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SLR-ISG Set 1 Industry Comments Final
	ML20196L925
Person / Time
Site:	Nuclear Energy Institute
Issue date:	07/16/2020
From:	Blocher E, William Burton, Disosway J, Earls C; NRC/NRR/DNRL/NLRP, Nuclear Energy Institute
To:	;
	Burton W
References
	Download: ML20196L925 (10)
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SLR-ISG Set #1 Industry Review Comments Chris Earls Eric Blocher John Disosway July 16, 2020

Agenda:

ISG Set #1 Industry Review Comments

XI.E7 High Voltage Insulators

XI.E3A/3B/3C Inaccessible Cables

XI.S8 Protective Coating Monitoring & Maintenance

XI.M2 Water Chemistry

XI.M26 Fire Protection (AMRs)

Missing AMRs

XI.M42 Internal Coatings

SLR-ISG-Electrical-2020-XX - Comments XI.E7 Voltage Classification

Text inserted to expand scope to include Medium Voltage does not conform to standard usage for power system classes.

Replace power systems operating at voltages above 4 kV with nominal system voltages greater than 1 kV and equal to or less than 765 kV)

XI.E7 New Aging Effect/Mechanism of Wind Driven Particles

New Aging Effect/Mechanism of wind driven particles impacting surfaces

- created without technical reference

- inconsistently assigned to metallic or insulating surfaces, and across insulator types (polymer, porcelain, or toughened glass)

Provide the technical justification for wind driven particles impacting surfaces or eliminate from the ISG.

Clarify which insulator types and which material types the new Aging Effect/Mechanism applies to.

SLR-ISG-Electrical-2020-XX - Comments XI.E3A/3B/3C Inaccessible Cables

Recommend deleting the additions of potentially before exposed to significant moisture within the Scope Elements (1) of AMPs XI.E3A and XI.E3B. Potentially was not added in AMP XI.E3C.

Potentially exposed is not the same as exposed and is inconsistent with the exception noted in the PBAPS SER (ML#

19317E013).

Based on operating experience cables elevated on supports might be potentially exposed but not actually exposed. This would result in unnecessary preventive and/or corrective actions. That is, cables exposed to significant moisture are tested to determine the age degradation of the electrical insulation.

Automated water level monitoring will prevent water accumulation and cable submersion.

SLR-ISG-Structural-2020-XX - Comments XI.S8 In-Vessel Debris Limits

September 2019, Staff Review Guidance for In-Vessel Downstream Effects Supporting Review of Generic Letter 2004-02 Responses (ML19228A011), indicates that in-vessel particulate debris limits are not necessary. Only in-vessel fiber limits are required.

Consistent with Generic Letter 2004-02 responses, qualified, unqualified, and damaged coatings (particulates) are one part of the total debris inventory. Debris inventory also includes insulation (fiber) and other debris.

Coatings are treated as particulates; therefore, there are no in-vessel debris limits required.

Recommend deleting Element 5 text inserted at the end of first paragraph to ensure in-vessel debris limits are not exceeded. Also delete other references to in-vessel debris margin in Element 5 and other portions of the AMP XI.S8. ©2020 Nuclear Energy Institute 5

SLR-ISG-Mechanical-2020-XX - Comments XI.M2 EPRI Primary Water Chemistry Guidelines

The correct EPRI document number for EPRI PWR Primary Water Chemistry Guidelines Rev 7, April 2017 is EPRI 30020005505.

Correction noted in NUREG-2221 Table 2-29 XI.M2 (pg 2-280)

Update the 2014 EPRI document issue date noted in the ISG to reflect April 2017

Update the following ISG Appendix B sections:

- Program Description (page 1)

- References (page 4)

- 3.1.6. References (page 8)

SLR-ISG-Mechanical-2020-XX - Comments XI.M26 Fire Protection AMR Changes

AMP XI.M26 manages cracking and loss of materials for cementitious, subliming and silicate fire barrier materials- See PBAPS SER (ML#

19317E013), Section 3.3.2.3.5

Delete Aging Effect for Change in Material Properties

Cementitious coatings Aging Effects consistent with NUREG-2191 AMP XI.M42 element 3

Loss of material and cracking is managed for cementitious materials. See the term Cracking due to chemical reaction, weathering, settlement, or corrosion of reinforcement (reinforced concrete only); loss of material due to delamination, exfoliation, spalling, popout, scaling, or cavitation, in the GALL-SLR Report Chapter IX.F.

Protection program based upon the intended function of enclosing or acting as a barrier for the material to be protected.

Based on the intended function, delamination or separation are aging mechanisms that potentially result in a loss of material.

SLR-ISG-Mechanical-2020-XX - Comments AMRs: Missing AMRs The following AMRs discussed with Industry during prior ISG meetings are missing from the Draft Mechanical ISG:

Loss of coating integrity in compressed air steel tanks

LOM in compressed air steel tanks

LOM/etc. in Zn in condensation environment

LOM/etc. in carbon steel, SS, and copper alloy in treated water

Use of XI.M20 or XI.M38 for AMR items VII.C1.A-400 & VII.C3.A-400

SLR-ISG-Mechanical-2020-XX - Comments XI.M42 Coating OE for Fire Water Systems

OE exclusion noted in item (c) of the last paragraph of AMP XI.M42 element 4 sets an unreasonable standard that is not consistent with plant CLB and License Renewal guidance.

Delete OE exclusion does not allow opportunistic inspections of internally coated fire water system piping if plant-specific OE is unacceptable (i.e. no leaks due to aging)

As noted in Plant CLB fire water system leakage is allowed and monitored, fire water system is normally maintained at required operating pressure by the jockey pump and is monitored such that loss of system pressure is detected and corrective actions initiated.

NUREG-2192 Appendix A indicates past failures would not necessarily invalidate an AMP because the feedback from OE should result in appropriate corrective action and/or program enhancements. Corrective actions, including causal evaluations, root cause determination, and prevention of recurrence, should be timely. Preventive actions should prevent recurrence.

Also delete OE discussion in the Reason for Revision Section. It implies that OE associated with different materials, environments and aging effects could be used to demonstrate OE is unacceptable.

Are there any comments that require discussion?

ML20196L925

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