ML22024A017

Breakout Questions - Trp 18 - Bolting Integrity

ML22024A017
Person / Time
Site:	Oconee
Issue date:	01/20/2022
From:	Angela Wu NRC/NRR/DNRL/NLRP
To:
Wu A, 301-415-2995
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Download: ML22024A017 (5)

Text

Oconee SLRA: Breakout Questions SLRA Section B2.1.9, Bolting Integrity AMP: B2.1.9 l TRP: 18 Question SLRA SLRA Background / Issue Discussion Question / Request Number Section Page (As applicable/needed) 1 B2.1.9 B - 86 SLRA Section B2.1.9, Bolting Integrity, Program

Description:

states that the AMP is an existing condition

• Clarify/confirm that the bolting monitoring program which manages loss of integrity AMP is an existing preload, cracking, and loss of material related program, except for managing to closure bolting on pressure-retaining the sampling and direct components. inspection for piping systems that are difficult to detect However, based on review of documents on leakage.

the portal, it is not clear if the existing program

• Explain/discuss how already manages leakage for systems where management of leakage for leakage is difficult to detect, or if leakage for systems where leakage is these systems will be managed through difficult to detect is being updates to an existing procedure. Based on addressed as an the documentation on the portal, it appears a enhancement or via a new procedure will be developed. completely new.

2 B2.1.9 B - 88 The GALL-SLR Report AMP XI.M18 Preventive Actions:

recommends that selection of bolting material

• Clarify how the enhancement and the use of lubricants and sealants is in will be consistent with the accordance with the guidelines of EPRI GALL-SLR Report AMP Reports 1015336 and 1015337 and the recommendation to ensure additional recommendations of NUREG-1339 that selection of bolting to prevent or mitigate stress corrosion material and the use of cracking (SCC). lubricants and sealants are in accordance with the provided

• SLRA Enhancement No. 1 seeks to guidance and not just a revise applicable procedure and reference.

specifications to include reference to EPRI Report 1015336, EPRI Report 1015337,

• Clarify how the program will and NUREG-1339, as appropriate. be consistent with the GALL-SLR report AMP However, it is not clear how just including recommendation to ensure the references will ensure that adequate that molybdenum disulfide preventive actions are implemented within

Oconee SLRA: Breakout Questions SLRA Section B2.1.9, Bolting Integrity AMP: B2.1.9 l TRP: 18 the procedures. The staff notes that the (MoS2) is not used as a intent of the recommended preventive lubricant.

actions in GALL-SLR Report XI.M18 is to implement within the procedures the

• Clarify where the existing specified preventive or mitigative actions program includes preventive from these guidelines. measures to ensure that bolting material with an actual

• The GALL-SLR Report emphasizes the measured yield strength of industry guidance recommendation to less than 150 ksi is being restrict the use of molybdenum disulfide used.

(MoS2) as a lubricant since it has been shown to be a potential contributor to SCC.

However, no restriction was identified in the program for its use. The staff noted that the AMP recommends the use of Loctite N-5000 or equivalent for lubrication, but no restriction on MoS2 was identified. The staff also noted some procedure markup addressing this, but no enhancement in the SLRA has been provided.

• The GALL-SLR Report recommends including preventive actions which limits the use of bolting material to those with an actual measured yield strength less than 150 ksi.

However, it is not clear whether the AMP already considers this as a preventive action or if an exception was made since the staff couldnt verify it within the provided references.

3 B2.1.9 B - 86

• The GALL-SLR Report AMP XI.M18 Detection of Aging Effects:

recommends monitoring for crack

Oconee SLRA: Breakout Questions SLRA Section B2.1.9, Bolting Integrity AMP: B2.1.9 l TRP: 18 initiation, loss of preload, or loss of

• Clarify how/where the existing material as bolting degradation that may program ensures that result in leakage from the mating surfaces degradation of pressure or joint connections of pressure boundary boundary closure bolting due components. to crack initiation, loss of preload, or loss of material However, it is not clear where Oconee that may result in leakage implements these inspection criteria in from the mating surfaces or their existing procedures. joint connections of pressure boundary components is

• The GALL-SLR Report AMP recommends being detected during the SLRA to state how the aging effects inspections.

associated with closure bolting of components that are not normally

• Clarify how/where the existing pressurized will be managed. program ensures that closure bolting of components that However, it is not clear where this is are not normally pressurized addressed in the SLRA and/or how will be managed (e.g.,

Oconee will address this concern. checking the torque to the extent that the closure bolting is not loose) during the inspections.

4 B2.1.9 B - 88 The GALL-SLR Report AMP XI.M18 Monitoring and Trending:

recommends the inspections results be

• Clarify how the GALL-SLR evaluated and, when practical, degradations report AMP recommendation be projected until the next scheduled related to projection of inspection to ensure that components inspection results to the next intended function will be maintained inspection is addressed by throughout the SPEO. the existing AMP or how it will be addressed.

The staff noted AD-MN-ALL-0006 generally addresses this within the procedure for general leakages. However, it is not clear how Oconee addresses this for closure bolting in locations that preclude detection of joint

Oconee SLRA: Breakout Questions SLRA Section B2.1.9, Bolting Integrity AMP: B2.1.9 l TRP: 18 leakage, or where the piping systems contain air or gas for which leakage is difficult to detect.

5 B2.1.9 B - 88 The GALL-SLR Report AMP XI.M18, Corrective Actions:

Corrective Action program element

• Clarify if the intent of this recommends, for sampling-based inspections, enhancement is to implement to conduct additional inspections if one of the additional inspections for inspections does not meet the acceptance each inspection that did not criteria. meet the acceptance criteria or a more general approach

• SLRA AMP Enhancement No. 5 seems to of once when any sample-imply that additional inspections will be based inspection as a whole performed when sample-based does not meet the acceptance inspections, in general, not meet the criteria. Enhancement may acceptance criteria. Therefore, it is not need to be clarified, as clear if the procedure will implement this necessary.

additional inspection for each inspection that did not meet the acceptance criteria.

• Clarify if inspections of similar bolting (enhancement It is noted that the proposed draft No. 5) is intended to be procedure (Section 8.1) states that for bolting in other units having each unsat inspection result the same material, However, it is not stated as clearly in the environment, and aging effect SLRA enhancement that is being combination.

evaluated.

The GALL-SLR Report AMP also seeks to ensure that, at multi-unit sites, the additional inspections include inspections at all of the units with the same material, environment, and aging effect combination.

• SLRA Enhancement No. 5 will enhance the AMP to ensure that additional inspections of similar bolting will be performed at all three units

Oconee SLRA: Breakout Questions SLRA Section B2.1.9, Bolting Integrity AMP: B2.1.9 l TRP: 18 6 A2.9 A-10 The FSAR Supplement states, in part, that FSAR Supplement:

closure bolting on pressure-retaining

• Clarify why testing by components and mechanical bolting that are alternate means (e.g.,

submerged or closure bolting on pressure- inspected or tested) was not retaining components located in piping included as part of the FSAR systems that contain air or gas is inspected by supplement summary alternate means, However, it is not clear description.

why the testing by alternate means was omitted. It is noted that enhancement No. 4 includes the use of other testing methods (e.g., soap bubble testing) to detect cracking for this system.