ML11111A105
| ML11111A105 | |
| Person / Time | |
|---|---|
| Issue date: | 07/01/2011 |
| From: | Mcginty T Division of Policy and Rulemaking |
| To: | |
| Regner L | |
| References | |
| RIS 2011-005 | |
| Download: ML11111A105 (10) | |
See also: RIS 2011-05
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATIONS
WASHINGTON, DC 20555-0001
July 1, 2011
NRC REGULATORY ISSUE SUMMARY 2011-05
INFORMATION ON REVISION 2 TO THE
GENERIC AGING LESSONS LEARNED REPORT
FOR LICENSE RENEWAL OF NUCLEAR POWER PLANTS
ADDRESSEES
All holders of a power reactor operating license under Title 10 of the Code of Federal
Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities,
except those who have permanently ceased operations and have certified that fuel has been
permanently removed from the reactor vessel.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to provide information to applicants and licensees on the changes to NUREG-1801, Generic
Aging Lessons Learned (GALL) Report, Revision 2, issued December 2010.
The purpose of this RIS is to inform applicants and licensees, especially those with license
renewal applications currently under review and those with a renewed operating license, of
operating experience incorporated since the previous revision to the GALL Report and the
associated changes to staff positions concerning adequate aging management of structures,
systems, and components within the scope of license renewal.
This RIS does not discuss all the Revision 2 changes; instead, it identifies the more noteworthy
modifications that the staff has evaluated as important to ensure that the effects of aging at
nuclear power plants are adequately managed so that structure, system, and component
functions are maintained during the period of extended operation. Revision 2 of the GALL
Report identifies all the changes.
This RIS requires no specific action or written response. The NRC recommends that licensees
review the recently issued changes to Revision 2 of the GALL Report. It also encourages
licensees with renewed operating licenses to review the changes to the GALL Report and
consider actions necessary to incorporate these updates, as appropriate, into existing aging
management programs (AMPs) at their plants.
BACKGROUND INFORMATION
NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear
Power Plants (SRP-LR), Revision 2, issued December 2010, references NUREG-1801 as a
Page 2 of 9
technical basis document. The GALL Report lists generic aging management reviews of
systems, structures, and components that may be in the scope of license renewal applications
and identifies aging management programs (AMPs) that the NRC finds acceptable for managing
the aging effects expected during a plants operation past the expiration date of its original
license (i.e., the period of extended operation). The NRC staff uses the GALL Report as a basis
for review of license renewal applications consistent with guidance in the SRP-LR.
The NRC staff issued Revision 2 to the GALL Report in December 2010 (Agencywide
Documents Access and Management System (ADAMS) Accession No. ML103490041). The
changes incorporate (1) lessons learned from the reviews of previous license renewal
applications, (2) operating experience obtained after the NRC issued Revision 1 to the GALL
Report, and (3) other public input, including industry comments. The staff from the Division of
License Renewal (DLR) analyzed operating experience information during a screening review of
domestic operating experience, foreign operating experience from the international Incident
Reporting System database, and NRC generic communications. The information reviewed
included operating experience from January 2004 to approximately April 2009.
SUMMARY OF ISSUE
This document provides an overview of noteworthy changes identified by the NRC staff in
Revision 2 of the GALL Report and a useful synopsis to help licensees and applicants
understand the significant differences between Revision 1 and Revision 2. Licensees and
applicants should review Revision 2 for details on programmatic changes and other aging
management information that may apply to specific plants.
This RIS is also meant as a reminder of the significance of aging-related operating experience
and of the value that the NRC staff places on this information. Aging-related operating
experience was a fundamental consideration in the development of the GALL Report, and it
continues to play a key role in revisions to the document. Furthermore, the GALL Report and
the SRP-LR state that the staffs evaluation of a license renewal application in determining the
adequacy of AMPs is based, in part, on the applicants consideration of, and its actions taken to
address, both plant-specific and industry operating experience.
As discussed in the GALL Report, each AMP includes 10 elements. Element 10, Operating
Experience, states the following:
Operating experience involving the AMP, including past corrective actions
resulting in program enhancements or additional programs, should provide
objective evidence to support a determination that the effects of aging will be
adequately managed so that the structure and component intended functions will
be maintained during the period of extended operation.
Since the issuance of Revision 1 of the GALL Report, some applicants have committed to
evaluate plant-specific and appropriate industry operating experience and to incorporate
lessons learned to assess aging effects for new programs. The staff finds that these
commitments have merit and has revised the SRP-LR to clarify its expectations.
Page 3 of 9
Section A.1.2.3.10, Operating Experience, of Appendix A, Branch Technical Positions, to
Revision 2 of the SRP-LR states the following:
For new AMPs that have yet to be implemented at an applicants facility, the
programs have not yet generated any operating experience (OE). However,
there may be other relevant plant-specific OE at the plant or generic OE in the
industry that is relevant to the AMPs program elements even though the OE was
not identified as a result of the implementation of the new program. Thus, for
new programs, an applicant may need to consider the impact of relevant OE that
results from the past implementation of its existing AMPs that are existing
programs and the impact of relevant generic OE on developing the program
elements. Therefore, operating experience applicable to new programs should
be discussed. Additionally, an applicant should commit to a review of future
plant-specific and industry operating experience for new programs to confirm
their effectiveness.
After the NRC issues a renewed license, licensees continue to (1) review industry, foreign, and
plant-specific operating experience, (2) evaluate its applicability, and (3) incorporate appropriate
changes in accordance with Appendix B, Quality Assurance Criteria for Nuclear Power Plants
and Fuel Reprocessing Plants, to 10 CFR Part 50 and 10 CFR 50.65, Requirements for
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The NRC revised the
SRP-LR to provide guidance on applying operating experience associated with systems,
structures, and components that are within the scope of license renewal. Section A.1.2.3.10 in
Revision 2 of the SRP-LR states the following:
Reviews of operating experience by the applicant in the future may identify areas
where aging management programs should be enhanced or new programs
developed. An applicant should commit to a future review of plant-specific and
industry operating experience to confirm the effectiveness of its aging
management programs or indicate a need to develop new aging management
programs.
NRC inspectors routinely evaluate licensee corrective action and operating experience review
programs as part of the Reactor Oversight Process (Inspection Manual Chapter 0310,
Components within the Cross-Cutting Areas, and Inspection Procedure 71152, Problem
Identification and Resolution).
The following summarizes the significant updates to aging management guidance, detailed in
Revision 2 of the GALL Report:
- Fatigue Monitoring. The revised scope of AMP X.M1, Fatigue Monitoring, now
includes all components with a fatigue time-limited aging analysis and updated specific
guidance for calculating environmentally adjusted cumulative usage factors for different
materials.
Page 4 of 9
The revision also clarifies the scope to include locations identified in NUREG/CR-6260,
Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power
Plant Components, issued February 1995, as a minimum, and additional plant-specific
component locations if they may be more limiting than those considered in
- Reactor Head Closure Stud Bolting. The revision to AMP XI.M3, Reactor Head Closure
Stud Bolting, updates the program to include the more appropriate yield strength
designation for high-strength bolts, which reflects information in the reference document,
NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in
Nuclear Power Plants, issued June 1990. In addition, the revision specifically identifies
that molybdenum disulfide is a potential contributor to stress corrosion cracking and
should not be used.
Vessel Internals, added the technical contents of the current AMP XI.M13, Thermal
Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steels (CASS);
referenced the new BWR Vessel Internals Program (BWRVIP) reports; and updated the
existing BWRVIP reports. Additionally, the program scope added the thermal aging and
neutron irradiation embrittlement of precipitation-hardened martensitic stainless steel
and martensitic stainless steel and the irradiation embrittlement of X-750 alloy in the
BWR reactor vessel.
- Cracking of Nickel-Alloy Components and Loss of Material due to Boric-Acid-Induced
Corrosion. AMP XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material
due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary
Components (PWRs Only), supersedes AMP XI.M11A, Nickel-Alloy Penetration
Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water
Reactors (PWRs only), and AMP XI.M11, Nickel-Alloy Nozzles and Penetrations.
AMP XI.M11B recognizes the industrys Materials Reliability Program (MRP) MRP-139,
Materials Reliability Program: Primary System Piping Butt Weld Inspection and
Evaluation Guideline, for the inspection of dissimilar metal welds in the primary system.
It also recognizes Code Cases N-791 and N-722 of the American Society of Mechanical
Engineers Boiler and Pressure Vessel Code (ASME Code) for nickel-alloy components
that NRC regulations now mandate.
Internals, reinstates the vessel internals AMP which is based on MRP-227, Pressurized
Water Reactor Internals Inspection and Evaluation Guidelines. The staffs final safety
evaluation on MRP-227 was issued on June 22, 2011. The staff also plans to issue a
RIS that provides information on the implementation of MRP-227 for license renewal and
will issue an interim staff guidance document to make conforming changes to the GALL
Report.
Page 5 of 9
- Steam Generators. AMP XI.M19, Steam Generators, includes extensive revisions to
reflect Nuclear Energy Institute 97-06, Steam Generator Program Guidelines,
Revision 2, issued May 2005, and adds aging management review line items to ensure
adequate aging management of divider plate assemblies and to provide consistency
between once-through steam generators and recirculating steam generators for tube to
tubesheet welds.
- One-Time Inspection and Selective Leaching. The revision to AMP XI.M32, One-Time
Inspection, and AMP XI.M33, Selective Leaching, provides additional details on
sample sizes for these programs.
- One-Time Inspection of ASME Code Class 1 Small-Bore Piping. The revision to
AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore-Piping, explicitly
includes aging management of socket welds, allows for destructive examinations of
these welds, and recognizes that advances in ultrasonic testing may make volumetric
examinations of socket welds more effective. The revised program describes conditions
under which this one-time inspection is appropriate and explains when a periodic
inspection program would be more appropriate. The program revision includes guidance
on the number of welds to be inspected that represents a sufficient number of locations
to ensure an adequate sample and on the implementation schedule of the one-time
inspections.
- External Surfaces Monitoring of Mechanical Components and Inspection of Internal
Surfaces in Miscellaneous Piping and Ducting. The revisions to AMP XI.M36, External
Surfaces Monitoring of Mechanical Components, and AMP XI.M38, Inspection of
Internal Surfaces in Miscellaneous Piping and Ducting Components, increase the scope
of materials covered to include all metallic and polymeric components. The NRC revised
the scope of aging effects to include loss of material for all metallic materials and
changes in material properties for polymeric materials. The revised AMPs provide
details of the examination of polymeric materials using manual manipulation, provide
acceptance criteria for nonmetallic materials, and better define the acceptance criteria
for metallic materials.
- Flux Thimble Tube Inspection. The revision to AMP XI.M37, Flux Thimble Tube
Inspection, clarifies that this program is a condition-monitoring program, not an
inspection program. It also clarifies the scope of program terminology by stating that the
instrument guide tubes are not in the scope of this program (instrument guide tubes are
managed by the inservice inspection, water chemistry, and nickel-alloy AMPs). Finally,
the NRC revised the monitoring and trending and acceptance criteria elements to
clarify that licensees must base their examination frequencies and calculated wear rates
on actual plant-specific wear data. To this end, a methodology that includes sufficient
conservatism is necessary to ensure that acceptance criteria continue to be met
between scheduled inspections.
Page 6 of 9
- Neutron-Absorbing Materials Other than Boraflex. New AMP XI.M40, Monitoring of
Neutron-Absorbing Materials Other than Boraflex, is a monitoring program for each
neutron-absorbing material credited for criticality control in the spent fuel pool (other than
Boraflex, which is managed by the boraflex monitoring AMP). AMP XI.M40 implements
LR-ISG-2009-01, Aging Management of Spent Fuel Pool Neutron-Absorbing Materials
Other than Boraflex, issued April 2010.
- Buried Piping and Tanks. The GALL Report now combines the previous buried piping
and tanks surveillance program (AMP XI.M28) and the buried piping and tanks
inspection program (AMP XI.M34) to create a new program, AMP XI.M41, Buried and
Underground Piping and Tanks, that incorporates aspects of both of the previous
programs.
AMP XI.M41 increases the number of materials covered and recommends cathodic
protection for all materials covered by National Association of Corrosion Engineers
Standard Practice (SP)0169-2007, Control of External Corrosion on Underground or
Submerged Metallic Piping Systems, including steel, cast iron, copper, and aluminum.
This new AMP better defines inspection programs that vary based on plant-specific
factors, such as the quality of backfill around the piping and the use of cathodic
protection.
- Subsection IWE of Section XI, Rules for Inservice Inspection of Nuclear Power Plant
Components, of the ASME Code. The revision to AMP XI.S1, ASME Section XI,
Subsection IWE, incorporates LR-ISG-2006-01, Plant-Specific Aging Management
Program for Inaccessible Areas of Boiling Water Reactor Mark I Steel Containment
Drywell Shell, issued 2006, related to the monitoring of Mark 1 drywell corrosion. The
revision also augments the requirements in Subsection IWE to include surface
examinations to detect cracking in stainless steel penetration sleeves, dissimilar metal
welds, and steel components that are subject to cyclic loading but have no current
licensing-basis fatigue analysis.
- Masonry Walls. The revision to AMP XI.S5, Masonry Walls, includes changes that
better define degradation parameters. AMP XI.S5 also establishes an inspection
frequency of every 5 years (or more frequent if cracking is observed) instead of the
previous recommendation that was based on plant-specific operating experience.
- Structures Monitoring Program. The revision to AMP XI.S6, Structures Monitoring,
includes a new recommended frequency of inspections for the in-scope structures,
settlement monitoring, and inaccessible below-grade concrete. In addition, the revision
includes provisions for monitoring ground water chemistry, clarifies the use of relevant
codes and standards, and incorporates monitoring criteria for structural bolting and
elastomeric vibration isolation elements. Applicants that are not committed to American
Concrete Institute (ACI) Standard 349.3R and that elect to use plant-specific criteria for
concrete structures should describe the criteria and provide a technical basis for
deviations from those in ACI Standard 349.3R.
Page 7 of 9
- Protective Coating Monitoring and Maintenance. The revision to AMP XI.S8, Protective
Coating Monitoring and Maintenance Program, emphasizes the importance of coating
assessments for emergency core cooling system performance. The NRC increased the
scope of the program to include coatings on concrete in order to address all Service
Level 1 (at a minimum) coatings in containment.
- Inaccessible Power Cables Not Subject to the Environmental Qualification Requirements
in 10 CFR 50.49, Environmental Qualification of Electric Equipment Important to Safety
for Nuclear Power Plants. The revision to AMP XI.E3, Inaccessible Power Cables Not
Subject to 10 CFR 50.49 Environmental Qualification Requirements, increases the
scope to include 400-volt and above power cables. It also revises cable test frequencies
to at least once every 6 years, deemphasizes the degradation mechanism associated
with water treeing, and recommends consideration of water intrusion. The program
also removes the exclusion allowance of removing from scope those cables that are
energized 25 percent of the time or less. The program revision increases periodic
manhole inspection frequencies to at least annually, incorporates event-driven
inspections (heavy rain or flood events), and clarifies cable testing and manhole
inspection actions.
In summary, the NRC recommends that licensees review the recently issued changes to
Revision 2 of the GALL Report. It also encourages licensees with renewed operating licenses
to review the changes to the GALL Report and consider actions necessary to incorporate these
updates, as appropriate, into existing AMPs at their plants. Any licensee planning to submit a
license renewal application for renewal should consider the latest revision to the GALL Report
that is in effect at the time of submittal. The latest revision to the GALL Report can be found
under ADAMS Accession No. ML103490041 and at
http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1801/r2/.
BACKFIT DISCUSSION
This RIS requires no action or written response. Any action on the part of addressees to update
existing AMPs in accordance with the guidance that appears in this RIS or in Revision 2 to the
GALL Report is strictly voluntary. Therefore, this RIS does not constitute a backfit under
10 CFR 50.109, Backfitting, and the staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
The NRC did not publish a notice of opportunity for public comment on this RIS in the Federal
Register because the RIS is informational and because the agency has worked closely with
industry representatives from the Nuclear Energy Institute, members of the public, and other
stakeholders over a period of time on the development of Revision 2 of the GALL Report. As
appropriate, the NRC has solicited public comment on proposed activities and a draft version of
the GALL Report in the Federal Register and at public meetings.
Page 8 of 9
The schedule for the development of Revision 2 to the GALL Report can be found at
http://www.nrc.gov/reactors/operating/licensing/renewal/guidance/updated-guidance.html.
This site lists the dates of milestones, including public meetings and requests for comments,
that the agency met in the development of this revision to the GALL Report.
CONGRESSIONAL REVIEW ACT
The NRC has determined that this action is not a rule as designated by the Congressional
Review Act (5 U.S.C. 801-808) and, therefore, is not subject to the Act.
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not contain new or amended information collection requirements that are subject
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management
and Budget (OMB) approved existing information collections under OMB control
numbers 3150-0011 and 3150-0155.
PUBLIC PROTECTION NOTIFICATION
The NRC may not conduct or sponsor, and a person is not required to respond to, a request for
information or an information collection requirement unless the requesting document displays a
currently valid OMB control number.
Page 9 of 9
CONTACT
Please direct any questions about this matter to the technical contact listed below.
/RA by Robert A. Nelson for/
Timothy J. McGinty, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contact: Lisa M. Regner, Senior Project Manager
NRR/DLR/RPB2
(301) 415-1906
E-mail: lisa.regner@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under NRC Library/Document Collections
Page 9 of 9
CONTACT
Please direct any questions about this matter to the technical contact listed below.
/RA by Robert A. Nelson for/
Timothy J. McGinty, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contact: Lisa M. Regner, Senior Project Manager
NRR/DLR/RPB2
(301) 415-1906
E-mail: lisa.regner@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under NRC Library/Document Collections.
DISTRIBUTION:
PUBLIC ARP R/F RidsOeMailCenter RidsOgcMailCenter
RidsOIS
ADAMS Accession Number: ML11111A105 *concurrence via e-mail
OFFICE LA: NRR/DLR* NRR/DLR/RPB2 Tech Editor* NRR/DLR/RPB2 NRR/DLR/RAPB*
NAME SFigueroa LRegner KAzariah-Kribbs DWrona DPelton
DATE 04/26/2011 04/26/2011 05/04/2011 05/04/2011 05/16/2011
OFFICE NRR/DLR/RASB NRR/DLR/RARB NRR/DLR NRR/DORL OE*
NAME RAuluck ADias BHolian JGiitter NHilton
DATE 05/ 24/2011 05/16/2011 05/05/2011 05/ 19/2011 05/19/2011
OFFICE NRR/PMDA* OIS* OGC/NLO LA: NRR/DPR NRR/DPR/PGCB
NAME LHill TDonnell SUttal CHawes CMH LBanic
DATE 05/18/2011 05/24/2011 06/ 07/2011 06/29/2011 06/29/2011
OFFICE NRR/DPR/PGCB NRR/DPR
TMcGinty
NAME SRosenberg
RANelson for
DATE 06/30/2011 07/01/2011
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