ML19332D371
| ML19332D371 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1989 |
| From: | NRC |
| To: | |
| References | |
| FRN-55FR29043 AD04-1-017, AD4-1, AD4-1-17, NUDOCS 8912010086 | |
| Download: ML19332D371 (61) | |
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Nuclear = Regulatory Commission-fls Public Workshop' on Technical and
Title:
Policy considerations'ror Nuclear-
' Power Plant License Renewal:
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. Fluid and Mechanical System-p Docket No.
SESSION 3 L
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PUBLIC WORKSHOP
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7 TECHNICAL AND POLICY CONSIDERATIONS 8
FOR 9~
NUCLEAR POWER PLANT LICENSE RENEWAL 10 11-12 Session 3
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.Q 13' FLUID AND MECHANICAL SYSTEM 14
~15 16 Sheraton Resort Hotel 17 Conference Rooms A, B and C
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11810 Sunrise Valley Drive 19 Reston, Virginia 20 r
21 22 Monday, November 13, 1989 L
23 1:15 o' clock p.m.
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-1 SESSION LEADERS:
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2-Milton Vagins, Chief, Electrical'and Mechanical.
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3 Engineering Branch, Division of Engineering 4
Jarad Wermiel, Plant Systems Branch,. Division of 5'
System Technology i
6 PARTICIPANTS:
i 7
Joseph McCumber, Yankee Atomic 8
Bruce Snow,,NUMARC 9
Richard Burke, EPRI 10 Owen Rothberg, NRC 11 Rhonda Doney, Combustion Engineering 12 Curt Cousins, NUMARC j-s -
( j 13 Dan Leonard, Multiple Dynamics 14 Dave Eissenberg, Oak Ridge National Lab 15 16 17, 18 19 P
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3E MR. VAGINS:
Let me take care of some housekeeping l
4 things-first.
First, let me introduce myself.
My name is 5
Milton Vagins.
I'm the Branch Chief of the Electrical and 6
Mechanical Engineering Branch, the Office of Research.- My co-7 chairman is Jarad Wermiel, with a "W" not a "V," from NRR.
8 Now, you'll see me speaking into this phantom mic, 9
and you won't hear anything on speakers.
The reason for that 10 is that the mic is connected up to the court reporter.
He'll 11 be wearing the-earphones; he needs the mic to hear properly.
r 12 So all speakers will be asked to talk into this mic, even
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13 though you won't hear anything.
I 14 Some more housekeeping.
I want to remind everybody 15 that all the sessions, including this morning, are being 16 recorded.-
A-transcription will be available from Ann Riley: &
17 Associates, 1612, that's 1-6-1-2, K Street, Northwest, Suite 18 300, Washington, DC, 20006, and they'll be ready approximately l
19
'one week from today.
You can send in your request earlier; 20 whenever they get them ready, they'll send them out to you.
-21 I also ask that speakers later on give us a copy of'
-22 your overheads or whatever you have.
The court reporter needs E
23 them and so do we.
24 Okay.
With that, I'll launch right into the session.
25 This is Session 3, called Fluid and Mechanical Systems of l
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1-Interest.
I'll'begin by just noting, first, something you
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' won't see'on the board.
I'm going to repeat the basic I
3' underlying premise of NRC's purpose in license renewal.
It's
~4 put into four words:
Assurance of continued safe operation.
j 5-The whole premise of license renewal isLassurance of continued v
6 safe operation, regardless of the licensing period.
We are not 7
going to ask for enhanced safety, just continued safe 8
operation.
9 This will be repeated in several of the sess' ions.
10 It's basically four common items of approach to the scope of 11 technical issues.
12 One:
The first element defines a proposed screening Lj/s,)-
13 process for_ equipment and structures to be reviewed.
The i'
14 screening process-is extremely important.
15 Two:
Defines structure systems and components for 16 evaluation.
17 Three:
Defines a specific ets of degradation 18 mechanisms for evaluation.
19 Four:
Defines requirement for corrective action when 20 degradation is not being monitored.
In other words, if we 21 define degradation as a continuing process, that's well within 22' our design envelope, and we can monitor it to a specific point 23
-at which we will either refurbish or replace.
That is a
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24 perfectly acceptable procedure.
25 All right.
Now, before I launch into the questions
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Fluid mechanical systems of interest.
Let's define 4
that. _These fluid and mechanical' systems relied upon for the 5
integrity of the reactor coolant pressure boundary, safe 6
shutdown, and accident prevention and mitigation.
Anything 7
that does that is the first level of concern.
e 8
In this area, for example -- this is not an all-9 inclusive list -- ycu.might find, in a PWR, this list of items.
'10 There might be more.
Obviously, reactor coolant pressure 11 boundary, which is being covered next door; service water L
12 system; component cooling water system; emergency core cooling h %k) 13 system; residual heat removal system; chemical volume and L
14-control' system; fuel pool structure and cooling system.
That 15 should be P-0-R-Vs, not R-Vs.
I don't know where that came 16 from.
That's pressure operator relief valves; block valves; 1
l 17 and interconnected piping; seismic Category 1 piping; raceways; 18
. hangars; supports; auxiliary feedwater systems; controlled rod 1
L 19 drive systems.
Some of the obvious systems which may or may l
20 not be subject to aging degradation.
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'21 In a BWR, similar list, again reactor coolant 22 pressure boundary system; standby-liquid control system; 23 reactor core isolation cooling system; high pressure cool and l
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24 injection syctem; residual heat removal system; emergency
- C 25 equipment cooling; fuel pool structure and cooling system; and
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1 control rod drive systems.
Again, just an example of what we
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2 mean_by fluid and mechanical systems.
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3-Again, let me emphasize,- these may not be subject, L
.4-not ' all _'subj ect, t'o aging degradation, but I will say that they
-5 all are subject of the aging research program being conducted 6
by the NRC.
7' All right.
With that in mind, there is a second
.8 category of systems of interest that you might think of as the 9
frontend, or those -- the failure of which may challenge the 10 system that we are interested in, and not normally come under
-11 any regulatory process prior to license renewal.al.
12 These fluid and mechanical systems whose failure can f
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l 14 significantly challenges structures, systems, and components 15-which are relied upon for the integrity of the reactor coolant 16 pressure boundary system and safe shutdown or accident l
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18 In other words, we not only want to look at the 19 safety related system, or those systems necessary to cause a
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20 safe shutdown, but we want to look at those systems which can l-21 cause a challenge to these systems.
The exact way we're going 22 to handle that is not completely defined just yet, but you'll 23 find most of these, of course, in balance of plant.
And we
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24 have the common state feedwater system, including reheat; the V
25 turban; the main steam system; the condenser cooling system; 7
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Particulary, we're looking again, f
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2 and I'll say:it again, at balance of plant systems, which 3
normally are not regulated.
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We put out a list of questions which was in the 5
Federal Register, and just summarizing them, or paraphrasing 6
them in very simple terms -- actually -- I'm sorry --:they'
-i 17 weren't in the Federal Register; they were in a letter-we sent 8
out for this meeting.
It was in a letter.
Basically, we have 9
identified seven questions which we would like to have some l
i 10 answers on.
11 The first one is:
What additional criteria for
-12 periodic surveillance and preventive maintenance to ensure operability of mechanical equipment beyond initial design life?
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14 In other words, are there areas that you can think of that 15 require additional either surveillance, monitoring trending,-or 16 preventive maintenance programs identified as such?
17 Do we need, in certain areas, augmented inspections 18 and/or analysis to address aging mechanisms in pumps and 19 valves?
Now, we all know we have problems with pumps and 20 valves today, and I'm not talking about today's problems.
I 21 This question itself may eventually be answered by lb 22 our attempts to update the ISTs.
There's an industry-wide 23 effort going on.
I don't have to identify those.
You know it.
24 I know it.
That may be taken care of, but the question is
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25 still valid.
Since we don't have the whole answer for ISTs,
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thatfquestion_ remains up there.
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2J This question came up over and over again in several 3
meetings:
Should there be' functional pretests for our systems 4-as'a. prerequisite for license renewal?al?
5 Remember, these are just questions to' stir interest.
6
- They're not reallylpart of a rule-making now.
- 7 Fatigue.- Well, we all-know the problem with fatigue.
~8 Those of us-who do design structures, piping systems 9
particularly, know we started back at the end of life and-10 worked our way_back.
Things were designed to last 40 years.-
11 Some items have fatigue problems.
112 Residual fatigue life for Class 2 and 3 components ---
i 13 there was no fatigue analysis done on them.
What do we do now
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14-when we go into extended life?
l 15 Effects of water, environment, elevated. temperatures, 16 or fatigue on life of piping components?
There does exist l
1 17-evidence that the so-called safety margins and the SM curves in 18 Section III have been eroded due to the high temperature water l-L 19 environment.
The question is, what do we do about that?
Is j
20 there time to do anything about it in the period we have now, 1
L 21 or do we note that, move on, and correct it when we have the 22 data available?
23 Proof testing and hot functional testing.
- Again, e
24 this goes back to the question of -- these two are really tied 25 together:
three and seven.
Should we have another baseline
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for all equipment?
L /.~NL And you ain't going to get me to defend a
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.that we should.
I'm just asking the question rhetorically 3
because it:has been raised.
4 Those are the basic summation of those questions-
-5 which were not in the letter, and-any other questions.will be 6
brought up and addressed.
I'm perfectly willing to address any 7'
and all of them.
We have three speakers who are scheduled'to 8
speak.
Before I go on, do we have any speakers who would like 9
to speak now who are not listed?
l-1 10 (No response.]
11 MR. VAGINS:
No?
Well, it might be a short. session.
12 All right.
With that in mind, I'll.go right into the first
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13 speaker, though I will address any questions raised to my L
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14 little introduction.
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MR. McCUMBER:
I'm Joseph McCumber with Yankee 16 Atomic. : Will we be given the opportunity to respond to the 17 questions following the presentation, or does that have to be 18.
done now?
19 MR. VAGINS:
No.
20 If you are following the three designated speakers, 21 you can speak as needed.
Hopefully, it will be on the topic.
22 Okay.
Let me get into the first speaker, then.
It 23 is just identified as NUMARC.
Who is speaking for NUMARC?
24 MR. SNOW:
Good afternoon.
My name is Bruce Snow.
25 And I am speaking to you today representing the NUMARC NUPLEX
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I am employed by the Rochester Gas & Electric 1
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3 nuclear, fossil, hydro and facilities engineering.
RG&E. owns 4
' and operates Ginna Station, which just completed.its second ten
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6 My purpose this afternoon is to. provide the NUMARC 7
NUPLEX working group conclusions with. regard to fluid' systems, 8
fluid and' mechanical systems.
9 In general, we have concluded that it is not
'10 mandatory for a regulatory guide, for evaluation of fluid and 11 mechanical systems, to be developed.
L 12 Topical reports should be sufficient, we believe.
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13 will describe these topical reports in a moment.
1; 14 However, it is our opinion that a regulatory guide 15 would be acceptable with the following. conditions:
16.
One, if a regulatory guide was developed, it would be 17' beneficial for the NRC to take advantage of the analyses and 18 conclusions which industry has developed in.the NUMARC NUPLEX 19 working group inuustry reports; 20 These reports are currently submitted, or in a 21 process of being developed, on reactor pressure boundary l:
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22 elements; 23 Two, the outlined conceptual rule presented in the
- 49 24 Federal Register is revised to reflect the philosophical 1
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25 positions discussed in the Federal Register, that is, credit is l
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Il given for ongoing NRC requirements and/or license programs, and Q
'2 that'the guide only require addressing significant. age-related 3-degradation issues; and 9
4-Three, that a regulatory guide not delay the lead 5
. plant activities.
6 The specific topical ~ reports for the fluid and 7
mechanical systems being developed are, BWR' primary pressure
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-8 boundary, PWR reactor coolant system, PWR pressure vessel, BWR 9
These reports are currently' scheduled 10 for completion by August of 1990.
11-The general outline of the industry reports-provides 12 the following process:
a determination of systems, structures, (3
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13 components, and components that are safety-significant, a l
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-description of all plausible aging degradation mechanisms, a 15 determination which age-related degradations are potentially 16
.significant, and then, logically, for potentially significant l
1 17 age-related degradation, a determination of the established 18 inspection, testing, or analysis procedures currently 19 implemented demonstrate that age-related degradation is bounded 20_
within acceptable limits, and further, and again logically,
-21 that for any significant age-related degradation beyond 22 established limits, degradation management activities are 23 required.
24 This process supports the philosophy that the current l
25 licensing basis provides for the safe operation of our nuclear l
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'The working group conclusions with regard to specific 3
. aspects of fluid and mechanical systems are as-follows:
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-Most mechanical systems do not have_an_ explicit 5
design life, but proper maintenance allows achievement of 6
operating life.
Typically, components are tested, inspected, t
7 repaired, or refurbished at intervals less than the original 8
license term.
In fact, many components are replaced within the 9
original ~ license term.
10 Aging occurs at all times during equipment life.
11 Aging is.not unique after a 40-year period.
Most components 12 are' currently addressed by NRC or license programs which are
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'13' effective now and will continue to be so during an extended 14 operating term.
15 With respect to fatigue, I may add that a NUMARC ad.
16 hoc committee on fatigue has recently been formed and just met 17 with the first time last week in Orlando.
18 The few components subject to potential significant 19 age-related degradations that are not currently'being managed 20 by effective programs can be shown to remain effective in the 21 extended term.
However, it will require aging management 22.
strategies to properly address the issue posed solely by the 23 extended operating life.
24 Aging management options addressing this limited set 25 of systems, structures, and components are detailed in the
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methodology to evaluate plant equipment for license renewal 1
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which has been submitted to the NRC by;NUMARC or in the 3
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. industry reports which are currently being prepared by NUMARC.
Many plausible aging degradation mechanisms are not r
S significant.
For example, general corrosion of primary coolant-6 pump and valve components are insignificant based on. inherent 7
corrosion resistance material properties of stainless steel.
8-Also, fluid velocities within PWR reactor coolant 9
pumps are not sufficient to cause erosion of the surface c
10 materials.
11 High alloy steels,' nickel-based alloys, and stainless 12 steel alloys are considered to be quite resistant:to erosion
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. corrosion, especially in a PWR environment.-
14 We conclude that most potentially significant age-15 related degradation mechanisms are currently ma naged by 1 <6 effective programs.
In-service testing programs are currently
.17 performed at the plants in accordance with ASME p mp and valve 18' provisions of IWP and IWL.
Existing plant programs regarding 19 maintenance supplement these programs as well.
And 20 furthermore, technical specifications mandate surveillance and 21 inspections which are governed by ANSI and ASME codes.
22 We believe there is no apparent need for imposing 23 additional surveillance maintenance inspections nor analysis of
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24 functional tests as a prerequisite to license renewal.
It is V
25 the working group's conclusion that the outlined conceptual
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1 rule.needs to reflect the NRC philosophical position, that is, (b--) ~-
.2 credit is given for ongoing NRC requirements and/or license 3
programs,-such as ISI,'IST, and so forth.
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4 The rule need only address significant age-related 5
degradation.
16 That concludes my remarks.
7 MR. VAGINS:
Thank you.
8 I will entertain questions to the speaker's 9
presentation, if there are-any.
10 Dr. Eisenberg?
11 MR. EISENBERG:
When you mention IST, are you 12 referring to the results of the current ASME-IST effort that is
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.just starting or are you referring-to existing IST as embodied 14 in IWV and IWP?
15 MR. SNOW:
If I understand the question, the 16 question is whether we are referring to the existing IST 17 requirements or the ongoing development for new requiremento.
18
'I think I can respond to that by saying, the 19 philosophy of current licensing basis will be adequate to 20 provide safe operation will fit that development.
So as things 21 are currently required, it is okay now.
But if things are 22 required to be augmented, then that's okay, too.
23 So the whole philosophy of the current licensing 24 basis, I think, we support.
25 MR. VAGINS:
Thank you.
l
I 15-1 I think this is a good time to re-emphasize again I,_Y
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2-that license renewal will not attack today's problems.
3 Today's problems are not an issue for license 1
4 renewal.
We all know the weaknesses in the present IST program 5
for. pumps and valves.
.We, the NRC, the industry, the 6
professional societies, we are all addressing this.
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7 And hopefully, the IST upgrade will be in place, and 8
will apply.
9 So all the way through the concept of license 10 renewal,.today's problems are to be solved today, even if they 11 are aging related.
The NRC has a very extensive aging program.
12 And if I find something which is going to go defunct er belly-j )
13' up when it'is 38 and a half years old, we will act under the
'14 present licensing basis, and be corrected.
15 So again, understand that what we are11ooking for are 16 those things which are not covered by the present licensing 17 basis, particulary aging related.
Today's problems will be 18 handled today, or within the relatively near future.
19 And that, I think, agrees with the speaker's 20 viewpoint.
21 okay.
The next speaker will be somebody from the 22 Northern States Power.
Do we have a speaker?
Decided not to
- :2 3 come.
They said this piece this morning, right?
Right.
24 Yankee Atomic.
Okay.
Good.
I thought, for a 25 minute, it was going to turn out to be the shortest session in
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'2 MR. McCUMBER:
No, I'm all set.
'3' Good afternoon.-
My name is Joe McCumber and I'm with "k
4 Yankee Atomic, and I'd like to give you a few key points that l
5 I'd like to hit with respect to fluid systems.
It has to do 6-with the focus of coverage, the actual scope, and then that I'd r
7
,like to see some flexibility in the method of' implementing what I
8 we do.
9-Just responding to one of Mr. Vagins' comments 10 earlier on balance of plant coverage and what would be 11 included, it's our feeling that the only balance of plant that 12 would'be covered within license renewal would be whatever meets fv o
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'13 the requirements of the definition of "important to safety," to 14 number 1 and 2 that are in Section 9(c), I think it is.
15 Fluid systems in general, the way we look at it, have 16 two prime functions.
One has to do with operability, and the 17 second with pressure boundary.
From everything-we've seen so 18 far, we feel that the operability function is being very well 19 handled right now by the several programs that are in place, 20 and, you know, that list is very long, going from test specs, 21 to surveillance, to disassembly of different components, to 22 MOVATS, to maintenance, vibration monitoring, leak tests.
You 23 know, when you combine all those programs and how they're being 24 applied to the different components, we think they're doing a 25-very good now, and that'll continue for the renewal period.
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l' As far as the pressure-boundary concerns, we feel 2:
that you are going to-ha're to take a look at some of them as 3
.far as how=is degradation acting on them, and a-lot of that 4
depends on the-specific material, or environmental within which i
5 it-is.
It'll differ, and I think that gets-again into the 6
flexibility of the level of work and documentation that you'll 7
have to apply, because depending on which system you're dealing 8
with, you may have to go further in assuring that that level of 9
safety is continued.
10 I think I may be getting a little bit into some of 11 the philosophy and stuff that was said this morning, but I 12 think ti's important to get into it in each of these sessions.
j, 13 Reading the NRC philosophy-that's expressed in the 14 document that we received, it's pretty clear that they do want 15 to limit what you look at cnd allow you to focus on what's 16 really important.
It kind of embodies a screening process.
17 When you actually get into the proposed rule wording, I think 18 it's not really clear that they are picking that up.
19 As far as specifics, we can see that the rule does 20 require you to provide information for all components, both as 21 far as design functions, environmental conditions, the 22 degradation mechanisms, and also the programs that you have for
^23 managing that degradation.
(3 Now, that is then dependent on the fact of whether or 24
(,j 25 not there is a degradation, whether or not the component within
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11 the system really is important.
And, again, that's every
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2 component -- that's not just components; they're asking you to 3-do this at the system level, the structural level..-I'm not 4-quiteLsure that that's what it's intended, but that's the way' 5
the wording is right now.
6 We feel that the scope right'now is unnecessary, that 7
the degradation concerns do not, you know, exist-for many.
8 components, based on design conditions, benign environment, i
9 inspection maintenance, and the fact that many of the 10 components are refurbished or replaced on a periodic basis. sis.
11 We feel that the process needs to consider these 12
. factors, and that you do the' level of effort in documentation
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13 that's required, again, as Mr. Vagins said, to show that a
14 continued level of safety, and the big thing that we're trying 15 to do here is to focus our resources so that you can put it 16 into what really needs to be done.
17 Again, we feel the rule does have to embody a I
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18 screening process, again to try to focus that work, and to try 19 to just key in on where you do have unresolved degradation 20' issues that aren't being managed.
21 We feel the screening process and the rule itself 22-needs to be comprehensive, clear, and consistent to make sure 23 that anything we're dealing with, that there isn't going to be
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24 ambiguity, and questions, and follow-up hearings, or whatever, 25 that everybody knows what we're talking about as far as
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1 definitions and everything elset We want_it to be efficient i
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2 and' flexible, flexible mainly in how you implement it, and.then j
3 also' to require _ just. the level of information that you need to
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- support the determination that you made.
5 Just a little bit of talk on degradation mechanisms.
6 You know, I think we all recognize that the mechanisms'that do 7
go after fluid and mechanical systems, they have been 8
recognized over the years, and, you'know, we do have a pretty 9
good handle on what they are, and that understanding is 10 increasing with time and experience.
11 Some examples are erosion / corrosion,_where right now 12 the code is addressing it, and we're putting, you know, more (Oj inspections into erosion / corrosion right now because it's 13~
14 needed now.
It has nothing to do with the fact that license l
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- 15
- renewal'is happening; it's erosion / corrosion is happening now.
16 Thermal fatigue is another issue that, again, it's a
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17 license renewal issue, because if it's not resolved and you're 18 not doing things, it's going to effect you.
But we're taking 19 care of it now, and appropriate actions are taking place now 20 because that's when it's happening.
I-L 21 Again, existing programs that we have in place right l
l 22 now are doing a good job.
They're monitoring; they're l
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They've been proven during (G
25 the original licensing term, and, again, they're being 1
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continuously updated as we. gain experience.
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2 The conclusion is that the law should allow for
_3 credit.for these programs to continue throughout the rest of' 4
this license and on into the future.
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5 One thing that I think we've got to think about, 6
though, is we. don't want'to let -- also,1we don't want to let; 7
the licensing renewal issue be a cause of making you go too 1
8 much further in areas that aren't needed.
We don't want 9
license renewal to be the tool that forces a maintenance rule 10-down your throat.
You know, maintenance changes should come as i
11 appropriate because of maintenance, not necessarily because of J
12 license renewal.
13 Getting to_the flexibility and implementation, we 14 feel there are many ways of demonstrating that a component is 15 adequately being: managed.
One is to show that the component, 16 based just'on its own design, is adequate for the continued 17 service.
The other one is all the-existing programu that are f
18' in place are doing a good job, and will continue to.
There may 19 be a need for procedural enhancement -- for instance, trending.
20
-- but again, only where appropriate and when it's appropriate, 21 not necessarily tied to the licensing renewal schedule.
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22 Another area could be to change operating practices.
23 If, for some reason, what we're doing right now is effecting a L '(/'
24 compound or causing it to degrade, that's another way that I
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25 maybe you can stop it, or replacement or refurbishment.
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~ Going a-little bit further on trending, in;the s
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li/
- 2.
. wording-of the rule;right now, trending seems to be pushed
'i 3
pretty strongly..Again, we see a need for trending in certain' o
.4 circumstances where we see a benefit, but, again, not in all 15 cases is it. required.
For instance, if there are programs that q
6
. replace the component, or if there's just no need, based on the-7 fact that it's not degrading.
So trending doesn't make s
8 everything go away, but it is, you know, it is a benefit in
~
9' certain circumstances.
10 Another issue that has come up is how do you 11 administratively control in the future that any. enhancements or 12.
. improvements.that you make to the program stay that.way
)f 13 throughout the license renewal period?
Weifeel that if there-
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+
' 14 -
is a special action: required to manage age-related degradation 15 to support licensing renewal, that yes, you know, that should 16 be/ controlled administrative 1y, and that those will become
-17 '
commitments for the license renewal' term.
However, we do not 18
, feel that we should be overburdening text specs, or anything 19 like that, that there are other administrative methods to make 20 sure that you keep up with that commitment.
21 In summary, we feel that Section 9, or XX.9, does 22 need to embody a screening process that allows you to focus on 23 what's really important, and that is safety -- important to 24 safety components for which unresolved aging degradation issues 25 have been identified; and that we feel that it' very important
U t
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22 l'
- 13) allow flexibility in the method, that you_actually show or c/'T.
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,2 demonstrate that you're adequately managing that aging.
3~
-That's it.
4 MR. VAGINS:
Thank you.
I'd like to throw the floor 51 open again. tar any questions to the speaker.
I'm a little
- 6 surprised by the -- I got the feeling that you didn't think we.
L7 were urging or trying to develop a very important part of the' 8
rule which is the screening procedure.
Is that the feeling you 1
9 got; that-the NRC was not trying to develop or have part of the.
-10 rule as screening procedure?
11 MR. McCUMBER:
No, the feeling that I have, 1
. 12 especially through the philosophy, is that it's very strongly
- l.m o
i X.)
. 13 built into it.
It's just the wording of the rule that does not 14 come across clearly at all.
i 15
. !0R. VAGINS:
It's quite clear that our wording.may 16
-need some clarification.
Certainly, it's like everything I 17 do.
I'm the world's worst proof reader.
I can't catch my own 18 mistakes.
So that's the purpose of this workshop.
We want 19 your feedback, but I want to make very clear that the key to 20 the license renewal is the screening procedure.
21 We are not going to ask you to do work that is 22 already in place.
We're not going to ask you to repeat 23-anything that is part of your present adequate safety basis.
24 MR. McCUMBER:
If it could just add this:
This is 25 Joe McCumber again.
I opened up with a definition of the scope
+
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23
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- 1'
-and what would-be the balance of plant components that would be A.A
- ' ^"
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included.
Is'that. consistent.with what you are atying, or are 3
you going beyond that?-
i
?
4-MR. VAGINS:
I'm not quite sure.
I want to make sure A
5 of what we'said.
We said that anything~-- any equipment:
6 failure in balance of plant that challenges your safety systems 7
must be looked at.
Now, let me give you an example from prior 8
history.
T!
Lf 9
You are all familiar with the pressurized thermal 10 shock' issue.
When we broke that to the industry in March of 11-1981, we presented 14 actual scenarios of thermohydraulic 12 transients which were full pressurized thermal shock scenarios.
r
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13; Every single one of those scenarios -- I mean, these were notL 14 scenarios.- 'These were-incidents, actual incidents, were 15 initiated by a failure of a non-safety related component or 16 balance of plant component.
-17 It's -- I mean, this is the kind of philosophy we're 18 looking at.
If you have a system out there which, if it 19 fails, will seriously challenge your system, then we would like 20 you to look at that and talk about the -- give that the same 21 consideration as you would really a safety related system as 22 far as aging goes.
Is it aging?
23 MR. McCUMBER:
Just to clarify the point, it's in
)
24 Section 9C thertf.
The definition as it's worded is non-safety 25 related safe -- whatever it is -- systems, structures and
ik i
24 i
h'.
components whose failure under environmental conditions could 1
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2 prevent satisfactory accomplishment of safety functions i
3 specified in paragraphs -- blah, blah.
I think you are going 4
beyond that.
5 MR. VAGINSt I think we -- well, I don't know what 6
will prevent me.
I think thot word, " prevent" means 7
intercesrsion into a safety system and there's no such thing.
8 The verbiage inay have to be changed.
How did the failure of a l
t 9
non-safety related system prevent anything?
T 10 MR. WEAMIELt That's a different pet.
What you're il randing is essentially the kind of wording that's right nov in 12 5043 for equipraent qualification where it speaks to a failuro 13 of a non-qualified component that may impact a qualified 14 component.
That would essentially be true for the kind of 15 analysis you de, even in the seismic arena where a failure of a 16 non-seismic component is not supposed to impact a seismically 17 qualified component and prevent it from doing its function, j
18 That's a little different from the kind of thing that 19 he's talking about.
I agree with you, it is different.
20 MR. VAGINS:
The words may have -- may need some word 21 engineering.
22 MR. WERMIELt What I think Milt is trying to say, if 23 I could put it maybe in more of a lay term, if I take a 24 feedwater system, for example, I know if I lose feedwater, I'm 25 going to challenge Auxfeed.
The feedwater pump is not a whole
~
h 25 I
lot different from a safety related pump and it's subject to l
2 certain age-related degradations.
3 Would there be a need -- and there's still a question 4
-- would there be a need to have a program in place if you l
5 determine you need a program for safety-related pumps, to also 6
have a similar program or something like it for a main feed 7
pump, in order to ensure that there's no more chance of a
[
8 feedcator challenge, a loss of feedwater, in the extended l'fe j
9 than there was in the previous 40-year life.
10 That's the sort of thing, I think, that Milt is 11 talking about as a focus -- something to think about -- and I 12 would agree, it cortainly it/n't clear that the existing we.rdirq 13 of the proposed rule -- and it's just a proposed rule -- would i
14 go to that sort of thing.
That's all I think he's trying to 15 st y.
a6 MR. BURKE:
My name is Richard Burke from FPRI.
I I
had a question, but first I wanted to maybe clarify for my own 1
18 self, what Mr. McCumber and you, Milton, just said.
Presently, 19 as I read it in the rule, this is very much like the 20 methodology to identify plant equipment for a license renewal 21 that NUMARC submitted, in that what I see here is that those 22 systems that could prevent the operation of a safety system; in 23 other words, that would necessarily challenge or prevent the 24 operation, would be included in what was defined in the 25 proposed rule.
26 l
r
/~i 1
The screening methodology presently, that was sent in Y j' 2
under NUMARC, identifies those systems that -- they might be
+
3 initiators that would challenge, but they also would be L
4 mitigators if they were initiators, or they're strictly 5
mitigator systems.
Feedwater systems can be used as a source 6
of water or something that would be used in emergency f
7 procedures would be considered a nitigation system.
L 8
But what's excitsdad are those that singly challenge.
9 Then, regarding that, since I brenght up the scraen!ng 10 procedure which is called the Methodology To Identify Plant 31 Equipment For License Renewal, I wanted to ask if the NRC had a 12 similar type of screening procedure that they were going to
\\- /
13 release or what they had in mind along that line to focus on 14 what you spoke about?
15 MR. VAGINS:
We're going to make that decision when 16 we finish reviewing the industry screening criteria.
If we 17.
feel that the industry screening criteria is satisfactory, 18 that's where it's going to end.
19 MR. ROTHBERG:
I'm Owen Rothberg.
I'm with the 20 Office of Research staff.
I have a comment and a question.
21 The comment is that the degradation mechanisms that I'm aware 22 of with respect to motor-operated valves and possibly other 23 valves, are not well understood.
Ih 24 I disagree with the characterization that they are V
25 well understood.
The other thing is a question and this is
l i
27 l
)
1-more or less for everyone.
k I
d 2
Is there any scenario where testing or analysis at 3
the end of a 40-year life of a plant and before licensing i
4 renewal or extension is necessary?
i 5
MR. VAGINS:
Say that again?
6 MR. ROTHBERG Is there any circumstance or scenario 7
Where testing or analysis at the end of a 40-year plant life 8
and before license renewal or extension is necessary?
Is there 9
any circumstance?
10 NR. VAGINS:
Specific components, any testing of li specific components.
12 MR. ROTHBERGt Thht's right.
In other words, does it 13 continue, or continue with a break?
14 MR. VAGINS:
Well, I think there's a general answer, 15 of course, and that is; where in these fatigue limited --
16 again, I'd bring back my experience in designing piping 17 systems.
We'd go to the end of life; look at assumed load; 18 pick something that would give us as close to a usage factor of 19 1; go back and pick out the scheduled piping.
We always had an 20 increment, because scheduled piping goes in steps and it 21 doesn't go smeothly.
22 We never tried to put excessive fitness in, because 23 that was money.
So, there are, as far as I'm concerned -- and 24 I've cone this -- is that there are certain pieces of equipment 25 that are fatigue limited, and obviously, those are going to
28 1
have to be handled in some way.
2 There art other things that have come up through life 3
such as thermal fatigue which was not originally designed and 4
in and have been identified and in some places, judgments are 5
made to -- well, it's okay through this present licensing l
6 period, but not much more.
This is rather Icw cycle, high
)
i 7
emplitu b fatigue.
l 8
There are otner judgments stbout arcsion/ corrosion 9
where the allowance or the thickness is sufficiant within the 10 licensing period.
If you make that jt.Jgment that that's all i
i 11 sufficient until you want to go for license renewal, you':re not 12 going to replace your piping syatem if your erosion rate is 13 within acceptable limits.
14 But it may not be for the 41st year or the 50th year I
15 or whatever.
So I can think of a series of scenarios where 16 I've either designed in a limited life by economic necessity at I
17 the beginning of life; where I have encountered a non-18 anticipated load such as some of our thermal loadings, or 19 where, indeed, I've encountered some things which I didn't 20 anticipate such as some of our erosion / corrosion problems.
1 21 Now, don't get me wrong.
I'm not implying these are
'22 very widespread, but there are conditions. I can name a few.
23 I'm sure everybody here can, too.
So, definitely, there are 24 some and I'd entertain questions and other responses from the 25 floor.
~.
I 1
I 29
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1 1
Yes?
r3 2
MR. SNOWS The !?UMARC response to that would be --
l 3
MR. VAGINS:
Would you give us an 2D?
4 MR. SNOWS My name is Bruce Sncw, representing the 5
NUMARC working group.
The NUMARC response to that would be 6
that there may be some circumstances identified as we apply the
-7 cereaning process to our various plants and as we review the 8
varicus systems in our industry reports.
There may be specific 9.
Itemn identified in that process.
10 specifically, because the plar,ts are all different, Il there more than likely will be various itens identified that i
12 would require further evaluation or work.
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13 MR. VAGINS:
This is an aside from our session, but m
14 it certainly is -- from my background -- of vital importance to 15 everybody in this room and that's, of course, the pressure 16 vessel.
The limiting item on the pressure vessel probably 17 would be embrittlement.
18 Again, it's probably governed by today's rules which 19 are going to carry over.
The PTS screening limit, 50-61 is 20 going to apply.
Some vessels are not going to make it on the 21 basis of that analysis, much beyond their present licensing 22 period.
23 So you see, it depends.
Again, it's plant-specific.
(~')
24 There are some generic things.
\\~J 25 MR. McCUMBER:
Hi, this is Joe McCumber frcm Yankee
t 30 i
i 7-1 Atomic again.
You shouldn't have let me sit next to a
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microphone.
j 3
(Laughter.)
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4 MR. McCUMBER:
I have just a couple of points that I I
i 5
think were relevant to some of the questions that were just 6
asked.
One had to do with; are there any needs to actually do 7
some type of one-time inspection before you go into license i
f 8
renewal.
9 T'd just like te read to you the results of a task i
l 10 force study on ASME 11 into exactly that question on the need
[
11 for re-baseline.
That is, a special task force studied the 12 potential for supplemental inspection, including re-baseline l
(~
i l
13 inspection for plex and concluded the following:
14 ASME Section 11 should not develop special 15 supplemental requirements related to license renewal and two; 16 ASME Section 11 should continue to play a proactive role in 17 addressing age-related degradation.
This should include code I
18 changes where technically justified and on time scales relevant 19 to the particular aging process.
I 20 I think that's probably relevant to most concerns.
l' l
21 We don't see the need right now, and we should attack it when i
22 we do.
One other comment that was made having to do with 23 fatigue:
I totally agree that fatigue is an issue that we're
(
24 all going to have to address, but there was something said V}
25 about it that we didn't want to add material.
l i
31 1
But I think a lot of it went the other way alsor that g-
- }
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2 in fatigue analysis, once you got yourself below that usage 3
factor 1, you said sometimes, the heck with that.
I don't want 4
to do any more analysis.
In fact, there's a lot of inherent 5
margin in the existing fatigue analyses at time also.
i 6
MR, VAGINS:
No question at all about that, I was 7
Sust pointing out how we did it.
I'm sure that everybody did
[
8 it the same way.
You work from the back, the front, and when l
9 people say that there's no basis for the four-year licensing i
10 period that is true but we made it a basis when we went into 11 the actual design instruction, when we went in and physically 12 designed the piping.
()
13 MS. DONEY:
My name is Rhonda Doney of Combustion 14 Engineering.
I have a couple of questionb and a couple of
[
15 comments and I thought I'd accumulate them all and only have to 16 come up here once and talk into the microphone.
17 The first is with respect to these seven questions 18 that were provided to us, specifically with respect to question 19 four regarding the treatment of fatigue for design Class I 20 components.
21 A lot of you in this room look familiar to me and i
'22 you're probably -- most of you are aware that a couple of years i
23 ago ASME Section XI formed a task group on fatigue and 24 operating plants, which I'm a member of, and at our most recent 25 meeting -- well, the charter of this group was to develop a 1
32 7-s white paper that would provide guidance to the ASME code and 1
I ()
l 2
recommendations for what to do on the issue of fatigue and at j
3 our last meeting, which actually took place just last week in 4
Orlando, we finally solidified what we feel our recommendations 5
are going to be to ASME Section SI and I'd just like to share i
6 those with you for those who aren't familiar with what our
)
7 group is doing.
8 I don't have anything tc read that's been pre-i 1
9 written so please bear with me, but as a group we came to the I
10 conclusion that we feel that ASME Section XI should te expanded 11 to address fatigue concerns and the guidance that we are
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l 12 proposing to provide would address three specific areas.
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13 The first would be those concerns related l.
14 specifically to license renewal.
i 15 The second area would be to provide guidance to the 16 industry for how to go about maintaining your current design 17, basis integrity, for example, technical specifications and 18 related documents.
19 The third area would be some generic guidance on how l
20 to address new issues related to fatigue as they arise such as l
21 those identified in NRC Bulletin 8808 and 8811, I believe, 22 regarding stratified flow in the surge lines and so we are i
j 23 planning to make that formal recommendation and it appears as
)
if we would go ahead then and begin to prepare code verbiage 24 25 that would address these three areas.
~
33 1
My second comment is with respect to question five I
(s')
2 and from my own personal -- this regards addressing residual 3
fatigue life or Clask II and III piping and components.
From
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4 my own experience most of these components that don't have a 5
fatigue design basis are that way because they were never i;
t t
6 considered to need one.
The thermal transients that the class 7
II and III components sse in the balance cf plant, in general, 8
they're just not subjective to the same type loadings that the 9
primary components are subjected to, and to unless we feel that 10 current requirements are not adequate with respect to the 11 design of these components, then it's my opinion thore should 12 be no need for any new requirements associated with license Ch
( ).
13 renewal.
14 My last comment is with respect to question six which 15 discusses new information that has been developed and 16 researched regardina the f atigue curves in Section III of the l
17 ASME code and that is that -- let me just refer to my notes 18 here.
I agree with the concern that's listed in this question 19 and this concern is being investigated by both ASME Section III 20 and is being followed very closely by Section XI specifically 21 by this task group on fatigue and I feel that while this is a l
22 valid technical issue it's not that's related specifically to 23 life extension and that it should be allowed to be addressed on f
24 a continuing basis and not something that's directly tied into l
25 life extension.
_~,
i 34 1
Questions.
I heard about this NUMARC/NUPLEX group, l
/, -
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2 this ad hoc group that was formed on fatigue and I was just 3
curious if there was any information available on what the real 4
purpose or the charter or the goal of the group was.
5-Curt, may you can answer that.
6 MR. COUSINS!
This, is Curt Cousins.
I'm with NUMARC 7
and in respunse to Rhond:t's quas?. ion, we were addressing it in 8
the scope of how should our irs address the question of fatigue i
9 and wo have a twofold step that actually goes a bit further i
i 10 than the scope of th4s current Section XI fatigue committee, 11 which was to ask questions what should be do about plants that 12 do not currently have a fatigue analysis?
And those that use 13 such as B-31-1 for analysis or such, so, we have incorporated 14 that into our examination.
We have some preliminary positions 15 that have been developed and we propose on -- passing those to 16 the industry and if there's a consensus that we should move 17 with those then we will be bringing them to the NRC.
18 Thirdly, we have represented on this ad hoc committee 19 the Section XI chairman of the fatigue group and he was quite 20 enthused and encouraged by this particular activity.
21 MS. DONEY:
Just one comment on that, Curt.
It's my 22 understanding that the guidance that we're going to try to come 23 up with in Section XI would also address components that were 24 pre-Section III and had that particular concern to cope with.
25 On the other hand, it may be difficult to complete l
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that in a manner that would be expeditious enough to support 2
license renewal for the first plant, so, I think I agree with 3
what you said.
4 The last question, maybe Mr. Vagins you can answer l
5 this one, we've got -- combustion engineering has an owner's j
6 group program, a iatigue monitoring program that we've had for f
i 7
a couple of years now before there was the benefit of this new 8
guidance that's co. ting out now and what types of components you i
9 should bq considering and things like that and the position
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10 we've taken in the past is you have a plant and basically
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11 overything in the piant is sabject to some sort of thermal i
12 transience and so our question was always where do you draw the I
O V
13 line also and so what we've done to date is we include all t
14 systems that are in the plant technical specifications and the 15 second thing we do is we review the plant's FSAR and any 16 systems that were either -- or components in systems that were 17 initiators of an accident or were credited in the accident 18 analyses as a mitigating system were included in this broad f
19 list of systems and then we went into each system on a 20 component level and started looking at individual components l
21 but our reason for that approach was we felt that between the 22 FSAR and the plant technical specifications those systems 23 formed your licensing basis for your plant and I just wondered
- t 24 if -- I was curious as to your opinion.
i 25 You know, theoretically Chapter 15 analyses are l
l
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i 36
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1-supposed to bound anything that can happen to your plant and if
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i 3
include, for example, the fatigue issue, that those components l
4 are required to be able to operate.during an event, and I just t
5 wondered if you felt that that was an appropriate envelope to i
6 chese?
7 MR. VAGINS:
Yes, well first, though, let's go back 8
to Chapter 15.
Chapter 15 cnly deals with design basis.
We i
9 know that design bases -- accidents do not envelope the 10 potential problem.
Again, l' go back to PTS.
PTS is not a i
11 design basis accident.
So, therefore we do have some problems f
12 on re-defining or looking at what we consider challenges to the 13 system.
So, this is why I, personally, put such greater 14 emphasis on balance of plant, failurer and challenges to the i
15 system, and I'm not speaking in this case for the NRC, this is 16
-- one of the questions we threw out, my personal opinion is 5
17 that they are extremely important when you find the potential 18 challenges that are outside the envelope.
i 19 I'm not ready to say yet what should be totally 1
20 involved -- what we should look for.
We are asking the 21 industry to give input.
The screening methodology is going 22 hopefully identify these components because everything excluded 23 will be justified.
That's fine.
In other words, the work will
- [ )
24 go to the justification rather than to any kind of proof that s_-
25 the system needs -- or, any kind of detail as far as managing
__........___,...-._,....,.,,.,__.._,e
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37 f
1 tho' aging process.
But the justifications have to be complete 7,!J N
2 and they have to say, okay, this is not important -- it's not 3
aging related, it's covered by the present licensirig basis and f
4 it's fine.
It's not an additional or new safety' issue that's f
5 solely related to licensing.
l 6
The thing -- I'd like to make one comment, again, as 7
a personal.
When you said ASME Section XI is getting a license 8
renewal, why?
Why isSection XI getting a license renewal?
9 Why should you have any time limits on your work?
Section XI 10 states it's not design criteria, it's inspection, and 11 inspection and testing procedures, right?
Why should there be 12 anything that says license renewal, not license renewal, why 13 should there be any time limits in anything the code does for 14 that matter?
15 Section XI says design by analysis.
Whatever your 16 time period is, such Section III should cover it.
Section XI 17 should not be governed by what is license renewal.
Section XI 18 should say what is good practice, how do you calculate 19 remaining life as you do in a crack provocation study.
20 So, I'm really confused as to why Section XI is doing
-21 this.
22 I mean, it's a magic word.
License renewal is a 23 magic word now.
24 MR. MCCUMBER:
This is Joe McCumber from Yankee 25 Atomic.
In general, I think, license renewal started a lot of
r i
h 38 1
activities within the industry that started looking into
\\-
2 degradation even more than before, so it's increased the focus 3
and there are committees in just about every code group right 4
now or standard group that is studying degradation with respect 5
to license renewal, but I totally agree with you that there is 6
not a difference in how the code should handle it.
It should 7
put in the proper wording where it's needed and I think what 8
Rhonda is also saying is that whatever is put in for fatigue 9
will both take care of concerns that people have right now with 10 respect to fatigue questions that they have but will be equally 11 applicable to anybody going into license renewal as far as 12 demonstrating that they have adequate margin and that whatever h
13 methods come up, again, will be applicable for both the older ik plants and the newer ones that will give different methods of 1
15 demonstrating adequacy.
16 MS. DONEY:
If I could just clarify that.
We're not i
17; planning to provide any technical guidance on what you do for 18 license renewal, but it seems that there was a need for a 19 utility to be able to demonstrate to the regulators that l
20 fatigue was not a concern or that they had adequately addressed 21 the fatigue issues or how to program and a place to address l
22 fatigue for the purpose of license renewal, not that we felt i
23 there were any actual technical issues there.
24 So, what our concept is so far is that we would 25 provide guidance for a fatigue assessment report that would be
!=
i 39 1
similar to -- in Section III there's guidance provided for what
,~m
('d) 2 goes into an equipment specification and what goes into an ASME 3
code design stress report.
Not how to do it, but just the 4
types of things that need to be considered in such a report and 5
what we are envisioning at this time is that we would provide 6
guidance for these are the types of things that you should 7
probably consider in a fatigue assessment report for the 8
purpose of license renewal, but not trying to provide guidance 9
to anybody and how you go about doing fatigue analyses or 10 anything like that.
11 MR. VAGINS:
Why don't you just say this is how you 12 do a fatigue assessment?
In other words what I'm saying is I
(
13 don't see where the words license renewal really belongs -- the 14 word license for that matter -- belongs in any Section III or 15 Section III or Section XI.
16 What we're doing in the professional society is 17 setting good design and practice -- good design and operating 18 practice and that should be independent and irrelevant at the 19 time.
The time, if we really mean design by analysis, if we 20 really mean operation by analysis, then whatever the time is 21 the time is and it really doesn't make any difference.
22 MS. DONEY:
Well, that's a very good point.
23 MR. VAGINS:
Well, it's just philosophy again, it's 24 my own.
l 25 MS. DONEY:
Just one additional comment for the NRC l
^
i l
40 i
,r'3 1
is if you're interested in any more information on what our
\\
)
2 task group is doing the NRC representative on our group is 3
Keith Whitman.
4 MR. LEONARD:
My name is Dan Leonard from Multiple i
3 Dynamics Corporation.
A comment in regards to the scope that's 6
needed to address the balance of plant systems.
I would offer i
7 that the balance of plant systems is certainly recognized by 8
the industry as being directly effecting the performance goals 9
of the plant, and that these issues are being currently 10 addressed through the industry in terms of performance i
11 indicators such as capacity factor, availability factors, scram 12 reduction programs, and many other programs.
I would suggest
(-
(_,/
13 that these ongoing programs are very valuable, and perhaps a i
14 sole definition of what we need to do to address balance of 15 plant systems.
16 Data in the industry is showing that in all these 17 areas, that the industry is improving in terms of scram-18 reduction.
NRC's concern is challenging to safety systems, and 19 that's certainly a leading indicator.
Continuation of these 20 types of program, perhaps specifically the scram reduction 21 program, is probably primarily the only thing that we need to 22 do for balance of plant systems.
23 MR. VAGINS:
My general answer to that is probably.
/T 24 Most probably, you are correct, and it definitely will be used.
U 25 We're not going to throw away anything valuable that the
s-41 1
fN-1 industry has come up with.
But I would like to point out that
\\_s!
t 2
there are types of failures that have never occurred before.
l 3
If we look at the statistical basis of failure and j
4 use that as the criteria for aging and what to study, we would 5
not worry about pressure vessels, would we?
I mean, a pressure f
i 6
vessel has never. failed.
7 The reason why it's never failed is because we i
8 anticipated it and we studied the hell out of it -- excuse me l
9
-- studied the heck out of it, and we are not going to let it 10 fail.
Well, I maintain that there is a possibility of L
i 11 squipment aging out there in the industry right now that could l
12 possibly fail.
~-
13 One of the missions of the aging program that I run 14 is to look for these things and the possibility of them 15 occurring.
I haven't found too many.
I have found one which 16 we are going to hear about later -- not today, but in the 17 coming future -- but that's fine.
So what I'm saying is, yes, 18 I think the NRC definitely will accept the industry incentives 19.
toward scram reduction total, all of these things.
Reliability 20 performance indicators and reliability improvement is a very 21 critical part of improvements and safety.
I think reliability 22 and safety go hand in hand.
They are not separable.
23 So, yes, we're going to use that.
()
24 MR. LEONARD:
Dan Leonard.
I would agree with what 25 you just said.
The point that I'm trying to make is perhaps, L
42 7-1 using reliability indicators as a first step, that if those
( )).
i 2
reliability indicators are good, they certainly are a strong 1
3 indication, perhaps, that we don't need to treat these balance t
f 4
of plant systems individually and examine the aging mechanism 5
in detail for those systems; that we can utilize that kind of 6
judgment in place of automatically going off and trying to 7
study them individually.
[
8 MR. VAGINS:
Until the occurrence of, say, the 9
feedwater failure systems and erodion/ corrosion, your method of 10 approach would have been, "That's not an important system 11 becauso we're not scramming due to it."
But it failed once,-
12 challenged the system and did some other damage and injury,
\\
13 etcetera.
14 So what I'm saying is, yes, I generally agree with 15 what you're saying, but we still have to take a good, hard look 16 at it and see that we're not moving toward the direction of 17 surprise.
I have a real simple way of running everything -- no 18 surprises if I can help it, both management and plants, 19 etcetera.
I 20 Yes?
21 MR. SNOW:
Bruce Snow, representing NUMARC.
I'd just 22 like to offer a comment, a different viewpoint.
It's probably
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v 23 our opinion that indicators are not matured enough to the point
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24 where we'd want to manage our plants by them.
We would agree 25 that the indicators provide a reason to evaluate further, but I
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think, been stated in the past.
4 MR. VAGINS:
Yes, I think NUMAR" (tated it very t
5 strongly in the past, and we appreciate that.
l 6
Eventually, if you develop a system which improves 7
the reliability of your plant significantly, it's certainly e
8 going to make a big step toward making license renewal easier.
9 One of the big things that is important with 10 indicators, of coursc, is how well your records are kept.
11 There is one other question, cne other thing I wanted 12 to bring up.
I want to go back a little bit.
We talk about r~~
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13 Class II and III. systems, and how the loads on them, generally, l
14 are very low, fatigue loads are very low.
This is not quite 15 true.
As we know, experience has shown that conditions of 16 water has -- that we have -- in many class II and III systems, 17 w'e have had some significant loads.
Maybe not too many, but 18 how has that effected its residual life?
19 These were not designed in, and they were not 20 considered when we did our equivalent fatigue analysis on class 21 II and III systems.
So, again, a consideration, just to look 22 at it.
23 What I'm saying here are -- these are words to stir
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24 discussion.
They do not represent the current NRC policy.
25 We're trying to form that.
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1 David?
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2 MR. EISSENBERGt Dave Eissenberg, oak Ridge National
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3 Lab.
I want to get back to owen's question because a lot of 4
this debate was supposed to be in response to it, or r
discussion, and summarize what I think I've heard, which is i
6 that I don't think I've heard any statements to the effect that 7
there's some unique tests that should be performed simply t
8 because there's a license renewal; that what should be 9
performed are tests which are important when the reactor 10 reaches age 40, or age 30, or age 50, but not sin. ply because of 11 license renewal.
12 I'd like to raise one potential reason for running a l
13 test simply because of license renewal, and that has to do with 14 design margin to take into account uncertainty.
That's done at 15 the very beginning of life.
When a piece of equipment is 16 designed, we extrapolate off to some future life, but then we 17 add a margin.
If we want to continue to run that piece of 18 equipment beyond its design life, do we have to rethink the l
L 19 margin?
20 Up to the 39th year, we don't worry about the margin l-21 because it was built in there at the very beginning to handle 22 the 40 years, but at the 40th year, when we look forward, do we 23 have to reassess the margin for uncertainty simply because 24-you're reevaluating it?
25 MR. VAGINS:
Well, I certainly think that the biggest 1
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place we deal with margins are in the fatigue area.
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2 margins on pressure, stress, temperature really shouldn't
'3 change that much unless you've had drastic geometry changes due o
4 to erosion, erosion / corrosion, etcetera, which we are going to 5
address in some way.
6 The other margins are seismic, and unless you can i
7 show that they are aging related, I'm not quite sure -- you 8
know, we have definitely shown one margin is aging related --
1 9
la fact, two, maybe -- in the case of fatigae and 10 erosion / corrosion.
If we can show something else is aging 11 related --
22 MR. EISSENBERG Temperature, radiation --
()
13 MR. VAGINS:
Radiation.
14 MR. EISSENBERG
-- wear, operating stresses, 15 pressure.
16 MR. VAGINS:
Operating stresses and pressure, unless 17 we'have a geometry change, doesn't change.
The radiation, yes.
18 I mean, there's no question about that.
Pressure vessel.
19 Anything that supports -- anything that's effected by radiation 20 will be considered in the total time domain.
But as I said 21 before, I think that we already have rules in place to handle 22 that.
The industry's problem is how to meet the present 23 requirements, and how to mitigate them.
24 You know, you really get down to it.
If we doing the 25 aging research had unlimited funds and time, license renewal is 7
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2 today's answers.
Then the problem is we're ont going to have 3'
all the answers, and we're going ot have to use the best 4
judgement of the best people in the country, and that's the 5
industry, us, whoever.
We're just not going ot have all the i
6 immediate answers to solve today's problems.
7 But, again, let me -- if there are no further l
8 questions, I'd like to emphasize again What is the philosophy 9
of license renewal?
Assurance of continued safe operation.
If 10 you're safe today, we just want to make sure you're safe 4
12.
tomorrow, and anything we can identify to help us along r. hat 12 line, we'll use.
()
13 We are not going to ask you to enhance your plant.
l 14 If you were not deened adequately safe today, we'd shut you 15 down.
So obviously, we deem you adequately safe by the 16 definition of the commission, and that's where we want to I
17 continue.
18 Are there any other questions?
I thought it was a 19 very stimulating session, by the way.
20 (No response.)
21 MR. VAGINS:
If not, that's it.
22 (Whereupon, at 2:27 p.m,.
Session No. 3 adjourned.)
23 24
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25
l O
FLUlD Ai.'7 MECHANICAL i
SYSTEMS OF INTEREST SESSION 3 1.
Those fluid and rnechanical systems relied upon for the integrity of the reactor coolant O
pressure soundary, afe.hutaown, no accident prevention and mitigation.
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FLUID AND MECHANICAL i
l SYSTEMS OF INTEREST l -
SESSION 3 E.W_El l
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Reactor Coolant Pressure Boundary Service Water System Component Cooling Water System i
LO Emergency Core Cooling System Residual Heat Removal System Chemical Volume and Control System Fuel Pool Structure and Cooling System i
RVs, Block Valves, and interconnected Piping Seismic Category l Piping, Raceways, Hangers and Supports Auxiliary Feedwater Systems Control Rod Drive O
4.
I O
FLUID AND MECHANICAL i
SYSTEMS OF INTEREST SESSION 3 I
i i
I BW.B.
1
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Reactor Coo! ant Pressure Boundary i
O Standby Liquid Controi System Reactor Core Isolation Cooling System l
l L
l High-Pressure Coolant injection System l
l-Residual Heat Removal System l
Emergency Equipment Cooling l
Fuel Pool Structure and Cooling System Control Rod Drives l
O
... _..... _ _...... _. _ _ _ _. _. ~ _ _ _ _ _,... _ _ _.. _.. _... _. _. _.
O LICENSE RENEWAL WORKSHOP l
SESSION 3 FLUID AND MECHANICAL SYSTEMS 1.
ADDITIONAL CRITERIA FOR PERIODIC SURRVEILLANCE AhT PREVENTATIVE MAINTENANCE TO ENSURE OPERABILITY OF MECHANICAL EQUIPMENT BEYOND INITIAL DESIGN LIFE 2.
AUGMENTED INSPECTIONS / ANALYSIS TO ADDRESS AGING O
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3.
FUNCTIONAL TESTING OF SYSTEMS AS A PREREQUISITE FOR LICENSE RENWAL 1
4.
LONG TERM EFFECT OF FATIGUE ON CLASS 1 COMPONENTS 5.
RESIDUAL FATIGUE LIFE FOR CLASS 3 AND 3 PIPING AND COMPONENTS 6.
EFFECTS OF WATER ENVIRONMENT AND ELEVATED TEPERATURES ON FATIGUE OF PIPING AND COMPONENTS 7.
PROOF TESTING AND HOT FUNCTIONAL TESTING TO DEMONSTRATE INTEGRITY AND OPERABILITY l
. ~.
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Oi APPROACH TO ESTABLISHING SCOPE OF TECHNICAL ISSUES i
l 1.
DEFINES A PROPOSED SCREENING PROCESS FOR EQUIPMENT AND STRUCTURES TO BE 4
REVIEWED 2.
?;EFINES STRUCTURES;
- SYSTEMS, AND h
COMPONENTS FOR EVALUATION i
1 1
3.
DEFINES SPECIFIC SET OF DEGRADATION MECHANISMS FOR EVALUATION 4.
DEFINES REQUIREMENTS FOR CORRECTIVE ACTION WHEN DEGRADATION IS NOT BEING MONITORED a
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SPEAKERS AND SESSION 1 FADERS WORKSHOP ON LICENSE RENEWAL t
OFFICE OF NUCLEAR REGULATORY RESEARCH:
Eric S. Beckjord, Director Themis P. Spels, Deputy Director for Generic issues Lawrence C. Shao, Director, Division of Engineering Robert J. Bosnak, Deputy Director, Division of Engineering Milton Vagins, Chief, Electrical and Mechanical Engineering Branch, Division of Engineering Mark A. Cunningham, Chief, Probabilistic Risk Analysis Branch, Division of Systems Research Donald P. Cleary, Senior Task Manager, Reactor and Plant Safety i
Issues Branch, Division of Safety issue Resolution CFnCE OF NUCLEAR REACTOR REGULATION:
g James H. Sniezek, Deputy Director Frank P. Gillespie, Director, Program Management, Policy Development and Analysis Staff James E. Richardson, Director, Division of Engineering Technoiogy Ashok C.Thadani, Director, Division of System Technology Jarad S. Wermiel, Section Leader, Plant Systems Branch, Division of System Technology OFFICE OF THE GENERAL COUNSEL:
Lawrence'J. Chandler, Assistant General Counsel for Hearings and Enforcement e
O O
O NRC LICENSE RENEWAL WORKSHOP
}
November 14, 1989 i
Tim _e Sublect Session Leader (s)
Place 8:00 am Registration Foyerof Room A i
8:30 am Concurrent Sessions Session 6 - Containments J. Richardson, L Shao Room C i
Session 7 - Electrical Systems A. Thadani, M. Vagins Room B i
Session 8 - Environmental Effects F. Gillespie. D. Cleary Room A
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10:00 am Break 10:15 am Sessions Continue 11:45 am Lunch l
1:15 pm Summary of Concurrent Sessions T. Speis. All Session Rooms A, B, & C
- i Leaders a
i 2:45 pm Break
- l 3:00 pm Comments and Discussion T. Speis, All Session Rooms A, B. & C Leaders f
4:00 pm Summary and Conclusion T. Speis Rooms A, B & C l
4:30 pm Adjoum i
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NRC LICENSE RENEWAL WORKSHOP l
November 13,-1989 Time Subiect
, Session Leader (s)
Place
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7:30 am Registration Foyerof Room A i
8:30 am introduction E. Beckjord Rooms A, B & C 8:45 am Regulatory Philosophy and Approach J. Sniezek Rooms A, B. & C
+
i 9:30 am Sesskm 1 - Overview of Conceptual Approach F. Gillespie, R. Bosnak, Rooms A, B. & C t
to a License Renewal Rule L Chandler I
10:00 am Break l
10:15 am Session 1 Continued Rooms A, B, & C l
12.90 am Lunch j
l 1:15 pm Concurrent Sessions Session 2 - Reactor Pressure Boundary J. Richardson, L Shao Room C
__Segston 3 - Fluid and_lWiechanicaLSystem J. Wermtel, M. Vagins Room B-Session 4 - Screening Methodology for System, A. Thadani, Room A Structures and Components important to Safety
.M. Cunnmgham j
Session 5 - Overview of Conceptual Approach C. Thomas, R. Bosnak, Room 5 and Regulatory Framework - continued L Chandler l
discussion from Session 1 I
2:45 pm Break
' i 3:00 pm Sessions 2,3,4, and 5 Continue I
j 5:00 pm Adjoum o
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t Session 3 Fluid and Mechanical Systems i
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Public Workshop on Technical and Policy Considerations for Nuclear Power Plant License Renewal
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. U. S. Nuclear Regulatory Commission November 1314,1989, Reston, Virginia O
SES$10N 3 FLU 1D AND MECHANICAL SYSTEMS 1.
What additional criteria should the proposed license renewal rule and associated regulatory guidance contain regarding periodic surveillance and preventative maintenance to ensure the operability of mechanical' equipment important to safety and fluid system performance beyond their initial design'11fe?
2.
What type of augmented _ inspections and/or analyses are needed to address aging mechanisms in pumps and-valves, such as:
' detection of degradation in pump and valve internals (e.g, erosion
'and corrosion due to flow turbulence and chemical attacks detection of possible cumulative fatique of pump shafts which may lead to cracking.
detection of possible cumulative fatique effects to valve discs and hinges due to cyclic stresses and impact loading from valve operation and flo* excitations.
3.
What should the proposed license renewal rule require regarding functional testing of systems important to safety as a prerequisite for license rene al, recognizing that such functi.enal testing may not have been per-formed prev.iously as pa. 6 of U:e.ir% :.v1 1 % ncing basis?
'4.
In licht of the great variability in the treatment'of fatique in the design of-Class I (or quality group A) piping and components, there is a need that license extension requirements be based on operating history of individual plants. How should the NRC confinn that Class I components have not exceeded their original fatique design requirements? Also, should the industry address this issue in a topical report?
o 5.
How can the residuel fatique life for Class 2 and 3 piping and components be detemined for license renewal?
6.
Existing fatique requirements do not take into account the accelerated damage caused by water environment and higher temperatures of LWR plants.
What provisions should be required to permit operating life to be safely extended without more definitive knowledge of this effect and how should
-these provisions affect the application of Miner's rule and the S.N curves applied in the ASME design code incorporated by reference into the NRC regulations? Should NDE techniques be used that give measures of remaining fatique life and levels of toughness?
7.
Are there any kinds of proof tests or hot functional tests that should be done to demonstrate integrity and operability to qualify for extended life?
O
I
,9m,.
REPORTER'S CERTIFICATE This is to certify that the attached proceed-ings before the United States Nuclear
]
Regulatory Commission in the matter of:
NAME OF PROCEEDING:
Session 3 Public Workshop DOCKET NUMBER:
PLACE OF PROCEEDING:
Reston, VA were held as herein appears, and that this is the original transcript thereof for the file-of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by-me or under the direction of the court report-ing company, and'that the transcript is~a true and accurate record of the foregoing proceedings.
d
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V l
l JON-HUNDLEY Official Reporter Ann Riley & Associates, Ltd.
1 l-P V(3 l
O FLUID AND MECHANICAL SYSTEMS OF INTEREST SESSION 3
~ 1 II. Those fluid and mechanical systems whose failures can cause or-adversely affect a transient or accident that significantly challenges structures, systems, and components relied upon for the integrity of the-O reactor coolant pressure boundary, safe shutdown, L
- or accident mitigation.
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LICENSE RENEWAL WORKSHOP SESSION'7 ELECTRICAL SYSTEMS l
- 1. ADDITIONAL CRITERIA FOR ELECTRICAL EQUIPMENT INCLUDED IN-THE-'E.Q. PROGRAM BUT NOT. PERIODICALLY REPLACED
- 2. ADDITIONAL' PROGRAMS TO ADDRESS AGING DEGRADATION
(
OF ELECTRICAL EQUIPMENT LOCATED IN MILD ENVIRONMENTS 3.: PROGRAMS TO ESTABLISH THE INSITU CONDITION OF CABLES AND COMPONENTS AND THE POTENTIAL FOR FUTURE DEGRADATION
- 4. REQUIREMENTS WITHIN THE RULE FOR ELECTRICAL EQUIPMENT L
IMPORTANT TO' SAFETY
- 5. FUNCTIONAL TESTING OF ELECTRICAL EQUIPMENT AS A PREREQUISITE FOR LICENSE RENEWAL O
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