ML24023A690
| ML24023A690 | |
| Person / Time | |
|---|---|
| Site: | 99902016 |
| Issue date: | 02/29/2024 |
| From: | Lois James Licensing Processes Branch |
| To: | Bonifanti M, Palm N Electric Power Research Institute |
| James L, NRR/DORL/LLPB | |
| References | |
| BWRVIP-138, BWRVIP-138, Rev 2, BWRVIP-138, Revision 2, EPID L-2023-NTR-0007 | |
| Download: ML24023A690 (1) | |
Text
February 29, 2024 Martin Bonifanti, Constellation, BWRVIP Chairman Nathan Palm, EPRI, BWRVIP Program Manager 1300 West W.T. Harris Blvd Charlotte, NC 28262-8550
SUBJECT:
ELECTRIC POWER RESEARCH INSTITUTE REGULATORY AUDIT IN SUPPORT OF REVIEW OF BWRVIP-138, UPDATED JET PUMP BEAM INSPECTION AND FLAW EVALUATION GUIDELINES, REVISION 2 (EPID L-2023-NTR-0007)
Dear Mr. Bonifanti and Mr. Palm:
By letter dated October 25, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23298A077), EPRI submitted Boiling Water Reactor (BWR) Vessel Internals Program (BWRVIP)-138, Revision 2, BWR Vessel and Internals Project, Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines, for U.S. Nuclear Regulatory Commission (NRC) review. BWRVIP-138 incorporates new crack growth and crack initiation data from BWRVIP-291, Revision 1, BWR Vessel and Internals Project, Microstructure, SCC, and J-R Fracture Resistance of Alloy X-750 and XM-19: Final Report 2017, and updated operating experience. The NRC accepted BWRVIP-138 for review on January 3, 2024 (ADAMS Accession No ML23299A287).
The NRC staff reviewed the vendors application and determined that a regulatory audit would assist in the timely completion of the NRC staffs review. The NRC staff will conduct a regulatory audit to support its review of BWRVIP-138 in accordance with the enclosed audit plan.
The NRC staff will conduct the audit to increase its understanding of the application and identify information that will require docketing to support the NRC staffs regulatory findings. The NRC staff plans to conduct the audit virtually at NRC Headquarters in Rockville, Maryland via a vendor-established electronic porta and NRC-established Teams Meeting. However, should the
M. Bonifanti, et al.
staff determine that an in-person audit would be a more efficient method to conduct the audit and gather needed information, the staff may use that approach in addition to the virtual audit.
If you have any questions, please contact me by email at lois.james@nrc.gov.
Sincerely,
/RA/
Lois M. James, Senior Project Manager Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 99902016
Enclosure:
Audit Plan
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION IN SUPPORT OF THE REVIEW OF BWRVIP-138, UPDATED JET PUMP BEAM INSPECTION AND FLAW EVALUATION GUIDELINES, REVISION 2 ELECTRIC POWER RESEARCH INSTITUTE DOCKET NO. 99902016
1.0 BACKGROUND
By letter dated October 25, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23298A077), Electric Power Research Institute (EPRI) submitted Boiling Water Reactor (BWR) Vessel Internals Program (BWRVIP)-138, Revision 2, BWR Vessel and Internals Project, Updated Jet Pump Beam Inspection and Flaw Evaluation Guidelines, for U.S. Nuclear Regulatory Commission (NRC) review. BWRVIP-138 incorporates new crack growth and crack initiation data from BWRVIP-291, Revision 1, BWR Vessel and Internals Project, Microstructure, SCC, and J-R Fracture Resistance of Alloy X-750 and XM-19:
Final Report 2017, and updated operating experience.
By e-mail dated January 3, 2024 (ADAMS Accession No. ML23299A287), the NRC staff accepted the BWRVIP-138, Revision 2 for review.
The NRC staff has identified the need to conduct a regulatory audit to better understand the new crack growth and crack initiation data in BWRVIP-291, Revision 1, and its impact on BWRVIP-138.
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. The audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. Performing a regulatory audit is expected to assist the NRC staff in efficiently conducting its review and gaining insights to the vendors processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket.
The NRC staff will perform the audit in accordance with this audit plan and NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ADAMS Accession No. ML19226A274).
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The objective of this audit is to verify, via an independent evaluation, the background information related to BWRVIP-138, Revision 2 that support the technical basis for the updated initial inspection intervals and reinspection intervals for the jet pump beams in BWR plants.
Specifically, the NRC staff will review BWRVIPs supporting documents related to the topics as described in Section 4.0 of this audit plan to determine if additional information will require docketing to develop and support the staffs conclusions for the NRC staffs safety evaluation of BWRVIP-138, Revision 2.
4.0 INFORMATION AND OTHER MATERIAL FOR THE REGULATORY AUDIT The NRC staff requests that the vendor have the following information readily available and accessible for the NRC staffs review via online portal:
4.1 BWRVIP-138, Revision 2, topics 4.1.1 Crack Initiation data and analysis in Section 5 of the topical report (TR).
4.1.2 Crack growth calculations in Section 6.
4.1.3 Flaw evaluation in Section 7.
4.1.4 The Inspection strategy in Section 8.
4.1.5 Updated crack growth calculations in Appendix G.
4.1.6 Implementation Protocol.
4.2 Clarification questions on the following sections of the TR 4.2.1 Background of the jet pump beams in Section 1.
4.2.2 Beam Susceptibility in Section 2.
4.2.3 Operational Experience in Section 3.
4.2.4 Nondestructive Examination in Section 4.
The NRC staff will forward questions to BWRVIP/EPRI in the beginning of the audit to facilitate the discussion related to the above topics.
4.3 Reports to be accessible for the NRC staffs review via online portal 4.3.1 Reference from Section 9 of the TR 4.3.2 BWR Vessel and Internals Project, Guidelines for Selection and Use of Materials for Repairs to BWR Internal Components (BWRVIP-84). EPRI Report, October 2000. TR-1000248.
4.3.3 Technical Basis for the Inspection Frequency of a BWR Group 2 Jet Pump Beam, 0000-0069-0773-01, Rev. 0, GE Hitachi Nuclear Energy.
4.3.4 Technical Basis for the Inspection Frequency of a BWR Group 3 Jet Pump Beam, 0000-0082-8669-01, Rev. 0, GE Hitachi Nuclear Energy.
4.3.5 PL Andresen, PW Emigh, MM Morra, and RM Horn: Alloy X750 Stress Corrosion Crack Growth Rate Behavior in High Temperature Water, Proc. 11th Int. Conf. on Environmental Degradation of Materials in Nuclear Power Systems-Water Reactors, NACE, Stevenson, WA, Aug. 10-14, 2003.
4.3.6 GEH Letter Report DRF 0000-0088-9987, BWRVIP-84 Alloy X-750 Design Criteria Assessment, November 25, 2009.
4.3.7 E-mail from P. Andresen to R. Carter dated April 27, 2020, Equations for X-750 CGR curves in BWRVIP-291, Rev 1.
4.3.8 Reference from Appendix G of the TR 4.3.9 BWRVIP-291, Revision 1: BWR Vessel and Internals Project:
Microstructure, SCC and J-R Fracture Resistance of Alloy X-750 and XM-19: Final Report 2017. EPRI, Palo Alto, CA: 2017. 3002011583.
4.3.10 BWRVIP-336: BWR Vessel and Internals Project, Irradiation and Post-Irradiation Examination of Alloys X-750 and XM-19. EPRI, Palo Alto, CA: 2020. 3002018307.
4.3.11 BWRVIP-315: BWR Vessel and Internals Project, Reactor Internals Aging Management Evaluation for Extended Operations. EPRI, Palo Alto, CA: 2019. 3002012535.
4.3.12 BWRVIP-03, Revision 20: BWR Vessel and Internals Project, Reactor Pressure Vessel and Internals Examination Guidelines. EPRI, Palo Alto, CA: 2021. 3002010675.
4.4 The NRC staff may request additional information to be added to the portal based on the staffs continued review of the application and documents and based on audit discussions with BWRVIP/EPRI.
4.5 Based on the audit, the NRC staff will determine whether additional information needs to be submitted on the docket for the staff to complete the review of the TR via request for additional information (RAIs).
5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff:
NAME E-MAIL DIVISION BRANCH Lois James Lois.james@nrc.gov Division of Operating Reactor Licensing (DORL)
Licensing Projects Branch (LPLB)
John Tsao John.Tsao@nrc.gov Division of New and Renewed Licenses (DNRL)
Vessels Internals Branch (NVIB)
Michael Benson Michael.Benson@nrc.gov DNRL NVIB 6.0 LOGISTICS The audit will be conducted from March 4 to March 29, 2024, through an online portal (also known as electronic portal, ePortal, or electronic reading room) established by EPRI.
The audit team will conduct a TEAMS-based entrance meeting with the vendor on March 4, 2024, for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the portal. Through the audit period between March 4 and March 28, 2024, the NRC staff will hold breakout sessions with representatives of EPRI to answer audit team questions. An exit meeting/call will be held at the conclusion of the audit on March 29, 2024.
The NRC staff does not foresee the need for an onsite visit or in-person discussions between the NRC and vendor staff to discuss information to be provided on the portal at this time.
However, if the need for a such a meeting is identified in the future, the audit plan will be revised, and the schedule for the audit will be adjusted accordingly. The NRC project manager (PM) will coordinate any changes to the audit schedule and location with the vendor.
7.0 SPECIAL REQUESTS The audit team would like access to the documents listed in Section 4.0 above through an online portal that allows the audit team to access documents via the internet. The following conditions associated with the online portal must be maintained throughout the duration that the audit team has access to the online portal:
The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.
The online portal will be sufficiently secure to prevent the NRC staff from printing, saving, downloading, or collecting any information on the online portal.
Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.
Username and password information should be provided directly to the NRC staff. The NRC PM will provide to EPRI the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated through the NRC PM.
8.0 DELIVERABLES An audit summary report will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the NRC staff will issue RAI(s) to the vendor.
- via eConcurrence NRR-106 OFFICE NRR/DORL/LLPB/PM* NRR/DORL/LLPB/LA* NRR/NDLR/NVIB/BC* NRR/DORL/LLPB/BC*
NAME LJames DHarrison ABuford GGeorge DATE 02/26/2024 02/27/2024 02/28/2024 02/29/2024 OFFICE NRR/DORL/LLPB/PM*
NAME LJames DATE 02/29/2024