ML20153F497
| ML20153F497 | |
| Person / Time | |
|---|---|
| Issue date: | 09/23/1998 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Walters D NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| NUDOCS 9809290148 | |
| Download: ML20153F497 (4) | |
Text
.
September 23, 1998 4
l
- t Mr. Douglas J.Walters i
Nuclear Energy Institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
LICENSE RENEWAL ISSUE No. 98-0014, " STAFF GUIDANCE FOR LICENSE RENEWAL APPLICATION SUBMITTALS ON TIME-LIMITED AGING ANALYSES FOR ENVIRONMENTAL QUALIFICATION"
Dear Mr. Walters:
Enclosed is the staff's evaluation and proposed resolution for the subject issue. The staff plans to implement the recommended resolution as part of the next revision to the draft Regulatory Guide entitled "Stanhrd Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses.' We also expect NEl 95-10, " Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule," to include the necessary changes to reflect the guidance provided in the enclosed guidance. Accordingly, if there are any industry comments on the evaluation basis or the proposed resolution, we request that you provide those comments to us in writing within 30 days following your receipt of this letter, to ensure a timely resolution of this issue. If you have any questions regarding this matter, please contact Robert Prato at 301-415-1147.
Sincerely, Orfoinalstned By Christopher I. Grimes, Project Director License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation
Enclosure:
As stated Q1S_TRtB.UTION ContalFilots PUBLIC PDLR R/F NRC FIF CENH COPY gwp h
3" '
g
- See orevious concurrence DOCUMENT NAME:G:\\ WORKING \\PRATO\\lL980014 (0
Te receive e copy of this document, Indicate in the bos: "C" = Copy without spelosures *E" = Copy with enclosures "N* = No copy OFFICE PDLR:ASC EELB:EE 9Cf EELB:BC, UDM:AD OGC PDLR.PD DR3M:DD NAME RPrato PShemanski JCalvo / f GNtnas JMoore CGrimes JFNe DATE 09/23/98*
09/U/98 09/23/98 Qb/Ff/98 09/23/38*
09/ /98 09h.$98 OFF/CIAL RECORD COPY
'>n M L-4 1 W 5 't
- o 98G9290148 98'0923 i
PDR REVOP ERGNUMRC.
l
?DR,
h GUIDANCE ON ENVIRONMENTAL QUALIFICATION TIME-LIMITED AGING ANALYSES FOR LICENSE RENEWAL An application for license renewal under 10 CFR Part 54 must contain an evaluation of time-limited aging snalyses (TLAAs). TLAAs are defined in 9 54.3 as "those licensee calculations and analyses that (1) Involve systems, structures, and components within the scope oflicense renewal, as delineated in f 54.4(a); (2) Consider the effects of aging; (3) Involve time-limited assumptions defined by the current operating term, for example, 40 years; (4) Were determined to be relevant by the licensee in making a safety determination; (5) Involve conclusions or provide the basis forconclusions related to the capability of the system, structure, and component to perform its intended functions, as defineatcd in f 54.4(b); and (6) Are contained orincorpomted by reference in the CLB." Most environmental qualification (EQ) anal: 9 meet this definition.
In accordance with @ 54.21(c)(1), "[a] list of time-limited aging analyses, as definedin @ 54.3, must be provided." The TLAA list for EQ should include ine components on the EQ Master Lis.t maintained pursuant to S 50.49(d) that are qualified for the fts term (or longer) of the current operating license. The applicable option, as described below, should be identified for each item on the list.
For each TLAA,6 54.21(c)(1) also requires that each applicant demonstrate one of following three epFU.s:
(c)(1)(i)
- Tile analyses remain valid for the period of extended operation.'
The applicant should summarize these analyses in the application for each item or group of electrical equipment. For the purposes of demonstration, these summaries should include (1) a summary of thermal and radiation analyses that show the existing analyses remain valid to the end of the period of extended operation and (2) the qualification calculation reference number. A thermal analysis summary should show l
that the bounding average ambient temperature used in the existing analysis is less than the calculated average ambient temperature based on preconditioning of the l
equipment for a 60-year qualified life. Each summary should also include the numerical values of these temperatures. A radiation analysis summary should show that the bounding 60-year integrated dose (normal dose plus design basis accident dose) is less I
than the dose used in the qualification of the equipment. Each summary should include i
the numerical values of these doses. Altemstively, the applicant may briefly explain why the equipment for which anal)ses remain valid is insensitive to aging.
1 (c)(1)(ii)
"The analyses have been propc:od to the end of the period of extended
}
operation."
i I
The applicant should summarize these analyses in the application for each item or y
group of electrical equipment. For the purposes of demonstration, these summaries should include (1) a summary of thermal and radiation analyses that show the analysis was projected to the end of the period of extended operation and (2) the qualification calculation reference numbers. /. thermal analysis summary should show that the i-bounding average ambient temperature, from actual temperature measurements,
_.. ~ _.
2 including self-heating, if appropriate, is less than the calculated average ambient temperature based on preconditioning of the equipment for a 60-year qualified life.
i Each summary should also include the numerical values of these temperatures. A l
radiation analysis summary should show that the bounding 60-year integrated dose (normal dose plus design basis accident dose) is less than the dose used in the original l
qualification of the equipment. Each summary should include the numerical values of these doses.
l (c)(1)(iii)
"The effects of aging en the intended function (t) of EQ equipment will be adequately managed for th3 period of extended operation."
Aging for the purposes of EQ, as identified under 10 CFR 50.49(e)(5), allows for replacement or refurbishment of all EQ components at the end of qualified life unless ongoing qualification demonstrates that the item has additional life. Therefore, for the purposes of license renewal, an aging management program for those components that are not qualified to the end of the period of extended operation should be placed in an ongoing qualification program, or replaced or refurbished at the end of its qualified life.
For the purpose of demonstrating that the effects of aging will be managed, the application should include a description of activities for each item or group of electrical equipment, as well as any changes to the current licensing basis and plant modifications that are relied on to demonstrate that the intended function (s) will be adequately maintained despite the effects of aging during the period of extended operation.
Guidance for providing a description of the activities for an aging management program (i.e., refurbish or replacement) can be found in NEl 95-10, 9 4.2.1.2, entitled " Identify Plant Aging Management Programs." In addition, in the Statements of Consideration accompanying the 1995 amendment to Part 54 (60 FR 22475), the Commission explained that "the straightforward approach to detecting and mitigating the effects of
(
aging begins with a process that verifies that the intended design functions of systems, i
simctures, and components have not been compromised or degraded." In addition, L
guidance for the level-of-detail that should be provided in the application can be found in l
NEl 95-10, @ 4.2.1.3, entitled " Demonstrating That the Effects of Aging are Managed,"
and 6 6.2, entitled " Exhibit A - Technical information." Toward that end, the demonstration should describe the process by which compl!ance with 9 50.49 will be maintained throughout the period of extended operation. Particularly usefulinformation regarding the process are those features reNad to the aging considerations described in 9 50.49(e)(5), and decision criteria for replacing or refurbishing EO equipment before the end of the equipment's qualified life.
If an applicant chooses to rely on testing as discussed under S 50.49(f) by applying ongoing test programs, the application should describe the program consistent with the guidance in IEEE 323-1974, Section 6.6 (1) or (2). In addition, the description should i
include the current qualified life for each item or groups of electrical equipment, and the period of time prior to the end of qualified life when testing will be completed.
1 In addition to the options discussed under 10 CFR 50.49, an applicant may want to l
re-analyze the qualified life of an item or group of electrical equipment at some time l
9 i
~ -._.. -..
1 3
after the renawed license has been approved. For the staff to evaluate this option at the time of cpplicat:on, the applicant should define its aging management program by descnbing the attributes of the program that will be used in the re-analyses in the license renewal application. The attributes of re-analyses that will be performed should include analytical methods; data collection and reduction methods, if needed; underlying assumptions; acceptance criteria; corrective actions if acceptance criteria are not met; and the period of time prior to the end of qualified life when re-analyses will be completed. This information can be provided at a level-of-detail consistent with the guidance found in NEl 95-10, 9 4.2.1.3, entitled " Demonstrating That the Effects of Aging are Managed," and 9 6.2, entitled " Exhibit A - Technical information."
The foregoing guidance describes an acceptable approach for satisfying the requirements of 9 54.21(c)(1) for EQ analyses. Applicants may propose alternate approaches, but such approaches shoald provide a comparable level of information so that the staff can conclude that the time-limited aging analyses for EQ have been identified and there is reasonable assurance that the effects of aging applicable to the EQ analyses will be adequately managed for the period of extended operation.
l L
t i
d w
,.