ML022060290
| ML022060290 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 07/24/2002 |
| From: | Kuo P NRC/NRR/DRIP/RLEP |
| To: | Alexis Nelson Nuclear Energy Institute |
| Kang P, NRR/DRIP/RLEP, 415-2279 | |
| References | |
| NEI 95-10 Rev 3 | |
| Download: ML022060290 (8) | |
Text
July 24, 2002 Mr. Alan Nelson Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
OBSERVATIONS FROM THE NUCLEAR ENERGY INSTITUTE (NEI) LICENSE RENEWAL DEMONSTRATION PROJECT AND COMMENTS FROM AN ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) LETTER THAT MAY RESULT IN CHANGES TO NEI 95-10, REVISION 3.
Dear Mr. Nelson:
Enclosed is the staffs compilation of observations from the NEI license renewal demonstration project and comments from an ACRS letter dated April 13, 2001, that may result in changes to NEI 95-10, Revision 3. Please consider incorporating those lessons learned (i.e., observations and comments) into NEI 95-10, Revision 3, where applicable. This is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry, as outlined in NRR Office Letter No. 805, License Renewal Application Review Process.
The staff plans to revise the improved renewal guidance documents, that include Regulatory Guide 1.188 that endorses NEI 95-10, Revision 3, in a future update. The staff requests that you submit a schedule for consideration of incorporating the enclosed lessons learned into NEI 95-10, Revision 3 to ensure a timely completion of the regulatory guide.
If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.
Sincerely,
/RA/
Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project 690
Enclosure:
As stated cc w/encl: See next page
Mr. Alan Nelson Nuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
OBSERVATIONS FROM THE NUCLEAR ENERGY INSTITUTE (NEI) LICENSE RENEWAL DEMONSTRATION PROJECT AND COMMENTS FROM AN ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) LETTER THAT MAY RESULT IN CHANGES TO NEI 95-10, REVISION 3.
Dear Mr. Nelson:
Enclosed is the staffs compilation of observations from the NEI license renewal demonstration project and comments from an ACRS letter dated April 13, 2001, that may result in changes to NEI 95-10, Revision 3. Please consider incorporating those lessons learned (i.e., observations and comments) into NEI 95-10, Revision 3, where applicable. This is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry, as outlined in NRR Office Letter No. 805, License Renewal Application Review Process.
The staff plans to revise the improved renewal guidance documents, that include Regulatory Guide 1.188 that endorses NEI 95-10, Revision 3, in a future update. The staff requests that you submit a schedule for consideration of incorporating the enclosed lessons learned into NEI 95-10, Revision 3 to ensure a timely completion of the regulatory guide.
If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.
Sincerely,
/RA/
Pao-Tsin Kuo, Program Director License Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project 690
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION: See next page Document Name:C:\\ORPCheckout\\FileNET\\ML022060290.wpd OFFICE RLEP LA SC:RLEP PD:RLEP NAME PKang EHylton SLee PTKuo DATE 7/3/02 7/3/02 7/3/02 7/24/02 OFFICIAL RECORD COPY
DISTRIBUTION: Letter to Alan Nelson, Dated: July 24, 2002 HARD COPY RLEP RF E. Hylton E-MAIL:
PUBLIC J. Johnson W. Borchardt D. Matthews F. Gillespie RidsNrrDe R. Barrett E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski H. Nieh G. Holahan H. Walker S. Black B. Boger D. Thatcher G. Galletti C. Li J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis T. Kobetz RLEP Staff A. Thadani C. Julian R. Gardner M. Farber M. Modes J. Vora
Observations and Comments for Consideration in Revising NEI 95-10, Rev 3 1.
In a letter dated April 13, 2001, the ACRS commented that the staff should encourage applicants to include the results of the scoping process in their applications (ADAMS accession No. ML011080765). SECY-01-0157 dated August 17, 2001, also stated that the staff will continue to work with industry to revise the guidance documents to further clarify that scoping results should be provided voluntarily to facilitate staff review and improve the publics access to information.
2.
In the July 25, 2001 public meeting, NEI indicated they needed a consistent review process. The staff experience indicated that the review approach referencing the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) used in the Plant X demonstration provided the most consistency. An applicant should address specific areas delineated in the SRP-LR. If the applicant deviates from the SRP-LR, it should be disclosed in the application and should be explained in sufficient detail to preclude a request for additional information.
3.
When the Generic Aging Lessons Learned (GALL) report identifies specific conditions that should be met for the GALL reports conclusion to apply, the applicant should provide a statement in the license renewal application indicating that the conditions specified in the GALL report are met. The appropriate wording to indicate that an applicants aging management program meets the evaluation as described in the GALL report is AMP is consistent with GALL. Engineering judgement may be used by the applicants in making this determination. When there is some expectation that NRC staff may not come to the same determination with respect to a particular program element, the applicants should identify these as differences from GALL report in their license renewal application.
4.
If a program name in the license renewal application is plant specific and different from the name used in the GALL report but the program is consistent with the GALL report, an applicant should reference which section in Chapter XI of the GALL report that the plant specific program is consistent with.
5.
An applicant could reference a program evaluated in the GALL report for a component not covered by the GALL report if it involves similar intended function, environment, material, aging effect, system, and ASME Code Class (if applicable) with another component that is covered in the GALL report. The components should be clearly identified and explained and the basis should be provided in the application.
6.
There is no guidance for how the applicant should address programs that have not been developed at the time the license renewal application is submitted where the applicant intends to develop the program at a later time to be consistent with GALL.
7.
In the application of the GALL report, the applicant must include a certification in the license renewal application that the verifications have been completed and are documented on-site in an auditable form. The certification process is the same as in the past where information is submitted to the NRC under oath and affirmation. Recent guidance is provided in Regulatory Issue Summary 2001-18.
Enclosure 8.
The GALL report is based on industry operating experience prior to April, 2001.
Operating experience after that date should also be evaluated in the license renewal application. In particular, the staff is interested in how a generic communication, such as a bulletin or an information notice, affects the applicants aging management program. An example of the need for such guidance is as follows: Information Notice 2001-09, dated June 12, 2001, discusses the flow accelerated corrosion of the main feedwater system inside the containment that was not considered to be susceptible to flow accelerated corrosion. This new experience has led to inspection of feedwater piping inside the containment and modification of the CHECWORKS program.
9.
Additional description of uncommon components not addressed in the GALL report should be included in the license renewal application to facilitate staff review of the aging management program. For example, Table 3.5.2 in the demonstration project indicates that Plant X has trisodium phosphate baskets that have no aging effects.
Additional descriptions in the sample license renewal application would have facilitated the staff review of the applicable aging effects. It is the applicants responsibility to provide the basis for the determinations on materials and aging effects that are not addressed in GALL and justify them in the application.
10.
In the demonstration project, the sample applicant used either the August 2000 version or the April 2001 version of the GALL report interchangeably depending on which version would support their position. An applicant needs to identify which version of GALL was used to prepare their license renewal application.
11.
In some cases, the final safety analysis report (FSAR) descriptions in the application were very general compared with those in the SRP-LR. For example, the flow accelerated corrosion program did not reference NSAC-202L-R2. The buried piping monitoring program also did not make reference to any code or standard such as NACE-RP-01-69. The applicant would probably have less requests for additional information if the FSAR descriptions were similar to the level of detail provided in the SRP-LR.
12.
An application based on the SRP-LR table consists of a number of components in GALL that are rolled up into a general component description. This roll up consists of several items that may be different from plant to plant. Information providing this roadmap should be available for onsite inspection and in the license renewal application so that an inspector and reviewer could determine how individual components in the GALL report that are referenced by the applicant were addressed.
13.
The Plant X sample application presents summary information and does not include detailed information that is in the GALL report. The regional inspectors perform inspection/verification to confirm the accuracy of information in the application. On-site documentation should be clearly linked to the summary application details to facilitate the regional inspection. Applicants need a clear paper trail that is auditable and retrievable for onsite inspections.
NUCLEAR ENERGY INSTITUTE
Project No. 690 cc:
Mr. Joe Bartell U.S. Department of Energy NE-42 Washington, DC 20585 Ms. Christine S. Salembier, Commissioner State Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601 Mr. Stephen T. Hale Florida Power & Light Company 9760 S.W. 344 Street Florida City, Florida 33035 Mr. William Corbin Virginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348 Ronald B. Clary Manager, Plant Life Extension V.C. Summer Nuclear Station Bradham Blvd.
PO Box 88 Jenkinsville, SC 2906 Mr. Robert Gill Duke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006 Mr. Joseph Gasper Manager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, NE 68023-0399 Mr. David Lochbaum Union of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919 Mr. Paul Gunter Director of the Reactor Watchdog Project Nuclear Information & Resource Service 1424 16th Street, NW, Suite 404 Washington, DC 20036 Mr. Hugh Jackson Public Citizens Critical Mass Energy &
Environment Program 215 Pennsylvania Ave. SE Washington DC 20003 Mary Olson Nuclear Information & Resource Service, Southeast Office P.O. Box 7586 Asheville, North Carolina 28802 Talmage Clements Manger - License Renewal Nuclear Engineering Services CP&L 410 South Wilmington Street Raleigh, NC 27602 George Wrobel Manager, License Renewal R.E.Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519