ML23318A402
| ML23318A402 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 11/14/2023 |
| From: | Licensing Processes Branch |
| To: | |
| References | |
| MRP-227, MRP-227, Rev 2, MRP-227, Revision 2, EPID L-2022-TOP-0029 | |
| Download: ML23318A402 (4) | |
Text
DRAFT 1
Draft Applicant/Licensee Actions (A/LAIs) and Conditions for the Staffs MRP-227, Rev. 2 Review NOTE: Numbers may change based on the order of appearance in the draft Safety Evaluation for MRP-227, Rev. 2 Draft A/LAIs A/LAI 1 Applicability: Westinghouse-design core barrel upper girth welds (UGWs) (currently Item W3.1 managed Expansion category welds in Table 4-6 of MRP-227, Rev. 2)
Action: The applicants/licensees with Westinghouse-designed reactor vessels shall implement the inspections of their core barrel upper girth weld (UGW) as a Primary Component. The applicants/licensees shall also define, justify, and implement corresponding Expansion-based criteria for Expansion category components or welds associated with the UGW (as a Primary category component).
A/LAI 2 Applicability: Westinghouse-design clevis insert assembly components (Item W14 managed assemblies in Table 4-9 of MRP-227, Rev. 2)
Action: For new Operating Experience (OpE) not explicitly addressed or identified in MRP-227, Rev.2 (e.g., the recent WEC-design clevis insert cracking in early 2023, and identification and discussion of OpE that has been dispositioned through NEI 03-08), identify the specific OpE and the actions addressing the OpE to ensure that the aging management of the clevis insert assemblies is adequate for that component.
A/LAI 3 Applicability: Babcock and Wilcox (B&W)-design core barrel cylinder top flange circumferential weld regions (Item B20 managed welds in Table 4-1 of MRP-227, Rev. 2)
Action: The following additional actions are to be implemented if a fatigue calculation is credited in lieu of inspecting the core barrel cylinder top flange circumferential weld regions under Item B20 of Table 4-1 of MRP-227, Rev 2: (1) the applicant/licensee shall assess fatigue for the entire core barrel assembly, which includes but is not limited to the flanges, cylinders, vertical, and circumferential seam welds, and submit this analysis to the NRC for review and approval, and (2) the applicant/licensee shall propose and justify a new Primary RVI weld type as an alternate Primary component for the linked Item B20.1. Expansion category plenum cover weldment ribs to each other welds and Item B20.2 Expansion category core support shield cylinder top flange as part of the justification for the submitted fatigue analysis (i.e., this results from the fact that no inspection data would be available for the Item B20.1 and B20.2 Expansion component types due to the omission of Primary inspections being applied to and performed on the core barrel cylinder top flange circumferential weld).
DRAFT 2
A/LAI 4 Applicability: Westinghouse-design thermal sleeves (Item W21a Alignment and Interfacing components [Existing Program category components] in Table 4-9 of MRP-227, Rev. 2)
Action: Regarding Item W21a for thermal sleeves in Table 4-9, applicants/licensees shall submit the technical basis for NRC review and approval to use the identified examination method in the latest version of PWROG-16003-P.
A/LAI 5 Applicability: Any WEC-design, CE-design, B&W-design PWR RVI component managed by an alternate aging management activity or analytical evaluation strategy in MRP-227, Rev. 2.
Applicability basis assumes that the licensees PWR RVI aging management program (AMP) has converted over to the aging management methodology in the staff-approved (-A) version of MRP-227, Rev. 2 and that the Final Safety Analysis Report (FSAR, as updated) Section providing the summary description of the PWR RVI AMP has been updated under the required 10 CFR 50.71(e) to reference use of the staff-approved (-A) version of MRP-227, Rev. 2.
For alternate aging management strategies, including those applied under Appendix C of MRP-227, Rev. 2 in lieu of the specified inspection or evaluation criteria for managed WEC-design PWR RVI components in Table 4-3, 4-6, 4-9, or 5-3 of MRP-227, Rev. 2 or managed CE-design PWR RVI components in Table 4-2, 4-5, 4-8, or 5-2 of MRP-227, Rev. 2, or those for alternate aging management strategies that are applied on a "unit-specific basis in lieu of the specified inspection or evaluation criteria for managed B&W-design PWR RVI components in Table 4-1, 4-4 or 5-1 of MRP-227, Rev. 2, the alternate aging management criteria may involve a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses as defined in 10 CFR 50.59(c)(2)(viii) because they differ from the specified inspection or evaluation criteria for the specified components types in the identification number item (ID item) of the applicable Chapter 4 or 5 table in MRP-227, Rev. 2 that applies to the component.
Action: Any alternate aging management strategies (including those proposed under the criteria in Appendix C of MRP-227, Rev. 2, those proposed for B&W-design PWR RVI components on a unit-specific basis, or those corresponding to referenced alternate aging management by analysis statements in applicable ID items for Primary component types in Table 4-1, 4-2, or 4-3 of MRP-227, Rev. 2 or Expansion component types in Table 4-4, 4-5, or 4-6 of MRP-227, Rev. 2) shall be submitted for staff review and approval, and shall consider whether: (1) the submittal needs to be processed as a 10 CFR 50.90 license amendment request under the provisions of paragraphs 50.59(c)(2) and (c)(2)(viii) of the 10 CFR 50.59 rule, and (2) any changes to the Primary-to-Expansion category relationships for the component type needs to be proposed as part of the alternate aging management strategy basis.
DRAFT 3
Draft Conditions Condition 1 Applicability: Babcock and Wilcox (B&W)-design Primary core barrel cylinder top flange circumferential weld regions, and linked core barrel Expansion category welds (Primary Item B16 managed welds in Table 4-1 of MRP-227, Rev. 2, and linked core barrel Expansion category weld per Items B16.1, B16.2, and B16.3 in Table 4-4 of MRP-227, Rev.2, as amended and superseded by changes in Tables 2-1, 2-2, and 2-3 of Attachment 2 to EPRI Letter No.
MRP 2023-004 dated April 4, 2034 [ML23095049 and ML23095A050]). Additionally, B&W-design Primary core barrel top and bottom cylinders center circumferential weld regions, and linked core barrel Expansion category welds (Primary Item B17 managed welds in Table 4-1 of MRP-227, Rev. 2, and linked core barrel Expansion category weld per Items B17.1, B17.2, and B17.3 in Table 4-4 of MRP-227, Rev.2, as amended and superseded by changes in Tables 2-1, 2-2, and 2-3 of Attachment 2 to EPRI Letter No. MRP 2023-004 dated April 4, 2034
[ML23095049 and ML23095A050])
Action: For B&W-design core barrel cylinder top flange circumferential weld regions and B&W-design core barrel top and bottom cylinders center circumferential weld region, the applicant/licensee owning the Oconee Nuclear Station (ONS) shall implement the Primary category inspections of the Primary Item B16 core barrel cylinder top flange circumferential weld regions and Primary Item B17 core barrel top and bottom cylinders center circumferential weld regions in at least one unit at the ONS site. The applicants/licensees owning the Arkansas Nuclear One, Unit 1 (ANO-1) and Davis Besse units shall implement the Primary category inspections of the Primary Item B16 core barrel cylinder top flange circumferential weld regions and Primary Item B17 core barrel top and bottom cylinders center circumferential weld regions at their respective sites. The applicants/licensees shall adjust their core barrel Expansion category weld criteria accordingly (as necessary).
Condition 2 Applicability: Combustion Engineering (CE)-design lower support structure (LSS) deep beams (Item C12 components in Table 4-2 of MRP-227, Rev. 2)
Action: The applicants/licensees shall perform enhanced visual (EVT-1) re-inspections of lower support structure deep beams Item at a 10-year re-inspection interval unless a longer rei-inspection interval of the deep beams can be demonstrated and justified by an analysis (covering evaluated fatigue, stress corrosion cracking, irradiation-assisted stress corrosion cracking, and irradiation embrittlement mechanisms) that has been reviewed and approved by the NRC.
Condition 3 Applicability: Combustion Engineering (CE)-design core shroud tie rods and nuts - applicable only to CE-design units whose core shroud assembly design includes tie rods and nuts (Item C18 components in Table 4-9 of MRP-227, Rev. 2)
Action: Regarding the inspection criteria for the CE-design core shroud tie rods and nuts (or other RVI components subject to visual inspections), the applicant/licensee shall include a description of the inspection procedures and acceptance criteria used for the visual inspections
DRAFT 4
if a non-qualified visual method is used to examine the reactor vessel internal components in their application.