ML20224A465

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Comment (1) of Allison Borst & Peter W. Kissinger, on Behalf of Nuclear Energy Institute, on Changes to Subsequent License Renewal Guidance Documents
ML20224A465
Person / Time
Site: Nuclear Energy Institute
Issue date: 08/10/2020
From: Borst A, Kissinger P
Nuclear Energy Institute
To: Borges J
Office of Administration
References
85FR39938 00001, NRC-2020-0160
Download: ML20224A465 (15)
v • d • e


Text

Page 1 of 1 SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 8/11/20 3:25 PM ADD: David Ducker, Tekia Received: August 10, 2020 Govan, Mary Neely Status: Pending_Post PUBLIC SUBMISSION Comment (1) Tracking No. 1k4-9ib6-vym2 Publication Date: 7/2/2020 Comments Due: August 10, 2020 CITATION 85 FR 39938 Submission Type: Web Docket: NRC-2020-0160 Changes to Subsequent License Renewal Guidance Documents Comment On: NRC-2020-0160-0001 Changes to Subsequent License Renewal Guidance Documents Document: NRC-2020-0160-DRAFT-0006 Comment on FR Doc # 2020-14323 Submitter Information Name: Allison Borst General Comment See attached file(s)

Attachments 08-10-20_NRC_Industry Comments on draft ISGs for SLR + Attachments https://www.fdms.gov/fdms/getcontent?objectId=09000064847ec677&format=xml&showorig=false 08/11/2020

PETER W. KISSINGER Sr. Project Manager 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 612.419.3602 pwk@nei.org Submitted via Regulations.gov August 10, 2020 Ms. Jennifer Borges Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments on the proposed changes to subsequent license renewal documents (electrical, mechanical, and structural ISGs). [85 FR 39938 & 46192; Docket ID NRC-2020-0160]

Dear Ms. Borges:

The Nuclear Energy Institute (NEI) 1, on behalf of its members, submits the following comments to the Interim Staff Guidance (ISG) documents related to subsequent license renewal (SLR). We are supportive of the effort to update subsequent license renewal guidance based on lessons learned and appreciate the opportunity to comment on the following four draft ISG documents:

  • SLR-ISG-MECHANICAL-2020-XX ERRATA
  • SLR-ISG-STRUCTURES-2020-XX, Updated Aging Management Criteria for Structures Portions of Subsequent License Renewal Guidance, June 2020 In our review, we noted that the draft ISGs generally offer improvements by incorporating lessons learned from subsequent license renewal activities to date. Specific comments to the electrical, mechanical and structural ISGs are contained in attachments to this letter. The following are a few examples of the more significant comments:
  • Structural, Appendix B, AMP XI.S8, Protective Coating Monitoring and Maintenance Program: The requirement to manage in-vessel debris limit for Service Level 1 coatings conflicts with existing NRC guidance (e.g., Section 2.1.2 of Staff Review Guidance for In-Vessel Downstream Effects Supporting 1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Ms. Jennifer Borges August 10, 2020 Page 2 Review of Generic Letter 2004-02 Responses) and closure documents for potential issues related to Emergency Core Cooling System strainer performance.

  • Mechanical, Appendix H, AMP XI.M42, Internal Coatings/Linings for In-Scope Piping, Piping Components, Heat Exchangers, and Tanks Program: Guidance on the use of operating experience (OE) does not allow the consideration of other acceptable ways to manage aging that results in leakage from the fire water piping. It is also not consistent with NUREG-2192 Appendix A guidance on consideration of past failures, use of corrective actions and preventive actions. In addition, the ISG Appendix H basis of revision section implies that operating experience associated with different materials, environments and aging effects could be used to demonstrate that the OE is unacceptable. Past failures would not necessarily invalidate an AMP since Station OE and Corrective Action programs are in place to resolve these issues.
  • Mechanical, Appendix E, Cementitious Coatings AMR: Change in material properties is identified as a new aging effect requiring management for fire barrier coatings and is not consistent with NUREG-2191 guidance, aging management for loss of material and cracking of cementitious materials, or prior SLR Safety Evaluation Reports. There is no basis (technical or operating experience) provided in Appendix E for the new aging effect of change in material properties.

Detailed comments are provided in the attachments to this letter. If you have questions in this matter, please contact me at pwk@nei.org or (612) 419-3602.

Sincerely, Peter W. Kissinger Attachments (4) c: William (Butch) Burton, NRC/NRR Robert Caldwell, NRC/NRR Omid Tabatabai, NRC/NRR

SLR-ISG-ELECTRICAL-2020-XX Comment # ISG Section/Page Comment Justification Proposed Resolution

1. Appendix D Typographical errors in the following Editorial Change the sentence to read: Visual AMP XI.E7, sentence: Visual inspection is used to detect inspection is used to detect the following Element 4, Pages the following two aging degradations: (a) loss two aging degradations: (a) loss of material 4 and 5 of 61 of material in the metallic parts due to in the metallic parts due to corrosion and/or corrosions and/or frequent movement, and frequent movement, and insulation surfaces insulation surfaces that might be subject to that might be subject to wind driven dust wind driven dust particles impacting surfaces. particles impacting surfaces, and (b) reduced (b) reduced insulation resistance. insulation resistance.
2. Appendix D Added text of ISG places peeling of silicone Editorial Move this effect to a new sentence for AMP XI.E7, rubber sleeves under metallic parts in the polymer insulating materials.

Element 6, Page following sentence: Metallic parts must be 5 of 61 free from significant loss of materials due to pitting, fatigue, crevice, and general corrosion, and peeling of silicone rubber sleeves (for polymer high-voltage insulators only).

Silicone rubber sleeves are not metallic parts.

3. Appendix D Text inserted into the Program Description to ANSI C84.1-1989 Change the voltage limit from voltages AMP XI.E7, expand the scope of the AMP to insulators above 4kV to nominal system voltages Program used in medium voltage applications reads as greater than 1 kV and equal to or less than Description, Page follows: Although the term high-voltage is 765 kV. The corrected text would appear as 2 of 61 used throughout AMP XI.E7, this program follows: Although the term high-voltage includes all insulators used in power systems is used throughout AMP XI.E7, this program operating at voltages above 4 kV and installed includes all insulators used in power systems on in-scope portions of switchyards, operating at nominal system voltages transmission lines, and power systems if the greater than 1 kV and equal to or less than insulators, for practical purposes, have similar 765 kV, and installed on in-scope portions of design, application, material, construction, switchyards, transmission lines, and power and are exposed to the same environmental systems if the insulators, for practical stressors. purposes, have similar design, application, material, construction, and are exposed to The limit applied in the text, power systems the same environmental stressors.

operating at voltages above 4 kV, does not conform to standard usage for power system voltage classes and may create confusion for some applicants. Since the intent of the ISG is 3

SLR-ISG-ELECTRICAL-2020-XX Comment # ISG Section/Page Comment Justification Proposed Resolution to expand the scope to include insulators used in medium voltage applications, it is recommended to use industry standard voltage classifications. ANSI C84.1-1989 identifies the Medium Voltage class as a class of nominal system voltages greater than 1000 volts and less than 100,000 volts. The AMP currently includes the High Voltage class which is defined as a class of nominal system voltages equal to or greater than 100,000 volts and equal to or less than 230,000 volts.

Electrical systems operating at a system nominal voltage of greater than 230,000 volts and equal to or less than 765,000 volts would be Extra-High Voltage insulators. It is expected that the AMP may apply to insulators used in systems operating in the Medium Voltage, High Voltage, and Extra-High Voltage ranges.

4. Appendix D Same issue as item 3 above for voltage range ANSI C84.1-1989 Change the voltage limit from voltages AMP XI.E7, specified in Element 1. above 4kV to nominal system voltages Element 1, Page greater than 1 kV and equal to or less than 4 of 61 765 kV. The corrected text would appear as follows: This AMP manages the age-related degradation effects of high-voltage insulators (nominal system voltages greater than 1 kV and equal to or less than 765 kV) within the scope of subsequent license renewal, susceptible to wind and airborne contaminants including dust, salt, fog, cooling tower plume, industrial effluent or loss of material.
5. Appendix D Same issue as Item 3 above for voltage range ANSI C84.1-1989 Change the voltage limit from voltages Table XI.01 FSAR specified in the FSAR Supplement Summary. above 4kV to nominal system voltages Supplement greater than 1 kV and equal to or less than Summary for 765 kV. The corrected text would appear as XI.E7, Page 12 of follows: The program was developed 61 specifically to address aging management of 4

SLR-ISG-ELECTRICAL-2020-XX Comment # ISG Section/Page Comment Justification Proposed Resolution in-scope high-voltage insulators (used on systems with nominal system voltages greater than 1 kV and equal to or less than 765 kV for the purpose of this AMP) aging mechanisms and effects.

6. Appendix D The ISG introduces a new Aging Proposed requirements Identify the sources in technical literature AMP XI.E7, Effect/Mechanism of loss of material due to are confusing and do not that confirm wind driven particles Program wind-driven particles impacting surfaces. have a stated technical impacting surfaces as a significant aging Description, Page Physical wear due to wind driven particles has basis. effect/mechanism to demonstrate that this 4; Element 3, not been identified as a significant aging effect is an aging effect requiring management or Page 4; Element in technical literature associated with eliminate wind-driven particles impacting 4, Page 5; insulators. surfaces as a valid aging effect/mechanism.

Summary Table on Page 44; Also, although SRP-SLR Table 3.6-1 and GALL- If wind driven particles impacting surfaces Chapter VI, Table SLR Table VI apply this aging is to be included as a valid aging A on Page 59 effect/mechanism to both the mechanical effect/mechanism, then it should be clearly portions and insulating materials of all types of stated which types of insulators are insulators (porcelain, polymer, and toughened susceptible to the new Aging glass), the Program Description revised text Effect/Mechanism of wind driven particles applies this to only the insulating surfaces of impacting surfaces and whether this polymer and toughened glass insulators. applies to metallic components, insulating Element 3, Parameters Monitored or surfaces, or both in the Program Inspected, applies this new aging Description, Element 3, Element 4, the effect/mechanism to all types of insulators, Summary Table, and Chapter VI, Table A.

but only the metallic parts of the insulators.

Element 4, Detection of Aging Effects, applies this aging effect/mechanism to all types of insulators, but only the insulation surfaces of the insulators.

It is unclear if this new aging effect/mechanism is a valid aging effect/mechanism, and, if so, how the regulator intends to apply this new aging effect/mechanism.

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SLR-ISG-ELECTRICAL-2020-XX Comment # ISG Section/Page Comment Justification Proposed Resolution

7. App. D AMP XI.E7 Recommend removing the word dust from The phrase subject to Change subject to wind driven dust Element 4 Page 5 the first sentence on top of page 5. wind driven dust particles impacting surfaces to subject to of 61 particles impacting wind-driven particles impacting surfaces.

surfaces is used only once in the HVI ISG. All other phrases in the HVI ISG state wind-driven particles. Removing the word dust will align this phrase with the other phrases used in the HVI ISG.

8. App. A AMP The additions of potentially before exposed The use of potentially Remove potentially to avoid unnecessary XI.E3A to significant moisture within the Scope could drive unnecessary inspections.

App. B AMP Elements (1) of AMPs XI.E3A and E3B but not inspections.

XI.E3B in E3C. While the same insertion was not App. C AMP made in the program description summary, XI.E3C we should ask about these additions in that they could create tangible effect(s) on For each AMP: implementing scope (for example, in E3A, Program Desc. cables elevated on supports might be Page 2 potentially exposed but not actually Element 2 Page 4 exposed). Why were these added beyond the main approved Peach Bottom Exception item of longer periods between inspections if automated water level monitoring successfully prevents water accumulation and cable submersion?

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SLR-ISG-MECHANICAL-2020-XX AMP Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
1. Appendix B AMP XI.M2, Water Chemistry See EPRI 30020005505, Rev 7 and Correct the following ISG AMP XI.M2 The correct EPRI document number for EPRI NUREG-2221 Table 2-29 XI.M2 (pg 2-280) sections for AMP XI.M2 to Page 1, 4, 8 PWR Primary Water Chemistry Guidelines Rev update the EPRI document of 10 7, April 2014 is EPRI 3002000505. The following number from EPRI 1014986 ISG sections for AMP XI.M2 require update of the to EPRI 3002000505:

EPRI document number: - Program Description (pg 1)

- Program Description (pg 1) - References (pg 4)

- References (pg 4) - 3.1.6 References (pg 8)

- 3.1.6 References (pg 8)

2. Appendix B, Proposed Revisions to Aging Management EPRI Report 3002010645 Revision 8 was Revise Basis for Revisions XI.M2, Program XI.M2, Water Chemistry, incorrectly published in 2017. section to note:

Water state that the EPRI Secondary Water Chemistry EPRI issued 3002010645, Chemistry, Guidelines Rev 8 was published in 2014. EPRI Pressurized Water Reactor Page 1 of 10 Report 3002010645 Revision 8 was published in Secondary Water Chemistry 2017. Guidelines, Revision 8, in 2014 2017 from the previous version (1016555).

3. Appendix E Cementitious Coatings NUREG-2191 AMP XI.M42 element 3 Revise aging effects managed VII.G.A-806 AMP XI.M26 manages cracking and loss of identifies aging effects managed for for cementitious coatings to Page 1, 17, materials for cementitious coatings. ISG proposed cementitious coatings as follows: specify:

77 aging effects are not consistent with aging effects Loss of material and cracking is managed for Cracking due to chemical managed for cementitious coatings identified in cementitious materials. See the term reaction or settlement; or NUREG-2191 AMP XI.M42 element 3 and Peach Cracking due to chemical reaction, loss of material due to Bottom SER (ML# 19317E013), Section 3.3.2.3.5. weathering, settlement, or corrosion of exfoliation, delamination, Based on the intended function, delamination and reinforcement (reinforced concrete only); loss separation, spalling.

separation are aging mechanisms that potentially of material due to delamination, exfoliation, Note separation was result in a loss of material. Change in material spalling, popout, scaling, or cavitation, in the proposed to be added as an properties is not an aging effect that results in a GALL-SLR Report Chapter IX.F. aging mechanism rather than loss of intended function in cementitious an aging effect.

coatings. No reference is provided in the Basis for In addition, Peach Bottom SER (ML#

Revision section of the ISG for change in material 19317E013), Section 3.3.2.3.5 also identifies properties of cementitious materials. loss of material and cracking as aging effects requiring management for cementitious fireproofing coating.

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SLR-ISG-MECHANICAL-2020-XX Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
4. Appendix E Subliming Compounds Peach Bottom SER (ML# 19317E013), Section Revise aging effects managed VII.G.A-805 Subliming compounds are fire-resistant coating 3.3.2.3.5 identifies loss of material and for subliming compounds to Page 1, 16 materials. Based on the fire proofing application, cracking as aging effects requiring specify:

and 77 loss of material and cracking are the appropriate management for subliming fireproofing Cracking due to chemical aging effects to be managed by the Fire coating. Based on the intended function, reaction or settlement; or Protection program based upon the intended delamination and separation are aging loss of material due to function of enclosing the material to be mechanism that could result in a loss of vibration, delamination, protected. Based on the intended function, material. Change in material properties is not separation, flaking.

delamination and separation are aging an aging effect that results in a loss of Note delamination and mechanisms that potentially result in a loss of intended function in subliming compounds. separation were proposed to material. Change in material properties is not an be added as aging aging effect that results in a loss of intended mechanisms rather than function in subliming compounds. aging effects.

No reference is provided in the Basis for Revision section of the ISG for change in material properties of subliming materials.

5. Appendix E Silicates Peach Bottom SER (ML# 19317E013), Section Revise aging effects managed VII.G.A-807 Silicates are fire-resistant insulation or barrier 3.3.2.3.5 identifies loss of material and for silicate materials to Page 1, 17 materials. Based on the fire proofing application, cracking as aging effects requiring specify:

and 77 loss of material and cracking are the appropriate management for silicate fireproofing Cracking due to settlement; aging effects to be managed by the Fire materials. Based on the intended function, or Loss of material due to Protection program based upon the intended delamination and separation are aging flaking, delamination, function of enclosing or acting as a barrier for the mechanism that could result in a loss of separation.

material to be protected. Based on the intended material. Change in material properties is not Note delamination and function, delamination or separation are aging an aging effect that results in a loss of separation were proposed to mechanisms that potentially result in a loss of intended function in silicate materials. be added as aging material. Change in material properties is not an mechanisms rather than aging effect that results in a loss of intended aging effects.

function in silicates.

No reference is provided in the Basis for Revision section of the ISG for change in material properties of silicates 8

SLR-ISG-MECHANICAL-2020-XX Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
6. Appendix E NUREG-2192 Table 3.3-1 item 265 & 266 This is too narrow of a definition. Use the component type of Page 76 and NUREG-2191 VII.H2.A-790 and VII.H2.A-800: Heat Exchanger Tubes.

Appendix F, Dont limit the component type to radiator Page 12 tubes. Recommend using a component type of heat exchanger tubes.

7. Appendix H AMP XI.M42 Internal Coatings: NUREG-2192 Appendix A indicates past Delete item (c) in the last Page 7 of 12 Delete item (c) in the last paragraph of AMP failures would not necessarily invalidate an paragraph of element 4 that element 4 that permits opportunistic inspections AMP because the feedback from OE should permits opportunistic of internally coated fire water system piping if result in appropriate corrective action and/or inspections of internally plant-specific OE is acceptable (i.e., no leaks due program enhancements or new programs. coated fire water system to aging). This sets an unreasonable standard that Corrective actions, including causal coatings only if plant-specific is not consistent with plant CLB and License evaluations, root cause determination, and OE is acceptable (i.e., no Renewal guidance. One age related leak allowed prevention of recurrence, should be timely. leaks due to aging).

by the CLB anytime during plant lifetime that was Preventive actions should prevent recurrence.

corrected with no recurrence at a dual unit site Recurring internal corrosion can result in the (fire water is typically a common system) could be need to augment AMPs beyond the considered unacceptable OE for both units. This is recommendations in the GALL-SLR Report.

also inconsistent with NUREG-2191/2192 From a plant CLB perspective, fire water guidance on the use of operating experience that system leakage is allowed and monitored. Fire permits corrective actions to prevent recurrence water system is normally maintained at and augmenting AMPs beyond GALL-SLR to required operating pressure by the jockey effectively manage aging. pump and is maintained such that loss of system pressure id detected and corrective actions initiated before there is a loss of intended function.

8. Appendix H AMP XI.M42 Internal Coatings: Fire water system coatings Operating Delete Operating Experience Page 1 of 12 Delete Operating Experience discussion in the Experience should be compared on a basis of discussion in the Basis for Basis for Basis for Revision Section. It implies that OE same coating, environment, and aging effect. Revision Section.

Revision associated with different materials, environments Different coating materials in different Section and aging effects (buried externally fire water environments will age differently.

piping vs Internally coated fire water piping with different coatings) could be used to demonstrate OE is unacceptable.

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SLR-ISG-MECHANICAL-2020-XX Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
9. TBD The following AMRs were discussed with the Provide information for missing AMRs. Issue errata letter.

(missing Industry during prior ISG meetings are missing AMRs) from the Draft Mechanical ISG:

- Loss of coating integrity in compressed air steel tanks (#2)

- LOM in compressed air steel tanks (#3)

- LOM/etc. in Zn in condensation environment

(#4)

- LOM/etc. in carbon steel, SS, and copper alloy in treated water (#12)

- Use of XI.M20 or XI.M38 for AMR items VII.C1.A-400 & VII.C3.A-400 (#16) 10

SLR-ISG-MECHANICAL-2020-XX - ERRATA Comment ISG Section/Page Comment Justification Proposed Resolution

1. Mechanical ISG, Changes to add NUREG-2191 Chapter The proposed NUREG-2191 AMR Line Revise AMR lines VII.E1.AP-79 and Appendix H, VII AMR lines for stainless steel in a revisions noted (See Comment 1 details VII.E1.A-103 as noted by red underline pages 5 to 15 of treated water environment were on the next page) for AMR lines text (See Comment 1 details on the next 15, Revised AMRs discussed during the lessons learned VII.E1.AP-79 and VII.E1.A-103 would page) to add a treated water Table VII.E1 meetings but not provided in the ISGs. simplify Staff SLRA review by eliminating environment and nickel alloy Revise existing AMR lines to provide the need for Applicants to provide cross- components. As an alternative, separate PWR stainless steel in a treated water Chapter annotations in SLRA Chapter 3 AMR lines could be created for the environment AMR lines in NUREG- Table 1s. Nickel alloy components should changes related to stainless steel in a 2191 Chapter VII consistent with also be added to be consistent with treated water environment. This would those in NUREG-2191 Chapter VIII. NUREG-2192 item 124. No changes are also require a NUREG-2192 change to (See Comment 1 details on the next required to NUREG-2192. incorporate the new AMR lines.

page).

2. Mechanical ISG, As discussed in the GALL Lesson The proposed NUREG-2191 and NUREG- Add a NUREG 2191 Chapter VII AMR line Appendix H, learned meeting, a NUREG 2191 292 changes would simplify Staff SLRA and an associated NUREG-2192 Table 1 pages 5 to 15 of Chapter VII AMR line and an review by eliminating the need for line for carbon steel in a treated water 15, Revised AMRs associated NUREG-2192 Table 1 line Applicants to provide cross-Chapter environment consistent with NUREG-Table VII.E1 are requested for carbon steel in a annotations in SLRA Chapter 3 Table 1s. 2192 Table 3.4-1 item 14.

treated water environment consistent with NUREG-2192 Table 3.4-1 item 14.

3. Mechanical ISG, On NUREG-2192 Table 3.3-1 item 138 Addition of the noted environments on Add air-dry, air, and condensation Appendix H, page and item 139, add air-dry, air, and NUREG-2192 Table 3.3-1 item 138 and environments in the component column 15 of 15 condensation environments in the item 139 is required to be consistent of NUREG-2192 Table 3.3-1 item 138 and component column to be consistent with the proposed changes for the item 139.

with the proposed changes for AMR referenced AMR lines VII.D.A-416 and lines VII.D.A-416 and VII.V.A-414. VII.V.A-414.

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SLR-ISG-MECHANICAL-2020-XX - ERRATA Comment 1 Details Management of Loss of Material and Cracking in Stainless Steel and Nickel Alloys with Treated Water Environments for NUREG-2191 Chapter VII Systems

1. Management of loss of material due to pitting, crevice corrosion, and MIC and cracking due to SCC in stainless steel, and nickel alloy exposed to a treated water environment by Water Chemistry (XI.M2) and One-Time Inspection Program (XI.M32) for GALL-SLR Chapter VII PWR Systems (e.g., CVCS).

Management of cracking due to SCC in stainless steel, and nickel alloy exposed to a treated water environment >60oC (>140o F) by Water Chemistry (XI.M2) and One-Time Inspection Program (XI.M32) is also recommended.

Justification: Provides a PWR treated water environment AMR line in NUREG-2191 Chapter VII consistent with those in NUREG-2191 Chapter VIII.

VII Auxiliary Systems Table E1 Chemical and Volume Control System (PWR)

Structure Aging SRP Item Aging Management Further Item and/or Material Environment (Table ID) Effect/Mechanism Program Evaluation Component VII.E1.AP-79 3.3-1,125 Piping, piping Stainless Steel; Treated water, Loss of material (AMP)/TLAA AMP XI.M2, "Water No components, steel with treated borated due to pitting, Chemistry," and AMP tanks stainless steel water crevice corrosion, XI.M32, One-Time cladding, nickel MIC Inspection alloy VII.E1.A-103 3.3-1,124 Piping, piping Stainless Steel, Treated water Cracking due to AMP XI.M2, "Water No components, nickel alloy >60oC (>140o F), SCC Chemistry," and AMP tanks treated borated XI.M32, One-Time water >60oC Inspection 12

SLR-ISG-STRUCTURES-2020-XX Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
1. Appendix B Aging management of in-vessel Qualified, unqualified, and damaged coatings are Recommend deleting Element 5 text AMP XI.S8 debris limits is not required. one part of the total debris inventory for GSI-191 inserted at the end of first paragraph Page 2, 3, and Consistent with GSI-191 evaluations of ECCS suction strainers. Existing to ensure in-vessel debris limits are 4 of 7 evaluations and closure aging management programs for coatings address not exceeded. Also delete other documentation, aging management degradation of qualified coatings and changes to references to in-vessel debris of coating integrity and the unqualified coatings. In GSI-191 evaluations, margin in Element 5 and other contribution of qualified, coating debris is treated as particulates and portions of the AMP XI.S8 as well as unqualified, and damaged coatings insulation debris is treated as fibers. the Basis for Revision section of the to the ECCS suction strainer total For PWRs, Section 2.1.2 the 2019 Staff Review ISG.

debris term/inventory will provide Guidance for In-Vessel Downstream Effects reasonable assurance of ECCS sump Supporting Review of Generic Letter 2004-02 strainer functions including Responses (ML19228A011), indicates in-vessel associated downstream effects and particulate debris limits are not necessary. Only in-in-vessel effects. vessel fiber limits are required. Staff previously concluded in a Technical Evaluation Report that post-LOCA debris limits inside the reactor vessel has low safety significance (ML19073A044).

For BWRs, the June 2018 letter for Closure of Potential Issues Related to ECCS Strainer Performance at BWRs (ML18078A061) also concluded that the BWROG Phase IV and V ECCS strainer evaluation demonstrated that debris impacts on ECCS sump strainer performance and associated ECCS downstream and in-vessel effects had low risk significance. The BWROG evaluations addressed coating assessment as one of 12 general issues and noted that fiber debris was the only criterion for strainer failure caused by large loadings of particulates that may include debris captured in coating assessments. Existing plant programs were assessed for management of qualified and unqualified coatings.

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SLR-ISG-STRUCTURES-2020-XX Comment ISG Comment Justification Proposed Resolution

  1. Section/Page
2. Appendix B, The trending of the total amount of The total amount of potential debris is the overall Generalize the last sentence to AMP XI.S8, degraded coatings, which is concern, not just coatings, which are only a require trending of the allowable Protective allowed, is generally completed by portion of the potential debris. As a result, overall amount of debris, including coatings, Coating someone else in the engineering trending of debris is generally completed by and delete the reference to the Page 1 of 7 organization that is knowledgeable someone else in the engineering organization that coating inspector trending the Item #1 in of the ECCS Strainer debris loading is knowledgeable of the ECCS Strainer debris allowable amount of degraded Basis of analysis and is not typically loading analysis, instead of a qualified coating coatings. This would be consistent Revision performed by the qualified coating inspector, that may be a contractor. with the AMP markup.

inspector.

3. Appendix B, Any coating degradation NUREG-2191 AMP XI.S8 element 3 identifies the Revise the second paragraph of item AMP XI.S8, mechanisms noted in item #5 following parameters monitored or inspected: #5 to read as follows:

Protective second paragraph in the Basis For blistering, cracking, flaking, peeling, rusting, and For an applicant to demonstrate that Coating Revision section is not consistent physical damage. Aging management programs an inspection interval of longer than Page 2 of 7 with guidance in NUREG-2191 AMP manage aging effects not age-related degradation every refueling outage is appropriate, Item #5 in XI.S8. Clarify the second paragraph mechanisms. it is necessary to identify any coating Basis of to identify aging effects monitored degradation mechanisms present Revision or inspected (e.g., blistering, aging effects such as blistering, cracking, flaking, peeling, rusting, cracking, flaking, peeling, rusting, and and physical damage) to be physical damage and to demonstrate consistent with element #3 of acceptable historical coating NUREG-2191 AMP XI.S8. performance. This is because coating degradation mechanisms can cause large amount of coatings.

4. Appendices C, The use of the term enhanced as The applicants response to the Further Delete enhanced as necessary in D, and E necessary in the AMP column of Evaluations will indicate if a plant specific AMP is the AMP column of NUREG-2192 NUREG-2192 NUREG-2192 Table 3.5-1 and required or if the existing GALL-SLR requires Table 3.5-1 and NUREG-2191 Table 3.5-1, NUREG-2191 Chapter II and enhancement based on the information presented Chapter II and III AMR Tables.

NUREG-2191 Chapter III AMR Tables are not in the Further Evaluation.

Chapters II & necessary and should be deleted.

III Tables Page - various 14

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