #1)

Primary objectives in the short term:

- Developed an OE database and analyze for trends to identify potential relationships between known failures and plant design/operating conditions This will be a significant input in developing Interim Guidance

- Issue initial NEI 03-08 Interim Guidance to MRP-227/228 in the Fall 2016 timeframe Potential update to Interim Guidance in 2017 based on OE from Fall 2016 and Spring 2017 refueling outages and other focus group activities

- Confirm refueling outage schedules for the next 2 years to feed into Focus Area #3 (Repair / Replacement needs)

This is needed to develop planning for both UT and replacement tooling and inventory assessment of typical BFB designs

- Support interfacing between regulatory authorities and industry groups 3

Extent of Condition / Interim Guidance / NRC Interfacing (Focus Area #1)

Many combinations of data are being assessed

- Are there plant parameters that indicate susceptibility?

- Are there combinations of parameters that indicate trends?

- Are there design parameters that indicate trends?

Trending of data continues and will support the development of Interim Guidance Development of the Industry BFB OE database is ongoing and will provide a means to capture and assess results of future inspections 4

Plant/Fleet Operating Experience Assessment (Focus Area #2)

Primary focus is on the development of the Westinghouse NSAL and the AREVA Customer Service Bulletin

- NSAL issued 7/5/16

- AREVA CSB issued 7/14/16 Assisted in the development of an operating experience assessment Will continue to review OE 5

Repair / Replacement (Focus Area #3)

Recent OE at IP2 and Salem 1 identified issues related to replacement tooling availability

- Delays in BFB replacement tooling were experienced due to limited availability of equipment Key input for this focus area is the development of the outage schedule for the next 2 years along with scheduled inspections (volumetric or visual)

Fall 2016 refueling outage support:

- Contingency plan recommendations are being developed to assist plants 6

Repair / Replacement (Focus Area #3)

Ongoing evaluations are underway for vendor capital and/or PWROG tooling investment

- What is the appropriate amount of tooling needed

- How do the outages overlap in Spring 2017

- Are modifications or changes needed to the existing equipment for production or reliability Material availability assessment completed

- Both vendors have bolting material to fabricate roughly 1,500 BFBs

- Items under consideration Are increased machining rates required to potential provide sufficient bolts in a timely manner if required Is a common bolt design possible to allow for faster machining rates 7

Inspection / NDE (Focus Area #4)

Current methods are identifying defects Review bolting UT results for lessons learned relevant to the protocol Provide input to Focus Area #5 on recommended NDE examinations of bolts received from IP2 and Salem 1

- Recommended PT prior to Destructive Examination Evaluate the ability to correlate UT signals with measured crack size from destructive examination

- May be impractical with multiple bolt designs and varying vendor UT techniques

- Internal hex head bolts and locking devices are particularly difficult to UT 8

Irradiated Testing Support (Focus Area #5)

Short-Term Testing (2016)

Work to support Indian Point and Salem root cause and operability analyses Intermediate-Term Testing (2016)

Testing with fleet-wide applicability resulting from the OE Long-Term Testing (2017+)

Evaluation of IASCC susceptibility of BFB materials with respect to dose and time

IP2 has shipped 32 bolts to the Westinghouse Hot Cell Facility (received 6/29/16)

Shipment of Salem bolts (6+) to follow

Ginna bolts (6) to be shipped in August 2016 9

Irradiated Testing Support (Focus Area #5)

Proposed Short-Term Testing (2016)

Activity Notes Bolt Receiving & Transportation into Hot Cell 32 bolts (IP2), 6 bolts (S1)

Bolt Fracture Surface Examination Work supports root cause

Optical microscopy, SEM analyses

Identify fracture modes (IASCC, fatigue, creep)

Correlate with opposite fracture surface to assess potential relative motion or rotation Remaining Property Testing

Room temperature pull tests of bolts determined by NDE to have cracking Alloy Chemistry Confirmation Radionuclide Analysis (dpa) Can be conducted on same sample as alloy chemistry Technical Report Clean-up & Return of Materials to Site All material to be returned to utility after testing 10

Irradiated Testing Support (Focus Area #5)

Focus Area #5 Action Items:

Develop testing plan by the end of July based on clear test objectives and outcomes

Prioritize needed information to optimize funding

Coordinate funding sources such as utility, PWROG, MRP, and DOE 11

Aging Management Assessment (Focus Area #6)

Focus Area #6 is taking a long term approach toward understanding the mechanisms and adjusting the guidance of MRP-227 as required; for example:

- Review previous aging management assessments and compare to recent OE

- What materials/structural models best replicate observed OE and what do they predict for the future Identify any requirements that would modify the interim guidance issued by Focus Area 1 12

Aging Management Assessment (Focus Area #6)

Recommend any updates for future MRP-227 revisions Evaluation of repair/replacement modifications

- Account for these within MRP-227

- Relative effectiveness of options over the long term Recommend adjustments to WCAP-17096 methodology as appropriate 13

Near Term Industry BFB FG Actions to be completed Assessment of Fall 2016 and Spring 2017 outage seasons for developing a contingency plan for tooling and BFB material needs Develop NEI 03-08 Interim Guidance taking into account trending of BFB OE database and recent OE Finalize integrated irradiated testing plan which will feed into Focus Areas 1, 2, 4, and 6 14

TogetherShaping the Future of Electricity 15

U. S. Nuclear Regulatory Commission NRC Perspectives on Baffle-Former Bolt Degradation July 19, 2016 1

Recent Operating Experience

From 2010-2016, MRP-227-A inspections were performed at several Westinghouse 2-loop and 3-loop plants loop plants had 5-10% degraded baffle-former bolts loop plants had very few degraded baffle-former bolts

In 2010, one Westinghouse 4-loop plant visually noted a large number of degraded bolts on one baffle plate (not during MRP-227-A inspection)

In 2016, two Westinghouse 4-loop plants performed MRP-227-A inspections and found more degraded bolts than expected (27% and 22%)

Plants with significant degradation are Westinghouse 4-loop designs with a downflow configuration and Type 347 stainless steel bolts 2

NRC Response to Recent OE

Reviewed recent industry and vendor guidance on this issue

Evaluated immediate safety significance of issue through internal processes (LIC-504)

Regional staff has been alerted to issue and have engaged the licensees at sites with susceptible reactor designs

Conducting baseline inspections focused on the issue at the two plants with extensive bolt degradation in 2016 3

NRC Inspections

The NRC staff performed targeted inspections at the two plants with significant degradation.

Inspection focused on:

- NDE quality and accuracy (VT, UT)

- Corrective actions, including evaluation of operating units

- Adequacy of replacement bolt pattern, including margin for additional failures during next cycle

Results of the NRC inspections will be documented in publically available inspection reports.

4

Safety Significance

NRC initial conclusion is that susceptible plants do not need to immediately shut down:

- The consequences of baffle plate detachment during normal operation would be limited to localized fuel damage, detectable by periodic coolant activity monitoring required by the TS

- Only certain events (large LOCA, medium LOCA, or seismic events) have the potential to rapidly detach the baffle plate due to baffle-former bolt degradation

- In such an event, the detachment of a baffle plate is not expected to pose a significant challenge to the ability to shutdown the reactor and cool the core

- Initial assessment is that the frequency of such events does not rise to the level of an imminent safety concern and does not require any immediate shutdown

Many degraded bolts retain significant load-bearing capacity such that they would resist failure during a LOCA or seismic event

NRC is monitoring inspection plans of susceptible plants.

5

NRC Ongoing Actions

NRC is gathering information on the root cause analyses and the metallurgical analysis of the bolts as it becomes available

NRC will monitor EPRI MRP changes to inspection guidelines based on current events.

- NRC will review and issue a safety assessment on interim guidance issued by MRP related to baffle-former bolts

- NRC may also address this issue under the review of MRP-227, Rev. 1.

NRC is evaluating the need for a generic communication, such as an information notice.

6

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