ML17097A489

Attachment 2 - NUREG-2191 and NUREG-2192 (February 2017 Draft) Mechanical Comments

ML17097A489
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/07/2017
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
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ML17097A486	List: ML17097A487 ML17097A488 ML17097A489 ML17097A490 ML17097A491
References
NUREG-2191, NUREG-2192
Download: ML17097A489 (14)

Text

ATTACHMENT 2 NUREG-2191 and NUREG-2192 (February 2017 Draft)

Mechanical Comments Comment Location of Description of Change Justification For Change

1. Change General-1 NUREG-2191 Remove review of research and development activities AMPs are informed by plant specific and Industry Chapter X & from AMP element 10 OE reviews. OE that include Code and Industry standard XI changes. Research and development activities AMPs needs to be assessed for applicability through element 10, other reviews (e.g. EPRI, NRC National last Labs/Universities, etc.). Research by itself can be paragraph misleading without further assessment. The requirement is too vague and will be problematic to demonstrate compliance if trying to prove all potentially research and development was considered.

Table NUREG-2191 Recommend consistency with regard to the Although most aging management programs will X.01-1 Tables X-01 implementation schedule identified for AMPs in the likely be characterized as existing, many AMPs will XI.01-1 and XI-01 fourth column of the table using no later than six require enhancement(s) to meet GALL-SLR, Implementat months prior to subsequent period of extended especially for those plants that referenced old ion Schedule operation unless there is an AMP-specific reason for a revisions of GALL for first license renewal, or column different schedule. whose first applications were reviewed pre-GALL.

throughout It is expected that there will be a license condition tables requiring implementation of new AMPs and enhancements to existing AMPs to be completed no later than six months prior to the subsequent PEO for SLR. If that is to be the case, this timing expectation should be specified in the GALL Tables X-01 and XI-01 so that it gets built into the license renewal commitments up front. It appears that the no later than six months qualifier was only included for AMPs XI.M36, XI.M38, and XI.M42.

X.M1-1 NUREG-2191 Revise X.M1 and SRP-SLR Section 4.3 to expand Allows a plant specific justification consistent with AMP X.M1 NUREG report references and allow use of Section NUREG-2192 Table 4.3-1 for a 10 CFR Page 1 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change Page X.M1, 4.3.2.1.3 of NUREG-1800, Revision 2 to evaluate 54.21(c)(1)(i) disposition - see components Line 13 environmental effects on fatigue. The following evaluated for CUF en second paragraph.

Page X.M1-3 revision (or similar) is recommended to be inserted on Line 27 page X.M1-2 in Line 13 and on page X.M1-3 in Line 27:

A plant-specific justification can be provided to demonstrate that existing CUF en calculations performed using the guidance in Section 4.3.2.1.3 of NUREG-1800, Revision 2, remain applicable for the subsequent period of operation when compared to guidance in RG 1.207, Revision 1, NUREG/CR-6909, Revision 0 (with average temperature used consistent with the clarification that was added to NUREG/CR-6909, Revision 1); or other subsequent NRC-endorsed alternatives.

SLR-SRP-1 NUREG-2192 Revise NUREG 2192 Section 4.3.3.1.2.1 next to last Corrects a typographical error and clarifies Section sentence as noted below. NUREG-2192 Section 4.3.3.1.2.1. As originally 4.3.3.1.2.1 A plant-specific justification can be provided to constructed, the plant-specific justification next to last demonstrate that existing CUFen calculations allowance presented in the sentence is not-useful sentence. performed using the guidance in unless it is linked to current CUF en calculation pg 4.3-6 Section 4.3.1.2.3 4.3.2.1.3 of NUREG-1800, Revision guidance presented elsewhere in the GALL/SRP-2, is remain applicable to existing CUFen SLR documents (RG 1.207, R1, etc.).

evaluations for the subsequent period of operation when compared to guidance in RG 1.207, Revision 1, NUREG/CR-6909, Revision 0 (with average temperature used consistent with the clarification that was added to NUREG/CR-6909, Revision 1); or other subsequent NRC-endorsed alternatives.

SLR-SRP-2 NUREG-2192 Correct typo graphical error in NUREG-2192, page 4.3- Editorial comment page 4.3-10 10, Table 4.3-1, 54.21(c)(1)(i) 2nd example, 2nd Table 4.3-1 paragraph to read as follows:

54.21(c)(1)(i

)

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ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change 2nd example ..4.3.1.2.3 4.3.2.1.3 of NUREG-1800, Revision 2 2nd paragraph Table NUREG-2191 Delete the following from Table X-01 in the X.M1 The phrase identified in strikethrough should not X.01-2 Page X01-1, Section as shown by the following strike through: be included in this sentence because stress based Table X-01, The description of the program states The aging analysis (monitoring) monitors plant parameters X.M1 section management program monitors and tracks the number not number of occurrences and severity. By of occurrences and severity of design basis transients monitoring of the parameters the occurrences and (including those that are calculated in accordance severities are already considered. The with plant-specific stress-based analysis methods). recommended addition provides a appropriate Recommend adding the following sentence for stress clarification for stress based fatigue calculations.

based fatigue monitoring:

The program also monitors applicable design transient parameters (e.g., temperatures, pressures, displacements, strains, flow rates, etc.) for components with stress-based fatigue calculations.

XI.M7-1 XI.M7, Page Delete this new added text:

• Adequate guidance already exists for the XI.M7-2, The potential for stagnant flow conditions such as dead selection of inspection locations within the Element 4 legs is considered when selecting inspection locations. guidance for selection of inspection locations The program identifies these locations. within BWRVIP-75-A, including consideration for stagnant flow conditions. (BWRVIP-75-A, If necessary add:

Sections 3.1.1, 3.2.1, and 3.3.1). Including The selection of inspection locations is in accordance specific mention of stagnant flow conditions in with BWRVIP-75-A. the GALL AMP can cause confusion as to how other considerations for inspection locations listed in BWRVIP-75-A are to be addressed, such as high carbon content, evidence of weld repair, surface cold work, residual and operating stresses.

• Considered is a meaningless term relative to what is expected in selecting inspection locations. Is there an intended meaning beyond Page 3 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change guidance already within BWRVIP-75-A? Given that the in-scope welds have to be 4NPS or larger, then there are probably very few in scope welds that are in stagnant flow conditions.

• The Industry does not know of industry OE where there have been additional SSC identified in welds in stagnant flow areas.

• This statement may require an enhancement to the AMP to identify the stagnant locations in the AMP implementation documents, and then consider those locations in selection of inspection locations.

XI.M2-1 NUREG-2191 Update of AMP XI.M2 is requested to be consistent with This is consistent with previous Industry XI.M2 EPRI PWR Primary Water Chemistry Guidelines Revision comments that identified PWRs have updated their Program 7 (3002000505, April 2014). Water Chemistry Programs to EPRI PWR Primary Description, Water Chemistry Guidelines Revision 7.

2nd paragraph XI.M9-1 NUREG-2191 Delete the following text in element 1 of AMP XI.M9: Control rod drive housing and lower plenum XI.M9, Page Control rod drive housing and lower plenum components are managed consistent with XI.M9-3, components (reactor vessel internal components): BWRVIP-47-A as described in GALL Report AMP Element 1 BWRVIP-47-A provides guidelines for inspection and XI.M8, Boiling Water Reactor Penetrations.

evaluation; BWRVIP-55-A provides guidelines for repair Therefore, components managed by BWRVIP design criteria. A do not need to also be managed by this AMP or discussed within Element 1, Scope of Program, for this AMP.

XI.M18-1 NUREG-2191 Revise the third paragraph of XI.M18 to clarify that Clarification of the AMP inspection requirements in XI.M18 inspection requirements for high strength closure element 4 for high strength closure bolting (actual Element 4 bolting and closure bolting for which yield strength is yield strength greater than or equal to 150 ksi) is 3rd unknown apply to one bolt in a similar group of bolts required. Consistent with ASME Examination paragraph that are greater than 2 inches in diameter. Category B-G-1, NUREG-2191 Bolting Integrity Page 4 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change program appears to limit the examination to high strength closure bolting greater than 2 inches in diameter. In addition; for high strength closure bolting in piping systems, Examination Category B-G-1 specifies the examination of one bolted connection among a group of bolted connections that are similar in design, size, function, and service.

XI.M18-2 XI.M18 Delete AMP XI.M18 element 4 second bullet for aging OE indicates that M18 program visual inspections element 4 management of air/gas system bolting as noted below: in conjunction with preventive actions have been 2nd bullet for For closure bolting where the piping systems contains effective at managing loss of preload for bolted air/gas air or gas for which leakage is difficult to detect, the connections in piping systems containing air or bolting SLRA states how integrity of the bolted joint will be gas. This effort to demonstrate integrity of bolted demonstrated. For example: (a) inspections consistent joints for piping systems containing air or gas with that of submerged closure bolting; (b) when would be a significant endeavor with no leakage of the environment inside the piping systems appreciable benefit.

would discolor the external surfaces, a visual inspection for discoloration; (c) when the bolted connection is located within an isolated boundary, monitoring and trending of pressure decay; (d) soap bubble testing; and (e) when the temperature of the fluid is higher than ambient conditions, thermography testing.

XI.M18-3 XI.M18 Editorial: Revise AMP XI.M18 element 4 second bullet Revision of AMP XI.M18 element 4 second bullet element 4 for aging management of air/gas system bolting as for aging management of air/gas system bolting is 2nd bullet for noted below to provide flexibility with various aging requested to provide flexibility with various aging air/gas management options: management options.

bolting For closure bolting where the piping systems contains air or gas for which leakage is difficult to detect, the SLRA states how integrity of the bolted joint will be demonstrated. For example: (a) inspections consistent with that of submerged closure bolting; (b) when leakage of the environment inside the piping systems Page 5 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change would discolor the external surfaces, a visual inspection for discoloration; (c) when the bolted connection is located within an isolated boundary, monitoring and trending of pressure decay; (d) soap bubble testing; and or (e) when the temperature of the fluid is higher than ambient conditions, thermography testing.

XI.M20-1 NUREG-2191 Corrective Actions (Expanded Inspection Element 7 of the referenced AMPs was revised to XI.M21A-1 XI.M20 Sample) require no fewer than five additional inspections XI.M32-1 XI.M21A Open Cycle Cooling Water Systems (XI.M20) for each inspection that did not meet acceptance XI.M33-1 XI.M32 Closed Treated Water Systems (XI.M21A) criteria. Five additional samples would result in a XI.M36-1 XI.M33 One-Time Inspections (XI.M32) disproportionately large inspection sample for XI.M38-1 XI.M36 Selective Leaching (XI.M33) small inspection populations or inspection defects XI.M38 External Surfaces of Monitoring of Mechanical with limited extent of condition.

Element 7 Components (XI.M36)

Inspections of Internal Surfaces in Miscellaneous Piping and Ducting (XI.M38)

Revise element 7 of the AMPs noted above to provide a reasonable inspection sample for small inspection populations or inspection defects with limited extent of condition. Recommend revising the corrective action to read:

The number of increased inspections is determined in accordance with the sites corrective action program.

As a minimum, the smaller of five additional inspections for each inspection that did not meet acceptance criteria or 20% of the inspection population is conducted. If subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause is conducted to determine the further extent of inspection.

XI.M21A-2 NUREG-2191 Element 7 states: Provides clarification when repair or replacement Pg IX M21A- If the cause of the aging effect for each applicable would eliminate the need for additional Page 6 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change 4 material and environment is not corrected by repair or inspections.

Element 7 replacement, additional inspections are conducted if one of the inspections does not meet acceptance criteria.

Revise this sentence to read as follows:

If a material and environment inspection sample component fails to meet acceptance criteria due to aging, and the component is not corrected by repair or replacement, additional inspection samples are required.

XI.M27-1 NUREG-2191 Revise the following paragraph to read as follows: Based on the extent of condition and extent of XI.M27 If a flow test (i.e., NFPA 25 Section 6.3.1) or a main cause analysis, the Licensees corrective action Element 7 drain test (i.e., NFPA Section 13.2.5) does not meet program is sufficient to determine the scope and acceptance criteria due to current or projected frequency of additional/increased testing degradation (i.e., trending) additional tests are requirements. The possibility exists where the conducted. The number of increased tests is cause of the aging degradation does not meet the determined in accordance with the sites corrective acceptance criteria and would be limited to one action program; however, there are no fewer than two unit of a multiple unit site.

additional tests for each test that did not meet acceptance criteria. The additional inspections are completed within the interval (i.e., 5 years, annual) in which the original test was conducted. If subsequent tests do not meet acceptance criteria, an extent of condition and extent of cause analysis is conducted to determine the further extent of tests. At multi-unit sites, the extent of condition and extent of cause analysis could require the additional tests include inspections at all of the units with the same material, environment, and aging effect combination.

XI.M29-1 NUREG-2191 Revise to replace XI.M29 element 7, third paragraph, The second bullet of Element 7 was revised to XI.M29 second bullet to read as follows: require a doubling of the inspection population Element 7 For other sampling-based inspections (e.g., 20 was required. A doubling of the inspection population would result in a disproportionately Page 7 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change 2nd bullet percent, 25 locations) that include components other large inspection sample for small inspection after 3rd than tanks, the smaller of five additional inspections or populations or inspection defects with limited paragraph 20% of the inspection population is conducted. If extent of condition.

subsequent inspections do not meet acceptance criteria, an extent of condition and extent of cause is conducted to determine the further extent of inspection.

XI.M35-1 NUREG-2191 The text in Element 4 and Table XI.M35-1 notes the If the cause of the flaw condition is mitigated it is XI.M35, following: Periodic examinations are implemented as appropriate to expand the scope of one-time Page per Category C if the one-time examinations detect any inspection as described in Category B, with the XI.M35-3, 4, unacceptable flaws or relevant conditions. expanded scope inspection locations determined Element 4 Table XI.M35-1, Category C applies only if the flaw by extent of condition evaluation based on the (Table condition is not mitigated. If the flaw condition cause of the failure.

XI.M35-1) identified during the one-time inspection is mitigated, If the cause of the flaw condition isnt or cannot Category B would apply and the one-time sample size be mitigated it is appropriate to expand the scope would be expanded. Category C would not be entered. of one-time inspection to implement periodic Clarification should be provided in Element 4 as follows inspection as described in Category C.

- Periodic examinations are implemented as per Category C if the one-time examinations detect any unacceptable flaws or relevant conditions that are not mitigated.

XI.M35-2 NUREG-2191 See Exhibit M35-1 at the end of Attachment 2 for the The proposed changes are an attempt to apply XI.M35, recommended revisions to Table XI.M35-1. some reasonableness to the selection of inspection Page The criteria for periodic inspection scope and sample locations focusing on the causes for the plant-XI.M35-3, 4, size for Category C, (where there is OE for age related specific failures, and to clarify the expectations Element 4 cracking and there has not been 30 years of that are not clearly communicated in the Table.

(Table subsequent OE of no failures) should reflect the

• The Table as it is would cause a plant that XI.M35-1) applicable extent of condition relative to the cause of has a single failure due to a specific cause, the historical crack. As currently worded the periodic such as a bad piping design or broken inspection scope includes the entire population of ASME piping support that causes abnormal Class 1 Small Bore Piping welds. fatigue, or a bad weld that doesnt leak The guidance for periodic inspection should require until after some aging, to have to do as Page 8 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change that the periodic inspection scope be applied to many as 25 UT examinations of socket population determined by extent of condition welds every 10 years (75 total inspections) evaluation as determined by application of the as a result of a condition until the corrective action program. See attached markup of corrective action has been proved effective Table XI.M35-1. per Note 3 (for 30 years). Most of the It should be clear in the Table that there are 2 Class 1 small bore piping welds are inside populations of welds (butt or socket) for Category B containment in high dose areas.

and C. The periodic inspection requirements should

• Since the Table also doesnt specify that only apply to the type of weld with the OE failure. the periodic inspection requirements only apply to the type (socket or butt) weld Note that the sample size percentages for periodic that failed, it could be interpreted that a inspection of the susceptible welds should be higher socket weld failure would result in than 10% since the size of the susceptible population additional one time inspections and will likely be small for most failures. Therefore, a periodic inspections of butt welds (and sample size of 20% (doubling of 10%) of the visa versa). This should not be intended susceptible welds with a maximum of 10 welds be and would result in a lot of unnecessary examined every 10 years because that seems inspections, mostly in high dose areas.

reasonable based on the small susceptible populations

• The Exam scope as shown in the revised observed during first license renewal.

Table XI.M35-1 of Exhibit M35 is consistent with recent experiences in first license renewal where the extent of condition identified a small susceptible population (e.g. welds that were susceptible to cracking based on piping configuration that contributed to the cracking)

SLR-SRP-3 NUREG-2192 Revise Section 4.3.2.2 on page 4.3-4 as follows: The reference to 10 CFR 54.21(c)(1) without the Page 4.3-4, The basis for demonstrating acceptance of the TLAA (ii) is more accurate since the FSAR supplement Section under 10 CFR 54.21(c)(1) (ii) should be included and should address which ever disposition is credited 4.3.2.2 demonstrated in the SLRA. not just (ii).

Table NUREG-2191 Revise the environment for IV.D2.R-31 to identify an Replacement of Air - indoor controlled with IV.D2-1 Table IV.D2 internal environment of steam or treated water. Also steam; treated water and clarifying the Row revise the structure and/or component column to component name to specify manway/handhole identify the component as Secondary seating surfaces provides considerations that are Page 9 of 14

ATTACHMENT 2 Comment Location of Description of Change Justification For Change

1. Change IV.D2.R-31 manway covers cover; handhole covers cover seating appropriate for an erosion aging evaluation.

surfaces Manway external and internal surface evaluations not associated with erosion are covered by other NUREG-2191 AMR lines associated with Steam Generator components.

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ATTACHMENT 2 Exhibit M35-1 Revised Table XI.M35-1 Table XI.M35-1. Examinations Plant Categor Operating Mitigatio Examinatio Examination Schedule Sample Size y Experienc n n Method e

Full penetration (butt) welds:

3% of total population per unit, up One-time:

No to 10 (4) completed within 6 years Volumetric or age-related Not A prior to the start of the destructive (5) cracking (1) applicable Partial (6)

(2) subsequent period of penetration extended operation (socket) welds: 3% of total population per unit, up to 10 (4)

Full penetration (butt) welds:

10% of total population Age-related Yes per unit, up One-time:

cracking of (But do not to 25 (4) completed within 6 years Volumetric or full have 30 B prior to the start of the destructive (5) penetration years OE Partial (6) subsequent period of (butt) of no penetration extended operation welds (2) failures) (3) (socket) welds: 103%

of total population per unit, up to 25 10(4)

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ATTACHMENT 2 Table XI.M35-1. Examinations Plant Categor Operating Mitigatio Examinatio Examination Schedule Sample Size y Experienc n n Method e

Full penetration (butt) welds:

3% of total population Age-related Yes per unit, up One-time:

cracking of (But do not to 10 (4) completed within 6 years Volumetric or partial have 30 B prior to the start of the destructive (5) penetration years OE Partial (6) subsequent period of (socket) of no penetration extended operation welds (2) failures) (3) (socket) welds: 10%

of total population per unit, up to 25(4)

Full Periodic: penetration first examination (butt) welds:

completed within the 10% of total No 6 years prior to the start population Age-related (Cause not of the subsequent period per unit, up cracking of corrected of extended operation to 25 (4)

Volumetric or full by design with subsequent C destructive (5) penetration change or examinations every Partial (6)

(butt) other 10 years thereafter penetration welds (2) corrective One-time: (socket) action) completed within 6 years welds: 103%

prior to the start of the of total subsequent period of population extended operation per unit, up to 2510 (4)

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ATTACHMENT 2 Table XI.M35-1. Examinations Plant Categor Operating Mitigatio Examinatio Examination Schedule Sample Size y Experienc n n Method e

Full penetration (butt)

Periodic: welds: 1020 first examination  % of completed within the susceptible 6 years prior to the start population of the per unit, up Ssubsequent examination to 2510 (7) s every 10 years after the start of the subsequent Partial period of extended penetration operation with (socket) subsequent examinations welds: 10%

every 10 years thereafter of total population per unit, up to 25 (4)

Full penetration (butt) welds:

3% of total population per unit, up One-time:

to 10 (4) completed within 6 years prior to the start of the Partial No subsequent period of penetration Age-related (Cause not extended operation (socket) cracking of corrected welds: 10% Volumetric or partial by design C of total destructive (5) penetration change or (6) population (socket) other per unit, up welds (2) corrective to 25 (4) action)

Partial penetration Periodic:

(socket)

Subsequent examinations welds: 20%

every 10 years after the of susceptible start of the subsequent population period of extended per unit, up operation to 10 (7)

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ATTACHMENT 2 Table XI.M35-1. Examinations Plant Categor Operating Mitigatio Examinatio Examination Schedule Sample Size y Experienc n n Method e

NOTES:

(1) Must have no history of age-related cracking.

(2) Age-related cracking includes piping leaks or other flaws where fatigue or stress corrosion cracking are contributing factors.

(3) Actions must have been taken to mitigate the cause of the cracking. These actions, such as design changes, would generally go beyond typical repair or replacement activities. If welds that have been redesigned or repaired and the applicant could demonstrate through OE that no additional failures have been reported for the last 30 years, then the inspection sample size could follow the guidance in Category A.

(4) The welds to be examined are selected from locations that are determined to be the most risk significant and most susceptible to cracking. Other factors, such as plant-specific and industry OE, accessibility, and personnel exposure, can also be considered in selecting the most appropriate locations for the examinations.

(5) Volumetric examinations must employ techniques that have been demonstrated to be capable of detecting flaws and discontinuities in the examination volume of interest.

(6) Each partial penetration (socket) weld subject to destructive examination may be credited twice towards the total number of examinations because more information can be obtained from a destructive examination than from a nondestructive examination.

(7) The welds to be examined are selected from locations that are determined to be susceptible to the cause(s) of cracking from extent of condition evaluation of the plant-specific age-related failure event(s). Other factors, such as industry OE, accessibility, and personnel exposure, can also be considered in selecting the most appropriate locations for the examinations.

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