ML12349A386
| ML12349A386 | |
| Person / Time | |
|---|---|
| Issue date: | 04/19/2013 |
| From: | John Lubinski Division of License Renewal |
| To: | Remer J Nuclear Energy Institute |
| Gavula J 630-829-9755 | |
| Shared Package | |
| ML13023A455 | List: |
| References | |
| LR-ISG-2012-01 | |
| Download: ML12349A386 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 19, 2013 Mr. Jason Remer Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
FINAL LICENSE RENEWAL INTERIM STAFF GUIDANCE, LR-ISG-2012-01, "WALL THINNING DUE TO EROSION MECHANISMS"
Dear Mr. Remer:
On July 13, 2012, the U.S. Nuclear Regulatory Commission (NRC) published in the Federal Register (77 FR 41457) a request for public comment on Draft License Renewal Interim Staff Guidance (LR-ISG), LR-ISG-2012-01, "Wall Thinning Due to Erosion Mechanisms." In response, the Nuclear Energy Institute (NEI) submitted comments by letter dated August 27,2012, which integrated several industry comments on the subject LR-ISG.
NEI broadly recommended that the NRC create a separate aging management program for mechanical erosion mechanisms, rather than mixing it into the existing Flow-Accelerated Corrosion program. NEI indicated that the industry believes that the proposed LR-ISG would cause confusion in the existing Flow-Accelerated Corrosion programs because the addition of erosion mechanisms would introduce different susceptibility criteria and separate inspection selection methods and strategies.
The NRC staff considered these comments in developing the final LR-ISG, but ultimately determined that the LR-ISG should be published in its current format. The staff notes that it initiated this LR-ISG because applicants were managing loss of material due to various erosion mechanisms, but there were no corresponding aging management review (AMR) items in license renewal guidance documents. The staff also notes that no applicant has ever proposed a separate aging management program to address erosion mechanisms in any previously submitted license renewal application. However, applicants have included aging management activities for erosion mechanisms within either their Flow-Accelerated Corrosion or the Open-Cycle Cooling Water System programs. The NRC staff has approved both approaches in previously issued Safety Evaluation Reports, and in that regard, this LR-ISG is consistent with existing industry and NRC practice. The staff further notes that it has not detected any confusion, as postulated by the industry, on the part of applicants that have chosen to include erosion mechanisms in the Flow Accelerated Corrosion program. Although the LR-ISG includes erosion mechanisms in the Flow Accelerated Corrosion program, this does not preclude applicants from managing these activities through alternate programs (either an existing program with appropriate enhancements, or a plant specific program) or by using a standard note E designation for AMR items, as prescribed in NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule."
There were two other broad categories of industry comments that the staff feels obligated to address here. First, the industry commented that erosion mechanisms are the result of deSign deficiencies, malfunctioning equipment, or abnormal system operation, and are not aging related degradation and thus they need not be managed for license renewal. The staff notes that the
J. Remer
- 2 related aging effect is loss of material, and in some cases applicants have chosen to manage this aging effect instead of making design or operational changes to eliminate or correct the underlying problem. It is the applicant's choice to manage the resulting loss of material through ongoing monitoring activities that cause these activities to be included in AMRS. Second, the industry commented that inclusion of erosion mechanisms would greatly increase the scope of the Flow Accelerated Corrosion program. This LR-ISG does not change any of the existing guidance for system susceptibility or inspection scoping provided in the Nuclear Safety Analysis Center (NSAC) 202L, "Recommendations for an Effective Flow-Accelerated Corrosion Program."
Enclosed is a copy of the final LR-ISG-2012-01 and the Federal Register notice announcing the issuance of LR-ISG-2012-01.
To inform other stakeholders of the issuance of LR-ISG-2012-01, courtesy copies of this letter are being sent to subscribers of an NRC electronic mailing list on general license renewal topics.
Sincerely, l!:J~!l/!!!::f Division of License Renewal
~
Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/encl: Reactor License Renewal Stakeholder Group Listserv
Sincerely, IRA by Melanie A. Galloway fori John W. Lubinski, Director Division of License Renewal Office of Nuclear Reactor Regulation RidsNrrDss Resource RidsOgcMailCenter Resource RidsOpaMaii Resource RidsOcaMailCenter Resource JGavula, NRR JWise, NRR RConte, RI JRivera, RII AStone, Rill NO'Keefe, RIV ML13023A455 Packa e, ML12349A386 Letter, ML12352A057 OFFICE ME:DLR:RAPB*
LA:DLR:RPB2*
JGavula IKing 12/14/12 1123/13 BC:DE:EPNB CE BC:DE:ESGB TLupold GKulesa 3/25/13
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LR-ISG ML12352A058 FRN PM:DLR:RPOB 3/8/13 *