ML20125A092

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May 4, 2020, Pre-submittal Meeting Handout Staff Comments Draft TSTF-577, Revised Frequencies for Steam Generator Tube Inspections
ML20125A092
Person / Time
Site: Technical Specifications Task Force
Issue date: 05/04/2020
From:
NRC/NRR/DNRL
To:
Technical Specifications Task Force
Honcharik M
References
Download: ML20125A092 (8)


Text

NRC Staff Comments Draft TSTF-577 Pre-Submittal Review NRR/DNRL/NCSG Public Meeting May 4, 2020

Background:

TSTF-577

  • Public meetings related to draft TSTF-577:

- November 2019

- February 2020 2

Background:

SG TS History

  • Original SG TS

- Prescriptive surveillance requirements

- Mill-annealed (MA) Alloy 600 degradation -

inspections beyond TS requirements to maintain tube integrity

- Performance based TS framework

- Changed regulatory focus to tube integrity

- Extended inspection periods and eliminated mid-point requirements 3

NRC Staff Perspective

  • The existing licensee SG programs and NRC regulatory framework are effective - good operating experience
  • No cracking in thermally-treated (TT) Alloy 690 tubing
  • Alloy 600TT tubing performance shows improvement compared to Alloy 600MA

- Not clear to NRC staff if cracking susceptibility will be limited to a small percentage of tubes 4

Staff Discussion - Alloy 600TT

  • The proposed maximum 72 Effective Full Power Months (EFPM) between inspections:

- Recent cracking in non-high stress Alloy 600TT tubes at two plants Fall 2019 - Top of tube support plate (TSP) (deposits)

Spring 2020 - Upper TSP (dent locations)

- Consistent operating experience or indicative of a larger susceptible population size?

5

Staff Discussion - Alloy 600TT

  • The proposed maximum 72 EFPM between inspections:

- Staff needs to improve understanding of how Alloy 600TT operating experience was used to develop the crack initiation/growth technical basis presented in February 24, 2020, SGTF slides

  • For example, which cracks were used in the trending and details of flaw comparisons 6

Staff Discussion - Inspection

  • The TSTF proposes longer times between inspections for Alloys 600TT and 690TT
  • If plants were permitted to go beyond current TS maximum intervals between inspections:

- Robust inspection with advanced probes needed for improved probability of detection

- A requirement for minimum advanced probe inspections in the EPRI Guidelines seems appropriate to NRC staff 7

Staff Comments on Draft TSTF-577 (Pre-submittal Review)

  • Higher-level comments in this presentation
  • Additional NRC staff comments will be provided in writing to TSTF 8