ML042510027

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Summary of Meeting Between the NRC, the NEI, and the Three Pilot Program LRA Held on June 3, 2004, to Discuss Generic License Renewal Topics and Lessons Learned on the Pilot Program for the New LRA Review Process
ML042510027
Person / Time
Site: Dresden, Arkansas Nuclear, Summer, Ginna, Farley, Cook, Quad Cities  Constellation icon.png
Issue date: 08/03/2004
From: Dozier I
NRC/NRR/DRIP/RLEP
To:
Lintz M, NRR/DRIP/RLEP/301-415-4051
Shared Package
ML042510011 List:
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Download: ML042510027 (28)
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Updating License Renewal Guidance Documents August 3, 2004 Jerry Dozier License Renewal and Environmental Impacts - B

2 Overview

  • Background
  • Schedule
  • Stakeholder involvement
  • Examples of new LR documents**

 **Examples are work in progress and have not received formal approval

  • Specific questions and discussion on NEI submittals

3 License Renewal Guidance Documents

  • RG 1.188, Standard Format and Content for Applications to Renew Nuclear power Plant Operating Licenses

4 Activities since 6/3/04 public meeting

  • NEI submittal (5/11/04)

 Staff complete line by line review of NEI submittal

 Resolving open items

  • Additional NEI submittal (39 items on 7/30/04)
  • Staff comment consolidation from NRC staff, contractors and national laboratory

5 Activities since 6/3/04 public meeting

  • Development of framework/databases to support project

6 Tentative Schedule

  • September 30, 2004 Preliminary draft update to GALL and SRP-LR (Rev A) scheduled to be posted on Web
  • November, 2004 Public meeting on GALL and SRP-LR on Web (Rev A)
  • January 30, 2005 Publication of draft update to GALL and SRP-LR (Rev B) with draft reference document that provides justification for changes for public comment

7 Tentative Schedule

  • February 1, 2005 to March 30, 2005 Public Comment Period
  • Public Workshop (1 or 2 day workshop scheduled late February or early March during public comment period)

8 Tentative Schedule

  • 6/30/2005 Address public comments and prepare final update to GALL and SRP-LR (Rev C) with Bases and Analysis of Public Comment NUREG
  • 9/30/2005 Final Publication of GALL and SRP-LR (Rev 1) with Bases and Public Comment NUREG

9 Scope for Update in September 2004 (Phase 1)

  • The GALL update will involve component consolidations, reformatting, correction of errors, and incorporation of approved staff positions (Precedents, Interim staff guidance)
  • Corresponding changes to the SRP-LR will also be developed including update to incorporate new review approach.

10 Phase 2

  • Phase 2 involves changes such as development of AMPs, additional approved staff positions, and enhancements
  • Phase 2 Comments evaluated for incorporation in January 2005 version
  • Significant benefit will be achieved with phase 1, but appropriate consideration will be given to all phase 2 comments

11 Stakeholder Involvement in updating guidance document

  • Improvements considered from NEI, NRC staff, Information Systems Laboratory (ISL),

and Argonne National Laboratory (ANL)

  • We welcome any public comments on this update
  • September posting on the website is to provide early information to all stakeholders

12 Example Comment Disposition ID:

GALL04: E-12 Phase:?

P1 Change Type:?

I Structure and/or Components:

Piping, piping components, piping elements, and tanks Material:

Stainless Steel Environment:?

Treated Borated Water

>140oF Aging Effect/Mechanism:

Loss of Material &

Cracking/Pitting & crevice corrosion & SCC AMP:?

XI.M2 I. Identification Comment originator: ANL Precedent Source: [NA/S SER, Section 3.5.2-1]

Specific comment: Table V_ESF-CompilANL.doc G-V.A1-1 Add item A1-d for loss of material due to pitting and crevice corrosion in the piping and fittings and miscellaneous elements (including instrument valve assemblies). All else in this item is unchanged from GALL3 item A.1-a.

Short description of change: Expand the aging effect and mechanism to include loss of material and cracking due to pitting and crevice corrosion and stress corrosion cracking. No other changes are made in NEI rollup line item E-12.

II. Evaluation Type of Change: A Basis for Change (as given by comment originator): Additional aging effect/ mechanism: As shown in NA/S FSER 3.5.2.1, the staff found it acceptable that both loss of material and cracking were conservatively identified as applicable aging effects for those portions of the ESF piping and elements fabricated from SS in sensitized condition and exposed to treated water.

Justification for approval: Explicit - [NA/S SER, Section 3.5.2-1] identifying loss of material and cracking for the material and environment combinations in question are conservative with respect to standard industry practices and are acceptable to the staff.

III. Implementation Change Type Document Update04-ID Rev01-ID Text ESF-1a Insert GALL E-12 A.1-a Loss of Material & Cracking/Pitting & crevice corrosion & SCC ESF-1b Insert GALL E-12 A.1-c Loss of Material & Cracking/Pitting & crevice corrosion & SCC ESF-1c Insert GALL E-12 A.3-a Loss of Material & Cracking/Pitting & crevice corrosion & SCC Implementation Completion Date:

NRC Concurrence Date: 7/08/04

13 Example GALL 2005 Containment Spray System (PWR)

Item Structure and/or Component Material Environment Aging Effect/

Mechanism Aging Management Program (AMP)

Further Evaluation E-12 Piping, piping components, piping elements, and tanks Stainless steel Treated borated water > 140°F Cracking/Stress corrosion cracking Chapter XI.M2, Water Chemistry, for PWR primary water in EPRI TR-105714 No E-17 Heat exchanger shell side components steel Closed cycle cooling water Loss of material/

General, pitting and crevice corrosion Chapter XI.M21, Closed-Cycle Cooling Water System No E-18 Heat exchanger shell side components including tubes steel Raw water Macrofouling and Loss of material/

General, Pitting, crevice, and,

microbiologically influenced corrosion and biofouling Chapter XI.M20, Open-Cycle Cooling Water System No E-19 Heat exchanger shell side components including tubes Stainless steel Closed cycle cooling water Loss of material/

pitting, and crevice corrosion Chapter XI.M21, Closed-Cycle Cooling Water System No E-20 Heat exchanger shell side components including tubes Stainless steel Raw water Loss of material and macrofouling/ Pitting, crevice, and microbiologically influenced corrosion and biofouling Chapter XI.M20, Open-Cycle Cooling Water System No

14 Example GALL 2005 EP-15 Piping, piping components, and piping elements Glass Air - indoor uncontrolled (Ext)

None None Note: Scoping/screening and aging management review will continue to apply

15 GALL 2005 (Added Definitions)

  • Definitions provided for materials, environments, aging effects, aging mechanisms, and selected components

 Cross-system analysis of nomenclature to assure consistency throughout GALL 2005

 Minimization of unnecessary detail and roll-up of similar terms

 Temperature thresholds for certain aging effects

16 Example GALL Definitions Materials --- Steel: Carbon steel, alloy steel, and cast iron (NOT stainless steel) may be considered the same for several aging effects. When other aging effects/mechanisms are addressed, materials are specifically mentioned.

Environment -- Diesel Exhaust: gases, fluids, particulates present in a diesel engine exhaust.

Aging Effect -- Macrofouling: fouling that causes plugging as opposed to fouling that causes loss of heat transfer.

Structures & Components -- Piping, piping components, and piping elements: Examples include piping, fittings, orifices, elements, strainers, pump casing and bowl, valve body, bonnet, nozzles, safe ends, and spray head.

17 Changes to SRP-LR

  • SRP-LR changes corresponding to the update in GALL
  • Update of review process
  • Incorporation of appropriate comments

18 Bases Document Provides justification for changes to the original GALL Report (July 2001)

 General Chapter describing rollup methodology changes and conversion

 Chapter that provides detailed justification for technical changes and additions

19 Bases Document - Conceptual Outline

  • Section I. Analysis of General Changes in Updated GALL

 Generalized component descriptions

 Consolidated materials types

 Environmental categories & definitions

 Aging effects & aging mechanisms

 Attributable and traceable to GALL 2001 Section II. Technical Modifications and Additions

 Justification for technical changes and modifications

20 Example Material Conversion Metal Designation or Definition (as referenced in Material Column of OldGALL)

Metal Description Designation/

Specification Ref.

OldGALL Ref, first introduced, questions/comm ents about original usage Bases Term for Materials Consolidation in NewGALL Explanation for Usage of Materials Consolidation Term CF-3M Cast Austenitic Stainless Steel (CASS), ASTM A743 or A444, Cr-Ni steel ASM datasheet)

IVB4.3 CASS Cast stainless steels containing ferrite in an austenitic matrix Inconel 182 Ni-Fe-Cr weld metal (caution-Note that according to ASM, 182 is also nomenclature for Glidcop variant)

ASM datasheet IVB1.1 - replace the term Inconel wherever it shows up in GALL with Alloy.

Nickel a lloys are used for a wide variety of applications, the majority of which involve corrosion resistance and/or heat resistance.

Nickel and nickel alloys, like the stainless steels, offer a wide range of corrosion resistance.

However, nickel can accommodate larger amounts of alloying elements, chiefly chromium, molybdenum, and tungsten, in solid solution than iron. Therefore, nickel-base alloys, in general, can be used in more severe environments than the stainless steels. Nickel-chromium-iron (-molybdenum) alloys are those such as the Alloy 600 and 690.

SB-166 Ni-Cr-Fe alloys and Ni-Cr-Co-Mo alloy in form of hot-finished and cold-work rod, bar, and wire.

ASME BPVC Section IIB (p.177-186,01)

IVA1.4 Nickel alloy As described for A-182 Particular material retained in GALL 2005 when appropriate

21 Example Bases Item Material Environment AE AMP EP-1 Steel (bolting)

Air - outdoor (Ext)

Loss of material/General, pitting, and crevice corrosion Chapter XI.M18, Bolting Integrity Precedent Basis: An approved precedent exists for adding this material, environment, aging effect and program combination item to the GALL Report. As shown in VCSNS SER 3.0.3.7.2, the staff has accepted the position that loss of material from general, pitting, and crevice corrosion, exhibited by steel bolting in an outdoor air environment is properly managed by the Bolting Integrity AMP which includes periodic inspection of closure bolting and ensures timely detection of corrosion and/or leakage. This program provides reasonable assurance that the components intended functions will be maintained within the CLB for the extended period of operation.

22 Example Bases (2)

Item Material Environment AE AMP EP-5 Steel Concrete None None Precedent Basis: An approved precedent exists for adding this material, environment, aging effect and program combination item to the GALL Report. As shown in VCSNS SER 3.3.2.4.21, the staff has accepted the position that steel in a concrete environment exhibits no aging effect and that the component or structure will therefore remain capable of performing its intended functions consistent with the CLB for the period of extended operation. This conclusion is based on the fact that corrosion of embedded steel is not significant if the attributes of the concrete design are consistent with ACI 318-63, in particular a low water-to-cement ratio, low permeability, and adequate air entrainment as cited in NUREG-1557.

23 Public Comment NUREG Document will be developed similar to NUREG-1739, Analysis of Public Comments on the Improved License Renewal Guidance Documents NRC Staffs analysis of the stakeholders comments on the license renewal guidance documents during the comment period

 License renewal public workshop

 Written comments submitted by NEI

 Written comments submitted by various stakeholders

24 Example from NUREG 1739 Table C: Disposition of Written Public Comments (continued)

Comment Number Item Number Comment/

Proposed Change Basis for Comment NRC Disposition NIRS-4 C.3.13 Additionally, the NRC and industry have provided no lessons learned in their GALL approach for assessing demonstrated shortfalls, failures and differing professional opinions in the current process to evaluate aging for the current licensing basis.

These failures and shortfalls can compound to adversely impact the scope and accuracy of generic evaluations within the context of license renewal when overlooked in the evaluation program of the adequacy of generic aging management programs.

The GALL, SRP-LR, and Draft RG have the benefit of the experience of the staff members who are part of the current process in evaluating aging for the current license term and also conducted the review of the initial license renewal applications. Therefore, lessons learned from the current process and from an efficiency and effectiveness standpoint in addressing unique issues related to license renewal from the first reviews have been incorporated into these documents. The GALL, SRP-LR, and Draft RG have been revised to address the issue but not specifically for this comment.

25 License Renewal Guidance Update Website

  • Keep all stakeholders informed about schedule and information such as relevant correspondence, meeting notices and summaries, NRC public presentations (coming soon!)

http://www.nrc.gov/reactors/operating/lic ensing/renewal/guidance.html

26 Comments

  • Recent operating experience (Davis Besse, finding on nickel alloy issue) will change some items in GALL

27 Example of 7/30/04 NEI Submittal

28 Near Term Path forward

  • Preliminary draft update to GALL and SRP-LR on September 30
  • Proposed public meeting in November
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