ML051050009
| ML051050009 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/13/2005 |
| From: | Daniel Merzke Division of Regulatory Improvement Programs |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML051030210 | List: |
| References | |
| Download: ML051050009 (12) | |
Text
APPROACH TO LICENSE RENEWAL TOPICS Approach to License Renewal Topics A number of License Renewal topics have received industry or regulatory interest. Relevancy of some of these topics to License Renewal warrants their separate listing and discussion in Table 1 below, with reference to where additional information can be found in the Monticello License Renewal Application (LRA). Some topics were raised by the NRC Staff during their review of other utility applications, and others have been the subject of NRC Interim Staff Guidance (ISG) or discussion at industry working groups. NMC's position on ISGs is provided in Section 2.1.4.3 of the LRA.
Where necessary, site specific studies and special investigations were conducted to establish a consistent approach with sufficient technical bases to address each topic. The results of these studies and investigations are included in a series of MNGP LR Technical Reports (LR-TRs), Aging Management Review (AMR)
Reports and other project documents.
Table 1: License Renewal Topics Topic Approach LRA Section(s)
Scoping:
Safety-Related Systems, Structures and Components Section 2.1.4.2.1 SSCs and 10 CFR (SSCs) required to perform the 54.4(a)(1) functions of 10 CFR 54.4(a)(1) for
[1.11 Design Basis Events were included in-scope for License Renewal (regardless of their CLB safety classification).
Design Basis Design Basis Events are defined in the Section 2.1.3.2 Events Current License Basis (CLB) and are
[1.2]
contained in Chapter 14 of the Monticello Updated Safety Analysis.
Use of Current The Current License Basis, in Section 2.1.3.1 License Basis In accordance with 10 CFR 54.3, was Section 2.1.4.1 Scoping used to ensure all plant systems and Determinations structures were evaluated for LR
[1.3]
scoping.
NUREG-1801 Scoping and screening methodology is Section 2.1.4 Scoping and consistent with guidance in SRP Section 2.1.5 Screening (NUREG-1 800), no exceptions are Guidance noted.
[1.4]
Page 1 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
License Renewal License Renewal Boundary Drawings Section 2.1.4.4 Boundary identify at a summary level those Drawing Legend, LR-36032 Drawings and mechanical, electrical, and structural Conventions components in-scope for License
[2]
Renewal. Standard drawing conventions are used. Components in-scope for License Renewal are consistently highlighted with those in-scope for 10 CFR 54.4(a)(2) separately identified.
Fuse Holders Fuse holders were addressed Section 2.1.4.3
[3.1]
consistent with ISG-05.
Table 3.6.2-2 Neutron and Instrument cables which may Section 2.5.2.3 Radiation experience a reduction in insulation Table 3.6.2-3 Monitoring resistance (IR) due to prolonged Appendix B2.1.16 Cables exposure to elevated temperatures or
[3.2]
high radiation are in-scope for License Renewal.
Steam Dryer The reactor vessel steam dryer is in-Section 2.3.1.3
[3.3]
scope for License Renewal. Aging Table 3.1.2-3 management of the dryer is addressed Appendix B.2.1.12 by the Plant Chemistry Program, the Appendix B.2.1.25 BWR Vessel Internals Program for SCC/IGSCC, and the BWR Vessel Internals Program for cyclic loading.
Refueling Seals The reactor pressure vessel to drywell Section 2.4.13
[3.4]
refueling seal, drywell to reactor Table 2.4.13-1 building refueling seal, and spent fuel Table 3.5.2-13 pool gate seals are all in-scope for Section 2.4.15 License Renewal.
Table 2.4.15-1 Table 3.5.2-15 Crane Rail Cranes, other lifting devices, including Section 2.4.1
- Supports, bridge, trolleys, and rail systems used in Table 3.5.2-1 Cranes, Rails, the Reactor and Turbine Buildings are Hoists, and Other in-scope for License Renewal in Lifting Devices accordance with 10 CFR 54.4(a)(2). No
[3.5 thru 3.9]
hoists are in-scope for License Renewal.
Offsite Power Equipment relied upon for SBO Section 2.1.4.3 System recovery is in-scope for License Section 2.5.2.4 Components, Renewal consistent with ISG-02. Plant Station Blackout specific recovery paths have been (SBO) Recovery identified.
[3.10]
Spent Fuel Pool The spent fuel pool system piping and Section 2.3.3.10 System Piping makeup water source piping inside the Section 2.3.4.1 and Makeup Reactor Building are in-scope for Water License Renewal in accordance with 10
[3.11]
CFR 54.4(a)(2) (non safety affecting safety).
Page 2 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Housings for Consistent with Interim Staff Guidance Section 2.1.4.3.2 Active on housings for active components, fan Components and damper housings with intended
[3.12]
functions meeting the criteria of 10 CFR 54.4(a) are in-scope for License Renewal and subject to aging management review (AMR).
Non safety related SSCs were identified Section 2.1.4.2.2 Non-Safety based on their impact to 10 CFR Section 2.1.4.3.2 Related SSC 54.4(a)(1) SSCs in accordance with 10 Evaluation CFR 54.4(a)(2), Interim Staff Guidance Methodology on Scoping Criterion 10 CFR 54.4(a)(2),
[4.1]
NUREG-1800 and appropriate guidance from NEI 95-10 as described in the LRA.
10 CFR 54A(a)(2)
Non-safety related SSCs credited in the Section 2.1.4.2.2 Preventive and/or CLB for preventive or mitigative Mitigative functions in support of 10 CFR Approach 54.4(a)(1) functions were included in-
[4.2]
scope for License Renewal.
SSCs meeting 10 CFR 54.4(a)(2)
Section 2.1.4.2.2 Scoping of Non-included three categories: (1) those Safety Related included in the CLB, such as prevention SSCs or mitigation of: internal or external
[4.3]
floods, high energy line breaks (HELB),
missile hazards, and seismic impacts; (2) those directly connected to 10 CFR 54.4(a)(1) systems (typically piping systems); and (3) those whose failure due to spatial proximity could prevent accomplishment of a 10 CFR 54.4(a)(1) function (spatial proximity assumed no credit for break type or spray/exposure duration).
Page 3 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s) 10 CFR 54.4(a)(2)
For non-safety related SSCs directly Section 2.1.4.2.2 Equivalent connected to 10 CFR 54.4(a)(1) SSCs, Anchors the in-scope boundary for license
[4.4]
renewal extends into the non-safety related (NSR) portion of the piping and supports up to and including the first equivalent anchor (as defined in the LRA) beyond the NSR/10 CFR 54.4(a)(1) interface. 10 CFR 54.4(a)(2) boundaries are clearly delineated on the License Renewal drawings. 10 CFR 54.4(a)(2) SSCs are managed by the appropriate Aging Management Program, typically the System Condition Monitoring, Structures Monitoring, Plant Chemistry, and/or One Time Inspection Programs. Components, assets, and commodities meeting Scoping Criterion 2 were identified in the same unique manner as all other SSCs in-scope for License Renewal (e.g., valves, pumps, piping, etc.).
l Thermal Thermal insulation on the piping in the Table 3.2.2-4 Insulation In-High Pressure Coolant Injection room Table 3.2.2-7 Scope for and the heat exchangers in the License Renewal Residual Heat Removal rooms has
[5]
been credited in room heat-up calculations and is in-scope for License Renewal. No other thermal insulation performs an intended function.
Consumables Evaluation of items to determine Section 2.1.5.3
[6]
whether or not they are consumables followed the guidance contained in Table 2.1-3 of NUREG-1800.
Structures not In-Structures, buildings, and houses within Table 2.2-1 Scope for the site boundary that perform no LR-36444 License Renewal intended function are listed in the LRA
[7]
and depicted on the site map License Renewal boundary drawing. Seismic Il/1 was considered.
Component Some system groupings and a very Section 2.1.4.1 Assignment to limited number of component Table 2.2-1 License Renewal realignments were performed to support Systems scoping activities and GALL
[8]
comparisons as described in the LRA.
Components and commodities are uniquely identified and tracked to these LR systems.
Page 4 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Aging Management Reviews (AMRs):
Intergranular IGSCC/SCC were identified as Section 3.1 Stress Corrosion applicable aging mechanisms for Table 3.1.1, Item 3.1.1-29 Cracking (IGSCC) mechanical systems. The Monticello Section 3.2 and Stress BWR Stress Corrosion Cracking and Table 3.2.1, Item 3.2.1-16 Corrosion Plant Chemistry Program manages Section 3.3 Cracking (SCC) cracking for pipe >4" with reactor Table 3.3.1, Item 3.3.1-27
[9]
coolant greater than 200F. For pipe <4" Section 3.4 with reactor coolant greater than 140F, Appendix B2.1.10 IGSCC/SCC is managed by ASME Note 108, 208, 308, 408 Section Xl Program, One Time Inspection Program and Plant Chemistry. For all other components with treated water greater than 140F cracking is managed predominantly by the One Time Inspection Program and Plant Chemistry Program.
Steam Generator Not part of the Monticello design (PWRs None Feedwater Inlet only).
Ring Assemblies
[10]
Ground Un-insulated ground conductors are not Section 2.5.2.3 Conductors in-scope for License Renewal. They
[11.1]
perform no intended function.
Transmission No aging effects requiring management Section 2.5.2.4 Conductors for the period of extended operation Table 3.6.2-4
[11.2]
were identified for Transmission Conductors or High Voltage Insulators.
Flow-Accelerated Consistent with the GALL, the aging Table 3.1.2-1 Corrosion (FAC) effect loss of material due to flow-Table 3.1.2-4 Program accelerated corrosion is managed by Table 3.2.2-4
[12]
the FAC Program.
Table 3.2.2-6 Table 3.3.2-2 Table 3.3.2-15 Table 3.4.2-2 Table 3.4.2-4 Table 3.4.2-5 Appendix B2.1.19 Reactor Vessel The reactor vessel flange leak detection Section 2.3.1.5 Flange Leak piping is in-scope for License Renewal.
Table 3.1.2-5 Detection Piping The aging mechanism of SCC for this
[13]
piping is managed by the Plant Chemistry Program and One Time Inspection Program.
Page 5 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Primary The drywell-to-suppression chamber Section 4.6.4 containment vent line bellows and primary Section 4.6.5
- Bellows, containment process penetration Section 2.4.13 Moisture bellows are in-scope for License Table 2.4.13-1 Barriers, Seals, Renewal and required a TLAA Table 3.5.2-13 and Gaskets evaluation for fatigue. Primary
[14]
containment moisture barriers, seals, and gaskets are in-scope for License Renewal and managed by the Primary Containment In-Service Inspection Program and the 10 CFR 50, Appendix J Program.
Galvanic Galvanic corrosion and selective For galvanic corrosion:
Corrosion and leaching are included as aging 3.2.1-y Tables Leaching Aging mechanisms requiring management 3.2.2-y Tables Mechanisms consistent with the GALL. AMPs are 3.3.2-y Tables
[15]
assigned to manage these AERMs.
3.4.2-y Tables For selective leaching:
3.2.2-y Tables 3.3.2-y Tables 3.4.2-y Tables Aging The Structures Monitoring Program Appendix B2.1.31 Management of manages aging effects for structural Table 3.3.2-18 Structural components and not pipinglfittings. For Table 3.3.2-13 Components example, piping embedded in concrete Section 2.3.3.6, Table 3.3.2-6,
[16.1]
or encased in guard pipes in-scope for and Table 3.5.2-5 License Renewal are managed as Section 2.4.13.d and Table follows:
3.5.2-13 Wells and Domestic Water System concrete embedded valves and pipe:
One Time Inspection Program Radwaste Solid and Liquid System concrete embedded pipe: One Time Inspection Program Portion of the fuel oil transfer pipe passing through the Access Tunnel encased in a fire protection guard pipe: Fuel Oil Chemistry and One Time Inspection Programs. The guard pipe (fire barrier) is covered in the Fire Protection Program.
Drywell penetrations, including those with a guard pipe between the hot process line and penetration nozzle:
10 CFR 50 Appendix J Program.
Page 6 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Aging Thermal sleeves are included in the Table 3.1.2-2 Management of Reactor Pressure Vessel Internals and Table 3.1.2-3 Thermal Sleeves Reactor Pressure Vessel Systems.
[16.2]
Aging effects are not managed by the Structures Monitoring Program or the Primary Containment In-Service Inspection Program. AMPs include Chemistry Program, BWR Vessel Internals Program, BWR Feedwater Nozzle Program, and BWR Stress Corrosion Cracking Program.
External and Both external and internal aging effects Appendix B2.1.23 Internal Aging and environments, consistent with the Appendix B2.1.32 Effects GALL, are identified in the LRA. Aging Management effects requiring management were
[17.1 & 46.2]
assigned to the aging management program(s) most effective for mitigation and/or inspection of the aging effect.
For example, System Condition Monitoring is only relied upon for external aging effects as it performs periodic external visual inspections.
Other programs are used to manage internal aging effects such as the One Time Inspection Program.
Preventive A plant specific AMP for preventive None Maintenance maintenance is not included in the LRA.
AMP Individual preventive maintenance tasks
[17.2]
relied upon for AMP implementation are included as part of the respective AMP.
Boric Acid Not applicable to Monticello (PWRs None Corrosion AMP only).
[17.3]
Further The Further Evaluation Recommended Table 3.1.1 Evaluation column concludes "Yes' or "No".
Table 3.2.1 Recommended Where "Yes" is stated, a reference to Table 3.3.1 Column in the the appropriate LRA section where Table 3.4.1 Aging additional evaluation details can be Table 3.5.1 Management found is included. Where uNo" is stated, Table 3.6.1 Evaluations additional details and bases can be Summary Tables found in the Discussion column.
[18]
Aging Management Programs:
Ten Program The ten elements recommended in Appendix B1.1 Elements Appendix A of the GALL for Appendix B2.1
[19]
demonstrating AMP effectiveness have Appendix B3 been addressed for all LRA AMPs including the plant specific programs.
Page 7 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
New Aging Six new aging management programs B2.1.6 Management will be developed and implemented, B2.1.15 Programs consistent with the GALL, to manage B2.1.16
[20]
specific aging effects during the period B2.1.21 of extended operation, they are:
B2.1.23 Bus Duct Inspection, B2.1.30 Electrical Cables & Connections Not Subject to 10 CFR 50.49, Environmental Qualification Requirements, Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, Inaccessible Medium Voltage (2kV to 34.5kV) Cables Not Subject to 10 CFR 50.49 EQ Requirements, One Time Inspection, and Selective Leaching of Materials.
Flux Detector Not part of the Monticello design (PWRs None Thimble Tube only).
[211 USAR The Updated Safety Analysis Report Appendix A2.1 Supplement and (USAR) supplement for each AMP is Appendix B2.1 AMP Consistency identical to the AMP description
[22]
contained in the LRA and provides sufficient detail as required by SRP Section 3.1.2.4.
GALL and A comparison of Monticello AMPs to Appendix B2 Monticello AMP GALL recommended AMPs is included Comparison in the LRA. A basis is provided for each
[231 GALL AMP that was not adopted.
BWRVIP Applicable guidelines issued by the Appendix B2.1 Guidelines BWR Vessel Inspection Project
[24]
(BWRVIP) have been used in various aging management programs to establish inspection and evaluation activities. Adopted guidelines are compared to those recommended by the GALL throughout the AMP descriptions.
BWRVIP BWRVIP Applicant Action Items Appendix B1.6 Applicant Action applicable to Monticello have been Items addressed as described in the LRA.
[25]
Page 8 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
In-Service The scope of ASME Section Xi Aging Appendix B2.1.2 Inspection (ISI)
Management Programs is defined, per Appendix B2.1.26 Relief Requests 10 CFR 50.55(a). The LRA does not Appendix B2.1.28
[26]
reference code cases and relief requests (except for a discussion on risk informed ISI). The LRA also states these code cases and relief requests are not exceptions to GALL.
Buried Piping The Buried Piping & Tanks Inspection Appendix B2.1.5 and Tank Program requires buried piping, tanks, Inspections and conduit inspections to be inspected
[27]
when uncovered. Additionally, the program requires these inspections be performed every ten years.
Selective Hardness testing will be performed in Appendix B2.1.30 Leaching addition to visual inspection, where
[28]
practical, to detect the presence of selective leaching. Other enhanced inspection techniques are used where hardness testing is not practical.
One-Time The One Time Inspection Program is a 3.2.1-y Tables Inspection new plant program, consistent without 3.2.2-y Tables Program exception, to the recommendations of 3.3.2-y Tables
[29]
NUREG-1801 ChapterXI, Program 3.4.2-y Tables XI.M32. The use of the One Time Inspection Program in the AMR tables was applied consistently with GALL.
Inspection Components selected for inspection are Appendix B2.1.23 Methods of the those most susceptible to aging effects One-Time based on time in service, materials, Inspection operating conditions, environment, and Program operating experience consistent with
[30]
the recommendations of NUREG-1801 Chapter Xl, Program XL.M32. ASME Section XI inspection techniques are used such as volumetric testing.
Augmented Not part of the Monticello design (PWRs None Inspection of only).
Steam Generator Shell Assemblies
[31]
Small Bore Small bore piping, not covered by Appendix 82.1.23 Piping ASME Section XI aging management
[32]
programs, is included in the One Time Inspection Program, which uses ASME Section XI inspection techniques such as volumetric testing.
Page 9 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Cast Austenitic Examinations are performed on CASS Appendix B2.1.33 Stainless Steel components inside the reactor pressure (CASS) vessel as part of the Thermal Aging &
Components Neutron Irradiation Embrittlement of Subject to Loss Cast Austenitic Stainless Steel (CASS) of Fracture Program. Examination techniques Toughness include ultrasonic volumetric (UT),
[33]
surface, and visual. Consistent with the GALL, examination requirements are based on ASME Section Xi as enhanced by applicable BWRVIP guidelines.
AMP Inspection Consistent with the GALL, specific AMP Appendix B2.1 Frequencies inspection frequencies are included in
[34 and 35]
the LRA (e.g., buried tank and pipe inspections every 10 years) or noted by reference to the applicable standards and guidelines used to establish inspection frequencies (e.g., ASME Section Xl and BWRVIP guidelines).
No exceptions to GALL inspection frequencies are noted in the LRA.
Reactor Vessel The Reactor Vessel Surveillance Appendix B2.1.29 Surveillance Program is an existing program that will Program be enhanced to be consistent with the
[36]
GALL. Monticello is part of the BWRVIP Integrated Surveillance Program (ISP) for monitoring reactor vessel loss of fracture toughness.
Monticello intends to follow the guidelines of BWRVIP-116, which is currently under review by the NRC.
BWR Vessel The BWR Vessel Internals Program will Appendix B2.1.12 Internals Aging be enhanced, with an exception, to the Management recommendations of the GALL. The Program one exception is a later version of the
[37]
BWR Chemistry Guidelines (BWRVIP-130) has been adopted by Monticello.
Time-Limited Agin Analyses (TLAA):
Evaluation of TLAAs evaluated by Monticello were Table 4.1-1 TLAAs identified by reviewing the CLB, Section 4.0
[38.1 thru 38.4]
NUREG-1800, the GALL, BWR Owners Group Technical Reports, NEI 95-10, and other utility LRA submittals.
Results are summarized in the LRA and applicable TLAAs are described in detail, including a summary of the analysis, acceptance criteria, and results.
Page 10 of 12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Neutron The impact of extended operation (54 Section 4.2.1 Embrittlement of
'effective full power years' EFPY) on Table 4.2.1-1 the Reactor Upper Shelf Energy (USE) and Section 4.2.2 Pressure Vessel Adjusted Reference Temperature (ART)
Table 4.2.2-1
[39]
was determined. Material data includes Table 4.2.2-2 both Monticello specific data and industry material test results.
Reactor Pressure The calculations associated with the Section 4.2.5 Vessel P-T Limits reactor pressure vessel Pressure-
[401 Temperature limits are a TLAA and have been evaluated for the effects of extended operation. The Adjusted Reference Temperature (ART) remains essentially unchanged.
Plant Unique Results of the TLAA review are Table 4.1-1 TLAAs summarized in the LRA. Plant unique
[41 & 41.1]
TLAAs identified from the CLB review include the RCIC and HPCI turbine exhaust penetration fatigue analysis and Reactor Building Crane load cycles analysis.
Fatigue Calculated Cumulative Usage Factors Section 4.3.1 Monitoring (CUF) remain < 1.0 with reactor coolant Section 4.5 Program environment effects included for all Appendix A3.2
[42.1 thru 42.4]
locations specified in NUREG/CR-6260 Appendix A3.7 for older vintage BWRs.
Appendix B3.2 Plant transients, projected to the end of Table A3.7-1 extended operation, were used in the fatigue analysis. The list is included in the LRA. Periodic updates are performed, as part of the Metal Fatigue of the Reactor Coolant Pressure Boundary Program, to confirm projections remain conservative and to manage the CUF. The program is not used to manage other aging effects, such as cracking.
Pump Flywheel Not applicable TLAA at Monticello.
None TLAA
[43]
Concrete Not applicable TLAA at Monticello.
Table 4.1-1 Containment Tendon Prestress
[44]
General:
Environmental The LRA includes an Environmental Appendix E Report Report as required by 10 CFR 51.53(c).
[45]
Page 11 of12 Rev 0
APPROACH TO LICENSE RENEWAL TOPICS Topic Approach LRA Section(s)
Scope of Aging The scope of AMPs was appropriately Appendix 82.1.
Management defined consistent with the GALL and Programs with the types of inspections and control E46.1 & 3]
activities included in each AMP. For example, the Flow-Accelerated Corrosion (FAC) Program manages loss of material due to flow accelerated corrosion but does not manage cracking. The program is based on appropriate industry guidelines and predictive tools for selecting inspection locations. See response to Item 17 for further details.
AMR Materials Material types were identified based on Section 3.0.8.2
[46.4 & 47.1 thru equipment design and procurement 3.1.2-y Tables 47.3]
specifications, drawings, vendor 3.2.2-y Tables technical manuals, piping specifications, 3.3.2-y Tables and select walk downs. Material types 3.4.2-y Tables are identified in the Aging Management 3.5.2-y Tables Review tables to a comparable level of 3.6.2-y Tables detail as the existing and draft revision of GALL. There is no cast iron in the Reactor Coolant System.
Steam Generator Not applicable to Monticello (PWRs None Integrity and only).
Boric Acid Corrosion AMPs
[46.5 & 46.61 Component Component types evaluated on a 3.1.2-y Tables Types system and structure basis are itemized 3.2.2-y Tables
[48.1 thru 48.4]
in the LRA. Component types are 3.3.2-y Tables consistent with the breakdown and level 3.4.2-y Tables of detail included in the existing and 3.5.2-y Tables draft revision of GALL.
3.6.2-y Tables License License commitments were included in Cover Letter Commitments an itemized list attached to the LRA
[49]
transmittal letter.
Intended Intended functions applied at the Table 2.1-1 Functions component level are itemized in the
[50]
LRA. Functions were established at sufficient detail to correlate the component to the associated system or structure function(s), confirm in-scope applicability relative to 10 CFR 54.4(a),
and provide sufficient detail to support identification of aging effects requiring management.
Page 12 of 12 Rev 0