ML003680254
| ML003680254 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/2000 |
| From: | Charemagne Grimes NRC/NRR/DRIP/RLSB |
| To: | Walters D Nuclear Energy Institute |
| Lee S | |
| References | |
| Download: ML003680254 (18) | |
Text
February 3, 2000 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
GENERIC AGING LESSONS LEARNED (GALL) REPORT AND STANDARD REVIEW PLAN FOR LICENSE RENEWAL (SRP-LR)
Dear Mr. Walters:
We held a public workshop on December 6, 1999, to discuss the development of the Generic Aging Lessons Learned (GALL) report and the Standard Review Plan for License Renewal (SRP-LR). As described in SECY 99-148, Credit for Existing Programs for License Renewal, the staff plans on referencing the GALL report in the SRP-LR as a basis for determining the adequacy of existing programs.
The staff intends to treat the GALL report as a topical report with generic applicability to all plants. We have drafted guidance on the treatment of the GALL report, including an example on a license renewal application and the corresponding staff safety evaluation report. (See ) We have also drafted the corresponding SRP-LR section as an example. (See ) We plan on using Enclosure 2 as a guide to develop the aging management review sections of the SRP-LR. Please note that Enclosure 2 references a Branch Technical Position (BTP) on aging management review. This BTP is intended to be the staff guidance for program acceptance using the 10 program elements contained in Section 3.0 of the draft SRP-LR, dated September 1997.
As discussed in the public workshop on December 6, 1999, the staff is releasing early drafts of license renewal implementation guidance documents to invite stakeholders participation.
Accordingly, we are providing these enclosures for your information and comment. We also would be willing to meet with industry representatives to discuss any comments you may have.
If you have any questions regarding this matter, please contact Sam Lee at (301)415-3109.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690
Enclosures:
As stated cc w/encl: See next page
Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
GENERIC AGING LESSONS LEARNED (GALL) REPORT AND STANDARD REVIEW PLAN FOR LICENSE RENEWAL (SRP-LR)
Dear Mr. Walters:
We held a public workshop on December 6, 1999, to discuss the development of the Generic Aging Lessons Learned (GALL) report and the Standard Review Plan for License Renewal (SRP-LR). As described in SECY 99-148, Credit for Existing Programs for License Renewal, the staff plans on referencing the GALL report in the SRP-LR as a basis for determining the adequacy of existing programs.
The staff intends to treat the GALL report as a topical report with generic applicability to all plants. We have drafted guidance on the treatment of the GALL report, including an example on a license renewal application and the corresponding staff safety evaluation report. (See ) We have also drafted the corresponding SRP-LR section as an example. (See ) We plan on using Enclosure 2 as a guide to develop the aging management review sections of the SRP-LR. Please note that Enclosure 2 references a Branch Technical Position (BTP) on aging management review. This BTP is intended to be the staff guidance for program acceptance using the 10 program elements contained in Section 3.0 of the draft SRP-LR, dated September 1997.
As discussed in the public workshop on December 6, 1999, the staff is releasing early drafts of license renewal implementation guidance documents to invite stakeholders participation.
Accordingly, we are providing these enclosures for your information and comment. We also would be willing to meet with industry representatives to discuss any comments you may have.
If you have any questions regarding this matter, please contact Sam Lee at (301)415-3109.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690
Enclosures:
As stated cc w/encl: See next page Document Name: C:\\GALL_SRP.wpd OFFICE LA RLSB RLSB:SC RLSB:BC NAME EHylton SLee PTKuo CGrimes DATE 02/02/00 02/02/00 02/02/00 02/03/00 OFFICIAL RECORD COPY
2/3/00 TREATMENT OF THE GALL REPORT APPROACH The Generic Aging Lessons Learned (GALL) report should be treated in the same manner as an approved topical report. The staff should not repeat its review of the matters described in the GALL report and should find it acceptable when the GALL report is referenced in a license renewal application. However, the staff should ensure that the material presented in the GALL report is applicable to the specific plant involved. The staff should also verify that the applicant has identified specific programs as described and evaluated in the GALL report.
Information in the License Renewal Application In Chapter 2 of the application, the applicant would identify structures and components subject to aging management review for license renewal. Scoping is not affected by the presence of the GALL report. (Note: Chapter 1 of the application contains administrative information.)
In Chapter 3 of the application, the applicant would provide the aging management review of the structures and components identified in Chapter 2. The applicant would reference the GALL report as appropriate. The applicant would briefly describe the system, components, materials, and environment, and state that they are bounded by the GALL report. The applicant would also state that the applicable aging effects and industry and plant-specific operating experience have been reviewed, and are bounded by the GALL report. Any outliers would be discussed in the application. Then, the applicant would state that certain aging management programs and the staff evaluation, as described in the GALL report, are applicable to their plant. The applicant would list those components, applicable aging effects, and aging management programs in a table. If the GALL report indicates that some of these aging management programs should be further evaluated, the applicant would provide the plant-specific proposal to augment these programs. For aging management programs and/or staff evaluation in the GALL report that do not apply or are otherwise different for their plant, the applicant would provide a plant-specific aging management review. Also, for components and/or applicable aging effects that are not addressed in the GALL report, the applicant would provide the plant-specific aging management review.
In Chapter 4 of the application, the applicant would provide the time-limited aging analysis (TLAA) evaluation. Similar to aging management review in Chapter 3, the applicant would reference the GALL report as appropriate. For TLAAs that have been evaluated in the GALL report, the applicant would state that certain TLAAs and staff evaluation, as described in the GALL report, are applicable to their plant. If the GALL report indicates that further evaluation should be performed, the applicant would provide that additional information in the application.
For TLAAs that have not been evaluated in the GALL report or if the TLAA evaluation in the GALL report does not apply to the plant, the applicant would provide the plant-specific evaluation.
2 2/3/00 A summary description of all aging management programs and TLAA evaluations would be provided in the final safety analysis report (FSAR) supplement.
Staff Review Guidance The staff should not repeat its review of the matters described in the GALL report. The staff should ensure that the material presented in the GALL report is applicable to the specific plant involved. For a particular system, the standard review plan for license renewal (SRP) should contain a summary table listing all the components, aging effects, and aging management programs, indicating whether the program is acceptable without change or should be further evaluated, as described in the GALL report. The staff would verify that the applicant has identified the appropriate programs as described and evaluated in the GALL report. The focus of the staff review would be on augmented programs for license renewal. The staff would also review information that is not addressed in the GALL report or is otherwise different from that in the GALL report. In addition, the staff would review the FSAR supplement based on the SRP.
3 2/3/00 EXAMPLE Containment Spray System (part of the Engineered Safety Features). Note: This example is for illustration only.
This example shows information in the license renewal application and the corresponding staff safety evaluation report.
4 2/3/00 Example: License Renewal Application 3.3 Engineered Safety Features The Engineered Safety Features at Plant X evaluated in this application consist of:....,
Containment Spray System,....
The Containment Spray System provides borated water to reduce the temperature inside containment in accident conditions, as described in FSAR Section Y. The system consists of stainless steel and carbon steel components, such as piping, valves, pumps, and bolting, orifice, spray heads (see Table 2.Z in this application). The internal environment is borated water and the external environment is containment air. A review of the industry experience shows that stagnant portions of the containment spray stainless steel piping have experience cracking. However, this aging effect has not been observed at Plant X.
Based on a review of the system, components, materials, environment, applicable aging effects, and operating experience, the information in the GALL report (Chapter V of Reference
- 1) regarding the Engineered Safety Features bounds Plant X. However, carbon steel piping and isolation valve in the Containment Spray System are not addressed in the GALL report and are evaluated in Sections 3.3.4.1 and 3.3.4.2 of this application.
3.3.1 Aging Management Programs Evaluated in the GALL Report that Are Relied on for License Renewal The following aging management programs and the staff evaluation for the Engineered Safety Features, as described in the GALL report, are applicable to Plant X:
GALL Item No.
Aging Effect or Mechanism Aging Management Program GALL Recommendation V.A.1.1 thru 1.3,....
Pitting and crevice corrosion Inservice inspection and water chemistry Further evaluation is recommended (see Section 3.3.2.1 of this application)
V.A.1.4,....
Corrosion/ boric acid wastage of external surfaces NRC Generic Letter 88-05 and inservice inspection No further evaluation is recommended 3.3.2 Further Evaluation of Aging Management as Recommended by the GALL Report 3.3.2.1 Detection of Pitting and Crevice Corrosion
5 2/3/00 The GALL report indicates that a one-time inspection of representative sample of the system population and most susceptible locations in the Containment Spray System should be conducted to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended periods.... For license renewal, Plant X is proposing....
3.3.3 Aging Management Programs or Evaluations that Are Different from those Described in the GALL Report 3.3.3.1 Aging Management Review of Stress Corrosion Cracking of Stainless Steel Piping and Fittings The aging management program for stress corrosion cracking of stainless steel piping and fittings up to the isolation valve of the Containment Spray System (Item No. V.A.1.1 of the GALL report) at Plant X is different from that evaluated in the GALL report. Plant X....
3.3.4 Components or Aging Effects that Are Not Addressed in the GALL Report 3.3.4.1 Aging Management Review of Carbon Steel Piping Plant X....
3.3.4.2 Aging Management Review of Isolation Valve Body Plant X....
3.3.5 FSAR Supplement The proposed FSAR Supplement for the Engineered Safety Features is as follows:
Program Description of Program Implementation Schedule Water chemistry program To mitigate aging effects on internal surfaces that are exposed to borated water as process fluid, chemistry programs are used to control primary water chemistry for impurities (chloride, fluoride, and sulfate) that accelerate corrosion.
Existing program One-time inspection of Containment Spray System To verify the effectiveness of the chemistry program and to supplement the limited scope of leakage monitoring program, one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion....
Program will be implemented by....
6 2/3/00 Implementation of NRC Generic Letter 88-05 The program consists of: (1) visual inspection of external surfaces that are potentially exposed to borated water for leaks, (2) timely discovery of leak path and removal of the boric acid residues, (3) assessment of the damage, and (4) follow up inspection for adequacy.
Existing program Inservice inspection in accordance with ASME Section XI, as required in 10 CFR 50.55(a)
The program consists of periodic visual inspection of external surfaces for signs of significant degradation and assessment of the damage and corrective actions.
Existing program
7 2/3/00 Example: Staff Safety Evaluation Report 3.3 Engineered Safety Features 3.3.3 Staff Evaluation In Section 3.3 of the application, the applicant provided an aging management review of the Engineered Safety Features at Plant X. The applicant referenced the GALL report in its aging management review. The staff has previously evaluated the adequacy of aging management for license renewal as documented in the GALL report. Thus, the staff did not repeat its review of the matters described in the GALL report, except to ensure that the material presented is applicable to the specific plant involved and to verify that the applicant has identified the appropriate programs as described and evaluated in the GALL report. The staff further evaluated certain aging management programs as recommended in the GALL report. The staff also reviewed aging management information provided by the applicant that is different from that in the GALL report or not addressed in the GALL report.
3.3.3.1 Aging Management Programs Evaluated in the GALL Report that Are Relied on for License Renewal The staff has reviewed the application and determined that the applicant has provided the information necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. The applicant has identified those aging effects for the Engineered Safety Features components that are contained in the GALL report as applicable to its plant. The applicant has identified the programs in the GALL report for the aging management of these components, and they are:
GALL Item No.
Aging Effect or Mechanism Aging Management Program GALL Recommendation V.A.1.1 thru 1.3,....
Pitting and crevice corrosion Inservice inspection and water chemistry Further evaluation is recommended (see Section 3.3.3.2.1 of this safety evaluation)
V.A.1.4,....
Corrosion/ boric acid wastage of external surfaces NRC Generic Letter 88-05 and inservice inspection No further evaluation is recommended The staff has verified that the applicant has identified the appropriate programs as described and evaluated in the GALL report. Thus, it is acceptable for the applicant to reference the information in the GALL report and no further staff evaluation is necessary if so recommended in the GALL report.
8 2/3/00 3.3.3.2 Further Evaluation of Aging Management as Recommended by the GALL Report 3.3.3.3 Aging Management Programs or Evaluations that Are Different from those Described in the GALL Report 3.3.3.4 Components or Aging Effects that Are Not Addressed in the GALL Report 3.3.3.5 FSAR Supplement The staff reviewed the proposed FSAR supplement for the Engineered Safety Features....
3.3.4 Conclusions The staff has reviewed the information in Section 3.3, Engineered Safety Features, of the license renewal application. The staff evaluation concludes that the applicant has demonstrated that the aging effects associated with the Engineered Safety Features will be adequately managed so that there is reasonable assurance that these systems will perform their intended functions in accordance with the current licensing basis during the period of extended operation. The staff also concludes that the FSAR supplement contains an appropriate summary description of the programs and activities for managing the effects of aging for the Engineered Safety Features.
2/3/00 3.3 Aging Management of Engineered Safety Features REVIEW RESPONSIBILITIES PRIMARY-Branch responsible for materials and chemical engineering SECONDARY-Branch responsible for mechanical engineering I.
AREAS OF REVIEW This review plan section addresses the aging management review of the Engineered Safety Features for license renewal. For a recent vintage plant, the information related to the Engineered Safety Features is contained in Chapter 6, Engineered Safety Features, of the plants Final Safety Analysis Report (FSAR) consistent with the Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants (NUREG-0800). Engineered Safety Features consist of systems, such as Emergency Core Cooling System, Containment Heat Removal Systems, Containment Spray, and Control Room Habitability Systems.
The staff has issued a Generic Aging Lessons Learned (GALL) report addressing aging management for license renewal (Reference 1). The GALL report documents generically the staffs basis for determining when existing programs are adequate to manage aging without change and when existing programs should be augmented for license renewal. The GALL report may be referenced in a license renewal application and should be treated in the same manner as an approved topical report.
Because a license renewal applicant may or may not be able to reference the GALL report, the following areas are reviewed:
A.
Aging Management Programs Evaluated in the GALL Report that Are Relied on for License Renewal The staff should not repeat its review of the matters described in the GALL report and should find it acceptable when the GALL report is referenced in a license renewal application. However, the staff should ensure that the material presented in the GALL report is applicable to the specific plant involved. The staff should also verify that the applicant has identified specific programs as described and evaluated in the GALL report.
B.
Further Evaluation of Aging Management as Recommended by the GALL Report The GALL report provides the basis for identifying those programs that warrant further evaluation during the staff review of a license renewal application. The staff review focus should be on augmented programs for license renewal.
2 2/3/00 C.
Aging Management Programs or Evaluations that Are Different from those Described in the GALL Report The GALL report provides a generic staff evaluation of certain aging management programs. If an applicant does not rely on a particular program for license renewal, or if the applicant indicates that the generic staff evaluation of the elements of a particular program does not apply to its plant, the staff should review the applicants aging management programs.
D.
Components or Aging Effects that Are Not Addressed in the GALL Report The GALL report provides a generic staff evaluation of certain components and aging effects. If an applicant has identified particular components subject to aging management review for its plant, or if the applicant has identified particular aging effects for a component, that are not addressed in the GALL report, the staff should review the applicants aging management programs.
E.
FSAR Supplement The FSAR supplement summarizing the programs and activities for managing the effects of aging for the period of extended operation is reviewed.
II.
ACCEPTANCE CRITERIA The acceptance criteria for the areas of review define methods for meeting the requirements of the Commissions regulations in 10 CFR 54.21.
A.
Aging Management Programs Evaluated in the GALL Report that Are Relied on for License Renewal Acceptable methods for managing aging of the Engineered Safety Features are described and evaluated in Chapter V of the GALL report (Reference 1). In referencing the GALL report, an applicant should indicate that the material presented in the GALL report is applicable to the specific plant involved and provide the information necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. An applicant may reference appropriate programs as described and evaluated in the GALL report.
B.
Further Evaluation of Aging Management as Recommended by the GALL Report The GALL report indicates that further evaluation should be performed for:
1.
Detection of Pitting and Crevice Corrosion The management of corrosion of pressure boundary components in the Containment Spray System. A one-time inspection is an acceptable method to verify the effectiveness of the mitigation and monitoring programs.
3 2/3/00 2.
C.
Aging Management Programs or Evaluations that Are Different from those Described in the GALL Report Acceptance criteria are described in Branch Technical Position 3.0-1.
D.
Components or Aging Effects that Are Not Addressed in the GALL Report Acceptance criteria are described in Branch Technical Position 3.0-1.
E.
FSAR Supplement The summary description of the programs and activities for managing the effects of aging for the period of extended operation in the FSAR supplement should provide appropriate description such that later changes can be controlled by 10 CFR 50.59. The description should contain information associated with the integrated plant assessment regarding the bases for determining that aging effects are managed in the period of extended operation.
III.
REVIEW PROCEDURES For each area of review, the following review procedures are to be followed:
A.
Aging Management Programs Evaluated in the GALL Report that Are Relied on for License Renewal An applicant may reference the GALL report in its license renewal application, as appropriate. The staff should not repeat its review of the matters described in the GALL report. The staff should find it acceptable when the GALL report is referenced in a license renewal application, if the applicant has provided the information necessary to adopt the finding of program acceptability as described and evaluated in the GALL report. The reviewer verifies that the applicant has provided a brief description of the system, components, materials, and environment, and has stated that the particular plant is bounded by the GALL report. The reviewer also verifies that the applicant has stated that the applicable aging effects and industry and plant-specific operating experience had been reviewed by the applicant and are bounded by the GALL report. The reviewer verifies that the applicant has identified those aging effects for the Engineered Safety Features components that are contained in the GALL report as applicable to its plant. The reviewer reviews any outliers identified by the applicant.
The applicant may state that certain aging management programs and the staff evaluation, as described in the GALL report, are applicable to its plant. The reviewer verifies that the applicant has identified the appropriate programs as described and evaluated in the GALL report. Programs evaluated in the GALL report regarding the Engineered Safety Features are tabulated in Table 3.3-1 of this review plan section. No further staff evaluation is necessary if so recommended in the GALL report.
4 2/3/00 B.
Further Evaluation of Aging Management as Recommended by the GALL Report 1.
Detection of Pitting and Crevice Corrosion The reviewer reviews the applicants augmented program to manage corrosion of pressure boundary components in the Containment Spray System. Aging management programs for the Containment Spray System include the chemistry program and the leakage monitoring program. However, the GALL report recommends further evaluation to verify the effectiveness of the chemistry program and to supplement the limited scope of the leakage monitoring program. An acceptable method is a one-time inspection as recommended in the GALL report. The reviewer reviews the applicants proposed program. The program should consist of a one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion....
2.
C.
Aging Management Programs or Evaluations that Are Different from those Described in the GALL Report Review procedures are described in Branch Technical Position RLSB 3.0-1.
D.
Components or Aging Effects that Are Not Addressed in the GALL Report Review procedures are described in Branch Technical Position RLSB 3.0-1.
E.
FSAR Supplement The reviewer verifies that the applicants FSAR supplement for aging management of the Engineered Safety Features for license renewal is consistent with Table 3.3-2 of this review plan section. The reviewer also verifies that the applicant has provided FSAR supplement for Subsection III.C, Aging Management Programs or Evaluations that are Different from those Described in the GALL Report, and Subsection III.D, Components or Aging Effects that are Not Addressed in the GALL Report, of this review plan section using a format similar to that in Table 3.3-2.
5 2/3/00 IV.
EVALUATION FINDINGS The reviewer verifies that sufficient and adequate information has been provided to satisfy the provisions of this review plan section and the staffs evaluation supports conclusions of the following type, to be included in the staffs safety evaluation report:
The staff evaluation concludes that the applicant has demonstrated that the aging effects associated with the Engineered Safety Features will be adequately managed so that there is reasonable assurance that these systems will perform their intended functions in accordance with the current licensing basis during the period of extended operation. The staff also concludes that the FSAR supplement contains an appropriate summary description of the programs and activities for managing the effects of aging for the Engineered Safety Features.
V.
IMPLEMENTATION Except in those cases in which the applicant proposes an acceptable alternative method for complying with specified portions of the Commissions regulations, the method described herein will be used by the staff in its evaluation of conformance with Commission regulations.
VI.
REFERENCES 1.
NUREG-??, Generic Aging Lessons Learned (GALL) Report,....
6 2/3/00 TABLE 3.3-1: Aging Management Programs Evaluated in the GALL Report for Engineered Safety Features GALL Item No.
Aging Effect or Mechanism Aging Management Program GALL Recommendation V.A.1.1 thru 1.3,....
Pitting and crevice corrosion Inservice inspection and water chemistry Further evaluation is recommended (see III.B.1 of this review plan section)
V.A.1.4,....
Corrosion/ boric acid wastage of external surfaces NRC Generic Letter 88-05 and inservice inspection No further evaluation is recommended
TABLE 3.3-2: FSAR Supplement for Aging Management of Engineered Safety Features Program Description of Program Implementation Schedule Water chemistry program To mitigate aging effects on internal surfaces that are exposed to borated water as process fluid, chemistry programs are used to control primary water chemistry for impurities (chloride, fluoride, and sulfate) that accelerate corrosion.
Existing program One-time inspection of Containment Spray System To verify the effectiveness of the chemistry program and to supplement the limited scope of leakage monitoring program, one-time inspection of internal surfaces of components (using visual inspection) at the most susceptible locations is performed to ensure that degradation is not occurring as a result of corrosion....
Program will be implemented by....
Implementation of NRC Generic Letter 88-05 The program consists of: (1) visual inspection of external surfaces that are potentially exposed to borated water for leaks, (2) timely discovery of leak path and removal of the boric acid residues, (3) assessment of the damage, and (4) follow up inspection for adequacy.
Existing program Inservice inspection in accordance with ASME Section XI, as required in 10 CFR 50.55(a)
The program consists of periodic visual inspection of external surfaces for signs of significant degradation and assessment of the damage and corrective actions.
Existing program
NUCLEAR ENERGY INSTITUTE (License Renewal Steering Committee)
Project No. 690 cc:
Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, D.C. 20585 Mr. Ricard P. Sedano, Commissioner State Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, N.W.
Washington, DC 20006 DJW@NEI.ORG National Whistleblower Center 3233 P Street, N.W.
Washington, DC 20007 Mr. Garry Young Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 GSB-2E Russellville, Arkansas 72802 Mr. James P. Riccio Public Citizens Critical Mass Energy Project 211 Pennsylvania Avenue, SE Washington, DC 20003 Mr. Robert Gill Duke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006 Mr. Charles R. Pierce Southern Nuclear Operating Co.
40 Inverness Center Parkway BIN B064 Birmingham, AL 35242 Carl J. Yoder Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway NEF 1st Floor Lusby, Maryland 20657 Chattooga River Watershed Coalition P. O. Box 2006 Clayton, GA 30525 Mr. David Lochbaum Union of Concerned Scientists 1616 P. St., NW Suite 310 Washington, DC 20036-1495 Mr. Paul Gunter Director of the Reactor Watchdog Project Nuclear Information & Resource Service 1424 16th Street, NW, Suite 404 Washington, DC 20036