ML031010423
| ML031010423 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 04/08/2003 |
| From: | Kuo P NRC/NRR/DRIP/RLEP |
| To: | Lochbaum D, Alexis Nelson Nuclear Energy Institute, Union of Concerned Scientists |
| Kang P, NRR/DRIP/RLEP, 415-2779 | |
| References | |
| +KBR1SISP20050608 | |
| Download: ML031010423 (9) | |
Text
April 8, 2003Mr. Alan NelsonMr. David LochbaumNuclear Energy InstituteUnion of Concerned Scientists 1776 I Street, NW., Suite 4001707 H Street, NW., Suite 600 Washington, DC 20006-3708Washington, DC 20006-3919
SUBJECT:
PROPOSED INTERIM STAFF GUIDANCE (ISG) ON IDENTIFICATION ANDTREATMENT OF HOUSING FOR ACTIVE COMPONENTS FOR LICENSE RENEWAL
Dear Messrs. Nelson and Lochbaum:
The purpose of this letter is to provide you with the opportunity to comment on the proposedISG on identification and treatment of housing for active components for license renewal. The NRC staff (the staff) has developed the subject ISG to clarify that screening of housings for active mechanical components is conducted in accordance with the requirements of Section 54.21(a)(1) of the license renewal rule (10 CFR Part 54). The staff has made further revisions to this ISG since it issued a May 1, 2002, letter that solicited comments on the issue. The proposed ISG incorporates lessons learned from recent license renewal reviews to indicate that housings for fans, dampers, and heating and cooling coils may be subject to an aging management review for license renewal. Enclosure 1 is a copy of the proposed ISG on identification and treatment of housing for activecomponents for license renewal. Enclosure 2 includes pertinent changes to Table 2.1-5 of the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR). The staff plans to incorporate this ISG position into the improved renewal guidance documents (NUREG-1800 and 1801) in a future update. We request that you comment on the proposed ISG and submit a schedule for resolution, in order to ensure a timely closure of this issue.
A. Nelson and D. Lochbaum-2-For the resolved ISGs, it is also possible that comparable changes might be needed toNEI 95-10, Revision 3, "Industry Guidance for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule." 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
Enclosures:
As stated cc w/encls: See next page A. Nelson and D. Lochbaum-2-For the resolved ISGs, it is also possible that comparable changes might be needed toNEI 95-10, Revision 3, "Industry Guidance for Implementing the Requirements of10 CFR Part 54 - The License Renewal Rule.
" 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
Enclosures:
As stated cc w/encls: See next pageC:\ORPCheckout\FileNET\ML031010423.wpd
- See previous concurrence OFFICELA: RLEP:DRIPPM:RLEP:DRIPSC:RLEP:DRIPC:DSSA:SPLBNAMEHBerilla*PKang*SLee*JHannon*
DATE1/31/031/31/032/03/032/06/03 OFFICED:DSSAOGCPD:RLEP:DRIP NAMEGHolahan*AFernandez*PTKuo DATE2/20/033/31/034/8/03OFFICIAL RECORD COPY DISTRIBUTION: Letter to A. Nelson and D. Lochbaum RE: ISG, Dated: April 8, 2003 HARD COPYRLEP R/FP. KangE-MAIL:PUBLICW. 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. Smith (srs3)
T. Kobetz C. Munson RLEP Staff
A. ThadaniC. Julian R. Gardner M. Farber M. Modes J. Vora ENCLOSURE 1PROPOSED INTERIM STAFF GUIDANCE (ISG) ON SCREENING OF HOUSINGS FOR ACTIVE COMPONENTS FOR LICENSE RENEWALStaff PositionThe proper implementation of 10 CFR Part 54 requires an applicant for a renewed license toconsider, in their screening evaluations, the intended function of the housing associated with an active mechanical component that performs a function within the scope of 10 CFR Section 54.4.
Pump casings and valve bodies, as described in both the license renewal rule (10 CFR Part 54 or the Rule) and its statement of consideration (SOC), are examples of how an applicant should evaluate housings for active mechanical components. Specifically, based on experience with recent license renewal reviews, the staff believes that the housings for fans, dampers, and heating and cooling coils may perform a critical pressure retention and/or structural integrity function which, should that function not be maintained, could prevent the associated active mechanical component from performing its intended function. Further, if such housings perform these functions and meet the long-lived and passive criteria, then the housings should be subject to an aging management review (AMR).The staff expects applicants for license renewal to identify active mechanical componenthousings that require an AMR pursuant to 10 CFR Section 54.21. This determination should consider whether failure of the housing would result in a failure of the associated active mechanical component to perform its intended function, and whether the housing meets the long-lived and passive criteria as defined in the Rule. The reasons for this position follow:RationaleThe SOC for the Rule states that the objective of a license renewal review is to determinewhether the detrimental effects of aging, which could adversely affect the functionality of systems, structures, and components (SSCs) that the Commission determines require review for the period of extended operation, are adequately managed. The SOC articulates the underlying philosophy of the Rule; that during the period of extended operation, safety-related functions should be maintained in the same manner and to the same extent as they are during the current licensing term. Aging effects, which could adversely impact the ability of SSCs to maintain these safety-related functions during the period of extended operation, should be evaluated.Section 54.21(a)(1) of the Rule states that components that perform their intended functionswithout moving parts and without a change in configuration or properties (Section 54.21(a)(1)(i))
and that are not subject to replacement based on qualified life or a specified time period (Section 54.21(a)(1)(ii)), are subject to an AMR. Such components are commonly considered to be "long-lived
" and to perform a passive function. Section 54.21(a)(1)(i) states, "Thesestructures and components include, but are not limited to . . . pump casings, valve bodies . . .
"and lists other components that perform passive functions.The SOC explains that major components may have active functions, passive functions, orboth, and cites pumps and valves as examples. 60 FR 22,477. Pumps and valves have moving parts, but the Commission concluded that the pressure-retaining function performed by the pump casing and the valve body should be subject to an AMR. The SOC further explains that the Commission does not limit the consideration of pressure boundaries to the reactorcoolant pressure boundary. The exclusion of a component from aging management review is focused on active functions, rather than on the exclusion of the entire component, while the AMR applies to the passive function of the component.On these bases, the staff concludes that a license renewal applicant must consider the non-active part of a component that performs a function within the scope of Part 54 (e.g., pump casings, valve bodies, and housings for fans and dampers). The proper implementation of the Rule requires that screening evaluations consider not just the active mechanical component, but also the intended function of its associated housing.
PROPOSED REVISIONS TO SRP-LR TABLE 2.1-5Current Table EntriesItemCategoryStructure, Component, orCommodity GroupStructure, Component, orCommodity Group Meets 10 CFR 54.21(a)(1)(i)
(Yes/No)58Heat ExchangersHVAC CoolersYes 116ValvesDampersNo 124FansVentilation FansNoProposed Revisions to the Table EntriesItemCategoryStructure, Component, orCommodity GroupStructure, Component, orCommodity Group Meets 10 CFR 54.21(a)(1)(i)
(Yes/No)58HeatExchangersHVAC Coolers(including housings)
Yes116ValvesHousings for Dampers(including louvers and gravity dampers)Yes124FansHousings for Ventilation Fans(Including exhaust fans)
YesENCLOSURE 2 NUCLEAR ENERGY INSTITUTE Project No. 690
cc:Mr. Joe BartellU.S. Department of Energy NE-42 Washington, DC 20585Ms. Christine S. SalembierCommissioner State Liaison Officer Department of Public Service 112 State St., Drawer 20 Montipelier, VT 05620-2601Mr. Stephen T. HaleFlorida Power & Light Company 9760 S.W. 344 St.
Florida City, FL 33035Mr. William CorbinVirginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Blvd.
Glen Allen, VA 23060Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348George WrobelManager, License Renewal R.E. Ginna Nuclear Power Plant 1503 Lake Rd.
Ontario, NY 14519Ronald B. ClaryManager, Plant Life Extension V.C. Summer Nuclear Station Bradham Blvd.
P.O. Box 88 Jenkinsville, SC 29065Mr. John B. HermanManager - Nuclear Licensing Omaha Public Power District Fort Calhoun Station FC-2-4 Adm.
Post Office Box 550 Fort Calhoun, NE 68023-0550Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service
1424 16 th St., 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, NC 28802 Talmage B. ClementsManager - License Renewal Nuclear Engineering Services
CP&L 410 South Wilmington St.
Raleigh, NC 27602