ML20133E916
| ML20133E916 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1996 |
| From: | Kuo P, Newberry S, Prato R Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-1568, NUDOCS 9701130209 | |
| Download: ML20133E916 (25) | |
Text
.
NUREG-1568 License Renewal Demonstration Program:
XRC Observations and Lessons Learned U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regu5ation R. J. Prato, P. T. Kuo, S. F. Newberry d* **%
p
'I Pp../
pW 3
I 11 961231 1568 R PDR
AVAILABILITY NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:
1.
The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC 20555-0001 2.
The Superintendent of Documents, U.S. Govemment Printing Office, P. O. Box 37082, Washington, DC 20402-9328 3.
The National Technical Information Service, Springfield, VA 22161-0002 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda; NRC bulletins, circulars, information notices, inspection and investigation notices; licensee event reports; vendor reports and correspondence; Commission papers; and applicant and licensee docu-ments and correspondence.
The following documents in the NUREG series are available for purchase from the Government Printing Office: formal NRC staff and contractor reports, NRC-sponsored conference pro-ceedings, international agreement reports, grantee reports, and NRC booklets and bro-chures. Also available are regulatory guides, NRC regulations in the Code of Federal Regula-tions, and Nuclear Regulatory Commission Issuances.
Documents available from the National Technical Information Service include NUREG-series reports and technical reports prepared by other Federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.
Documents available from public and special technical libraries include all open literature items, such as books, journal articles, and transactions. Federal Register notices Federal and State legislation, and congressional reports can usually be obtained from these libraries.
Documents such as theses, dissertations, foreign reports and translations, and non-NRC con-forence proceedings are available for purchase from the organization sponsoring the publica-tion cited.
Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Administration, Distribution and Mail Services Section', U.S. Nuclear Regulatory Commission, Washington DC 20555-0001.
Copies of industry codes and standards used in a substantive manner in the NRC' regulatory process are maintained at the NRC Library, Two White Flint North.11545 Rockville Pike, Rock-ville, MD 20852-2738, for use by the public. Codes and standards are usually copyrighted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York, NY 10018-3308.
NUREG-1568 License Renewal Deinonstration Program:
NRC Observations and Lessons Learned Manuscript Completed: September 1996 Date Published: December 1996 4
R. J. Prato, P. T !'uo, S. E Newbeny Disision of Reactor Program Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
/
r
ABSTRACT This report summarizes the Nuclear existing guidance and/or the inclu-Regulatory Commission staff's obser-sion of some new guidance may be vations and lessons learned from the needed for applicants to develop a five License Renewal Demonstration license renewal program that is Program (LRDP) site visits performed consistent with the intent of the by the staff from March 25, 1996, rule.
through August 16, 1996. The LRDP was a Nuclear Energy Institute (NEI)
The observations and lessons learned program intended to assess the discussed in this report, as well as effectiveness of the guidance pro-comments received from the industry vided by NEI 95-10, Revision 0, and members of the public, will be
" Industry Guideline for Implementing used to identify additional guidance 3
the Requirements of 10 CFR Part 54 -
or changes to existing guidance The License Renewal Rule," to imple-needed to implement the requirements ment the requirements of Title 10 of of license renewal as intended by the Code of Federa? Regulations, 10 CFR Part 54.
Draft Regulatory Part 54 (10 CFR Part 54), " Require-Guide (DG) DG-1047, " Standard Format ments for Renewal of operating and Content for Applications to Licenses for Nuclear Power Plants."
Renew Nuclear Power Plant Operating Licenses," contains the guidance In general, NEl 95-10 appeared to recommended by the staff for imple-contain the basic guidance needed menting the requirements under the for scoping, screening, identifying rule.
This draft regulatory guide, aging effects, developing aging when finalized, is expected to end-management programs, and performing orse NEI 95-10.
In addition, time-limited aging analyses. How-changes as approved by the staff i
ever, inconsistent implementation of from comments provided by the public this guidance in some areas was an and industry will be added prior to indication that clarification of final publication of the regulatory
- guide, 111 NUREG-1568
TABLE OF CONTENTS A8STRACT iii EXECUTIVE
SUMMARY
............................ vii ABBREVIATIONS ix 1.
INTRODUCTION I
1.1 Objective...........................
1 1.2 Description of the LRDP....................
I 1.3 Description of the Rule for the Renewal of Operating Licenses.
2 1.4 Implementation
........................ 3
- 2. LESSONS LEARNED FROM THE LRDP SITE VISITS 3
2.1 General Issues
......................... 3 2.1.1 Topical Reports..................... 3 2.1.2 GSIs and USIs...................... 3 2.2 Scoping Process
....................... 4 2.2.1 Identifying Systems, Structures, and Components..... 4 2.2.2 Identifying System-/ Structural-Level Intended Function 5
2.3 Screening Process........................
6 2.3.1 Evaluation Boundaries.................. 6 2.3.2 Identifying Structural-/ Component-Level Intended Function....................
6 2.3.3 Identifying Component Passive Functions.........
7 2.3.4 Identifying Long-Lived Characteristics.........
7 2.3.5 Identifying and Listing of Structures and Components 8
2.4 Aging Management Review..................... 8 2.4.1 Identifying Aging Effects................ 9 2.4.2 Use of Operating Experience............... 9 2.4.3 Aging Management Programs...............
10 2.5 Demonstration.........................
11 2.6 TLAA.............................
12
- 2. 7 FSAR Suppl ement........................
12
- 3. CONCLUSIONS.............................
13 REFERENCES 14 v
l EXECUTIVE
SUMMARY
Nuclear Energy Institute (NEI) pub-fulfilling the requirements of the lished NEI 95-10, " Industry Guide-rule.
line for Implementing the Require-ments of 10 CFR Part 54 - The Lic-In general, the participants appear-ense Renewal Rule," Revision 0, in ed to have performed the scoping and March of 1996. NEI 95-10 is an screening functions consistent with industry guideline for implementing the guidance provided by NEI 95-10 regulatory requirements associated and the intent of the rule. How-with the renewal of nuclear power ever, potential improvements in the plant licenses under Title 10 of the existing guidance under NEI 95-10, Code of Federa7 Regulations, Part 54 9 4.1.2 and 6 4.2.1.1, that is used (10 CFR Part 54), " Requirements for to identify intended functions and Renewal of Operating Licenses for to assess structures and components Nuclear Power Plants." Currently, passive functions have been ident-the Nuclear Regulatory Commission ified.
In addition, concerns asso-(NRC) staff is involved in reviewing ciated with the listing of struc-this NEI effort with the intention tures and components were observed of exercising its option to endorse during the LRDP, and indicated the the industry guideline.
need for additional guidance under NEI 95-10, Section 4.
The License Renewal Demonstration Program (LRDP) was an NEI effort Although a number of good aging man-intended to assess the effectiveness agement processes were presented of the guidance provided by during the site visits, concerns NEl 95-10, Revision 0, to implement were identified with some of the the requirements of 10 CFR Part 54.
aging management programs presented The LRDP consisted of an NRC staff by the participants during the site review of five license renewal (LR) visits.
In general, NEI 95-10, programs, including a sample LR 5 4.2.1, 6 4.2.1.2, and 9 4.2.1.3, methodology, LR application, and appeared to contain the basic guid-supporting information developed by ance for developing aging management volunteer licensees (hereinafter programs but the participants' fail-referred to as participants) from ure to implement this guidance con-the guidance provided in NEI 95-10, sistent with the ir. tent of the Revision 0.
guideline was an indication that additional de.ccription and/or clar-The site visits were intended to be ification may be needed.
The most a review of the processes developed noted concern, common to all site from implementing NEI 95-10 and a visits, was the participants' fail-review of sample supporting mater-ure to provide a " demonstration" of ials to ensure that adequate guid-the effectiveness of the aging man-ance existed for potential appli-agement programs to manage the eff-cants to develop the proper inform-ects of aging under current licen-ation in sufficient detail to allow sing-basis design conditions during the staff to make its findings. The the period of extended operation.
LRDP site visits did not include the review of any plant-specific program The content of the time-limited for the purpose of determining its aging analyses (TLAAs) presented adequacy or acceptability in during the LRDP was generally vii NUREG-1568 i
/
1 consistent with the guidance under visit to site visit, but most of the NEI 95-10, 5 5.1, and the intent of samples presented did not meet the the rule.
However, some of the intent of the rule. Additional participants indicated their intent guidance for developing an LR FSAR to postpone of a number of TLAA supplement is needed to ensure con-evaluations until some time after sistent development of FSAR supple-submitting their LR application.
ments that provide an adequate The staff emphasized its expectation summary description of the aging that TLAA evaluations would be comp-management program.
leted at the time of application.
Additional guidance may be needed to As a result of the LRDP, the staff clarify this requirement, will make recommendations to revise NEI 95-10 to include some additional The site-visit teams observed that description, clarification, and/or the sample Final Safety Analysis new guidance to address the concerns Report (FSAR) supplements presented identified during the LRDP.
during the LRDP improved from site NUREG-1568 viii
I I
ABBREVIATIONS AMP aging-management program 1
AMR aging-management review
)
CLB current licensing basis j
FSAR Final Safety Analysis Report J
GSI generic safety issue LR license renewal LRDP License Renewal Demonstration Program NEI Nuclear Energy Institute NRC U.S. Nuclear Regulatory Commission TLAA time-limited aging analysis i
{
USI unresolved safety issue J
I e
)
I k,
.i 1
J i
4 a
i i
t iX NUREG-1568 1
4 P
l.
INTRODUCTION 1.1 Objective This report summarizes the observa-The observations and lessons learned tions and lessons learned from the discussed in this report will be site visits performed by the Nuclear used to identify additional guidance Regulatory Commission (NRC) during and/or clarifications that need to the Nuclear Energy Institute (NEI) be added to NEI 95-10, Revision 0, license Renewal Demonstration Pro-for an acceptible implementation of gram (LRDP). The purpose of the the LR requirements under LRDP was to assess the effectiveness 10 CFR Part 54.
The resulting guid-of the guidance provided by ance from these observations and NEl 95-10. " Industry Guideline for lessons learned will be incorporated Implementing the Requirements of in NEI 95-10 or in the staff's final 10 CFR Part 54 - The License Renewal version of the draft Regulatory Rule," Revision 0, to implement the Guide (RG) DG-1047, " Standard format requirements of Title 10 of the Code and Content for Applications to of federal Regulations, Part 54 Renew Nuclear Power Plant Operating (10 CFR Part 54), " Requirements for Licenses."
Renewal of Operating Licenses for Nuclear Power Plants." NRC staff 1.2 Description of the LRDP participated in this effort by per-forming the site visits to assess The LRDP consisted of staff reviews the implementation of NEI 95-10 by of five LR programs developed by the volunteer licensees (hereinafter LRDP participants from the guidance referred to as participants) to provided in NEI 95-10, Revision 0.
determine if the participants under-In general, the LRDP participants stand the intent of the guidance and had not made a final decision to correctly implement that guidance pursue a renewed license but parti-consistent with the intent of the cipated in the LRDP to gain a better rule, and to assess the need for any understanding of the LR process to changes to the guideline.
help them in their decision.
Each review involved a week-long site During preparation of NEI 95-10, visit, by five to six NRC staff mem-Revision 0, the staff and industry bers, to assess a participant's realized that development of final implementation of the guidance pro-guidance for certain topics was best vided by NEI 95-10 in a demonstra-deferred until additional implement-tion LR program.
The NRC staff's ation experience was gained in the objectives for the LRDP site visits LRDP._ These topics included guid-were as follows: (1) assess the ance for level of detail of the extent to which the participants information needed for a license understand and correctly implement renewal (LR) application and FSAR the guidance consistent with the supplement, application of topical intent of the rule; (2) assess the reports, and overall level of detail scoping, aging management review of the guidance to develop an LR (AMR), and time-limited aging anal-program consistent with the intent ysis (TLAA) evaluation processes and of the rule.
These concerns were supporting information developed by addressed by the LRDP and potential the participants (based on the guid-areas for improvement identified.
ance contained in NEI 95-10) for documentation, control, consistency, and completeness with respect to the type of information required by the 1
I l
l rule; (3) assess that the LR appli-licensing period of 40 years are l
cations, TLAA evaluations and Final required to satisfy the requirements Safety Analysis Report (FSAR) sup-delineated under 10 CFR Part 54, the plements are of sufficient detail LR rule. This rule establishes the for the staff to make findings as criteria for the systems, struc-required under 10 CFR 54.29; tures, and components within the (4) assess the use and integration scope of LR that include: (1) safety of topical reports; and (5) assess related systems, structures, and the naterial provided by the parti-components, (2) non-safety related
{
cipants to identify any potential systems, structures, and components need for modifications to NEI 95-10, whose failure could affect safety-related systems, structures, and The scope of each participant's components, and (3) those systems, demonstration program included a structures and components that are sample LR methodology, an LR applic-relied upon to perform a function ation and supporting information for that satisfies the Commission reg-f approximately eight systems, two ulations for fire protection I'
components per system, a minimum of (10 CFR 50.48), environmental qual-two TLAA evaluations, and a sample ification (10 CFR 50.49), pressur-LR FSAR supplement.
The scope of ized thermal shock (10 CFR 50.61),
systems, structures, components, and anticipated transients without scram TLAAs for the LRDP was designed to (10 CFR 50.62), and station blackout provide a cross-section of the types (10 CFR 50.63).
of information expected to be seen in a LR application.
The LR rule requires applicants to perform a structured AMR of struc-The LRDP site visit teams reviewed tures and components that perform an the processes and sample materials intended function without moving developed from the guidance provided parts or change in configuration or by NEI 95-10 to ensure that adequate property (passive) and are not sub-guidance existed to develop an ject to replacement based on a qual-application and supporting informa-ified life or specified time period tion in sufficient detail. The site (long lived). The AMR may result in visit teams did not review plant-the development of new aging manage-I specific programs for the purpose of ment programs for passive /long-lived determining their adequacy or structures and components to ensure acceptability in fulfilling the their functionality during the requirements of the rule.
period of extended operation.
The results of the site visits were The rule also requires an applicant documented in site-visit trip to evaluate TLAAs for systems, reports (References 1-5).
The trip structures and components within the reports have been placed in the NRC scope of the rule that involve time-Public Document Room.
limiting assumptions defined by the current operating term. The applic-1.3 Description of the Rule for ant must demonstrate that (1) the the Renewal of Operating analyses remain valid for the period Licenses of extended operation, (2) the anal-yses have been projected to the end Nuclear power plant licensees that of the period of extended operation, choose to extend the operation of or (3) the effects of aging on the their plants beyond the initial intended functions will be NUREG-1568 2
adequately managed for the period of 2.1.1.2 Lessons Learned extended operation.
The aging man-agement programs and licensee eval-NEI 95-10, f 4.2.2, states that if uations of TLAAs will become part of an applicant chooses to rely "on the plant's licensing basis, and referenceable results of a previous will be subject to the NRC's ongoing aging management review...the ele-regulatory requirements.
ments of the AMR should include identifying and demonstrating the 1.4 Implementation applicability of a previous review and then demonstrating that the After publication of the amended LR results and conclusions are in rule in May 1995, the NRC staff and effect at the plant." In referenc-industry began preparing implementa-ing a generic topical report, an tion guidance.
In March 1996, applicant should verify the applic-NEI 95-10, Revision 0, was pub-ability of the information within lished.
From March through August the report to the specific site of 1996, the staff performed the being considered for a renewed lic-five site-visit reviews for the ense at the time of application, LRDP.
In August 1996, NRC published considering appropriate applicabil-DG-1047. This draft guide proposes ity statements made within the to endorse the guidance contained in report and the staff safety evalua-NEI 95-10.
The staff will use the tion report.
Information comparing experience gained through its obser-the topical report and site-specific vation of the plant-specific demon-characteristics such as design, mat-strations and any information or erials of construction, configura-comments received from members of tion, and environment stressors, the public to determine whether consistent with NEI 95-10, S 4.2.2, changes might be needed in NEI 95-10 should be discussed in the LR appli-or DG-1047.
cation.
In addition, due to the potential for an extenN period of
- 2. LESSONS LEARNED FROM THE LRDP time between the development of a SITE VISITS topical report and the submittal of an LR application, the site-visit 2.1 General Issues team concluded that the applicants should have made a statement about 2.1.1 Topical Reports any changes, or the absence of any changes, in plant conditions as they The use of topical reports, that relate to the information presented have been approved by NRC, is an in the report. Any " outlying" acceptable practice for addressing conditions must be evaluated on a process and technical matters con-plant-specific basis.
The staff sistent with 10 CFR 54.17(e).
The will make recommendations to add use of approved topical reports is additional description and/or addressed in NEI 95-10, 6 4.2.2.
clarification to address the applic-ability of topical reports.
2.1.1.1 Observations 2.1.2 GSIs and USIs The staff observed that some of the participants did not adequately Generic safety issues (GSIs) and demonstrate the site-specific unresolved safety issues (USIs) are applicability of topical reports to be considered for determining the used during the LRDP.
scope of the AMR and TLAAs as dis-3 NUREG-1568
cussed in the background information tural-level intended functions. The (60 FR 22484) issued with the rule.
participants then identified (refer I
NEI 95-10, f 1.5, provides general to 5 2.3 of this report) the struc-guidance for considering these tures and components requiring AMRs issues, without regard for the and/or evaluation of TLAAs, and priority assigned to the issues their structural-/ component-level under the NRC GSI program (Ref. 6).
intended functions.
This approach is consistent with NEI 95-10 and the 2.1.2.1 Observations intent of the rule.
During a review of a participant's 2.2.1 Identifying Systems, handling of GSIs/USIs, the site-Structures, and Components visit team noted that those GSIs designated as " low priority" in the The LR scoping process presented NRC GSI program (Ref. 6) were not during the LRDP includes the ident-being considered in identifying ification of the systems and struc-potential aging effects relating to tures that meet the criteria under LR. The participants along with NEI 10 CFR 54.4(a).
The guidance for initiated actions to address this identifying the systems and struc-concern.
tures within the scope of LR is In addition, the staff observed that participants were not discussing 2.2.1.1 Observations applicable generic safety issues in their AMR and TLAA documentation.
The site-visit teams observed that for example, GSI 168, " Environmental the participants typically provided Qualification of Electrical Equip--
a proceduralized approach for scop-ment," was not discussed by four ing. The approaches presented by participants in TLAAs relating to the participants appeared to follow equipment qualification.
the basic guidance under NEI 95-10, 6 3.1 and appeared to be consistent 2.1.2.2 Lessons Learned with the criteria under 10 CFR 54.4.
NEI 95-10, f 1.5, provides guidance For those participants that imple-for assessing GSIs/USIs.
- However, mented NEI 95-10, f 3.1, with the l
additional guidance appears to be intent to identify all plant systems necessary regarding the considera-and structures within the scope of tion of age-related GSIs.
LR, the site-visit teams performed a cursory review of their LR scoping 2.2 Scoping Process efforts, and did not identify any obvious omissions.
The site-visit The scoping process for LR includes teams also observed that the partic-the identification of the system, ipants' scoping processes included structures, and components within steps to evaluate safety-related the scope of LR and identifying systems, that did not meet the 10 their intended functions. The scop-CFR 54.4(a)(1) criteria, under 10 ing process performed by the five CFR 54.4(a)(2) and 54.4(a)(3) as participants typically involved a described under NEI 95-10, f 3.1.1.
two-step process.
Each participant In addition, the site-visit teams first identified the scope of observed that two participants systems and structures within the assessed systems and structures that scope of LR and their system-/struc-had been determined to be within the NUREG-1568 4
scope of LR under 10 CFR 54.4(a)(1)
The guidance for identifying these (safety-related criteria) for intended functions is provided under inclusion in the scope of LR under NEI 95-10, 6 3.2.
10 CFR 54.4(a)(2) and 54.(a)(3)
(nonsafety-related and specified 2.2.2.1 Observations Commission regulation criteria) as well.
Because this additional In general, the site-visit teams review of safety-related systems observed that the participants app-under 10 CFR 54.(a)(2) and 54.(a)(3) eared to have implemented the guid-was observed only during two site ance for identifying system-level visits, some additional description intended function that appeared to and/or clarification under be consistent with NEI 95-10, 6 3.2.
NEI 95-10, 9 3.1, may be needed to Although the site-visit reviews did meet the intent of 10 CFR 54.4.
not assess the completeness of the results presented, no specific con-2.2.1.2 Lessons Learned cerns were noted with the intended functions identified by the partic-Two participants included steps in ipants, and they appeared to meet their scoping process to evaluate the intent of the rule.
However, a those systems and structures, that site-visit team observed that one met the safety-related criteria participant identified the system-(10 CFR 54.4(a][1]), for inclusion level intended functions from mult-within the scope of LR under scoping iple plant documents such as design-criteria 10 CFR 54.4(a)(2) and basis documents, training handbooks, 54.4(a)(3) to ensure all system-/
scoping determination handbooks, structural-level intended functions etc.
This approach resulted in a and appropriate evaluation bound-more detailed, descriptive list of aries were identified, system-/ structural-level intended functions that appeared to better A review of the guidance under NEI meet the intent of the guideline.
95-10, 5 3.1, identified the guid-Some additional description and/or ance for assessing each system under clarification may be needed to meet each of the three scoping criteria the intent of 10 CFR 54.4(b).
in the flow-diagram, Figure 3-1.
However, the text under NEI 95-10, 2.2.2.2 Lessons Learned 9 3.1, does not contain a descrip-tion of the review performed by the One participant used more descrip-last two particioants. The staff tive onsite documentation to develop will recommend that additional a more d9 tailed, descriptive list of description and/or clarification be system-/ structural-level intended added to NEI 95-10 to ensure all functions.
From this improved list, system-/ structural-level intended the participant appeared to develop functions and appropriate evaluation a more complete and descriptive list boundaries are identified.
of the structure-/ component-level intended functions.
The staff may 2.2.2 Identifying System-/
recommend that additional descrip-Structural-Level Intended tion and/or clarification be added Function to the existing guidance to include the development of a more detailed, The need to identify system-/struc-descriptive list of system-/compo-tural-level intended functions is nent-level intended functions.
delineated under 10 CFR 54.4(b).
2.3 Screening Process 2.3.1.2 Lessons Learned The LR screening process described The industry guideline allows cppli-in NEI 95-10 includes establishing cants to use different approaches to evaluation boundaries, determining identify the structures and compon-the intended functions of the struc-ents within the scope of LR and to tures and components within the meet the intent of the rule. The evaluation boundary, and identifying site-visit team reviewed the process which of those structures and comp-and the structures and cort,'onents onents need to be included in the selected by the one participant who AMR.
In general, the screening did not use evaluation boundaries.
m a hodologies presented during the lhe site-visit team verified that LRDP were consistent with NEI 95-10 this participant's approach and list and the intent of the rule with few of selected structures and compon-exceptions as described below.
ents appeared to be consistent with the intended results from implement-2.3.1 Evaluation Boundaries ing the guidance under NEI 95-10, f 4.1, and the intent of the rule.
NEI 95-10 describes evaluation boun-No additional guidance appeared daries as "those portions of the necessary for identifying evaluation systems and structures that are nec-boundaries.
essary for ensuring the intended functions of the system or structure 2.3.2 Identifying Structural-/
will be performed."
Identifying Component-Level Intended evaluation boundaries has been rec-Functions ognized as a basic step of the screening process presented under Structural-/ component-level intended NEI 95-10, f 4.1.1, for determining functions are defined under the structures and components within 10 CFR 54.4(b).
The guidance for the scope of LR as intended by the identifying these intended functions rule.
is provided under NEI 95-10, f 4.1.2.
2.3.1.1 Observations 2.3.2.1 Observations The site-visit team observed that all but one participant identified The site-visit teams observed that evaluation boundaries using marked-the structural-/ component-level up, site-approved drawings consis-intended functions identified by the tent with the guidance under participants appeared to be consis-NEI 95-10, 6 4.1.1.
One participant tent with NEI 95-10, f 4.1.2 and the used an alternate approach to ident-intent of the rule.
Although the ify the structures and components site-visit reviews did not assess within the scope of LR that appeared the completeness of the results to be consistent with NEI 95-10, developed for the LRDP, no specific 6 4.1, and the intent of the rule.
concerns were identified with the NEI 95-10, f 4.1.1, appeared to con-intended functions presented by the tain sufficient guidance for deter-participants.
However, as discussed mining evaluation boundaries that previously, the site-visit team also supports the screening process observed that the participant that consistent with the intent of the developed a more detailed, descrip-rule.
tive list of system-/ structural-level intended functions also NUREG-1568 6
developed a more detailed, descrip-additional description and/or tive list of structural-/ component-clarification may be needed.
level intended functions than was observed during other site visits.
2.3.3.2 Lessons Learned This more descriptive list of struc-tural-/ component-level intended fun-Although NEI 95-10 appears to con-ctions appeared to better meet the tain the necessary guidance and has intent of 10 CFR 54.4(b).
Some add-a list of active / passive structures, itional description and/or clarific-components and commodity groups in ation may be needed to meet the Appendix B, concerns with the imple-intent of 10 CFR 54.4(b).
mentation of NEI 95-10, f 4.1.2, were noted during the site visits.
2.3.2.2 Lessons Learned The incorrect determination of com-The participant that developed the ponent passive functions can result more detailed, descriptive list of in an incorrect list of structures system-/ structural-level intended and components requiring an AMR and functions appeared to develop a more the subsequent failure to identify complete and descriptive list of the applicable aging affects.
For exam-structure-/ component-level intended ple, the participants considered the functions that appeared to better heat transfer function of a heat meet the intent of the rule. The exchanger to be active.
The trans-staff may recommend that additional fer of heat is performed by heat description and/or clarification be exchangers without moving parts or a added to the existing guidance to change in configuration or proper-include the development of a more ties making the component passive, complete and descriptive list of structural-/ component-level intended The failure to recognize that a heat functions.
exchanger is a passive component with respect to the heat transfer 2.3.3 Identifying Component Passive function, will eliminate the need to Functions consider scaling, obstructions and other aging effects that can effect To identify a component passive fun-the transfer of heat. The staff ction, an applicant has to determine will consider recommendations to if the component performs its inten-provide additional description ded function without moving parts or and/or clarification to NEI 95-10, change in configuration or property f 4.1.2, to address this concern.
as required under 10 CFR 54.21(a).
The guidance for determining which 2.3.4 Identifying Long-Lived components are passive is provided Characteristics under NEI 95-10, 9 4.1.2.
To determine the long-lived charact-2.3.3.1 Observations eristics of a component, an applic-ant has to determine if the compon-The site-visit team observed that ent is subject to replacement based some component passive functions on a qualified life or specified were not determined based on its use time period as required under 10 CFR of moving parts or change in config-54.21(a)(1)(ii).
The guidance for uration or properties of the struc-determining the long-lived charact-tures and components in performing eristics of a component is provided the intended functions.
Some under NEI 95-10, 9 4.1.2.
l 2.3.4.1 Observations structures and components is pro-vided in NEI 95-10, 9 4.1.2.
The site-visit teams observed that the participants identified the 2.3.5.1 Observations long-lived characteristics of struc-tures and components consistent with In general, the site-visit team t
NEI 95-10, S 4.1.2, without any observed that the participants noted concerns for those structures interpreted 10 CFR 54.21(a)(1) to and components within the scope of mean that they only needed to pro-the LRDP. However, the site-visit vide a listing of commodity groups teams did observe some inconsis-to fulfill the requirement to iden-tencies between the intent of the tify and list the structures and guidance under NEI 95-10, s 4.1.2, components requiring an AMR.
Some and the assessment of the long-lived additional description and/or clar-characteristics for components some-ification may be needed under times referred to as consumables; NEI 95-10, 6 4.2.1, to meet the e.g., seals gaskets, and packing.
intent of 10 CFR 54.21(a)(1).
Additional description and/or clar-ification of NEI 95-10, s 4.1.2, may 2.3.5.2 Lessons Learned l
l be needed for these items.
The rule, 10 CFR 54.21(a)(1), states 2.3.4.2 Lessons Learned that an applicant is to " identify and list the structures and comp-Gaskets, packing, and seals are onents requiring an aging management replaced relatively frequently but review." Although not adequately are not replaced on the basis of described under NEI 95-10, 6 4.2.1, qualified life or a specified time the participants only provided a period. However, some remain in use list of individual components (not 1
for many years and others are repla-included in any commodity groups) ced on a periodic basis or single-and/or commodity groups.
use application (e.g., single crush of a gasket).
These diverse appli-The site-visit teams concluded that cations make it difficult to imple-the participants should have pro-ment the guidance under NEI 95-10, vided a description of each commod-6 4.1.2, that appears to work well ity group that bounded and identif-in other applications presented ied the structures and components during the LRDP.
The staff is con-intended to be included in that com-sidering a recommendation that guid-modity group to fulfill the require-ance be added to NEI 95-10, 9 4.1.2, ment for " identifying" the struct-to address such items.
ures/ components requiring an AMR.
The staff may make recommendations 2.3.5 Identifying and Listing of to add additional description and/or Structures and Components clarification for " identifying" the structures and components within a Upon determining the structures and commodity group to meet the intent components requiring an AMR, an of 10 CFR 54.21(a)(1).
applicant is required to identify and list those structures and 2.4 Aging Management Review components consistent with 10 CFR 54.21(a)(1).
The guidance The AMR process for LR includes for identifying and listing of identifying aging effects, and developing and/or maintaining NUREG-1568 8
programs that manage these effects programs (AMPS) as the basis for of aging so that the structures and determining an aging effect as being components will perform their "not plausible" was the most common intended functions under current concern observed with the identif-licensing-basis (CLB) design condi-ication of aging effects during the tions during the period of extended LRDP.
For example, corrosion in a operation.
In general, NEI 95-10, closed fluid system containing 6 4.2.1.1 and 6 4.2.1.2 appear to carbon steel pipe was determined to provide the necessary guidance to be a "not plausible" aging effect.
perform an AMR consistent with This determination was based on the 10 CFR 54.21(a), but inconsistent fact that corrosion of the carbon implementation of this guidance steel had not occurred over the indicated that additional guidance previous 20 years of operation due may be needed.
to an existing chemistry control program.
Using an existing AMP, 2.4.1 Identifying Aging Effects such as chemistry control, to deter-mine an aging effect to be "not The identification of aging effects plausible" is not consistent with for the structures and components the intent of the rule. The staff within the scope of LR is required will recommend additional descrip-under 10 CFR 54.21(a).
The guidance tion and/or clarification to better for identifying aging effects is identify aging effects.
described under NEI 95-10, 9 4.2.1.
2.4.2 Use of Operating Experience 2.4.1.1 Observations The background information in general, the site-visit teams (60 FR 22467) that accompanied the observed that the aging effects rule discusses the use of operating identified by the participants to be experience applicable to LR as it
" plausible" appeared to be consis-may apply to applicants being con-tent with NEI 95-10, 6 4.2.1.1 and sidered for a renewed license, the intent of the rule.
- However, NEI 95-10, s 4.2.1.1, provides the some of the aging effects that were guidance for considering operating determined to be "not plausible" experience during the AMR process.
were not consistent with the intent of the rule.
Some additional guid-2.4.2.1 Observations ance may be needed to correctly determine the aging effects applic-In general, the participants used able to a particular structure or operating experience to help ident-component consistent with ify aging effects consistent with 10 CFR 54.21(a).
NEI 95-10, f 4.2.1.1, but some con-cerns with the source documents used 2.4.1.2 Lessons Learned to perform the operating-experience reviews were identified.
Although the intent of the site visits was not to assess the com-Each participant reviewed various pleteness of the aging effects source documents to perform an presented by the participants, the operating experience review, but in site-visit teams did observe some some cases NRC generic communica-concerns with the determination of tions were not used.
Some addi-
"not plausible" aging effects.
The tional guidance may be needed to use of existing aging management ensure a thorough operational review 9
is performed as intended by the (AMPS) that contained the basic rule.
elements of NEI 95-10, f 4.2.1.2.
However, the implementation of these 2.4.2.2 Lessons Learned programs sometimes produced results that were not consistent with the Because the LRDP site visits were intent of this guidance or the rule.
not intended to assess the complete-For example, the site-visit teams ness of the participants' results, observed that some of the AMPS pre-the site-visit teams did not assess sented by the participants relied on the completeness of the operating-the detection of a component failure experience reviews performed by the to manage some aging effects. Other participants. However, because NRC AMPS used inspection activities that generic communications are a good were not documented or controlled by l
source of aging operating-history, the site quality control program or the site-visit teams had expected site-approved procedures.
that the participants would review these communications and other In addition, the guidance for devel-sources of industry experience in oping the level of detail for AMRs determining aging effects. A number provided in an LR application of participants did not use NRC appeared to be adequately described generic communications as a source under NEI 95-10, f 4.2.1.2, but
{
for their operating experience inconsistencies in the level of I
review.
This raised a concern as to detail observed during the LRDP was the completeness of operating-exper-an indication that additional guid-ience reviews performed by the part-ance may be needed.
i icipants and the guidance provided under NEI 95-10, 9 4.2.1.1.
2.4.3.2 Lessons Learned NEI 95-10, f 4.2.1.1, does not spec-A number of AMPS relied on the ify the documents or document types detection of a component failure to that r.eed to be reviewed.
The staff manage some aging effects.
For may recommend that additional des-example, one participant offered cription and/or clarification be existing surveillance and inspection added to NEI 95-10, f 4.2.1.1, to programs as AMPS for loss of mat-ensure a thorough operational review erial associated with radiation-is performed.
monitoring tubing.
The intent was to perform periodic pressurization 2.4.3 Aging Management Programs of the tubing and subsequent inspec-tion of the exterior of the tubing An AMR is required under to detect interior wall thinning of I
10 CFR 54.21(a) to manage the the tubing.
I effects of aging for all structures and components within scope of LR This raised the concern that the consistent with the CLB during the tubing interior wall can degrade to period of extended operation. The the point where it could no longer development of AMPS is described sustain CLB design loads before under NEI 95-10, f 4.2.1.2.
through-wall flaws occur and the condition is detected.
The use of 2.4.3.1 Observations failure detection as a means of l
managing the effects of aging is not In general, the participants devel-consistent with NEI 95-10, 9 4.2.1.
oped aging-management programs NUREG-1568 10
)
Other participants used inspection that the intended function (s) will programs that were not documented or be maintained consistent with the controlled by the site quality con-CLB for the period of extended oper-trol program or site-approved proce-ation," for each structure and comp-dures, which is not consistent with onent subject to an AMR. NEl 95-10, NEI 95-10, f 4.4.
For the most f 4.2.1.3, provides guidance for part, this concern was based on the implementing this requirement and preliminary nature of the informa-examples of " demonstrations" are tion prepared for the LRDP, but in provided in Appendix C of NEI 95-10.
some cases, credit was taken for routine, informal walkdowns by plant 2.5.1 Observations personnel. Although the staff recognizes the importance of plant Early in the LRDP, the site-visit walkdowns in identifying physical teams observed that the participants damage and other related problems, interpreted the guideline to say the use of informal walkdowns as an that scoping, screening, identifica-AMP was considered insufficient, tion of aging effects and implement-ing an AMP were sufficient to In addition, inconsistencies were
" demonstrate" reasonable assurance observed during the LRDP relating to that the effects of aging will be information included in the sample managed under CLB design conditions applications.
Both the site-visit during the period of extended oper-teams and the participants believed ation.
In addition, the "demonstra-that there was a need for more des-tions" presented by the participants cription in LR applications and did not contain the information, in onsite information for new programs sufficient detail, consistent with (a program not previously reviewed guidance provided by NEI 95-10 or by the NRC) as compared to existing the intent of the rule.
Some programs.
additional guidance may be needed for developing a " demonstration."
The staff reviewed NEI 95-10, 9 4.2.1.2, and determined that 2.5.2 Lessons Learned guidance exists to address these concerns but will consider Implementing the requirements for recommendations for additional des-scoping, screening, identifying cription and/or clarification of aging effects and performing AMRs is existing guidance to address the use not consistent with NEI 95-10, of failure detection and undocumen-6 4.2.1.3, in " demonstrating" reas-ted AMPS to manage the effects of onable assurrance that the effects aging.
In addition, the staff will of aging will be managed under CLB recommend that additional guidance design conditions during the period be considered for new and existing of extended operation.
NEI 95-10, AMPS, including further guidance on 5 4.2.1.3, states that an applicant the level of detail needed in an LR needs to " collect and establish application.
supporting information and objective evidence for the aging management 2.5 Demonstration demonstration."
Consistent with 10 CFR 54.21(a)(3),
The site-visit teams commented that applicants are required to provide a a " demonstration" for an existing
" demonstration" that "the effects of program should include a summary of aging will be adequately managed sc
" objective evidence" observed from 11 NUREG-1568 l
the implementation of an AMP. The needed to ensure the timely submit-site-visit teams also commented that tal of TLAA evaluations.
a " demonstration" for a new program should include a schedule, method-2.6.2 Lessons Learned ology, acceptance criteria and cor-rective actions. A " demonstration" The intent of 10 CFR 54.21(c) is for of the effectiveness of some new applicants to submit TLAA evalua-AMPS may be required prior to tions at the time of application.
approval of an application.
The staff emphasized its expectation that TLAA evaluations need to be NEI 95-10, f 4.2.1.3, 6 4.4, 5 6.2 completed and submitted at the time and Appendix C does not contain of application. NEI 95-10 indicates separate guidance for a "demonstra-that there may be instances in which tion" of a new AMP.
In addition, TLAAs can be deferred; however, no the inconsistent implementation of criteria are provided. The staff the guidance contained in NEI 95-10, will recommend that additional guid-observed by the site-visit teams ance be added to NEI 95-10, 5 5.1.4, throughout the LRDP, is an indica-to clarify and strengthen the guid-tion that additional description ance for submitting TLAA evaluations and/or clarification of the existing at the time of applicath n.
guidance is needed. The staff will make recommendations to address 2.7 FSAR Supplement these concerns.
The rule. 10 CFR 54.21(d), requires 2.6 TLAA that a supplement to the FSAR be submitted at the time of application The TLAA evaluations required to be which provides a summary description included in an LR application by of LR program and activities used to 10 CFR 54.21(c) includes all calcu-manage the effects of aging and the lations and analyses as defined evaluation of TLAAs.
NEI 95-10, under 10 CFR 54.3.
Guidance for 5 6.2.3 and 9 6.3, contain the guid-preparing TLAA evaluations is pro-ance for this requirement.
vided under NEI 95-10, S 5.1.
2.7.1 Observations 2.6.1 Observations Although the site-visit teams obser-The content of TLAA evaluations pre-ved that the sample FSAR supplements sented during the site visits were had improved over the LRDP, the sup-generally consistent with the guid-plements presented did not fully ance under NEI 95-10, 6 5.1, and the meet the requirements of intent of the rule but a concern 10 CFR 54.21(d).
The most notable with the timing of TLAA evaluations deficiency was the lack of detail in was identified.
The site-visit the description of the LR programs teams observed, that for the purpose and activities.
In addition, the of the LRDP, a number of the partic-site-visit team noted that the guid-ipants indicated they intended to ance under NEI 95-10, 6 6.2.3 and defer tvaluating many of the TLAAs s 6.3, allows applicants to submit until after (in some cases, many descriptions that are consistent years) they submit their LR applica-with the level of detail currently tion which is not consistent with provided in some FSARs, which in NEI 95-10 or the intent of the rule.
some cases may not be consistent Some additional guidance may be with the current NRC position on the NUREG-1568 12
l information required in an FSAR.
The LRDP identified the need for i
Additional guidance may be needed to additional description and/or clar-address these concerns.
ification for referencing topical reports, identifying intended func-2.7.2 Lessons Learned tions, determining component passive functions, identifying commodity NEI 95-10, 5 6.3, states that " Sum-groups, determining aging effects, mary descriptions of the programs selecting AMPS, and providing a and activities for managing the eff-
" demonstration" for AMPS.
ects of aging shall be included in the FSAR supplement at the level of The LRDP also identified that addi-detail consistent with the current tional guidance may be needed for FSAR." This guidance implies that assessing GSIs/USIs, determining the the current level of description in long-lived characteristics for con-the applicant's FSAR, which may not sumables (e.g.; gaskets and seals),
include all the information required providing a " demonstration" for by 10 CFR 54.21(d), is adequate.
AMPS, and providing timely submittal of TLAA evaluations.
The Commission recently directed that this issue, for LR, be coordin-Gaining experience with the level of ated with FSAR concerns observed at detail for an LR application, onsite operating reactors. The staff will information, and an FSAR supplement recommend that the guidance under was a key objective of the LRDP.
NEI 95-10, 9 6.3, be revised and The LRDP was beneficial in this additional guidance ba developed to regard and confirmed the need for provide the guidance necessary to some additional description and/or develop an FSAR supplement that clarification of the guidance in meets the intent of the rule.
these areas.
- 3. CONCLUSIONS The improvements and additions to NEI 95-10, that are needed for In general, NEI 95-10, appeared to developing an LR program consistent contain most of the guidance needed with the intent of the rule, will be for scoping, screening, identifying included in NEI 95-10 or the RG.
In aging effects, developing AMPS, and addition, changes as approved by the evaluating TLAAs.
However, as staff from comments provided by the expected, the LRDP site-visit public and industry will be added reviews identified the need for some prior to final publication of the improvements to assist applicants in RG.
developing LR applications and sup-porting documentation.
13 NUREG-1568 l
I REFERENCES 1.
U.S. Nuclear Regulatory Comission, " License Renewal Demonstration Program Site Visit, Calvert Cliffs Nuclear Power Plant Trip Report,"
Project No. 690, Washington D.C., April 15, 1996.
2.
U.S. Nuclear Regulatory Comission, " License Renewal Demonstration Program Site Visit, Oconee Nuclear Power Station Trip Report," Project No. 690, Washington D.C., May 21, 1996.
3.
U.S. Nuclear Regulatory Comission, " License Renewal Demonstration Program Site Visit, Hatch Nuclear Power Plant Trip Report," Project No.
690, Washington D.C., July 9, 1996.
4.
U.S. Nuclear Regulatory Comission, " License Renewal Demonstration Program Site Visit, Point Beach Nuclear Power Station Trip Report,"
Project No. 690, Washington D.C., July 30, 1996.
5.
U.S. Nuclear Regulatory Comission, " License Renewal Demonstration Program Site Visit, Peach Bottom Atomic Power Plant Trip Report,"
Project No. 690, Washington D.C., September 16, 1996.
6.
U.S. Nuclear Regulatory Commission, "Prioritization of Generic Safety Issues," NUREG-0933, June 30, 1995.
NUREG-1568 14 l
l
NQ Fonu 335 U.S. NUCLEQQ REGULQTORY COMMISSION 1.
P TN E
hRCM i102.
ed AdCmdum Numbers,if env.)
- ,22 5 BIBLIOGRAPHIC DATA SHEET ISee onstructoons on the reverse) z intE A~o suBrif tE NUREG-1568 3
DATE REPORT PUBLISHED License Renewal Demonstration Program:
l NRC Observations and Lessons Learned December 1996
- 4. FIN OR GR ANT NUMBER 4 b AU THOR (S) 6 TYPE OF REPOHT Regulatory R.J. Prato, P.T. Kuo, S.F. Newberry
' P6 "'oo cov 6 " E o ""<'"~ "
3/96 8/96 8.
FORMING Nf LA 1lON - N AM L AND ADDR E SS H9 NRc. crove Onvenoon. Ottore or Roeron, V5 hackar Regelerorv Commooseen. ane eseohne adens or contwror, prouw DRPM, NRR, U.S. Nuclear Regulatory Conssission, Washington, DC 20555 9 ONSOR G ANIZA TION - N AM E AND ADDR E SS tar NRc. rvoo ~some ss onore ', ar canorector prov.ee NRc o,vnoon. on.cn or neevn. u s Nucieer noeuterors cornmown.
DRPM, NRR, U.S. Nuclear Regulatory Conunission' Washington, DC 20555
- 10. SUPPLEMENTARY NOTES i
- 11. ABST R AC T Goo mores or was This report summarines the Nuclear Regulatory Commission staff's observations and lessons learned from the five License Renewal Demonstration Program (LRDP) site visits performed by the staff from March 25,1998, through August 18,1996. The LRDP was a Nucieer Energy institute (NEI) program intended to assess the effectiveness of the guidance pro-vided by NEl 9510, Revision 0,
" Industry Guideline for implementing the Requirements of 10 CFR Part 54 The License Renewal Rule," to implement the requirements of Title 10 of the Code of Feders/ #eputadons, Part 54 (10 CFR Part 54), " Requirements for Renewal of Operating Licenses for Nuclear Power Plants."
in general, NEl 9510, appeared to contain most of the guidance needed for scoping, screening, Identifying aging effects, developing aging managememt programs, and evaluating time limited aging analysis. However, as expected, the LRDP site-visit reviews identified the need for some improvements to assist applicants in developing license renewal applications and supporting documentation. The improvements and additione to NEl 95-10, that are needed for developing an license renewal program conalstent with the intent of the rule, wtl be included in NEl 9510 or the applicable Regulatory Guide,
- 12. KE Y WORD $/DESCH:P IQH S it,st oon8s or parews taat svedr essist rosearcheru m locarmp rae rnoorr. J 13 Av Astatsa Le t Y S f AIL MENI NE! g5-10, license renewal demonstration program, LRDP,
- i. se cuRi f v e t*>>'* 'ca i 'o~
l t iha Peert lessons learned I thos Nepore)
Ib NUMBEH OF PAGES
- 16. PRICE NRC F ORM 3)$ G,96
Printed on recycled paper Federal Recycling Program
~
NUREGT-568 MSE RENEWAL DEMONSTRATMIOGRAM: hMTIONS AND LESSONS LEARh'ED DECEMBER 1996 UNITED STATES RRST N M NUCLEAR REGULATORY COMMISSION 120555139531 1 1anj9g POSTAGE AND FEES PATO WASHINGTON, DC 20555M1 US NRC-OaDM USNRC hp[ h Nyhn.]BLICATIONSSucg PEME NO. M f Jk ON WM BNSS 0C
?"555 PENALTY FOR PRfVATE USE, $300 l
- _ _ _ _ _ _ _ _ _.