ASME BPV XI NUCLEAR INSERVICE INSPECTION STANDARDS COMMITTEE HANDOUT

Transcription

1 ASME BPV XI NUCLEAR INSERVICE INSPECTION STANDARDS COMMITTEE HANDOUT 1. RECORD# PG RECORD # PG RECORD # PG RECORD # PG BWRVIP REPORT PG EPRI BWRVIP LETTERS PG

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5 Handout Item #2 Record WGISC I03-05 Page 4 of 5 (f) For BWRs, in lieu of examining all nozzles, a minimum of at least 25% of nozzle inner radii and nozzleto shell welds, including at least one nozzle for each system and nominal pipe size, may be performed examined for Table IWB , Examination Category B D Item No. B3.90 and B3.100, provided the following conditions are met:. 1) The nozzles are not feedwater nozzles or control rod drive return line nozzles. 2) The provisions of Appendix VIII are used for examinations. 3) The maximum RPV heatup/ and cooldown rates are is limited to less than 115 F/hour (64 C/hr). 4) For recirculation inlet nozzles, (pr/t)/crpv 1.15; where p is the RPV normal operating pressure (psi or MPa), r is the RPV inner radius (in.ch or mm), t is the RPV wall thickness (in.ch or mm), and CRPV = (for imperial U.S. Customary units) or (for metric S.I. units); 5) For recirculation inlet nozzles, [p(ro 2 +ri 2 )/(ro 2 ri 2 )]/CNOZZLE 1.47; where p is the RPV normal operating pressure (psi or MPa), ro is the nozzle outer radius (in.ch or mm), ri is the nozzle inner radius (in.ch or mm), and CNOZZLE = 1637 (for imperial U.S. Customary units) or (for metric S.I. units). 6) For recirculation outlet nozzles, (pr/t)/crpv 1.15; where p is the RPV normal operating pressure (psi or MPa), r is the RPV inner radius (in.ch or mm), t is the RPV wall thickness (in.ch or mm), and CRPV = (for imperial U.S. Customary units) or (for metric S.I. units). 7) For recirculation outlet nozzles, [p(ro 2 +ri 2 )/(ro 2 ri 2 )]/CNOZZLE 1.59; where p is the RPV normal operating pressure (psi or MPa), ro is the nozzle outer radius (in.ch or mm), ri is the nozzle inner radius (in.ch or mm), and CNOZZLE = 1977 (for imperial U.S. Customary units) or (for metric S.I. units). 8) Fluence levels do not exceed 1x10 17 n/cm 2 on any portion of the examined component. 9) The total number of heatup/ and cooldown cycles from plant startup for the component will not exceed 40 by the end of the interval. A cycle consists of both a heatup and a cooldown. (g) For BWRs, a VT 1 visual examination may be used performed in lieu of volumetric examination for Table IWB , Examination Category B D, Item No. B3.100, provided that the conditions of paragraph IWB 2500 (f)(1) through (f)(7) are met. 5

6 Handout Item #2 ASME BPVC.XI-2017 susceptible to outside surface attack, require surface examination each interval, in the same sequence, to the extent practical, over the lifetime of the item. The plant-specific review shall be updated each interval. The requirements of IWB-2411 shall be met. Acceptance standards shall be in accordance with IWB Forany socket weld connections identified as susceptible to thermal fatigue, VT-2 visual examination shall be performed at operating pressure during each refueling outage. Contributors to outside surface attack include proximity to nearby leak paths, proximity to chloride-bearing materials, existence of moisture- or salt-laden atmosphere, and existence of insulation or other coating or cover that traps moisture. Specific outside surface attack susceptibility criteria are as follows: (1) austenitic stainless steel base metal, welds, or heat-affected zone (HAZ); operating temperature greater than 150 F (65 C); and piping outside surface within five pipe diameters of a probable leak path (e.g., valve stem) and covered with nonmetallic insulation not in compliance with U.S. NRC Regulatory Guide 1.36 (e.g., chloride content) or equivalent requirements (2) austenitic stainless steel base metal, welds, or HAZ and piping outside surface exposed to wetting from a concentrated chloride-bearing environment (e.g., seawater, brackish water, brine) or (3) itemsidentifiedassusceptible to any mechanisms of outside surface attack other than external chloride stress corrosion cracking based on a review of plant experience and plant-specific processes and programs addressing chlorides and other contaminants (e) For PWR stainless steel residual and regenerative heat exchangers, in lieu of the requirements of Examination Categories B-B, B-D, and B-J, VT-2 visual examinations may be performed in accordance with the following: (1) These alternative examination requirements shall not be applied to any heat exchanger, nor to any heat exchanger design or configuration, that has experienced a through-wall leak, such as heat exchangers with an inner shell (inner barrel). The Owner shall review industry experience to determine which heat exchanger designs or configurations have leaked. If any leakage is detected, it shall be corrected in accordance with Article IWA Any subsequent use of these alternative examination requirements shall then be discontinued. The affected heat exchanger and others of the same design or configuration shall be examined in accordance with (a). (2) Application of these alternative examination requirements is limited to those welds that are part of the as-received heat exchanger assembly. The regenerative heat exchanger assembly may be formed from multiple smaller heat exchanger subcomponents connected by sections of piping. All of the smaller heat exchanger subcomponents and the connecting piping are within the boundary of the heat exchanger assembly. (3) All welds, other than reinforcing plate welds, shall have received at least one volumetric examination. The preservice or Construction Code volumetric examination may be used to meet this requirement. Reinforcing plate welds shall have received at least one surface examination. (4) The component shall be VT-2 visually examined for evidence of leakage while undergoing the system leakage test as required by Examination Category B-P, to be performed every refueling outage. IWB-3522 shall be met. (f) For BWRs, in lieu of examining all nozzles, at least 25% of nozzle inner radii and nozzle to shell welds, including at least one nozzle for each system and nominal pipe size, may be examined for Table IWB (B-D), Item Nos. B3.90 and B3.100, provided the following conditions are met: (1) The nozzles are not feedwater nozzles or control rod drive return line nozzles. (2) TheprovisionsofAppendixVIIIareusedfor examinations. (3) The maximum RPV heatup and cooldown rates are limited to less than 115 F/hr (64 C/h). (4) For recirculation inlet nozzles where C RPV = 19,332 (for U.S. Customary units) or (for SI units) p = the RPV normal operating pressure, psi (MPa) r = the RPV inner radius, in. (mm) t = the RPV wall thickness, in. (mm) (5) For recirculation inlet nozzles where C NOZZLE = 1,637 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (6) For recirculation outlet nozzles where C RPV = 16,171 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (7) For recirculation outlet nozzles 6 75

7 Handout Item #2 ASME BPVC.XI-2017 where C NOZZLE = 1,977 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (8) Fluence levels do not exceed n/cm 2 on any portion of the examined component. (9) The total number of heatup and cooldown cycles from plant startup for the component will not exceed 40 by the end of the interval. A cycle consists of both a heatup and a cooldown. (g) For BWRs, a VT 1 visual examination may be performed in lieu of volumetric examination for Table IWB (B-D), Item No. B3.100, provided the conditions (f)(1) through (f)(7) are met. 76 7

8 Handout Item #2 ASME BPVC.XI-2017 susceptible to outside surface attack, require surface examination each interval, in the same sequence, to the extent practical, over the lifetime of the item. The plant-specific review shall be updated each interval. The requirements of IWB-2411 shall be met. Acceptance standards shall be in accordance with IWB Forany socket weld connections identified as susceptible to thermal fatigue, VT-2 visual examination shall be performed at operating pressure during each refueling outage. Contributors to outside surface attack include proximity to nearby leak paths, proximity to chloride-bearing materials, existence of moisture- or salt-laden atmosphere, and existence of insulation or other coating or cover that traps moisture. Specific outside surface attack susceptibility criteria are as follows: (1) austenitic stainless steel base metal, welds, or heat-affected zone (HAZ); operating temperature greater than 150 F (65 C); and piping outside surface within five pipe diameters of a probable leak path (e.g., valve stem) and covered with nonmetallic insulation not in compliance with U.S. NRC Regulatory Guide 1.36 (e.g., chloride content) or equivalent requirements (2) austenitic stainless steel base metal, welds, or HAZ and piping outside surface exposed to wetting from a concentrated chloride-bearing environment (e.g., seawater, brackish water, brine) or (3) itemsidentifiedassusceptible to any mechanisms of outside surface attack other than external chloride stress corrosion cracking based on a review of plant experience and plant-specific processes and programs addressing chlorides and other contaminants (e) For PWR stainless steel residual and regenerative heat exchangers, in lieu of the requirements of Examination Categories B-B, B-D, and B-J, VT-2 visual examinations may be performed in accordance with the following: (1) These alternative examination requirements shall not be applied to any heat exchanger, nor to any heat exchanger design or configuration, that has experienced a through-wall leak, such as heat exchangers with an inner shell (inner barrel). The Owner shall review industry experience to determine which heat exchanger designs or configurations have leaked. If any leakage is detected, it shall be corrected in accordance with Article IWA Any subsequent use of these alternative examination requirements shall then be discontinued. The affected heat exchanger and others of the same design or configuration shall be examined in accordance with (a). (2) Application of these alternative examination requirements is limited to those welds that are part of the as-received heat exchanger assembly. The regenerative heat exchanger assembly may be formed from multiple smaller heat exchanger subcomponents connected by sections of piping. All of the smaller heat exchanger subcomponents and the connecting piping are within the boundary of the heat exchanger assembly. (3) All welds, other than reinforcing plate welds, shall have received at least one volumetric examination. The preservice or Construction Code volumetric examination may be used to meet this requirement. Reinforcing plate welds shall have received at least one surface examination. (4) The component shall be VT-2 visually examined for evidence of leakage while undergoing the system leakage test as required by Examination Category B-P, to be performed every refueling outage. IWB-3522 shall be met. (f) For BWRs, in lieu of examining all nozzles, at least 25% of nozzle inner radii and nozzle to shell welds, including at least one nozzle for each system and nominal pipe size, may be examined for Table IWB (B-D), Item Nos. B3.90 and B3.100, provided the following conditions are met: (1) The nozzles are not feedwater nozzles or control rod drive return line nozzles. (2) TheprovisionsofAppendixVIIIareusedfor examinations. (3) The maximum RPV heatup and cooldown rates are limited to less than 115 F/hr (64 C/h). (4) For recirculation inlet nozzles where C RPV = 19,332 (for U.S. Customary units) or (for SI units) p = the RPV normal operating pressure, psi (MPa) r = the RPV inner radius, in. (mm) t = the RPV wall thickness, in. (mm) (5) For recirculation inlet nozzles where C NOZZLE = 1,637 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (6) For recirculation outlet nozzles where C RPV = 16,171 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (7) For recirculation outlet nozzles 8 75

9 Handout Item #2 ASME BPVC.XI-2017 where C NOZZLE = 1,977 (for U.S. Customary units) or (for SI units) For definitions of p, r, and t, see (4). (8) Fluence levels do not exceed n/cm 2 on any portion of the examined component. (9) The total number of heatup and cooldown cycles from plant startup for the component will not exceed 40 by the end of the interval. A cycle consists of both a heatup and a cooldown. (g) For BWRs, a VT 1 visual examination may be performed in lieu of volumetric examination for Table IWB (B-D), Item No. B3.100, provided the conditions (f)(1) through (f)(7) are met. 76 9

10 BC Proposal file Handout Item #3 ð17þ Table IWE (E-A) Examination Category E-A, Containment Surfaces Item No. E1.10 Parts Examined Containment Vessel Pressure-Retaining Boundary [Note (1)] Examination Requirements/ Fig. No. [Note (1)] Examination Method Acceptance Standard Extent and Frequency of Examination 1st Inspection Interval Successive Inspection Intervals Deferral of Inspection to End of Interval E1.11 Accessible Surface Areas IWE-2310 General visual IWE % during each inspection period 100% during each inspection period N/A E1.12 Wetted Surfaces of Submerged Areas IWE-2310 VT-3 IWE % 100% See [Note (2)] E1.20 BWR Vent System Accessible Surface Areas [Note (1)] [Note (3)] IWE-2310 VT-3 IWE % 100% See [Note (2)] 202 E1.30 Moisture Barriers E1.31 E1.32 Accessible caulking, flashing, and sealants [Note (4)] Accessible Leak Chase Channel System Closures [Note (5)] IWE-2310, Figure IWE General visual IWE-3510 IWE-2310 General visual IWE % during each inspection period 100% during each inspection interval 100% during each inspection period 100% during each inspection interval N/A Not permissible ASME BPVC.XI-2017 NOTES: (1) Examination shall include all accessible interior and exterior surfaces of Class MC components, parts, and appurtenances, and metallic shell and penetration liners of Class CC components. The following items shall be examined: (a) integral attachments and structures that are parts of reinforcing structure, such as stiffening rings, manhole frames, and reinforcement around openings. (b) surfaces of attachment welds between structural attachments and the pressure-retaining boundary or reinforcing structure, except for nonstructural or temporary attachments as defined in NE-4435 and minor permanent attachments as defined in CC (c) surfaces of containment structural and pressure boundary welds, including longitudinal welds (Category A), circumferential welds (Category B), flange welds (Category C), and nozzle-to-shell welds (Category D) as defined in NE-3351 for Class MC and CC-3840 for Class CC; and surfaces of Flued Head and Bellows Seal Circumferential Welds joined to the Penetration. (d) pressure-retaining bolted connections, including bolts, studs, nuts, bushings, washers, threads in base material, and flange ligaments between fastener holes. Bolted connections need not be dissassembled for performance of examinations. (2) Examinations may be performed at any time during the interval, provided successive examinations are performed no less frequently than every third period. (3) Includes flow channeling devices within containment vessels. (4) Examination shall include accessible moisture barrier materials intended to prevent intrusion of moisture into inaccessible areas of the metal containment shell or liner at concreteto-metal interfaces and at metal-to-metal interfaces that are not seal-welded. Containment moisture barrier materials include caulking, flashing, and other sealants used for this application. 10

11 Handout Item #3 Table IWE (E-G) Examination Category E-G, Pressure Retaining Bolting Examination Extent and Frequency of Examination Deferral of Requirements/ Examination Acceptance 1st Inspection Interval Successive Inspection Inspection to End Item No. Parts Examined Figure No. Method Standard Intervals of Interval E8.10 Bolted Connections [Note (1)] IWE 2310 VT 1 IWE % of each bolted connection [Note (2)] 100% of each bolted connection [Note (2)] Permissible Notes: (1) Examination shall include bolts, studs, nuts, bushings, washers, threads in base material, and flange ligaments between fastener holes. (2) Examination may be performed with the connection assembled and bolting in place under tension, provided the connection is not dissassembled during the interval. If the bolted connection is dissassembled for any reason during the interval, the examination shall be performed with the connection dissassembled. END OF NOTES Changes: removed the word and in front of threads in base material and inserted a comma following threads in base material in Table IWE E-A note (1)(d) and Table IWE E-G note (1). 11

12 Handout Item #4 Record No Table IWB (B-J) Examination Category B-J, Pressure-Retaining Welds in Piping Item No. Parts Examined B9.10 NPS 4 or larger (DN 100) B9.11 Circumferential welds B9.20 B9.21 B B9.31 B9.32 B9.40 IWB Extent and Frequency of Examination Examination Method Surface and volumetric Acceptance Standard IWB-3514 Less than NPS 4 (DN 100) Circumferential welds other than PWR high pressure safety injection systems Surface IWB Circumferential welds of PWR high pressure safety injection systems IWB-3514 First Inspection Interval Welds [Note (2)], [Note (3)], [Note (4)], [Note (5)], [Note (6)] Welds [Note (2)], [Note (3)], [Note (4)] Successive Inspection Intervals [Note (1)] Deferral of Examination to End of Interval Same as for first interval Not permissible Same as for first interval Not permissible Welds [Note (3)], [Note (5)], [Note (6)], [Note (7)] Volumetric Branch pipe connection welds NPS 4 or larger (DN 100) Less than NPS 4 (DN 100) Socket welds Surface and volumetric IWB , IWB , and IWB Surface IWB-3514 IWB IWB-3514 Surface Welds [Note (2)], [Note (3)], [Note (4)], [Note (5)], [Note (6)] Same as for first interval Not permissible Welds [Note (2)], [Note (3)], [Note (4)] Welds [Note (2)], [Note (3)] Same as for first interval Not permissible NOTES: (1) The initially selected welds are to be examined in the same sequence during successive inspection intervals, to the extent practical. (2) Examinations shall include the following: (a) All terminal ends in each pipe or branch run connected to vessels. (b) All terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under loads associated with specific seismic events and operational conditions: (1) primary plus secondary stress intensity range of 2.4 S m for ferritic steel and austenitic steel (2) cumulative usage factor U of 0.4 (c) All dissimilar metal welds not covered under Category B F. (d) Additional piping welds so that the total number of circumferential butt welds (or branch connection or socket welds) selected for examination equals 25% of the circumferential butt welds (or branch connection or socket welds) in the reactor coolant piping system. This total does not include welds exempted by IWB-1220 or welds in Item No. B9.22. These additional welds may be located as follows: (1) For PWR plants (-a) one hot leg and one cold leg in one reactor coolant piping loop (-b) one branch, representative of an essentially symmetric piping configuration among each group of branch runs that are connected to reactor coolant loops and that perform similar system functions See Insert A on Page ASME BPVC.XI-2017 B9.30 Examination Requirements/ Figure No.

13 Handout Item #4 Record No (2) Examinations shall include the following: Category B-J welds shall be selected for examination such that 25% (excluding welds exempted by IWB-1220 or welds in Item No. B9.22) of the circumferential butt welds (or branch connection or socket welds) are examined during the interval. The welds selected for examination shall be prorated to include the welds listed in (a), (b) and (c) below, up to 25% of the total population of Category B-J welds. If additional welds are required to meet the 25% criteria, they shall be selected in accordance with (d) below. (a) All Terminal ends in each pipe or branch run connected to vessels. (b) All Terminal ends and joints in each pipe or branch run connected to other components where the stress levels exceed either of the following limits under loads associated with specific seismic events and operational conditions: (1) primary plus secondary stress intensity range of 2.4 Sm for ferritic steel and austenitic steel (2) cumulative usage factor U of 0.4 (c) All Dissimilar metal welds not covered under Category B F. (d) Additional piping welds so that the total number of circumferential butt welds (or branch connection or socket welds) selected for examination equals 25% of the circumferential butt welds (or branch connection or socket welds). in the reactor coolant piping system. This total does not include welds exempted by IWB-1220 or welds in Item No. B9.22. These additional welds may be located as follows: Insert A 2 13

14 Handout Item #5 08/01/2017 Boiling Water Reactor Vessel and Internals Project (BWRVIP) Report Aug 10, 2017 ASME Section XI Standards Committee I. 2017, BWRVIP Committee Meetings/Training Meeting Purpose Date(s) Location BWRVIP IVVI Training BWRVIP IVVI Training BWRVIP Executive Committee Materials Action Plan Committee (MAPC) Inspection Focus Group Assessment Committee Mitigation Committee BWRVIP IVVI Training at GEH Training Facility BWRVIP IVVI Training at GEH Training Facility Approve 2019 Scope and Budget July 11-13, 2017 Aug 22-24, 2017 Aug 29, 2017 (EPRI NPC week) Semi-Annual Meeting Aug 30, 2017 (EPRI NPC week) Update Participants on Dec 5-6, 2017 Status of IFG Activities Update Participants on Dec 6-7, 2017 Status of AC Activities Update Participants on Dec 6-7, 2017 Status of MC Activities San José, CA San José, CA Hollywood, FL Hollywood, FL Clearwater, FL Clearwater, FL Clearwater, FL Integration Committee Strategic Planning Dec 7-8, 2017 Clearwater, FL II. The following BWRVIP Guidelines, or EPRI reports that were co-funded by the BWRVIP, were issued since the BWRVIP report-out at May s Section XI Standards Committee meetings: 1. Title: BWRVIP-310: BWR Vessel and Internals Project, Report and Nuclear Regulatory Commission Correspondence DVD, Version 2016 Product Number: Date Published: 31-May Title: BWRVIP-296, Revision 1: BWR Vessel and Internals Project, Brunswick Unit 1 Lower Plenum ECP Analysis after Implementation of On-Line NobleChem (OLNC) Product Number: Date Published: 31-July Title: BWRVIP-306: BWR Vessel and Internals Project, Stress Corrosion Crack Growth Rates of Low Alloy Steels During Chloride Transients: Crack Activation and Arrest Times Product Number: Date Published: 01-Aug-17 III. The BWRVIP is working with the NRC to complete their review of several BWRVIP reports. 1. BWRVIP-41, Revision 4: BWR Vessel and Internals Project, BWR Jet Pump Assembly Inspection and Flaw Evaluation Guidelines, EPRI TR This is the optimized version of the jet pump I&E guidelines. Revision 4 of BWRVIP-41 was submitted to the NRC on September 24, The NRC issued a Request for Additional Information (RAI) on May 5, 2016 and the BWRVIP replied to the RAI on February 9, Per the NRC s schedule, they expected to issue the Draft SE by September 13 th of this year. However, the NRC and the BWRVIP just went through a round of clarification questions on the BWRVIP s RAI responses so the SE is likely delayed until sometime in October. 1 of 2 14

15 Handout Item #5 08/01/ BWRVIP-25, Revision 1: BWR Vessel and Internals Project, BWR Core Plate Inspection and Flaw Evaluation Guidelines, EPRI TR Revision 1 of BWRVIP-25 was submitted to the NRC on September 30, Per the NRC s schedule, they were to be issued by June. The draft RAI were received in June for proprietary material identification and the BWRVIP s NRC Project Manager has reported that the RAI have been signed out, but they have not yet been received by the BWRVIP or posted in ADAMS. Their receipt should be imminent. The BWRVIP has scheduled a public meeting with the NRC on September 7 th to discuss the RAI with them. IV. Status of NRC review of BWRVIP-62, Revision 1: BWR Vessel and Internals Project, Technical Basis for Inspection Relief for BWR Internal Components with Hydrogen Injection, EPRI TR Timeline: Revision 1 of BWRVIP-62, which incorporated on-line noble metals chemical addition (i.e., On-Line Noble/Chem, OLNC TM ), was submitted to the NRC for review and approval on March 7, Since most U.S. BWRs were transitioning from traditional noble metals chemical application (NMCA) to OLNC TM, and the NRC approved version of BWRVIP-62 (i.e. BWRVIP-62-A) did not specifically address OLNC TM, the BWRVIP notified the NRC on November 20, 2012 that plants would be using Revision 1 for inspection relief consistent with the limitations and conditions for NMCA in the NRC s SE for BWRVIP-62. The NRC issued RAI on March 3, The NRC issued a 2 nd set of RAI September 19, On March 17, 2017, the BWRVIP withdrew BWRVIP-62, Revision 1 from NRC review. On April 18, 2017, the BWRVIP sent a letter to the NRC further explaining the status of BWRVIP-62 revision and inspection relief for BWR piping welds and internal components with HWC. Work to address the NRC RAI involves in-situ sampling for noble metal loadings (i.e., deposition amounts) at the plants. This work has to be planned for, and completed in conjunction with, plant refueling outages, and thus is taking several years to complete. To date, the in-situ sampling has shown positive results, but has indicated that some changes to BWRVIP-62 would be required to address the issue of noble metal loadings. As such, the BWRVIP withdrew Revision 1 with plans to address the necessary changes in Revision 2 to BWRVIP-62. With the withdrawal of BWRVIP-62, Revision 1, the NRC has expressed concerns with the status of HWC inspection relief for GL 88-01/BWRVIP-75-A piping weld inspections (the NRC mentions these concerns in Section 3 of their report for the Anchorage ASME Code Committee meetings). The BWRVIP s April 18, 2017 letter (referenced above) provides the BWRVIP s initial feedback on the NRC s concerns and the BWRVIP is working with the NRC to resolve their concerns. As a part of those efforts, the BWRVIP is having a closed meeting with the NRC on September 21 st to present an update on the BWRVIP s proprietary work to verify the effectiveness of OLNC TM. 2 of 2 15

16 Handout Item # BWR Vessel & Internals Project (BWRVIP) (via ) July 6, 2017 TO: All BWRVIP Committee Members FROM: SUBJECT: Drew Odell, Exelon, BWRVIP Integration Chairman Andrew McGehee, EPRI, BWRVIP Program Manager Method of NRC Approval to Use ASME Code Case N-702, Alternative Requirements for Boiling Water Reactor (BWR) Nozzle Inner Radius and Nozzle-to-Shell Welds References: 1. BWRVIP-108NP: BWR Vessel and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzleto-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , November BWRVIP-241: BWR Vessel and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , October Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 17, August The purpose of this letter is to provide clarification to BWRVIP members on the current method of NRC approval to use Code Case N-702. The technical basis for N-702 is BWRVIP-108NP [1] and BWRVIP-241[2]. The inspection relief provided by the use of N-702 results in significant dose and monetary savings for BWR plants. Therefore, N-702 is being widely used by the BWRs. As N-702 was not listed in RG [3] until Revision 17, the initial requests for its use were all submitted as requests for a technical alternative in accordance with 10 CFR 50.55a(z); often referred to as relief requests. However, N-702 is now conditionally approved for use in RG 1.147, Revision 17. Therein, it states the following: The technical basis supporting the implementation of this Code Case is addressed by BWRVIP-108: BWR Vessel and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , October 2002 (ML ) and BWRVIP-241: BWR Vessel and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and 16

17 Handout Item #6 BWRVIP Nozzle Blend Radii, EPRI Technical Report , October 2010 (ML11119A041). The applicability of Code Case N-702 must be shown by demonstrating that the criteria in Section 5.0 of NRC Safety Evaluation regarding BWRVIP-108 dated December 18, 2007 (ML ) or Section 5.0 of NRC Safety Evaluation regarding BWRVIP-241 dated April 19, 2013 (ML13071A240) are met. The evaluation demonstrating the applicability of the Code Case shall be reviewed and approved by the NRC prior to the application of the Code Case. Since N-702 is now conditionally approved in RG-1.147, it is considered an approved technical alternative to Code requirements and can be used subject to the conditions given in the RG. Therefore, approval in accordance with 10 CFR 50.55a(z) is no longer required. The NRC has brought it to the BWRVIP s attention that a number of plants that are updating their ASME Section XI relief requests for a new 10-year inspection interval, are resubmitting relief requests for the use of N-702. Instead, the plants need only meet the conditions in RG Those conditions do still require NRC review and approval of the plant s demonstration of compliance with the criteria in Section 5.0 of the Safety Evaluations for BWRVIP-108 or BWRVIP-241, as applicable. To accomplish this, the plants should provide their evaluation demonstrating applicability of N-702 for their plant to their NRC Project Manager in the Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation. It is recommended that the information contained within this letter be communicated to utility staff responsible for implementation of Inservice Inspection (ISI) programs in accordance with ASME Boiler and Pressure Vessel Code or 10CFR50.55a requirements. If you have any questions regarding this subject, please contact Chuck Wirtz at EPRI by telephone at or by at cwirtz@contractor.epri.com. c: BWRVIP EPRI Task Managers 2 17

18 Handout Item # BWR Vessel & Internals Project (BWRVIP) (via ) August 1, 2017 TO: All BWRVIP Committee Members FROM: SUBJECT: Drew Odell, Exelon, BWRVIP Integration Chairman Andrew McGehee, EPRI, BWRVIP Program Manager Retraction of Description of Method of NRC Approval to Use ASME Code Case N-702 Provided by BWRVIP Letter References: 1. BWRVIP Letter , Method of NRC Approval to Use ASME Code Case N-702, Alternative Requirements for Boiling Water Reactor (BWR) Nozzle Inner Radius and Nozzle-to-Shell Welds, dated July 6, BWRVIP-108NP: BWR Vessel and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzleto-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , November BWRVIP-241: BWR Vessel and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , October Regulatory Guide 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1, Revision 17, August Reference 1 was sent to the BWRVIP membership to provide clarification on the current method of NRC approval to use Code Case N-702. The technical basis for N-702 is BWRVIP-108NP [2] and BWRVIP-241[3]. The inspection relief provided by the use of N-702 results in significant dose and monetary savings for BWR plants. Therefore, N-702 is being widely used by the BWRs. Since N-702 was not listed in RG [4] until Revision 17, the initial requests for its use were all submitted as requests for a technical alternative in accordance with 10 CFR 50.55a(z); often referred to as relief requests. However, N-702 is now conditionally approved for use in RG 1.147, Revision 17. Therein, it states the following: The technical basis supporting the implementation of this Code Case is addressed by BWRVIP-108: BWR Vessel and Internals Project, Technical Basis for the Reduction of Inspection Requirements for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , October 2002 (ML ) 18

19 Handout Item #6 BWRVIP and BWRVIP-241: BWR Vessel and Internals Project, Probabilistic Fracture Mechanics Evaluation for the Boiling Water Reactor Nozzle-to-Vessel Shell Welds and Nozzle Blend Radii, EPRI Technical Report , October 2010 (ML11119A041). The applicability of Code Case N-702 must be shown by demonstrating that the criteria in Section 5.0 of NRC Safety Evaluation regarding BWRVIP-108 dated December 18, 2007 (ML ) or Section 5.0 of NRC Safety Evaluation regarding BWRVIP-241 dated April 19, 2013 (ML13071A240) are met. The evaluation demonstrating the applicability of the Code Case shall be reviewed and approved by the NRC prior to the application of the Code Case. Since N-702 was conditionally approved in RG-1.147, it was considered to be an approved technical alternative to Code requirements and believed that it could be used subject only to the conditions given in the RG without the need for approval in accordance with 10 CFR 50.55a(z). In fact, NRC staff in the Division of Nuclear Reactor Regulation (NRR) informed the BWRVIP that was their position and thus Reference 1 was generated and sent to our members. However, the BWRVIP has now been informed that the NRC s Office of General Council (OGC) has overturned NRR s position and states that approval to use N-702 must still be sought in accordance with 10 CFR 50.55a(z). In summary, the method of NRC approval to use Code Case N-702 that was described in Reference 1 is retracted and until further notice, approval to use Code Case N-702 should still be sought in accordance with 10 CFR 50.55a(z). As it was with Reference 1, it is recommended that the information contained within this letter be communicated to utility staff responsible for implementation of Inservice Inspection (ISI) programs in accordance with ASME Boiler and Pressure Vessel Code or 10CFR50.55a requirements. If you have any questions regarding this subject, please contact Chuck Wirtz at EPRI by telephone at or by at cwirtz@contractor.epri.com. c: BWRVIP EPRI Task Managers 2 19