ML20206S376
| ML20206S376 | |
| Person / Time | |
|---|---|
| Issue date: | 08/24/1998 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-3120, NUDOCS 9905210110 | |
| Download: ML20206S376 (8) | |
Text
W8 ~ 3W CERTIFIED BY:
Date issued: 8/24/98 M. H. Fontana - 9/2/98 i
' ADVISORY COMMITTEE ON REACTOR SAFEGUARDS PLANT LICENSE RENEWAL SUBCOMMITTEE MEETING MINUTES JULY 16,1998 ROCKVILLE, MARYLAND The Advisory Committee on Reactor Safeguards (ACRS) Subcommittee on Plant License Renewal held a meeting on July 16,1998, in Room T-2 B3,11545 Rockville Pike, Rockville, Maryland, with representatives of the U.S. Nuclear Regulatory Commission (NRC). The i
purpose of this meeting was to hear presentations by and hold discussions with the NRC staff regarding the activities associated with license renewal, proposed staff's plans and schedule for reviewing the license renewal applications. The Subcommittee also discussed the ACRS involvement in reviewing the license renewal submittal and related matters. Dr. Medhat El-Zeftawy was the cognizant ACRS staff engineer for this meeting. The meeting was convened at 8:30 a.m. and adjoumed at 12:45 p.m.
l ATTENDEES ACRS M. Fontana, Chairman R. Seale, Member G. Apostolakis, Member W. Shack, Member D. Miller, Member R. Uhrig, Member D. Powers, Member M. El-Zeftawy, Staff NBC F. Miraglia, NRR C. Grimes, NRR S. Hoffman, NRR R. Prato, NRR P. Shemanski, NRR D. Thatcher, NRR C. Gratton, NRR J. Vora, RES OTHERS U
A. Carson, Bechtel J. Weil, McGraw Hill Q1O J. Dozier, NUS C. Negin, EPRI O.LOTq D. Staudinger, Winston & Strawn D. Walters, NEl M
4 No written comments or requests for time to make oral statements were received from members of the public. A list of attendees is available in the ACRS Office and will be made available upon request.
9905210110 900824
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\\ 1.s Plant Lice,nse Renewal July 16,1998
~ Subcommittee Meeting OPENING REMARKS BY THE SUBCOMMITTEE CHAIRMAN Dr. 'Mario Fontana, Chairman of the Plant License Renewal Subcommittee, convened the meeting at 8:30 a.m. and stated that the purpose of this meeting is to discuss the NRC's staff V
acthnties associated with hcense renewal, proposed staff's plans and schedule for reviewing the boense renewal appbcations, and related safety issues. The Subcommittee will also discuss the j
' ACRS involvement in reviewing the hconse renewal submittal and related matters. The Subcommittee will gather information, analyze relevant issues and facts, and formulate proposed positions and actions as appropnate for delibershon by the full Committee. Dr.
L Fontana stated that expenonce shows that interactions with the ACRS at appropriate times have led to a much smoother process and final agreement than has been the case in instances where the ACRS reviews were delayed until the very end.
NRC STAFF PRESENTATION Mr. Frank Miraglia, NRR, stated that pursuant to 10 CFR 50.51, licenses to operate nuclear power plants are issued by the NRC for a fixed period of time not to exceed 40 years.
However, these licenses may be renewed by the NRC for an additional period of up to 20 years before expiration of the current operating term. The revised license renewal rule,10 CFR 54, published on May 8,1995 and effective on June 7,1995, sets forth the requirements for the renewal of operating licenses for nuclear power plants.
The NRC Chairman tasked the Executive Council (EC) (Mr. L. Joseph Callan) to develop a plan to oversight and coordinate the license renewal activities. The Chairman stated that " In order for the NRC to be fully' prepared to renew the licenses of nuclear power plants, it is essential that the license renewal be addressed and implemented within a unified and coherent process.'
The EC has met several times with line NRR managers to discuss the best approach for EC oversight. The EC could contribute by focusing on three areas:
i Oversight - review of the license renewal process and periodic monitoring of implementation and early identification of implementation problems or policy issues.
j Coofdination - facilitating cross-office cooperation to ensure the best agency-wide contribution to achieving an effective and efficient license renewal process (e.g., IT support, training).
j Strategic implementation - identifying longer term issues which can affect desired outcomes and ability to efficiently and effectively implement the program in the future (e.g., resources, skill mix).
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i Tha EC involvement should reinforce the fundamental responsibility and accountability of NRR line management to effectively and efficiently implement the license renewal program.
In addition to the EC involvement, the Director of NRR has formed a license renewal Steering l Committee (LRSC) that consists of nine members, with Mr. Frank Miraglia as the Chairman.
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Plant License Renewal July 16,1998 Subcommittee Meeting
. The members of the LRSC have been selected to represent the principal functions associated with the processing of license renewal applications submitted pursuant to 10 CFR Parts 54 and 51! The LRSC will fulfill its responsibility in an advisory capacity to the Director of NRR in.
support of the line managers who are fundamentally responsible and accountable for the implemordation process.
NRR STAFF PRESENTATION Mr. Robert Prato stated that under 10 CFR Part 54, an applicant requesting an extension to an
. operating license for a commercial nuclear power plant beyond the original licensing term must submit a license renewal application (LRA). Each LRA must contain general information and conforming changes to standard indemnity agreements as specified under 10 CFR 54.19. An -
application must also contain an integrated plant assessment (IPA), changes to the current licensing basis (CLB) implemented during the LRA review process, evaluations of time-limited aging analysis (TLAA), evaluations of 10 CFR 50.12 plant-specific exemptions based on TLAA, and a final safety analysis report (FSAR) supplement that contains a summary description of the programs and activities for managing the effects of aging and the evaluation of TLAA for the penod of extended operation. Each application will also include technical specification changes and justifications necessary to manage the effects of aging, and a supplement to the environmental report that complies with the requirements under Subpart A of 10 CFR Part 51.
The NRR staff has developed a draft regulatory guide,'Standatd Format and Content for.
. Applications to Renew Nuclear Power Plant Operating Licenses (DG-1047)', a draft of a license renewal standard review plan," Standard Review Plan for the Review of License Renewal Applications for Nuclear Power Plants", and an environmental standard review
- plan," Environmental Standard Review Plan". DG-1047 proposes to endorse the industry ~
guidelines (NEl 95-10, Revision 0) for implementing the requirements of 10 CFR Part 54. The draft SRP contains guidance for the staff review of an LRA and other documents necessary to demonstrate compliance with the provisions of the license renewal rule. In addition the staff is developing a license renewal inspection program (LRIP) for the verification and inspection of documentation, programs, activities, and material condition of structures and components that are within the scope of the rule.
As a result of reviewing and inspecting LRA programs and activities, the staff is expected to j
identify technical and process concems, licensee commitments, and renewal licensing requirements. Technical and process concems will be documented, controlled, and tracked to resolution. The LRA review process has been estimated to be a 3-year process involving the technical and environmental reviews of an LRA, and the inspection and verification of site-specific programs and activities. The LRA reviews are performed by NRR headquarters and include the review of the IPA, the supplemental envirorimental report, changes to an applicant's CLB, T1.AAs, and the final safety evaluation report (SER) supplement that contains a summary description of the programs and activities for managing the effects of aging and the evaluation of TLAAs for the period of extended operation.
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i 3-Plant License Renewal July 16,1998.
Subcommittee Meetmg The staff identified 13 Generic lesues for the license renewal process. These issues are:
. Credit for existing programs-additional guidance is needed on the extent to which justificaten is required for existing programs and condition monitoring. The industry would prefer to limit the descriptions of the existing programs, which they believe could potentially expose the CLB, particularly requirements mandated by regulation, to unnecessary review and litigation, j
Demonstration Detail-additional guidance is needed for the content for demonstrating the adequacy of aging management programs pursuant to 10 CFR 54.21(a)(3) and the extent to which the adequacy of aging management can depend on staff review of onsite records rather than docketed information. This issue includes the extent to which surveillance data must be provided in the application to support the demonstration of adequacy for existing and new programs.
A related issue concerns the extent to which the adequacy of existing programs could be addressed by inspection rather than docketed information. The licensees would prefer very simple descriptions of the existing programs in the renewal applications, to the extent that the majority of the justification for the adequacy of the existing programs to manage aging effects would be reviewed onsite and rely on existing NRC inspection findings.
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Operating Experience-additional guidance is needed on the scope and details of operating experience that should be addressed to define the plausible aging effects.
L Component Failure & Intended System Functions-the industry would intend to define the scope of structures and components by maintaining system-level" intended function (s)"
by relying on the detection of failure of particular components in the system as a form of
' system maintenance or aging management. This approach seems inconsistent with the defense-in-depth design basis.
Plausible or Potential Aging Effects-in order to demonstrate that the effects of aging will be adequately managed for the period of extended operation, the applicant must describe all of the aging effects for the applicable components and structures and determine which of those effects are sufficiently plausible during the period of extended operation to warrant an aging management program. Additional guidance is needed for
. determining which aging effects are " plausible" during the period of extended operation.
Generic Safety issues-cnteria to be developed for the scope and level of GSis to be addressed in a renewal application, and the level of detail needed to justify excluding the i
.GSis from aging management.
Risk-informed License Renewal-the statements of consideration for the amendment to j
Part 54 describes how risk insights might be used to assess the importance of safety
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functions or the adequacy of aging management programs. Additional guidance is
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July 16,1998 Subcommittee Meeting needed on the use of risk insights to establish the need for or adequacy of aging.
management programs.
Component Lists-additional guidance is needed on the appropriate details needed for
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listing structures and components within the scope of the renewal review, particularly for commodity groups.
FSAR Content-because of variety in the form and content of existing FSARs, additional guidance is needed on the form and content and timing for information in the renewal application that must be included in the FSAR update.
TLAA Timing-. guidance on the general requirements for when TLAAs must be submitted for staff review, particularly for EQ. Many TLAAs will still be valid when the renewal application is submitted and the industry would like to have the option of
. postponing the analysis updates, including reliance on commitments and license conditions to perform the analysis updates using specified methods after issuance of the renewed license but prior to the expiration of the existing analysis.
Passive or Active Determinations-Part 54 defines " passive" for the purpose of the scope of structures and components subject to review for license renewal. Additional guidance is needed to clarify that definition as it relates to problematic components (for
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example, fuses and hydrogen recombiners).
- Consumables-some passive components include "consumables" parts which are replaced during routine maintenance and testing. For example, gaskets and other sealing materials. Additional guidance is needed to establish whether these parts should be included in the scope of the renewal review, to the extent that they are
- passive in nature and subject to aging effects, or excluded on the basis that they are
- replaceable" components as permitted by the rule.
. Degradation Induced by Human Error-aging effects are generally understood to be the result of material and chemical phenomena. However, damage can also result from human actions. Additional guidance is needed to clarify how degradation caused by human actions, particularly as it relates to operating experience, should be treated as a
- plausible aging effect requiring an aging management program.
Mr. C. ' Grimes, NRR, stated that efforts by the nuclear power industry to renew the operating licenses of commercial power plants have been underway for approximately ten years, with technical issues related to the cost-effective management of aging effects and regulatory acceptance of the associated aging management programs as areas of concem. In order to resolve as many of these technical issues as possible generically, the Electric Power Research institute (EPRI) and the U.S. Departmat of Energy (DOE) cooperated in the preparation and submittal of license renewal industry reports (irs). However,17 open generic technical issues remain unresolved from the irs, although resolution for many issues involves only finct documentation. These issues are:
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Plant License Renewal July 16,1998 c,
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= Fatigue of metal components L
Environmental qualification of low-voltage, in-containment cables Thermal embnttlement of cast mustenitic stainless steel components Irradiation-assisted stress corrosion cracking of reactor intomals
. Stress relaxation of pressurized water reactor intamals components
. Primary water stress corrosion cracking of high-nickel alloy components Stress corrosion cracking of PWR reactor coolant system components Degradation of Class 1 small bore piping
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- . i Neutron irradiation embrittlement of reactor vessel beltline materials Ultrasonic inspection of pressure vessels and components Visual examination of components and structures
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One-time inspections of concrete and steel structures.
Freeze-thaw damage in concrete containment structures Alkali-aggregate reactions in concrete containment structures Differential settlement in PWR containments and Class i structures Reinforcement corrosion in PWR containments Void swelling of reactorintemals Mr. Grimes stated that NRR on June 18,1998, issued an office' letter No. 805, " License Renewal Application Review P.ocess" to all NRR employees. The primary purpose of this letter is to document the license renewal application review process. The office letter contains a description of the basic steps, and the roles and responsibilities of the different staff organizations involved in the LRA review. This letter provides three main elements:
Guide for reviewing LRAs Guide for processing renewed license action items Guide for technical and process lessons leamed for license renewal The leEsons loamed will be used to revise the SRP-LR and DG-1047, revise existing technical positions, and enhance the LRIP, as applicable.
The' staff's priorities for license renewal are first the review of the Baltimore Gas and Electric (BG&E) Calvert Cliffs, and Duke Energy Corporation (Duke) Oconee, applications followed by the resolution of generic activities. Schedules have been established for the review of the applications. However, in parallel, with available resources, the staff intends to pursue resolution of generic issues with NEl.
As required under 10 CFR 54.25, each LRA is to be referred to the ACRS for review and report.
The associated SER will also be referred to the ACRS. For the Calvert Cliffs, the staff expects
- to receive the ACRS letter in February 2000, and for the Oconee plant in May 2000.
NRC Staff Commitments L
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Plant Licqnse Renewal July 16,1998 j
Subcommittee Meeting Crediting existing programs for managing aging of long-lived passive SCs Briefing the ACRS on the importance of some topical reports and technical issues
. Publishing the draft SRP-LR and the draft Regulatory Guide that endorses the NEl 95-
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. Providing the ACRS with any new developments regarding the requests for hearing and the consequences on the proposed review schedule SUBCOMMITTEE DISCUSSION AND FOLLOW-UP ACTIONS Should the' ACRS be proactive in reviewing the technical reports submitted by the
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industry? and to what extent?
Does the ACRS get involved in the cost-benefit argument supplied by the industry?
Does the ACRS get involved in the resolution of the 17 generic issues submitted by EPRI?.
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What should be the level of ACRS reviews regarding the identification of SCs subject to age management review (AMR)?
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How risk-informed regulation be used for license renewal reviews?
l What research activities are reeded regarding aging?
j What should be the involvement of other ACRS Subcommittees, e.g., Materials and Metallurgy?.
1 What information should be included in the ACRS reports?
Background material provided to the Subcommittee Standard Review Plan for the review of license renewal applications for nuclear power plants-NRC, Draft dated September 1997.
Calvert Cliffs Nuclear Power Plant (Units 1 and 2) License Renewal Application, Volumes 1 and 2,' dated April 1998.
Presentation Slides and Handouts Provided During the Subcommittee Meeting The presentation slides and handouts used during the meeting are available in the ACRS Office p files or as attachments to the meeting transcripts.
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- e Plant License Retnewal July 16,1998 Subcommittee Meeting NOTE:
Additional details of this meeting can be obtained from a transcript available in the NRC Public Document Room,2120 L Street, N.W., Washington, D.C. 20006, (202) 634-3274, or can be purchased from Ann Riley & Associates LTD.,1250 i Street, N.W., Suite 300, Washington, D.C. 20005, (202) 842-0034.
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