ML20211K571
| ML20211K571 | |
| Person / Time | |
|---|---|
| Issue date: | 09/01/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20211K554 | List: |
| References | |
| PROJECT-704 NUDOCS 9909080023 | |
| Download: ML20211K571 (10) | |
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I FINAL SAFETY EVALUATION REPORT BY THE OFFICE OF THE NUCLEAR REACTOR REGULATION CONCERNING "BWR VESSEL AND INTERNALS PROJECT, INSTRUMENT PENETRATION I
- INSPECTION AND FLAW EVALUATION GUIDELINES (BWRVIP-49),"
FOR COMPLIANCE WITH THE LICENSE RENEWAL RULE
~
(10 CFR PART 54)
PROJECT NO. 704 1
9909080023 990901 i
PDR TOPRP EXIEPRI C
Table of Contents
1.0 INTRODUCTION
.1 1.1 Background..
.... 1
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1.2 Purpose......
......2 1.3 Organization of this Report
.2 j
2.0
SUMMARY
OF BWRVIP-49 REPORT..
.......2 2.1 identification of Structures and Components Subject to an Aging Management Review....
.............................. 3 2.2 Effects of Aging.............
..3 2.3 Aging Management Programs.............
..3 2.4 Time-Limited Aging Analyses...
.........................4 3.0 STAFF EVALUATION..
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. 3.1 Structures and Components Subject to Aging Management Review... 5 3.2 Intended Functions...
...5 3.3 Effects of Aging....
......5 l
3.4 Aging Management Programs.............................. 5 l
3.5 Time-Limited Aging Analyses
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4.0 CONCLUSION
S......
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4.1 Renewal Applicant Action items.............
....6
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i 1
5.0 REFERENCES
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FINAL SAFETY EVALUATION REPORT FOR "BWR VESSEL AND INTERNALS PROJECT, INSTRUMENT PENETRATION INSPECTION AND FLAW EVALUATION GUIDELINES (BWRVIP-49),"
FOR COMPLIANCE WITH THE LICENSE RENEWAL RULE (10 CFR PART 54)
PROJECT NO. 704
1.0 INTRODUCTION
1.1 Background
Ey letter dated March 13,1998, the Boiling Water Reactor Vessel and Internals Project (BWRVIP) submitted the Electric Power Research Institute (EPRI) Topical Report TR-108695, "BWR Vessel and Internals Project, Instrument Penetration Inspection and Flaw Evaluation Guidelines (BWRVIP-49)," for NRC staff review. The BWRVIP intended, in submitting the j
BWRVIP-49 report, to provide inspection and evaluation procedures to ensure the long term integrity of instrument penetrations. Instrument penetrations, consisting of penetrations, nozzles, and safe ends / extensions in a variety of configurations and materials, are used to allow j
measurement of reactor water level and maintain the reactor pressure boundary. The materials used are stainless steel, Alloy 600, Alloy 182 or 82, and low alloy steel (nozzles). The sizes of the instrument lines are under NPS 4 (4-inch pipe size). By letter dated August 4,1998, the NRC staff issued its safety evaluation (SE) on the BWRVIP-49 report's acceptability for the current operating period.
By letter dated April 2,1999, the BWRVIP submitted an expanded non-proprietary version of the BWRVIP-49 document, and the associated Appendix A, "BWR instrument Penetration inspection Demonstration of Compliance with the TechnicalInformation Requirements of the License Renewal Rule (10 CFR 54.21)," for NRC staff review in accordance with the License Renewal Rule (10 CFR Part 54).
Section 54.21 of the License Renewal Rule requires, in part, that each application for license renewal contain an integrated plant assessment (IPA) and an evaluation of time-limited aging analyses (TLAAs). The (PA must identify and list those structures and components subject to an aging management review and demonstrate that the effects of aging will be adequately managed so that their intended functions will be maintained consistent with the current licensing basis (CLB) for the period of extended operation. In addition,10 CFR 54.22 requires that each application include any technical specification changes or additions necessary to manage the effects of aging during the period of extended operation as part of the renewal application.
if a license renewal applicant participating in the BWRVIP confirms that the BWRVIP-49 document applies to its plant and that the results of the Appendix A IPA and TLAA evaluation are in effect at its plant, then no further review by the NRC staff of the issues described in the documents is necessary, except as specifically identified by the staff in its safety evaluation
. below. With this exception, such an applicant may rely on BWRVIP for the demonstration required by Section 54.21(a)(3) with respect to the components and structures within the scope of the report. Under such circumstances, the NRC staff intends to rely on the evaluation in this safety evaluation (SE) report to make the findings required by 10 CFR 54.29 with respect to a particular application.
1.2 Purpose The staff reviewed the BWRVIP-49 report to determine whether its guidance would ensure the long term integrity of instrument penetrations. The review also considered compliance with the License Renewal Rule in order to allow applicants the option ofincorporating the BWRVIP-49 guidelines by reference in a plant-specific IPA and associated TLAAs.
1.3 Organization of this Report This SE contains a brief summary of the general contents of the non-proprietary BWRVIP-49 report in Section 2, with the NRC staff's evaluation presented in Section 3. The conclusions are summarized in Section 4. The presentation of the evaluation is structured according to the organization of the BWRVIP-49 report.
2.0
SUMMARY
OF BWRVIP-49 REPORT The BWRVIP-49 report and its Appendix A contain a generic evaluation of the management of the effects of aging of the instrument penetrations so that the intended functions will be maintained consistent with the CLB for the period of extended operation. This evaluation applies to BWR applicants who have committed to implementing the BWRVIP-49 report and want to incorporate the report and Appendix A by reference into a plant-specific IPA and associated TLAAs.
2.1 The BWRVIP-49 report addresses the following topics:
Component Description and Function - The various instrument penetration components are described in considerable detail by a series of illustrations along with brief descriptions of each component's function and characteristics.
Susceptibility Factors - The various types of material degradation mechanisms (e.g.,
fatigue, stress corrosion cracking, age embrittlement) that could impact the instrument penetrations are characterized. Materials, stress, and environmental factors are described in general terms, followed by specific references to localized regions relative to plant operating experience for particular mechanisms and components.
Potential Failure Locations and Safety Conseauences - Each of the instrument penetrations (e.g., potential failure locations) are addressed from the standpoint of inspection history, future susceptibility to degradation, and consequences of failures in terms of component functions and plant safety. Based in these qualitative considerations, the BWRVIP-49 report concludes that the consequences of instrument penetration cracking would not prevent safe shut down of a plant.
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. Backaround and Inspection History - Data on service related failures of components are summarized. The major sources of such data are the various GE Service information f
Letters (SILs) and Rapid Information Communication Service Information Letters j
(RICSILs).
BWRVIP inspection Guidelines - The guidelines recommend the specific locations, NDE e
methods, and inspection frequencies for examinations of instrument penetrations.
2.2 Appendix A to the BWRVIP-49 report discusses the following topics:
2.2.1 Identification of Structures and Components Subject to an Aging Management Review i
10 CFR 54.21(a)(1) requires that an IPA identify and list those structures and components within the scope of license renewal that are subject to an aging management review. Structures and components subject to an aging management review shall encompass those structures and components that (1) perform an intended function, as described in 10 CFR 54.4, without moving parts or without a change in configuration or properties and (2) are not subject to replacement based on a qualified life or specified time period. These structures and components are also referred to as " passive" and "long-lived" structures and components, respectively.
In Section 2.0 of the BWRVIP-49 report, the BWRVIP describes the intended function of the instrument penetrations. Their functions are to allow the measurement of the reactor vessel water level, which is used as a signal for safety systems, and to maintain the reactor vessel pressure boundary.
In Appendix A, the BWRVlP identified the passive and long-lived components as required by 10 CFR 54.21(a)(1). The BWRVIP noted that the penetration configurations are passive and long-lived and, therefore, are subject to aging management review, 2.2.2 Effects of Aging The BWRVIP identifed the aging mechanisms and aging effects for the penetrations using the guidance from NUMARC 90-02, "BWR Reactor Pressure Vessel License Renewal Industry Report," Revision 1, dated August 1992, and the resolution to the NRC's questions on that Industry Report. The BWRVIP also used NUREG-1557, " Summary of TechnicalInformation and Agreements from Nuclear Management and Resources CouncilIndustry Reports Addressing License Renewal," dated October 199C ' i correlate the aging effects and their associated aging mechanisms. Using these repor _ ae BWRVIP determined that crack initiation and growth is the only aging effect that rec. es aging management review for the penetrations.
In Section 2.0 of the BWRVIP-49 report, the BWRVIP discussed the causes of crack initiation and growth and provided a susceptibiiity assessment, and also discussed the susceptibility factors of environment, materials, and stress state. The BWRVIP's review of the degradation history determined that there have been no leaks due to cracking at penetration welds.
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. 2.2.3 Aging Management Programs 10 CFR 54.21(a)(3) requires that the applicant demonstrate, for each component identified, that the effects of aging will be adequately managed so that the intended function will be maintained consistent with the CLB for the period of extended operation.
In Section 3.0 of the BWRVIP-49 report, the BWRVIP discussed the inspection strategy to be used for ensuring that cracks that might occur in the instrument penetrations are detected in a timely manner. The program specifies an ASME Section XI VT-2 visualinspection for leakage and ASME Section XI, IWB-2500, Category B-D volumetric inspections (for low alloy steel nozzle configurations). The BWRVIP concluded that both its inspection program and plant-specific considerations will result in verification of the pres sure boundary requirements in the CLB for the instrument penetrations.
2.3 Time-Limited Aging Analyses (TLAAs) 10 CFR 54.21(1)(c) requires that each application for license renewal contain an evaluation of time-limited aging analyses as defined in 10 CFR 54.3. TLAAs are those licensee calculations and analyses that:
(1) involve the instrument penetrations within the scope of license renewal,
_ (2) consider the effects of aging, (3) involve time-limited assumptions defined by the current operating term, (4) were determined to be relevant by the licensee in making a safety determination, (5) involve conclusions or provide the basis for conclusions related to the capability of the j
instrument penetrations to perform their intended function, and 1
(6) are contained or incorporated by reference in the CLB.
If a plant-specific analysis identified by an applicant meets all six criteria above, the analysis will be considered a TLAA for license renewal and evaluated by the applicant.
The susceptibility of the instrument penetrations to fatigue results in a potential TLAA issue. The BWRVIP evaluated this issue under 10 CFR 54.21(c)(1)(ii) by projecting the analysis to the end of the period of extended operation. The BWRVIP found that the typical cumulative usage factors for the penetrations are below the 0.4 threshold specified in NUMARC 90-02 for all instrument penetrations during the current and extended operating periods.
3.0 ' STAFF EVALUATION The staff reviewed the BWRVIP-49 report to determine if it demonstrated that the effects of aging on the subject reactor vessel components covered by the report will be adequately managed so that the components' intended functions will be maintained consistent with the CLB
. for the period of extended operation, in accordance with 10 CFR 54.21(a)(3). This is the last step in the IPA described in 10 CFR 54.21(a).
Besides the IPA, Part 54 requires an evaluation of TLAAs in accordance with 10 CFR 54.21(c).
The staff reviewed the BWRVIP-49 report to determine if the TLAAs covered by the report were evaluated for license renewal in accordance with 10 CFR 54.21(c)(1).
3.1 Structures and Components Subject to Aging Management Review The staff agrees that the instrument penetrations are subject to aging management review because they perform intended functions without moving parts or without a change in configuration or properties. The staff concludes that BWR applicants for license renewal must identify the instrument penetrations as subject to aging management review to meet the j
applicable requirements of 10 CFR 54.21(a)(1).
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3.2 Intended Functions The staff agrees that the intended functions of the instrument penetrations are as stated. Their intended functions are to allow the measurement of the reactor vessel water level, which is used
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as a signal for safety systems, and to maintain the reactor vessel pressure boundary.
3.3 Effects of Aging The information necessary to demonstrate compliance with the requirements of the license renewal rule 10 CFR 54.21 is provided in Appendix A of BWRVIP-49. The BWR Reactor Pressure VesselIndustry Report NUMARC 90-02, Revision 1, August 1992, and the resolution to the NRC's questions on that industry report were used to identify the aging mechanisms for j
the instrument penetrations. If the industry report concluded that the aging mechanism is significant then the aging mechanism was included in the aging management review. Using this methodology it was determined that crack initiation and growth is the only aging effect that required aging management review j
Accordingly, NUREG-1557 states that crack initiation and growth are the aging effects that need to be considered. The staff agrees that this mechanism is the only one applicable to the penetrations.
3.4 Aging Management Programs The staff evaluated the BWRVIP's aging management program to determine if it contains the following 10 elements constituting an adequate aging management program for license renewal:
scope of program, preventive actices, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience.
The staffs evaluation of the BWRVIP-49 report was transmitted by letter dated August 4,1998, to Carl Terry, BWRVIP Chairman. For the reasons set forth in that SER, the staff concluded that the inspection strategy and evaluation methodologies discussed in the BWRVIP-49 report are
. acceptable. Implementation of the above inspection program provides reasonable assurance that crack initiation and growth will be adequately managed such that the intended functions of the instrument penetrations will be maintained consistent with the CLB in the extended operating period.
3.5 Time-Limited Aging Analyses (TLAAs)
One of the mechanisms that can cause degradation of instrument penetrations is fatigue.
During the initial design process, the influence of fatigue on the penetrations was considered. In a majority of irstances, the penetrations were determined to be exempt from the requirements of a detailed ASME Code Section lli fatigue analysis. In those instances where a fatigue analysis was required, the fatigue cumulative usage factors were extended to 60 years and determined to be very low when compared to the Code allowable of 1.0.
4.0 CONCLUSION
S The staff has reviewed the subject BWRVIP-49 rec.rt submitted by the BWRVIP. On the basis of its review, the staff concludes that the BWRVir.49 report provides an acceptable demonstration that the BWRVIP member utilities referencing this topical report will adequately manage the aging effects of reactor vessel components within the scope of the report, with the exception of the noted renewal applicant action items set forth in Section 4.1 below, so that there is reasonable assurance that the reactor vessel instrument penetrations will perform their intended functions in accordance with the CLB during the period of extended operation. The staff also concludes that, upon completion of the renewal applicant action items, the BWRVIP-49 report provides an acceptable evaluation of time-limited aging analyses for the reactor vessel instrument penetrations for the BWRVIP member utilities for the period of extended operation.
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Any BWRVIP member utility may reference this report in a license renewal application to satisfy the requirements of (1) 10 CFR 54.21(a)(3) for demonstrating that the effects of aging on the reactor vessel components within the scope of this topical report will be adequately managed and (2) 10 CFR 54.21(c)(1) for demonstrating the appropriate findings regarding evaluation of time-limited aging analyses for the reactor vessel instrument penetrations for the period of extended operation. The staff also concludes that, upon completion of the renewal applicant action items set forth in Section 4.1 below, referencing this topical report in a license renewal application and summarizing in an FSAR supplement the aging management programs and the TLAA evaluations contained in this topical report will provide the staff with sufficient information to make the necessary findings required by Sections 54.29(a)(1) and (a)(2) for components within the scope of this topical report.
4.1 Renewal Applicant Action items The following are license renewal applicant action items to be addressed in the plant-specific license renewal application when incorporating the BWRVIP-49 report in a renewal application:
(1) The license renewal applicant is to verify that its plant is bounded by the topical report.
Further, the renewal applicant is to commit to programs described as necessary in the BWRVIP report to manage the effects of aging on the functionality of the reactor vessel o
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! instrument penetrations during the period of extended operation. Applicants for license renewal will be responsible for describing any such commitments and identifying how such commitments will be controlled. Any deviations from the aging management programs within this BWRVIP report described as necessary to manage the effects of aging during the period of extended operation and to maintain the functionality of the reactor vessel components or other information presented in the report, such as materials of construction, will have to be identified by the renewal applicant and evaluated on a plant-specific basis in accordance with 10 CFR 54.21(a)(3) and (c)(1).
(2) 10 CFR 54.21(d) requires that a FSAR supplement for the facility contain a summary description of the programs and activities for managing the effects of aging and the evaluation of TLAAs for the period of extended operation. Those applicants for license renewal referencing the BWRVIP-49 report for the instrument penetrations shall ensure that the programs and activities specified as necessary in BWRVIP-49 document are summarily described in the FSAR supplement.
(3) 10 CFR 54.22 requires that each application for license renewalinclude any technical specification changes (and the justification for the changes) or additions necessary to manage the effects of aging during the period of extended operation as part of the renewal application. In its Appendix A to the BWRVIP-49 report, the BWRVIP stated that there are no generic changes or additions to technical specifications associated with instrument penetrations as a result of its aging management review and that the applicant will provide the justification for plant-specific changes or additions. Those applicants for license renewal referencing BWRVIP-49 for the instrument penetrations shall ensure that the inspection strategy described in the BWRVIP-49 document does not conflict or result in any changes to their technical specifications. If technical specification changes do result, then the applicant should ensure that those changes are included in its application for license renewal.
5.0 REFERENCES
1.
NUREG-1557, Summary of TechnicalInformation and Agreements from Nuclear Management and Resources CouncilIndustry Reports Addressing License Renewal, October 1996.
L 2.
Electric Power Research Institute (EPRI) Topical Report TR-108695, "BWR Vessel and Internals Project, Instrument Penetration Inspection and Flaw Evaluation Guidelines (BWRVIP-49)," March 13,1998.
3.
Electric Power Research Institute (EPRI) Topica! Report TR-108695NP, "BWR Vessel and Internals Project, Instrument Penetration Inspection and Flaw Evaluation Guidelines (BWRVIP-49NP)," April 2,1999.
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