ML11356A317
| ML11356A317 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/21/2011 |
| From: | Mcginty T Office of Nuclear Reactor Regulation |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML11356A300 | List: |
| References | |
| RAS 21618, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 RIS-11-007 | |
| Download: ML11356A317 (8) | |
See also: RIS 2011-07
Text
NYS000310
Submitted: December 22, 2011
UNITED STATES
NUCLEAR REGULA TORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001
July 21, 2011
NRC REGULATORY ISSUE SUMMARY 2011-07
LICENSE RENEWAL SUBMITTAL INFORMATION FOR
PRESSURIZED WATER REACTOR INTERNALS AGING MANAGEMENT
ADDRESSEES
All holders of and applicants for a pressurized water power reactor operating license or
construction permit under Title 10 of the Code of Federal Regulations (10 CFR) Part 50,
"Domestic Licensing of Production and Utilization Facilities," except those that 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 inform addressees of updated NRC procedures for license renewal application (LRA) reviews
or the review of certain licensee submittals related to commitments made in the process of
receiving a renewed license. LRAs for pressurized water reactor (PWR) plants have identified
that an aging management program (AMP) is needed to manage the effects of aging for reactor
vessel internal (RVI) components that are within the scope of license renewal, in accordance
with 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power
Plants." This RIS requires no action or written response on the part of addressees. This RIS
also provides information to licensees with respect to how to meet their existing license renewal
commitments related to reactor vessel internals aging management programs, and on
acceptable changes to existing license renewal commitments in order to account for the recent
issue of the staff's final Safety Evaluation (SE) of MRP-227, Rev.O, and the forthcoming issue of
the approved version of MRP-227.
The purpose of this RIS is to facilitate a predictable and consistent method for reviewing the
AMPs of commercial PWR LRAs and the AMPs and inspection plans for PWR plants that have
received renewed operating licenses. This RIS does not transmit or imply any new or changed
requirements or staff positions. Although no specific action or written response is required, the
information contained in this RIS will enable licensees to plan effectively for anticipated LRAs
and inspection activities.
This RIS is part of the NRC's ongoing oversight of license renewal and is unrelated to the
agency's response to the March 11, 2011, earthquake in Japan.
OAGI0001161 00001
Page 2 of 7
BACKGROUND INFORMATION
In 10 CFR Part 54, the NRC addresses the requirements for plant LRAs. The regulation in
10 CFR 54.21, "Contents of Application-Technical Information," requires that each LRA
contain an integrated plant assessment and an evaluation of time-limited aging analyses. The
integrated plant assessment must identify and list those structures and components subject to
an aging management review (AMR) and must demonstrate that the effects of aging (such as
cracking, loss of material, loss of fracture toughness, dimensional changes, and loss of preload)
will be adequately managed so that the intended functions of the structures and components will
be maintained consistent with the current licensing basis for the period of extended operation as
required by 10 CFR 54.29(a). Structures and components subject to an AMR shall encompass
those structures and components (1) that perform an intended function, as described in
10 CFR 54.4, "Scope," without moving parts or without a change in configuration or properties,
and (2) that are not subject to replacement based on a qualified life or specified time period.
These structures and components are referred to as "passive" and "long-lived," respectively.
On April 26, 2001, the NRC issued N UREG-1801, "Generic Aging Lessons Learned (GALL)
Report," (Agencywide Documents Access and Management System (ADAMS) Accession Nos.
ML011080185 and ML011080393). On September 30, 2005, the NRC issued NUREG-1801,
Revision 1, "Generic Aging Lessons Learned (GALL) Report," (ADAMS Accession Nos.
ML052770419 and ML052780376). On December 31, 2010, the NRC issued NUREG-1801,
Revision 2, "Generic Aging Lessons Learned (GALL) Report," (ADAMS Accession No.
ML 103490041). The GALL Report provides generic AMRs of systems, structures, and
components that are within the scope of license renewal, as described in 10 CFR 54.4, and
provides generic AMPs that the staff has found acceptable to manage the effects of aging
identified in the AMR. As described in NUREG-1800, Revision 2, "Standard Review Plan for
Review of License Renewal Applications for Nuclear Power Plants" (ADAMS Accession No.
ML 103490036) (LR-SRP), treatment of the GALL Report as an approved topical report
improves the efficiency of the license renewal process.
An applicant may reference in its LRA that its AMPs are consistent with those in the GALL
Report. If an applicant takes credit for an AMP in the GALL Report, it is incumbent on the
applicant to ensure that the conditions and operating experience at the plant are bounded by
those for which the AMP in the GALL Report was evaluated and found acceptable. In such a
case, the NRC staff's review of the AMP is limited to verifying that the applicant's AMP is
consistent with that provided in the GALL Report, including the conditions and operating
experience provided in the GALL Report.
If the applicant's conditions and operating experience are not bounded by those of the GALL
Report AMP, it is incumbent on the applicant to address the additional effects of aging that may
apply to the applicant's facility and supplement the GALL Report AMR line items and AMPs as
necessary. The staff's review then addresses the acceptability of the AMR and the AMPs to be
used by the applicant.
Revision 1 of the GALL Report provides AMP XI.M16, "PWR Vessel Internals," which refers to
the aging management guidance of the AMR line items for RVI components. Within the context
OAGI0001161 00002
Page 3 of 7
of this RIS, NRC license renewals, theSE for MRP-227 and other NRC licensing actions, "RVI"
refers to reactor vessel internals. In recognition that the industry was conducting programs to
investigate aging of RVI components and to develop aging management guidelines for RVI
components, the AMR line items for RVI components state that:
No further aging management review is necessary if the applicant provides a
commitment in the FSAR [final safety analysis report] supplement to (1) participate in the
industry programs for investigating and managing aging effects on reactor internals; (2)
evaluate and implement the results of the industry programs as applicable to the reactor
internals; and (3) upon completion of these programs, but not less than 24 months
before entering the period of extended operation, submit an inspection plan for reactor
internals to the NRC for review and approval.
Each licensee that made a commitment to conform to GALL AMP XI.M16, or an equivalent
commitment under the 2001 GALL Report, also made a commitment in its FSAR supplement
that it will implement a plant-specific AMP for its RVI components based on the industry-
developed guidance.
On January 12, 2009, the Electric Power Research Institute (EPRI) submitted for NRC staff
review and approval the Materials Reliability Program (MRP) Report 1016596 (MRP-227),
Revision 0, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines"
(ADAMS Accession No. ML090160204). MRP-227 is the industry-developed guidance that
licensees will use to develop their plant-specific AMP for RVI components. MRP-227,
Revision 0 contains a discussion of the technical basis for the development of plant-specific
AMPs for RVI components in PWR vessels. MRP-227, Revision 0 also provides inspection and
evaluation guidelines for PWR licensees to use in their plant-specific AMPs. Once approved by
the NRC, MRP-227 will provide the basis for renewed license holders to develop plant-specific
inspection plans to manage aging effects on RVI components, as described by their FSAR
commitment.
The scope of components considered for inspection under the guidance of MRP-227,
Revision 0 includes core support structures (typically denoted as Examination Category B-N-3
by Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel
Code), and those RVI components that serve an intended safety function consistent with the
criteria in 10 CFR 54.4(a)(1). The scope of the program does not include consumable items
such as fuel assemblies, reactivity control assemblies, and nuclear instrumentation because
these components are not subject to an AMR, as defined in 10 CFR 54.21(a)(1).
On June 22, 2011, the NRC issued its final SE regarding topical report MRP-227, Revision 0
(ADAMS Accession No. ML 111600498), which license renewal applicants and renewed license
holders will use to develop their plant-specific AMPs for RVI components. This SE contains
specific conditions on the use of the topical report and applicant/licensee action items that must
be addressed by those utilizing the topical report as the basis for a submittal to the NRC. The
NRC approved version of the topical report is designated as MRP-227-A.
Subsequent to the submittal of MRP-227 and prior to the issuance of theSE on MRP-227,
GALL Report, Revision 2 was issued, providing new AMR line items and aging management
OAGI0001161 00003
Page 4 of 7
guidance in AMP XI.M16A, "PWR Vessel Internals." This AMP was based on staff expectations
for the guidance to be provided in MRP-227-A. After December 21, 2010, any licensees
submitting an LRA were encouraged to reference and utilize GALL Report, Revision 2 to
manage the effects of aging identified in the AMR. With the issuance of theSE for MRP-227,
the NRC will issue License Renewal Interim Staff Guidance (LR-ISG) to revise the GALL Report
AMR line items and AMP XI.M.16A for consistency with theSE and to reflect acceptability of the
MRP-227-A report for use in license renewal applications.
SUMMARY OF ISSUE
The NRC granted renewed licenses to some owners of PWR units based on a commitment in
the FSAR supplement to, in part, submit an inspection plan for RVI components to the NRC for
review and approval. This plan was to be based on aging management guidelines for RVI
components developed by the industry and approved by the NRC. This commitment in the
FSAR would require those licensees to review and update their aging management inspection
plans for RVI components based on the guidance provided in MRP-227-A.
With the issuance of the staff SE for MRP-227, the NRC has updated internal guidance on
implementation of this RVI component AMP guidance relative to license renewal for PWR plants
on a plant-specific basis, as indicated in the following table for the plants in Categories "A"
through "D." The different plant categories reflect the licensee's status relative to license
renewal approval (i.e., licensee has received a renewed license, has submitted an LRA, or has
not), and, for those plants with renewed licenses, whether the licensee has or has not submitted
its inspection plan to the NRC for review and approval.
Category "A" facilities address licensees that previously submitted an RVI inspection plan based
on the draft Revision 0 of MRP-227. Licensees of Category "A" facilities, those that made a
commitment in the FSAR supplement to comply with the industry-developed guidance and
choose to withdraw their inspection plans to conform to their commitments, must do so in writing
and should include a commitment to resubmit the required information based on MRP-227-A, no
later than October 1, 2012. Licensees of Category "A" facilities who propose in their resubmittal
to deviate from provisions of MRP-227-A based upon having completed specific inspections, will
need to provide a justification for each deviation from the MRP-227-A guidelines. The NRC will
evaluate proposed deviations from the MRP-227-A guidelines to ensure that licensee programs
will still provide an acceptable approach for managing the effects of aging in RVI components.
This will ensure compliance with the commitment in the FSAR supplement.
Licensees of Category "B" facilities that have committed to follow the industry-developed
guidance, will be expected to make the submittal of their RVI AMP based on the guidance of
MRP-227-A, consistent with their commitment. Licensees of Category "B" facilities who are
required by their commitments to submit their RVI inspection plan prior to one year after the
issuance of this RIS may modify their commitments to submit their RVI inspection plan no later
than October 1, 2012. All other Category "B" facility licensees will be expected to make the
submittal of their RVI AMP in accordance with their existing commitments. This will ensure
compliance with the commitment in the FSAR supplement.
OAGI0001161 00004
Page 5 of 7
For those PWR plants that have an LRA currently under review (as addressed in Category "C")
with a commitment to follow the industry-developed guidance, the NRC staff expects the
applicant to revise the commitment for aging management of PWR vessel internals such that
the plant-specific action items identified in theSE for MRP-227 would be submitted to the NRC
for review and approval not later than two years after issuance of the renewed license and not
later than two years before the plant enters the period of extended operation, whichever comes
first. It is expected that Category C licensees will follow the guidance of MRP-227-A, consistent
with their commitment.
For those PWR plant licensees that have not submitted their LRAs (as addressed in Category
"D") but plan to submit an LRA in the future, the NRC staff encourages these future license
renewal applicants to, and anticipates that the applicant will, provide an AMP for vessel internals
in their LRA that is consistent with MRP-227-A. As described previously, the NRC will issue an
LR-ISG to revise the GALL Report to ensure that GALL AMP XI.M16A, "PWR Vessel Internals,"
and associated AMR line items are consistent with theSE on MRP-227 and reflect acceptability
of the MRP-227-A report for use in license renewal applications. It is expected that all
Category D LRAs will meet GALL Revision 2 as updated by the LR-ISG.
If a license renewal applicant confirms that it will implement an AMP consistent with
MRP-227-A, Licensee/Applicant Action Item 8 from the NRC staff SE (Section 3.5.1) indicates
that the LRA shall include, in part, an AMP that addresses the 10 program elements as defined
in AMP XI.M16A, and an inspection plan. The NRC review of an AMP which is consistent with
GALL AMP XI.M16A would include those items specifically identified in Section 4.0 of theSE.
Category Description NRC Expectations
Licensees may withdraw their current
Plants with renewed licenses that AMP/inspection plan submittals and provide
have already submitted an new/revised commitments to resubmit
A AMP/inspection plan based on AMPs/inspection plans in accordance with
MRP-227, Revision 0 to comply MRP-227-A no later than October 1, 2012.
with an existing commitment. Future submittals should address all
information required by MRP-227-A.
Licensees will be expected to submit
AMPs/inspection plans in accordance with
MRP-227-A, consistent with the timing
Plants with renewed licenses that
requirements reflected in their LR
have a commitment to submit an
commitments. Licensees who would be
AMP/inspection plan based on
B required by their commitments to make their
MRP-227, but that have not yet
submittal prior to one year after the issuance
been required to do so by their
of this RIS may modify their commitments to
commitment.
reflect a requirement to submit their
AMPs/inspection plans no later than
October 1, 2012.
OAGI0001161 00005
Page 6 of 7
Applicants will be expected to revise their
commitment for aging management of PWR
vessel internals such that the submittal
information identified in the SE for MRP-227
Plants that have an LRA currently would be submitted to the NRC for review
c under review. and approval not later than two years after
issuance of the renewed license and not later
than two years before the plant enters the
period of extended operation, whichever
comes first.
Applicants will be expected to submit an AMP
Plants that will apply for an LR in
for vessel internals that is consistent with
D the future based on the GALL
MRP-227-A for NRC staff review and
Report, Revision 2.
approval.
BACKFIT DISCUSSION
This RIS is being issued to inform stakeholders of the implementation of updated internal NRC
guidance for staff in performing reviews of LRAs with AMPs. The backfit rule applies to
procedures necessary to operate a nuclear power plant. The NRC's regulatory review process
is not a licensee procedure required for operating the plant.
This RIS requires no action or written response. The intent is to provide licensees sufficient
time to modify their AMPs to be consistent with MRP-227-A. This RIS provides information to
licensees regarding (1) updated NRC procedures for LRA reviews or the review of certain
licensee submittals related to commitments made in the process of receiving a renewed license
and (2) the potential for licensees to modify the original commitment date for the submittal of a
RVI AMP for their facilities. The technical position of GALL Rev. 2 has not changed.
Compliance with the guidelines specified in MRP-227-A would satisfy a licensee's license
renewal commitment. For those applicants following GALL Rev. 1, which provided no definition
on the RVI AMP, other than following the industry's future program, this RIS provides
clarification as to what an acceptable RVI AMP would be in light of the issuance of the staff SE
of MRP-227. Any action on the part of addressees to submit a request for a licensing action or
to adhere to the industry guidance contained in the EPRI's MRP-227-A guidance document is
strictly voluntary. Any changes to a licensees' AMP/inspection plan to adhere to MRP 227-A,
ensures compliance with a license commitment. Therefore, this RIS does not constitute a
backfit under 10 CFR 50.109, "Backfitting," and a backfit analysis is not required.
FEDERAL REGISTER NOTIFICATION
This RIS is informational and does not represent a departure from current regulatory
requirements. The NRC did not publish a notice of opportunity for public comment on this RIS
in the Federal Register because the RIS pertains to an administrative aspect of the regulatory
process that involves the voluntary use of industry guidance by addressees. However, on
OAGI0001161 00006
Page 7 of 7
June 13, 2011, the NRC posted a draft version of this RIS on its public website for a 10-day
public comment period. Comments were received from the industry's Materials Reliability
Program (ADAMS Accession No. ML 11188A 162) and considered.
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.). Existing requirements were
approved by the Office of Management and Budget (OMB), approval number 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.
CONTACT
Please direct any questions about this matter to the technical contact listed below.
IRA/
Timothy J. McGinty, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contact: Sheldon D. Stuchell, Senior Project Manager
NRR/DPR/PLPB
(301) 415-1487
E-mail: sheldon.stuchell@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site,
http://www.nrc.gov, under NRC Library/Document Collections.
OAGI0001161 00007
ML 11188A 162) and considered.
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.). Existing requirements were
approved by the Office of Management and Budget (OMB), approval number 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.
CONTACT
Please direct any questions about this matter to the technical contact listed below.
IRA/
Timothy J. McGinty, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contact: Sheldon D. Stuchell, Senior Project Manager
NRR/DPR/PLPB
(301) 415-1487
E-mail: sheldon.stuchell@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: MMitchell, NRR MEvans, NRR BHolian, NRR AHiser, NRR
ADAMS Accession Number: ML 111990086 *via e-mail TAC ME5988
OFFICE NRR/DPR/PLPB/PM Tech Editor NRR/DCI/CVIB/BC NRR/DPR/PLPB/BC NRR/PMDA
NAME SStuchell* JDougherty* MMitchell* JJolicoeur LHill*
DATE 05/18/11 04/08/11 04/22/11 04/22/11 04/25/11
OFFICE OE OIS NRR/DORL/D NRR/DCI/D NRR/DLR/D
MEvans (JLubinski
NAME NHilton* TDonnell* JGiitter* BHolian*
for)
DATE 05/16/11 04/28/11 05/16/11 05/04/11 04/29/11
NRR/DPR/PGCB/
OFFICE OGC NRR/DPR/PGCB/PM NRR/DPR/PGCB/BC NRR/DPR/D
LA
NAME MSmith* (NLO) CHawes ARussell SRosenberg TMcGinty
DATE 06/02/11 07/18/11 07/18/11 07/19/11 07/21/11