ML20205C178

Ack Receipt of to R Zimmerman Providing Views on How Existing Plant Programs & Activities Should Be Created for License Renewal

ML20205C178
Person / Time
Issue date:	03/26/1999
From:	Kane W NRC (Affiliation Not Assigned)
To:	Pietrangelo A NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
PROJECT-690 NUDOCS 9904010092
Download: ML20205C178 (3)

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. Mr. Anthony R. Pietrangelo, Director March M.1999 Licensing Nucisar Generation Division i

Nuclear Energy Institute 1776 i Street, NW., Suite 400 Washington, DC 20006-3708 i

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SUBJECT:

CREDIT FOR EXISTING PROGRAMS FOR LICENSE RENEWAL

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Dear Mr. Pietrangelo:

Your March 3,1999, letter to Roy Zimmerman provided the industry's views on how existing plent programs and activities should be credited for license renewal. We have informed the Commission of the receipt of this letter in the enclosed memorandum.

We will discuss this issue at the March 30,1999, public meeting between the industry's License Renewal Working Group and the NRC's License Renewal Steering Committee. We plan on submitting an options paper to the Commission after that meeting.

Sincerely, 0 rginalsignedby William F. Kane, Associate Director for inspection and Programs Office of Nuclear Reactor Regulation

Enclosure:

As stated Project No. 690 Distribution See next page

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4 safety analyses may have been based on an explicitly assumed 40 year plant life p.g.,

aspects of the reactor vessel design). As a result, an evaluation for license renewal would be required"(60 FR 22479). Thus, the license renewal rule focuses on the aging management review of passive, long-lived structures and components and the evaluation of time-limited aging

analyses, i

1 The NRC staff recognizes that exiding programs will usually be found fully adequate to manage 4

the effects of aging if continued into the period of extended operation. The staff currently views Part 54 such that existing programs are not automatically adequate to manage aging effects for i

license renewal simply because they are part of the current licensing basis. There could be area's within existing programs that may not adequately address aging effects for license renewal. For example,10 CFR 50.55a(g) requires licensees to perform yservice inspection in accordance with the American Society of Mechanical Engineers (ASME) Boiler and Pressure 1

Vessel Code,Section XI. However, during I; cense renewal reulews, the staff found that the ASME Section XI Code does not address certain areas, such as cracklr<g of less the 4-inch-f diameter reactor coolant system piping, clad pressurizer shell, and containment penetration bellows. The staff identified these areas within the inservice inspection program by matching the 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, l' any, within these programs that may not adequately address aging effects for license renewal, consistent with the staff's view of the outcome expected for a Part 54 review.

The industry remains concerned that existing programs should be deemed adequate for license i

renewal without rejustification to avoid having the adequacy of these programs challenged. The 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 submit an options paper to the Commission with the staff's recommenda'.lons by May 28,1999.

Attachment:

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l NUCLEAR ENERGY INSTITUTE l

(License Renewal Steering Committee) l Project No. 690 l

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Mr. Dennis Harrison Mr. Robert Gill U.S. Department of Energy Duke Energy Corporation NE-42 Mail Stop EC-12R Warhington, D.C. 20585 P.O. Box 1006 Chariotte, NC 28201-1006 Mr. Ricard P. Sedano, Commissioner Mr. Charles R. Pierce State Liason Officer Southern Nuclear Operating Co.

Department of Public Service 40 Inverness Center Parkway 112 Staie Street BIN B064 Drawer 20 Birmingham, AL 35242 Montipelier, Vermont 05620-2601 Mr. Douglas J. Walters Mr. Barth Doroshuk Nuclear Energy institute Baltimore Gas & Electric Company 1776 i Street, N.W.

1650 Ca! vert Cliffs Parkway Washington, DC 20006 Lusby, Maryland 20657-47027 DJW@NEl.ORG NationalWhistleblower Center Chattooga River Watershed Coalition 3233 P Street, N.W.

P. O. Box 2006 Washington, DC 20007 Clayton, GA 30525 Mr. William H. Mackay Entergy Operations, Inc.

Arkansas Nuclear One 1448 SR 333 GSB-2E Russellville, Arkansas 72802

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S UNITED STATES NUCLEAR REGULATORY COMMISSION 5,

wasumaron, o.c. mes.emi Ng March 24, 1999 MEMORANDUM TO: Chairman Jackson i

Commissioner Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield MOM:

William D. Travers.

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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 and the industry concem about rejustifying existing programs relied upon to manage aging.

By letter dated March 3,1999, the Nuclear Energy Institute (NEl) 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.

1 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 managod under the current licensing basis. Rather than requiring "a new showing of programmatic adequacy" for license renewal, the industry believes that existing programs that have been found acceptable for the current term should be deemed adequate unless a significant 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 management review because of the existing regulatory process, existing licensee programs and activities, and the maintenance rule. However, the Commission concluded that "an aging management review cf 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 plant-specific

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S. Newberry C. Grimes F. Akstulewicz J. Strosnider R. Wessman G. Bagchi H. Brammer i

T. Hiltz G. Holahan C C atton R. Correia R. Latta J. Moore R. Weisman M. Zobier G. Mizuno J. Craig M. Mayfield J. Vora W. McDowell S. Druggitis G. Tracy PDLR Staff r13004

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man ocacunouo.mion March 8,1999 Mr. Roy P. Zimmerman, Chairman License Renewal Steering Committee U.S. Nuclear Regulatory Coaumission Washington, D.C. 20555 0001

Dear Mr. Zimmerman:

Enclosed is a draft paper that discusses the industry's views on how existing plant programs and activities should be credited for license renewal. We are providing I

this paper with the objective that it will serve as a starting point for discussions on the level of detail versus re verification question that has dominated many of our meetings with the Steering Committee.

The paper provides background information including our view of the NRC staffs position on the topic. If we have misrepresented the staffs position, we did so unintentionally and look forward to understanding the differences so that this matter can be resolved.

i In summary, we believe that existing programs that comply with the current licensing basis and that are subject to NRC oversight should be credited for the 1

renewal period. The focus of the staffs review should be on aging effects that are not being managed by current licensing basis programs.

We look forward to meeting with the Steering Committee March 30 and trust this paper will help facilitate discussions and drive the issue to closure.

Sincerely, Anthony R. Pie:.rangelo Enclosure

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Mr. Roy P. Zimmerman March 3,199.9 r.-

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DRAFT LEVEL OF DEMONSTRATION REQUIRED FOR EXISTING PROGRAMS UNDER THE LECENSE RENEWAL RULE l

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i LEVEL OF DEMONSTRATION REQUIRED FOR EXISTING PROGRAMS j

UNDER THE LICENSE RENEWAL RULE i

L Introduction The purpose of this paper is to present the industry's view on how to make the demonstration required for license renewal when the demonstration is taking credit for existing plant programs and activities.

For some time, the industry and NRC staff have struggled with articulating how a license renewal applicant makes the demonstration called for in 10 C.F.R. 54.21(a)(3). Our objective is to use this paper as a four.dation for dialogue with the NRC stasto drive the issue to resolution.

We have taken some liberty in describing our understanding of the NRC staff's views on this issue. If we misrepresented their views we did so unintentionally and look forward to understanding the differences so that we can resolve this matter.

The paper begins with some background information on the issue of the demonstration required for license renewal and creoiting existing programs. There is a summary of the industry position regarding the demonstration. A briefdiscussion ofour understanding of the NRC staff's position is also provided. Next is an overview of the license renewal rulemaking history followed by a summary and conclusion. Appendix A is a detailed discussion of the industry approach. It includes an example of how the industry envisions an existing current licensing basis program being credited for license renewal. Appendix B is a typical list of current licensing basis programs.

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Background

The integrated plant assessment is the centerpiece of the license renewal application. Section 54.21(a)(3) states that the integrated plant assessment must:

... demonstrate that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the current licensing basis for the period of extended operation" A.

Industry Position The industry position is that the demonstration required for license renewal is continued compliance with current licensing basis programs that manage aging effacts plus any new programs to address aging effects not managed by the current licensing basis. It is important to note that when we discuss our position, our reference to the current licensing basis is not a zeference to the definition provided in Part 54. The current licensing basis in this context is a set ofinformation and the regulatory oversight process which includes ongoing inspections, I-

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Rather than requiring a new showing ofprogrammatic adequacy for license renewal, the industry believes the rule allows a graded approach under which the adequacy ofprograms relied upon to manage aging would depend on the degree of regulatory oversight for such programs. Existing programs that have been found acceptable for the current term should be deemed adequate unless a signif; cant change in the aging effect is expected during the period of extended operation.

i New or modified programs or actions would require a more detailed demonstration of adequacy.

His recommended approach would better fulfill th. Commission's policy objectives, as understood by the industry, underlying the revt ed Part $4.

A detailed discussion of the industry position is included as Appendix A to this paper.

B.

He NRC Staff Position Recent pronouncements from the NRC staff suggest that the demonstration for license renewal is a level of detail question; meaning how much information about an aging management program needs to be provided in the license renewal application. Other views expressed by the NRC staff suggest that the demonstration requires a new showing of adequacy for existing programs that are relied upon under the current license to manage aging. This appears to be true even for programs that are based on regulatory requirements, such as in-service inspection programs under 10 C.F.R. i 50.55a and environmental qualification pursuant to 10 C.F.R. i 50.49.

The NRC staff's position is best captured in the following excerpts from their letter to the Westinghouse Owners' Group dated January 29,1998 regarding the ASME Code Section XI in-serviceinspection program:

ne ASME Code Section XI ISI program is used to meet the require:nents of 10 C.F.R. Part 50 but does not explicitly address the regulatory requirements of 10 C.F.R. Part 54.

De Commission promulgated the License Renewal rule under the basic premise that currentprograms may or may not be adequate to manage the efects ofaging on passive, long-lived structures and components or with regard to time-limited aging analyses during the period of extended operation. While there may be many existing programs that will provide adequate aging management under Part 54, the License Renewal rule requires that the NRC staff formally conclude how that adequacy is demonstrated as part of the basis for granting a renewed license." (Emphasis added.)

Similarly, in a recent Request for Additional Information, the adequacy of the containment inspection program which is based on the NRC's regulations in 10 C.F.R. 6 50.55a is questioned.

De license rmewal rule requires a specific " demonstration" that the effects of aging are adequately managed to ensure structure and component intended function during the period of extended operation. De report needs to provide f

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We believe these views are derived from (1) an overly broad interpretation of the demonstration required under Section 54.21(aX3) and the finding required by Section 54.29, and (2) a misconception that the renewed license issued under Part $4 is a new license which offers the opportunity to " neaten up" the technical specifications and FSAR to comport with the "new license."

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Rulemakinn Historv 4

So often, and even in this paper, isolated phrases or sections of the rule or Statements of i

Consideration are cited to support one view or another. The starting point in the analysis of any regulation is the language and structure of the regulation itself. A particular part or section of the regulation may not be considered in isolation but must be interpreted in reference to the entire regulation so as to produce a " harmonious whole." A regulation must also be interpreted in light ofits regulatory history ifit is not otherwise clear on its face. We reviewed the Part 54 rulemaking history and believe it is clear that the Commission did not intended applicants to re-j justify the adequacy of existing programs that manage aging oflong-lived passive structures and t

components ne license renewal rule was first promulgated in 1991 to establish specific procedures, criteria and standards goveming nuclear power plant license renewal. A fundamental principle of the license renewal rule is that "[t]he licensing basis for a nuclear power plant during the renewal tenn will consist of the current licensing basis and new commitments to monitor, manage, and correct age related degradation unique to license renewal, as appropriate."' The Commission engages in a large number of regulatory activities which, when considered together, constitute a regulatory process that provides ongoing assurance that the licensing bases ofnuclear power plants provide an acceptable level ofsafety. That led the Commission to conclude that there is likely only one real issue generally applicable to all plants - age-related degradation. The renewal rule focuses the C=- != ton's review on this one safety issue but provides leeway for the Commission to consider, on a case-by-case basis, other issues unique to extended operation.

4 Thus, with the exception of age-related degradation unique to license renewal and possibly a few otherissues related to safety only during extended operation, the Commincion concluded that regulatory process is adequate to ensure that the licensing bases ofall currently cg..Geg plants provide and maintain an aevable level of safety for operation so that operation will not be inimical te public health and safety or common defense and security.8

. I $6 Fed. Reg. 64946 2Id. at 64949. Sw also 60 Fed. Reg. 22461,22464 (May 8,1995).

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m Following promulgation of the original license renewal rule in 1991, the Commission

" determined that the requirement for carrying out the license ren:wal review can and should be simplified and clarified. 'Ihe Commission has concluded that, for certain plant systems, structures, and components, the existing regulatory process will continue to mitigate the effects of aging to provide an acceptable level ofsafety in the jeriod of extended operation."' As a result, the Commission concluded that the license renewal review "is intended to identify any pdditional actions that will be needed to maintain the functionality ofsystems, structures, and components in the period of extended operation.'"

Because aging is a continuing process, the Commission has concluded that existing programs and regulatory requirements that continue to be applicable in the period of extended operation and provide adequate aging management for systems, structures, and components should be credited for license renewal. Accordingly, the license renewal rule " focuses the renewal review on plant systems, structures, and components for which current activities and requirements may not be sufficient to manage the effects of aging in the period of extended operation."*

The concept of the current licensing basis continuing through the renewal term is a critical principle underlying the license renewal rule. Unfortunately, despite the Commission's clear statement ofintent to the contrary, questions have been raised conceming the need for licensees to document their current programs to demonstrate compliance with NRC regulations as part of the license renewal appiication.

The Commission addressed precisely this issue in its Statement of Considerations of the 1995 rule. Two commenters had raised concems that the proposed mle could be erroneously interpreted as requiring a general demonstration of compliance with the current licensing basis as a prerequisite for the issuance of a renewed license.

The Commission concluded that the proposed rule was sufficiently clear in distinguishing between the issues that must be addressed as part of the renewal review versus those that must be addressed in the context of operation under the current license. However, to elimiaae any possible misinterpretation, the Commission narrowed the findings required to be made under Section 54.29, Standardfor Issuance ofRenewedLicense, for is:;uance of a renewed license. A new provision, 54.30, Matters Not Subject to a Renewal Review, was created to clarify the licensee's responsibilities for addressing safety matters under its current license that are nel 3 60 Fed. Reg.22464.

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within the scope of the renewal review.* He Commission observed that "[s]eparating the subjects into two different sections should minimire any possibility ofmisinterpreting the scope j

of the renewal review and finding."'

Section 54.30 requires additional licensee, and NRC, action under the current license if the reviews of the integrated plant assessment or time-limited aging analyses required by Sections 4

j 54.21(a) and (c) show that there is not reasonable assurance during the current license term that licensed activities will be conducted in accordance with the current licensing basis. It does not require a licensee to demonstrate that the current licensing basis contains programs adequate to i

ensure compliance with current NRC requirements.

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Here is no regulatory basis for a demand by the NRC staff that a license renewal applicant providejustification that its programs or other aspects ofits cu rent licensing basis comply with NRC regulations, nor does the license renewal rule require that the Commission make a finding that the spplicant's programs comply with Commission regulations such as tojustify the required j

submission by a license renewal applicant of any data regarding the sufficiency of current licensee programs.

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Summary i

j From a review of the rule and its history, it is clear that the way in which the demonstration is made is not well defined. Nevertheless, it appears that the Commission did not intend that i

applicants would have to re justify existing programs relied upon to manage aging. Instead, a j

review of the revised Part 54 supports the view that existing performance and condition j

monitoring programs can be effectively relied upon in sadsfying the aging management review requirements applicable to long-lived, passive structures and components.

l The fundamental issue then becomes did the Commission conclude that existing programs that i

adequately manage aging effects during the current term to ensure compliance with the current j

licensing basis will continue to be adequate in the renewal term because of the ongoing j

regulatory oversight, or, did they conclude that existing programs may or may not be adequate and direct the Staff to formally conclude how that adequacy is demonstrated as part of the basis forgranting a renewedlicense?

l When the Commission directed the Staff to revise Part 54 ud generically eliminata active i

components from aging management reviews, the purpose behind the effort was to realign the j

focus of the rule away from a "mdanidc" evaluation of aging degradation and toward ensur j

" functionality" of key equipment. Moreover, the Commission wanted to allow greater reliance

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on existing programs, including performance and condition monitoring programs, provided that the applicant performed a review to ensure that those programs that indirectly verify 4

j functionality oflong lived, passive components were adequate to provide the requisite reasonable assurance offunction for the renewal term.

De precise nature of the programs relied upon by renewal applicants to manage the effects of aging are not defined in Part 54. Nor is there a specific requirement in Part 54 for a renewal applicant to re-justify existing current licensing basis programs. He rule requires only that the i

FSAR supplement contain a " summary description of the progratus and activities for managi the effects of aging." At most, in derming the findings the Commission must make prior to issuing a renewed license, the rule requires a finding that "[a]ctions have been identified and j

have been or will be taken... such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis, and that any changes made to the plant's current licensing basis in order to comply with this paragraph are in accord with the Act and the Commission's regulations." 10 C.F.R. ) 54.29(a). The rule is silent with regard to thejustification necessary to demonstrate reasonable assurance.

V.

Conclusion If a license renewal applicant reviews an existing program and has sufficient technical basis to conclude that the program provides reasonable assurance that the intended function will be maintained throughout the period of extended operation, the program should simply be credited in the aging management review process. He demonstration provided in the license renewal 4

application should be proportional to the level ofregulatory scrutiny that is applied in the current term. Programs that are subject to full regulatory scrutiny under the current licensing basis should not require detailedjustiScation for the renewal term. Rose programs that must be created or significantly enhanced to provide rr nnable assurance that the intended function will be maintained throughout the renewal term maj.equire additionaljustification and discussion in the license renewal application.

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l Appendix A INDUSTRY APPROACH TO THE LICENSE RENEWAL DEMONSTRATION

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Elements of a Demonstration ne industry approach to demonstrating the adequacy of existing programs is graded. Following the identification oflong-lived passive structures and components, an applicant determines the aging effects which challenge the ability of the stmeture or component to perform the intendM function in accordanc' with the current licensing basis. Rese effects would then be comparea e

against existing programs which manage them. Adequate aging management can be accomplished by any one or a combination of existing programs, establishment of new programs, revisions to existing programs, one-time inspections, analytical techniques or replacement.

If existing programs are used, the applicant would present a correlation of the aging effects to the existing programs at a program level and a description of the basis for the conclusion that aging is being adequately managed. Under the first principle oflicense renewal, existing programs should be deemed adequate unless the aging effect is found to be new or significantly different in the period of extended operation. If a new aging effect or significant change to an existing aging effect is identified, then a new program or enhancement to an existing program is necessary.

He demonstration required by Section 54.21(a)(3) is provided by the correlation of the aging effects to the existing program and the description of the basis for the conclusion that aging is being adequately managed. He level of detail that needs to be provided in the application would depend on the degree ofregulatory oversight. Where the existing program is based on a current regulatory requirement, a specific current licensing basis commitment, or otherwise is subject to detailed regulatory oversight (e.g., the subject of a Staff Safety Evaluation Report), a detailed description would not be needed. For new or modified programs, or other programs initiated by the applicant and not previously subject to NRC staff review, a more detailed description ofits effectiveness would be required.

In summary, the elements of a demonstration that should be described in the license renewal application include the identification of the component or structure, identification of the fur a description of the environment, the applicable aging effects, the existing program credited,.ud a discussion of the link betw the existing program and thwther elements.

A discussion of each element is provided below. An example is provided as Enclosure I.

A.

Component / Structure Identification The rule language is fairly straight forward; however, the rule also allows for the use of commodity groups. Ifcommodity groups are utili=A it is not necessary to identify each component or structure in the group. Rather, a description of the characteristic that apply to the commodity group abould be provided.

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B.

Intended Function i

Intended function is defined as the function that causes the component or structure to be included l

in the scope of the rule. While the rule is also clear that the aging management review is performed at the structure and component level, initial scoping is conducted at the system level.

In this regard, system level functions are identified. The intended function may be the same as i

the system level function or it may be a function that supports the system level function.

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C.

Aging Effects The license renewal rule also requires the identification of the aging effects that need to be managed in the period of extended operation. The application does not have to identify the aging effects that were considered but dispositioned as not applicable. Onsite documentation identifies i

those effects / mechanisms considered and their disposition. It is also true that aging mechanisms must be known in order to identify the aging effects. However, mechanisms are not required to i

be discussed or identified in the license renewal application.

D.

Pronrams i

Programs that manage aging are in place for var 5s reasons. One method to characterize existing programs is with a scale which measures the amount of NRC direction to initiate the program. At the high end are those programs mandated by regulation (e.g. the EQ program per 50.49). Less directed programs are the result ofgeneric correspondence which requests the implementation of a program (e.g. Generic Letter 89-13 which deals with degradation ofservice j

water piping and heat exchangers). Even less directed are those programs that the industry initiated and implemented proactively, either on a plant specific basis or with an industry wide program such as the EPRI water chemistry guidelines and erosion-corrosion programs. He lowest level are those programs that individual utilities have implemented to address problems at their plant which resulted from aging of structures and components (e.g. inspection of river water pumps because ofcavitation).

i He term " programs" as used for purposes oflicense renewal includes n' broad range of activities, from formal programs to procedures to specific work orders. Formal programs are typically characterized by a governing document which describes the history and purpose of the program, i

and how it is implemented. Formal programs typically have reporting requirements that allow management to review the results of the program. Less formally, procedures are used to achieve the same results as a formal program. When the scope of the " program"is not extensive, it may be more appropriate to implement the " program" with a procedure that describes the purpose and implements the necessary actions. Th use of a procedure as a " program"can bejust as effective as implementing a formal program. The least formal approach to a " program" occurs when a plant decides that the appropriate implementation of a " program"is through specific work orders.

He implementation details will be unique to the plant, but generally are characterized by one or more work orders that are performed at a specified frequency and include the information needed

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to perform the required work, analyze the results, and initiate corrective actions if needed. The work orders will include information as to the reason for the work order, including the initiating event. For example, a utility's response to Generic 89-13," Service Water System Problems Affecting Safety-Related Equipment," may have included a commitment to perform UT wall thickness measurements on piping to determine if general corrosion is causing loss of wall thickness. The utility may have elected to implement these examinations with a series of work order activities which are automatically issued at the required frequency, without having a formal 1

program that describes the work to be performed.

E.

The Link The " link"is the correlation that shows how the program manages a spe-ific aging efect. A program may manage more than one effect, but the application must show that the program is linked to each of the aging efects. It may also be necessary to show the link between a specific part of a program and the effect of concern. As an example, the applicant's in-service inspection program addresses many different types of aging for various components. The link will be to the appropriate part of the in-service inspection program. A reference to the in-service inspection program as the aging management program does not show the link. What is needed in the application to demonstrate this link depends on how closely the aging management program is tied to the aging effect.

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The link for a program such as the EQ program is both simple and direct. Licensees established EQ program to comply with 10 C.F.R. i 50.49 which requires that electrical equipment must be qualified to operate under accident conditions when considering the effects ofvarious stressors.

EQ programs exist specifically, and clearly, to manage the effects of aging due to exposure to elevated temperatures, humidity and radiation.

For programs that are unique to a power plant, the description of the link will be more extensive.

The link will have to describe how the program prevents, mitigates, or detects the aging effect so that the intended function will be maintained.

F.

Other Considerations 1.

Regulatory Oversight:

Regulatory oversight is a key element of the first principal oflicense renewal,providing and maintaining an acceptable level of safety. Regulatory oversight is the Commission's process that includes research, inspections, audits, investigations, evaluation ofoperating experience, and regulatory actions to resolve identified issues. When evaluating the acceptability of an aging management program, the amount ofregulatory oversight abould be considered in mag the demonstration forlicense renewal I.

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Operating Experiets,

The operating experience that exists for an aging management program can vary greatly, depending both on the age of the aging management program, and on the operating history of the equipment associated with the aging management program.

Some aging management programs have been in existence since initial operation of the plant, l

and there is an extensive amount ofinformation about the equipment, its operating and maintenance history, and changes that may have been made to operations and maintenance because ofproblems with the equipment. The infonnation derived from an aging management program that has been in existence for a long time will vary, depending on equipment performance. A review of operating experience for equipment that has operated well will show that there has been little, if any, degradation of the equipment, meaning that the aging management programs in place have been effective at preventing or mitigating the effects of aging. In some cases, the absence of degradation may be due to a good design that resulted in a combination ofmaterial, environment and stressors. For this equipment, there will be no need for an aging management program.

He opposite extreme is equipment that has significant amount ofproblems caused by rapid degradation of structures and components. A review of the operating history of this equipment may reveal that aging management programs were in place that detected the degradation and were successful at correcting the aging before loss of function occurred, or the review may reveal that the function of the equipment was lost before the degradation was detected. In the latter case, the corrective action program will have caused improvements in the aging management program so that future degradation will be detected before the equipment function is impacted again. Any of these scenarios are examples of aging management programs that have been i

effective at managing aging in the past, and should manage aging in the future.

A key aspect of the different types of operating experience as described above is that in all three, the oversight process, whether it be the licensee's oversight process or the Commission's oversight process, has been successful at maintaining function, or at detecting and restoring the lost function. De history ofmost plants will include examples of all three scenarios For other aging management programs, there may be little, or no, opern'dng experience. An aging management program may have been initiated only a short time before the submittal of a license renewal application. His could be because there has not been any degradation of the equipment, and the program was only newly instituted as a precautionary measure by the licensee to provide additional assurance that the equipment was not degr. ding. Other aging management programs could be recently instituted because aging was discovered at the plant, or at another plant, and there is little if any information because the aging management program has only recently been putin place.

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An aging management program which is well understood by the NRC, is clearly tied to the aging effect, and for which there is extensive operating experience will require only a very brief discussion in the license renewal application. "Brief"in this context is not a one or two sentence discussion. Sufficient information must be provided so that the link is clear. A program that has received very httle attention by the NRC, that contributes to the management of the effect of aging on a secondary level, and for which there is little information validating the effectivenen of the prograrn will require a much more extensive discussion explaining how the program will manage the effect of aging such that the intended function will be maintained. These two cases are at opposite extremes of the range of the level of detail needed in the application to make the demonstration.

Other programs that fall between these two extremes will require a level of detail in the application that is adequate to allow a reviewer to conclude that the aging management program provides reasonable assurance that the effects of aging will be adequately managed.

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Demonstration Example

" Service Water System Problems Affecting Safety-Related Equipment (Generic Letter 89-13)"

This is an example of a program or programs implemented as a result of commitments made in response to Generic Letter 89-13. In the industry's approach to making the demonstration for license renewal, these programs are adequate aging management programs requiring mini==1 description in the applications. The basis for this conclusion is that the programs are in place and the regulatory oversight process ensures they will continue into the renewal period. The conclusion is also based on specific actions identified in the generic letter.

While the Generic Letter covers the entire service water system, this example focuses on a specific commodity group - heat exchangers.

Overview of Generic Letter 89-13 The NRC issued Generic f,etter 89-13 July 18,1989 to require licensees andapplicants to supply information abon:t Hlr respective service water systems to assure the NRC ofsuch compliance andto corgf that the safetyfunctions oftheir respective service water systems are be!ng met. Specifically '. a letter recommended the following actions:

I. Implement and maintain an ongoing program of surveillance and control techniques to significantly reduce the incidence of flow blockage problems as a result of biofouling.

II. Conduct a test program to verify the heat transfer capability of all safety related heat exchangers cooled by service water.

III. Establish a routine inspection and maintenance program that ensures erosion, corrosion, protective coating failure, silting, and biofouling cannot degrade the performance of the safety-related systems supplied by service water.

IV. Confirm that the service water system will perform its intended function in wider,cc with the licensing basis of the plant.

V. Confirm that maintenance practices, operat'ng and emergency procedures, and training i

that involves the service water system are adequate to ensure that safety-related equipment cooled by the service water system will function as intended and that operators of this equipment will perform effectively.

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All the recommend actions in the Generic Letter touch on heat exchangers. However, Action II is specifically focused on heat exchangers. Action II is implementing a test program to verify the heat transfer capability of all safety-related heat exchangers cooled by service water. The j

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" Operating experience andstudies indicate that closed-cycle service water systems, such as component cooling water systems, have thepotentialfor signifcantfouling as a consequence ofaging-relatedin-leakage anderosion or corrosion. "

He Letter then goes on to discuss a program acceptable to the NRC for heat exchanger testing.

The first element of the NRC's program is scope - all safety-related heat exchangen.

Next the program discusses initial baseline testing.

As apart ofthe initial testprogram, a licensee or app!! cant may decide to take corrective action before testing. Tests shouldbeperformedfor the heat exchangers after the corrective actions are taken to establish baseline dataforfuture monitoring ofheat exchangerperformance Then the program outlines expectations for the continuing program for periodic retesting.

in implementing the continuingprogramforperiodic retesting ofsafety-relatedheat

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exchangers cooled by service water in open cycle systems, the Inillalfrequency oftesting should be at least once eachfuel cycle, but after three tests, licensees andapplicarits shoulddetermine the bestfrequencyfor testing toprovide assurance that the equipment willperform the intendedsafetyfunctions during the intervals bet.nen tests andmeet the requirements ofGDC 44, 45, and 46. The minimumpnal testingfre:uency should be once every5 years.

As in the Inillal testprogram, tests should be repeated afer any corrective actions are taken to establish baseline dataforfuture monitoring ofheat exchangerperformance.

The parameters that need to be monitored are also identified. These include, cooling water flow and inlet and outlet temperatures during the modes of operation in which cooling water is flowing through the heat exchanger. For each measurement, the licensee is to verify that the cooling water tempems and flows are within design limits. These results are trended to ensure that flow blockage or excessive fouling accumulation does not exist.

In summary, the Generic Letter identifies the aging ofconcern (age-related in-leakage, fouling, erosion, and corrosion), and discusses a progmm for dealing with that aging. De program as described in the Generic letter, has many of the attributes of an aging management program.

The scope is well defined (all safety-related heat exchangers). The program includes monitored parameters, trending, and timely corrective action with a confirmation process.

Attachment I is a flow diagram showing the relationship of the Generic letter to the license i

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-I renewal demonstration. Attachment 2 is a draA section of a license renewal application.

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Scope - A11 Sofety Related Heat Exchangers i

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NRC REQUIREMENT WHAT WHY HOW 33 "I N ** * **" 'I i

8 GenericIAtter 3913 Verify Heat Transfer Ann capability esingelewd Wege and NRC deseN la E l

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Heat Exchangers LICENSE RENEWAL APPLICA110N EXE1EER Service Water Comoonent Subject to Aoine Mananement Review All safety related heat exchangers in the service water system Intended Function Heat transfer capability Acine E6ects Loss ofheat transfer Acine Mananement Prorram :

The NRC issued Generic Letter 89-13 July 18,1989 to require licensees andapplicants to supply information about their respective service wattr systems to assure the NRC ofsuch compliance and to confirm that the safetyfunctions oftheir respective service water systems are being met. Action II in the generic letter is a recommendation to conduct a test program to verify the heat transfer capability of all safety related heat exchangers cooled by service water.

A testing program acceptable to the NRC is also discussed in the Generic Letter. As documented in our response to the generic letter, PLANT X has implemented such a program.

Cooling water flows and temperatures are monitored and evaluated to ensure they are within.

design limits. Corrective actions are initiated if necessary. The parameters are also trended to ensure that flow blockage or excessive fouling accumulation does not exist. Also, NRC conducted an inspection to verify the actions committed to in our response to the generic letter.

4 The testing program provides reasonable assurance that the heat exchangers will perform their intended function, in accordance with the current licensing basis, in the period of extended OPeratiott

' ne description of the aging management program should be consistent with the licensees response to the Generic 14tter. De examples is not intended to suggest that a licensee that credits their Generic letter 89-13 progran would write the renown! application exactly in this way.

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TYPICAL EXISTING CURRENT LICENSING BASIS PROGRAMS 1

This appendix is a typical listing of current licensing basis programs that the industry believes most renewal applicants will credit for renewal. 'Ibese programs also have a regulatory foundation, are subject to inspection and enforcement and, manage aging in the current operating term. Therefore, to the extent they are described in the renewal application, they should receive minimal review.

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l TYPICAL EXISTING CURRENT LICENSING BASIS PROGRAMS i

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Program orActMty

1. Battery RackIssgetions Improved Technical Specifications (ITS)- SR 3.8.1.3, SR 3.8.3.2, and i

SR 3.10.1.10

2. Boric Acid Wastage Surveillance Commitment to GL 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components 3.

Chemistry ControlProgma Commitments to EPRI Water Chemistry Documents,1735.5.14, ASTM D975, Standard Specification for Diesel Fuel Oils 4.

Coatings Program Commitment to RG 1.54, Quality Assurance Requirements for Protective Costings Applied to Water-Cooled Nuclear Power Plants 5.

Containmentinservice issgsion 10 CFR $50.55a ASME Code,Section XI, Subsections IWE, IWL 6.

Containment Leak Rate Test Program 10 CFR 50, Appendix J and ITS 3.6.1 and 5.5.2.

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Control Rod Drive Mechanism Nozzle Commitment to GL 97 01, Degradation of Control Rod Drive and Other Vessel Closure Penetrations Mechanism Nozzle and Other Vessel head Closure Penetrations Inspection Program 8.

Crane inspection Program 29 CFR XVil, (1910.179, Occupational Safety and Health Administration, Overhead and Gantry Cranes 9.

EnvironmentalQualification 10 CFR 50.49

10. FERC Five YearInsistice 18 CFR Part 12, Subpart D, Safety of Water Power projects and Project Works

11. Fire Protection Program 10 CFR 550.48 10 CFR 50, Appendix R

12. Heat Exchanger Performance Testing Commitmentin response to OL 89-13, Service Water System Problems Affecting Safety-Related Esluipment

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v;w Inspsive Plan 10 CFR 550.55a ASME Code Section XI, Subsections IWB, IWC,IWF.

14. Isspwtion Program for Civil Engineerug 10 CFR $50.65 Structures and Components *

(NEi 46 03 Industry Guideline for Monitoring the Condition of Stmetures atNuclearPowerPlants) t i

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• TYPICAL EXISTING CURRENT LICENSING BASIS PROGRAMS Existing RegulatoryBasis Program orActMty I

15. Piping Erosion /Co..wlon Program Commitment in response to BL 87 01, Thinning of Pipe Walls in 3

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Commitment in response to GL 89 08, Erosion /Conosion Induced Pip; i

WallThinning

16. Program to !=g+ ' the High.i=+=.

Commitment in response to GL 85-20, Resolution of Generic issue 69:

Iglection Connections to the RCS High Pisasure Iq)ection/Make up Nozzle Cracking in hwand 3

Wilcox Plants; j

BL 88-08, Thermal Stresses in Piping Connected to the Reactor Coolant System

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-u 10 CFR 50, Appi. dix B

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20. Service WaterPiping Corrosion Commitment in inyonse to GL 89-13, Service Water System Problems j

Affecting Safety Related Equipment

21. Steam Generator Tube Surveillance

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22. System Performance Testing Commitment in response to GL 89 13, Service Water System Problems Affecting Safety Related Equipment l

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