ML20204J203
| ML20204J203 | |
| Person / Time | |
|---|---|
| Issue date: | 03/24/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Diaz N, Dicus G, Shirley Ann Jackson, Mcgaffigan E, Merrifield J, The Chairman NRC COMMISSION (OCM) |
| Shared Package | |
| ML20204J208 | List: |
| References | |
| NUDOCS 9903300030 | |
| Download: ML20204J203 (2) | |
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e UNITED STATES 4
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NUCLEAR REGULATORY COMMISSION e
WASHINGTON, D.C. 20065-0001 o
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March 24, 1999 MEMORANDUM TO: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield r
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I FROM:
William D. Travers M{h m'a Executive Director for Operations
SUBJECT:
CREDIT FOR EXISTING PROGRAMS FOR LICENSE RENEWAL The purpose of this memorandum is to keep the Commission informed of a potential policy issue that may require Commission direction. The license renewal rule requires (1) a demonstration that the effects of aging on passive, long-lived structures and components will be adequately managed for the period of extended operation and (2) an evaluation of time-limited aging analyses. The initial license renewal applicants have found that about 80 to 90 percent of the aging management programs for license renewal are existing programs. The subject issue relates to how existing programs may be credited for license renewal end the industry concern about rejustifying existing programs relied upon to manage aging.
By letter dated March 3,1999, the Nuclear Energy Institute (NEI) submitted a draft paper discussing the industry's views on how existing plant programs and activities should be credited for license renewal (see attachment). The staff will be meeting with NEl to discuss their views on March 30,1999.
The industry position is that the demonstration required for license renewal is " continued compliance with current licensing basis" programs that manage aging effects plus any new programs to address aging effects not managed under the current licensing basis. Rather than requiring "a new showing o! programmatic adequacy" for license renewal, the industry believes that existing programs that have been found acceptable for the current terrn should be deemed adequate unless a signTicant change in the aging effect is expected during the period of extended operation. NEl also stated that " isolated phrases or sections of the rule or Statements of Consideration are cited to support one view or another."
The license renewal rule excludes active, short-lived structures and components from an aging I
management review because of the existing regulatory process, existing 'icensee programs and C activities, and the maintenance rule. However, the Commission concluded that "an aging management review of the passive functions of structures and components is warranted to provide the reasonable assurance that their intended functions are adequately maintained during the period of extended operation"(60 FR 22476). In addition,"certain piant-specific Wb
Contact:
Sam Lee, NRR 415-3109 9903300030 990324
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safety analyses may have been based on an explicitly assumed 40-year plant life (e.g.,
aspects of the reactor vessel design). As a result, an evalua' ion for license renewal would be
- required" (60 FR 22479). Thus, the license renewal rule focuses on the aging management j.
- review of passive, long-lived structures and components and the evaluation of time-limited aging analyses.
The NRC staff recognizes that existing programs will usually be found fully adequate to manage the effects of aging if continued into the period of extended operation. The staff currently views Part 54 such that existing programs are not automatiuilly adequate to manage aging effects for 4
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- license renewal simply because they are part of the current licensing basis. There could be areas within existing programs that may not adequately address aging effects for license i
renewal.- For example,10 CFR 50.55a(g) requires licensees to perform inservice inspection in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI. However, during license renewal reviews, the staff found that the ASME Section XI Code does not address certain areas, such as cracking of less than 4-inch-diameter reactor coolant system piping, clad pressurizer shell, and containment penetration l
bellows. The staff identified these areas within the inservice inspection program by matching the j
aging effects with attributes of the existing program. Thus, the staff has requested applicants to provide new aging management programs to address these areas. The focus of the staff's
- review of existing programs is to identify areas, if any, within these programs that may not adequately address aging effects for license renewal, consistent wiih the staffs view of the outcome evpected for a Part 54 review.
The industry remains concerned that existing programs should be deemed adequate for license renewal without rejustification to avoid having the adequacy of these programs challenged. The i
~ staff is examining the issue raised by NEl in its March 3,1999, letter to see whether changes in implementation of the rule can be justified. The staff will pursue this issue generically while continuing to meet plant review schedules for Calvert Cliffs and Oconee. The staff plans to j
submit an options paper to the Commission with the staff's recommendations by May 28,1999.
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