ML23284A374
| ML23284A374 | |
| Person / Time | |
|---|---|
| Issue date: | 10/10/2023 |
| From: | Sayoc E, Leslie Terry NRC |
| To: | Office of Administration |
| References | |
| NRC-2023-0096, 88FR53544 00027 | |
| Download: ML23284A374 (1) | |
Text
10/11/23, 8:08 AM blob:https://www.fdms.gov/9cd5349c-294f-4173-addf-44d1a126e7e7 SUNSI Review Complete Template=ADM-013 E-RIDS=ADM-03 As of: 10/11/23, 8:08 AM ADD: Manny Sayoc; Received: October 10, 2023 PUBLIC SUBMISSION Carol Moyer; Priyam Talukdar, Mary Neely Status: Pending_Post Tracking No. lnk-mbi9-njns Comment (27) Comments Due: October 11, 2023 Publication Date:
8/8/2023 Submission Type: Web Citation: 88 FR 53544 Docket: NRC-2023-0096 Draft NUREG : Revision 1 of Subsequent License Renewal Guidance Documents, and Supplement 1 to Associated Technical Basis Document Comment On: NRC-2023-0096-0001 Draft NUREG: Revision to Subsequent License Renewal Guidance Documents, and Supplement to Associated Technical Bases Document Document: NRC-2023-0096-DRAFT-0031 Comment on FR Doc # 2023-14577 Submitter Information Email: emmanuel.sayoc@nrc.gov Government Agency Type: Federal Government Agency: NRC General Comment Comment from Leslie Terry, NRC Staff related to AMP XI.M19 Steam Generators.
Attachments Comments on Draft Docs Related to AMP XI.M19 Steam Generators blob:https://www.fdms.gov/9cd5349c-294f-4173-addf-44d1a126e7e7 1/1
Comments Related to AMP XI.M19 Steam Generators Draft Revision 1 of NUREG-2192 Comment 1: The following parenthetical was added to Item 1 in Section 3.1.2.2.11 in draft Revision 1 of NUREG-2192, (e.g., dimensional assumptions for the divider plate, channel head, tube sheet and stub runner; material assumptions for the bottom head and cladding, upper vessel wall, tubesheet, stub runner, divider plate and welds, design, and transient loads).
Because both design loads and transient loads are examples of plant-specific parameters to be compared to the industry analyses, please consider revising the parenthetical as follows:
(e.g., dimensional assumptions for the divider plate, channel head, tube sheet and stub runner; material assumptions for the bottom head and cladding, upper vessel wall, tubesheet, stub runner, divider plate and welds; design and transient loads)
Comment 2: Section 3.1.2.2.11 in draft Revision 1 of NUREG-2192 uses the following phrases:
Steam Generator AMP, Steam Generators AMP, and Steam Generator Program. Please consider revising the section for consistency.
In addition, Section 3.1.3.2.10 in draft Revision 1 of NUREG-2192 uses the following phrases:
one-time inspection AMP and One-Time Inspection AMP. Please consider revising the section for consistency.
Comment 3: Section 3.1.2.2.11 in draft Revision 1 of NUREG-2192 uses the following phrases:
One-Time Inspection AMP, one-time Inspection AMP, and one-time inspection AMP.
Please consider revising the section for consistency.
Comment 4: The following reference (Reference 51) was added to Section 3.1.6 in draft Revision 1 of NUREG-2192:
EPRI. Letter SGMPIL1602, Guidance for Addressing Aging Management Plans for Steam Generator Channel Head Components. Palo Alto, California: Electric Power Research Institute.
October 2016.
Please consider changing SGMPIL1602 to SGMP-IL-16-02.
Draft Revision 1 of NUREG-2191, Volume 2 Comment 1: For AMP XI.M19, Table XI-01 in draft Revision 1 of NUREG-2191, Volume 2 states, This program manages the aging of steam generator tubes, plugs, sleeves, divider plate assemblies(as applicable), tube-to-tubesheet welds, heads (interior surfaces of channel or lower/upper heads), tubesheets (primary side), and secondary side components that are contained within the steam generator.
It appears that the divider plate should be managed by the Water Chemistry AMP if stainless steel and by both the Water Chemistry and Steam Generator AMPs if steel (with nickel alloy cladding) or nickel alloy, therefore, it is unclear what (as applicable) means in this instance. In addition, AMP XI.M19 does not use this parenthetical. Therefore, please consider revising this statement as follows:
This program manages the aging of steam generator tubes, plugs, sleeves, divider plate assemblies, tube-to-tubesheet welds, heads (interior surfaces of channel or lower/upper heads),
tubesheets (primary side), and secondary side components that are contained within the steam generator.
Comment 2: For AMP XI.M19, Table XI-01 in draft Revision 1 of NUREG-2191, Volume 2 uses General Visual. Please consider revising changing General Visual to general visual.
Comment 3: AMP XI.M19 in draft Revision 1 of NUREG-2191, Volume 2 uses Steam Generator program and Steam Generators program. It also uses AMP when referring to some other programs and this AMP. Please consider revising to be consistent.
Comment 4: The following references are in AMP XI.M19 in draft Revision 1 of NUREG-2191, Volume 2:
_____. 10 CFR Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. Washington, DC: U.S. Nuclear Regulatory Commission. 2016. 10 CFR Part 50-TN249
_____. Information Notice 94-05, Potential Failure of Steam Generator Tubes Sleeved with Kinetically Welded Sleeves. Washington, DC: U.S. Nuclear Regulatory Commission. January 1994.
The date for 10 CFR Part 50, Appendix B should be changed from 2016 to 2021. In addition, the title for Information Notice 94-05 should be Potential Failure of Steam Generator Tubes with Kinetically Welded Sleeves. Please consider making these changes to the references noted above.
Draft Supplement 1 of NUREG-2221 Comment 1: The Technical Bases for Changes column in Table 2-21 in draft Supplement 1 of NUREG-2221, for AMR Item Nos. IV.D1.RP-367, IV.D1.RP-358, and IV.D2.RP-185, includes a discussion about plant-specific SG design parameters to be compared to the industry analyses.
However, a discussion of plant-specific SG design parameters to be compared to the industry analyses was not added to these AMR items. The change to the AMR items relates to changing plant-specific AMP to One-Time Inspection AMP. Therefore, please consider revising the Technical Bases for Changes for these AMR items to the following:
The staff changed the reference to a plant-specific AMP to the One-Time Inspection AMP because the GALL-SLR Report states that a plant-specific AMP, may include a One-Time Inspection that is capable of detecting cracking to verify the effectiveness of the water chemistry and steam generator programs and the absence of primary water stress corrosion cracking (PWSCC) in the divider plate assemblies. The One-Time Inspection AMP fulfills this recommendation from the GALL-SLR and eliminates the need for a plant-specific AMP to be evaluated.
Comment 2: The Summary of Significant Changes column in Table 2-33 under Section XI.M19, Steam Generators appears to erroneously refer to a plant-specific AMP. Please consider revising the second paragraph in that column related to the Parameters Monitored or Inspected program element to change plant-specific AMP to use of the One-Time Inspection AMP.
Comment 3: he Technical Bases for Changes column in Table 3-3 in draft Supplement 1 of NUREG-2221, for Section 3.1.2.2.11 states, Additionally, the reference to a plant-specific AMP was replaced with a reference to the One-Time Inspection AMP for applicants that would need to manage cracking due to PWSCC in their SG divider plates. However, the reference to a plant-specific AMP was replaced with a reference to the One-Time Inspection AMP for tube-to-tubesheet welds in SRP-SLR Section 3.1.2.2.11, Item 2 guidelines. In addition, applicants would manage cracking due to PWSCC in their SG divider plates and tube-to-tubesheet welds with the Water Chemistry and Steam Generator AMPs regardless of if the use of the One-Time Inspection AMP was necessary. Therefore, the phrase for applicant that would need to manage does not appear to be correct. Therefore, please consider revising this statement as follows:
Additionally, for the SRP-SLR Section 3.1.2.2.11, Items 1 and 2 guidelines, the reference to a plant-specific AMP was replaced with a reference to the One-Time Inspection AMP for applicants that would need to use the One-Time Inspection AMP to verify the effectiveness of the Water Chemistry and Steam Generator AMP at managing cracking due to PWSCC in their SG divider plates and tube-to-tubesheet welds.
Conforming changes should be considered for Table 4-2 in draft Supplement 1 of NUREG-2221.
Comment 4: Please consider revising each instance of SGMP IL 16 02 to SGMP-IL-16-02 in draft Supplement 1 of NUREG-2221.