ML20254A054

NRC-2018-000831 - Resp 5 - Interim, Agency Records Subject to the Request Are Enclosed, Part 1 of 2

ML20254A054
Person / Time
Issue date:	09/01/2020
From:	NRC/OCIO
To:
Shared Package
ML20254A052	List: ML20254A053 ML20254A054 ML20254A055
References
FOIA, NRC-2018-000831 PNNL-27120
Download: ML20254A054 (608)

Text

Note to requester: Attachment to this email record is immediately following . This same email record was released in fu ll, and forwarded without its attachment, in the second interim response.

This record also addresses the first bullet in your 5/19/2020 letter.

From: Purtscher, Patrick Sent: Fri, 7 Sep 2018 17:54:12 +0000 To : 'Ramuhal li, Pradeep' Cc: Hiser, Matthew

Subject:

DMLR Specific Comment s on PNNL-27120-pr nrc 9-7-18_w -PTP_add-ons.docx Attachments: DMLR Specific Comment s on PNNL-27120-pr nrc 9-7-18_w-PTP _add -ons.docx Here is a copy of your report with all of our comments. We think this addresses the NRR comments and we hope it will be relatively easy for you to review, accepting those changes that you agree with . Where you don 't agree, highlight them for our further discussion .

The one main comment I had that is not noted in each case is the rating or ranking that is present, mainly in Tables 1 through 4. It should be clea rly noted where those values come from , some were from EMDA and others were from the author's assessment of the criteria in each table. Clearly the final assessment at the bottom of each table is TBD by each organization that is considering harvesting , given their own set of priorities.

Pat

Note to requester: The document provided to the FO IA 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 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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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: Attachments to this email record are immediately following . This same email record was released in full , and forwarded without its attachments , in the second interim response .

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

Subject:

MDLR comments on PNLL"s Guidelines for Harvesting Materials for SLR Date: Tuesday, March 20, 2018 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: 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 withWith the U.S. Department of Energy Contract DE-AC05-76RLO 1830 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

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

GENERAL COMMENT

S ON PNNL-27120

• 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:

(b)(SJ This statement is flat wrong. The issuance of the GALL-SLR and the SRP-SLR reports provides l(b)(S) !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:

• Confirmation of the current GALL-SLR approaches for aging management.

• 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 example, there should be a reference cited in (b)(5) .... Section3AA,item6,whichstatesl I (b)(5) ********************************************* i----....= ********;********

...-*********-********-********_ ... _ _ _ _ _ _ _ _ _ _ _ _ _....,I (b)(5) I Similarlv in the second oaraaraoh of section 3.4.1 the statement (b )(5)

I (b)(5) !should be supported by a reference.

• 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.

• ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,*********** ' ,,,.,,, ' ' ' ** ' ' ' ' ,,, ',, ' ( ~)(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 (b )(5) 2007, Jtwouldb.ecorrectto.statethatl I (b)(5)I :

• J... IThis 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 Repo,.cL.a.o.d....Qy extension, we should not be issuing renewed licenses for plants in theL....=jtfmeframe, l amconfident.. (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: (b)(5)_

(b)(5)

(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 oaraqraph qoes on to state.I -- 1 . {l:l)(?)

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• 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)

For the first underlined sentence, does this mean that we won't have! - l ( ~_)(5)

(b)(5) _J_. !In that case, how can we issue (b)(5) . . . .arenewedJicense forl !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 I .... L. __j ~J@

(b)(5) l ..

• 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.

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! l§Pl~J. 8 ~row. GALL~SLR, !_ ...* - - - - - - - - - -

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• * * *.** ***.*,.~~~J:~ ~* 8'~roj'GALL:SLR,!...._* _ _ _ _ _ _ _ _ _ _ _ _ _ ____,

• 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: Attachment to this email record is immediately following. This same email record was released in part, and forwarded without its attachment , in the From: Ramuhalli, Pradeep second interim response.

Sent: Thu, 21 Jul 2016 16:14:07 +0000 To: Purtscher, Patrick;Hiser, Matthew;Knobbs, Katie Cc: Hull, Amy

Subject:

[External_Sender) RE: RRIM Attachments: Draft.docx Patrick, Matt, Attached is a draft document for discussion later today.

With best regards, Pradeep Ramuhalli, PhD Tel: 509-375-2763 Email: pradeep.ramuhalli@pnnl. gov

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Original Appointment-----

From: Ramuhalli, Pradeep Sent: Tuesday, July 12, 2016 7:50 AM To: Ramuhalli, Pradeep; 'Purtscher, Patrick'; Hiser, Matthew (Matthew.Hiser@nrc.gov); Knobbs, Katie Cc: Hull, Amy

Subject:

RRIM When: Thursday, July 21, 2016 10:00 AM-11:00 AM (UTC-08:00 ) Pacific Time (US & Canada).

Where: Skype Meeting

All, Apologies - I have been incommunicado for a couple of weeks. I'd like to set up a conference call to play catch up. Let me know if this time works for you.

7 Join Skype Meeting This is an online meeting for Skype for Business, the professional meetings and communications app formerly known as Lyne.

Join by phone Join the meeting and have Lyne call you or dial-in (Richland) English {United States) 866-528- 1882 or 509-375-4555 (Richland) English (United States)

On-campus PNNL staff dial 5-4555 (Richland) English (United States)

Find a local number

Conference1D:._!(b_)_(6_)____.

Forgot your dial-in PIN? IHelp

PNNL-SA-XXXXX Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal Publish Date 1FM Last 3FM Last 2FM Last 4FM Last U . S . DEPARTMENT OF ENERGY Prepared for the U.S. Department of Energy under Contract DE-ACOS-76RL01830

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

Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal FM Last FM Last FM La st FM Last Publish Date Prepared for the U.S. Department of Energy under Contract DE-AC05-76RL01 8 30 Pacific Northwest National Laboratory Richland, Washington 99352

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y Pacific Northwest NATIONAL LABORATORY I ENERGY U .S. DEPARTMENT OF Proudly Operated by Baneue Since 1965 902 Battelle Boulevard P.O. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov

Note to requester: Attachment to this email record is immediately following. This same email record was From: Purtscher, Patrick released in full, and forwarded without its attachment, in the second interim response. This email record, and its Sent: Wed, 29 Aug 2018 16:42:31 +0000 attachment, partially address your sixth bullet point in To: 'Ramuhalli, Pradeep';Hiser, Matthew your 5/ 19/2020 letter.

Subject:

RE: TLR Update Attachments: harvesting_composite_8-28.docx Hi, Matt and I took turns changing the report with our recommendations, the attached is a composite of our comments. The biggest changes were to drop the abstract, combine sections 1 and 2, make the examples in section 3.3.2 into a separate section, and drop the specific harvesting examples in Section

4. We don't need that level of details for historical perspective. The general lessons learned are the points to be emphasized.

These are suggestions and would like to discuss with you after you have some time to review. Let me know when you have time. We hope to meet with NRR near the end of Sept. to go over the report and how their comments were considered.

Pat From: Ramuhalli, Pradeep [mai lto:Pradeep.Ramuhalli@pnnl.gov]

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 o n these.

Note to requester: After searching further, the 8/17/2018 Email from PNNL to NRC staff with the subject line "[External_Sender] TLR With best regards, Update" could not be located.

Pradeep Pradeep Ramuhalli, PhD Senior Resea rch Scientist, Applied Physics Group Pacific Northwest National Laboratory 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

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Note to requester: Attachment to this email record is immediately following. Attachment was also included in the 4th interim response .

From: Purtscher Patrick To : Hiser Matthew; Audrain Margaret ; Jregonjng Robert Subject : Harvesting-TLR-final DRAFT- 12_04_2017.docx Date: Tuesday, December 05, 201 7 8 :20 :45 AM Attachments: Harvestng-TLR-final DRAFT- 12 04 2017.docx Here is the final draft of the harvesting report.

Pat

PNNL-XXXXX 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. DEPARTMENT OF ENERGY

DISCLAIMER Tilis report was prepared as an account of work sponsored by an agency of the United States Government. NeitJier tl1e U1lited States Govermnent nor any agency thereof, nor Bat1elle Memorial Institute, nor any of their employees, makes any warranty, ex1,ress or implied, or assumes any legal liability or res1,onsibility fo r the accuracy, com1, lctcncss, or usefulness of any information, a1,paratus, product, or process disclosed, or re1,resents that its use would not infringe 1,rivatcly owned tights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, orotheiwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Govenuncnt or any agency thereof, or Battelle Memorial Institute. The views and opi1lions of autl10rs expressed herein do not riecessarily state or reflect those of tl1e United States Governme nt or any agency thereof.

PACTFIC NORTHWEST NATIONAL LABORATORY operated by BATTELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contract DE-AC05-76RL0/830 Printed in the United Sta tes of America Available to DOE a nd DOE contractors from the O fllce of Scicntlflc and Tcchnknl lnfor11111tlon, P.O. Box 62, Oak Ridge, T N 37831-0062; ph: (865) 576-8401 fax: (865) 576-5728 email: report "adonis.osti.go,*

Avnilablc to the pu blic from the Nntional Technical Information Service 5301 Shawnee Rd., Alexandria, VA 22312 ph: (800) 553-NTIS (6847) email: orders(a)ntis.go,* <http://www.ntis.gov/a bout/form.nspx>

Online o r*dc r-ing: http://www .ntis.gO\'

@Tllis document was printed on recycled paper.

(8/2010)

Note to requester: The document provided to the FOIA staff also included skipped numbers PNNL-XXXXX 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 Dev anathan KKnobbs RM Meyer December 201 7 Prepared for the U.S. N uclear Regulatory Commission under a Related Services Agreement with the U.S. Department of Energy Contract DE-AC05-76RLO 1830 Pacific Northwest National Laboratory Richla nd, Washington 99352

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NATIONAL LABORATORY Proudly Operated by Banelle Since 1965 902 Battelle Boulevard P.O. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.g ov 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-AC05-76RL01830 ENERGY

Note to requester: Attachment to this email record is immediately following.

Attachment was also included in From: Purtscher Patrick the 4th interim response.

To: Hiser Matthew; Audrain Margaret; ~  ; Tregoning Robert

Subject:

harvesting report Date: Tuesday, October 31, 2017 1:51 :55 PM Attachments: Harvesting-TLR-final DRAFT Oct 2017.dOC){

Draft from Pradeep on harvesting.

Pat

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Original Message-----

From: Purtscher, Patrick Sent: T uesday, October 3 l , 2017 1 :49 PM To: 'Ramuhalli, Pradeep' <Pradeep.Ramuhalli@pnnl.gov>

Subject:

RE: You have files ready for pickup Thanks, I got the file.

My idea to finish everything now is for us (Amy, Matt, Rob, Meg, and myself) to read through it one more time and then send it to my branch chief for his information. Then you can get a PNNL lab report# and complete phase l of the project.

Pat

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Original Message-----

From: Ramuhalli, Pradeep [maj]to*col)aboratjon@pool ~ov]

Sent: T uesday, October 31, 2017 10:41 AM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Subject:

[External_Sender] You have files ready for pickup Hello, Ramuhalli, Pradeep (Pradeep.Ramuhalli@pnnl.gov) has sent you the following 1 file(s:)

Subject:

TLR - resending draft Comments: Patrick, (b )(6)

The TLR update should be available via the link below. Just saw your email from last week ( ._l_ _ __..l and then playing catchup). Resending this via FfP instead of email attachment.

Pradeep The following files have been uploaded to the MassTransit Web File T ransfer Services. You can download them by going to:

I (b)(4)1 and selecting the file(s) and clicking Download (All/Selected).

NOTE: This link and contained passkey are only good for 14 days.

Harvesting-TLR-DRAFf.docx (5 .07M bytes)

PNNL-XXXXX Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal November 2017 P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer U . S . DEPARTMENT OF ENERGY Prepared for the U.S. Department of Energy under Contract DE-ACOS-76RL01830

DISCLAIMER Tilis report was prepared as an account of work sponsored by an agency of the United States Government. NeitJier tl1e U1lited States Govermnent nor any agency thereof, nor Bat1elle Memorial Institute, nor any of their employees, makes any warranty, ex1,ress or implied, or assumes any legal liability or res1,onsibility fo r the accuracy, com1, lctcncss, or usefulness of any information, a1,paratus, product, or process disclosed, or re1,resents that its use would not infringe 1,rivatcly owned tights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, orotheiwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Govenuncnt or any agency thereof, or Battelle Memorial Institute. The views and opi1lions of autl10rs expressed herein do not riecessarily state or reflect those of tl1e United States Governme nt or any agency thereof.

PACTFIC NORTHWEST NATIONAL LABORATORY operated by BATTELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contract DE-AC05-76RL0/830

@ 111.is docLUnent was printed on recycled paper.

(9f2003)

Note to requester: The document PNNL-XXXXX provided to the FOIA staff also included 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 November 2017 Prepared for the U.S. Department of Energy under Contract DE-AC05-76RL01830 Pacific Northwest National Laboratory Richland, Washington 99352

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y Pacific Northwest NATIONAL LABORATORY I ENERGY U .S. DEPARTMENT OF Proudly Operated by Baneue Since 1965 902 Battelle Boulevard P.O. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov

Note to requester: Attachment to this email record is immediately following. Attachment was also included in the 4th interim response.

From: Hiser Matthew To: Sircar Madhumita Cc: Purtscher Patrick

Subject:

FW: Harvesting document update Date: Friday, March 17, 2017 10:12:20 AM Attachments: Draft Outline Harvesting PNNL rev3-0131 17 docx Hi Mita, Here is t he latest version of the PN NL report. Please feel free to take a look and provide comme nts.

I' ll be reviewing and sending comments to Pat in the next few days.

Thanks!

Matt From: Ramuhal li, Pradeep [mai lto:Pradeep.Ramuha ll i@pnn l.gov]

Sent: Wednesday, February 01, 2017 1:10 AM Note to requester: After searching further, the To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov> 2/1/2017 Email from PNNL to NRC staff with Cc: Hiser, Matthew <Matthew.H iser@nrc.gov> the subject line "[External_Sender] Harvesting document update" could not be located.

Subject:

[Externa l_Sender] Harvesting document update

Patrick, Attached is an updated draft of the harvesting document. Please note - this is a draft. As always, feedback/suggested edits are welcome. I am f in ish ing up t he draft slides and w ill have them out later tomorrow.

With best regards, Pradeep Pradeep Ramuha ll i, PhD Sen ior Research Scientist, Applied Physics Group Pacific Northwest National Laboratory 902 Battelle Blvd.

P.O.Box 999, MSIN K5-26 Richland, WA 99352 Tel: 509-375-2763 Emai l: pradeep.ramuha lli@pnn l.gov http'(/www pool gov

PNNL-XXXXX Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal January 2017 P Ramuhalli SW Glass R Devanathan K Knobbs RM Meyer U . S . DEPARTMENT OF ENERGY Prepared for the U.S. Department of Energy under Contract DE-ACOS-76RL01830

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Note to requester: The document provided PNNL-XXXXX to the FOIA staff also included 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 January 2017 Prepared for the U.S. Department of Energy under Contract DE-AC05-76RL01830 Pacific Northwest National Laboratory Richland, Washington 99352

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Distr.1

y Pacific Northwest NATIONAL LABORATORY I ENERGY U .S. DEPARTMENT OF Proudly Operated by Baneue Since 1965 902 Battelle Boulevard P.O. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.gov

Note to requester: Attachment to this email record is immediately following. Attachment was From: Purtscher Patrick also included in the 4th interim response .

To : Hiser Matthew Subject : FW: TLR Date: Tuesday, September 25, 2018 6:54:43 AM Attachments: DM LR So~cilli;J&m!ill!ntuin PNNL-27120-Rr nrc 9-7-18 w-PTP a d ~ ~

From: Ram uhal li, Pradeep [mai lto:Pradeep .Ramuha lli@pnn l.gov]

~------~--~~~~-~~

Sent: M ond ay, Se ptem ber 24, 2018 3:02 PM Note to requester: After searching further, the To: Purtscher, Patri ck <Pat rick. Purt scher@ nrc.gov> 9/24/2018 Email from PNNL to NRC staff with the subj ect line "[External_Sender] TLR"

Subject:

[Ext erna I_Se nder] TLR could not be located .

Pat, Att ac hed is an upd ated (changes acce pted) vers ion of TLR. Rea di ng throug h yo ur comments, seemed like most of t hem were OK. I accept ed th em. Abou t th e only o nes I have left in th ere are some fo rmattin g cha nges, comments on add ing refe rences (I agree - just haven't added t hem yet), and a suggest ed deletion of the co ncret e sectio n. I also have a suggestion on drastica lly cutti ng down t he past harvesti ng disc ussions. W e can talk about t his on th e ca ll today.

With best rega rds, Pradee p Pradee p Ramuha ll i, PhD Se ni or Research Scient ist, Applied Physics Group Pacific North west Nat io nal Laborat ory 902 Battelle Blvd.

P. O.Box 999, MSIN KS-26 Ric hland, WA 99352 Tel : 509 -37 5-2763 Emai l: pra deep. ramu halli @p nnl .gov http://www.pnni.gov

Note to requester: The document provided to the FO IA 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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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: Attachment to this email record is From: Hiser Matthew immediately following. Attachment was also included To: Miller Kenneth A; Sircar Madhumita in the 4th interim response.

Subject:

FW: TLR Update Dat e: Tuesday, August 21 , 2018 10:36:00 AM Attachments: DMLR Soecific Comments on PNNL-27120-or.docx.

Hi Mita and Kenn, FYI for your awareness - PNNL report on prioritizing harvesting needs (has somewhat informed our criteria). We are addressing NRR comments, which were mostly concerned with implications of wording in report on SLR guidance and reviews .. .

Thanks!

Matt Matthew Hiser Materials Engineer US Nuclear Regulatory Commission I Office of Nuclear Regulatory Research Division of Engineering I Corrosion and Metallurgy Branch Phone: 301-415-24541 Office: 1WFN 10D62 Matthew Hiser@nrc gov From: Ramuhal li, Pradeep [mai lto:Pradeep.Ramuha ll i@pnn l.gov]

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 fa r is attached. This stil l needs some clea nup and citations incl uded; I am working on a tech editor on t hese.

Note to requester: After searching further, the 8/17/2018 Email from PNNL to NRC With best regards, staff with the subject line "[External_Sender] TLR Update" could not be located.

Pradeep Pradeep Ramuha ll i, Ph D Se nior Research Scient ist, Applied Physics Grou p Pacific Nort hwest National La boratory 902 Battelle Blvd.

P. O.Box 999, MSIN K5-26 Richland, WA 99352 Tel : 509-375-2763 Emai l: pradeep.ramuha lli@p nn l.gov http://www,pnnl,gov

Note to requester: The document provided to the FOIA staff also included skipped n umbers 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 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

Note to requester: Attachment to this email record is immediately following.

Attachment was also included in the 4th interim response , and was also included as an attachment in a previous record in the 5th interim response .

From: Hiser Matthew To : Audrain Margaret Subject : FW : TLR Update Date: Friday, August 17, 2018 2 :45:59 PM Attachments: DMLR So~cilli;J&m!ill!ntuin PNNL-27120-pr.~

From: Ramuhal li, Pradeep [mai lto:Pradeep .Ramuha ll i@pnn l.gov]

Sent: Fri day, August 17, 2018 2:45 PM To: Hiser, Matt hew; Purtsc her, Patrick

Subject:

[E xternal_ Sender] TLR Update The update so far is attached . This sti ll needs some cleanup and citations incl uded; I am working on a tech editor on these .

W ith best regards, Pradeep Pradeep Ramuha ll i, PhD Note to requester: After searching further, the 8/ 17/2018 Email from Senio r Research Scientist, PNNL to NRC staff with the subject line "[External_Sender] TLR Applied Physics Grou p Update" could not be located .

Pacific Northwest Nationa l La boratory 902 Battel le Blvd.

P.O.Box 999, MS IN K5-26 Rich land, WA 99352 Tel : 509 -37 5-2763 Ema il: pra deep.ramuha lli@p nnl .gov http://www,pnn l. 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 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

Note to requester: Both attachm ents to this email record From:

are immediately following. Second attachment was also Purtscher Patrick To : "Ramuham Pradeep" included in the 4th interim response.

Cc : Hiser Matthew Subject : First Draft Outline Harvesting PNNL rev2 PTP comments Date : Friday, December 09, 2016 10:45:25 AM Attachments : First Draft Outline Harvesting PNNL rev2 PTP comments.docx Harvestjna Workshop Announcement docx HI, I have added a few more comments, but mainly ed itor ial. Can you give me an estimated de livery date for final draft?

We are moving ahead with plann ing the workshop. It wi ll be a closed meeting on March 7-8, 2017.

We expect to li mit the attendance to 25 to 30 peop le.

We stil l need to talk about a contract mod to all ow for your travel and works hop summary. Let me know what yo ur ava ilabi li ty wi ll be for next week . I co uld be ava ila ble most any day aroun d noon.

Pat

PNNL-SA-XXXXX Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal January 2017 P Ramuhalli SW Glass R Devanathan K Knobbs R Meyer U. S. DEPARTMENT OF ENERGY Prepared for the U.S. Department of Energy under Contract DE-ACOS-76RL01830

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PNNL-SA-XXXXX Criteria and Planning Guidance for Ex-Plant Harvesting to Support Subsequent License Renewal FM Last FM Last FM Last FM Last January 20 17 Prepared for the U.S. Department of Energy under Contract DE-AC05-76RLO 1830 Pacific Northwest National Laboratory Richland, Washington 99352

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y Pacific Northwest NATIONAL LABORATORY I U .S . DEPARTMENT OF ENERGY Proud/)' Opercited b)' Ba1lele Since /965 902 Battelle Boulevard P.O. Box 999 R,chland, WA 99352 1-888-37S-PNNL (7665) www.pnnl.gov

Note to requester: This document, an attachment to the previous email record, was also released in full in the second interim response.

Ex-Plant Materials Harvesting Workshop Location: NRC Headquarters in Rockville, MD, USA Dates: March 7-8, 2017 Motivation:

• There are increasing opportunities to harvest the safety-critical components from decommissioning plants, both domestic and international.

• The harvested materials are valuable because they have been exposed to actual in-service plant operating conditions (temperature, irradiation, coolant, etc.), unlike virgin materials tested under simulated conditions in the lab.

• Data from ex-plant materials should help address technical gaps identified for extended operation of nuclear power plants due to highly relevant aging conditions.

Purpose and Objective:

• For NRC staff and interested stakeholders to have greater awareness and knowledge of the benefits and challenges associated with ex-plant harvesting.

• Facilitate contacts and communication to enable specific cooperative ex-plant harvesting programs to be initiated.

Workshop Topics:

• Harvesting decision-making and prioritization o Technical data needs best addressed by harvesting o Technical information needed in advance of harvesting

• Sources of materials:

o Decommissioning reactors o Operating reactors - replaced components o Previous harvesting programs - "boneyards" o Tracking available materials

• Harvesting process o Lessons learned from harvesting experience o Perspective of utility-owner and decommissioning contractor on harvesting o Communication and coordination between decommissioning and researchers

• International collaborative programs on specific components at specific plants Workshop will consist of solicited presentations followed by discussion periods. If interested in attending or learning more about the workshop, please reach out to the contacts below.

Contacts: Robert Tregoning, Robert.Tregoning@nrc.gov Matthew Hiser, Matthew.Hiser@nrc.gov Patrick Purtscher, Patrick.Purtscher@nrc.gov

Note to requester: Attachment to this email record is immediately following. Attachment was also included in the 4th interim response.

This record addresses the second bullet in your 5/ 19/2020 letter.

From: Ramuhalli, Pradeep Sent: Mon, 4 Dec 2017 21:21 :48 +0000 To: Purtscher, Patrick

Subject:

[External_Sender] RE: draft report from PNNL on Harvesting project Attachments: Harvesting-TLR-final DRAFT-120417 .docx

Patrick, I don't reca ll if I got this back to you or not. If not, attached is the updated version . In addition to the editorial changes you suggested, an internal peer review caught a few more editorial changes (format checks, grammatical issues) . These are in the attached .

With best regards, Pradeep Ramuhal li, PhD Tel: 509-375-2763 Email: pradeep.ramuhalli@pnnl.gov From: Purtscher, Patrick [1] Note to requester: After searching further, the Sent: Friday, November 24, 201710:05 AM 11 /24/2017 Email from NRC staff to PNNL with the To: Ramu ha Iii, Pradeep <Pradeep.Ramuhalli@pnnl.gov> subject line "FW: draft report from PNNL on Harvesting proj ect" could not be located. Therefore,

Subject:

FW: draft report from PNNL on Harvesting project we could not locate its attachment, and we also could also not locate any emails forwarding this Good afternoon, information. This addresses the third bullet in your 5/19/2020 letter.

Here is the report with some little editorial changes that we would like you to make before we send it through for management approval.

Pat

PNNL-XXXXX 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. DEPARTMENT OF ENERGY

DISCLAIMER Tilis report was prepared as an account of work sponsored by an agency of the United States Government. NeitJier tl1e U1lited States Govermnent nor any agency thereof, nor Bat1elle Memorial Institute, nor any of their employees, makes any warranty, ex1,ress or implied, or assumes any legal liability or res1,onsibility fo r the accuracy, com1, lctcncss, or usefulness of any information, a1,paratus, product, or process disclosed, or re1,resents that its use would not infringe 1,rivatcly owned tights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, orotheiwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Govenuncnt or any agency thereof, or Battelle Memorial Institute. The views and opi1lions of autl10rs expressed herein do not riecessarily state or reflect those of tl1e United States Governme nt or any agency thereof.

PACTFIC NORTHWEST NATIONAL LABORATORY operated by BATTELLE for the UNITED STATES DEPARTMENT OF ENERGY under Contract DE-AC05-76RL0/830 Printed in the United Sta tes of America Available to DOE a nd DOE contractors from the O fllce of Scicntlflc and Tcchnknl lnfor11111tlon, P.O. Box 62, Oak Ridge, T N 37831-0062; ph: (865) 576-8401 fax: (865) 576-5728 email: report "adonis.osti.go,*

Avnilablc to the pu blic from the Nntional Technical Information Service 5301 Shawnee Rd., Alexandria, VA 22312 ph: (800) 553-NTIS (6847) email: orders(a)ntis.go,* <http://www.ntis.gov/a bout/form.nspx>

Online o r*dc r-ing: http://www .ntis.gO\'

@Tllis document was printed on recycled paper.

(8/2010)

Note to requester: The document provided to the FOIA staff also included PNNL-XXXXX 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-AC05-76RLO 1830 Pacific Northwest National Laboratory Richland, Washington 99352

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NATIONAL LABORATORY Proudly Operated by Banelle Since 1965 902 Battelle Boulevard P.O. Box 999 Richland, WA 99352 1-888-375-PNNL (7665) www.pnnl.g ov 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-AC05-76RL01830 ENERGY

Note to requester: After searching further, the 3/26/2018 email from NRC staff to PNNL with the subject line "FW: MDLR comments on PNLL's Guidelines for Harvest ing Materials for SLR" could not be located. This 3/26/2018 emanl forwarded the 3/20/2018 email on this page. However, we located another email, dated 3/21/2018, that had the same subject line with its attachments, that was also forwarding the same 3/20/2018 email message. Both of the attachments to this email are following.

This record addresses the fourth bullet in your 5/ 19/2020 letter.

From : Purtscher, Patrick Sent: Wed, 21 Mar 2018 17:54:22 +0000 To: Tregoning, Robert;Audrain, Margaret; Hiser, Matthew

Subject:

FW: MDLR comments on PNLL's Guidelines for Harvesting Materials for SLR Attachments: DMLR Specific Comments on PNNL-27120.docx, DMLR General Comments on PNNL -27120.docx Here are DMLR comments. Eight people provided comments, do you think that is some kind of record?

I don't remember any RES document that got that kind of review while I was in NRR.

Pat From : Brady, Bennett Sent: Tuesday, March 20, 2018 5:19 PM To: Purtscher, Patrick <Patrick.Purtscher@nrc.gov>

Cc: Oesterle, Eric <Eric.Oesterle@nrc.gov>

Subject:

MDLR comments on PN LL's Guidelines for Harvesting Materials for SLR 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 - D8 301-4 15-2981

Note to requester: The document provided t o 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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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 FO IA team.

GENERAL COMMENT

S ON PNNL-27120

• 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 hlrvesting efforts. In particular, this report cites the following: ~b)~sil This statement is flat wrong. The issuance of the GALL-SLR and the 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:

• Confirmation of the current GALL-SLR approaches for aging management.

• 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 example, there should be a reference cited in (b )(5) Section.. 3. .4.A. item6,whichstates 1 I (b )(5)

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • t *******************************************************************************************************************************************************

(b)(5) ****************************************** *..__ _______ ____.1should be supported by a reference .

• 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.

• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • ...... (_~)(5)

(b )(5)

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 (b )(5) ..... 2007 ... . . 1.t .wouJd ..be.correctto.statethat l -- I (b )(5)1' J ... . rrhis 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 ! * +t+meframe.. . . .Lam...confident ( 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:! * . . .. . j ......... {~)(?)

(b)(5) ............................................... ****+*

(b)(5) . . . . . . . . ..]

... ---------------------,..!-lf-th-is_ i_s_o_u_r b- a-s-is- f-10_,r 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 .. . {~)(?)

(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)

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)  ! I 9bl~J ... .81~row, GALL~SLR, ._!_

(b)(5)

(b)(5) lIable2, 8 ~row, 1

I GALL~SLR+.....________________,

• 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).

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