ML20035H738
| ML20035H738 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1993 |
| From: | Taylor J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| FRN-59FR46574 AF05-1-007, AF5-1, AF5-1-7, SECY-93-113, NUDOCS 9305060372 | |
| Download: ML20035H738 (41) | |
Text
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RELEASED TO THE PDR r
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April 30, 1993 SECY-93-113 FOR:
The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
ADDITIONAL IMPLEMENTATION INFORMATION FOR 10 CFR PART 54,
" REQUIREMENTS FOR RENEWAL OF OPERATING LICENSES FOR NUCLEAR
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POWER PLANTS" rdRPOSE:
To clarify the staff approach described in SECY-93-049, to describe the integrated plant assessment through the use of conceptual examples using selected structures and components, and to make recommendations to the Commission involving license renewal issues.
To inform the Commission that a package containing proposed rulemaking, of an l
appropriate form, is being developed by OGC with input from NRR to resolve key differences between the staff's position in SECY-93-049 and the statement of considerations for 10 CFR Part 54.
The paper submitting the rulemaking
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package may involve a confidential discussion of issues that the Commission would wish to withhold and thus should be separate from the present paper.
l BACKGROUND:
In SECY-93-049 of March 1, 1993, the staff informed the Commission of the conclusions of the staff's senior management review of key license renewal issues.
The staff also requested approval of its proposals for implementing the license renewal rule,10 CFR Part 54.
In a memorandum to the Commission of March 9,1993, the Office of General Council (OGC) commented on the staff's
Contact:
Scott Newberry, NRR:PDLR 504-1183 NOTE: TO BE MADE PUBLICLY AVAILABLE IN THREE (3) WORKING DAYS FROM THE DATE OF THIS PAPER.
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1 The Commissioners approach described in SECY-93-049. 0GC discussed the need to consider inter-pretive rulemaking because the staff's proposed approach departs, in some areas, from the Commission's explanation of the manner in which the rule would apply in the statement of considerations accompanying the notice of final rulemaking in the Federal Reaister.
0GC suggested that the Commission con-sider issuing an interpretive rule and exercise its discretion to follow notice and comment procedures for a proposed rulemaking if the Commission agrees with the staff's approach. This would assure licensees considering renewal that the Commission will not fundamentally change its explanation of the manner in which the rule would be applied without going through rulemaking procedures.
OGC, with staff support, is preparing a proposed rulemaking package to resolve key differences between the statement of considerations of the final rule and the staff's proposed approach in SECY-93-049. The proposed rulemaking package will be submitted to the Commission shortly.
By memorandum of March 24, 1993, the staff notified the Commission of its intent to further discuss several of the license renewal issues described in SECY-93-049.
Additionally, the staff committed to provide specific examples illustrating the approach for performing an integrated plant assessment.
In a staff requirements memorandum of March 24, 1993, the Commission requested that the staff determine if any of the recommendations in SECY-93-049 should be modified as a result of the public meeting on March 12, 1993, and the Commission briefing on March 15, 1993.
In a memorandum of April 1, 1993, the staff informed the Commission that the staff found no need to modify any of the recommendations in SECY-93-049 and reaffirmed its intent to further clarify several of the license renewal issues contained in SECY-93-049.
Upon considering the Commission's concerns and other issues, the staff expanded the scope of the effort described in its March 24 and April 1,1993, memoranda to the Commission.
The scope now includes the issues discussed in SECY-93-049 and other issues associated with 10 CFR 54.21(a), 54.21(c),
54.33(d), 54.37(a), and 54.37(c).
In a memorandum of April 2, 1993, Commissioner Curtiss commented on the staff's March 24, 1993, memorandum and requested the staff to (1) discuss the level of detail required in a renewal application, (2) discuss the circum-stances under which matters that are included as part of a licensee's effec-tive program must be addressed by technical specifications or other docketed commitments, (3) clarify the term " acceptance criteria" as it relates to effective programs, (4) clarify the meaning of the terms " character" and
" magnitude" as they relate to the definition of age-related degradation unique to license renewal (ARDUTLR), and (5) describe the enforcement implications of the staff's approach. These issues are also addressed in this paper.
t The Commissioners DISCUSSION: discusses questions with the approach described in SECY-93-049.
Specifically, the staff clarifies (1) the meaning of the term " acceptance criteria" as it applies to effective programs, (2) the meaning of the terms
" character" and " magnitude" as they apply to the definition of age-related degradation unique to license renewal, (3) the staff's expectations for descriptions of effective programs in a renewal application, and (4) the practical implications of the effective program descriptions from an enforce-ment perspective.
The discussion regarding the terms " character" and " magni-tude" includes additional information on the staff's proposed approach for identifying structures and components which are or could be subject to ARDUTLR. Specifically, the discussion identifies that in addition to replace-ment programs based on fixed time intervals, other replacement programs based on condition monitoring could be used to justify a conclusion that a structure or component is not subject to ARDUTLR. As a result, a greater number of structures or components than that estimated in SECY-93-049 may be disposi-tiened in accordance with 10 CFR 54.21(a)(3).
In Enclosure 2 the staff discusses proposals for implementing other require-ments of the license renewal rule. The staff proposes guidance on the expected level of detail a licensee should submit as part of its renewal application to justify the continuation of exemptions and relief.
The staff also discusses guidance for implementing the recordkeeping provisions of the rule and discusses the need to report changes in programs used to manage ARDUTLR. Most importantly, the staff discusses its proposed implementation of 10 CFR 54.21(a)(5) which requires the licensee to demonstrate either of the following for structures or components important to license renewal that are or could be subject to ARDUTLR:
(1) it has an effective program that meets all the requirements of 10 CFR 54.21(a)(6) or (2) an effective program is not necessary. This discussion includes an additional method not described in SECY-93-049 for determining that an effective program is not necessary.
This method would allow a licensee to demonstrate, pursuant to 10 CFR 54.21(a)(5)(ii), that an effective program which meets the specific requirements of 10 CFR 54.21(a)(6) is not required based on a determination that the structure or component is not of fundamental safety importance and that either (1) no activity is needed, or (2) that activities are in place, that will be safficient to ensure compliance with the current licensing basis.
The staff has included proposed criteria which could be used to identify structures and components of fundamental safety importance.
Programs that are needed to manage ARDUTLR for structures or components which are not of fundamental safety importance, would be described in the application and reviewed and approved by the staff, but would not be subject to effective program requirements including the administrative requirements of 10 CFR 54.33(d) and 54.37. contains examples of selected structures and components and discusses how licensees could implement the integrated plant assessment including the disposition of each specific component or structure.
i The Commissioners !
COORDINATION:
l OGC has reviewed this paper and has no legal objection.
RECOMMENDATIONS:
Unless the Commission directs otherwise, within 3 days from the date of this paper, the staff will release this paper to the public to facilitate public and industry review of the proposed staff's positions and implementation guidance.
After review of this paper and the OGC draft rulemaking package, the staff recommends that the Commission direct the staff to publish for public comment, l
for a period of 45 days, the staff's approach described in SECY-93-049, the positions and implementation guidance contained in this paper, and the l
proposed rule.
In addition to soliciting public comment on the two Commission l
papers and the proposed rule, the staff would solicit responses to the following questions:
1.
Are there any specific changes that the NRC should make to the license renewal rule? Provide the specific language that should be used, clearly state the reasons for the proposed changes and how the proposed changes resolve the issue of concern.
2.
Are there other approaches to implementation of the current license renewal rule that the staff should pursue or additional alternatives the process proposed in SECY-93-049 and this paper? Please provide the reasons or basis for any proposed alternatives or suggested changes.
3.
Are the staff's proposed criteria for identifying structures and compo-nents which are of fundamental safety importance for license renewal appropriate?
4.
Will the approach for meeting the requirements of 10 CFR Part 54, as described in SECY-93-049 and this paper, result in the imposition of regulatory requirements for plant structures or components that are not of fundamental safety importance?
(a) What are specific examples of equipment that are not of fundamental safety importance but would become newly subject to the regulatory r
controls as a result of the license renewal process?
(b) Would any resulting regulatory requirements be needed to satisfy the rule's objective--that age-related degradation unique to license renewal will be managed to ensure that the licensing basis will be maintained during the renewal term?
(c) Would any such regulatory requirements be overly burdensome?
If yes, provide a detailed explanatian for your conclusions.
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The Commissioners,
On receiving direction from the Commission, the staff will prepare a Federal Reaister notice announcing the availability of the two Commission papers and the rule for public comment.
Following the close of the comment period, the staff will inform the Commission of the issues raised during the comment period and will discuss proposals for resolution of any new or significant issues that could affect the implementation of the proposed staff's approach contained in the two Commission papers or the rule. At that time, the staff may propose specific draft guidance which could be issued by the Commission.
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A am'es M. T lor Executive Director for Operations
Enclosures:
1.
Clarification of Terms and Proposed Staff Approach Described in SECY-93-049 2.
Implementation Guidance for Selected License Renewal Requirements 3.
Illustration of The Integrated Plant Assessment
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Commissioners ' comments or consent should be provided directly to the Office of the Secretary by COB Monday, May 17, 1993.
Commission Staff Office comments, if any, should be submitted to the Commissioners NLT May 10, 1993, with an information copy to the Office of the Secretary.
If the paper is of such a nature that it requires additional review and comment, the Commissioners and the Secretariat should be apprised of when comments may be expected.
DISTRIBUTION:
Commissioners OGC OCAA OIG PA OPP DCD Central Files EDO ACRS SECY
l CLARIFICATION OF TERMS AND PROPOSED STAFF APPROACH DESCRIBED IN SECY-93-049 I.
J_NTRODUCTION In SECY-93-049, the staff proposed an approach for implementing the inte-grated plant assessment provisions of the license renewal rule. The staff's proposed approach, as described in SECY-93-049, was based on a review philosophy that requires initial consideration of all plant systems and structures.
Further, however, this philosophy provides a process that would quickly focus the staff's review on structures, systems, or components that may require new or enhanced programs for managing age-related degradation that would occur during the period of extended operation. This approach employed a broad interpretation of the definition of age-related degradation unique to license renewal (ARDUTLR) and described an approach that a licensee could use to determine when an effective program was needed and how to document these programs.
The Commission briefing on March 15, 1993, regarding SECY-93-049 and subsequent questions from Commissioner Curtiss (memorandum to James M. Taylor dated April 2,1993) identified areas of the proposed approach that require clarification.
In this enclosure, the staff clarifies (1) the meaning of the term " acceptance criteria" as it applies to effective programs, (2) the mean-ing of the terms " character" and " magnitude" as they apply to the definition of ARDUTLR, (3) the staff expectations for descriptions of effective programs in the renewal application, and (4) the practical implications of the des-cription from an enforcement perspective.
In Enclosure 2 of this paper, the staff discusses other implementation issues related to different provisions of the license renewal rule that are not explicitly discussed in SECY-93-049.
II. ACCEPTANCE CRITERIA A number of questions have been raised concerning the term " acceptance criteria" as it is used in the rule (10 CFR 54.21(a)(6)(ii)) with respect to the requirements of an effective program. By " acceptance criteria" the staff means specific defined values or conditions that a licensee would use to determine when to take corrective actions. The staff expects that licensees would obtain these values or conditions, when necessary, from the current licensing basis so that the acceptance criteria preserves necessary safety margins and maintains the current licensing basis. Examples of this type of acceptance criteria could be (1) the need to maintain a minimum pipe-wall thickness of 0.25 inches in order to ensure integrity of the pressure boundary or (2) a fan that must provide a minimum flowrate of 2000 standard cubic feet per minute at 0.32 inches water gauge static head pressure. However, the staff also recognizes that not all acceptance criteria would have defined or ENCLOSURE 1 1
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i derived quantitative _ values. The criteria could describe'a physical condition that would initiate corrective action. An example of this type of acceptance criteria would be a program that required a licensee to initiate repairs to a safety-related cooling water intake structure when inspection reveals exposed t
reinforcing steel.
The staff notes that the specific values or conditions need not necessarily be submitted for each structure or component as part of the effective program description in an application. The NRC will confirm through the use of selective inspections that acceptance criteria exist, that licensees have incorporated these criteria into plant procedures, and that existing plant administrative controls effectively control changes to these criteria.
However, the adequacy of the acceptance criteria may be challenged in a license renewal proceeding.
In this case, submittal and justification of the criteria may be required as part of the hearing process, but it would not become part of the current licensing basis unless so ordered by the Hearing Board.
Acceptance criteria and the implementing procedures for license renewal could be those that already exist in current plant surveillance procedures for such things as technical specification compliance.
Further, licensee programs i
established to implement the maintenance rule may also contain performance criteria that could serve as the criteria against which a licensee would evaluate the need for timely corrective action for license renewal required effective programs.
i III.
CHARACTER OR MAGNITUDE The current definition of ARDUTLR identifies' three sets of conditions under I
which degradation would be classified as unique to license renewal.
Part one of the definition states degradation is unique' to license renewal if it is degradation "...that occurs during the term of the current operating license but whose effects are different in character or magnitude after the term of 1
the current operating license (the period of extended operatton);...." The i
staff has received questions concerning the meaning of the terms " character" or " magnitude" and how they will be interpreted and applied.
For the license renewal rule, the character of degradation is different when either the rate of degradation changes significantly from that seen during the initial licensed term or if the physical or chemical properties of a material or component change from that known during the initial licensed term.
Examples of changes in the character of degradation would be either a case in which the rate of degradation was known to accelerate during the period of extended operation,-a case in which the structural integrity of'a component would not be maintained because of continued degradation during the period of extended operation, or a case in which a materia 1' began to leach or emit caustic gases during the extended periods but had not done so during the' initial licensed term.
Effects of degradation that are different in " magnitude" refer to the condi-i tion that occurs when-degradation of a structure or component (1) continues beyond the degradation that would have occurred if operation had ceased at the j
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end of the currently licensed term and (2) the degradation would or could result, if unmitigated by any action, in unacceptable performance or condition of the structure or component (i.e., outside the current licensing basis) during the period of extended operation.
Structures or components that are not normally replaced are subject to cumulative degradation greater than that experienced in the original 40-year license period.
Examples would include primary system piping that would experience continued erosion or stainless steel that would experience additional thermal embrittlement caused by continued exposures to high temperatures during plant operations.
If a licensee evaluates, by inspection and/or analysis, the cumulative effect of such degradation and determines that the effect of the degradation will result in a failure to maintain the current licensing basis, then the effects of the degradation are "different in magnitude" and the structure or component ja subject to ARDUTLR.
If by evaluation, the licensee determines that the effect of the degradation will not result in the failure to maintain the current licensing basis during the renewal term and that no activity is necessary to manage the degradation, then the effects of the degradation are not "different in magnitude."
If the evaluation further concludes that there is no change in the character (e.g.,
no significant increase in the rate of degradation in the renewal period), the structure or component is not subject to ARDUTLR. A licensee could then use the specific structure or component evaluation in its integrated plant assessment as a basis to conclude either (1) that, in accordance with 10 CFR 54.21(a)(3), the structure or component is not subject to ARDUTLR, or (2) that, in accordance with 10 CFR 54.21(a)(5)(ii), an effective program to manage the effect of the degradation is not needed.
The staff concludes that structures or components that are replaced before the original operating term ends (i.e., at least one like-kind replacement between 20 and 40 years) and which are not projected to be affected by a significantly greater degradation rate during the renewal term, would not be subject to ARDUTLR. Such replacement would ensure that the structure or component would not experience service greater than 40 years and, accordingly, ARDUTLR could not occur. This conclusion is viewed as consistent with the Commission's statement of considerations accompanying 10 CFR Part 54 which indicated that a generic conclusion regarding the acceptability of all periodic replacement programs could not be made at the time the rule was promulgated. The staff's position for concluding that due to replacement a structure or component is not subject to ARDUTLR is based on the specific requirement that like-kind replacement occur such that service life will not exceed 40 years.
Programs which involve replacement based on condition monitoring and which do not ensure a service life of 40 years or less would not permit a conclusion that a structure or component is not subject to ARDUTLR. However, programs which rely on condition monitoring to determine replacement, but which also ensure that service life does not exceed 40 years (e.g., replacement has already occurred or a specific replacement commitment is included) can be used to justify a conclusion that a structure or component is not subject to ARDUTLR. Using this approach, a greater number of structures and components could be identified as not subject to ARDUTLR than was indicated in SECY-93-049.
3
Should a licensee choose not to perform a specific evaluation of the degradation effect for the period of extended operation in accordance with 10 CFR 54.21(a)(3), then as part of the integrated plant assessment, the licensee assumes that the structure or component could be subject to ARDUTLR.
The licensee would be required to discuss how the effects of degradation would be managed during the period of extended operation. The presence of existing programs or activities that would adequately manage degradation effects that are or could be important to license renewal is NOT an acceptable basis for arguing that a component could not experience ARDUTLR but could be used as the means of demonstrating how the effects of ARDUTLR would be managed.
IV. DESCRIPTION OF AN EFFECTIVE PROGRAM The license renewal rule at 10 CFR 54.21(a)(6) requires that a licensee submit a description of the applicable effective programs for each structure or component and demonstrate that these programs will be effective in managing the effects of ARDUTLR as part of the technical information to be submitted in a renewal application. At issue, is what level of detail is necessary in the application to " describe" a proposed effective program that satisfies the requirements in the rule.
To fulfill its obligations under the rule, a licensee would need to provide sufficient detail for the staff to conclude that all the necessary elements of an effective program are present.
Specifically, the description must include (1) how it will ensure the identification and mitigation of any effects of ARDUTLR, (2) conditions or parameters used to establish the acceptance criteria, (3) how timely corrective action will be taken if acceptance criteria are not met, and (4) the administrative controls for implementing the program.
As the examples in Enclosure 3 illustrate, the staff would expect that the identification and mitigation of the degradation can be described by clearly identifying the function (s) of the structure or component and the program elements that would ensure, by testing, monitoring, or evaluating, the applicable performance or condition regardless of the type of degradation.
These descriptions could rely to a large extent on methods, processes, and quantitative values that have been previously accepted by the staff (i.e., are given in some existing licensing documentation). The " description" of the effective programs simply refers to the basis for the criteria and state the vehicle that implements the specific program actions. The practical effect of this type of description is that the detailed plant procedures are not drawn into the specific review as part of the renewal application.
Further, should the implementing surveillance procedures be revised, the process in 10 CFR 54.33(d) to determine whether the effectiveness of the programs is decreased would only be initiated if a licensee were to change an element of the program description contained in the application (e.g., the period of a surveillance, the type of inspections, the value of a minimum wall thickness, or the method for calculating the critical crack size) or if the program described incorporates by reference a specific element of the plant procedures. NRC
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approval would only be necassary should this determination conclude that the change involved is a decrease in effectiveness. Other changes to the 4
implementing surveillance procedures which are not contained in the application or directly referenced in the application would be reportable in the 10 CFR 54.37(c) annual report. The staff discusses the implementation of changes to programs and the reporting requirements in greater detail in.
V.
ENFORCEMENT ISSUES The fundamental enforcement-related requirement for license renewal is the need to ensure that appropriate enforcement actions can be taken in cases when licensees fail to perform actions necessary for managing the effects of ARDUTLR during the period of extended operation. Concerns have been raised regarding the possibility that the staff approach for implementing the renewal rule will result in tighter regulatory controls for some current activities.
The NRC can take appropriate enforcement action in instances where a licensee fails to adequately manage the effects of age-related degradation during the period of extended operation. Failure to perform an effective program, or parts of an effective program, can result in enforcement action being taken.
Additionally, failure to follow the change and reporting requirements contained in 10 CFR 54.33 and 54.37 can also result in enforcement action being taken.
Commitments to perform activities that ensure that a structure or component is not subject to ARDUTLR will be treated like other licensee commitments contained in the Final Safety Analysis Report (FSAR), unless the Commission deems it necessary to impose license conditions and/or technical specifica-tions as indicated in 10 CFR 54.33. Additionally, commitments contained in the application that demonstrate that no effective program is needed to manage the effects of ARDUTLR for a structure or component will also be treated like other licensee commitments contained in the FSAR, unless the Commission deems it necessary to impose license conditions and/or technical specifications.
The staff expects that license conditions and/or technical specifications will not be required for most commitments contained in a license renewal applica-tion.
Pursuant to 10 CFR 54.33(e), the legal status, including enforcement options, for existing regulatory commitments which are not relied upon to demonstrate an effective program for license renewal remains unchanged in the renewal period.
The staff views the requirements of 10 CFR Part 54, combined with existing enforcement policy, as sufficient to ensure appropriate enforcement options during the renewal term.
If, after issuance of the renewed license, the staff were to determine, based on operational experience, that these provisions were not sufficient, the staff has the regulatory authority to impose changes to correct any deficiencies pursuant to 10 CFR 50.109.
5
i IMPLEMENTATION GUIDANCE FOR SELECTEr LICENSE RENEWAL RULE REOUIREMENTS I.
INTRODUCTION This enclosure discusses staff proposals for the implementation of certain requirements of the license renewal rule.
These staff prooosals give guidance on the expected level of detail an applicant would include as part of a renewal application for justifying the continuation of exemptions or reliefs.
The proposals also provide guidance for implementing the rule's recordkeeping provisions and provisions related to the need to report changes in programs or procedures used to manage the effects of age-related degradation unique to license renewal (ARDUTLR). Most importantly, in this enclosure, the staff discusses its proposed implementation of 10 CFR 54.21(a)(5) which requires, for structures and components important to license renewal (ITLR) that are or could be subject to ARDUTLR, the demonstration of an effective program that i
meets all the requirements of 10 CFR 54.21(a)(6) or that an effective program is not necessary.
1 11.
DEMONSTRATION THAT AGE-RELATED DEGRADATION UNIOUE TO LICENSE RENEWAL 15 MANAGED (10 CFR 54.21(a)(51)
As currently written, the integrated plant assessment (IPA) of the license renewal rule provides a licensee two methods for demonstrating how the effects of ARDUTLR will be managed.
Specifically,10 CFR 54.21(a)(5) requires a licensee to demonstrate that structures or components that could have ARDUTLR are (i) addressed through an effective program, or (ii) need not be addressed in an effective program. The requirements for compliance with 10 CFR 54.21(a)(5)(i) are defined in 10 CFR 54.21(a)(6).
Previously, the staff's interpretation of 10 CFR 54.21(a)(5)(i) has been that if any program was required to manage the degradation of a structure or component, then the program was to meet the specific requirements of an effective program.
In the application, a licensee could demonstrate by analyses or inspection that the component required no program to manage the degradation.
The staff's review and conduct of the IPA process by preparing examples (Enclosure 3) identified the following " graded approach" that includes three methods for dispositioning structures and components using the provisions of 10 CFR 54.21(a)(5):
54.21(a)(5)(i):
EFFECTIVE PROGRAM IS NECESSARY Effective programs would be required for those structures and components of fundamental safety importance. Such structures and components pursuant to 10 CFR 54.21(a)(5)(i) would r.eed to meet the i
specific requirements of 10 CFR 54.21(a)(6).
ENCLOSURE 2 1
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I In implementing this approach, the licensee could identify structures and components of fundamental safety importance using, for example, l
criteria that is described in SECY-93-067, " Final Policy Statement on Technical Specifications improvements," dated March 19, 1993. The SECY-93-067 criteria include:
i Criterion 1:
Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 3:
A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
j Criterion 4:
A structure, system or component which operating experience or probabilistic safety assessment has shown to be j
significant to public health and safety.
l 54.21(a)(5)(ii):
NO EFFECTIVE PROGRAM NEEDED - NO ACTION t
No effective program needed pursuant to 10 CFR 54.21(a)(5)(ii) would l
apply to those structures and components for which no action would be l
necessary to manage ARDUTLR such that the current licensing basis ir maintained through the renewal term.
l 54.21(a)(5)(ii):
NO EFFECTIVE PROGRAM NEEDED - ACTION REQUIRED Structures and components, which are or could be subject to ARDUTLR, but which are determined not to be of fundamental safety importance (i.e.,
do not require " effective programs") would be addressed by current
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licensee programs or commitments (e.g., maintenance programs) if they were demonstrated to be sufficient to ensure compliance with the current licensing basis. Although program demonstrations under 10 CFR 54.21(a)(5)(ii) would not need to meet all of the specific requirements for effective programs, they would require descriptions in the i
application which would be reviewed and approved by the staff.
Such program descriptions would not be subject to 10 CFR 54.33(d) or 54.37.
4 In performing the example IPA (Enclosure 3), the staff made use of the graded approach for dispositioning structures and components that are not of fundamental safety importance under 10 CFR 54.21(a)(5)(ii) because (a) effective programs would be required for structures and components of fundamental safety importance, and (b) structures and components which require actions to manage ARDUTLR but which are dispositioned under 10 CFR r
54.21(a)(5)(ii) will be subject to other programs' and controls,.such as the 2
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maintenance rule, 10 CFR Part 50, Appendix B, Criterion XVI (Corrective i
Action), and 10 CFR 50.59.
In' the absence of formal criteria, the staff used its experience and engineering judgment in determining if a component was of fundamental safety importance. To disposition a structure or component under j
10 CFR 54.21(a)(5)(ii), a renewal application would contain a description of i
the evaluation or program performed which demonstrates that the effects of ARDUTLR will not adversely affect the performance or condition of the structure or component during the renewal period.
Detailed evaluations and implementing procedures need not be submitted but would be retained by the licensee in accordance with the requirements of 10 CFR 54.37(a).
This approach which is based on graded importance to safety represents a departure from the staff's approach in SECY-93-049.
The staff believes that implementation of this approach will require an interpretive rule that would i
clarify implementation of the IPA at 10 CFR 54.21(a)(5) and that the requirements of 10 CFR 54.33(d) are applicable only to effective programs required by 10 CFR 54.21(a)(5)(i).
An alternative to the graded approach initially considered for dispositioning under 10 CFR 54.21(a)(5)(ii) when conducting the example IPA was that effective programs would be required only for those structures and components that are determined by review to require augmented or new program requirements for managing ARDUTLR.
10 CFR 54.21(a)(5)(ii) would be used to disposition those structures and components that have either adequate existing programs for managing the effects of ARDUTLR such that no additional programmatic requirements are necessary, or require only a one-time inspection in order to demonstrate that no further action is necessary to manage the effects of i
ARDUTLR. This approach is not proposed because it would emphasize the current
't existence of a program rather that the safety significance of the structure or
. component.
Ill.
EXEMPTIONS (10 CFR 54.21(c))
To comply with 10 CFR 54.21(c), a license renewal applicant must submit a list of all plant-specific exemptions granted in accordance with 10 CFR 50.12.and reliefs granted in accordance with 10 CFR 50.55a.
Additionally,10 CFR 54.21(c) requires a licensee to submit justification for continuing current i
exemptions or reliefs into the renewal term if the exemptions or reliefs were granted on the basis of an assumed service life or period of operation bounded by the original license term (i.e., if they have_ a time-dependent basis) or if the exemption or relief is related to structures or components subject to ARDUTLP,.
A.
STAFF APPROACH The regulations in 10 CFR 50.12 and 10 CFR 50.55(a) define the types of information that must be submitted in order for the staff to grant exemptions and reliefs, respectively.
For license renewal, the staff approach for continuation of existing exemptions or reliefs relies to the maximum extent on NRC-approved information that the licensee previously submitted. Therefore, a
. licensee's justification for the continuation of an exemption or relief into the renewal period should refer to previous staff evaluations when still valid 3
t and should provide additional analyses which are needed to support the resolution of issues that are not valid for the renewal period.
Exemptions or reliefs that would require either an additional analysis or an update include those granted on the basis of (1) cost-benefit evaluations or risk assessments which include the remaining term of the license, (2) the service life of a component, or (3) other time-dependent rationale.
For exemptions or reliefs t
that are related to structures or components that are or could be subject to ARDUTLR, licensees should assess the impact of the exemption or relief on managing the effects of age-related degradation unique to the period of extended operation. Specifically, the licensee should review the exemption or relief to ensure that the proposed action or relief has been evaluated in the t
utility's effective programs for t% affected SSCs.
The staff has selected several exam;.:es to illustrate the type of information that could be submitted to satisfy the requirements of 10 CFR 54.21(c).
Tables 1 and 2 include the summarized information for two exemptions and two j
4 reliefs.
What licensees would be expected to submit to meet the requirements t
of 10 CFR 54.21(c) and the examples in Tables 1 and 2 are discussed in the remainder of this section.
t B.
DOCUMENTATION REQUIREMENTS 1.
Exemptions l
l Licensees are required to list all exemptions granted in accordance with 10 CFR 50.12 that are currently in effect.
Exemptions that have expired and are no longer valid need not be listed. The listing should include a brief explanation of the exemption and the date granted (see Table 1).
For all i
exemptions, the licensee should determine whether the exemption was granted on i
the basis of a time dependent criterion and whether the exemption is related l
to SSCs that are or could be subject to ARDUTLR.
Licensees'should use the following information to determine if either of the two criteria are met.
Time Basis Determination A licensee will need to review the licensing documentation for each exemption I
to determine if the exemption was granted on the basis of a service life or the original license term.
If the exemption is not based on any time i
dependency, the licensee would indicate this and would briefly explain its determination that the exemption has no time dependent basis.
If a licensee chooses to use the format shown in Table 1, this explanation j
would appear in the CONTINUATION JUSTIFICATION column of the table (see
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Example 1 of Table 1).
If a licensee determines that the exemption does t
include a time-dependent basis, it must reanalyze or update that portion of the initial analysis to account for the revised remaining life of the plant, assuming the staff were to approve the application for license renewal.
Example 2 of Table 1 illustrates an exemption from the requirements of 10 CFR 50.62(c) that requires a diverse turbine trip for mitigation of anticipated transients without scram events. To continue this exemption for a renewed license, a licensee would have to reference the previously submitted analysis 4
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and state that, with the exception of the time-dependent provisions, all of the previous analyses or evaluations are still valid and any commitments would remain in effect for the renewal term. NRC's justification for granting the relief was, in part, based on the fact that the licensee performed a safety assessment for the remaining license term and determined that the resultant reduction in risk was negligible with the automatic turbine trip installed.
Because the risk assessment was integrated over the remaining license term, the licensee would need to reconsider the risk over the renewal term.
The results would be included in the application and the specific location would be referenced in the exemption list.
ARDUTLR Determination Licensees are expected to review their licensing documentation and indicate whether the exemption is related to SSCs which are or could be subject to ARDUTLR. The licensee's results could be indicated in such an ARDUTLR column as shown in Table 1.
If the exemption is related to SSCs subject to ARDUTLR, the licensee is expected to list the related systems and reference the location within the renewal application that evaluates effective programs for the structures or components in light of the exemption.
These results could be summarized in such a CONTINUATION JUSTIFICATION column, as shown in Table 1, with specific references to more detailed analyses (see Example 1 of Table 1).
If the exemption is not related to SSCs subject to ARDUTLR, the licensee should indicate this in the table (see Example 2 of Table 1).
2.
Reliefs Similar to exemptions, the licensee must list all reliefs granted in accordance with 10 CFR 50.55a.
Reliefs that have expired or are no longer valid would not be listed. A licensee's listing should include a brief explanation of the relief. and the date granted. As with exemptions, the licensee should determine whether the relief was granted on the basis of a time-dependent criterion and whether the relief is related to SSCs that are ITLR and are subject to ARDUTLR.
Unlike exemptions that grant exceptions to the regulations of 10 CFR Part 50, reliefs granted in accordance with 10 CFR 50.55a exempt licensees from performing inspections or tests required by the ASME Code or permit licensees to perform inspections or tests that differ from the code requirements. The information required by a licensee for listing reliefs differs slightly from that required for exemptions.
Licensees should use the following information as guidance in providing information for continuation of reliefs into the renewal period.
Time-Basis Determination As ISI or IST programs and corresponding reliefs are granted for a specific period and. not for the remaining term of the license, reliefs are generally not granted on a time-dependent basis. However, a relief could have a time-dependent basis if a renewal application were submitted in the last ISI or IST interval of the current license. Therefore, the staff expects a licensee to review the licensing documentation to determine if a relief was granted on the 5
basis of a service life or the original license term.
For example, if the current ISI or IST interval was approved in year 35, the pronram could contain a relief based on the fact that only 5 years remained under the current license.
If the relief does not have a time dependent-basis, the licensee should summarize its rationale for this conclusion (see Example I of Table 2).
Reliefs in effect for license renewal applications submitted before the last ISI or IST interval (i.e., the third ISI or IST interval) cannot be continued into the renewal period because a new ISI or IST program would need to be submitted for review and approval before the end of the original license term.
No discussion of a relief's time-dependent basis is required for license renewal applications before the last ISI or IST interval (see Example 2 of Table 2).
ARDUTLR Determination As with exemptions, licensees are expected to review their licensing documentation and indicate whether the relief is related to SSCs that are ITLR and subject to ARDUTLR.
If it is, the licensee should reference the location l
within the renewal application that evaluates effective programs for the SSCs in light of the relief or any alternative ISI testing requirements.
If the relief is not related to SSCs that are ITLR and subject to ARDUTLR, the licensee must provide a brief summary supporting this determination.
For t
license renewal applications submitted before the last ISI or IST interval i
that do not rely on the system ISI or IST program as an effective program, the licensee need not consider ARDUTLR, but need only reflect this situation in the relief list (see relevant portion of Example 2 of Table 2).
l 3.
Justification For Continuation i
When first granting exemptions and reliefs during the initial license term, the staff made specific findings, as required by the regulations, related to 1
each exemption or relief. For exemptions, 10 CFR 50.12 required the staff to determine that the exemptions were allowed by law, did not present an undue risk to the public health and safety, and were consistent with the common defense and security.
Furthermore, 10 CFR 50.12 requires the staff to find that special circumstances (as defined in 10 CFR 50.12(a)(2)) existed to warrant the exemption. Similar findings, as specified in 10 CFR 50.55a(g)(6),
were made for the granting of reliefs.
Therefore, to reissue exemptions and reliefs for continuation into the renewal period, the staff must again make these findings.
l Although, licensees will not be required to resubmit entirely new exemption or relief requests, they are expected to review their licensing documentation to l
ensure that all special circumstances, staff conclusions, and bases for those conclusions are still valid for the renewal term. With the exception of those differences noted in the Tjme-Basis Determination and ARDUTLR Determination sections for exemptions and reliefs in this enclosure, the requirements for justifying the continuation of exemptions and reliefs are the same.
Licensees are expected to make definitive statements about the validity of the previous findings and reference the appropriate licensing documents (e.g., the Final Safety Analysis Report (FSAR) or NRC safety evaluations) (see Table I, j
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Examples 1 and ?; and Table 2, Example 1).
For example, if plant conditions were assumed and commitments were made as a basis for granting an exemption, a licensee must state its intention to maintain plant conditions as before or to continue with previous commitments (see Example 2 of Table 1).
Likewise, if the basis for granting a relief was the impracticality of performing a code-required test, a licensee must indicate the continued impracticality for the renewal period (see Example 1 of Table 2).
If previous conclusions or bases for an exemption or relief are no longer valid, as in the case of a time-dependent evaluation, a licensee must reanalyze the specific issue to justify continuing the exemption or relief for the expanded time interval of license renewal (see Example 2 of Table 1).
Additionally, if the exemption or relief is related to SSCs that are ITLR and subject to ARDUTLR, the licensee is expected to list the related systems and provide a referer.;e to the location within the renewal application that describes effective programs for the SSCs. A licensee must include any reanalysis in the application and reference it accordingly in the exemption and relief list.
The staff expects that a licensee's additional analyses should be sufficiently detailed to show how the circumstances, conditions, or bases of the previously granted exemption or relief are changed or unchanged in the renewal term; and i
if changed, why these changes support the continuation of the exemption or relief. The licensee must examine the reanalyzed element and reach a conclusion to support continuation of the exemption or relief in light of all previous conclusions and commitments relied on in granting the original i
exemption or relief.
For instance,_ in Example 2 of Table 1, the licensee updated the risk reduction for the renewal period because the previous risk assessment was based on'the remaining term of the license.
The licensee's new analyses must not only show that the resultant reduction in risk is still low, but that the negligible reduction in risk together with the licensee commitments of increased relief capacity and more negative moderator temperature coefficient, yield the same justification for granting the initial exemption.
IV. CHANGES TO PREVIOUSLY APPROVED PROGRAMS AND ANNVAL REPORTING RE0UIREMENTS (10 CFR 54.33(d) AND 54.37(c))
The second principal of license renewal is that the licensing basis.must be maintained during the renewal term. Part 54 of 10 CFR ensures this principal by requiring that programs-the NRC approved as being effective for managing the effects of ARDUTLR be maintained during the license renewal period.
In accordance with 10 CFR 54.33(d), the licensee can, without prior NRC approval, change effective programs for managing the' effects of ARDUTLR that do not decrease their effectiveness, provided the changes are reviewed by the onsite review committee.
The NRC must approve any licensee change that involves a decrease in effectiveness of programs described in the FSAR or' application for i
managing ARDUTLR before 'it can implement the change.
In accordance with 10 CFR 54.37(c), the licensee must annually report to the NRC any changes. that do not decrease the effectiveness of programs described in the FSAR that 7
manage the effects of ARDUTLR and maintain records of these changes, including a written safety evaluation of the bases for concluding that the changes do not decrease the effectiveness.
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A.
ADMINISTRATIVE CONTROLS Before changing its effective programs, the licensee will need to determine whether the change affects a program described in the renewal application that
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the NRC approved as effective for managing the effects of ARDUTLR.
If it does, the next step would be to determine whether the change decreases the effectiveness of that program for managing the effects of ARDUTLR.
Licensees a
have procedures that define how to prepare safety evaluations and when to submit proposed changes to the NRC for approval (e.g.,10 CFR 50.54, 50.59, l
technical specification changes, and changes to the facility).
These procedures usually require a description of the change and step-by-step instructions for determining when NRC approval is required and how and when to report changes.
For example, such a procedure might ask if the change involves a change to the ser.urity plan.
If the answer is "yes," the procedure i
will direct the engineer to another question asking if the change results in a i
decrease in the effectiveness of the security plan.
From here, the procedure will instruct the engineer to either justify a "no" answer or obtain prior NRC approval if the answer is "yes."
License renewal will require a licensee to
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add a similar set of steps to their procedure to determine whether any changes could decrease the effectiveness of license renewal effective programs as described in the renewal application.
For example, the procedure could ask if the change involves a change to a license renewal program for managing the effects of ARDUTLR.
If "yes," the procedure would then ask if the change is described in the FSAR or in the renewal application and whether it decreases the effectiveness.
If "no," the engineer would document the justification for E
why the change does not decrease the effectiveness, and proceed with the change without NRC approval.
If "yes," the licensee needs to seek NRC approval before implementing the change.
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I The determination of whether a change _ decreases the effectiveness of a program is the responsibility of the licensee. No specific guidance for judging a i
decrease in effectiveness is provided in the rule, however, a decrease in program effectiveness would be represented by an actual or potential decrease in safety function performance or condition of SSCs ITLR as specified by the current licensing basis.
B.
SUBMITTALS AND STAFF REVIEWS Changes to license renewal effective programs for managing ARDUTLR are controlled by the provisions of 10 CFR 54.33(d) and 54.37(c).
- However, changes to effective programs may affect programs already required by i
regulations or technical specifications and controlled by 10 CFR Part 50 change processes. NRC regulations 10 CFR 50.90 through 50.92 define the regulatory process for changes to technical specifications and license amendments, and 10 CFR 50.59 defines the conditions that determine when plant
-changes constitute an unreviewed safety question for which NRC review is required.
NRC regulations in 10 CFR 50.54 establish change control processes under which changes to the quality assurance (QA), emergency preparedness I
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(EP), and physical security programs may be performed.
The staff process for controlling changes to license renewal programs and procedures for managing i
the effects of ARDUTLR is similar to the 10 CFR 50.54 processes for controlling changes in QA, EP, or security programs.
Prior Acoroval Recuired: Because the licensee may depend on existing programs, such as technical specifications, to support demonstration of the effectiveness of their license renewal effective programs, certain changes may i
be subject to both 10 CFR Parts 50 and 54 controls.
Changes that involve technical specifications, license amendments, exemptions, or otherwise require j
prior NRC approval under 10 CFR Part 50 may have different requirements for review and approval.
In this case, the more stringent regulatory requirements take precedence.
For instance, a change to a license renewal program that decreases the effectiveness of that program and involves a change to technical specifications would require a licensee to submit an application for a license amendment (10 CFR 50.90).
In this case the more stringent requirement, the license amendment, governs the licensee's action, and the licensee's justification of a decrease in the effectiveness of a license renewal program to manage the effects of ARDUTLR can simply be included in or as an attachment to the basis for the license amendment.
In its safety evaluation for the license amendment, the staff will also evaluate the licensee's analysis of the effect of the change on the license renewal programs that manage the effects i
of ARDUTLR.
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Part 54 of 10 CFR also permits a licensee to make changes, following NRC l
approval, that decrease the effectiveness of programs that manage the effects of ARDUTLR but which are not governed by other more stringent controls (e.g.,
technical specifications). The request for a change to a license renewal effective program that decreases its effectiveness should include a description of the change, the need for the proposed action, a technical l
analysis of the change, and a description of how any commitments made in i
accordance with 10 CFR Parts 50 and 54 are affected.
In reviewing the submittal, the NRC staff will verify that the change is properly documented i
with an adequate safety evaluation that resolves all safety issues pertinent
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l to the change and will prepare a safety evaluation documenting the basis for approving or disapproving the change.
l Prior Approval Not Reauired: The licensee may implement a change that does l
not decrease the effectiveness of a license renewal effective program to manage the effects of ARDUTLR without prior NRC approval.
For changes such as i
these, the licensee need only submit an annual report in accordance with the provisions of 10 CFR 54.37(c) as described in the next paragraph.
C.
ANNUAL REPORTING REQUIREMENTS p
Changes to the license renewal effective programs that do not require prior NRC approval-(i.e., changes that do not decrease the effectiveness of the programs) must be submitted in an annual report.
The staff envisions that the annual license renewal report of such changes would contain brief descriptions l
and supporting discussions that-will be similar in scope and detail to that currently contained in the required report of 10 CFR 50.59 changes. To meet the 10 CFR Part 54 annual reporting requirement, the licensee would submit a 9
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brief description of the change and the justification for concluding why it i
does not decrease the effectiveness.
To avoid duplication of reports, the documentation of changes required by 10 CFR 54.37,;, ^uld be attached to the 10 CFR 50.59 report (if submitted annually) or th:
' 50.59 report could be reformatted to incorporate additional informatic.
ae.;sary to fulfill the 10 CFR 54.37(c) requirements. The 50C for 10 CFR Part 54 (56 FR 64943) appear I
to recommend submitting a separate report.
However, the staff interprets
" separate" to mean that these changes be kept separate from the routine 10 CFR 50.59 changes such as in a separate report, as an attachment to the 10 CFR 50.59 report, or otherwise indicated by a specific statement in the individual 10 CFR 50.59 summary so that the changes are easily recognized. As with 10 CFR 50.59 changes, the NRC staff will review the annual reports submitted l
as a basis for selecting change packages for inspection, ard the inspections will be similar in scope and depth to inspections of 10 CFR 50.59 documenta-tion.
The staff will document the changes inspected to ensure that the licensee is properly implementing the requirements of 10 CFR Part 54. The NRC l
inspection will focus on the accuracy of the safety evaluations prepared by l
the licensee. The inspection will include a review to verify that the change is properly documented with (1) an evaluation that provides a justification for the change, (2) an adequate technical basis for determining that the change will not decrease effectiveness, and (3) resolution of all safety issues pertinent to the change.
D.
EXAMPLES Example 1 The licensee changes a component listed as ITLR in the supplement to the FSAR for a like *ind component, however, the manufacturer has increased the interval recommended for performing maintenance from monthly to quarterly.
This component is being managed by an effective program in accordance with 10 CFR 54.21(a)(6), but is not included in technical specifications or any program required by 10 CFR Part 50. The licensee determines that this change in maintenance interval will not decrease the effectiveness of the program.to manage the effects of ARDUTLR, based on the manufacturer's recommendation and industry experience. Therefore, the licensee proceeds with the change after-.
review by the onsite review committee. Documentation that there is no reduction in effectiveness must be maintained by the licensee, but need not be submitted to NRC.
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in the 10 CFR 54.37(c) annual report, the licensee states, as part of its summary of the evaluation of the change, that the component is involved in an j
effective program, and that the change did not decrease the effectiveness of j
the program. The licensee must maintain docamentation that provides the basis for concluding that the change does not reduce the effectiveness of the program.
l Examole 2 j
i The licensee wants to increase a surveillance interval in technical specifications for a component based on a change in the manufacturer's recommendation for testing. This surveillance is also relied on as part of an l
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effective program for managing the effects of ARDUTLR under 10 CFR j
54.21(a)(6). The licensee determines that thir, change does not decrease the effectiveness of the program to manage the effects of ARDUTLR.
The licensee i
is not required under 10 CFR Part 54 to receive prior NRC approval of this change.
However, because it is a change to technical specifications, the licensee must submit a license amendment request in accordance with the provisions of 10 CFR 50.90. This functions as documentation for the basis of the conclusion that there is no reduction in effectiveness as required by 10 CFR 54.33(d).
No submittal will be required to comply with 10 CFR Part 54 other than to include a summary of the evaluation of the change in the annual 10 CFR 54.37(c) report.
Alternatively, if the licensee determines in this example, that the change
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involving a license amendment could decrease the effectiveness of an effective program for managing the effects of ARDUTLRs prior NRC approval in accordance with 10 CFR 54.33(d) would be required.
In this case, the licensee's safety 4
analysis required to justify the license amendment would need to provide the basis for why the change to licensee programs will continue to provide i
adequate monitoring of the condition or functional performance. The staff will include an evaluation of the licensee's basis for this determination. in i
its safety evaluation for the license amendment.
The licensee need not include a summary of the evaluation of this change in the annual 10 CFR 54.37(c) report.
Example 3 l
In response to Generic Letter XX, the licensee has committed to measuring the wall thickness at certain points along the service water (SW) piping to monitor pipe wall thinning and currently performs this inspection every j
outage. The staff based its finding that this inspection is effective in i
managing the effects of ARDUTLR on the licensee's evaluation of generic
.i experience and conservative assumptions for degradation rates. The licensee
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wants to increase the inspection interval from every outage to every 5 years, l
based on additional plant specific and generic data obtained showing no significant wall thinning since the inspections began and an analysis that predicts that the pipe wall will not degrade beyond ASME code requirements-for i
another 30 years.
The licensee determines that this change will not decrease the effectiveness of the program to manage the effects of ARDUTLR, and, therefore proceeds with the change. A summary of the safety evaluation for.
the change would be included in the annual 10 CFR 54.37(c) report and the i
licensee must maintcin documentation that provides the basis for concluding that the change does not reduce the effectiveness of these programs.
V.
MAINTAIN RECORDS IN AUDITABLE AND RETRIEVABLE FORM (10 CFR 54.37(a))
NRC regulation 10 CFR Part 54.37(a) requires a licensee to retain all information and documentation that demonstrates compliance with 10 CFR Part 54 i
in an auditable and retrievable form for the term of the renewal license.
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i A.
STAFF IMPLEMENTATION Because much information will be submitted in a renewal application, the primary intent of this rule provision is to ensure that the documents used as a basis for the licensee's conclusions contained in the application are available for review and that the conclusions are justified.
In this regard, the documentation that should be maintained includes the records that demonstrate the implementation of the licensee's programs and methodologies i
and any key technical information or analyses used to justify specific i
technical conclusions.
i As an example, a license renewal application will contain a list of SSCs ITLR.
To support the development of this list, the licensee should have available the specific procedures or documented processes used to develop that list as well as any work products that show that the specific plant procedures or methodologies were properly implemented.
The staff may want to inspect these types of documents as part of its license renewal review.
t The requirements of 10 CFR 54.37(a) do not establish new reqairements for a
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recordkeeping system.
Licensees can use their existing document control i
systems to store, control, and retrieve specific information. The staff does not interpret this license renewal rule provision to require that all license renewal information be located in one central location.
In fact, the staff expects that existing utility processes for storage of information would be i
followed and simply revised to include reference to license renewal information, as appropriate.
For example, license renewal information for the i
fire protection systems would most probably be retained within the organizational unit of a utility responsible for fire protection.
Similarly, license renewal information related to the high pressure injection system 7
might be retained by the systems engineer responsible for that system.
i When plant procedures require the development of specific worksheets or tables, the worksheets or tables must be available for inspection.
Similarly, when licensee analyses lead to changes in current regulatory commitments, the licensee will need to show how existing regulatory commitments were modified to reflect the implementation of changes required for license renewal.
The intent of this provision is not to extend the requirements of 10 CFR Part 50, Appendix B, and QA programs to programs and document control systems that are not currently covered by these requirements.
Therefore, the staff will not require licensees to expand their existing QA programs to cover SSCs that are currently not part of the QA effort but yet are identified as ITLR and could have ARDUTLR.
B.
STAFF REVIEW The staff will review the documentation that supports the license renewal l
application during staff inspections of the licensee's facilities. The specific areas of review will be dependent on the issues selected by the NRC.
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i At a minimum, the NRC will review (1) some portion of the implementation of the licensee's screening methodology for selecting SSCs ITLR, (2) selected evaluations of components and structures that could hav'e ARDUTLR, and 1
(3) evaluations of the need for or justification of effective programs.
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TABLE 1 (EXEMPTIONS)
TITLE DATE DESCRIPTION TIME BASIS ARDUTLR CONTINUATION JUSTIFICATION 1.
App. K (ECCS) 01/23/92 Sections I.D.3, I.D.4, and NO YES In its safety evaluation, the staff Exemption from demon-I.D.5 of App. K to 10 CFR previously concluded that these sections stration of ECCS Part 50 detail the require-were not applicable to this plant and that performance requirements ments for the calculation of the licensee used an acceptable evaluation of I.D.3, I.D.4, and reflood rate, steam inter-model that is more applicable to top flood-I.D.5 of App.K action, and refill and re-ing plants to satisfy the intent of these flood heat transfer for ECCS sections.
The staff has reviewed and modeling for PWRs. These approved the licensee's ECCS evaluation sections were based on bot-model. (See SE dated January 23, 1993.)
tom flood plants. This The ECCS evaluation models are not de-plant has Upper Plenum In-pendent on assumptions related to length jection (UPI).
of a license and therefore have no time-dependency basis.
The systems relied upon in the ECCS mod-eling are The effective program review for these systems, in light of this exemption is found in Section of this application. (See Effective Program Review for these systems.)
2.
ATWS 03/12/90 10 CFR 50.62(c) requires YES NO In its safety evaluation, the staff Exemption from 50.62 re-automatic auxiliary (or found ; hat the licensee has taken steps to quirement to have diverse emergency) feedwater system substantially mitigate the consequences of turbine trip on ATWS and turbine trip, diverse limiting postulated ATWS events.
The from reactor trip, for-utility committed to increased relief conditions indicative of capacity and to refuel with a more negative ATWS. The licensee does not moderator temperature coefficient.
In meet the requirement for addition, the licensee's Integrated Safety initiation of turbine trip Assessment Program (ISAP) indicated a neg-under ATWS conditions.
ligible reduction in risk over the remaining life of the plant, with turbine trip installed.
(See NRC SE' dated March 12, 1990.)'
TABLE 1 (EXEMPTIONS) (Continued)
TITLE DATE DESCRIPTION TIME BASIS ARDUTLR CONTINUATION JUSTIFICATION The licensee has reviewed the previous assumptions in its ISAP and has updated the risk reduction for the renewal period.
Further, the licensee commits to the plant conditions previously assumed in in the safety evaluation to mitigate ATWS events. (See FSAR supplement Section
.)
No automatic turbine trip system is in-stalled, therefore, this exemption does not involve equipment subject to ARDUTLR.
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i TABLE 2 (RELIEFS)
TITLE DATE DESCRIPTION TIME BASIS ARDUTLR CONTINUATION JUSTIFICATION l.
ISI - SERVICE WATER 10/26/87 Section XI of the ASME Code N0 YES In its safety evaluation, the staff Relief from performane requires system hydrostatic found it impractical to perform the of system hydros. for 4th test pressure to be "the hydrostatic tests at the test pressures 10-year ISI interval.
lowest pressure setting delineated in Section XI ASME Code, 1980.
among the number of safety The staff found the licensee's alternative or relief valves provided tests sufficient to assess the system's for overpressure protection" structural integrity.
(See SE dated within the system to be October 26,1987.) This relief was granted tested and the " imposed for the 4th 10-year ISI interval which will pressure, including static extend years into the renewal period.
head, will not exceed, 106%
The licensee concludes that the ASME Code of test pressure for system.
requirements will remain impractical to Due to the system designs, perform for the remainder of the ISI period there is no practical way that extends into the renewal period and to achieve the required test commits to continue to perform the alter-pressures at all elevations.
native tests delineated in the SE.
The systems included in these hydrostatic tests are -
, which are subject to ARDUILR. The effective program review has been performed for these systems in light of these alternative tests dis-cussed in Section of the application.
(See Effective Program Review.)
This relief was not granted based on the remaining term of the operating license or any service life; therefore, it has no time-dependent basis.
2.
ISI - SERVICE WATER 10/26/87 Same as 3. above NO YES The licensee relies on the Service Water RQlief from performance ISI program in their effective programs.
of hydrostatic test for The systems included in the hydrostatic 3rd 10-year ISI interval tests are -,
, and
, which are subject to ARDUTER.
t TABLE 2 (RELIEFS) (Continued)
TITLE DATE DESCRIPTION TIME BASIS ARDUTLR CONTINUATION JUSTIFICATION The effective program review has been per-formed for these systems in light of the alternative tests, and are discussed in Section of this application.
(See Effective Program Review.)
This relief will expire at the end of the 3rd ISI interval, which will occur prior to the end of the current license term. The need for this relief will be reexamined upon the submittal of the next ISI program.
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I ILLUSTRATION OF THE INTEGRATED PLANT ASSESSMENT 1.
INTRODUCTION In SECY-93-049, the staff informed the Commission of the outcome of the staff's senior management review of key license renewal issues and requested t
approval of the staff's proposals for implementing the provisions of the license renewal rule, 10 CFR Part 54.
This enclosure provides clarification of two SECY-93-049 issues:
(1) implementation of the integrated plant assess-ment (IPA) screening requirements, and (2) the appropriate level of detail required in a license renewal application. To provide clarification of these issues, the staff prepared examples to illustrate how the IPA approach could j
be implemented.
The staff selected two structures and seven components to test its proposed approach for an IPA. Taking on the role of a license renewal applicant, the structures and components were individually evaluated against the IPA screen-ing criteria of 10 CFR 54.2'.(a)(1) through (6) with the exception of 54.21(a)(4) as discussed below. The staff sought to illustrate the level of detail expected in an IPA through the use of these examples.
The structures and components that the staff selected were:
Feedwater pump Safety-related feedwater system vent, drain, and test lines Safety-related station batteries i
Refueling water storage tank Internal flood mitigation components (floor drains, water level instruments, etc.)
Class I piping Intake structure Cable to RHR pump Safety-related motor operated valves
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The results of the staff's evaluation of these nine structures and components I
against the requirements of 10 CFR 54.21 are provided in the following section as Examples I through 9.
Each example includes a summary rationale of the determination and its supporting program description. A standard format was used to document the results of the staff's evaluation for each structure or component. The section titled " Functional Description" provides an overview of the selected structure or component's purpose as used in the example.
The results of the staff's evaluation for 10 CFR 54.21(a)(1) through (6), as applicable, are documented in the section titled " IPA Determination." The requirements of 54.21(a)(4) that require the methods for performing 10 CFR 54.21(a)(1) through (3) be described and justified are not directly addressed in the examples.
However, the staff expects that a licensee would (1) rely principally on the important to license renewal (ITLR) criteria in 10 CFR 54.3 i
ENCLOSURE 3 r
in addressing 54.21(a)(4)(i), (2) describe a plant-specific methodology for addressing 10 CFR 54.21(a)(4)(ii), and (3) utilize the approach a described in SECY-93-049 and this document to identify structures or components that could be subject to age-related degradation unique to license renewal (ARDUTLR) per 10 CFR 54.21(a)(4)(iii).
11.
EXAMPLES 1.
FEEDWATER PUMP IN PWR Functional
Description:
The feedwater pumps raise the pressure of the condensate system so that water can be injected into the steam generators.
IPA Determination 54.21(a)(1): Scope Review The feedwater pump is not important to license renewal per 10 CFR 54.3 since:
1.
It is not safety-related because it is not required to remain func-tional during or following any design basis event.
2.
Its failure would not directly prevent the satisfactory accomplish-ment of a safety-related function.
3.
It is not needed to demonstrate compliance with regulations for fire protection, environmental qualification, pressurized thermal shock, i
anticipated transients without scram, or station blackout.
4.
It is not subject to the operability requirements contained in the l
technical specifications.
2.
SAFETY-RELATED fEEDWATER SYSTEM VENT, DRAIN, AND TEST LINES Functional
Description:
All safety-related vent, drain, and test lines that are used for filling, draining, and hydrostatically testing the feedwater.
system are included in this evaluation.
This group of lines does not include the portions that are normally isolated from the pressure boundary via isolation valves.
IPA Determination 54 21(a)(1): Scope Review Because these vent, drain, and test lines are safety-related, they are important to license renewal.
54.21(a)(2):
Functional Review For these vent, drain, and test lines, an analysis demonstrates that failure of the unisolated portion would not impede the system from 2
1 l
4 performing its required function.
Specifically, leakage resulting from a complete failure of any of these lines would be too small to affect the ability of the auxiliary feedwater pump from delivering the required I
water to the steam generator. Therefore, these lines do not perform a required function and were not considered in our license renewal evalua-tion per 10 CFR 54.21(a)(2).
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3.
SAFETY-RELATED STATION BATTERIES Functional
Description:
In the event of a less of all ac power, station batteries provide c7ntrol power for starting diesel generators, operating electrical circuit breakers, and control of logic circuits associated with electrical safety equipment.
Batteries also provide ac power through dc-to-ac inverters to the safety-related instrument buses. Some plants also use these batteries to control the switchyard circuit breakers when ac power is lost In the event of a station blackout (all offsite power is lost and the diesel generators do not start), the batteries are the only installed source of electrical power to provide for the safe shutdown of the nuclear reactor.
l IPA Determination 54.21(a)(1):
Scope Review l
The station batterics are important to license renewal because they are safety-related.
Batteries are necessary to ensure the capability to shut down the reactor and maintain it in a safe shutdown condition, or to ensure the capability to prevent or mitigate the consequences of acci-dents. Batteries are also relied on in safety analyses and plant evaluations to demonstrate compliance with the Commission's regulations concerning station blackout (10 CFR 50.63).
54.21(a)(2):
Functional Review Batteries are relied upon to remain functional to provide power to electrical safety-related equipment and instrument buses. Batteries also control the switchyard circuit breakers when ac power is lost.
During a loss of all offsite power, the batteries are the only installed source of electrical power for the safe shutdown of the nuclear reactor.
54.21(a)(3): Uniqueness Review Batteries are not subject to ARDUTLR based on the definition in 10 CFR 54.3.
Specifically, batteries are short-lived components. They have already been replaced at intervals based on condition during the term of the current license and will continue to be replaced during the renewal term. The age-related degradation (ARD) that occurs during the term of the current operating license will not be different in character or magnitude after the term of the current operating license..Specifically, there is no expectation that the operating environment will be signifi-
.cantly different during the renewal period.
If the rate of battery degradation were to increase significantly in the renewal period, the l
3
T effects of such degradation will be identified by existing testing programs and appropriate replacement will be implemented.
Therefore, it is determined that batteries do not have ARDUTLR per 10 CFR 54.21(a)(3).
Justification Operational experience has shown that aging degradation commonly results in swelling of plates which can result in reduced capacity and damage to the case; embrittlement of the lead components which can lead to broken plates and conductors; and loss of electrolyte which can cause loss of capacity or total battery failure. The effects of such aging can be easily detected by the plant maintenance procedures established in accordance with NUMARC 93-01, Revision 3, " Industry Guideline for 1
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."
Presently, the safety-related station batteries are replaced when the capacity is less that 80 percent of the manufacturer's rated capacity.
This, and the requirements to perform discussed inspections, is explic-itly addressed in the technical specifications.
For the above reasons, it is determined that station batteries are not
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subject to ARDUTLR.
l 4.
REFUELING WATER STORAGE TANK Functional
Description:
The refueling water storage tank (RWST) provides a reservoir of borated water for refueling operations and emergency core cooling system (ECCS) safety injection.
IPA De, termination i
54.21(a)(1):
Scope Review l
^
The RWST is safety-related which makes it important to license renewal.
54.21(a)(2):
Functional Review The tank's required function is to maintain a reservoir of borated water i
during and after design basis events, such that it will be available for refueling and ECCS operations. 'There are technical specification requirements to ensure that adequate water level in the tank is being maintained throughout the renewal term.
54.21(a)(3): Uniqueness Review i
Tank wall and foundation degradation could occur into the renewal term -
l since replacement of the tank is not planned during the current term.
A one-time inspection-as described below has been conducted to support an analysis that tank wall thickness and foundation bolting will continue to meet the current licensing basis (CLB) requirements throughout the-h' 4'
9 t
m
.=
t renewal term.
Inspection results demonstrate little or no degradation.
Also, projections through the end of the renewal term demonstrate that the CLB will be maintained.
Evaluation of the results of these activi-ties demonstrates that the CLB function of the RWST will be maintained, absent programmatic action, through the renewal term.
Additionally, there is no expectation that the operating environment will significantly j
change during the renewal period. Tank water level and boron concentra-tion will be maintained and will continue to be monitored regularly per the technical specifications. Therefore it is determined that there is no ARDUTLR (54.21(a)(3).
i One Time Inspection a.
Tank wall thickness was measured on a one-time inspection basis to f
ensure that its structural integrity had not degraded.
Measurements have been taken at the top and also at the bottom of the tank, l
including welds.
1 b.
Foundation bolting was inspected using ultrasonic testing to verify
[
the structural integrity of bolting.
(10 percent minimum of all bolts).
I c.
Foundation bolting was torqued to specified design values to verify bolt and concrete were still properly bonded.
(All foundation bolts).
5.
INTERNAL FLOOD MITIGATION COMPONENTS l
Functional
Description:
As part of the current licensing basis, the plant has been designed to protect against the effects of internal flooding from various sources like postulated non-safety-related piping failures and high energy line breaks.
ipa Determinations 54.21(a)(1):
Scope Review l
Mitigative components designed to protect the plant from the consequences of internal flooding are important to license renewal since-their failure could directly prevent accomplishment of a required function.
For r
example, water level indicators and floor drains are needed to protect vital equipment from the consequences of an internal flood and are
'important to license renewal.
54.21(a)(2):
Functional Review Mitigative components designed to protect the plant from the consequences j
of internal flooding have. safety functions because their failure during a flood could result 'in damage to plant safety equipment.
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54.21(a)(3): Uniqueness Review The mitigative components for protection against internal flooding could be subject to ARD that would be different in magnitude for the renewal term since they will be in service into the renewal term and a continuing program is necessary to assure their performance.
Therefore, by defini-tion, the ARD is unique to license renewal (e.g., testing of water level indication instrumentation and inspection of floor drains).
54.21(a)(5)(ii):
Effective Program Not Required These components have been determined to not be of fundamental safety importance because they do not directly mitigate design basis accidents and transients or affect the integrity of the reactor coolant pressure boundary.
However, there are current programs which address the effects of all ARD for the term of the current license which will ensure CLB compliance. Actions have been taken to adequately address the effects of these ARDs for the renewal term as described below.
Therefore, ARD of mitigative components to protect the plant from the consequences of internal flooding effects is not required to be addressed by any new or effective program per 10 CFR 54.2)(a)(5)(ii).
l The following programs are in place and actions have been taken to address the effects of all ARD on the mitigative components necessary for protection against internal flooding effects in the renewal term.
1.
Instrumentation, such as room water level switches and floor drains will continue to be maintained and tested in accordance with the applicable plant procedures implemented in accordance with the plant maintenance program.
There is no expectation that the character of
~
degradation (e.g., operating environment / rate of degradation) will be different in the renewal period.
2.
Other mitigative measures which are not components, such as guard i
piping, room curbing, and structural water sealants will be addressed separately.
6.
CLASS I PIPING Functional
Description:
Along with the other components of the reactor coolant system (RCS), the Class 1 piping is the second barrier of three preventing the release of fission products to the environment. Simil arly, it is part of the pressure boundary of the reactor coolant system.
IPA Determination 54.21(a)(1):
Scope Review The RCS piping is safety-related which makes it important to license renewal.
6
t i
54.21(a)(2):
Functional Review i
See above functional description for its required function.
i 54.21(a)(3):
Uniqueness Review l
The RCS piping could be subject to ARDUTLR because the piping may be i
subject to degradation which, if unmanaged, may be of a different magnitude than that expected during the current term of operation.
A i
continuing programmatic action (e.g.,Section XI inservice inspections) will be required to ensure Class I piping function in the renewal term.
t 54.21(a)(5):
Effective Program Requirement Class I piping is of fundamental safety importance because it is essen-t tial to maintain the reactor coolant pressure boundary and cooling of the i
reactor following design basis accidents and transients.
54.21(a)(6):
Effective Program Class 1 piping will be addressed by an effective program in accordance with 10 CFR 54.21(a)(6). The following programs are in place and actions have been taken to address the effects of ARD on Class 1 piping that are common to both current and renewal terms.
i 1.
Volumetric and surface examinations will continue to be performed as a part of ASME Section XI inservice inspection program. This has been augmented by guidance for the qualification of nondestructive examination personnel and for the establishment of ultrasonic exami-nation procedures as contained in Appendices VII and VIII, respec-tively of the 1989 Edition of the ASME Code Section XI. Adoption of these two appendices was requested by the staff and agreed upon during the review of industry reports such as PWR Reactor Vessel and BWR Reactor Vessel Internals.
2.
An ASME Section III fatigue analysis was performed for 40 years as part of the original design. An evaluation has been performed to verify that the time-dependent aspects of fatigue analyses do not exceed the CLB limit for cumulative usage factor (CUF) being greater than 1.0 for the renewal term as defined in ASME Code Section III for Class I components.
If the limit was exceeded, components were replaced.
i 3.
An evaluation has been performed to ensure that the time-dependent CLB high energy pipe break criteria limit of CUF = 0.1 has not been exceeded in the renewal term. When exceeded, an evaluation of the i
new postulated break effects was made in accordance with the CLB.
l 4.
For all postulated break locations, an evaluation has been performed to determine the critical flaw size, beyond which structural integ-rity is not assured, for the specific component and loading condi-.
7 i
s
.~
tions. This evaluation established the maximum permissible flaw size i
for inspection purposes. The evaluation considered the specific characteristics of the aging mechanism and the time interval between-inspections. An appropriate margin was applied to the critical flaw i
size to account for uncertainties in the analyses and flaw detection.
5.
To ensure continued structural integrity of cast stainless steel components, the time-dependent aspects of thermal embrittlement have been evaluated for the renewal term.
t 6.
On a one-time inspection basis, small bore Class 1 piping of nominal pipe size 1 inch and smaller, which is excluded from the scope of ASME Section XI, was inspected for signs of aging.
Visual inspection was used, with any degradation documented, evaluated, and, when needed, repaired or replaced.
I 7.
INTAKE STRUCTURE j
Functional
Description:
The intake structure provides a source of water for the circulating water system and the safety-related service water system. The majority of this reinforced concrete structure is below grade.
The intake i
structure houses the safety-related service water pumps and the non-safety-related circulating water pumps.
It is composed of two distinct parts:
the screen well and the pump well.
It is a seismic Category I structure capable of resisting various design loads including the design basis earthquake and missiles.
IPA Determination 54.21(a)(1) - Scope Review The intake structure is important to license renewal because it is i
safety-related seismic Category I.
54.21(a)(2):
Functional Review i
The intake structure contributes to the performance of a required function to shut down the reactor and maintain it in a safe shutdown condition. The intake structure provides a source of water for the l
safety-related service water system and the circulating water system.
The failure of the intake structure prevents a system important to l
license renewal from performing its required function.
54.21(a)(3):
Uniqueness Review The portion of the intake structure exposed to' an environment of running water is susceptible to degradation associated with corrosion of embedded steel, abrasion and cavitation, and' corrosion of reinforcing and struc.
tural steel which will be of a different magnitude than that experienced during the current term of operation..The intake structure is currently
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not routinely subject to inspection.
Monitoring of this structure through the renewal term will be necessary to ensure proper condition and performance, thus, the ARD is unique to license renewal.
54.21(a)(5):
Effective Program Requirement
(
The intake structure is of fundamental safety importance because its i
function is required to provide cooling for safety-related equipment following design basis transients and accidents.
It is not presently subject to inspection and ARDUTLR for the intake structure is not i
addressed through any program.
Therefore, an effective program will be developed to ensure that the CLB is maintained during the period of extended operation as required by 10 CFR 54.21(a)(6).
i 54.21(a)(6):
Effective Program Management of ARD of the intake structure during the renewal term is t
accomplished by implementing the requirements of 10 CFR 50.65 (Mainte-nance Rule) and through periodic inspection provisions in accordance with r
NRC Regulatory Guide 1.127, " Inspection of Water-Control Structures Associated with Nuclear Power Plants," as discussed below:
l A.
Proaram Element j
As outlined in Regulatory Guide 1.127, the inspection of water-control structures is performed at a periodic interval not to exceed 5 years and includes the activities of (1) engineering data compilation and (2) on-site inspection program.
For the intake structure, to specifi-i cally address the provisions of 10 CFR 54.21(a)(6)(i), the following on-l site inspection program as recommended is Regulatory Guide 1.127 and in l
Section 5.2.1 of NUMARC Report 90-06, " Class I Structures License Renewal Industry Report," will be implemented to assure timely identification or v
any significant degradation of structural condition:
i On-Site inspection Proaram The on-site inspection program includes inspection and evaluation of:
l t
Concrete Surfaces:
The condition of the concrete surfaces is exam-ined to evaluate the deterioration and continuing service-ability of the concrete'in accordance with the provisions of ACI 201.lR-68, i
" Guide for Making a Condition Survey of_ Concrete in Service".
Structural Cracking:
Concrete structures are examined for structural' I
cracking resulting from overstress due to applied loads, shrinkage, temperature effects, or differential movements.
Water Passage: All water passages and other concrete surfaces
-subject to running water are examined for erosion, cavitation, 3
obstructions, leakage,. or significant structural cracks.
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B.
Acceptance Criteria / Corrective Action The on-site inspection of structural cracking and water passage-induced degradation will continue to be performed in accordance with the plant Nondestructive Examination Procedure Manual NDE-1234, Revision 3, " Safety-Related Intake Structure Inspection." The manual defines the scope of inspection, personnel qualification, examination methods, documentation requirements, etc. As described in the manual, acceptance criteria are noted in terms of crack sizes and the cavitation patterns. Any crack that is considered significant will be evaluated in accordance with the procedure contained in NDE-1234.
In accordance with Regulatory Guide X.XXX, which endorses NUMARC 93-01, " Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," the requirements of 10 CFR 50.65 have been implemented by applicable plant operating procedure.
This, in addition to the requirements of Appendix B to 10 CFR Part 50, provides the process for initiating preventive and correc-tive actions and developing administrative control to satisfy the provisions of 10 CFR 54.21(a)(6)(ii) and (iii).
8.
CABLE TO RHR PUMP Functional Descriotion:
The cable provides rated voltage and rated current to the residual heat removal (RHR) pump and is required to remain functional during normal plant operation and during design basis events (DBEs), to ensure safe operation or achieving and maintaining safe shutdown, and the prevention or mitigation of accidents. The cable is required to be environmentally qualified in accordance with 10 CFR 50.49 since it may be exposed to a harsh
-environment outside containment resulting from radiation or a high energy line break.
ipa Determination 54.21(a)(1):
Scope Review The cable to the RHR pump is safety-related which makes it important to license renewal.
54.21(a)(2):
Functional Review The cable is required to be environmentally qualified per 10 CFR 50.49 and must be capable of performing its required function during DBEs.
54.21(a)(3): Uniqueness Review The cable could have ARDUTLR since NUREG-0588 Category I equipment was qualified for only 40 years per 10 CFR 50.49.
(NOTE: A licensee could perform an evaluation which considers the existing bases for qualifica-tion of the cable for the initial license term. The evaluation would need to demonstrate that the cable's qualification will be maintained 10
1 l
through the renewal period. This would result in a conclusion that the cable is not subject to ARDUTLR. The following discussion assumes that such an evaluation is not performed.)
l 54.21(a)(5):
Effective Program Requirement
.l Cables are of fundamental safety importance because their function is required to ensure the function of the safety-related RHR system which has been shown by operating experience to be important during shutdown j
operations. They are not presently evaluated for ARD and, therefore, an effective program is required per 10 CFR 54.?l(a)(6).
l 54.21(a)(6):
Effective Program The following effective program will address ARDUTLR for the cable to the RHR pump:
A.
Procram Elements There are currently no standardized methods for continuous monitoring t
of cables.
However, for license renewal, a one-time inspection has been performed on the condition of the cable to the RHR pump.
Maintenance records and performance data were also reviewed.
l The performance of the cable is monitored each time the RHR pump is t
tested.
Cable deterioration can be manifested as insulation and
+
jacket embrittlement, which occurs primarily from thermal and radia-l tion aging.
The major concern that failure of the deteriorated cable l
might be induced during DBE conditions will be mitigated through 7
implementation of the cable monitoring program as described below.
t B.
Acceptance Criteria / Corrective Action The following steps will be performed when maintenance is per-formed on the RHR pump in accordance with plant maintenance procedures established per NUMARC 93-01, Revision-3, " Industry l
Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear 1
Power Plants." This is consistent with the recommendations provided in-NUREG/CR-5643, " Insights Gained From Aging Research," which is l
based on the findings in NUREG/CR-5461, " Aging of Cables, Connec-l tions, and Electrical Prevention Assemblies in Nuclear Power Plants,"
and NUREG/CR-5655, " Submergence and High Temperature Steam Testing of Class IE Electrical Cables."
1.
The cable near the RHR pump will be inspected for physical damage due to installation, operation, or maintenance.
j 2.
The cable near the RHR pump will be checked for embrittlement i
when it is manipulated.
3.
Selected accessible connections will be checked for integrity and i
verified to be. free of corrosion.
t 11 I
I i
i t
4.
If cable embrittlement is identified, cable samples uill be removed to perform material break elongation measurements.
l Acceptance criteria is above 50 percent absolute elongation.
t i
If cable degradation or damage are identified through inspection and testing, the effects will be evaluated and, if necessary, will result in RHR pump cable replacement.
9.
MOTOR OPERATID VALVES Functional
Description:
Motor-operated valves (MOVs), which control the flow in fluid systems, are generally designed for intermittent use in nuclear power plants. MOVs have safety and non-safety functions. However, this example commodity group only addresses safety-related MOVs.
Systems which utilizc MOVs include high pressure core injection, residual heat removal, service water, standby gas treatment, reactor core isolation cooling for BWRs, auxiliary feedwater for PWRs, and main feedwater.
The application would contain a tubular listing which identifies safety-related MOVs which may be segregated by functional types and would be addressed separately in the IPA.
ipa Determination 54.21(a)(1):
Scope Review
[
The MOVs are important to license renewal because they are safety-related. MOVs are relied upon to remain functional to ensure that the system of which they are a component remains functional.
MOVs permit the flow of water in systems that are relied upon to shut down the reactor and maintain it in a safe shutdown condition.
For example, MOVs in the RHR systems are required to remain functional to meet the ECCS require-ments.
Auxiliary feedwater MOVs are required to provide feedwater to the steam generator to remove decay heat.
i 54.21(a)(2):
Functional Review MOVs are components of systems that contribute to the performance of a required function to shut down the reactor and maintain it in a safe shutdown condition.
If MOVs fail, the failure prevents a system from performing its required function.
Safety-related MOVs are important to license renewal.
t 54.21(a)(3):
Uniqueness Review In general safety-related MOVs will remain inservice through the renewal term.. The insights gained from the Nuclear Plant Aging Research Program as documented in NUREG/CR-5643 and plant operating experience have identified aging that occurs in the first 40 years.- The aging identified-i is wear, erosion, and corrosion.
The effects of age-related degradation could be different in character or magnitude after the term of current license and a continuing program will be necessary. This ARD is unique to renewal.
12
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54.21(a)(5):
Effective Program Requirement Safety-related MOVs are of fundamental safety importance since their function could be critical to safety-related fluid systems in the plant which are necessary following design basis accidents or transients.
54.21(a)(6):
Effective Program The ARDUTLR is addressed through an effective program. MOVs are within the scope of the plant inservice testing program in accordance with the requirements of ASME Section XI. This program will continue to be implemented during the renewal term.
In addition, Generic Letter 89-10
" Safety-Related Motor-0perated Valve Testing and Surveillance", and its supplements have been implemented at the plant and the required periodic testing programs will continue in the renewal term. Therefore, it is determined that the effects of degradation are adequately addressed in an effective program per 10 CFR 54.21(a)(5)(i).
The following programs are in place and will continue to adequately address the effects of ARD for MOVs by ensuring proper performance in the renewal term.
1.
In accordance with the technical specifications for all necessary systems, closure times, leakage, and valve positions will be veri-fied.
2.
Section XI testing and inspection requirements will continue to be implemented during the license renewal term.
3.
GL 89-10 and its supplements have been implemented and the required periodic testing programs will be continued in the license renewal term.
As required by ASME Section XI (OM-8) and GL 89-10, a diagnostic testing program (e.g., MOVATS or V0TES) will continue to be used in the license renewal term. This existing program for safety-related MOVs addresses the thrust required to open and close the valve and the thrust delivered to the motor actuator. This testing program monitors the following parameters: valve stem position, torque, and thrust; spring pack displacement; time of actuation of all control switches; motor current, voltage, and power; actuator vibration; and actuator output torque. Monitoring of the parameters ensures that the valve will function when required.
4.
Valve bodies will be inspected in accordance with ASME Section XI.
l Corrective actions will be taken if any of the following conditions exist:
a.
Corrosion or erosion that reduces the pressure retaining wall thickness by more that 10 percent 13 4
--..------- --- ------------N
L b.
Wear of mating services that may lead to loss of function or I
leakage c.
Crack-like surface flaws that developed in-service or that grew in size beyond that recorded during preservice visual inspection E
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