ML23229A002

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SLR Guidance Update Public Meetings Slides - 8-21-2023 Mechanical
ML23229A002
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Issue date: 08/21/2023
From: Carol Moyer, Sayoc E
NRC/NRR/DNRL/NLIB
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Subsequent License Renewal Guidance Update GALL-SLR/SRP-SLR Notable Proposed Revisions Mechanical U.S. Nuclear Regulatory Commission Emmanuel Sayoc, Carol Moyer August 21, 2023

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Background===

General Reminders

  • Public comment period 7/11/23 to 9/11/23.
  • Purpose of this meeting is o to interact with the public regarding SLR Guidance o to provide an overview of the revision process and significant updates o to offer recommendations on how to best formulate comments to facilitate staff adjudication or resolution.
  • No Staff decisions, findings, or commitments to be made during these public meetings.
  • Comments should be submitted in writing with sufficient detail, justification or explanation.

o Mark up of proposed changes is highly recommended 3

Submission of Comments

o Submit comments online.

  • Alternate Method o Mail comments to: Office of Administration, Mail Stop: TWFN-7-A60M, U.S.

Nuclear Regulatory Commission, Washington, DC 20555-0001, ATTN: Program Management, Announcements and Editing Staff.

  • Deadline September 11, 2023 4

Guidance Documents for Subsequent License Renewal (SLR)

o published Dec 2017, ML17362A126 o Supplement 1, Draft for Comment, Published July 2023, ML23180A208 Public Comment Period: 7/11/23 to 9/11/23 5

Bases for Updates to SLR Guidance Documents

  • Revised and new guidance based on:

o New or updated industry guidance, and Codes and standards o Plant operating experience o Research o To fill gaps or make technical revisions in guidance identified from previous SLR reviews

  • Substantive corrections
  • Incorporate completed SLR-ISGs since initial SLR guidance development.

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Summary of Notable Proposed Revisions (Mechanical)

Incorporation of Completed Interim Staff Guidance (ISGs)

  • Structural ISG (SLR-ISG-2021-03-STRUCTURES)(1) issued 2/18/2021
  • Mechanical ISG (SLR-ISG-2021-02-MECHANICAL)(2) issued 2/18/2021
  • Electrical ISG (SLR-ISG-2021-04-ELECTRICAL)(3) issued 2/18/2021

Reactor Pressure Vessel Supports

  • Updated guidance to address loss of fracture toughness due to irradiation of reactor vessel structural steel support components and potential loss of intended function of the support assembly o New AMR that provides guidance to evaluate whether a plant-specific AMP or plant-specific enhancement to existing AMP is needed o Current guidance only addresses irradiation of concrete 9

AMP XI.M19 Steam Generators

  • Updated the inspection frequency of divider plate assemblies, tube-to-tubesheet welds, heads (channel or lower/upper heads), and tubesheets to be consistent with the maximum inspection interval allowed by the steam generator tube inspection requirements in Revision 5 of the Standard Technical Specifications.

oTechnical Specifications Task Force Travel 577, which has been incorporated into Revision 5 of the Standard Technical Specifications, increased the maximum inspection interval for thermally treated alloy 690 tubing to 96 effective full power months.

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AMP XI.M27 Fire Water System

  • Revised drain down level for hydrant barrels based on the plant-specific frost line and operating experience.
  • Added visual inspection and cleaning of the mainline strainers of the private fire service main consistent with NFPA 25 Section 7.2.2.3.
  • Revised inspection of the exterior surfaces of insulated fire water storage tanks to allow insulation removal and inspection consistent with AMP XI.M29, Outdoor and Large Atmospheric and Metallic Storage Tanks, and revised the inspection frequency consistent with AMP XI.M29.
  • Added replacing or testing dry sprinklers and fast response sprinklers consistent with NFPA 25 Sections and 5.3.1.1.1.6 and 5.3.1.1.1.3, respectively.
  • Revised extent and frequency for other water-based fire protection component inspections and tests based on plant-specific operating experience, results meeting acceptance criteria, and sampling-based AMPs.

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AMP XI.M32 One-Time Inspection

  • Revised to incorporate an incubation period for one-time inspections of replaced/repaired components to ensure confidence that age related degradation will not affect the components 12

AMP XI.M33 Selective Leaching

  • Based on operating experience:

o Eliminated the conditional exclusion of buried components with external coatings from inspection o Included malleable iron as a material susceptible to selective leaching o A technical justification for using the sample size specified in the AMP should be provided for gray cast iron piping exposed to soil.

  • Revised recommendations to consider soil parameter consistency when reducing the total number of inspections at multi-unit sites for buried components.

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AMP XI.M41 Buried and Underground Piping and Tanks

  • Clarified the guidance on cathodic protection of copper alloy or aluminum alloy components.
  • Clarified evaluation of plant-specific OpE includes out-of-scope buried components if they are representative of in-scope buried components.
  • Revised the Preventive Actions program element to recommend external coatings for underground cementitious piping.
  • Clarified that Preventive Action Category F inspection is for in-scope buried piping that has a cathodic protection system installed, which is not meeting the performance criteria defined in Preventive Action Category C.

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AMP XI.M43 HDPE Piping and CFRP

  • New AMP added to manage the aging of the internal and external surfaces of high-density polyethylene (HDPE) piping and carbon fiber reinforced polymer (CFRP) o CFRP Included as a new material
  • Identifies the parameters monitored or inspected to detect aging effects, such as loss of material, cracking, disbondment, damage, and leakage.
  • Depending on the material o inspection activities may include electrochemical verification of the effectiveness of the cathodic protection for the metallic substrate of the terminal ends of the repaired piping o nondestructive evaluation (NDE) of pipe wall thicknesses o pressure testing of the pipe o volumetric and visual inspections of the pipe from the exterior and/or interior surfaces.

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AMP XI.M43 HDPE Piping and CFRP (cont.)

  • Inspections are conducted during each 10-year period, commencing 10 years prior to the subsequent period of extended operation.
  • Acceptance criteria are based on the material type.

o For HDPE, the acceptance criteria include requirements for cracking, backfill, pressure tests, and surface scratches or blemishes.

o For CFRP, acceptance criteria are provided for coating degradation, cracking, wall thickness measurement (loss of material), pressure tests, delamination, disbondment, backfill, and pipe to soil potential when using a saturated copper/copper sulfate reference electrode.

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Path Forward

  • Formal comments from all parties are invited, deadline 9/11/23.
  • Formal comments will be addressed prior to finalizing NUREGs.
  • Final draft NUREGs to be presented to Advisory Committee for Reactor Safeguards.
  • Final NUREGs issued, estimate Oct 2024.

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Questions and Discussion 18

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