ML20034G674

Corrected Commission Paper Re Outcome of Staff Senior Mgt Review of Key License Renewal Issues & to Obtain Commission Approval of Staff Proposals for Implementing Provisions of 10CFR54

ML20034G674
Person / Time
Issue date:	03/01/1993
From:	Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To:
References
SECY-93-049, SECY-93-49, NUDOCS 9303100375
Download: ML20034G674 (19)

Text

{{#Wiki_filter:' ooeoe.............e.e(e. l RELEASED TO THE PDR ? ym i 3/5/q $ c f_, y* Ti 2 dats' i.1i!A! 3 3 ,g u oe........... 7 l $$$h/8 =s POLICY ISSUE March 1, 1993 (Notation Vote) SECY-93-049 For: The Commissioners Fro _m: James M. Taylor t Executive Director for Operations Sub_iect: IMPLEMENTATION OF 10 CFR PART 54, " REQUIREMENTS FOR RENEWAL OF OPERATING LICENSES FOR N"C!. EAR POWER PLANTS"

Purpose:

To inform the Commission of the outcome of the staff's senior management review of key license renewal issues and to obtain the Commission's approval of staff proposals for implementing the provisions of 10 CFR Part 54. Summary: The staff discusses its review of significant license renewal issues that have been identified since 10 CFR Part 54 was promulgated. On the basis of'its review, the staff concludes that a rule change is not needed to facili-tate an effective and efficient renewal review process. The staff identifies a specific approach for carrying out the rule-required integrated plant assessment, which includes an initial broad scope of plant equipment but provides mecha-nisms to quickly focus on important equipment whose perfor-mance or condition could be negatively impacted by aging in the renewal term. The approach recognizes that both mainte-nance rule requirements and risk based methodologies can play a role in meeting license renewal requirements. Addi-tionally, the staff identifies a resource-efficient approach for future staff review of industry reports sponsored by the Nuclear Management and Resources Council (NUMARC); which is l intended to utilize areas of technical agreement between NUMARC and the staff. Specific recommendations are pre-sented to establish Commission-approved positions on key license renewal issues. 090118 e l i i NOTE: TO B2 MADE PUBLICLY AVAILABLE l ON MARCH 3, 1993 i CONTACT: .4 W.D. Travers, ADAR/NRR II 504-1117 j! j de F 9303100375 930301 93-049 PDR 2/

t a-j The Commissioners, i l Backaround: In 1989, the Commission published an advanced notice of i proposed rulemaking for license renewal and published the proposed rule in the summer of 1990. In December 1990, the staff published a draft regulatory guide and a draft stan-dard review plan (SRP), which were both based on the pro- -l posed rule. The final rule was published in December 1991 and became effective in January 1992. The final rule included some significant changes from the proposed rule such as (1) a reliance on the regulatory process to ensure that, except l for renewal-term aging issues which the regulatory process was determined not to address explicitly, the licensirs bases for each plant provide and maintain an acceptable E level of safety; (2) the addition of a definition of age-t related degradation unique t; license renewal (ARDUTLR); (3) changes to the definition of equipment important to license renewal; and (4) revision of the integrated plant f assessment (IPA) to no longer include compilation and ex-plicit review of the current licensing bases (CLBs). ~ Since publishing the final rule, the staff has been. conduct-ing various activities for implementing the license renewal i rule implementation. These actions have included revising the regulatory guide and SRP, interacting with the lead l plant licensees, and reviewing industry technical reports -{ sponsored by NUMARC. Over the past year., a number of sig-nifican*> policy issues have been identified. On December 7, 8, and 18. 1992, the staff briefed the Com-mission on the status of the various license renewal activi-ties and on the staff's plans to resolve key license renewal issues. The staff informed the Commission that a senior management revi?w group would address these issues. The i i staff also stated that it would interact with HUMARC in public meetings to obtain the industry's views. In a staff l requirements memorandum of December 21, 1992, the Commission endorsed the staff's senior management review, identified a number of issues for consideration by the group, and i directed the staff to submit its recommendations to the Commission. I i Discussion: The senior management group has reviewed the following 1 issues identified over the past year: (1) effective and efficient implementation of the IPA screening requirements, t (2) the question of whether the maintenance and license renewal rules can be integrated further, (3) the appropriate scope of the license renewal rule, (4) the appropriate interpretation of ARDUlLR, (5) the role of risk-based meth-l odologies in the IPA, (6) the appropriate level of detail required in an.4pplication and in updates required by the I

4 The Commissioners rule, (7) the question of whether !ssues pertaining to fatigue and the environmental qualification of electrical equipeent (EQ) for older plants should be evaluated for license renewsl or as a current generic safety issue, and (8) the question of whether the form of a renewed license affects the technicM equirements for license renewal. The staff began its r> .ew by focusing broadly on the over-all principles and objectives of the rule. The staff reaf-firmed the rule's two key principles as well as the appro-priateness of the current focus of what must be examined before a renewed license is issued. Specifically, except for NEPA environmental requirements and absent special circumstances, the issue for license renewal is the ef fec-tive management of aging effects on the performance or condition of important plant equipment during the renewal term. The staff's proposed approach focuses on effective programs rathcr than the identification of aging that is or is not unique to the renewal term. Additionally, the ap-proach builds on the judgement that performance and condi-tion monitoring of plant equipment can be relied upon to demonstrate that aging effects, including potential effects in the renewal term, are being effectively managed. Further, the staff concluded that the rule appropriately recognizes that, except for mitigating the effhtts of ARDUTLR, the existing NRC regulatory oversight process is adequate and will continue to ensure that each plant's !icensing bases provides an acceptable level of safety. Before new requirements are established, the regulatory-process requires the NRC staff to evaluate the safety sig-nificance of the requirements pursuant to the backfit provi-sions of 10 CFR 50.109. The staff review and conclusions fer key license renewal issues are discussed below. Lntearated Plant Assessment The rule requires each applicant for license renewal to perform an IPA to demonstrate that plant systems, struc-tures, and components (SSCs) that are important to license renewal (ITLR) have been identified and that, for those components subject to ARDUTLR, AROUILR will be adequately managed. Recognizing that the IPA is the central action required to implement the rule, the staff focused on identi-fying an effective and efficient IPA approach. The specific details identified by the staff for implement-ing the IPA, and described in the following, are based on-a review philosophy which requires initial consideration of

t The Commissioners 1 l t the entire plant to identify those SSCs defined by the rule as ITLR. Furthermore the approach provides mechanisms to quickly focus on equipment that may require new or enhanced ( programs to manage aging in the renewal term. The enclosure provides a discussion and flow path description of the j staff's IPA approach. Under this approach all SSCs currently defined as ITLR, in- ? cluding those subject to operability requirements contained in facility technical specification limiting conditions for i operation (TS LCOs), would be identif4 ! and would.be sub-ject to further evaluation within tb ..n. Although the staff considered the possibility of narrowing the ITLR scope (e.g., to focus only on TS LCOs which include SSCs necessary to mitigate design basis events) it concluded that (1) a-rule change would be required to change the rule's specified 4 scope, (2) the existing ITLR scope is consistent with the rule's philosophy that the applicant should consider equip-ment within a large initial scope in the license renewal process, and (3) SSCs that are currently included 19 TS LCOs but are not safety significant can be removed from V.he TS in s advance of license renewal. 1 The next step in the IPA provides for eliminating parts of i systems or structures that are not required to support the f ITLR function of the previously identified equipment. - i The proposed IPA next determines whether age-related degra-t dation (ARD) is not unique or whether it could be unique. . i The staff believes that most structures and components " s) could be subject to age-related degradation that is u j to license renewal and would therefore not be screened c c of the IPA at this step. This is consistent with both tne IPA requirement to identify SCs that could have any ARDUTLR and the definition of ARDUTLR which includes aging whose effects were not explicitly evaluated by the applicant and approved by the NRC for the renewal term. Although some long-lived ITLR equipment might be identified by the appli- { cant as not being subject to ARDUTLR, a demonstration that t this equipment could not have ARDUTLR would require a de-tailed justification by structure-or component-specific inspection and/or analysis. p i Relatively short-lived equipment that is replaced at a fixed 4 interval could also be identified as not subject to ARDUTLR. Such identification would, however, require an. applicant to provide detailed SC-specific justification in the applica-l tion. The staff expects that the justification for conclu-sions that such equipment has no ARDUTLR will be based on commitments for continuing licensee action to periodically l replace the equipment. As provided in 10 CFR 54.33(b), the ~,,, ~ ,--y

h The Commissioners L5-I staff can include license conditions and technical specifi--- cations as necessary to ensure that licensee actions will be continued so that equipment will not experience ARDUTLR. In determining whether or not technical specifications or _ i license conditions are necessary, the staff will consider such factors as safety significance, the_ nature of adminis-trative controls on commitments and changes to commitments, and reporting requirements. The staff concluded that the disadvantages of justifying that SCs are not subject to ARDUTLR, particularly short-lived SCs covered by periodic replacement programs,are not i offset by an advantage of screening out early in the IPA and most SCs would not be dispositioned by such a justification. Additionally, the staff concluded that, since such justifi-cations would need to be detailed and might be based on con-l tinuing programs, the time and resources required for hear-ings would not be significantly different from the time and resources needed for hearings related to effective program i .iustifications. As discussed below, the staff concluded that, for most SCs, effective programs could be demonstrated. more effectively and efficiently and would provide greater flexibility for future program changes than "no ARDUTLR" justifications. Accordingly, the staff focused on an imple-mentation approach that would provide a permissible alterna-tive to the detailed component-by-component justification. If few SCs are screened out due to "not ARDUTLR,"_ subsequent-screening should be focused upon demonstrating that a sig-nificant majority of SCs are already included in effective programs and can be dispositioned with minimum documentation submitted in the application. The staff believes that an effective program can be demonstrated with minimum docu-mentation if the SC is; (1) covered by regulation or the facility's technical specifications, with specified accep-tance criteria for performance or condition and (2) is in the maintenance rule scope and requirements. As a result of meeting these stipulations, this equipment would be (1) sub-ject to either performance-or condition-related acceptance criteria as a condition of the license or regulation and (2) covered by requirements for root-cause analysis and follow-on corrective action, enhanced monitoring, or both in the event of maintenance preventable failure. For such components this could result in programs with acceptance criteria and monitoring and corrective action requirements that assure conformance with the CLB throughout the renewal term. This approach is valid if the requrred surveilla: a acti-s vity is sufficient to detect, in a timely mannt., ARD effects on performance or condition. If the required _sur-

t, The Commissioners i veillance activity tests the function or condition of the component sufficient to assure the component'4 capability to perform its safety function and comply with the CLB (e.g., Emergency Diesel Surveillance Testing) then this approach is valid. The staff's judgement is that this will be the case for many SCs because the technical specifications already include explicit performance and condition surveillance acceptance criteria, which assure compliance with the CLB. It is possible that some surveillance tests may be partially i sufficient. In such cases, the applicant would need to address those aspects of performance or condition which are not covered by currently required surveillance. This IPA approach recognizes that performance or condition monitoring can be relied upon to demonstrate that aging effects are being effectively managed and controlled. I Whether an applicant chooses to disposition an SC under "not. unique" to license renewal or under " effective program" the staff will review the applicants justification for either disposition. This review will consider that the rule calls for an explicit identification and evaluation of ARD effects to justify dispositioning at the "not unique" phase. SCs included in existing programs but not addressed by tech-l nical specification or by regulation, as discussed above, may also be found to already be subject to effective pro-grams for license renewal. However, the applicant would be required to provide additional justification in the applica-tion. This additional information would demonstrate that the existing programs, including performance or condition monitoring programs established under the maintenance rule (MR), meet the requirements of effi.ctive programs prescribed by 10 CFR Part 54. .i While the MR does not require such information to be subait-ted for evaluation to the NRC, it would be required in a license renewal application to support an agency finding that the standards for issuance of a renewed license, 10 CFR 54.29, have been met. New programs determined to be needed for certain SCs would also require additional information beyond the summary information described above. Alternatively, the applicant could justify that no actions are required because the performance or condition of the SC and compliance with the CLB are not affected by age-related degradation. No changes to the rule are needed to facilitate this IPA ap-proach. i u.-

i l i The Commissioners ! The enclosure provides additional information for performing i the IPA. Intearation of Maintenance and License Renewal Rules Although different in some respects, the MR ard the license renewal rule (LRR) share a fundamentally similar objective and scope. The objective of both rules is to ensure that the effects of age-related degradation on the oerformance or condition of important plant equipment are ader1ately miti-gated; the specific focus of the maintenance rule - mainte-nance preventable failures - essentially encompasses all forms of age-related degradation. Although the maintenance rule 10 CFR 50.65(a)(1) calls for performance goals to be set, the rule does not prescribe specific goals, rather the methods for establishing goals are described in the draf t NUMARC guidelines endorsed by the NRC draft regulatory guide (RG). Similarly the maintenance rule 10 CFR 50.65(a)(2) does not require goals if preventive maintenance is effec-tive, with effectiveness defined in the draft NUMARC guide-lines. The scope of equipment covered by the rules is simi-i lar with a somewhat broader scope (e.g., non-safety-related i equipment that is included in plant emergency operating-procedures) covered by the MR. Additionally, although, the scopes of the two rules are not identical, the somewhat l broader scope of the MR serves to facilitate the proposed IPA approach, since most ITLR equipment will be covered by the MR requirements. The IPA approach described above, which would screen a large majority of SSCs as currently included in effective pro-grams, recognizes.the similarities of the two rules. The approach relies, in part, on MR results-oriented require-ments to assess the effectiveness of maintenance activities. The MR requires licensees to monitor the condition or per-formance of applicable SSCs against goals established by the licensee. Where goals are not met, licensees are required to take corrective actions. Where preventive maintenance has been demonstrated effective through the absence of failures or unacceptable degradation in performance or t condition, formal goal-setting, monitoring, and corrective action are not explicitly required. Together, maintenance rule programs and NRC previously. approved acceptance criteria (i.e., in regulation or within facility technical specifications) provide an efficient mechanism for identifying existing programs which are "ef-fective" under the LRR. In order to 'stablish effective-ness, the acceptance criteria established under technical specification or regulation, and the performance goals, monitoring, preventive maintenance and corrective actions

~_. The Commissioners established under the maintenance rule, must in combination assure compliance with the CLB during the _ license renewal period. Using this approach, a large majority of equipment would be expected to be dispositioned on the basis of the effectiveness of programs. This IPA approach is viewed as an integration of the two rules. Under this approach the emphasis for implementing license renewal and the MR will be essentially the same (i.e., effectiveness of programs) and will not be focused principally on potential uniaueness of aging in the renewal term. The staff noted that although the MR requirements are not effective until 1996, many licensees will begin implementing the maintenance rule in 1993-94 and all licensees are ex-pected to be in full compliance by July 1996. Given the current schedules for plant-specific renewal applications, this approach of integrating the maintenance and license renewal rules is appropriate No changes to either rule are required to implement this pror: sed approach. Role of Risk-Based Methodolooies Although the IPA methodology adopted in the rule is based on a deterministic approach, the Commission recognized that probabilistic risk assessment (PRA) can be useful for achieving the aging-mitigation goals of license renewal. The Commission concluded that PRA could be used to supple-ment the IPA process to further ensure that important equip-ment is identified for the license renewal review. Relying partly on maintenance activities and MR require-ments, the proposed IPA approach recognizes that risk sig-nificance is expected to be a key factor in implementing MR requirements. The draft MR regulatory guide that endorses HUMARC guidelines emphasizes the use of risk in-sights in (1) determining the equipment for which goals and monitoring are established under 10 CFR 50.65(a)(1) and (2) establishing appropriate performance criteria for pre-ventive maintenance programs under 10 CFR 50.65(a)(2). Accordingly, the staff expects that in implementing the MR, licensees will consider insights from plant-specific PRAs, including the results of individual plant examination prc~ grams and reliability-based maintenance assessments. As a result, risk methodologies will play a key role in imple-menting the maintenance rule and an indirect role in imple-menting the LRR requirements. However, use of PRAs will be more limited under the renewal rule. Specifically, use of PRAs cannot excuse nonconformance with the CLB or develop-ment of an effective program to assure CLB compliance during the renewal term.

--~ i I The Commissioners r Level of Detail and Reportina Reauirements j The staff recently noted_ industry concerns regarding the level of detail needed in the supplemental final safety analysis report (SFSAR) application for license renewal. In addition to requiring information on effective programs and j IPA methodology, the rule requires that the SFSAR applica-tion include a list of all SSCs determined to be important t to license renewal (ITLR). Section 54.37 of the rule also requires an annual update to the SFSAR, including any newly identified or deleted ITLR SSCs and ...a list of all changes made to programs for man-l agement of age-related degradation unique to license renewal that do not decrease the effectiveness of programs to which the licensee committed and a brief description, including a summary of the safety evaluation of each change. The staff understands that the ii.dustry has the following principal concerns regarding these requirements: (1) SSCs contained in the SFSAR list could become newly subject to the requirements of 10 CFR 50.71(e), (2) a detailed listing of each ITLR structure and component would result in a voluminous SFSAR application and is inconsistent with the level of detail contained in the initial FSAR and supple-ments, and (3) the requirement for annual reporting of all i changes to effective programs would be an unwarranted admin-- { istrative burden. The staff believes that these concerns can be adequately addressed without changing the rule. For example, the reporting requirements of 10 CFR 50.71(e) are consistent j with the requirements of 10 CFR 54.37(b) as they apply to j additions and deletions from the list of SSCs ITLR. Addi-tionally, the ITLR SSC listing can be accomplished by aroup-inc SSCs (e.g., by function). The staff does not envision a list that includes the identity of each component (such as each containment penetration with identification number). E i The staff believes that the annual reporting requirements of 10 CFR 54.37(c) should not place an unwarranted burden on renewal licensees. The requirements of the rule require a safety evaluation summary of such changes and are explicitly i focused on changes to specific commitments made in the l renewal application. Since, for many.SCs, programs already f required by regulation or technical specification will be used to support the demonstration of-effective programs in j the application, the safety rationale supporting any license amendments related to these programs.will also support reports required by 10 CFR 54.37(c). 'l

~. 1, The Commissioners l Fatiaue and Environmental Oualification of Electrical Eauin-ment While preparing the implementation. guidance for license renewal in the SRP, the staff found several significant issues related to fatigue resistance and environmental qualification of electrical equipment (EQ). A key aspect of the issues related to both fatigue and EQ was whether the licensing bases, particularly for older plants whose licens-t ing bases differ from newer ones, should be reassessed or enhanced in connection with license renewal or whether they should be reassessed for the current license term. The staff reexamined and reaffirmed that the current licens-ing basis is carried forward into the renewal period and that the NRC's regulatory processes will provide assurance i that, except for ARDUTLR, the CLB will be maintained throughout the renewal term. The staff's regulatory pro-i cesses require that potential generic issues, such as i fatigue and EQ, be evaluated for backfit in accordance with 10 CFR 50.109. Where a facility's current licensing Lases includes time-dependent elements, some additional analyses and/or actions may be needed to demonstrate that the CLB requirements continue to be satisfied in the renewal term. As a result of its evaluation of the technical adequacy of fatigue and EQ requirements for renewal in 1992, the staff ioentified generic issues that should be evaluated for i backfit during the current license term. The staff is developing interoffice action plans to address upgrading fatigue and EQ requirements for older plants. These plans will integrate ongoing research and licensing reviews to ensure timely resolution. l Form of Renewal License i The staff reviewed the form of the renewal license (i.e., a new license or an amendment to the current operating li-i cense) and its impact on technical requirements for license renewal. The staff has reaffirmed the position that the form of the license does not affect the scope of the techni-cal issues to be reviewed or the safety evaluations required [ to be performed. The scope and criteria of the staff's review for license renewal and the scope of lice > renewal i hearings are unaffected by the rule's stipulatic at a l renewed, rather than an amended, license be isst in con-nection with NRC_ authorization for extended operation. Neither the rule nor staff activities in developing regula-t tory guidance presume that the form of the renewal license affects what is technically necessary for license renewal. i l

. - ~ _ _ i i 1 The Commissioners ! NUMARC-Sponsored Industry Reports The staff reviewed the status of the NUMARC-sponsored indus-i try reports (irs). Ten irs address aging issues associated-l with specific structures and systems, and one IR on IPA i screening' methodology. The original intent of-the irs for specific structures and systems was to serve as a reference-able surrogate for carrying out the IPA requirements of the license renewal rule. The staff has been reviewing the irs to develop safety evaluation reports (SERs). -l To best us, the technical information and agreements from the NUMARC program, the staff plans to follow a new approach for handling the irs. Instead of writing an SER for each IR, the staff plans to incorporate appropriate technical information from the irs into the draft SRP for license renewal. This approach is expected to result in a single docue nt that will include IR insights and establish the staff's review acceptance criteria. It is also' expected to result in more efficient use of staff resources. l i

== Conclusions:== The staff's conclusions are the following: I. The license renewal rule does not need to be changed. The rule, including its two key principles, is logical i and practical, and provides a sound basis for safe operation beyond the 0-year term of the original l operating license. 2. The license renewal review begins with a defined broad scope but enables the applicant to quickly focus.on important equipment that could be negatively affected by aging in the renewal term. l 3. The proposed approach for implementing the IPA (a) is consistent with the rule, (b) is technically sound, j (c) provides an appropriate integration of the MR and LRR requirements, and (d) will enable both the NRC and t the applicant to use their resources efficiently. j 4. The scope of ITLR SSCs, including those subject to operability requirements contained in TS LCOs, is defined in the rule and any change would require a rule l change. Changes to remove TS LCOs which are not safety significant can be effected outside of license renewal. l The proposed IPA approach will result in most SSCs subject to TS LCOs being identified as currently sub-i ject to effective programs without the need for de-l tailed analyses. j

i [ The Commissioners : 5. In conducting the IPA, ARDUTLR should be viewed broadly [ and the IPA should focus on effective programs rather than the identification of aging that is or is not unique to the renewal term. Although SCs may be demon-e strated as not'being subject to ARDUTLR, as defined in the rule, such a demonstration would require a detailed analysis by the applicant and review by the NRC staff for each SC. The focus of the proposed IPA approach (i.e., on program effectiveness) is a more appropriate i and efficient approach. 6. Programs that involve, in part, performance and condi-tion monitoring can be structured so that they can be relied upon to demonstrate that aging is being effec-tively managed. 7. The IPA can be carried out so that a large majority of SCs can be demonstrated to be included in existing effective programs as evidenced by (a) the equipment being addressed by regulation or in facility technical specifications, with specified acceptance criteria for performance or condition; and (b) inclusion in the maintenance rule scope and requirements. 8. Issues, including those related to fatigue and EQ, that involve the adequacy of the CLB will be addressed as potential safety issues within the existing regulatory f process. Where a facility's current licensing bases 1 includes time-dependent elements, some additional analyses and/or actions may be needed to demonstrate that the CLB requirements continue to be satisfied in the renewal term. 9. The level of detail required for information in the application, and for future reporting, is appropriate and does not result in unwarranted administrative bur-dens. Specifically, (a) ITLR SSCs can be identified in the application by means of appropriate groupings rather than the identification of each piece of equip-ment, (b) reporting requirements for listed ITLR SSCs are applicable to additions and deletions and should not result in additional burdens, (c) requirements in 10 CFR 54.37(c) for annual reporting of changes - will not result in unwarranted burdens for renewal licensees.

10. The form of the renewal license does not affect the scope of the technical issues reviewed or the safety evaluations required.

a s

l The Commissioners 11. The areas of technical agreement in the industry re-ports should be incorporated in the standard review plan instead of SERs. Coordination: The Office of the General Counsel has no legal objection to this paper and is preparing a separate paper to address the legal issues associated with the approach discussed in this paper. Recommendations: That the Commission: 1. Approve the staff's proposed approach for implementing the integrated plant assessment provisions (10 CFR 4 54.21(a)) of the license renewal rule including; a 1 broad view of ARDUTLR, a focus on program effectiveness and minimization of documentation for SCs that are already includeo in an effective program. 2. Approve the staff's positions on the level of detail i required in an application. 3. Approve the staff's approach for handling the NUMARC - i industry reports. 4. Note that, prior to meeting with the Commission, the staff will conduct a public meeting to discuss the proposed positions contained in this paper. The public meeting will be scheduled in mid-March 1993. If we find a need to change our recommendations as a result of the public meeting we will promptly inform the Commission. On receiving approval from the Commission for recommenda- ^, tions 1, 2, and 3 above, the staff will begin revising both the draf t regulatory guide and draft standard review plan to i incorporate these recommendations. Additionally, in con-ducting our initial activities to implement this approach, the staff will inform the Commission of any new issues which are identified. The staff is developing interoffice action plans to address t the upgrading of requirements pertaining to fatigue and EQ for older plants. These plans will integrate ongoing re-search ar.d licensing reviews to ensure timely resolution. l l 4 9 orm ~ r ~,

The Commissioners Unless the Commission directs otherwise, within 1 day from the date of this paper, the staff will release this paper to the public to facilitate public and industry review before the upcoming Commission briefing which is being scheduled for late-March 1993.* 3 7 eYTi fxecutiveDirector for Operations

Enclosure:

IPA approach Commissioners' comments or consent should be provided directly to the Office of the Secretary by COB Monday, March 15, 1993. 4 Commission Staff Office comments, if any, should be submitted to the Commissioners NLT Monday, March 8, 1993, with an infor-mation copy to the Office of the Secretary. If the paper is of such a nature that it requires additional review and comment, the Conc.:issioners and the Secretariat should be apprised of when comments may be expected. DISTRIBUTION: Commissioners OGC OCAA OIG OPP EDO SECY

• As at " arch 3, 1993, this meeting is scheduled for Monday, March 15, 1993, at 2:00 p.m.

y f INTEGRATED PLANT ASSESSMENT I figure 1 illustrates the integrated plant assessment (IPA) flow path required \\ by the rule at 10 CFR S4.21(a). Preliminary staff estimates of the disposi-tion of systems, structures, and components (SSCs) within the IPA are indi-cated on the figure. s The staff's proposed approach for implementing the IPA is consistent with the requirements of the rule. All plant equipment would initially be included. SSCs defined in the rule as important to license renewal (ITLR) would be identified at the first step of the IPA, "54.21(a)(1): Scope Review." The scope of ITLR equipment defined in the rule is broad and encompasses more than safety related SSCs, including equipment subject to operability requirements contained in facility technical specification limiting conditions for opera-would also be initially identified as ITLR pports SSCs subject to TS LCOs tion (TS LCOs). Equipment that directly su The staff estimates that approximately 30 percent of plant SSC* would be eliminated from the IPA at i this step. At the second step, "54.21(a)(2): Functional Review," equipment that is part of ITLR systems or structures but that is determined not to be needed to support ITLR functions would be eliminated from the IPA. The staff estimates that only about 5 percent of plant structures and components (SCs) would be eliminated at this step. i The third step of the IPA, "54.21(a)(3): Uniqueness Review," involves the identification, from among the remaining ITLR'SCs, of SCs that are not unique and those which could have age-related degradation that is unique to license. renewal (ARDUTLR). Age-related degradation that is unique to license renewal is defined in 10 CFR 54.3 and is focused on the effects of the degradation. The definition of ARDUTLR is broad and includes degradation whose effects were l not explicitly identified and evaluated by the licensee for the period of ex-tended operation and the evaluation found acceptable by the NRC. Since the effects of age-related degradation during the period of extended operation, for the most part, will not have been plicitly considered, most of the SCs identified in the uniqueness review will be identified as SCs that could have ARDUTLR. This step allows a licensee to forward a technical rationale for its conclusion that an SC could not have ARDUTLR. The staff believes that few SCs would be eliminated from the IPA as not subject to ARDUTLR. Figure 2 illustrates how the uniqueness review would be carried out, in demonstrating that an SC is not subject to ARDUILR a detailed justification, submitted to the staff previously or included in the license renewal applica-tion, would be required. Two types of potentially acceptable justifications Current regulatory practice for TS LCOs defines the necessary criteria that must be satisfied for an SSC to be operable or to have operability. Specifically, an SSC is operable when it is capable of performing its speci-fied function (s) and when all necessary attendant instrumentation, controls, i electrical power, cooling or seal water, lubrication, or any other auxiliary equipment that is required for the SSC to perform its function (s) is also capable of performing their related support functions. i ENCLOSURE ?

L L i of no ARDUTLR could be provided. Long-lived SCs could be evaluated by means of analyses and/or inspection to demonstrate that very little age-related l degradation is occurring and that no future actions are needed to manage aging l through the renewal term. Assuming NRC agrees with this conclusion, no further IPA review or licensing action would be required. Additionally, for short-lived SCs, a demonstration of no ARDUTLR could be made on the basis of existing plant replacement programs that are implemented at fixed intervals. Such identification would, however, require an applicant to provide detailed SC-specific justification in the application. The staff expects that the justification for conclusions that such equipment has no ARDUTLR will be based on commitments for continuing licensee action to peri-odically replace the equipment. As provided in 10 CFR 54.33(b), the staff can include license conditions and technical specifications as necessary to ensure that licensee actions will be continued so that equipment will not experience ARDUTLR. In determining whether or not technical specifications or license conditions are necessary, the staff will consider such factors as safety sig-nificance, the nature of administrative controls on commitments and changes to commitments, and reporting requirements. t The staff's recommended approach is focused on the "54.21(a)(5): Effective Program Review" as the principle mechanism for addressing SCs which (1) are i a already subject to performance or condition monitoring programs for managing l l the effects of aging, or (2) may require new or enhanced programs. The staff estimates that the IPA approach would result in most plant SCs being identi-fied as already subject to effective programs with minimal documentation in the application. Another group of SCs would be screened out as part of an ex-isting effective program, however, the application would need to identify and justify the acceptance criteria, corrective action requirements and facility review, and procedure controls. Much of this could be done by generic grcupings of SCs. Figure 3 presents additional information on the conduct of the "54.21(a)(5): Effective Program Review." SCs identified as (1) subject to technical speci-fications or regulations, with specified acceptance criteria for performance 1 or condition, and (2) included in the maintenance rule scope and requirements could be demonstrated to be addressed by existing effective programs. These l criteria ensure that SCs are subject to formal regulatory requiremerts that i will effectively manage the effects of aging through the renewal term. As previously noted, the staff estimates that a cignificant majority of plant SCs would be eliminated from further evaluation on this basis. An application j' would need to contain minimal documentation to address these criteria. Addi-tionally, since the programs for these SCs are already subject to established i NRC change and reporting requirements, the 10 CFR Part 54 change and reporti g requirements would not be applicable. As indicated on Figure 3 the staff estimates that the remaining plant SCs, j approximately 5 percent, would require additional evaluations as a result of j one of two situations. Information will need to be provided (1) to establish the effectiveness of any new programs determined to be necessary or (2) to i justify that no actions are needed to manage aging effects for some SCs.

FIGURE 1: INTEGRATED PLANT ASSESSMENT (IPA) ALL PLANT EQUIP VIENT ,r 54.2- (a)(- ): SCOPE REV EW + ~ao* 5L.21 (a)(2}: FUNCTIONAL REVIEW + ~s* 54.2- (a)(3): UNIQUENESS REVIEW + 7;? 54.2' (a} (5} : EFFECTIVE PROGRAVI REVIEW v ~5%

m FIGURE 2: UNIQUENESS REVIEW l ~ l + 54.21(a)(3): UNIQUENESS REVIEW [ is or could be uniqu[ conse enewai l 54.21(a)(5): EFFECTIVE REQUIRE 5 5XPLICIT ID PROGRAM REVIEW AND EVALUATION BY APPLICANT AND FOUND ACCEPTABLE BY THE NRC (54.3) FUTURE ACTIONS REQUIRED NO YES NO TECHNICAL SPECIFICATION PROGRAM NEEDED. OR LICENSE CONDITION LIC. COND. OR TS (Few SCs) PER 54.33(b) TO-ENSURE NO ARDUTLR & TO MAINTAIN THE CLB exampie: One-Ume inspection of tanks - little or no corrosion Example: Replacement at fixed intervals

~ FIGURE 3: EFFECTIVE PROGRAM REVIEW { ~ 65% 60% ~ 1 54.21(a)(5): EFFECTIVE PROGRAM REVIEW l ~5% Most SCs Some SCs

• EXISTING PROGRAM
• ACCEPTANCE CRITERIA IN ACCEPTABLE, BUT EXIS"ING TS OR REG. AND NO ACCEPTANCE INCLUDED IN MAINT. RULE CRITERIA IN TS Minimum information provided.

Additional information provided. Very few SCs , Very few SCs

• NEW PROGRAM
• NO PROGRAM REQUIRED NEEDED Detailed information provided.

Detailed information provided.

• Must ensure CLB is maintained during renewal period s

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