ML22024A029

Breakout Questions - Trp 41 - IWE

ML22024A029
Person / Time
Site:	Oconee
Issue date:	01/20/2022
From:	Angela Wu NRC/NRR/DNRL/NLRP
To:
Wu A, 301-415-2995
Shared Package
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References
Download: ML22024A029 (7)

Text

Oconee SLRA: Breakout Questions SLRA Section B2.1.28, ASME XI, Subsection IWE AMP TRP: 041 Question SLRA SLRA Background / Issue Discussion Question / Request Number Section Page (As applicable/needed) 1 3.5.2.2.1.3, 3-1308 SRP-SLR Section 3.5.3.2.1.3 guidance 1. Discuss how the moisture item 1 says a plant-specific program is not barrier degradation, at the recommended if, among other junction where the shell or considerations, (1) the moisture barrier, liner becomes embedded, is at the junction where the shell or liner managed.

becomes embedded, is subject to aging management activities in accordance 2. Discuss how OE (the with ASME Code Section XI, Subsection borated water spills and water IWE requirements; (2) the borated water ponding on the concrete floor) spills and water ponding on the concrete is addressed.

floor when detected are cleaned up or diverted to a sump in a timely manner. 3. Discuss plans to update the SLRA to address the above.

FE Section does not provide information for the moisture barrier, at the junction where the shell or liner becomes embedded, and the borated water spills and water ponding on the concrete floor.

2 3.5.2.2.1.6 3-1310 FE Section states stainless steel high 1. Discuss how the IWE AMP energy pipes that penetrate the and Appendix J AMP B2.1.28 B-198 containment are connected to carbon examination/testing methods steel penetration sleeves with dissimilar will be sufficient to manage A2.28 A-30 metal welds. dissimilar metal welds without additional appropriate FE Section also states that the IWE examinations capable of AMP and Appendix J AMP manage the detecting cracking due to aging effects of these dissimilar metal SCC. Clarify if all the dissimilar welds (DMWs). However, SLRA Section metal welds are subjected to B2.1.28 states that Appendix J AMP Type B local leak rate tests

manages the aging of these dissimilar that are capable of detecting metal welds, which is inconsistent with cracking due to SCC.

FE.

2. Clarify the discrepancy between FE Section and SRP-SLR Section 3.5.3.2.1.6 guidance SLRA Section B2.1.28, and states that IWE and leak rate testing revise SLRA as necessary.

may not be sufficient to detect cracks

[due to SCC or fatigue], especially for 3. Clarify the discrepancy dissimilar metal welds. between SLRA A2.28 and the descriptions in B2.1.28 and FE SLRA Section A2.28 states: The 3.5.2.2.1.6, and identify the program includes surface or enhanced specific pressure-retaining examinations to detect cracking for components that will be specific pressure-retaining components. subject to surface or enhanced Containment liners and penetrations examinations to detect were analyzed for cracking. Discuss how this will cyclic fatigue and do not require surface be incorporated into the examinations in addition to visual B2.1.28 AMP and FE examinations to detect 3.5.2.2.1.6 or applicable SLRA cracking in stainless steel and dissimilar sections.

metal welds of penetration sleeves and components that are subject to cyclic loading. The above statements appear to imply that the surface or enhanced examinations would apply to components DMWs for SCC since analysis for fatigue loading does not preclude cracking due to SCC. But SLRA B2.1.28 AMP and the FE do not appear to include the surface or enhanced examinations and identify the specific pressure-retaining components on which these examinations will be performed, as stated in A2.28.

3 Table 3.5.1 3-1328 Item 3.5.1-010 claims to be not 1. Clarify what is the material applicable. FE Section 3.5.2.2.1.6 states used for the electrical 3.5.2.2.1.6 3-1310 that ONS containment does not have penetration sleeves in UFSAR stainless steel penetration sleeves, Figure 3-20.

UFSAR P595 of penetration bellows, vent line bellows, or Figure 3- 2264 suppression chamber shell (interior 2. Clarify the discrepancy 20 surface) as part of the containment between FE Section, item pressure boundary. However, UFSAR 3.5.1-010, SLRA Table 3.5.2-Table 3-1455 Figure 3-20 shows the sleeve for 23 and UFSAR Figure 3-20.

3.5.2-23 electrical penetrations and SLRA Table Revise SLRA as necessary.

3.5.2-23 lists a component for penetration sleeve. 3. Justify the non-applicability claim in SLRA Table 3.5.1, for Also, item 3.5.1-010, with corresponding item 3.5.1-010 in FE Section AMR item II.A3.CP-38, also apply to 3.5.2.2.1.6. Further, clarify dissimilar metal welds which do exist at ONS understanding of the ONS. However, the non-applicability distinction between an AMR claim for SLRA Table 3.5.1, item 3.5.1- item being not applicable and 010 appears to be not sufficiently not used.

justified or even made in FE Section 3.5.2.2.1.6. Further the discussion for item 3.5.1-010 also claims the item is not used.

4 B2.1.28 B-198 SLRA states that procedures will include Clarify what enhancements for preventive actions to ensure bolting preventive actions are needed integrity for replacement and to ensure bolting integrity.

maintenance activities by specifying proper selection of bolting material and lubricants, and appropriate installation torque or tension to prevent or minimize loss of bolting preload and cracking of high strength bolting. However, it does not appear that AMP enhancement 1 includes an enhancement for those preventive actions to ensure bolting integrity.

5 Table 3-1331 Note: This question is also presented in 1. List the containment-3.5.1, item TRP 146. pressure-retaining boundary

-027 components covered by SRP-Accounting AMR of containment SLR Table 3.5-1, item 027 3.5.2.2.1.5 3-1310 pressure-retaining boundary (e.g., personnel airlock, components that have no CLB fatigue equipment hatch, electrical analysis with regard to managing penetration, penetration cracking due to cyclic loading (AMR item sleeves, penetration bellows, 3.5.1-027): etc.) that are subject to cyclic SLRA Table 3.5.1, in the Discussion loading but do not have a CLB column for item 3.5.1-027 states: Not fatigue analyses.

applicable. Cracking due to cyclic loading of the Containment liner and 2. Clarify if fatigue TLAAs exist penetrations is a time-limited aging for all containment analysis (TLAA), as defined in 10 CFR penetrations as implied.

54.3. The evaluation of this TLAA is addressed in Section 4.6. The 3. Justify the non-applicability associated NUREG-2191 aging items claim of SLRA Table 3.5.1, are not used. item 3.5.1-027, for each of these components.

SLRA Section 3.5.2.2.2.1.5 states that TLAAs for fatigue of the containment OR liner plate and main feedwater and main steam penetrations are addressed in Explain how cracking due to SLRA Section 4.6. SLRA Section cyclic loading (cumulative 3.5.2.2.2.1.5 does not address fatigue or fatigue damage) will be fatigue waiver analyses of any other adequately managed for these containment pressure-retaining components pursuant to 10 boundary components other than those CFR 54.21(a)(3), and how do above, nor provides any further you plan to address them in evaluation associated with SRP-SLR the SLRA.

item 3.5.1-027 for containment pressure-retaining boundary components that do not have a CLB fatigue analysis.

However, it is not clear how the other containment pressure-retaining boundary components subject to cyclic loading, but do not have a CLB fatigue analysis, covered by item 3.5.1-027 will be adequately managed for cracking due to cyclic loading.

[Note: The SRP-SLR and GALL-SLR provides guidance for addressing or accounting for cracking due to cyclic loading (where no CLB fatigue analysis exists) by any of the following ways:

(i) By performing supplemental surface examinations (or alternate like E-VT1 examinations) (recommended in GALL-SLR AMP XI.S1)

(ii) By crediting an appropriate Appendix J Type B leak rate test capable of detecting cracking ) (recommended in GALL-SLR AMP XI.S1)

(iii) By performing a fatigue waiver analysis (recommended in FE 3.5.2.2.2.1.5 associated with item 3.5.1-027 per SLR-ISG-2021 STRUCTURES (ADAMS No.

ML20181A381)

(iv) Other applicant proposed or plant-specific justification for aging effect not requiring management or not applicable]

6 N/A N/A GALL-SLR report (XI.S1) describes Explain how the IWE AMP parameters monitored or inspected, manages aging effects of the

detection of aging effects, and cracking for the steel, SS, and acceptance criteria for the steel, SS, and dissimilar metal weld dissimilar metal weld pressure-retaining pressure-retaining components that are subject to cyclic components that are subject to loading but have no CLB fatigue cyclic loading but have no CLB analysis. fatigue analysis.

It appears that IWE AMP Evaluation report (SLR-ONS-AMPR-XI.S1, Rev. 2) does not cover this subject, and SLRA claims AMR item 3.5.1-027 to be not applicable.

7 N/A N/A Both GALL-SLR report (XI.S1) and 1. Clarify whether using the ASME code IWE-2420 state that the third inspection interval is an sequence of component examinations exception.

established during the first inspection interval shall be repeated during successive intervals, to extent practical. 2. Explain why use of the sequence from the third However, Section 4.5 in the IWE AMP inspection interval is Evaluation report (SLR-ONS-AMPR- acceptable.

XI.S1, Rev. 2) uses the sequence of component examinations established during the third inspection interval, which appears to be an exception to NUREG-2191.

8 B2.1.28 B-198 Program enhancement 3 (SLR 1. Clarify whether each unit Commitment 28.3) related to will be subject to the A2.28 A-30 supplemental volumetric examination volumetric examination if the states, in part: The supplemental triggering OE occurs in any Table A-94 volumetric examinations for each one unit, or will the A6.0-1 unit will occur within two refueling examination only be outages after identifying the trigger for conducted in the unit in which the examination. the triggering OE occurred, or some other treatment? If not

From the sentence cited above, with the former case, explain and regard to the conduct of the provide a justification of the supplemental volumetric examination, intended treatment of the 3 there is a lack of clarity of the treatment units for the one-time of the 3 ONS units if the triggering OE supplemental volumetric occurs in one of the units. examination if the triggering Also, it is not clear from the SLRA OE occurs in any one unit.

whether the triggering OE has occurred to date since the issuance of the first 2. Provide affirmation whether renewed license. or not the triggering OE has occurred in any unit to date since the issuance of the initial renewed license.