ML22311A080

Public Meeting Regarding Staff Review of EPRI Non-Proprietary Rpt MRP-227 R2 - 22-11-07

ML22311A080
Person / Time
Site:
Issue date:	11/07/2022
From:	James Medoff Licensing Processes Branch
To:
References
MRP-227, MRP-227, Rev 2, MRP-227, Revision 2, EPID L-2022-TOP-0029
Download: ML22311A080 (1)

Text

Public Meeting Regarding Staff Review of EPRI Non-Proprietary Report No. 3002020105, Materials Reliability Program: Pressurized Water Reactor Inspection and Evaluation Guidelines (MRP-227, Revision 2)

Clarifications on Scope of Staff Review Presenter: James Medoff Public Meeting of Nov. 7, 2022

Staff Review for TR MRP-227, Rev. 2 (the Subject TR)

• NRC accepted MRP-227, Rev. 2 for review in Summer of 2022

• NRC PM for MRP-227, Rev. 2 review initiated the review as a Standard Review with inclusion of a PM option to hold an audit of changes made in MRP-227, Rev. 2 from the prior version in MRP-227, Rev. 1-A Standard Review was chosen because:

Number and the complexity of changes in MRP-227, Rev. 2 versus MRP-227, Rev. 1-A Methodology in MRP-227, Rev. 2 assesses aging over a 80-year service period versus MRP-227, Rev. 1-A only assessed aging over a 60-year service period Potential logistics issues (See next slides for examples)

Regulatory Audit is being conducted for efficiency and effectiveness:

Address clarifications and confirmations Ensure RAI process is used only for necessary topics to support NRC review/conclusions in SE

TR MRP-227, Rev. 2 Logistics Issues

• Logistics Issue #1: Bases for some component-specific screening or inspection and evaluation have been revised in MRP-227, Rev. 2 versus MRP-227, Rev. 1-A Main objective of MRP-227, Rev. 2 - focus on changes to MRP-227 criteria that are needed to accommodate implementation of the guidelines during 60 - 80 year subsequent license renewal (SLR) periods NRC staff conclusions in MRP-227, Rev. 1-A (i.e.,related to 60-year service period) are may not be applicable for 80-year service period for these for some component-specific screening or inspection and evaluation

TR MRP-227, Rev. 2 Logistics Issues (Continued)

• Logistics Issue #2 - Revisions to Applicant/Licensee Action Item Resolution:

• MRP-227-A included Applicant/Licensee Action Items (A/LAI)

• MRP-227, Rev. 1-A addressed these Applicant/Licensee Action Items from MRP-227-A Justification to resolve these A/LAIs in MRP-227, Rev. 1-A were based on an aging over a 40 - 60 year license renewal period MRP-227, Rev. 2, appears to resolve some topics in these A/LAIs in a manner different from MRP-227, Rev. 1-A.

NRC staff seeks to understand if:

Resolution of A/LAIs remain valid for MRP-227, Rev. 2 or Updates made in MRP-227, Rev. 2, including bases, support A/LAIs remaining resolved for 80-year service period A/LAI #6 on inaccessible B&W core barrel components is an example.

TR MRP-227, Rev. 2 Logistics Issues (Continued)

• Logistics Issue #3 - Referencing of WCAP-17096-NP-A, Rev. 2 WCAP-17096-NP-A, Rev. 2 applies only to MRP-227-A (status of Primary and Expansion category components)

WCAP-17096, Rev. 3 (a pending review) applies to MRP-227, Rev. 1-A (the status of Primary and Expansion category components)

Version of WCAP-17096 applicable to MRP-227, Rev. 2 (status of Primary and Expansion category components) has NOT been developed yet

• Logistics Issue #4 - MRP-227, Rev. 2, discusses use of MRP-211 and BWRVIP-100, Revision 1-A lower bound fracture toughness value methods Chapter 6 does not address the Part 21 and open item on lower bound fracture toughness values identified in EPRI Letter MRP 2021-019

• Logistics Issue #5 - MRP-227, Rev. 2, references Crack Growth Model in EPRI Report No. 3002003103 Same report used for development of ASME Code Case N-889 MRP-227, Rev. 2 doe not address conditions on Code Case N-889, as described in able 2 of Regulatory Guide 1.147, Revision 20