ML20254A055

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NRC-2018-000831 - Resp 5 - Interim, Agency Records Subject to the Request Are Enclosed, Part 2 of 2
ML20254A055
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Issue date: 09/01/2020
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FOIA, NRC-2018-000831
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Text

From: Brady Bennett To: Py rtscher. Pat Cc: Oesterle, Eric

Subject:

MDLR comments on PNLL"s Guidelines for Harvesting Materia ls for SLR Date: Tuesday, March 20, 201 8 5:19:23 PM Attachments: DM LR Specific Comments on PNNL-27120.docx DMLR General Comments on PNNL -22120.docx Pat Following your request, I asked eight of our technical review staff to review and provide comments on PNNL's technical letter report on harvesting materials. Attached are general comments on the report and specific comments that I have compiled in redline/strikeout version of the report itself. Some of the comments are repetitious of comments made by other reviews. I have tried to group similar comments together. When you have had a chance to review them, please see me if you have any questions. I will try to answer your questions or get you to the right reviewer.

In spite of the rather negative comments on this report, we continue to believe that the Materials Harvesting Project will be in valuable in the future as the NRC deals with aging plants and needs an organized approach for selecting materials for harvesting withe the increased availability of sources.

Bennett Bennett M. Brady Senior Project Manager Division of License Renewal Office of Nuclear Reactor Regulation 0 11 - 08 301 -415-2981 Note to requester: Both attachments to this email are fo llowing this email message. Following the attach ments are records from the technical reviewers as mentioned in this email message. The FOIA Office received some of these as stand-alone records , with no forward ing emails. We are providing them to you as we received them . The 3/20/2018 email, its attachments, and the additional records address the fifth bullet in your 5/19/2020 letter.

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-271 20 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Dcvanathan K Knobbs RM Meyer December 2017 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement withWith the U.S. Department of Energy Contract DE-AC05-76RLO 1830 Pacific Northwest National Laboratory Richland, Washington 99352

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Pacific Northwest y

NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

Note to requester: The yellow highlighted portions was in the version of this document provided to the FOIA team.

GENERAL COMMENT

S ON PNNL-271 20

  • In a meeting with the Director of DMLR, George Wilson, he recommended that the information or criteria for harvesting to be captured on the sample to be harvested include an estimate of the cost of the material, including the cost of shipping it from the source to the research facility and the cost of storing the sample for later use.
  • He also suggested that priority be given in the following order to:

o Domestic sources o International sources where the research would be done in collaboration with other research organizations (such as the Haldon Reactor projects) with the results and cost to be shared o Other international sources

  • This report is very misleading about the need for and impact of data from harvesting efforts. In particular, this report cites the following:

I This statement is flat wrong. The issuance of the GALL-SLR and the (b)(5il SRP-SLR reports provides!(b)(5) !without any additional information from harvesting. And , SLR could proceed without any information from harvesting in the future.

o The roles/benefits of data from harvested materials are:

  • The potential to reduce margins if the data from harvested materials indicate such a possibility.
  • The form, function, and characteristics of the "information tools" in section 5 should be reconsidered by NRC staff, both RES and NRR. The description provided is very ambitious and may not have clear benefits to either harvesting activities or plant regulation.
  • From the UNR, NRR was expecting the project to provide a database of potential components with specific materials and potential sources of components and guidance on determining the selection of materials to be harvested. Section 5 appears to go beyond that which may be difficult in times of reduced budgets and staff.
  • The report (or follow-on work) could provide a substantial benefit by identifying harvesting efforts over the last 30 plus years, not just those since 2010. Such a review will greatly aid in the technical "lessons learned" from past harvesting 1

efforts and help to identify those areas with true holes in harvested data in a comprehensive manner.

  • The word "gap" is overused in the report - 63 times.
  • Consider a different word choice instead of "techn ical gap" which has a pejorative connotation of no knowledge or no basis for regulatory decisions.
  • Many statements of "fact" are presented without attribution - these should have references to support them. As an exam le, there should be a reference cited in (b )(5) Section3.4.4 item6 which state (b )(5)

(b )(5) in the second h of section 3.4.1 the statement (b)(5) . . . . . . . . . . . . . . . . . . . . . . . . . . . J;::;:;:;;;;==========~~~==--.-.. . . . .

(b)(5)

---.-------_J y a re erence.

  • The phrase "real-world" should be replaced with more accurate terminology - for example, "in-service cond itions," "service aging," or "operating reactor service time," depending on the context. Otherwise it implies that current guidance is not based on relevant data/knowledge.
  • Pa e 3, 2 nd full para raph - Text states that (b)(5)

(b)(5) This is incorrect as the GALL/GALL-SLR reports are predominantly based on lessons learned from plant operating experience and review of license renewal applications. Note that the first GALL report (Rev . 0) was issued in 2000 and PMDA was not issued until 2007. It would be correct to state that!(b)(5) I

!(b)(5) !This context should be added to other places in the report as well.

  • The NRR technical staff did a review of the five volumes of EMDA and noted any new issues or component types of materials that were not in GALL 2. These items were all viewed by the expert panels and dispositioned as to whether they should be included in GALL-SLR. They did no review the PMDA as the EMDA authors had reviewed the PMDA tables and updated them in the EMDA.
  • Harvesting components is GREAT and getting more data/information is a nice to have. But there are places in the report that seem to indicate/imply that without this information from harvesting that going into SLR is a concern. I am not sure this is the correct messaging, considering the NRC just issued the GALL-SLR and SRP-SLR.
  • Throughout the report, the tone seems to be that harvesting activities NEED to be performed otherwise failure of components will lead to unsafe operation of plants. I disagree with this notion - the whole premise of aging management is to inspect/manage so that issues are detected before they happen or early 2

enough before there is a loss of intended function of a component. The inspection/aging management is normally commensurate with how much we know about the material and degradation. For example - If we know less - there should be more inspections. If we know more -inspections may not need to be as frequent.

  • The report is full of statements that could lead a reader to believe that we have an inadequate basis for the GALL-SLR Report and by extension, we should not be issuing renewed licenses for plants in the ! +timeframe*.. . . l. .am.c.onfi.d.e nt (b)(5) that this is not the authors' intent. The report either needs to be significantly toned down in regard to knowledge gaps or we need to include the basis for why we are moving forward with SLR in light of knowledge gaps.
  • I get what the authors are trying to state. However, if I was an intervener, I would use this document to shutdown SLRAs. I did not see any "robust" text in the report that tempered the words or put them into a context that we are confident in the means of managing aging effects for the four classes of SSCs of concern (e.g., concrete, cables). For example, this statement: ! I, . . _J~)_@

(b )(5)

(b )(5) ~~t: IIt this is our basis to) why the GALL-SLR Report is adequate, it's pretty weak compared to the below underlined sentences. Further, the same paragraph goes on to state, I - - - ~ _________ . .J~)(?.L (b )(5)

(b )(5) I

  • Big picture, I think that the entire report needs to be scrubbed for text that points to gaps and if issued we need a stronger basis for why we will grant renewed licenses before the harvesting and testing is completed.
  • In the Abstract, the author states:

(b)(5)

How did we issue the GALL-SLR Report with technical gaps and how are we going to be able to issue a renewed license if there are technical gaps to reaching a reasonable assurance conclusion?

  • On page 2, the second full paragraph, the author states 3

(b)(5)

H....

For the first underlined sentence, does this mean that we won't have ...b).._(5_).,_ __.

(b)(5) In that case, how can we issue a renewed license for (b)(5) years before the testing is completed? Will we generate license conditions to restrict how far into the SPEO a licensee can operate before the testing is complete? This statement is too broad. For the second underlined sentence, should I infer that the (b)(5)

(b)(5)

  • The next paragraph says (b)(5)

Similar comment to the above, are these knowledge gaps addressed in the applicable GALL-SLR AMPs, with compensatory measures in place?

  • The first paragraph in section 3.3 page 5 states:

(b)(5) 4

This provides another good example of the report stating that we lack sufficient information to understand failure mechanisms.

  • The GALL report is the NRC staff's generic evaluation of the acceptable aging management for the period of extended operation based on the technical basis developed in the EMDA and PMDA.

I do not believe that the EMDA and PMDA present the complete technical basis for the GALL-SLR report. We issued an entire NUREG 2221 which provides the complete technical bases for the technical bases for all the changes that were made in the GALL 2 and SRP Revision 2. Before beginning the revision of the GALL and SRP, the NRR staff reviewed the EMDA reports to see if there were any new issues that needed to be addressed for SLR. The staff did not review the PMDA as the EMDA was an update and expansion of the PMDA and the PMDA only addressed operation to 60 years.

(b )(5) * . . .TabJ~J . 81~r.ow. GALL~SLR,!...._* _ _ _ _ _ _ _ __.

(b)(5) *. . . .l TabJe. 2 .*.8~~ row, I GALL~SLR,j...__

(b)(5)

  • What data would be sought from the harvested material and how would it be used to inform aging management? An example could be cast austenitic stainless steel (CASS) from RV internals. The data sought are fracture toughness of CASS material subject to both irradiation and thermal aging at the same time. The use of this data could be to perform flaw evaluations if cracks are ever found in CASS components, or flaw tolerance evaluations to determine the appropriate interval for inspections, or to avoid inspection altogether.
  • Are there any mitigating factors for the degradation mechanism? For example, for CASS in RV intemals, maybe fracture toughness is not so important since CASS is known to be very resistant to stress corrosion cracking initiation. Without an active cracking mechanism, fracture toughness data are less important. So this would tend to lower the priority of harvesting CASS from RV internals.
  • The report doesn't always do an adequate job of distinguishing between age-related degradation mechanisms, failure mechanisms, and intended functions. In addition, after reading some of the statements in the PNNL report, I come away with the impression the report sets the tone that, if the RES/PNNL recommended harvesting and supplemental testing activities are performed, the results of those activities would be (by themselves) sufficient to ensure reasonable assurance of component structural integrity intended functions. Instead, the results of such studies only provide additional insights into how a given age-related degradations mechanisms is occurring and progressing, and possibly how a component would fail. The harvesting activities and supplement studies (by themselves) would not constitute a sufficient basis for drawing conclusions on reasonable assurance of 5

component structural integrity or component intended function(s). That would need to be done by each licensee as part of its design and licensing basis.

  • One thing to note is that the report refers back to the Office of Research's (RES)

PMDA and EMDA studies for SLR, in which RES made recommendations on some of the areas NRR/DLR (before we turned into DMLR) would need to focus on when going through its GALL-SLR (NUREG-2191) and SRP-SLR (NUREG-2192) update efforts. When we started our efforts in late 2014 to perform the updated guidance reviews, we were instructed by our management team to review the EMDA recommended actions to see if we agreed with the actions RES was recommending. From a historical perspective, it is important to point that the staff did not always agree with the RES's PMDA / EMDA recommended actions for updating the GALL-SLR and SRP-SLR reports. For your knowledge, the Technical Basis Report for the SLR updates provides the technical bases for the changes we incorporated into NUREG-2191 and NUREG-2192, NUREG-2221 and NUREG-2222 from the prior versions of the reports (NUREG-1801, Revision 2 and NUREG-1800, Revision 2).

6

Note to requester: The yellow highlighted portions was in the version of this document provided Harvesting Report Comments (A. Hiser) to the FO IA team .

General

1. This report is very misleading about the need for and im act of data from harvesting efforts. In particular, this report cites the following: (!J)(5)

(b)(5)

(b )(5)

      • * ** * * * * * * * * * * * * * * * * * * *J ---======~~======----.----------___J

- this statement is flat wrong. The

'-i-ss_u_a_n-c e- of- t- he_ G_A_L-L--S-L_R_a_n_d_t-he_ S_R_P-

-S- L_R__.reports provides I J.(b)(5) without any additional information from harvesting. And, SLR could proceed without any information from harvesting in the future.

a. The roles/benefits of data from harvested materials are:
i. Confirmation of the current GALL-SLR approaches for aging management.

ii. The potential to reduce margins if the data from harvested materials indicate such a possibility.

2. The form, function and characteristics of the "information tools" in section 5 should be reconsidered by NRC staff, both RES and NRR. The description provided is very ambitious and may not have clear benefits to either harvesting activities or plant regulation .
3. The report (or follow-on work) could provide a substantial benefit by identifying harvesting efforts over the last 30+ years, not just those since 2010. Such a review will greatly aid in the technical "lessons learned" from past harvesting efforts and help to identify those areas with true holes in harvested data in a comprehensive manner.
4. The word "gap" is overused in the report - see comment 1 above.
5. Many statements of "fact" are presented without attribution - these should have references to support them. As an exam le, there should be a reference cited in bullet 6 (b)(5) . . . . . . . . Q[Section 3.4.4, which . states........

(b )(5) imilarly in the second

~~~~~~~:.:...!...!....~~~~-------.-.....=::====~==......J (b)(5)

(b)(5) *************************************************************t;;;;;;;;;;:.;:;:::=::=;.___ _ _ _ _ _ _ _ _ _ _ _ ____J should be supported by a reference.

6. The phrase "real-world" should be replaced with more accurate terminology - for example, "in-service conditions," "service aging," or "operating reactor service time,"

depending on the context. Otherwise it implies that current guidance is not based on relevant data/knowledge.

7. Consider a different word choice instead of "techn ical gap", which has a pejorative connotation of no knowledge or no basis for regulatory decisions.

Specific Comments

1. See the attached file for specific comments and questions in the report - I apologize that many of the comments may require interpretation .

2 . Page 3, 2nd full paragraph - Text states tha .......... ... ( b)(5)

(b )(5) b...=...===;;;;;;;;;;;;;;;;;;=::=::.:.:.::__ _ _ _ _ _ _ __1This is incorrect as the GALL/GALL-SLR reports are predominantly based on lessons learned from plant operating experience and review of license renewal applications. Note that the first

GALL report (Rev . 0) was issued in 2000 and PMDA was not issued until 2007. It would (b)(5) be correctJostateJ hat . .

(b)(5) l I This context s-h-ou_l_d_b_e_a_d_d-ed-to_o_t_h_e_rp-1-ac_e_s_i_n-th-e-re_p_o_rt_a_s_w_e_ll_. - -

PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal December 2017 P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer U.S. DEPARTM ENT OF ENERGY

DISCLAIMER This report was pre1>ared as an account of work sponsored by tm agency of the Unitcd States Govenunent. Neither tlic United States Govenunent nor any agency tlicreof, nor Battelle Memorial Institute, nor any of their employees, makes :my warranty, ex1,ress or im1>lied, 01* assumes any legal liabilit~* or res1,onsibility for the accuracy, com11tete11ess, or usefulness of any information, ap1rnratus, fH'Oduct, or 1>roccss disclosed, or represents that its use wou ld not infringe fHivately owned rights. Reference herein to any specific commercial product.

process. or service by trade name. trademark. manufacturer. orotlicrwisc does not necessarily constitute or imply its endorsement, recommendation, or favoring by tlic United States Govenuncnt or any agency thereof. or Bauellc Memorial Institute. The views and opinions of autlmrs expressed herein do 1101 1iccessarily state or rcnect those of the United States Government or any agency thereof.

PACIFIC NORTHWEST NATIONAL LABORATORY opemtedby BATI'ELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contrnct DE-AC05-76Rl0/830 P,i_ntt'd In thr Unlt"d Slnh*t of 1\nll'rll'll Anllahlt to l>OE ~nd DOE c-ontrnctors from tht Offl<'t> of 8'-l<'nl Inf 1,nd TC'dml<<-111 lnfonnutlon, P.0. llo< 62, Oak Rid~<. TN 37831-0062; ph: (865) 576-8al01

'",: (865) 576-5728 t int1U: rtpor1~/wadonis..ostl.ao,*

1-\\'1dl11bl<' IO the publk from the National l'NhnJrul Information S"1,ice 5301 S hawuce- Rel., A le1andria, VA 22312 ph: (1100) !l.'\l, NTIS (68-17) tmall: ortlr1':!I" nll"l.g o, < hccp:/1\\*ww.nlls.gov/o bo ut/f'onn.n.!Jpl>

Online ordt1i 11i: hllp:Jh,*ww.nfl~.a:ov

@ 11us docwncnl was printed on n,'Cycled paper.

(8f.2010)

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer December 2017 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy Contract DE-AC05-76RLOl 830 Pacific Northwest National Laboratory Richland, Washington 99352

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NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

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Criteria and Planning Guidance for E -Plant Harvesting to Sup ort Subsequent License Renewal December 2017 P Ramuhalli SW Glass R Oevanathan K Knobbs RM Meyer U.S. DEPARTMENT OF ENERGY

DISCLAIMER This report was prepared as an accowt of wod'. sponsored by an agency of the United States Government. Neither the United States Govemmentoorany agency thereof, uor Battelle Memorial I.mtitute, nor any of their eq,loyees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or uaefulness of any iaformatioa, apparatus, product, or process dillclo8ed, or represents that its use would not infringe privately owned rigbts. Reference herein to any specific coDDDCtcial product, process, or service by trade name, trademadc, mamfacturer, orotrerwise does uot necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof, or Battelle Memorial Imtitute. The views and opioiom ofauthors expressed herein do not necessarily state or Jd1ect those of the United States Govermnent or any agency thereof.

PACIFIC NOR1HWEST NATIONAL LABORATORY operated by BATI'ELLE for the UNITFD STATES DEPARTMENT OF ENERGY under Contract DE-AC05-76RL01830 Prlnteil In the United SCates o f ~

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Note to requester: The document provided to the FOIA staff also included PNNL-27120 skipped numbers before page 1. There are no missing pages.

Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Devanathan KKnobbs RM Meyer December 2017 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy Contract DE-AC05-76RL0I 830 Pacific Northwest National Laboratory Richland, Washington 99352

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PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal December 2017 P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer U.S. DEPARTM ENT OF ENERGY

DISCLAIMER This report was pre1>ared as an account of work sponsored by tm agency of the Unitcd States Govenunent. Neither tlic United States Govenunent nor any agency tlicreof, nor Battelle Memorial Institute, nor any of their employees, makes :my warranty, ex1,ress or im1>lied, 01* assumes any legal liabilit~* or res1,onsibility for the accuracy, com11tete11ess, or usefulness of any information, ap1rnratus, fH'Oduct, or 1>roccss disclosed, or represents that its use wou ld not infringe fHivately owned rights. Reference herein to any specific commercial product.

process. or service by trade name. trademark. manufacturer. orotlicrwisc does not necessarily constitute or imply its endorsement, recommendation, or favoring by tlic United States Govenuncnt or any agency thereof. or Bauellc Memorial Institute. The views and opinions of autlmrs expressed herein do 1101 1iccessarily state or rcnect those of the United States Government or any agency thereof.

PACIFIC NORTHWEST NATIONAL LABORATORY opemtedby BATI'ELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contrnct DE-AC05-76Rl0/830 P,i_ntt'd In thr Unlt"d Slnh*t of 1\nll'rll'll Anllahlt to l>OE ~nd DOE c-ontrnctors from tht Offl<'t> of 8'-l<'nl Inf 1,nd TC'dml<<-111 lnfonnutlon, P.0. llo< 62, Oak Rid~<. TN 37831-0062; ph: (865) 576-8al01

'",: (865) 576-5728 t int1U: rtpor1~/wadonis..ostl.ao,*

1-\\'1dl11bl<' IO the publk from the National l'NhnJrul Information S"1,ice 5301 S hawuce- Rel., A le1andria, VA 22312 ph: (1100) !l.'\l, NTIS (68-17) tmall: ortlr1':!I" nll"l.g o, < hccp:/1\\*ww.nlls.gov/o bo ut/f'onn.n.!Jpl>

Online ordt1i 11i: hllp:Jh,*ww.nfl~.a:ov

@ 11us docwncnl was printed on n,'Cycled paper.

(8f.2010)

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer December 20 17 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy Contract DE-AC05-76RLOl 830 Pacific Northwest National Laboratory Richland, Washington 99352

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Pacific Northwest y

NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal December 2017 P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer U.S. DEPARTM ENT OF ENERGY

DISCLAIMER This report was pre1>ared as an account of work sponsored by tm agency of the Unitcd States Govenunent. Neither tlic United States Govenunent nor any agency tlicreof, nor Battelle Memorial Institute, nor any of their employees, makes :my warranty, ex1,ress or im1>lied, 01* assumes any legal liabilit~* or res1,onsibility for the accuracy, com11tete11ess, or usefulness of any information, ap1rnratus, fH'Oduct, or 1>roccss disclosed, or represents that its use wou ld not infringe fHivately owned rights. Reference herein to any specific commercial product.

process. or service by trade name. trademark. manufacturer. orotlicrwisc does not necessarily constitute or imply its endorsement, recommendation, or favoring by tlic United States Govenuncnt or any agency thereof. or Bauellc Memorial Institute. The views and opinions of autlmrs expressed herein do 1101 1iccessarily state or rcnect those of the United States Government or any agency thereof.

PACIFIC NORTHWEST NATIONAL LABORATORY opemtedby BATI'ELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contrnct DE-AC05-76Rl0/830 P,i_ntt'd In thr Unlt"d Slnh*t of 1\nll'rll'll Anllahlt to l>OE ~nd DOE c-ontrnctors from tht Offl<'t> of 8'-l<'nl Inf 1,nd TC'dml<<-111 lnfonnutlon, P.0. llo< 62, Oak Rid~<. TN 37831-0062; ph: (865) 576-8al01

'",: (865) 576-5728 t int1U: rtpor1~/wadonis..ostl.ao,*

1-\\'1dl11bl<' IO the publk from the National l'NhnJrul Information S"1,ice 5301 S hawuce- Rel., A le1andria, VA 22312 ph: (1100) !l.'\l, NTIS (68-17) tmall: ortlr1':!I" nll"l.g o, < hccp:/1\\*ww.nlls.gov/o bo ut/f'onn.n.!Jpl>

Online ordt1i 11i: hllp:Jh,*ww.nfl~.a:ov

@ 11us docwncnl was printed on n,'Cycled paper.

(8f.2010)

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-271 20 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer December 201 7 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy Contract DE-AC05-76RLOl 830 Pacific Northwest National Laboratory Richland, Washington 99352

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Pacific Northwest y

NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

I have comments on the following paragraphs. My comments are in bold italics and I underlined specific portions of the excerpt that I am commenting on. I stopped commenting on these specific examples after the first four (I have other comments as shown below).

I get what the authors are trying to state. However, if I was an intervener, I would use this document to shutdown SLRAs. I did not see any "robust" text in the following pages that tempered the following words or put them into a context that we are confident in the means of managing aging effects for the four classes of SSCs of concern e .. concrete cables . For (b)(5) ......~.x.~m Je,Jhisstatement...

(b )(5)

If this is our basis for why the GALL-SLR Report is adequate, it's pretty weak compared to the below underlined sentences. Further, the same paragraph goes on to state.I ((~)(?)

(b )(5)

(b)(5)

I I

Big picture, I think that the entire report needs to be scrubbed for text that points to gaps and if issued we need a stronger basis for why we will grant renewed licenses before the harvesting and testing is completed.

(b)(5)

(b )(5) ....___________,I How did we issue the GALL-SLR Report with technical gaps and how are we going to be able to issue a renewed license if there are technical gaps to reaching a reasonable assurance conclusion?

(b)(5)

(b )(5) *t;:::=..e,_L.t:S:u:..tlle.Imil.Ll..flfj!ecJ!Uli~WWlJ~LI!a.eUW*~ mean that we won't have ,._(b __)__

(5__) _ __.

In that case, how can we issue a

~r==e=-=n=-=e~w":"::e:-:rir:":,c::"":e=-=n=-=s=-=e--r=o'='r~~-,::"':"e=o:a=-=r==s-.::-:e:""Zo=-r==e=--n:=-=e~e-=s~mg is completed? Will we generate license conditions to restrict how far into the SPEO a licensee can operate before the testing is complete? This statement is too broad. For the second underlined sentence, should I infer that thg(b)(5) I

!(b)(5)

(b)(5) .__ _________ _.ISimilar comment to the above, are these knowledge gaps addressed in the applicable GALL-SLR AMPs, with compensatory measures in place?

(b)(5)

(b)(5)

(b)(5) _____....II don't have any new comments for this one; I included it because it's another good example of the report stating that we lack sufficient information to understand failure mechanisms.

Additional comments not related to the above :

The GALL report is the NRC staff's generic evaluation of the acceptable aging management for the period of extended operation based on the technical basis developed in the EMDA and PMDA. I do not believe that the EMDA and PMDA present the complete technical basis for the GALL-SLR report. We issued an entire NUREG with the technical basis. None of the changes I generated to GALL-SLR Chapter V VII and VIII are based on the above cited documents .

(b)(5) . . . Table 1.. 8'h. row; GALL-SLRJ * *

'.=========~----------,

(b)(5)

(b)(5) l~~~le2,8 ~row, GALL~SLR,I........_. - - - - - - - - - - - - - - - - - - - -

1

This record is responsive to the second sixth bullet point in your 5/19/2020 letter: the emails that Mr. Purtscher received from Mr.

Hiser.

From : Hiser, Matthew Sent: Mon, 27 Aug 2018 15:27:01 +0000 To: Purtscher, Patrick

Subject:

RE: TLR Update Hi Pat, I had also rewritten the first paragraph and deleted the last paragraph from the summary and path forward section (see screenshots below), so I'm definitely in agreement at a high level with where changes should be made.

(b)(5)

I'd suggest reworking the first sentence to avoid commenting on whether and how technical gaps are addressed by GALL-SLR. Here's my suggestion, which has some similarities to what I had in tracked changes on Friday. Feel free to take this below and pull from the couple sentences in the screenshot above if that would be useful.

(b )(5)

Thanks!

Matt Matthew Hiser Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I CotTosion and Metallurgy Branch Phone: 301-415-2454 I Office: TWFN JOD62 Matthew.Hiser@nrc.gov From : Purtscher, Patrick Sent: Monday, August 27, 2018 11:11 AM To: Hiser, M atthew <M atthew.H iser @nrc.gov>

Subject:

RE: TLR Updat e Matt, Can you could give me any comments you might have on these changes for the I ... . * * *

  • I ( ~)(?)

(b)(5)

  • * *l * ** I (b)(5)

(b)(5)

Pradeep originally had this for the first paragraph (b)(5)

I also think we should recommend the last paragraph shown below, be deleted.

(b)(5)

Pat

\

From: Hiser, M atthew Se nt: Friday, August 24, 2018 2:29 PM To: Purtscher, Patrick <Patrick.1Purtscher@nrc.gov>

Subject:

RE : TLR Update Hi Pat, Here's my edits and comments on the whole report. I went through pretty closely up through section 3.3, then mostly skimmed focusing on areas where NRR staff had major comments.

It's definitely a lot better, but needs a lot of cleaning up. I think we might need to iterate again with Pradeep and have him do a more thorough scrub before sending back to NRR.

Thanks!

Matt From: Hiser, Matthew Sent: Thursday, August 23, 2018 2:28 PM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

RE: TLR Update Hi Pat, OK, here's my fairly extensive editing of everything up to Ch. 2. I'll keep plugging on Ch. 3 and beyond tomorrow...

Thanks!

Matt From: Purtscher, Patrick Sent: Thursday, August 23, 2018 9:13 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update I still think "technical issue" would raise the same concern from NRR as "technical gap". It should be OK to use "technical gap" for pre-GALL-SLR documents, but not after that.

Pat From: Hiser, Matthew Sent: Thursday, August 23, 2018 8:37 AM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

RE: TLR Update Hi Pat, Yeah, I agree that the use of "gap" needs to be scaled back even more. In a few places I've been replacing "gap" with "issue."

I like what you've written - I think it's pretty similar to this text in the Abstract (my tracked changes marked there), but that may need to be pulled into the Intro section as well.

(b)(5)

I've started working through with a clean version of what Pradeep sent to make my suggested edits (attached). I'm hoping to get all the way through it today if possible and share with you.

Thanks!

Matt From : Purtscher, Patrick Sent: Thursday, August 23, 2018 8:02 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update

Matt, I was reviewing the document and was struck by the continued used of "gap" (90 times). The combination "technical gaps" is used 24 times. This does seem excessive and it would seem to be a good idea to find different words to use. I would suggest "topic" as a sub in many of these places, probably not all.

The main concern of the NRR reviewers is that the document makes SLR look like it is dependent on harvesting. Pradeep suggested in his response to one of the comments that "Perhaps there needs to be a context setting statement up front". I don't see that he has proposed anything in this draft, but I think that is true and we should provide a specific recommendation like "For many years now, harvesting and evaluation of ex-plant materials has been a critical part of the technical basis behind the regulatory framework used at the NRC, but the process was always limited by the availability of representative materials. Now with multiple plants announcing that they are or will be closing, many new potential opportunities will become available." I hope that by starting with this, we can reduce the concern of the NRR reviewers.

What do you think?

Pat Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I Corrosion and Metallurgy Branch 11545 Rockville Pike I Rockville, MD 20852-2738 Phone: 301-415-3942 I Office: TWFN 10A49 ptpl@nrc.gov From : Ramuhalli, Pradeep [1]

Sent: Friday, August 17, 2018 2:45 PM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>; Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

[External_Sender] TLR Updat e

The update so far is attached. This still needs some cleanup and citations included; I am working on a tech editor on these .

With best regards, Pradeep Note to requester: After searching Pradeep Ramuhal li, PhD further, the 8/17/2018 Email from PNNL Senior Research Scientist, to NRC staff with the subject line Applied Physics Group "[External_Sender] TLR Update" could Pacific Northwest National Laboratory not be located.

902 Battelle Blvd .

P.O.Box 999, MSIN K5-26 Richland, WA 99352 Tel: 509-375-2763 Email : pradeep.ramuhalli@pnnl.gov http ://www.pnnl .gov

This record is responsive to the second sixth bullet point in your 5/19/2020 letter: the emails that Mr. Purtscher received from Mr.

Hiser. The attachment to this email is following.

From : Hiser, Matthew Sent: Fri, 24 Aug 2018 18:29:22 +0000 To: Purtscher, Patrick

Subject:

RE: TLR Update Attachments: DMLR Specific Comments on PNNL-27120-pr mah 8-24.docx Hi Pat, Here's my edits and comments on the whole report. I went through pretty closely up through section 3.3, then mostly skimmed focusing on areas where NRR staff had major comments.

It's definitely a lot better, but needs a lot of cleaning up. I thin k we might need to iterate again with Pradeep and have him do a more thorough scrub before sending back to NRR.

Thanks!

Matt From : Hiser, Matthew Se nt: Thursday, August 23, 2018 2:28 PM To: Purtscher, Patrick <Patrick.1Purtscher@nrc.gov>

Subject:

RE: TLR Update Hi Pat, OK, here's my fairly extensive editing of everything up to Ch. 2. I'll keep plugging on Ch. 3 and beyond tomorrow...

Thanks!

Matt From : Purtscher, Patrick Se nt: Thursday, August 23, 2018 9:13 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update I still think "technical issue" would raise the same concern from NRR as "technical gap". It should be OK to use "technical gap" for pre-GALL-SLR documents, but not after that.

Pat From : Hiser, Matthew Sent: Thursday, August 23, 2018 8:37 AM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

RE: TLR Update

Hi Pat, Yeah, I agree that the use of "gap" needs to be scaled back even more. In a few places I've been replacing "gap" with "issue."

I like what you've written - I think it's pretty similar to this text in the Abstract (my tracked changes marked there), but that may need to be pulled into the Intro section as well.

(b)(5)

I've started working through w ith a clean version of what Pradeep sent to make my suggested edits (attached). I'm hoping to get all the way through it today if possible and share with you.

Thanks!

Matt From : Purtscher, Patrick Sent: Thursday, August 23, 2018 8:02 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update

Matt, I was reviewing the document and was struck by the continued used of "gap" (90 times). The combination "technical gaps" is used 24 times. This does seem excessive and it would seem to be a good idea to find different words to use. I would suggest "topic" as a sub in many of these places, probably not all.

The main concern of the NRR reviewers is that the document makes SLR look like it is dependent on harvesting. Pradeep suggested in his response to one of the comments that "Perhaps there needs to be a context setting statement up front". I don't see that he has proposed anything in this draft, but I think that is true and we should provide a specific recommendation like "For many years now, harvesting and evaluation of ex-plant materials has been a critical part of the tec hnical basis behind the regulatory framework used at the NRC , but the process was always limited by the availability of representative materials. Now wit h multiple plants announcing that they a re or will be closing, many new potential opportunities will become available." I hope that by starting w ith this, we can reduce the concern of the NRR reviewers.

What do you think?

Pat

Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I Corrosion and Metallurgy Branch 11545 Rockville Pike I Rockville, MD 20852-2738 Phone: 301-415-3942 I Office: TWFN 10A49 ptpl@nrc.gov From : Ramuhalli, Pradeep [2]

Sent: Friday, August 17, 2018 2:45 PM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>; Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

[External_Sender] TLR Update The update so far is attached. This still needs some cleanup and citations included; I am working on a tech editor on these.

With best regards, Pradeep Pradeep Ramuhalli, PhD Note to requester: After searching Senior Research Scientist, further, the 8/ 17/2018 Email from Applied Physics Group PNNL to NRC staff with the subject Pacific Northwest National Laboratory line "(External_Sender] TLR Update" 902 Battelle Blvd. could not be located.

P.O.Box 999, MSIN K5-26 Richland, WA 99352 Tel: 509-375-2763 Email: pradeep.ramuhalli@pnnl.gov http://www.pnnl.gov

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-271 20 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Dcvanathan K Knobbs RM Meyer December 2017 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement With the U.S. Department of Energy Contract DE-AC05-76RLO 1830 Pacific Northwest National Laboratory Richland, Washington 99352

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Pacific Northwest y

NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

This record is responsive to the second sixth bullet point in your 5/19/2020 letter: the emails that Mr. Purtscher received from Mr. Hiser. The attachment is following.

From : Hiser, Matthew Sent: Thu, 23 Aug 2018 18:28:17 +0000 To: Purtscher, Patrick

Subject:

RE: TLR Update Attachments: DMLR Specific Comments on PNNL-27120-pr mah 8-23.docx Hi Pat, OK, here's my fairly extensive editing of everything up to Ch. 2. I'll keep plugging on Ch. 3 and beyond tomorrow...

Thanks!

Matt From : Purtscher, Patrick Sent: Thursday, August 23, 2018 9:13 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update I still think "technical issue" would raise the same concern from NRR as "technical gap". It should be OK to use "technical gap" for pre-GALL-SLR documents, but not after that.

Pat From : Hiser, Matthew Sent: Thursday, August 23, 2018 8:37 AM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

RE: TLR Update Hi Pat, Yeah, I agree that the use of "gap" needs to be scaled back even more. In a few places I've been replacing "gap" with "issue."

I like what you've written - I think it's pretty similar to this text in the Abstract (my tracked changes marked there), but that may need to be pulled into the Intro section as well.

(b )(5)

I've started working through with a clean version of what Pradeep sent to make my suggested edits (attached). I'm hoping to get all the way through it today if possible and share with you.

Thanks!

Matt From : Purtscher, Patrick Sent: Thursday, August 23, 2018 8:02 AM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>

Subject:

RE: TLR Update

Matt, I was reviewing the document and was struck by the continued used of "gap" (90 times). The combination "technical gaps" is used 24 times. This does seem excessive and it would seem to be a good idea to find different words to use. I would suggest "topic" as a sub in many of these places, probably not all.

The main concern of the NRR reviewers is that the document makes SLR look like it is dependent on harvesting. Pradeep suggested in his response to one of the comments that "Perhaps there needs to be a context setting statement up front". I don't see that he has proposed anything in this draft, but I think that is true and we should provide a specific recommendation like "For many years now, harvesting and evaluation of ex-plant materials has been a critical part of the technical basis behind the regulatory framework used at the NRC, but the process was always limited by the availability of representative materials. Now with multiple plants announcing that they are or will be closing, many new potential opportunities will become available." I hope that by starting with this, we can reduce the concern of the NRR reviewers.

What do you think?

Pat Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I Corrosion and Metallurgy Branch 11545 Rockville Pike I Rockville, MD 20852-2738 Phone: 301-415-3942 I Office: TWFN 10A49 ptpl@nrc.gov From : Ramuhalli, Pradeep [3]

Sent: Friday, August 17, 2018 2:45 PM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>; Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

[External_Sender] TLR Updat e

The update so far is attached. This still needs some cleanup and citations included; I am working on a tech editor on these .

With best regards, Pradeep Pradeep Ramuhal li, PhD Senior Research Scientist, Note to requester: After searching Applied Physics Group further, the 8/ 17/2018 Email from PNNL Pacific Northwest National Laboratory to NRC staff with the subj ect line 902 Battelle Blvd . "[External_Sender] TLR Update" could P.O.Box 999, MSIN K5-26 not be located.

Richland, WA 99352 Tel: 509-375-2763 Email : pradeep.ramuhalli@pnnl.gov http ://www.pnnl .gov

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-271 20 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Dcvanathan K Knobbs RM Meyer December 2017 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement With the U.S. Department of Energy Contract DE-AC05-76RLO 1830 Pacific Northwest National Laboratory Richland, Washington 99352

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Pacific Northwest y

NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

This record is responsive to the second sixth bullet point in your 5/19/2020 letter: the emails that Mr. Purtscher received from Mr.

From : Hiser, M atthew Hiser. The attachment is Se nt: Thu, 23 Aug 2018 12:37:16 +0000 ,, .::.

To: Purtscher, Patrick

Subject:

RE: TLR Update Attachme nts: DMLR Specific Comments on PNNL-27120-pr mah.docx Hi Pat, Yeah, I agree that the use of "gap" needs to be scaled back even more. In a few places I've been replacing "gap" with "issue."

I like what you've written - I think it's pretty similar to this text in the Abstract (my tracked changes marked there), but that may need to be pulled into the Intro section as well.

(b)(5)

I've started working through with a clean version of what Pradeep sent to make my suggested edits (attached). I'm hoping to get all the way through it today if possible and share with you.

Thanks!

Matt From: Purtscher, Patrick Se nt: Thursday, August 23, 2018 8:02 AM To: Hiser, Matthew <Matthew.H iser@nrc.gov>

Subject:

RE : TLR Update

Matt, I was reviewing the document and was struck by the continued used of "gap" (90 times). The combination "technical gaps" is used 24 times. This does seem excessive and it would seem to be a good idea to find different words to use. I would suggest "topic" as a sub in many of these places, probably not all.

The main concern of the NRR reviewers is that the document makes SLR look like it is dependent on harvesting. Pradeep suggested in his response to one of the comments that "Perhaps there needs to be a context setting statement up front". I don't see that he has proposed anything in this draft, but I think that is true and we should provide a specific recommendation like "For many years now, harvesting and evaluation of ex-plant materials has been a c ritical part of the tec hnical basis behind the regulatory framework used at the N RC , but

the process was always limited by the availability of representative materials. Now wit h multiple plants announcing that they a re or will be closing, many new potential opportunities will become available." I hope that by starting with this, we can reduce the concern of the NRR reviewers.

What do you think?

Pat Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I Corrosion and Metallurgy Branch 11545 Rockville Pike I Rockville, MD 20852-2738 Phone: 301-415-3942 I Office: TWFN 10A49 ptpl@nrc.gov From : Ramuhalli, Pradeep [4]

Sent: Friday, August 17, 2018 2:45 PM To: Hiser, Matthew <Matthew.Hiser@nrc.gov>; Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

[External_Sender] TLR Update The update so far is attached. This still needs some cleanup and citations included; I am worki ng on a tech editor on these.

With best regards, Pradeep Pradeep Ramuhalli, PhD Note to requester: After searching Senior Research Scientist, further, the 8/17/2018 Email from Applied Physics Group PNNL to NRC staff with the subject Pacific Northwest National Laboratory line "[Extennal_Sender] TLR Update" 902 Battelle Blvd. could not be located.

P.O.Box 999, MSIN K5-26 Richland, WA 99352 Tel: 509-375-2763 Email: pradeep.ramuhalli@pnnl.gov http://www.pnnl.gov

Note to requester: The document provided to the FOIA staff also included skipped numbers before page 1. There are no missing pages.

PNNL-27120 Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal P Ramuhalli SW Glass R Dcvanathan K Knobbs RM Meyer December 20 17 Prepared for the U.S. Nuclear Regulatory Commission under a Related Services Agreement With the U.S. Department of Energy Contract DE-AC05-76RLO1830 Pacific Northwest National Laboratory Richland, Washington 99352

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NATIONAL LABORATORY l'roudly Operated b)' Ba1lele Since /965 902 Battelle Boulevard PO. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov Prepared for the U.S. Nuclear Regulatory Commission U . S. DEPARTMENT OF under a Related Services Agreement with the U.S. Department of Energy CONTRACT DE-ACOS-76RL01830 ENERGY

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