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

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

OAGI0001161

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BACKGROUND

INFORMATION

RIS 2011-07 Page 2 of 7 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 U REG-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 OAGI0001161

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RIS 2011-07 Page 3 of 7 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 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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RIS 2011-07 Page 4 of 7 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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RIS 2011-07 Page 5 of 7 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 Plants with renewed licenses that MRP-227-A, consistent

with the timing have a commitment

to submit an requirements

reflected

in their LR AMP/inspection

plan based on commitments.

Licensees

who would be B MRP-227, but that have not yet required by their commitments

to make their been required to do so by their submittal

prior to one year after the issuance of this RIS may modify their commitments

to commitment.

reflect a requirement

to submit their AMPs/inspection

plans no later than October 1, 2012. OAGI0001161

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c Plants that have an LRA currently

under review. Plants that will apply for an LR in D the future based on the GALL Report, Revision 2. BACKFIT DISCUSSION

RIS 2011-07 Page 6 of 7 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 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. Applicants

will be expected to submit an AMP for vessel internals

that is consistent

with MRP-227-A

for NRC staff review and approval.

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 OAGI0001161

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RIS 2011-07 Page 7 of 7 June 13, 2011, the NRC posted a draft version of this RIS on its public website for a 1 0-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

RIS 2011-xx Page 7 of 7 June 13, 2011, the NRC posted a draft version of this RIS on its public website for a 1 0-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.

DISTRIBUTION:

MMitchell, NRR MEvans, NRR ADAMS Accession

Number: ML 111990086

BHolian, NRR *via e-mail AHiser, NRR 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

NAME NHilton* TDonnell*

JGiitter*

MEvans (JLubinski

BHolian* for) DATE 05/16/11 04/28/11 05/16/11 05/04/11 04/29/11 OFFICE OGC NRR/DPR/PGCB/ 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 OFFICIAL RECORD COPY OAGI0001161

00008