ML20246G654
| ML20246G654 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 09/02/2020 |
| From: | Kissinger P Nuclear Energy Institute |
| To: | Borges J Office of Administration |
| References | |
| 85FR46735 00002, NRC-2020-0153 | |
| Download: ML20246G654 (5) | |
Text
PUBLIC SUBMISSION As of: 9/2/20 12:51 PM Received: September 02, 2020 Status: Pending_Post Tracking No. 1k4-9iqd-hffz Comments Due: September 02, 2020 Submission Type: Web Docket: NRC-2020-0153 Changes to Subsequent License Renewal Guidance Documents Comment On: NRC-2020-0153-0001 Changes to Subsequent License Renewal Guidance Documents Regarding Reactor Vessel Internal Components in Pressurized Water Reactors Document: NRC-2020-0153-DRAFT-0002 Comment on FR Doc # 2020-16699 Submitter Information Name: Pete Kissinger General Comment See attached file(s)
Attachments 09-02-20_NRC_Draft SLR-ISG-PWRVI NEI Comments Page 1 of 1 09/02/2020 https://www.fdms.gov/fdms/getcontent?objectId=09000064848387ac&format=xml&showorig=false SUNI Review Complete Template=ADM-013 E-RIDS=ADM-03 ADD: David Druker, Tekia Govan, William Burton, Jeffrey Mitchell Mary Neely Comment (2)
Publication Date:
8/3/2020 CITATION 85 FR 46735
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 September 2, 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 document SLR-ISG-PWRVI-2020-XX. [85 FR 46735; Docket ID NRC-2020-0153]
Dear Ms. Borges:
The Nuclear Energy Institute (NEI)1, on behalf of its members, submits the following comments to the Interim Staff Guidance (ISG) document related to subsequent license renewal (SLR). We are supportive of the effort to update this subsequent license renewal guidance based on lessons learned and appreciate the opportunity to comment on the following draft ISG document:
SLR-ISG-PWRVI-2020-XX, Updated Aging Management Criteria for Reactor Vessel Internal Components for Pressurized-Water Reactors, July 2020 In our review, we noted that the draft ISG offers improvements by incorporating lessons learned from subsequent license renewal activities to date. Specific comments to the PWRVI ISG are contained in the attachment to this letter. The following are examples of the more significant comments:
Revise the ISG guidance to reference MRP-191 Rev 2, Materials Reliability Program: Screening, Categorization, and Ranking of Reactor Internals Components, for Westinghouse and Combustion Engineering PWR Design, or MRP-189 Rev 3, Materials Reliability Program: Screening, Categorization, and Ranking of Babcock and Wilcox Designed Pressurized Water Reactor Internals Component Items and Welds, as acceptable ways to screen reactor vessel internals aging effects and aging mechanisms during the Reactor Vessel Internals Gap Analysis. Use of MRP-191 Rev 2 and MRP-189 Rev 3 will facilitate alignment with MRP-227 Rev 2, Materials Reliability Program:
Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, development and its associated NRC safety evaluation.
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 September 2, 2020 Page 2 Revise ISG guidance to reference MRP-2018-022, Materials Reliability Program: Transmittal of MRP-191-SLR Screening, Ranking and Categorization Results and Interim Guidance in Support of Subsequent License Renewal at U.S. PWR Plants, as an acceptable starting point for identification of changes to the existing MRP-227 Rev 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines, program characteristics or criteria during the Reactor Vessel Internals Gap Analysis. Use of MRP 2018-022 will facilitate alignment with MRP-227 Rev 2 development and its associated NRC safety evaluation Additionally, NEI has reviewed and supports the comments applicable to this ISG that are being submitted separately by EPRI.
Detailed comments are provided in the attachment to this letter. If you have questions on this matter, please contact me at pwk@nei.org or (612) 419-3602.
Sincerely, Peter W. Kissinger Attachments (1) c:
William (Butch) Burton, NRC/NRR Robert Caldwell, NRC/NRR Omid Tabatabai, NRC/NRR
SLR-ISG-PWR Vessel Internals-2020-XX Comment ISG Section/Page Comment Justification Proposed Resolution
- 1.
Appendix C FER 3.1.3.2.9 Page 3 & 4 of 4
PWR applicants will use MRP-191, Rev 2, Screening, Categorization, and Ranking of Reactor Internals Components, for Westinghouse and Combustion Engineering PWR Design, or MRP-189 Rev 3, Screening, Categorization, and Ranking of Babcock and Wilcox Designed Pressurized Water Reactor Internals Component Items and Welds, as the principal input for the aging effects and aging mechanism screening portion (first two bullets of the Gap Analysis on page 3 of Appendix C) for their Reactor Vessel Internals (RVI) Gap Analysis. Recommend revising the ISG to reference MRP-191 Rev 2 or MRP-189 Rev 3 as one acceptable way to screen RVI aging effects and aging mechanisms (first two bullets of the Gap Analysis on page 3 of ISG Appendix C).
Prior revisions of MRP-191 and MRP-189 have been used to perform screening, categorization, and ranking of PWR reactor internals in support of the development of MRP-227-A and MRP-227 Rev 1-A. MRP-227-A and MRP-227 Rev 1-A and the associated development methodology were accepted by NRC safety evaluation. Use of MRP-191 Rev 2 and MRP-189 Rev 3 will also align SLR applications with MRP-227 Rev 2 development activities.
Revise the RVI ISG to allow the use of MRP-191 Rev 2 and MRP-189 Rev 3 as one acceptable way to perform screening of RVI aging effects and aging mechanisms (first two bullets of the Gap Analysis on page 3 of Appendix C).
- 2.
Appendix C FER 3.1.3.2.9 Page 3 & 4 of 4
MRP 2018-022, Transmittal of MRP-191-SLR Screening, Ranking and Categorization Results and Interim Guidance in Support of Subsequent License Renewal at U.S. PWR Plants, provides expert panel results that supplement MRP-227 Inspection and Evaluation guidance for subsequent license renewal prior to the publication of MRP-227 Revision 2. Recommend revising the ISG to reference MRP-2018-022 as an acceptable starting point to identify changes to the existing MRP-227 Rev 1-A program characteristics or When issued, MRP 2018-022 guidance was the current state of knowledge and its guidance is expected to become applicable to the Westinghouse and Combustion Engineering fleet with the future publication of MRP-227 Rev 2.
MRP 2018-022 SLR recommended changes to NEI 03-08 Needed inspection tables associated with MRP-227-A have been made. Use of MRP 2018-022 will align SLR applications with MRP-227 Rev 2 development activities.
MRP-2018-022 guidance will be Revising ISG guidance to reference MRP-2018-022 as an acceptable starting point for identification of changes to the existing MRP-227 Rev 1-A program characteristics or criteria (third bullet of the Gap Analysis on page 3 of ISG Appendix C). It is recognized that MRP-2018-022 guidance will need to be supplemented with review of RVI operating experience since its publication to fully inform aging management changes to program characteristics or criteria.
SLR-ISG-PWR Vessel Internals-2020-XX Comment ISG Section/Page Comment Justification Proposed Resolution criteria (third bullet of the Gap Analysis on page 3 of ISG Appendix C).
supplemented with review of RVI operating experience since its publication to fully inform aging management changes to program characteristics or criteria (third bullet of the Gap Analysis on page 3 of ISG Appendix C).
MRP 2018-022 was previously reviewed by the NRC as part of the Surry Power Station SLR Safety Evaluation.
- 3.
Appendix B1 thru B4 various pages Aging effects and mechanisms identified in NUREG-2191 AMR lines and NUREG-2192 Table 1s should be consistent with those identified in MRP-227 Rev 1-A Section 4 I&E Tables.
Provides consistency of aging effects and aging mechanisms identified in NUREG-2191 AMR lines and NUREG-2192 Table 1s with the aging effects and aging mechanisms identified and managed by MRP-227-Rev 1-A Section 4 I&E Tables and associated NRC Safety Evaluation.
Revise aging effects and aging mechanisms identified in NUREG-2191 AMR lines and NUREG-2192 Table 1s to be consistent with the aging effects and aging mechanisms identified and managed by MRP-227-Rev 1-A Section 4 I&E Tables.