ML20006D152
| ML20006D152 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 02/19/2020 |
| From: | Dennis Morey Licensing Processes Branch |
| To: | Burgos B Electric Power Research Institute |
| Holonich J, 415-7297 | |
| References | |
| EPID L-2019-TOP-0053 | |
| Download: ML20006D152 (6) | |
Text
February 19, 2020 Brian Burgos MRP Program Manager Electric Power Research Institute 3420 Hillview Avenue Palo Alto, CA 94304
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION VERIFICATION LETTER FOR ELECTRIC POWER RESEARCH INSTITUTE TOPICAL REPORT MRP 227, REVISION 1, MATERIALS RELIABILITY PROGRAM: PRESSURIZED WATER REACTOR INTERNALS INSPECTION AND EVALUATIONS GUIDELINE (L-2019-TOP-0053)
Dear Mr. Burgos:
By letter dated December 3, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19339G364), the Electric Power Research Institute submitted for U.S. Nuclear Regulatory Commission (NRC) staff review topical report MRP 227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluations Guideline.
The -A version of the TR incorporates the NRC staffs safety evaluation. Based on its review of MRP-227, Revision 1-A, the NRC staff has determined that the TR is acceptable to the extent delineated in the NRC staffs safety evaluation dated April 25, 2019 (ADAMS Accession No. ML19081A001). Any facility referencing MRP-227, Revision 1-A should address the items contained in the enclosure to this letter.
If you have any questions or require any additional information, please feel free to contact the Project Manager for this topical report, Joseph Holonich, at 301-415-7297 or joseph.holonich@nrc.gov.
Sincerely,
/RA/
Dennis C. Morey, Chief Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Enclosure:
As stated Docket No. 99902021
U.S. Nuclear Regulatory Commission Staff Comments on MRP 227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluations Guideline.
Table 1 - Summary of MRP-227, Rev. 1-A Issues or Contents Needing EPRI Confirmation Issue Issue Topic Issue Topic Gap in MRP-227, Rev. 1-A, or TR Topic Needing Topic Issue Needing Confirmation or No. Or Confirmation Topic Confirmation from EPRI with Regard to Contents in Rev. 1-A Consideration from the EPRI MRP Content Issues in MRP-227, Rev. 1-A (the TR) Needing Attention and Potential Resolution by EPRI 1 Combustion Engineering- The line item entry for the core support column bolts in Either the line item entry for the core support design (CE-design) core TR Table 3-2 (on page 3-24) identifies that the bolts are located in column bolts in TR Table 3-2 needs to be moved support column bolts the lower support structure. from the lower support structure part of the table to the core shroud part of the table, or Line Item C1.1 Item C1.1 in TR Table 4-5) in TR Table 4-5 needs to change the listed In comparison to the line item entry for the bolts in TR Table 3-2, assembly from Core Shroud Assembly (Bolted)
Expansion Category Item C1.1 in TR Table 4-5 (on page 4-30) identifies that the core to Lower Support Structure.
Components support column bolts are located in core shroud assembly for CE-design plants with bolted core shroud assembly designs. TR Table 5-2 would need to be adjusted accordingly.
2 CE-design core support The line item for the CSB LFW in TR Table 3-2 (on page 3-25) If the CSB LFW is the same as the CSB flexure barrel (CSB) assembly identifies that the final inspection category for the LFW is weld, then the line item entries for the weld in TR lower flange weld (LFW) Primary. Table 3-2 and 4-2 need to be adjusted to make it clear that the CSB LFW and CSB flexure weld are Line item entry for the LFW the same component.
in TR Table 3-2 In comparison, TR Table 4-2 (the TRs examination table for Primary Components) does not include any line item entry for the Otherwise, if the CSB LFW is not the same (See line item on CSB LFW. Instead, TR Table 4-2 includes Line Item C7 component as the CSB flexure weld, then a line page 3-25 of the TR) (on page 4-19) for what is defined as a flexure weld in the CSB item entry for the CSB flexure weld needs to be and which is identified as a lead Primary category component for added to TR Table 3-2 and a line item for the CSB CE-designed plants. LFW needs to be added to TR Table 4-2.
TR Table 5-2 would need to be adjusted accordingly.
Issue Issue Topic Issue Topic Gap in MRP-227, Rev. 1-A, or TR Topic Needing Topic Issue Needing Confirmation or No. Or Confirmation Topic Confirmation from EPRI with Regard to Contents in Rev. 1-A Consideration from the EPRI MRP 3 CE-design core support The line item entry for CSB LGWs in TR Table 3-2 (Page 3-25) If the EPRI MRP downgraded the CE-design CSB barrel (CSB) assembly identifies that the LGWs are Primary category components for LGWs to Expansion category components in lower girth welds (LGWs) CE-design plants. This line item includes a reference to Table response to one of our RAIs for the MRP-227, Revision 1 methodology and we accepted the RAI Note 4 on the SCC and IE mechanisms and Final Group entries Item C5.1 in TR Table 4-5 basis change in our April 25, 2019 safety for the line item, with Note 4 stating Upgraded to Primary from evaluation for the MRP-227, Rev. 1 methodology, Expansion category Expansion in accordance with the NRC SER on MRP-227, then the SCC, IASCC, IE and Final Group column components Revision 0. The line item also includes a reference to Table Note references for the CSB LGWs in the Table 3-2 of 7 for the listed IASCC entry in the line item, with Note 7 stating: the MRP-227, Rev. 1-A report will need to be fixed Mechanism IASCC upgraded from No Additional Measures to from P to E, and Notes 4 and 7 for TR Table 3-2 Primary for lower cylinder welds in accordance with NRC SER on will need to be adjusted accordingly. However, the existing TR Table 3-2 notes in the draft MRP-227, MRP-227, Revision 0.
Rev. 1-A report appear to indicate that the CSB LGWs remain as Primary category components.
In comparison to the line item entry for the CSB LGWs in TR Table 3-2, Item C5.1 in TR Table 4-5 (on Page 4-29) identifies If instead, the CSB LGWs remain as Primary that the CSB LGWs are Expansion category components for category components for the program, then CE-design plants. Item C5.1 for the CSB LGWs is incorrect and needs to be deleted from the scope of TR Table 4-5, and a new Item for the CSB LGWs would need to be developed and included in Table 4-2 of the MRP-227, Rev. 1-A report. Table 5-2 would need to be adjusted accordingly.
4 CE-Design Incore The line item for the ICI thimble tubes in Table 3-2 (on page 3-26) The EPRI MRP needs to establish whether the Instrumentation (ICI) of the MRP-227, Rev. 1-A report indicates that CE-design ICI MRP-227, Rev. 1-A guidelines are continuing to Thimble Tubes thimble tubes - lower are Existing Program components for CE- define the ICI Thimble Tubes-Lower as Existing Program components for CE-design RVI aging designed plants; yet Table 4-8 in the report does not include any Line item entry for the management programs, and if so, whether the ICI Thimble Tubes-Lower line item entry for ICI Thimble-Tubes - Lower. inclusion of the tubes in the Existing Program in TR Table 3-2 category is based on the designation of the ICI thimble tubes as ASME Section XI components or (See line item on known site-specific programs for the tubes, page 3-26 of the TR) therefore may need a revision to Table 4-8 to include a line item for the thimble tubes.
Issue Issue Topic Issue Topic Gap in MRP-227, Rev. 1-A, or TR Topic Needing Topic Issue Needing Confirmation or No. Or Confirmation Topic Confirmation from EPRI with Regard to Contents in Rev. 1-A Consideration from the EPRI MRP Confirmations Needed from the EPRI MRP on Renumbering of Restructuring of Table Notes in MRP-227, Rev. 1-A 5 Confirmation of Changes Notes for Item W6 in TR Table 4-3. For Westinghouse-design Unless addressed in subsequent paragraphs of to Tabular Footnote Primary components associated with Item W6 (i.e., baffle-former this column entry, the staff requests that EPRI References for bolts) in TR Table 4-3, the applicable note designations for the MRP confirm that changes to the note number TR Tables 4-1 through 4-6 bolts went from Notes 3, 6, and 9 in Table 4-3 of the designation or the contents of notes on TR Section and 4-8 and 4-9 MRP-227, Rev. 1 report to Notes 3, 4, 7, and 9 in Table 4-3 of the Table component items were based on either: (1) draft MRP-227, Rev. 1-A report. administrative reshuffling of the notes, or (2)
Notes for Item W1 in TR Table 4-3. For Westinghouse-design adjustments of the note criteria based on the EPRI Primary components associated with Item W6 (i.e., CRGT guide MRPs resolution of staff-issued requests for cards) in TR Table 4-3, applicable note designation went from additional information (RAIs) on the MRP-227, Note 7 in Table 4-3 of the MRP-227, Rev. 1 report to Note 5 in Rev. 1 methodology, where the response bases Table 4-3 of the draft MRP-227, Rev. 1-A report. were accepted by the staff.
Notes for Items C5 and C6 in TR Table 4-2. For CE-design Primary components associated with Item C5 (core support Additional clarifications for notes associated with barrel upper flange weld) and Item C6 (i.e., core support barrel TR Table 4-2, Items C5 and C6. For the change in middle girth weld) in TR Table 4-2, the applicable note the designation of Note 6 in Table 4-2 of TR MRP-designations went from Notes 5 and 6 in Table 4-2 of the MRP- 227, Rev. 1 to Note 5 in Table 4-2 of MRP-227, 227, Rev. 1 report to Note 5 in Table 4-3 of the draft MRP-227, Rev. 1-A, EPRI MRP to confirm whether or not the Rev. 1-A report. For some reason, the EPRI MPR did not failure to reference the renumbered Note 5 in the reference the renumbered Note 5 in the Examination Column Examination Coverage column entries for Item entries for Items C5 and C6 in Table 4-2 of the MRP-227, C5 and C6 in Table 4-2 of the MRP-227, Rev. 1-A Rev. 1-A report. was an inadvertent omission and whether or not Notes for Items W3 and W4 in TR Table 4-3. For Primary the Examination Coverage column entries for components associated with Item W3 (core barrel upper flange Items C5 and C6 in Table 4-2 of the Rev. 1-A weld) and Item W4 (i.e., core barrel lower girth weld) in TR Table report should be amended to include reference to 4-3, the applicable note designations went from Notes 8 and 10 in both renumbered Notes 4 and 5 (and not just Table 4-3 of the MRP-227, Rev. 1 report to Note 6 in Table 4-3 of renumbered Note 4).
the draft MRP-227, Rev. 1-A report.
Additional clarifications for notes associated with The applicable note on minimum inspection coverages applying to TR Table 4-3, Items W3 and W4. EPRI to confirm the Primary core barrel welds in Items W3 and W4 of Table 4-3 whether or not the Examination Coverage column in MRP-227, Rev. 1, was listed as Note 8. In Table 4-3 of MRP- entries for Items W3 and W4 in Table 4-3 of the 227, Rev. 1-A, the note on minimum inspection coverages MRP-227, Rev. 1-A report should include reference applying to Items W3 and W4 was renumbered to Note 6. For to a renumbered note that is analogous to Note 10 some reason this note did not carry forward as an applicable note in Table 4-3 of the MRP-227, Rev. 1 report.
for Table 4-3 of the report similar to manner that the analogous note for CE Primary core support barrel welds had carried over in Table 4-2 of the report. Thus, the Examination Coverage column entries for Items W3 and W4 in Table 4-3 of the MRP-227, Rev. 1-A report do not currently include reference to a note that is analogous to Note 10 in Table 4-3 of the MRP-227, Rev. 1 report.
Issue Issue Topic Issue Topic Gap in MRP-227, Rev. 1-A, or TR Topic Needing Topic Issue Needing Confirmation or No. Or Confirmation Topic Confirmation from EPRI with Regard to Contents in Rev. 1-A Consideration from the EPRI MRP Notes for Items W4.2 and W4.3 in TR Table 4-6. For Expansion components associated with Item W4.2 (core barrel middle axial welds) and Item W4.3 (i.e., core barrel lower axial welds) in TR Table 4-6, the applicable note designations were renumbered from Notes 2 and 3 in TR Table 4-6 of the MRP-227, Rev. 1 report to Notes 3 and 4 in TR Table 4-6 of the draft MRP-227, Rev. 1-A report.
ML20006D152 *concurred via e-mail OFFICE NRR/DORL/LLPB/PM NRR/DORL/PLPB/LA* NRR/DNLR/NVIB/BC*
NAME JHolonich DHarrison HGonzales DATE 02/18/2020 01/27/2020 02/18/2020 OFFICE NRR/DORL/PLPB/BC NAME DMorey DATE 02/19/2020