Information Notice 2012-19, License Renewal Post-Approval Site Inspection Issues
| ML12242A195 | |
| Person / Time | |
|---|---|
| Issue date: | 10/23/2012 |
| From: | Mcginty T Division of License Renewal |
| To: | |
| Jones H | |
| References | |
| IN-12-019 | |
| Download: ML12242A195 (6) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001 October 23, 2012 NRC INFORMATION NOTICE 2012-19: LICENSE RENEWAL POST-APPROVAL SITE
INSPECTION ISSUES
ADDRESSEES
All holders of or applicants for operating licenses for nuclear power reactors under the
provisions of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing
of Production and Utilization Facilities, except those who have permanently ceased operations
and have certified that fuel has been permanently removed from the reactor vessel.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice (IN) to inform
addressees of issues of concern identified during inspection procedure (IP) 71003 inspections, Post-Approval Site Inspection for License Renewal, (Agencywide Documents Access and
Management System [ADAMS] Accession No. ML082830294), related to the management and
implementation of the aging management programs (AMPs) described in the updated final
safety analysis report (UFSAR) supplement, regulatory commitments for license renewal, and
license conditions that are added as part of the renewed license. The examples of
discrepancies included in this IN could have generic implications and may impact the licensees
ability to meet a commitment or effectively implement an AMP as was intended by the various
license renewal documents. Licensees are reminded to apply thoroughness, diligence, and
attention to detail when implementing, managing, and controlling the UFSAR supplement, commitments for license renewal, and license conditions that are specific to license renewal.
The NRC expects that recipients will review the information for applicability to their facilities and
consider actions, as appropriate, to avoid similar problems. Suggestions contained in this IN
are not NRC requirements; therefore, no specific action or written response is required.
BACKGROUND
The NRC regulations in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for
Nuclear Power Plants, provide a means by which licensees can obtain a renewed operating
license which allows continued operation of a nuclear power plant beyond its original license
term (40 years). NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Revision 2, issued December 2010 (hereafter referred to as the GALL Report), provides recommended
programs that the NRC staff finds acceptable to manage the aging effects of passive and
long-lived systems, structures, and components as plants enter the period of extended
operation. License conditions are added to a renewed license to allow for changes to the
licensees AMPs in accordance with NRC requirements and to ensure that certain future
programs and activities are completed before the period of extended operation.
ML12242A195 As licensees approach the period of extended operation, the NRC regional offices conduct
inspections using IP 71003. The objectives of IP 71003 inspections include: (1) verifying the
implementation of license conditions added as part of the renewed license and regulatory
commitments for license renewal; and (2) confirming that the licensee has implemented the
AMPs as described in the UFSAR supplement. A majority of these inspections are conducted
before the licensee enters the period of extended operation. The inspections are scheduled to
support completion of the review in sufficient time for licensees to make any necessary
corrections to their AMPs before entering the period of extended operation.
DESCRIPTION OF CIRCUMSTANCES
The NRC staff has performed many post-approval site inspections for license renewal at
several plants, shortly before the plants entered the period of extended operation. The
following information in this section describes issues that were identified during IP 71003 inspections conducted from 2009 to 2012.
Oyster Creek Generating Station - Implementation of Corrosion Prevention Measures
Several issues were identified involving license renewal activities to implement corrosion
prevention measures. Specifically, a strippable coating that was applied to the reactor cavity
liner to prevent water leakage and protect the drywell shell from corrosion, unexpectedly de- laminated. This allowed water to leak into the gap between the drywell shell and concrete
shield wall and flow down the outside of the drywell shell into four of the ten sand bed bays.
Additionally, NRC inspectors identified that an established administrative limit for cavity seal
leakage did not prevent water intrusion into the gap. Further, the licensee monitored for water
leakage from the sand bed bay drains by checking bottles connected via tygon tubing and
funnels to the sand bed bay drain lines. Subsequently, the licensee identified that the tubing
was not connected to the drain lines for two sand bed bays. When deficiencies or
nonconformances are identified associated with the inadequate implementation of activities for
license renewal, it is important that licensees establish corrective actions to prevent the
ineffective aging management of systems, structures, and components. This event is described
in Oyster Creek Generating Station-NRC License Renewal Follow-Up Inspection Report 05000219/2009006, dated May 18, 2009 (ADAMS Accession No. ML091380379).
Dresden Nuclear Power Station Unit 2 - Implementation of the One-Time Inspection Program
NRC inspectors identified instances in which the licensees one-time inspection of a system
(i.e., a ventilation system) identified degradation (i.e., ducting corrosion), but the evaluation to
address the identified aging effect was inadequate. Specifically, the licensee scheduled
follow-up examinations of the identified degraded system and did not conduct an
extent-of-condition review for other similar in-scope systems, such as other ventilation systems
with ducting of the same material under similar environmental conditions. The purpose of the
one-time inspection program is to provide reasonable assurance that an aging effect, such as
degradation from corrosion, is not occurring or that the aging effect is occurring in a manner
such that the component or structures intended function(s) will not be affected during the period
of extended operation and, therefore, not require additional aging management (e.g., measures
to monitor and prevent corrosion of that structure or component). If a one-time inspection
identifies age-related degradation that could jeopardize an intended function before the end of
the period of extended operation, the one-time inspection program calls for the licensee to: (1) perform an evaluation of the need for follow-up examinations to monitor the progression of any
age-related degradation; and (2) perform an extent-of-condition review. This event is described
in Dresden Nuclear Power Station, Unit 2 NRC Post-Approval Site Inspection for License
Renewal Inspection Report 05000237/2009007, dated December 22, 2009 (ADAMS Accession
No. ML093570258).
Palisades Nuclear Plant - Management of CHECWORKS Software
Consistent with the GALL Report, some licensees made regulatory commitments that were
incorporated into the UFSAR that stated an effective flow accelerated corrosion program
includes analysis using a predictive code, such as CHECWORKS. NRC inspectors identified
one example in which the licensee classified and managed the CHECWORKS software at a
lower level (i.e., Business Important instead of Regulatory Commitments) than what was
specified in the licensees procedure for software quality assurance. It is important that any
software used to perform calculations be classified and managed in accordance with licensee
procedures for software quality assurance to ensure that the appropriate software quality
assurance requirements are applied during installation and testing of the program, and prior to
its use. Also, it should be noted that regulatory commitments incorporated as part of the
UFSAR supplement are considered components of the UFSAR, and are managed in
accordance with the requirements of 10 CFR 50.59, Changes, tests, and experiments. This
event is described in Palisades Nuclear Plant Post-Approval Site Inspection for License
Renewal, Inspection Report 05000255/2011008 (DRS), dated May 6, 2011 (ADAMS Accession
No. ML11126A328).
H.B. Robinson Steam Electric Plant (H.B. Robinson) and Surry Power Station (Surry) Units 1 and 2 - Implementation of Procedures for AMPs
NRC inspectors identified one example where steps added to site-specific procedures in order
to satisfy a UFSAR action item, which consisted of enhancements to the systems monitoring
program, were inadvertently deleted as a result of a procedure revision. The procedure revision
deleted enhancements made to the list of aging effects included in a system walkdown
checklist. The elimination of such enhancements occurred during a transition from site-specific
procedures to corporate procedures. The resulting implementation procedures would not have
provided adequate guidance to meet the action as described in the plants UFSAR because one
of the applicable aging effects would not have been addressed in the procedure. This event is
described in H.B. Robinson Steam Electric Plant - NRC Post-Approval Site Inspection for
License Renewal Inspection Report 05000261/2010008, dated April 7, 2010 (ADAMS
Accession No. ML100970495).
Additionally, NRC inspectors identified one example where the adequacy of an approved station
procedure, as part of an AMP to monitor water intrusion into manholes, which could lead to
age-related degradation in high- or medium-voltage cables for non-environmental qualification
applications, was not effectively verified prior to its final approval. The NRC inspectors noted
that the procedure to inspect manholes would not have provided adequate instructions, during
the period of extended operation, to fully meet the actions described in the UFSAR, due to
physical limitations in the manhole design. This event is described in Surry Power Station
Units 1 and 2 - NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000280/2011010 and 05000281/2011010, dated September 12, 2011 (ADAMS Accession
No. ML112560062). It is important for licensees to: (1) establish implementation procedures that provide adequate
instructions for activities involving the testing, inspection, operation, or maintenance of systems, structures, and components within the scope of license renewal; and (2) ensure revisions to
procedures are controlled such that any changes to instructions that are incorporated to fulfill a
commitment for license renewal are given full consideration before being revised. By doing so, licensees can preclude the reduction in the effectiveness of AMPs and the unsatisfactory
completion of activities for license renewal. The licensees for H.B. Robinson and Surry
documented the deficiencies in their corrective action programs and initiated corrective actions
to address the issues.
Vermont Yankee Nuclear Power (Vermont Yankee) - Management of License Conditions
Added As Part of the Renewed License
During the license renewal application review, regulatory commitments are made by the
applicant and listed in Appendix A of the license renewal safety evaluation report. NRC
inspectors identified that commitments listed in Appendix A of the license renewal safety
evaluation report for Vermont Yankee had not been incorporated as part of the UFSAR
supplement. The conditions that were added as part of the renewed operating license for
Vermont Yankee did not require the commitments for license renewal to be incorporated as part
of the UFSAR. Furthermore, the specific wording of one of the license conditions that was
added to the renewed license stated, The UFSAR supplement, as revised, submitted pursuant
to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the
period of extended operation. [The licensee] shall complete these activities in accordance with
Appendix A of the safety evaluation report for license renewal. This wording escalated the
regulatory commitments to license conditions. Regulatory commitments that are incorporated
as part of the UFSAR supplement are considered components of the UFSAR, and are managed
in accordance with the requirements of 10 CFR 50.59. Regulatory commitments that are
referenced in the license condition for license renewal, but not incorporated as part of the
UFSAR, are to be treated as license conditions. Changes to license conditions require NRC
approval and are processed in accordance with the requirements of 10 CFR 50.90, Application
for amendment of license, construction permit, or early site permit. This issue appears in
Vermont Yankee Nuclear Power - NRC Inspection Report 05000271/2012008, dated April 20,
2012 (ADAMS Accession No. ML12103A406).
DISCUSSION
The renewed operating license requires that licensees update the UFSAR with the UFSAR
supplement, which includes programs and activities associated with license renewal. The
renewed license also requires that certain future activities be completed before the period of
extended operation. NRC inspectors conduct post-approval site inspections for license renewal
to verify that the licensee effectively implements and manages license conditions, AMPs, and
commitments for license renewal and to ensure that the licensee has made any necessary
corrections before the licensee enters the period of extended operation. This IN summarizes
several issues of concern that were identified during previous post-approval site inspections and
may have broad implications for plants scheduled for upcoming IP 71003 inspections.
Licensees manage changes to commitments and AMPs incorporated into the UFSAR
supplement in accordance with 10 CFR 50.59. Commitments that are not incorporated in the UFSAR, but are referenced in the license conditions for license renewal, are escalated to
license conditions. In accordance with 10 CFR 50.90, licensees can apply for amendments to
license conditions. Both the NRC and the licensees need to ensure that there is a clear
understanding of the intent and expectations with regard to the implementation of license
conditions and commitments for license renewal at the time the renewed license is issued.
A nonconformance with a commitment or AMP description included in the UFSAR could be a
deviation, whereas a nonconformance with a license condition could be a violation. Licensees
are required to correct deviations, deficiencies, and nonconformances in accordance with
Criterion XVI of Appendix B to 10 CFR Part 50, Corrective Action, or through their corrective
action programs.
CONTACT
S
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contacts listed below or the appropriate NRC project manager.
/RA/
Timothy J. McGinty, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contacts: Stuart Sheldon, Region III Heather Jones, NRR
630-829-9727 301-415-4054 email: Stuart.Sheldon@nrc.gov email: Heather.Jones@nrc.gov
Note: You can find NRC generic communications on the NRCs public Web site, http://www.nrc.gov, under Electronic Reading Room/Document Collections.
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