ML12034A099
| ML12034A099 | |
| Person / Time | |
|---|---|
| Issue date: | 05/03/2012 |
| From: | Galloway M Division of License Renewal |
| To: | Gallagher M, Keys J Exelon Generation Co, Nuclear Energy Institute |
| Wise J 415-8489 | |
| Shared Package | |
| ML12034A131 | List: |
| References | |
| LR-ISG-2011-01 | |
| Download: ML12034A099 (6) | |
Text
May 3, 2012 Ms. Julie Y. Keys Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE, LR-ISG-2011-01, AGING MANAGEMENT OF STAINLESS STEEL STRUCTURES AND COMPONENTS IN TREATED BORATED WATER
Dear Ms. Keys:
On November 8, 2011, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (76 FR 69292) a request for public comment on Draft License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2011-01, Aging Management of Stainless Steel Structures and Components in Treated Borated Water. In response, the NRC received comments from the Nuclear Energy Institute by letter dated December 13, 2011, and Exelon Generation Company, LLC by letter dated December 14, 2011.
The Nuclear Energy Institute and Exelon submitted similar comments suggesting the expansion of the new guidance to chemical and volume control system piping and spent fuel pool racks for the aging management of loss of material and cracking, while also suggesting the withdrawal or revision of the new guidance for management of reduction of heat transfer in heat exchangers.
The NRC staff (the staff) incorporated the comments regarding the expansion of the new guidance to additional components for management of loss of material and cracking, because the staff considered these changes as providing important clarity to license renewal applicants.
However, the staff did not incorporate the comments regarding the withdrawal or revision of the new guidance for heat exchangers.
The comments regarding the heat exchanger guidance were that the proposed one-time inspection was either not necessary due to lack of operating experience with fouling of heat exchangers in the chemical and volume control system, or was not an appropriate aging management method due to the potential for inspection personnel to be exposed to significant radiation. The staff considers the one-time inspection approach as appropriate for components with limited operating experience of age-related degradation. If age-related degradation were known, the Generic Aging Lessons Learned (GALL) Report One-Time Inspection program recommends a periodic inspection approach. Also, the one-time inspection guidance does not preclude a license renewal applicant from proposing and justifying other aging management approaches that minimize dosage. For these reasons, the staff chose not to eliminate the new guidance for heat exchangers.
Enclosed is a copy of the final LR-ISG-2011-01 and the Federal Register notice announcing the issuance of the LR-ISG-2011-01.
J. Keys To inform other stakeholders of the issuance of LR-ISG-2011-01, courtesy copies of this letter are being sent to subscribers to an NRC electronic mailing list on general license renewal topics.
Sincerely,
/RA/
Melanie A. Galloway, Acting Director Division of License Renewal Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/encls: Reactor License Renewal Stakeholder Group Listserv
May 3, 2012 Mr. Michael P. Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE, LR-ISG-2011-01, AGING MANAGEMENT OF STAINLESS STEEL STRUCTURES AND COMPONENTS IN TREATED BORATED WATER
Dear Mr. Gallagher:
On November 8, 2011, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (76 FR 69292) a request for public comment on Draft License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2011-01, Aging Management of Stainless Steel Structures and Components in Treated Borated Water. In response, the NRC received comments from the Nuclear Energy Institute by letter dated December 13, 2011, and Exelon Generation Company, LLC by letter dated December 14, 2011.
The Nuclear Energy Institute and Exelon submitted similar comments suggesting the expansion of the new guidance to chemical and volume control system piping and spent fuel pool racks for the aging management of loss of material and cracking, while also suggesting the withdrawal or revision of the new guidance for management of reduction of heat transfer in heat exchangers.
The NRC staff (the staff) incorporated the comments regarding the expansion of the new guidance to additional components for management of loss of material and cracking, because the staff considered these changes as providing important clarity to license renewal applicants.
However, the staff did not incorporate the comments regarding the withdrawal or revision of the new guidance for heat exchangers.
The comments regarding the heat exchanger guidance were that the proposed one-time inspection was either not necessary due to lack of operating experience with fouling of heat exchangers in the chemical and volume control system, or was not an appropriate aging management method due to the potential for inspection personnel to be exposed to significant radiation. The staff considers the one-time inspection approach as appropriate for components with limited operating experience of age-related degradation. If age-related degradation were known, the Generic Aging Lessons Learned (GALL) Report One-Time Inspection program recommends a periodic inspection approach. Also, the one-time inspection guidance does not preclude a license renewal applicant from proposing and justifying other aging management approaches that minimize dosage. For these reasons, the staff chose not to eliminate the new guidance for heat exchangers.
Enclosed is a copy of the final LR-ISG-2011-01 and the Federal Register notice announcing the issuance of the LR-ISG-2011-01.
M. Gallagher To inform other stakeholders of the issuance of LR-ISG-2011-01, courtesy copies of this letter are being sent to subscribers to an NRC electronic mailing list on general license renewal topics.
Sincerely,
/RA/
Melanie A. Galloway, Acting Director Division of License Renewal Office of Nuclear Reactor Regulation
Enclosures:
As stated cc w/encls: Reactor License Renewal Stakeholder Group Listserv
Package: ML12034A131 Letter: ML12034A099 ISG: ML12034A047 FRN: ML12034A050 OFFICE LA:RPB1:DLR ME:RAPB:DLR PM:RPOB:DLR BC:RAPB:DLR NAME YEdmonds JWise EGettys RAuluck DATE 02/28/12 04/19/12 03/09/12 05/01/12 OFFICE BC:RPOB:DLR BC:ESGB:DE BC:CPNB:DE OGC (NLO)
NAME YDiaz-Sanabria GKulesa DAlley AGendelman DATE 04/02/12 03/27/12 03/16/12 05/01/12 OFFICE D:DLR NAME MGalloway DATE 05/03/12
Letter to Julie Y. Keys, et al. from Melanie A. Galloway dated May 3, 2012
SUBJECT:
FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE, LR-ISG-2011-01, AGING MANAGEMENT OF STAINLESS STEEL STRUCTURES AND COMPONENTS IN TREATED BORATED WATER DISTRIBUTION:
E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRapb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDra Resource RidsNrrDe Resource RidsNrrDss Resource RidsOgcMailCenter Resource RidsOpaMail Resource RidsOcaMailCenter Resource
EGettys JWise YDiaz-Sanabria JRivera,RII AStone, RIII NOKeefe, RIV RConte, RI