ML11356A317
| 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: |
| 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
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
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
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