ML17097A490

Attachment 3 - NUREG-2191 and NUREG-2192 (February 2017 Draft) Structural Comments

ML17097A490
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/07/2017
From:	Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Shared Package
ML17097A486	List: ML17097A487 ML17097A488 ML17097A489 ML17097A490 ML17097A491
References
NUREG-2191, NUREG-2192
Download: ML17097A490 (8)

Text

ATTACHMENT 3 NUREG-2191 and NUREG-2192 (February 2017 Draft)

Structural Comments Comment Location Description of Change Justification For Change

1. of Change SLR-SRP-1 NUREG- Delete newly added wording, added since the Dec A local leakage rate test is an Appendix J Type B 2192 2015 Draft of the SLR-SRP. or C test which is not applicable or possible on the paragraph The newly added wording states that unless containment shell or containment liner, heads, 3.5.2.2.1.3 pressure boundary components are subject to many if not most penetration sleeves and other local leakage rate testing (i.e. Appendix J Type B related pressure boundary components. IWE or C testing) and IWE that further evaluation and Pressure Boundary components are not excluded justification from exclusion from Appendix J from but are subject to Appendix J Type A Testing testing and selection of another AMP or TLAA to (Integrated Leakage Rate Testing) and do not manage the corrosion aging effect are to be require justification for their exclusion from 10 CFR addressed and identified in the basis document. Part 50 Appendix J testing. Previous versions of GALL have relied on IWE and Appendix J testing (Type A, B, or C) together to manage these subject aging effects. The IWE code alone relies on IWE visual examination to detect degradation or aging of loss of material due to general, pitting and crevice corrosion. IWE visual examination can be supplemented if deemed warranted by the IWE Responsible Individual or Engineering evaluation with other methods in addition to visual examination. Industry OE has proven IWE visual examination (supplemented if required by the licensees engineering) to be adequate and effective to detect and manage loss of material due to corrosion. There is no need for Appendix J exclusion in this further evaluation.

SLR-SRP-2 NUREG- This February 2017 SLR SRP Draft newly added The new wording also refers to paragraphs in the 2192 wording to these paragraphs should be removed. SLR-SRP Section 3.2 which are mechanical sections paragraph The Table 1 line item changes associated with the for background information and also to mechanical 3.5.2.2.2.4 further evaluation should also receive the AMPs XI.M32 and XI.M36 for implementation which Page 1 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change and corresponding changes. are not appropriate and not applicable to structural 3.5.3.2.2.4 supports.

Such structural supports are currently managed by Structures Monitoring or the ASME Section XI, Subsection IWF AMPs regardless of the material.

The further evaluations now require one-time inspections to be conducted consistent with AMP XI.M32 that would require EVT-1 or surface examinations for aluminum or stainless steel structural support members. Inspection Methods for structural support should be consistent with NUREG-2191 structural aging management programs. Revise AMP XI.M32 Table 32-1 and other sections to include a loss of material and cracking (structural components) line item that specifies VT-3 examinations (ASME Section XI Subsection IWF) or structural visual examinations (AMP XI.S6 Structures Monitoring) for the inspection method.

OE does not suggest that SCC or significant Loss of Material due to pitting or crevice corrosion is problematic for structural members made from the aluminum or stainless steel materials used for structures. There is also no technical information to suggest that the Structures Monitoring or IWF AMPs are inadequate to manage the aging effects of aluminum or stainless steel structural members.

Although typically the Aluminum in use for structural members is or is expected to be 6061-T6 or other excluded series which would be excluded from SCC considerations, the Aluminum type used is not always well documented or readily retrievable, especially for the in-scope switchyard structures which are not safety-related and in some cases Page 2 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change materials may have been separately procured and the construction separately managed from the rest of the plant construction. Lack of documentation for aluminum alloys may result in a conservative decision that would require aging management considerations.

AMP XI.S03 (IWF) and AMP XI.S6 (Structures Monitoring) should be used for the aging management inspection methods rather than XI.M36 (External Surfaces) which is intended for mechanical components.

SLR-SRP-3 NUREG- Change mismanagement/distortion at the end of This is an editorial change that is required for 2192, the sentence to misalignment/distortion. consistency with other SLR-SRP sections to address section an aging effect.

3.5.3.2.1.8, 2nd sentence addressing indications of ASR XI.S01-1 NUREG-

Subject:

Surface Examination of all pressure Revise Table 3.5-027 to include a further evaluation XI.S04-1 2191 Vol. boundary components (including that requires aging management based on a XI.S06-1 II. containment shells and liners) subject to screening threshold for cyclic loading or a plant Page XI.S1- cyclic loading without CLB Fatigue Analysis specific justification for cyclic loading applicability.

3 and XI.S- to be performed once per interval. The further evaluation should provide reasonable 4 and AMP XI.S1, Table 3.5-027 and AMRs II.A3/B4.CP- cyclic loading screening threshold values above XI.S1-6; 37 now require a surface examination of all which susceptible components would receive an Elements 3, pressure retaining components that are subject to augmented surface examination as part of the 4, and 6 cyclic loading but do not have a current licensing ASME Section XI Subsection IWE Program.

basis (CLB) fatigue analysis. This surface Consistent with the EPRI Fatigue Management examination requirement is not consistent with Handbook (TR-104534), a reasonable screening Table 3.5-009 for pressure retaining components threshold of 200F is recommended for carbon steel cyclic loaded components (with no CLB fatigue Page 3 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change that are subject to fatigue/cyclic loading/cyclic analysis) and a screening threshold of 270F is displacement with a CLB fatigue analysis. The recommended for stainless steel and dissimilar examination population for cyclic loaded metal weld cyclic loaded components (with no CLB components (no CLB fatigue analysis) is fatigue analysis).

unreasonably expanded to include all containment During the 2016 Industry-NRC meetings a revision components, regardless of material, and requires was discussed that would restore the GALL Rev 2 performance of an augmented surface wording for cyclic loading with some clarification examination. Revise Table 3.5-027 to include a that SSC considerations for stainless steel further evaluation that requires aging penetration components would be addressed as a management based on a screening threshold for further evaluation that potentially included aging cyclic loading or a plant specific justification for management considerations. Limiting surface cyclic loading applicability. The further evaluation examinations to penetration sleeves and dissimilar should provide reasonable cyclic loading screening metal welds on those sleeves with cyclic load but no threshold values above which susceptible CLB fatigue analysis was also discussed.

components would receive an augmented surface Requiring surface exams for all steel or stainless examination as part of the ASME Section XI steel pressure boundary components including Subsection IWE Program. Consistent with the EPRI components such as the primary containment steel Fatigue Management Handbook (TR-104534), a shell or steel liner and drywell head and all other reasonable screening threshold of 200F is pressure boundary components should also be recommended for carbon steel cyclic loaded restored to GALL Rev 2 wording. The GALL-SLR components (with no CLB fatigue analysis) and a changes are a very significant scope increase such screening threshold of 270F is recommended for that the entire liner or shell and containment head stainless steel and dissimilar metal weld cyclic and every part of the pressure boundary, if subject loaded components (with no CLB fatigue analysis).

to cyclic load and if no CLB fatigue analysis exists, OR as an alternate: now require monitoring for cracking regardless of Remove newly added word Steel from sentence whether they are steel or stainless steel and addressing components that are subject to cyclic regardless of plant specific or industry OE need for loading, and add back in the deleted words such examinations, or the feasibility for effective penetration sleeves, penetration bellow, and vent performance of the surface examination on coated line bellows and steel bellows and delete the surfaces, etc. The coatings on carbon steel surfaces newly added words (i.e., components covered by have to be removed prior to surface examinations Standard Review Plan for Review of Subsequent and then replaced following surface examinations.

License Renewal Applications for Nuclear Power The term surface examination as supplemented into Page 4 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change Plants (SRP-SLR) Table 3.5-1, items 27 and 40, scope in Element 4 means special NDE techniques and corresponding GALL-SLR items; as such as Liquid or Dye Penetrant testing or applicable),. examination; or Magnetic Particle testing or Similar changes to restore the GALL R2 wording examination. Attachment 1 (page 16 and 17) and on this topic are recommended in Elements 3, 4, Attachment 6 (Comment 4.15) of SECY 1996-080 and 6 as well as other sections of the GALL and for the 10 CFR50.55a changes associated with SRP that were changed. In addition, the ASME Section XI, Subsection IWE and Subsection restrictions and limitations for using Appendix J IWL changes noted that use of surface testing should be removed. The frequency examinations on stainless steel penetrations and restriction of performing the surface examination dissimilar metal welds of penetration components once each inspection interval should also be was not appropriate considering that there had removed to permit licensee flexibility. been no evidence of problems and the occupational dose that would be incurred could not be justified.

Sometimes Appendix J testing is the most appropriate option where Type A testing is possible.

These restrictions on the use of Appendix J testing are contrary to present code and 10 CFR50.55a requirements.

XI.S01-2 NUREG-

Subject:

Volumetric Examinations of shell or The use of the words any instance of metal shell or 2191 Vol. liner components with any instance of liner corrosion is not reasonable, subject to varying II. inaccessible side corrosion. interpretation, and does not provide a quantitative Page XI.S1- The last paragraph of AMP XI.S1 requires a one- qualifier. It would be difficult at best to detect 4 and time volumetric examination of the containment instances of any corrosion on the inaccessible side Elements 4 metal shell or liner surfaces that are inaccessible if that side is truly inaccessible. Similarly it is not from one side if triggered by plant specific OE. The feasible to demonstrate that there has not been any trigger for this supplemental examination is plant- corrosion on the inaccessible side. As written, the specific occurrence or recurrence of any instance requirement could be inferred to always require of metal shell or liner corrosion initiated on the volumetric examinations, which we currently believe inaccessible side or areas, since the date of is not the intent. During the June 2, 2016 NRC-issuance of the first renewed license. Revise any Industry meeting it was discussed that any instance to identify significant or measurable instance be revised to identify significant or degradation from the accessible side of the shell measurement of degradation from the accessible or liner such as through wall corrosion or corrosion side of the shell or liner such as through wall Page 5 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change with greater than 10% wall thickness loss. corrosion or corrosion with greater than 10% wall thickness loss. A greater than 10% wall thickness loss due to corrosion on the inaccessible side as measured from the accessible side is consistent with current ASME Section XI, Subsection IWE examinations.

SLR-SRP-7 NUREG-

Subject:

IWE and Appendix J Type A (ILRT) This was not previously discussed or presented in 2192Furth no longer considered adequate to manage any written document to the industry and is er corrosion of containment pressure boundary unnecessarily burdensome and does not appear to Evaluation components for Loss of material due to be technically correct or technically warranted.

paragraph general, pitting and crevice corrosion.

3.5.2.2.1.3 In the first paragraph of the further evaluation A local leakage rate test is an Appendix J Type B delete the fourth sentence that requires or C test which are not applicable or possible on the justification from exclusion of Appendix J local containment shell or containment liner, heads, leakage rate testing (i.e. Appendix J Type B and many if not most penetration sleeves and other Type C testing). Revise the further evaluation and related pressure boundary components. IWE restore the prior evaluation for IWE aging Pressure Boundary components are not excluded management considerations. Aging management from but are subject to Appendix J Type A or ILRT of containment shell or containment liner, heads (Integrated Leakage Rate Testing) and do not as and other related IWE pressure boundary stated require justification of their exclusion from components are not excluded from, but are 10 CFR Part 50 Appendix J testing. Previous subject to Appendix J Type A ILRT (Integrated versions of GALL have relied on IWE and Appendix J Leakage Rate Testing) and IWE examinations. testing (Type A, B, or C) together to manage these subject aging effects. The IWE code alone relies on IWE visual examination (which can be supplemented if deemed warranted by the IWE Responsible Individual or Engineering evaluation with other methods in addition to visual) to detect degradation or aging of loss of material due to general, pitting and crevice corrosion. Industry OE has proven IWE visual examination (supplemented if required by the licensees engineering) to be adequate and effective to detect and manage loss Page 6 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change of material due to corrosion.

Section NUREG- Revise the AMPs noted in the AMR lines to be AMPs noted in the AMR lines to be updated III.B 2191 Vol. I. consistent with comment resolution of SLR-SRP-2. consistent with comment resolution of SLR-SRP-2 (Supports) Tables (supports)

B1.1, B1.2, B1.3, B2, B3, B4, and B5 Lines for aluminum, stainless steel in air, condensatio n:

III.B1.1.T-36a/b/c III.B1.2.T-36a/b/c III.B1.3.T-36a/b/c III.B2.T-37a/b/c III.B2.T-37a/b/c III.B3.T-37a/b/c III.B4.T-37a/b/c III.B5.T-Page 7 of 8

ATTACHMENT 3 Comment Location Description of Change Justification For Change

1. of Change 37a/b/c Page 8 of 8