ML11356A317

New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000310, NRC Regulatory Issue Summary 2011-07 License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management

ML11356A317
Person / Time
Site:	Indian Point
Issue date:	07/21/2011
From:	Mcginty T Office of Nuclear Reactor Regulation
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML11356A300	List: ML11356A303 ML11356A305 ML11356A306 ML11356A307 ML11356A312 ML11356A317 RIS 2011-07, New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit Nys000310, NRC Regulatory Issue Summary 2011-07 License Renewal Submittal Information for Pressurized Water Reactor Internals Aging Management
References
RAS 21618, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 RIS-11-007
Download: ML11356A317 (8)

See also: RIS 2011-07

Text

NYS000310

Submitted: December 22, 2011

UNITED STATES

NUCLEAR REGULA TORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001

July 21, 2011

NRC REGULATORY ISSUE SUMMARY 2011-07

LICENSE RENEWAL SUBMITTAL INFORMATION FOR

PRESSURIZED WATER REACTOR INTERNALS AGING MANAGEMENT

ADDRESSEES

All holders of and applicants for a pressurized water power reactor operating license or

construction permit under Title 10 of the Code of Federal Regulations (10 CFR) Part 50,

"Domestic Licensing of Production and Utilization Facilities," except those that have

permanently ceased operations and have certified that fuel has been permanently removed

from the reactor vessel.

INTENT

The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)

to inform addressees of updated NRC procedures for license renewal application (LRA) reviews

or the review of certain licensee submittals related to commitments made in the process of

receiving a renewed license. LRAs for pressurized water reactor (PWR) plants have identified

that an aging management program (AMP) is needed to manage the effects of aging for reactor

vessel internal (RVI) components that are within the scope of license renewal, in accordance

with 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for Nuclear Power

Plants." This RIS requires no action or written response on the part of addressees. This RIS

also provides information to licensees with respect to how to meet their existing license renewal

commitments related to reactor vessel internals aging management programs, and on

acceptable changes to existing license renewal commitments in order to account for the recent

issue of the staff's final Safety Evaluation (SE) of MRP-227, Rev.O, and the forthcoming issue of

the approved version of MRP-227.

The purpose of this RIS is to facilitate a predictable and consistent method for reviewing the

AMPs of commercial PWR LRAs and the AMPs and inspection plans for PWR plants that have

received renewed operating licenses. This RIS does not transmit or imply any new or changed

requirements or staff positions. Although no specific action or written response is required, the

information contained in this RIS will enable licensees to plan effectively for anticipated LRAs

and inspection activities.

This RIS is part of the NRC's ongoing oversight of license renewal and is unrelated to the

agency's response to the March 11, 2011, earthquake in Japan.

ML 111990086

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BACKGROUND INFORMATION

In 10 CFR Part 54, the NRC addresses the requirements for plant LRAs. The regulation in

10 CFR 54.21, "Contents of Application-Technical Information," requires that each LRA

contain an integrated plant assessment and an evaluation of time-limited aging analyses. The

integrated plant assessment must identify and list those structures and components subject to

an aging management review (AMR) and must demonstrate that the effects of aging (such as

cracking, loss of material, loss of fracture toughness, dimensional changes, and loss of preload)

will be adequately managed so that the intended functions of the structures and components will

be maintained consistent with the current licensing basis for the period of extended operation as

required by 10 CFR 54.29(a). Structures and components subject to an AMR shall encompass

those structures and components (1) that perform an intended function, as described in

10 CFR 54.4, "Scope," without moving parts or without a change in configuration or properties,

and (2) that are not subject to replacement based on a qualified life or specified time period.

These structures and components are referred to as "passive" and "long-lived," respectively.

On April 26, 2001, the NRC issued N UREG-1801, "Generic Aging Lessons Learned (GALL)

Report," (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML011080185 and ML011080393). On September 30, 2005, the NRC issued NUREG-1801,

Revision 1, "Generic Aging Lessons Learned (GALL) Report," (ADAMS Accession Nos.

ML052770419 and ML052780376). On December 31, 2010, the NRC issued NUREG-1801,

Revision 2, "Generic Aging Lessons Learned (GALL) Report," (ADAMS Accession No.

ML 103490041). The GALL Report provides generic AMRs of systems, structures, and

components that are within the scope of license renewal, as described in 10 CFR 54.4, and

provides generic AMPs that the staff has found acceptable to manage the effects of aging

identified in the AMR. As described in NUREG-1800, Revision 2, "Standard Review Plan for

Review of License Renewal Applications for Nuclear Power Plants" (ADAMS Accession No.

ML 103490036) (LR-SRP), treatment of the GALL Report as an approved topical report

improves the efficiency of the license renewal process.

An applicant may reference in its LRA that its AMPs are consistent with those in the GALL

Report. If an applicant takes credit for an AMP in the GALL Report, it is incumbent on the

applicant to ensure that the conditions and operating experience at the plant are bounded by

those for which the AMP in the GALL Report was evaluated and found acceptable. In such a

case, the NRC staff's review of the AMP is limited to verifying that the applicant's AMP is

consistent with that provided in the GALL Report, including the conditions and operating

experience provided in the GALL Report.

If the applicant's conditions and operating experience are not bounded by those of the GALL

Report AMP, it is incumbent on the applicant to address the additional effects of aging that may

apply to the applicant's facility and supplement the GALL Report AMR line items and AMPs as

necessary. The staff's review then addresses the acceptability of the AMR and the AMPs to be

used by the applicant.

Revision 1 of the GALL Report provides AMP XI.M16, "PWR Vessel Internals," which refers to

the aging management guidance of the AMR line items for RVI components. Within the context

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of this RIS, NRC license renewals, theSE for MRP-227 and other NRC licensing actions, "RVI"

refers to reactor vessel internals. In recognition that the industry was conducting programs to

investigate aging of RVI components and to develop aging management guidelines for RVI

components, the AMR line items for RVI components state that:

No further aging management review is necessary if the applicant provides a

commitment in the FSAR [final safety analysis report] supplement to (1) participate in the

industry programs for investigating and managing aging effects on reactor internals; (2)

evaluate and implement the results of the industry programs as applicable to the reactor

internals; and (3) upon completion of these programs, but not less than 24 months

before entering the period of extended operation, submit an inspection plan for reactor

internals to the NRC for review and approval.

Each licensee that made a commitment to conform to GALL AMP XI.M16, or an equivalent

commitment under the 2001 GALL Report, also made a commitment in its FSAR supplement

that it will implement a plant-specific AMP for its RVI components based on the industry-

developed guidance.

On January 12, 2009, the Electric Power Research Institute (EPRI) submitted for NRC staff

review and approval the Materials Reliability Program (MRP) Report 1016596 (MRP-227),

Revision 0, "Pressurized Water Reactor Internals Inspection and Evaluation Guidelines"

(ADAMS Accession No. ML090160204). MRP-227 is the industry-developed guidance that

licensees will use to develop their plant-specific AMP for RVI components. MRP-227,

Revision 0 contains a discussion of the technical basis for the development of plant-specific

AMPs for RVI components in PWR vessels. MRP-227, Revision 0 also provides inspection and

evaluation guidelines for PWR licensees to use in their plant-specific AMPs. Once approved by

the NRC, MRP-227 will provide the basis for renewed license holders to develop plant-specific

inspection plans to manage aging effects on RVI components, as described by their FSAR

commitment.

The scope of components considered for inspection under the guidance of MRP-227,

Revision 0 includes core support structures (typically denoted as Examination Category B-N-3

by Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel

Code), and those RVI components that serve an intended safety function consistent with the

criteria in 10 CFR 54.4(a)(1). The scope of the program does not include consumable items

such as fuel assemblies, reactivity control assemblies, and nuclear instrumentation because

these components are not subject to an AMR, as defined in 10 CFR 54.21(a)(1).

On June 22, 2011, the NRC issued its final SE regarding topical report MRP-227, Revision 0

(ADAMS Accession No. ML 111600498), which license renewal applicants and renewed license

holders will use to develop their plant-specific AMPs for RVI components. This SE contains

specific conditions on the use of the topical report and applicant/licensee action items that must

be addressed by those utilizing the topical report as the basis for a submittal to the NRC. The

NRC approved version of the topical report is designated as MRP-227-A.

Subsequent to the submittal of MRP-227 and prior to the issuance of theSE on MRP-227,

GALL Report, Revision 2 was issued, providing new AMR line items and aging management

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guidance in AMP XI.M16A, "PWR Vessel Internals." This AMP was based on staff expectations

for the guidance to be provided in MRP-227-A. After December 21, 2010, any licensees

submitting an LRA were encouraged to reference and utilize GALL Report, Revision 2 to

manage the effects of aging identified in the AMR. With the issuance of theSE for MRP-227,

the NRC will issue License Renewal Interim Staff Guidance (LR-ISG) to revise the GALL Report

AMR line items and AMP XI.M.16A for consistency with theSE and to reflect acceptability of the

MRP-227-A report for use in license renewal applications.

SUMMARY OF ISSUE

The NRC granted renewed licenses to some owners of PWR units based on a commitment in

the FSAR supplement to, in part, submit an inspection plan for RVI components to the NRC for

review and approval. This plan was to be based on aging management guidelines for RVI

components developed by the industry and approved by the NRC. This commitment in the

FSAR would require those licensees to review and update their aging management inspection

plans for RVI components based on the guidance provided in MRP-227-A.

With the issuance of the staff SE for MRP-227, the NRC has updated internal guidance on

implementation of this RVI component AMP guidance relative to license renewal for PWR plants

on a plant-specific basis, as indicated in the following table for the plants in Categories "A"

through "D." The different plant categories reflect the licensee's status relative to license

renewal approval (i.e., licensee has received a renewed license, has submitted an LRA, or has

not), and, for those plants with renewed licenses, whether the licensee has or has not submitted

its inspection plan to the NRC for review and approval.

Category "A" facilities address licensees that previously submitted an RVI inspection plan based

on the draft Revision 0 of MRP-227. Licensees of Category "A" facilities, those that made a

commitment in the FSAR supplement to comply with the industry-developed guidance and

choose to withdraw their inspection plans to conform to their commitments, must do so in writing

and should include a commitment to resubmit the required information based on MRP-227-A, no

later than October 1, 2012. Licensees of Category "A" facilities who propose in their resubmittal

to deviate from provisions of MRP-227-A based upon having completed specific inspections, will

need to provide a justification for each deviation from the MRP-227-A guidelines. The NRC will

evaluate proposed deviations from the MRP-227-A guidelines to ensure that licensee programs

will still provide an acceptable approach for managing the effects of aging in RVI components.

This will ensure compliance with the commitment in the FSAR supplement.

Licensees of Category "B" facilities that have committed to follow the industry-developed

guidance, will be expected to make the submittal of their RVI AMP based on the guidance of

MRP-227-A, consistent with their commitment. Licensees of Category "B" facilities who are

required by their commitments to submit their RVI inspection plan prior to one year after the

issuance of this RIS may modify their commitments to submit their RVI inspection plan no later

than October 1, 2012. All other Category "B" facility licensees will be expected to make the

submittal of their RVI AMP in accordance with their existing commitments. This will ensure

compliance with the commitment in the FSAR supplement.

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For those PWR plants that have an LRA currently under review (as addressed in Category "C")

with a commitment to follow the industry-developed guidance, the NRC staff expects the

applicant to revise the commitment for aging management of PWR vessel internals such that

the plant-specific action items identified in theSE for MRP-227 would be submitted to the NRC

for review and approval not later than two years after issuance of the renewed license and not

later than two years before the plant enters the period of extended operation, whichever comes

first. It is expected that Category C licensees will follow the guidance of MRP-227-A, consistent

with their commitment.

For those PWR plant licensees that have not submitted their LRAs (as addressed in Category

"D") but plan to submit an LRA in the future, the NRC staff encourages these future license

renewal applicants to, and anticipates that the applicant will, provide an AMP for vessel internals

in their LRA that is consistent with MRP-227-A. As described previously, the NRC will issue an

LR-ISG to revise the GALL Report to ensure that GALL AMP XI.M16A, "PWR Vessel Internals,"

and associated AMR line items are consistent with theSE on MRP-227 and reflect acceptability

of the MRP-227-A report for use in license renewal applications. It is expected that all

Category D LRAs will meet GALL Revision 2 as updated by the LR-ISG.

If a license renewal applicant confirms that it will implement an AMP consistent with

MRP-227-A, Licensee/Applicant Action Item 8 from the NRC staff SE (Section 3.5.1) indicates

that the LRA shall include, in part, an AMP that addresses the 10 program elements as defined

in AMP XI.M16A, and an inspection plan. The NRC review of an AMP which is consistent with

GALL AMP XI.M16A would include those items specifically identified in Section 4.0 of theSE.

Category Description NRC Expectations

Licensees may withdraw their current

Plants with renewed licenses that AMP/inspection plan submittals and provide

have already submitted an new/revised commitments to resubmit

A AMP/inspection plan based on AMPs/inspection plans in accordance with

MRP-227, Revision 0 to comply MRP-227-A no later than October 1, 2012.

with an existing commitment. Future submittals should address all

information required by MRP-227-A.

Licensees will be expected to submit

AMPs/inspection plans in accordance with

MRP-227-A, consistent with the timing

Plants with renewed licenses that

requirements reflected in their LR

have a commitment to submit an

commitments. Licensees who would be

AMP/inspection plan based on

B required by their commitments to make their

MRP-227, but that have not yet

submittal prior to one year after the issuance

been required to do so by their

of this RIS may modify their commitments to

commitment.

reflect a requirement to submit their

AMPs/inspection plans no later than

October 1, 2012.

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Applicants will be expected to revise their

commitment for aging management of PWR

vessel internals such that the submittal

information identified in the SE for MRP-227

Plants that have an LRA currently would be submitted to the NRC for review

c under review. and approval not later than two years after

issuance of the renewed license and not later

than two years before the plant enters the

period of extended operation, whichever

comes first.

Applicants will be expected to submit an AMP

Plants that will apply for an LR in

for vessel internals that is consistent with

D the future based on the GALL

MRP-227-A for NRC staff review and

Report, Revision 2.

approval.

BACKFIT DISCUSSION

This RIS is being issued to inform stakeholders of the implementation of updated internal NRC

guidance for staff in performing reviews of LRAs with AMPs. The backfit rule applies to

procedures necessary to operate a nuclear power plant. The NRC's regulatory review process

is not a licensee procedure required for operating the plant.

This RIS requires no action or written response. The intent is to provide licensees sufficient

time to modify their AMPs to be consistent with MRP-227-A. This RIS provides information to

licensees regarding (1) updated NRC procedures for LRA reviews or the review of certain

licensee submittals related to commitments made in the process of receiving a renewed license

and (2) the potential for licensees to modify the original commitment date for the submittal of a

RVI AMP for their facilities. The technical position of GALL Rev. 2 has not changed.

Compliance with the guidelines specified in MRP-227-A would satisfy a licensee's license

renewal commitment. For those applicants following GALL Rev. 1, which provided no definition

on the RVI AMP, other than following the industry's future program, this RIS provides

clarification as to what an acceptable RVI AMP would be in light of the issuance of the staff SE

of MRP-227. Any action on the part of addressees to submit a request for a licensing action or

to adhere to the industry guidance contained in the EPRI's MRP-227-A guidance document is

strictly voluntary. Any changes to a licensees' AMP/inspection plan to adhere to MRP 227-A,

ensures compliance with a license commitment. Therefore, this RIS does not constitute a

backfit under 10 CFR 50.109, "Backfitting," and a backfit analysis is not required.

FEDERAL REGISTER NOTIFICATION

This RIS is informational and does not represent a departure from current regulatory

requirements. The NRC did not publish a notice of opportunity for public comment on this RIS

in the Federal Register because the RIS pertains to an administrative aspect of the regulatory

process that involves the voluntary use of industry guidance by addressees. However, on

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June 13, 2011, the NRC posted a draft version of this RIS on its public website for a 10-day

public comment period. Comments were received from the industry's Materials Reliability

Program (ADAMS Accession No. ML 11188A 162) and considered.

CONGRESSIONAL REVIEW ACT

The NRC has determined that this action is not a rule as designated by the Congressional

Review Act (5 U.S.C. §§ 801-808) and, therefore, is not subject to the Act.

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain new or amended information collection requirements that are subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were

approved by the Office of Management and Budget (OMB), approval number 3150-0011 and

3150-0155.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for

information or an information collection requirement unless the requesting document displays a

currently valid OMB control number.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

IRA/

Timothy J. McGinty, Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

Technical Contact: Sheldon D. Stuchell, Senior Project Manager

NRR/DPR/PLPB

(301) 415-1487

E-mail: sheldon.stuchell@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site,

http://www.nrc.gov, under NRC Library/Document Collections.

OAGI0001161 00007

ML 11188A 162) and considered.

CONGRESSIONAL REVIEW ACT

The NRC has determined that this action is not a rule as designated by the Congressional

Review Act (5 U.S.C. §§ 801-808) and, therefore, is not subject to the Act.

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain new or amended information collection requirements that are subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were

approved by the Office of Management and Budget (OMB), approval number 3150-0011 and

3150-0155.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for

information or an information collection requirement unless the requesting document displays a

currently valid OMB control number.

CONTACT

Please direct any questions about this matter to the technical contact listed below.

IRA/

Timothy J. McGinty, Director

Division of Policy and Rulemaking

Office of Nuclear Reactor Regulation

Technical Contact: Sheldon D. Stuchell, Senior Project Manager

NRR/DPR/PLPB

(301) 415-1487

E-mail: sheldon.stuchell@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site,

http://www.nrc.gov, under NRC Library/Document Collections.

DISTRIBUTION: MMitchell, NRR MEvans, NRR BHolian, NRR AHiser, NRR

ADAMS Accession Number: ML 111990086 *via e-mail TAC ME5988

OFFICE NRR/DPR/PLPB/PM Tech Editor NRR/DCI/CVIB/BC NRR/DPR/PLPB/BC NRR/PMDA

NAME SStuchell* JDougherty* MMitchell* JJolicoeur LHill*

DATE 05/18/11 04/08/11 04/22/11 04/22/11 04/25/11

OFFICE OE OIS NRR/DORL/D NRR/DCI/D NRR/DLR/D

MEvans (JLubinski

NAME NHilton* TDonnell* JGiitter* BHolian*

for)

DATE 05/16/11 04/28/11 05/16/11 05/04/11 04/29/11

NRR/DPR/PGCB/

OFFICE OGC NRR/DPR/PGCB/PM NRR/DPR/PGCB/BC NRR/DPR/D

LA

NAME MSmith* (NLO) CHawes ARussell SRosenberg TMcGinty

DATE 06/02/11 07/18/11 07/18/11 07/19/11 07/21/11