ML003691666
| ML003691666 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 03/10/2000 |
| From: | Charemagne Grimes NRC/NRR/DRIP/RLSB |
| To: | Walters D Nuclear Energy Institute |
| References | |
| Download: ML003691666 (11) | |
Text
March 10, 2000 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
LICENSE RENEWAL ISSUE NO. 98-12, CONSUMABLES
Dear Mr. Walters:
is the staffs proposed resolution of the subject issue. Based on the December 8, 1999, meeting, as documented in the January 21, 2000, meeting summary (Enclosure 2), the staff concluded that the enclosed changes should be made to the draft Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants. It is expected that comparable changes will be made to NEI 95-10, Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule.
If there are any industry comments on the proposed resolution, we request that you document those comments within 30 days following your receipt of this letter to ensure a timely resolution of this issue. If you have any questions regarding this matter, please contact Stephen Koenick at 301-415-1239.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project 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:
LICENSE RENEWAL ISSUE NO. 98-12, CONSUMABLES
Dear Mr. Walters:
is the staffs proposed resolution of the subject issue. Based on the December 8, 1999, meeting, as documented in the January 21, 2000, meeting summary (Enclosure 2), the staff concluded that the enclosed changes should be made to the draft Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants. It is expected that comparable changes will be made to NEI 95-10, Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule.
If there are any industry comments on the proposed resolution, we request that you document those comments within 30 days following your receipt of this letter to ensure a timely resolution of this issue. If you have any questions regarding this matter, please contact Stephen Koenick at 301-415-1239.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project 690
Enclosures:
As stated cc w/encl: See next page Distribution: See next page DOCUMENT NAME:C:\\consumables follow ltr to n~.wpd OFFICE LA RLSB RLSB:SC NAME EHylton*
SKoenick*
PTKuo*
DATE 02/ 11 /00 02/ 11 /00 02/ 11 /00 OFFICE DE/EMEB DSSA/SPLB RLSB/DRIP NAME EImbro*
JHannon*
CGrimes DATE 02/15 /00 02/ 16 /00 03/10 /00
- See previous concurrence OFFICIAL RECORD COPY
Proposed Changes to the SRP Based on the discussion provided in the Summary of December 8, 1999, Meeting on License Renewal Issue (LR) 98-12, Consumables, dated January 21, 2000, the following should be added to Table 2.2-2, Typical Structures, Components, and Commodity Groups, and 10 CFR 54.21(a)(1)(i) Determinations for Integrated Plant Assessment, of the draft Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants.
ITEM CATEGORY STRUCTURE, COMPONENT, OR COMMODITY GROUP STRUCTURE, COMPONENT, OR COMMODITY GROUP MEETS 10 CFR 54.21(a)(1)(i)
(YES/NO)
Subcomponent Packing, Gaskets, Components Seals, and O-rings Yes1 Subcomponent Structural Sealants Yes2 Consumable Oil, Grease, and Component Filters No3 Consumable System Filters, Fire Extinguishers, Fire Hoses, and Air Packs Yes4 1
These subcomponents would not necessarily be called out explicitly in the scoping and screening procedures. Instead they would be implicitly addressed at the component level. The applicant will be able to exclude these subcomponents utilizing a clear basis such as the example of ASME Section III not being relied upon for pressure boundary.
2 These subcomponents would not necessarily be called out explicitly in the scoping and screening procedures. Instead they would be implicitly addressed at the component level. Structural sealants may perform functions without moving parts or change in configuration and they are not typically replaced. It is expected that the applicants structural aging management program will address these items with respect to an aging management review program on a plant specific basis.
3 For these commodities, the screening process would be expected to exclude these materials because they are short-lived and are periodically replaced.
4 These components may be excluded, on a plant-specific basis, from an aging management review under 10 CFR 54.21(a)(1)(ii) in that they are replaced on condition. The application should identify the standards that are relied on for replacement as part of the methodology description, for example, NFPA standards for fire protection equipment.
January 21, 2000
ORGANIZATION Nuclear Energy Institute (NEI)
SUBJECT:
SUMMARY
OF DECEMBER 8, 1999, MEETING ON LICENSE RENEWAL ISSUE (LR) 98-12, CONSUMABLES The Nuclear Regulatory Commission (NRC) met with the NEI on December 8, 1999, to discuss LR 98-12, Consumables. The agenda for the meeting is provided in Attachment 1. Attendees are listed in Attachment 2.
Background
As part of an effort to more efficiently resolve generic issues involved with license renewal, the NRC staff is in the process of implementing a informal process for resolving generic issues.
This process will be outlined in NRR Office Letter No. 805, License Renewal Application Review Process. To resolve the generic issues in which there is disagreement between stakeholders and NRC, the NRC is implementing an appeals process in which stakeholders and NRC staff have successive management meetings in order to identify resolution paths for the issues. The meeting on December 8, 1999, was a trial appeals meeting. The NRC issued a staff position on consumables in a letter dated April 21, 1999. In a letter from D. Walters of NEI to C. Grimes of NRC dated July 30, 1999, NEI articulated several disagreements with the NRC staff position.
Discussion The meeting provided useful dialogue with consensus being reached in numerous areas. The result of the meeting is captured in this meeting summary. The outcome of this process is for the NRC staff to develop proposed guidance that will be incorporated into the working draft, Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants (SRP). It would be expected that NEI would revise their industry document NEI 95-10, Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, accordingly. In order to ensure proper characterization of the dialogue between the stakeholders and staff, this meeting summary will be followed with a letter to interested stakeholder containing proposed guidance soliciting feedback. The meeting summary according to the agenda of the topics discussed at the meeting is as follows:
2 1.
The need to categorize consumables as components, piece parts, or subcomponents.
LR 98-12, Consumables, represented an attempt to categorize various components, subcomponents, piece parts and other materials that are typically replaced during routine maintenance and testing, or based on component performance. The NRC staff position divided the consumables into four categories. There was agreement that the four categories represented different types of material that need to be addressed differently for the purpose of license renewal. Category A, comprises packing, gaskets, component seals, and o-rings, represent subcomponents and specific guidance is addressed below in item 3.a. Category B, comprises structural sealants, represent subcomponents that are treated differently from Category A in that they are long-lived components and may serve a passive function. Specific guidance is addressed in item 3.b. Category C, comprises oil, grease, and component filters, represent consumables that are short-lived. Specific guidance is provided in item 3.c.
Category D, comprises of system filters, fire extinguishers, fire hoses, and air packs, represent components that are routinely replaced on condition. Specific guidance is provided in item 3.d.
With respect to the need to categorize consumables there was a general consensus to not exclusively categorize consumables as components, piece parts, or subcomponents. However, from a process consideration the following was discussed.
The consumable would not be explicitly called out in the scoping and screening procedures.
Instead it would be implicitly included at the component level, (i.e., if a valve is identified as being in scope, a seal would be in scope as a subcomponent of the valve). The consumable will be considered during the aging management review. The methodology for performing the aging management review of the various subcomponents is a procedure that is maintained onsite and is auditable. It is in this procedure, in which the applicant can provide justification for excluding the specific consumable from scope.
2.
Reliance on performance or condition monitoring for generic exclusion.
There was mutual agreement between NRC and NEI that performance or condition monitoring cannot be used for generic exclusions, but this does not prevent it from being used for a site-specific justification.
3.
Component Replacement Strategy or Aging Management Program a.
Packing, Gaskets, Components Seals, and O-rings For the purpose of addressing packing, gaskets, components seals, and o-rings during the review of a license renewal application, the reviewer should consider these items as subcomponents. These subcomponents would not be explicitly called out in the scoping and screening procedures. Instead they would be implicitly included at the component level, (i.e., if a valve is identified as being in scope, a seal would be in scope as a subcomponent of the valve). They will be considered during the aging management review. The methodology for performing the aging management review of the various subcomponents is a procedure that is maintained onsite and is auditable. For this category of consumables consistent with the staff position, the applicant will be able to exclude these components utilizing a clear basis such as the example identified in the NRC staff position of ASME Section III not being relied upon for pressure boundary.
3 This process of addressing this category of consumables during the aging management review should be summarized in the application during the methodology for conducting the aging management review.
b.
Structural sealants For the purpose of addressing structural sealants during the review of a license renewal application, the reviewer should consider these items as subcomponents. These subcomponents would not be explicitly called out in the scoping and screening procedures.
Instead they would be implicitly included at the component level. They will be considered during the aging management review. The methodology for performing the aging management review of the various subcomponents is a procedure that is maintained onsite and is auditable. For this category of consumables consistent with the staff position, structural sealants may perform functions without moving parts or change in configuration and they are not typically replaced on condition. It is expected that the applicants structural aging management program will address these items with respect to an aging management review program on a plant specific basis.
This process of addressing this category of consumables during the aging management review should be summarized in the application during the methodology for conducting the aging management review.
c.
Oil, Grease, and Component Filters For the purpose of addressing oil, grease, and component filters during the review of a license renewal application, the reviewer should consider these other materials as consumables that are short-lived. For this category of consumables consistent with the staff position, this material can be excluded on the basis of being short-lived and periodically replaced.
This process of addressing this category of consumables during the aging management review should be summarized in the application during the methodology for conducting the aging management review.
d.
System Filters, Fire Extinguishers, Fire Hoses, and Air Packs For the purpose of addressing system filters, fire extinguishers, fire hoses, and air packs during the review of a license renewal application, the reviewer should consider these items as components. For this category of consumables consistent with the staff position, these components may be excluded, on a plant-specific basis, from an aging management review under 10 CFR 54.21(a)(1)(ii) in that they are replaced on condition.
This process of addressing this category of consumables during the aging management review should be summarized in the application during the methodology for conducting the aging management review.
4 Conclusion The proposed staff guidance will be developed based on the discussion above. This guidance will be incorporated into the SRP as it is revised. In accordance with the appeals process being developed, the interested stakeholders will have the opportunity to provide feedback to the proposed guidance. If notified, the specific disagreement with accompanying basis would be elevated to the next level of management. Without comment, the proposed guidance based on this meeting summary will represent resolution and closure of LR 98-12, Consumables.
/RA/
Stephen S. Koenick, Project Manager License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690 Attachments: As stated cc w/atts: See next page
Agenda for December 8, 1999, meeting on License Renewal Issue No. 98-12 (LR 98-12), Consumables 1.
The need to categorize consumables as components, piece parts, or subcomponents.
2.
Reliance on performance or condition monitoring for generic exclusion.
U.S. Nuclear Regulatory Commission, Nuclear Power Plant License Renewal; Revisions, Federal Register, Vol. 60, No. 88, Monday May 8, 1995, page 22478.
It is important to note, however, that the Commission has decided not to generically exclude passive structures and components that are replaced based on performance or condition from an aging management review. Absent the specific nature of the performance or condition replacement criteria and the fact that the Commission has determined that components with passive functions are not as readily monitorable as components with active functions, such generic exclusions is not appropriate. However, the Commission does not intend to preclude a license renewal applicant from providing site-specific justification in a license renewal application that a replacement program on the basis of performance or condition for a passive structure or component provides reasonable assurance that the intended function of the passive structure or component will be maintained in the period of extended operation.
3.
Component Replacement Strategy or Aging Management Program a.
Packing, Gaskets, Components Seals, and O-rings b.
Structural sealants c.
Oil, Grease, and Component Filters d.
System Filters, Fire Extinguishers, Fire Hoses, and Air Packs
ATTENDANCE LIST MEETING ON LICENSE RENEWAL ISSUE NO. 98-12 (LR 98-12), CONSUMABLES DECEMBER 8, 1999 NAME ORGANIZATION BOB PRATO NRC/NRR/DRIP/RLSB JANICE MOORE NRC/OGC P.T. KUO NRC/NRR/DRIP/RLSB CHRIS GRIMES NRC/NRR/DRIP/RLSB GOUTAM BAGCHI NRR/DE BILL CORBIN VIRGINIA POWER FRED POLASKI PECO-ENERGY BERNIE VAN SANT OMAHA PUBLIC POWER JOHN RYCYNA CONSTELLATION NUCLEAR SERVICES DOUG WALTERS NEI STEVE HALE FPL STEPHEN KOENICK NRC/NRR/DRIP.RLSB JAKE ZIMMERMAN NRC/NRR/DRIP/RLSB STEVE HOFFMAN NRC/NRR/DRIP/RLSB LYNN CONNOR DSA KAMAL MANOLY NRC/NRR/DE/EMEB HANS ASHAR NRC/NRR/DE/EMEB WILLIAM BURTON NRC/NRR/DRIP/RLSB MELVIN FRANK SCIENTECH/NUSIS MICHAEL SEMMLER DUKE ENERGY HAI-BAH WANG NRC/NRR/DRIP/RLSB NANCY CHAPMAN SERCH/BECHTEL JIT VORA NRC/RES/DET/MEB
NUCLEAR ENERGY INSTITUTE 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., Suite 400 Washington, DC 20006-3708 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. 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