NUREG-1800, Proprosed Revision of Chapters II & III of Generic Aging Lessons (Gall) Report on Aging Management of Concrete Elements
| ML013300440 | |
| Person / Time | |
|---|---|
| Site: | PROJ0690 |
| Issue date: | 11/23/2001 |
| From: | Charemagne Grimes NRC/NRR/DRIP/RLSB |
| To: | Lochbaum D, Alexis Nelson Nuclear Energy Institute, Union of Concerned Scientists |
| Kang P, NRR-RLSB, 415-2279 | |
| References | |
| +KBR1SISP20050608, NUREG-1800, NUREG-1801 | |
| Download: ML013300440 (6) | |
Text
November 23, 2001 Mr. Alan Nelson Mr. David Lochbaum Nuclear Energy Institute Union of Concerned Scientists 1776 I Street, NW., Suite 400 1707 H Street, NW Washington, DC 20006-3708 Suite 600 Washington, DC 20006-3919
SUBJECT:
PROPOSED REVISION OF CHAPTERS II AND III OF GENERIC AGING LESSONS LEARNED (GALL) REPORT ON AGING MANAGEMENT OF CONCRETE ELEMENTS
Dear Messrs. Nelson and Lochbaum:
The purpose of this letter is to provide you with the opportunity to comment on the proposed revision of Chapters II (Containment) and III (Structures) of the GALL report. The need for the proposed clarification on concrete in these GALL chapters was discussed with the Nuclear Energy Institute (NEI) during the lessons learned meeting on the license renewal demonstration project held on October 11, 2001. This issue is listed as item No. 3.9 in the letter to Alan Nelson of NEI, from Christopher Grimes of NRC, dated October 3, 2001. This process is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry as outlined in NRR Office Letter No. 805, License Renewal Application Review Process.
The staff has revised sections of Chapters II and III of the GALL report and a brief description of the basis for the clarification and its changes is provided in Enclosure 1. Since the proposed changes also affect other parts of the guidance documents, all pertinent changes in Chapters II and III of GALL Volume 2 and Table 5 of GALL Volume1 (NUREG-1801), and Table 3.5-1 of Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) have been included as Enclosure 2.
We are requesting your comments on the proposed markup, and we request that you submit comments within 45 days following the date of this letter to ensure a timely resolution of this issue. The staff plans on incorporating this position into the improved renewal guidance documents in a future update. If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690
Enclosures:
As stated cc w/encl: See next page Mr. Alan Nelson Washington, DC 20006-3708 Nuclear Energy Institute 1776 I Street, NW., Suite 400
Mr. David Lochbaum Union of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919
SUBJECT:
PROPOSED REVISION OF CHAPTERS II AND III OF GENERIC AGING LESSONS LEARNED (GALL) REPORT ON AGING MANAGEMENT OF CONCRETE ELEMENTS
Dear Messrs. Nelson and Lochbaum:
The purpose of this letter is to provide you with the opportunity to comment on the proposed revision of Chapters II (Containment) and III (Structures) of the GALL report. The need for the proposed clarification on concrete in these GALL chapters was discussed with the Nuclear Energy Institute (NEI) during the lessons learned meeting on the license renewal demonstration project held on October 11, 2001. This issue is listed as item No. 3.9 in the letter to Alan Nelson of NEI, from Christopher Grimes of NRC, dated October 3, 2001. This process is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry as outlined in NRR Office Letter No. 805, License Renewal Application Review Process.
The staff has revised sections of Chapters II and III of the GALL report and a brief description of the basis for the clarification and its changes is provided in Enclosure 1. Since the proposed changes also affect other parts of the guidance documents, all pertinent changes in Chapters II and III of GALL Volume 2 and Table 5 of GALL Volume1 (NUREG-1801), and Table 3.5-1 of Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) have been included as Enclosure 2.
We are requesting your comments on the proposed markup, and we request that you submit comments within 45 days following the date of this letter to ensure a timely resolution of this issue. The staff plans on incorporating this position into the improved renewal guidance documents in a future update. If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.
Sincerely,
/RA/
Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690
Enclosures:
As stated cc w/encl: See next page Distribution: See next page DOCUMENT NAME:C:\Program Files\Adobe\Acrobat 4.0\PDF Output\GALL CC lessons learned.wpd OFFICE RLSB LA (A)RLSB:SC NAME Pkang EHylton J Nakoski DATE 11/20/01 11/20/01 11/20/01 OFFICE DE:D RLSB:BC NAME JStrosnider CGrimes DATE 11/21/01 11/23/01 OFFICIAL RECORD COPY
DISTRIBUTION: Package: ML013300426 HARD COPY RLSB RF E. Hylton E-MAIL:
PUBLIC J. Johnson W. Borchardt D. Matthews C. Carpenter C. Grimes B. Zalcman J. Strosnider (RidsNrrDe)
F. Eltawila G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski S. Rosenberg G. Holahan B. Boger D. Thatcher G. Galletti B. Thomas J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis N. Dudley RLSB Staff A. Thadani R. Zimmerman C. Julian R. Gardner D. Chyu M. Modes J. Vora
NUCLEAR ENERGY INSTITUTE Project No. 690 cc:
Mr. Joe Bartell Mr. Robert Gill 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 Mr. Richard P. Sedano, Commissioner State Liaison Officer Mr. Charles R. Pierce Department of Public Service Southern Nuclear Operating Co.
112 State Street 40 Inverness Center Parkway Drawer 20 BIN B064 Montipelier, Vermont 05620-2601 Birmingham, AL 35242 Mr. Stephen T. Hale Mr. Paul Gunter Florida Power & Light Company Director of the Reactor Watchdog Project 9760 S.W. 344 Street Nuclear Information & Resource Service Florida City, Florida 33035 1424 16th Street, NW, Suite 404 Washington, DC 20036 Mr. William Corbin Virginia Electric & Power Company Hugh Jackson Innsbrook Technical Center Public Citizen's Critical Mass Energy &
5000 Dominion Boulevard Environment Program Glen Allen, Virginia 23060 215 Pennsylvania Ave. SE Washington DC 20003 Mr. Frederick W. Polaski Manager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348
Description of the Basis for the Clarification and Changes for Concrete Elements (Item No. 3.9 in a letter to NEI dated October 3, 2001)
Basis:
The staff position is that aging of concrete elements of the containment and other Class 1 structures should be managed. Contrary to this position, the staff observed during review of the Nuclear Energy Institute (NEI) license renewal demonstration project that the participants misinterpreted the staffs license renewal guidance on this issue and determined that there were no aging effects requiring management for concrete elements for the above structures. The reasons for the misinterpretation were that: (1) applicable aging management programs (AMPs) for concrete elements in the current Generic Aging Lessons Learned (GALL) report were not clearly stated and (2) some inconsistencies were found between Chapters II and III of the GALL report for the concrete elements. During the review, all participants agreed that each AMP should be divided into accessible and inaccessible areas that are addressed separately. The staff agreed that applicable AMPs for degradation of concrete should be clarified in the GALL report and the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) of the improved renewal guidance documents.
Changes:
Under the Aging Management Program (AMP), column for concrete elements in the containment and Class 1 structures in Chapter II of the GALL report, the staff replaced the current AMP with a new AMP that addresses accessible and inaccessible areas separately based on: (1) the inspection for accessible areas would be required to be performed in accordance with ASME section XI, Subsection IWL under the requirements of 10 CFR 50.55a (existing mandated program) and (2) a plant-specific aging management program is required for inaccessible areas if the below grade environment is found to be aggressive or exposed to flowing water. Therefore, with the existing mandated program, the plant-specific AMP for concrete elements in the containment and Class 1 structures is only required to address inaccessible areas. For Chapter III, the staff again replaced the current AMP with a new AMP that addresses accessible and inaccessible areas separately.
The inspection for accessible areas would be required in accordance with a Structural Monitoring Program based on the requirement of 10 CFR 50.65 (Maintenance Rule), while a similar plant-specific program would be required for inaccessible areas by closely following the Chapter II example.
The staff chose not to change the answer in the Further Evaluation column of the GALL report, but has clarified when further evaluation is required following the Yes or No response. The staff has determined this was an efficient and effective method for updating the license renewal guidance documents.
Enclosure 1