ML20205S154
| ML20205S154 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1999 |
| From: | Charemagne Grimes NRC (Affiliation Not Assigned) |
| To: | Walters D NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT & |
| References | |
| PROJECT-690 NUDOCS 9904260118 | |
| Download: ML20205S154 (7) | |
Text
77 April 20,1999
,o Mr. Douglas J; Walters
, Nuclear Energy Institute 1776 i Street, NW, Suite 400 Washington, DC 20006-3708
)
SUBJECT:
LICENSE RENEWAL ISSUE No. 98-0012, CONSUMABLES C'sar Mr. Walters:
Attached is the staff's evaluation and proposed resolution for the subject issue. The draft
" Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plant" (SRP-LR) will be revised to reflect this position, as applicable. Accordingly, if there are any industry comments on the evaluations or the proposed resolution, we request that you
- document those comments within 30 days following your receipt of this letter, to ensure a timely resolution of these issues. We also expect that NEl 95-10, " Industry Guideline for Implementing l
. the Requirements of 10 CFR Part 54 - The License Renewal Rule " be revised to include the necessary guidance to implement the attached staff position. If you have any questions l
regarding this matter, please contact Robert Prato at 301-415-1147.
Sincerely, 1
W By l
Christopher 1. Grimes, Chief I//
l License Renewal & Standardization Branch I
l Division of Reactor improvement Programs l
Office of Nuclear Reactor Regulation l
Enclosure:
As stated cc w/ enclosure: See next page DISTRIBUTION:
Note: The attachment to this letter reflects S. Coiiins changes that resulted from a License PUBLIC oo Renewal Steenng CommHtee meeung held Propect 090 Docket File
- 9 9 $ 3 on March 25,1999, and additional changes RLSB RIF '
following a management meeting on 4/1599 N. Dudley, ACRS - T2E26 to discuss steff concems related to the E-Ma11: See next page reliance on condition monitoring in item D.
DOCUMENT NAME:G:WVORKING\\PRATO\\LLP lSS\\lL980012.WPD
NAME H Wang
- R Prato
- R Wessman
- T Marsh
- J Moore
- C GrimaC D MatMFws 0
DATE. l 2/19/99 2/19/99 1/11/99-1/14/99 3/4/99 4/15/99 4/4 /99 OFFICIAL RECORD COPY PDR REV0P ERONUPWtC
, -o W
% nu esTm COPY Nha&
)
4
)
i E-mail:
)
R. Zimmerman W. Kane D. Matthews k
S. Newberry I
C. Grimes I
C. Carpenter B. Zaleman J. Strosnider R. Wessman t
E. Imbro W. Bateman J. Calvo -
H. Brammer T. Hiltz G. Holahan T. Collins C. Gratton B. Boger R. Correia R. Latta J. Moore J, Rutberg R. Weisman M. Zobler 1
M. Mayfield S. Bahadur A. Murphy
- D. Martin W. McDowell S. Droggitis RLSB Staff G. Tracy A. Thadani C. Julian C
U
(*
NUCLEAR ENERGY INSTITUTE l
(License Renewal Steering Comm.ttee) l Project No. 690 cc:
i i
Mr. Dennis Harrison Mr. Robert Gill I
U.S. Department of Energy Duke Energy Corporation NE-42 Mail Stop EC-12R Washington, D.C. 20585 P.O. Box 1006 Charlotte, NC 28201-1006 l
Mr. Ricard P. Sedano, Commissioner Mr. Charles R. Pierce l
State Liaison Officer Southern Nuclear Operating Co.
Department cf Public Service 40 inverness Center Parkway 112 State 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 Calvert Cliffs Parkway Washington, DC 20006 Lusby, Maryland 20657-47027 DJW@NEl.ORG National Whistleblower 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.
l Arkansas Nuclear One 1448 SR 333 GSB-2E Russellville, Arkansas 72802 l
1
n LICENSE RENEWAL ISSUE NO. 98-0012 CONSUMABLES 1.
BACKGROUND in a letter dated July 15,1998, the Nuclear Energy Institute (NEI) requested clarification on the need to include consumables within the scope of components requiring an aging management review (AMR). Consumables are typically replaced during routine maintenance and testing, or based on component performance. Additional guidance would be helpful in assisting applicants in determining whether consumables require an aging management review.
2.
EVALUATION The Statements of Consideration (SOC) (60 FR 22464) states the following:
[T]he first principle [of license renewal states that), with the possible exception of the detrimental effects of aging on the functionality of certain plant systems, structures, and components in the period of extended operation and possibly a few other issues related to safety only during extended operation, the regulatory process is adequate to ensure that the licensing bases of all currently operating plants provides and maintains an acceptable level of safety so that operation will not be inimical to public health and safety or common defense and security.
)
The second and equally important principle of license renewal holds that the plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the originallicensing term....
The Commission still believes that mitigation of the detrimental effects of aging resulting from operation beyond the initial license term should be the focus for license renewal. After further consideration and experience in implementing the previous rule, the Commission has, however, determined that the requirements for carrying out the license renewal review can and should be simplified and clarified. The 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 of safety in the period of extended operation.
A.
Packina. Gaskets. Comoonent Seals. and 0-rinas The systems, structures, and components (SSCs) within the scope of license renewal are set by 10 CFR 54.4(a), and inc!ude (1) safety-related SSCs, (2) nonsafety-related SSCs whose failure could prevent satisfactory accomplishment of functions of safety-related SSCs, as defined in Part 54, (3) SSCs relied on in safety analyses or plant evaluations to perform functions that demonstrate compliance with certain Commission regulations. In particular,10 CFR 54.4(a)(1)(i) defines as safety related those SSCs relied upon to remain functional during and following design-basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut dcwn the reactor and to maintain it in a m
j shutdown condition, or the capability to prevent or mitigate the consequences of accidents.
'e Pecking, gaskets, seals, and O-rings are typically not required by the current licensing i
bases to fulfill any of these functions. More specifically, as stated in ASME, Section 111, NB 2121, NC 2121, and ND 2121, packing, gaskets, seals and O-rings are not relied upon for a l
pressure retaining function in components for which these Code design practices apply. In addition, these components usually do not serve any other function defined in section 54.4(a), nor could their failure prevent satisfactory accomplishment of any such function, except for those components that are explicitly included in the renewal scope because they are subject to environmental qualification as described under section 54.4(a)(3).
1 Applicants can exclude packing, gaskets, seals, and O-rings where there is a clear basis for concluding that such components are not relied upon for a system, structure, or component to perform its intended function (s) under Part 54, like that described above. However, there may be other circumstances, such as seals en ventilation systems that provide a primary radiological barrier, seals that ensure the pressure envelope of the control room and structural sealants described under Section 2.8 below, where the component may be passive, long-lived and necessary for the system to perform its intended function. In these cases, the NRC would expect such components to be included in the scope of the renewal reviev B.
Structural Sealants Structural sealants (as opposed to the seals discussed under Section 2.A of this evaluation) that are within the scope of the rule typically meet the requirements under 10 CFR 54.21(a)(1)(i) and (a)(1)(ii), and therefore, require an aging management review. Structural sealants are often required for containment and structural integrity of safety related structures, and perform these functions without moving parts or change in configuration or properties. These sealants are typically not replaced based on qualified life or specified time period, are often relied upon for decades of service, are subject to aging, and therefore, should not be classified as consumables for the purpose of renewal scoping.
C.
Oil. Grease. and Comoonent Filtgrg in general, oil, grease, and component filters (as distinguished from system filters discussed in Section 2.D below) are short-lived with periodic replacement required by the manufacturer for warranty purposes and equipment reliability. Oil and grease replacement is an integral part of a typical plant preventive maintenance program, as is replacement of air filters, oil filters and filters for other fluids. Accordingly, oils, greases, and component filters which are covered by routine maintenance activities would be considered as components that are replaced based on a specified time period.
D.
System Filters. Fire Extinauishers. Fire Hoses. and Air Packs As a result of the staff's experience with the implementation of the license renewal rule, the staff has found that system filters, fire extinguishers, fire hoses, and air packs may be excluded, on a plant-specific basis, from an aging management review under 10 CFR 54.21(a)(1)(ii).
2-
i j
System filters, fire extinguishers, fire hoses, and air packs are typically monitored routinely e
and replaced based on measured degradation in performance or condition replacement criteria specified in applicable codes, technical specifications, or site-approved programs and procedures ensuring that each component will maintain its intended function. In the Statements of Consideration for 10 CFR Part 54, the Commission stated that it had decided not to generically exclude structures and components that are replaced based on performance or condition monitoring from an aging management review. 60 FR 22478.
However, in doing so, the Commission indicated that it did not intend to preclude an applicant from providing a site-specific justification in its license renewal application for excluding structures or components that are replaced based on performance or condition monitoring from an AMR. /d.
System filters, fire hoses, fire extinguishers, and air packs should be excluded from an aging management review based on performance and condition monitoring activities for these components that clearly establish a routine replacement practice based on a qualified component life. Excluding these components would result in a more efficient review, but should be clearly documented to avoid any misunderstanding. Therefore, an applicant may exclude system filters, fire hoses, fire extinguishers, and air packs (within the scope of license renewal) that are replaced based on specific performance and condition monitoring activities, as described below, provided that the applicant (1) lists in its license renewal application (LRA) the components so excluded and (2) states in its LRA that the components excluded are replaced according to appropriate standards, e.g., those set fcrth in this evaluation.
Examples of monitoring programs that provide a justifiable basis for such a replacement practice include charcoal and other types of system filters that are periodically replaced based on a differential system pressure test. An applicant having performance monitoring programs that routinely monitor and trend differential pressure across such filters and require replacement based on differential pressure criteria that provide a well-established performance criteria for periodic replacement may exclude filters subject to these programs from an aging management review under 10 CFR 54.21(a)(1)(ii).
The National Fire Protection Association (NFPA) standards in NFPA 10 (for fire i
extinguishers) and NFPA 1962 (for fire hoses) require performance and condition monitoring for fire extinguishers and hoses, respectively. The performance and condition monitoring programs for fire extinguishers and fire hoses include routine inspection for wear and damage, and periodic hydrostatic testing. Components that do not meet stringent condition and hydrostatic testing requirements must be replaced under the code. Similarly, the NFPA standards in NFPA 1981 and 42 CFR Part 84 require performance and condition monitoring for air packs. These performance and condition monitoring activities for air packs include routine inspection for wear and damage, and periodic hydrostatic testing. Air packs are subject to replacement if they do not meet the condition and performance criteria set forth in these standards. Applicants having performance and condition monitoring programs that require periodic inspection for wear and damage and hydrostatic testing of fire hoses, fire extinguishers, and air packs, and that require replacement based on indications of wear and damage or failure to meet hydrostatic requirements prior to loss of intended function, pursuant to the NFPA standards identified above and 42 CFR Part 84, may exclude fire extinguishers, fire hoses, and air packs subject to these programs from an aging management review under 10 CFR 54.21(a)(1)(ii).
3-
o a
e On the basis of the performance and condition monitoring activities implemented under the standards and regulations described above, an applicant may propose on a plant-specific basis that system filters, fire extinguishers, fire hoses, and air packs are readily monitorable, components subject to replacement based on qualified life even though their functions are passive.
Based on this evaluation, the staff will consider system filters, fire extinguishers, fire hoses, and air packs as being appropriately excluded from an aging management review under 10 CFR 54.21(a)(1)(ii), subject to a plant-specific condition monitoring replacement program, providec usat the applicant (1) identifies each component type subject to such replacement (system filter type, fire extinguisher, fire hose, air pack, etc.) in the application, and (2) identifies the applicable programs that conform to appropriate standards (e.g., for fire protection components - applicable NFPA standards and 42 CFR Part 84). This guidance was specifically developed for system filters, fire extinguishers, fire hoses, and air packs.
j 3.
RESOLUTION The staff recommends that applicants include specific provisions for the consumables discussed above (packing, gaskets, component seals, o-rings, system filters, fire extinguishers, fire hoses, air packs, oil, grease and component filters) in their scoping and screening procedures for license renewal so that the determinations regarding whether such components are either outside the scope of the license renewal rule or are replaced based on qualified life or specified time period will be clearly auditable. Structural sealants i
that are within the scope of the rule are generally considered passive, long-lived structural components would be expected to require an aging management review.
]
Consumables that are replaced based on a qualified life or specified time period without reference to performance or condition monitoring need not be identified in a renewal application nor listed as requiring an aging management review. An applicant seeking to exclude system filters, fire hoses, fire extinguishers, air packs, or other components from an aging management review based on monitoring and replacement activities, as discussed above, should identify, in the application, the component types so excluded and describe in the application the plant-specific programs justifying such exclusion.
The NRC recommends that the guidance for scoping and screening consumables in NEl 95-10 be augmented to reflect the guidance described above. The NRC will add complementary guidance into the Standard Review Plan for License Renewal after any comments on this guidance are resolved.