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, 2002Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
OBSERVATIONS FROM THE NUCLEAR ENERGY INSTITUTE (NEI) LICENSERENEWAL 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 staff's compilation of observations from the NEI license renewal demonstrationproject 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 RegulatoryGuide 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 DirectorLicense Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690
Enclosure:
As stated cc w/encl: See next page Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC 20006-3708
SUBJECT:
OBSERVATIONS FROM THE NUCLEAR ENERGY INSTITUTE (NEI) LICENSERENEWAL 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 staff
's compilation of observations from the NEI license renewal demonstrationproject 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 RegulatoryGuide 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 DirectorLicense Renewal and Environmental Impacts Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject 690
Enclosure:
As stated cc w/encl: See next pageDISTRIBUTION: See next pageDocument Name:C:\ORPCheckout\FileNET\ML022060290.wpd OFFICERLEPLASC:RLEPPD:RLEPNAME PKangEHyltonSLeePTKuo DATE 7/3/027/3/02 7/3/027/24/02OFFICIAL RECORD COPY DISTRIBUTION: Letter to Alan Nelson, Dated: July 24, 2002 HARD COPY RLEP RFE. HyltonE-MAIL:PUBLICJ. 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. ThadaniC. Julian R. Gardner M. Farber M. Modes J. Vora Observations and Comments for Consideration in Revising NEI 95-10, Rev 31.In a letter dated April 13, 2001, the ACRS commented that the staff should encourageapplicants to include the results of the scoping process in their applications (ADAMSaccession No. ML011080765). SECY-01-0157 dated August 17, 2001, also stated thatthe 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 public
's access to information. 2.In the July 25, 2001 public meeting, NEI indicated they needed a consistent reviewprocess. 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 conditionsthat should be met for the GALL report
's conclusion to apply, the applicant shouldprovide 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
applicant's aging management program meets the evaluation as described in the GALLreport is "AMP is consistent with GALL.
" Engineering judgement may be used by theapplicants 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 fromthe 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 componentnot 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 beendeveloped 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 thelicense 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.
Recentguidance 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 renewalapplication. In particular, the staff is interested in how a generic communication, such as a bulletin or an information notice, affects the applicant
's aging managementprogram. 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 reportshould be included in the license renewal application to facilitate staff review of theaging 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 versionor 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 applicationwere 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 GALLthat are "rolled up" into a general component description. This roll up consists of severalitems 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 includedetailed 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 BartellU.S. Department of Energy NE-42 Washington, DC 20585Ms. Christine S. Salembier,Commissioner State Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601Mr. Stephen T. HaleFlorida Power & Light Company 9760 S.W. 344 Street Florida City, Florida 33035Mr. William CorbinVirginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Ronald B. ClaryManager, Plant Life Extension V.C. Summer Nuclear Station Bradham Blvd.
PO Box 88 Jenkinsville, SC 2906Mr. Robert GillDuke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006Mr. Joseph GasperManager - Nuclear LicensingOmaha Public Power DistrictFort Calhoun Station FC-2-4 Adm.
Post Office Box 399 Hwy. 75 - North of Fort Calhoun Fort Calhoun, NE 68023-0399Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service
1424 16 th Street, NW, Suite 404Washington, DC 20036Mr. Hugh JacksonPublic Citizen
's Critical Mass Energy &Environment Program 215 Pennsylvania Ave. SE Washington DC 20003Mary OlsonNuclear Information & Resource Service, Southeast Office P.O. Box 7586 Asheville, North Carolina 28802 Talmage ClementsManger - License Renewal Nuclear Engineering Services
CP&L 410 South Wilmington Street Raleigh, NC 27602George WrobelManager, License Renewal R.E.Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519