ML003751115

Analysis of Participant Comments from the December 6, 1999, License Renewal Public Workshop

ML003751115
Person / Time
Site:	PROJ0690
Issue date:	09/15/2000
From:	Charemagne Grimes NRC/NRR/DRIP/RLSB
To:	Lochbaum D, Walters D Nuclear Energy Institute, Union of Concerned Scientists
Dozier J, NRR/RLSB 415-1014
References
Download: ML003751115 (56)

Text

September 15, 2000 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708

SUBJECT:

Mr. David Lochbaum Union of Concerned Scientists 1707 H Street, NW, Suite 600 Washington, DC 20006-3919 ANALYSIS OF PARTICIPANT COMMENTS FROM THE DECEMBER 6, 1999, LICENSE RENEWAL PUBLIC WORKSHOP Gentlemen:

The staff of the U.S. Nuclear Regulatory Commission (NRC), with the assistance of Argonne and Brookhaven National Laboratories, has completed the analysis of participant comments from the December 6, 1999, License Renewal Workshop. Enclosed is a copy of the report.

The workshop was attended by over one hundred people. Altogether, 33 individuals spoke and/or made comments during the workshop; 12 individuals were from NRC and 21 were from other organizations. A total of approximately 90 comments were identified during this workshop. The NRC analysis of the stakeholder comments are provided in Section 11 of the report. The analysis of the stakeholder comments indicated that most of them were already incorporated or addressed by the GALL report. The remaining items were further evaluated and incorporated into the August version GALL report, if appropriate.

We will be holding another public workshop on Monday, September 25, 2000, from 8:30 a.m. to 4:00 p.m. in the NRC auditorium to discuss the improved license renewal guidance documents and facilitate the development of additional public comments. We look forward to working with you and other stakeholders to develop constructive comments that will improve the safety benefits, effectiveness and efficiency of the license renewal process. If you have any questions regarding this matter, please contact Jerry Dozier at 301-415-1014.

Sincerely,

/RA/

Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690

Enclosure:

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"UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 15, 2000 Mr. Douglas J. Walters Mr. David Lochbaum Nuclear Energy Institute Union of Concerned Scientists 1776 I Street, NW, Suite 400 1707 H Street, NW, Suite 600 Washington, DC 20006-3708 Washington, DC 20006-3919

SUBJECT:

ANALYSIS OF PARTICIPANT COMMENTS FROM THE DECEMBER 6,1999, LICENSE RENEWAL PUBLIC WORKSHOP Gentlemen:

The staff of the U.S. Nuclear Regulatory Commission (NRC), with the assistance of Argonne and Brookhaven National Laboratories, has completed the analysis of participant comments from the December 6, 1999, License Renewal Workshop. Enclosed is a copy of the report.

The workshop was attended by over one hundred people. Altogether, 33 individuals spoke and/or made comments during the workshop; 12 individuals were from NRC and 21 were from other organizations. A total of approximately 90 comments were identified during this workshop. The NRC analysis of the stakeholder comments are provided in Section 11 of the report. The analysis of the stakeholder comments indicated that most of them were already incorporated or addressed by the GALL report. The remaining items were further evaluated and incorporated into the August version GALL report, if appropriate.

We will be holding another public workshop on Monday, September 25, 2000, from 8:30 a.m. to 4:00 p.m. in the NRC auditorium to discuss the improved license renewal guidance documents and facilitate the development of additional public comments. We look forward to working with you and other stakeholders to develop constructive comments that will improve the safety benefits, effectiveness and efficiency of the license renewal process. If you have any questions regarding this matter, please contact Jerry Dozier at 301-415-1014.

Sincerely, Christopher I. Grimes, Chief License Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Project No. 690

Enclosure:

As stated cc w/encl: See next page

NUCLEAR ENERGY INSTITUTE Project No. 690 cc:

Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, D.C. 20585 Mr. Michael S. Tuckman Duke Energy Corporation Mail Stop EC-07H P.O. Box 1006 Charlotte, NC 28201-1006 Mr. Robert Gill Duke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC 28201-1006 Mr. Paul Gunter Director of the Reactor Watchdog Project Nuclear Information & Resource Service 1424 16' Street, NW, Suite 404.

Washington, DC 20036 Mr. James P. Riccio Public Citizen's Critical Mass Energy Project 211 Pennsylvania Avenue, SE Washington, DC 20003 National Whistleblower Center 3238 P Street, N.W.

Washington, DC 20007-2756 Mr. Charles R. Pierce Southern Nuclear Operating Co.

40 Inverness Center Parkway BIN B064 Birmingham, AL 35242 Mr. Garry Young Entergy Operations, Inc.

Arkansas Nuclear One 1448 SR 333 GSB-2E Russellville, Arkansas 72802 Mr. Richard P. Sedano, Commissioner State Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601

Analysis of Participant Comments from the December 6, 1999, License Renewal Public Workshop Prepared by A. B. Hull, D. R. Diercks and Yung Y. Liu Energy Technology Division Argonne National Laboratory Argonne, Illinois 60439 and Jerry Dozier Office of Nuclear Reactor Regulation Nuclear Regulatory Commission Washington, D.C. 20555 September 2000

Table of Contents Sect.

Topic Page No.

Table of Contents 2

Workshop Agenda 3

Acronyms 4

1 Executive Summary 6

2 Participant Affiliation 7

3 Participant Comments Identified in the Transcript 10 (Sorted by Organization) 4 Comments in the NEI Opening Remarks 11 5

Comments in the UCS Opening Remarks 12 6

Overview of GALL, SRP-LR, NEI 95-10 13 6.1 Summary of NRC Presentation 6.2 Participant Comments 7

Examples of Regulated Programs 15 7.1 Summary of NRC Presentation 7.2 Participant Comments 8

Examples of Reactive Programs 19 8.1 Summary of NRC Presentation 8.2 Participant Comments 9

Examples of General Practice Programs 21 9.1 Summary of NRC Presentation 9.2 Participant Comments 10 Closing Comments from Participants 23 11 Analysis of Participant Comments 26 12 References 51 September 2000 2

License Renewal Public Workshop December 6, 1999 AGENDA Time Speaker &

Topic T-Pg.*

Affiliation 8:30am Chris Grimes, NRC Introduction (Moderator) 6 8:35am Sam Collins, NRC Opening Remarks (Keynote) 6 8:45am Doug Walters, NEI Opening Remarks 16 9:00am David Lochbaum, UCS Opening Remarks 20 9:15am Sam Lee, NRC Overview of GALL, SRP-LR, DG on 36 NEI 95-10 10:am (Break) 59 10:30am Barry Elliot, NRC Examples of Regulated Programs 61 11:57am (Lunch) 1:15pm Stephanie Coffin, NRC Examples of Reactive Programs 121 2:15pm Jit Vora, NRC Examples of General Practice 155 Programs 3:00pm (Break) 3:15pm Chris Grimes, NRC Participant Comments & Questions 179 4:00pm Chris Grimes, NRC Summary & Conclusions 203 4:05pm Chris Grimes, NRC Meeting Adjourned 205

• as shown in official print transcript of meeting September 2000 3

Acronyms (Also, see NUREG NRC Collection of Abbreviations (NUREG-0544, Rev. 4) http://www.nrc.gov/NRC/NUREGS/SR0544/R4/srO544.htm and NRC Organizational Abbreviations http://www.nrc.gov/NRC/PHONE/org.html)

ACRONYM DEFINITION ACRS Advisory Committee on Reactor Safeguards AEP American Electric Power AMP Aging Management Program ANL Argonne National Laboratory ANS American Nuclear Society ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials BNL Brookhaven National Laboratory BWRVIP Boiling Water Reactor Vessels Internal Program CLB Current Licensing Basis CNS Constellation Nuclear Services CP&L Carolina Power & Light Co.

CRMP Configuration Risk Management Program DSA Diagnostic Self-assessment EPM Electric Power Monthly EPRI Electrical Power Research Institute EQ Environmental Qualifications FSAR FinalSafety Analysis Report GALL Generic Aging Lessons Learned GE General Electric GEIS Generic Environmental Impact Statement GL Generic Letter INEEL Idaho National Engineering &

Environmental Laboratory ISI In-service inspections IST In-service testing ITTA International Technology & Trade Association, Inc.,

Organizational affiliation of workshop attendee IWE Code designation for a chapter in Section XI in the ASME code that applies to Class MC and metallic liners inspection requirements.

IWL Code designation for a chapter in Section XI in the ASME code that applies to reinforced and prestressed concrete inspection requirements.

LSS Licensing Support Services, organizational affiliation of workshop attendee LER Licensee Event Report LLNL Lawrence Livermore National Laboratory September 2000 4

MIC Microbiologically induced (or influenced) corrosion MRP Materials Research Project Program NEI Nuclear Energy Institute NGO Nongovernmental Organization NIRS Nuclear Information and Resource Service NPAR Nuclear Plant Aging Research NRC Nuclear Regulatory Commission NRC/DSSA NRC Division of Systems Safety and Analysis NRC/NMSS/DWM NRC Office of Nuclear Material Safety and Safeguards, Division of Waste Management NRC/NRR NRC's Office of Nuclear Reactor Regulation NRC/NRR/DE NRC/NRR/Division of Engineering NRC/NRR/DE/EMCB NRC/NRR/DE Materials and Chemical Engineering Branch NRC/NRR/DE/EMEB NRC/NRRIDE Mechanical and Civil Engineering Branch NRC/NRR/DRIP NRC/NRR/Division of Regulatory Improvement Programs NRC/NRR/DRIP/RLSB NRC/NRR/DRIP License Renewal and Standardization Branch NRC/OGC NRC Office of the General Counsel NRC/RES NRC Office of Nuclear Regulatory Research NRC/RES/DET NRC/RES Division of Engineering Technology NRC/RES/ERAB NRC/RES/DET Engineering Research Applications Branch NRC/RII NRC Region 11--Atlanta, Georgia NUREG Nuclear Regulatory Guide NUSIS NUS Information Services, a branch of SCIENTECH ORNL Oak Ridge National Laboratory PDR Public Document Room PM Preventive maintenance PNNL Pacific Northwest National Laboratory PP&L Pennsylvania Power & Light Co.

PTS Pressurized thermal shock RG&E Rochester Gas & Electric SCE&G South Carolina Electric & Gas Co.

SER Safety evaluation report SNL Sandia National Laboratory SRP-LR Standard Review Plan for License Renewal SSCs Systems, structures, and components TLAA Time Limited Aging Analysis UCS Union of Concerned Scientists VIP Vessel Internals Program VT2 Examination, per Sect. XI, including pressure boundary WEPCO Wisconsin Electric Power Co.

September 2000 5

1.

EXECUTIVE

SUMMARY

Per staff requirements memorandum (SRM) dated August 27, 1999, the Commission approved the staffs recommendation and directed the staff to focus the staff review guidance in the Standard Review Plan (SRP-LR) for license renewal on areas where existing programs should be augmented for license renewal. The staff would develop a "Generic Aging Lessons Learned (GALL)" report which evaluates existing programs generically to document the basis for determining when existing programs are adequate without change and when existing programs should be augmented for license renewal. The GALL report would be referenced in the SRP-LR as a basis for determining the adequacy of existing programs. Also, the staff is directed to seek stakeholder's participation in the development of the GALL report. The public workshop held at NRC on December 6, 1999 was the first outreach effort to obtain feedback from stakeholders on the NRC development of the GALL report and the revised guidance for the conduct of review of license renewal applications. Copies of the draft GALL report were distributed at the Workshop.

Approximately 110 people attended the workshop from organizations representing industry, government, and the general public, The NRC staff made several presentations that were designed to elicit stakeholder input on the NRC vision of the GALL report, the SRP-LR, and the draft Regulatory Guide on NEI 95-10. The workshop discussion was based on dividing existing programs into 3 groups: regulated aging management programs (e.g., programs required by regulations); reactive aging management programs (e. g., programs evolved from plant operating experience); and general practice aging management programs (e.g., preventive maintenance, chemistry control, crane inspections, etc.).

Altogether, 33 individuals spoke and/or made comments during the workshop; 12 individuals were from NRC and 21 were from other organizations (see Table 3). A total of approximately 90 comments were identified (shown in the following sections), and the recurring themes appear to involve the following:

Credit for existing programs for license renewal Regulatory and/or attribute creep Adequacy of mechanisms for public review Stakeholder comments follow the order of the topical sessions of the workshop. All comments made by stakeholders are sorted in alphabetical order and listed in Section 11 of this report, along with the NRC analysis of the stakeholder comments.

The analysis of the stakeholder comments indicated that most of them were already incorporated or addressed by the GALL report. The remaining items were further evaluated and incorporated into the August version GALL report, if appropriate.

September 2000 6

2.

PARTICIPANT AFFILIATION Of the 107 documented attendees, 44 were from the NRC, at least 16 participants represented power companies, 9 were from National Laboratories, one participant was from the Union of Concerned Scientists, and one participant from the Nuclear Energy Institute. The participant list is shown alphabetically as follows.

ATTENDEE AFFILIATION ANAND, RAJ NRC/NRR/DRIP/RLSB ANKRUM, AL PNNL BAGCHI, GOUTAM NRC/NRR BATEMAN, WILLIAM NRC/NRR/DE BOARDMAN, JOHN NRC/RES BOIVIN, JOE Vermont Yankee BOWMAN, MARVIN Constellation Nuclear BURTON, WILLIAM NRC/NRR/DRIP BYRD, RON Entergy CAREY, JOHN EPRI CHANG, T.Y.

NRC/RES/DET CHAPMAN, NANCY Bechtel CHENG, THOMAS NRC/NRR/DE COFFIN, STEPHANIE NRC/NRR/DE/EMCB COLAIANNI, PAUL Duke Power COLLINS, SAM NRC/NRR CONNOR, LYN DSA (Doc-Search Associates)

DAVIS, JIM NRC/NRR/DE DOROSHUK, BARTH CNS/BG&E DUDLEY, NOEL NRC/ACRS DYLE, ROBIN Inservices Engineering ELLIOT, BARRY NRC/NRR!DE/EMCB FALK, BOB CNS FEHRMAER, JOHN INEEL FINDLAY, DON CNS FLYTE, DAVE PP&L FRANK, MELVIN NUSIS GRATTON, CHRIS NRC/DSSA GRAVES, HERMAN NRC GRAY, JACK New York Power Authority GRIMES, CHRIS NRC/RSLB GUNTER, PAUL NIRS.

GURICAN, GREG GPUN, Inc.

GUTH, JOHN SNL HARTWIG, ED TVA, Brown Ferry HERMANN, ROBERT NRC/NRR/DE HISER, ALLEN NRC/NRR September 2000 7

HOANG, HOA GE HOFFMAN, STEVE NRC/NRR HORVATH, DAVE ILLLUEngineering HOU, SHOU-NIEN NRC/NRR HUDSON, GREG INEELJBBWI HUSTON, ROGER LSS (Licensing Support Services)

JONES, A. J.

National Catholic Reporter JULIAN, CAUDLE NRC/RII KANG, PETER J.

NRC/NRR/DRIP/RLSB KAPSALOPOULOU, A.

New Jersey Dept. of Environ. Protection KATERS, PAUL J.

EPM KOENICK, STEPHEN NRC/NRR KOO, WILLIAM NRCJNRR/DE KOZGRA, JAN CP&L KUNSEMILLER, DAVID AEP-Cook KUO, P. T.

NRC/NRR/DRIP KUORV, JANOS WEPCO LEE, ARNOLD J.

NRC/NRR/DE LEE, SAM NRC/NRRIDRIP/RLSB LINN, JOHN Southern Company LIU, WINSTON NRC/NRR/DRIP LIU, YUNG Y.

ANL LOCHBAUM, DAVE Union of Concerned Scientists MEDOFF, JAMES NRC MENOCAL, ANTONIO G.

Florida Power and Light MEYER, CHARLES Westinghouse/WOG MINIKOFF, TONY ERPA & Light MITRA, SIKHINDRA NRC/NRR/DRIP/RLSB MOORE, JANICE NRC/OGC MORANTE, RICH BNL NALLUSWAMI, M.

NRC/NMSS/DWM NGUYEN, DUC NRCINRR NICKELL, BOB EPRI O'CONNER, DAN R ORNL PAGLIA, AL SCE&G PAL, AMAR NRC/NRR/DE PARCZEWSKI, KRIS NRC/NRRIEMCB PATNAIK, PAT NRC PETROU, MANFRED German Nuclear Forum PICKENS, TERRY Northern States Power POLASKI, FREDERIC W.

PECO Energy PRASSINOS, PETE LLNL PRATO, BOB NRC/NRR/DRIP/RLSB RAY, NIHAR INEEL RICKARD, IAN ABB September 2000 8

RYAN, TOM INEELIBBWI RYCYNA, JOHN CNS SANWARWALLA, MANSOOR Sargent and Lundy SEMMLER, MIKE Duke Energy SHEMANSKI, PAUL NRC/NRR/DE/EELB SIMPSON, JOE Southern California Edison SNOW, TOM Virginia Power SO, DOMINIC AEP SOLORIO, DAVE NRC/NRR/DRIP/RLSB STENGER, DAN Hopkins and Sutter SUBUDHI, MANO BNL SULLIVAN, TED NRC/NRR/DE/EMCB SUTTON, KATHRYN Winston & Strawn TERMINELLA, FRANCIS Virginia Power VORA, J1T NRC/RES/DET WALLAR, ROBERT CNS WALTERS, DOUG NEI WANG, HAI-BOH NRC/NRRIDRIP/RLSB WEGNER, MARY S NRC/RES/ERAB WEIL, JENNY McGraw Hill WINDELL, ERIC ITTA (International Technology & Trade Assoc. Inc.)

WROBEL, GEORGE RG&E (Rochester Gas & Electric)

WRONEIWICZ, J. E.

Virginia Power WU, CHENG-IH NRC/NRR/DE/EMEB ZIMMERMAN, JAKE NRC/NRR September 2000 9

3.

PARTICIPANT COMMENTS IDENTIFIED IN THE TRANSCRIPT AFFILIATION ATTENDEE Pg. No. in Official Transcript AEP SO, DOMINIC 80-82,99-100, 174-177 BNL MORANTE, RICH 98, 139-140 CNS BOWMAN, MARVIN 128-129, 142, 147-148, 168-169, 197 198 CNS RYCYNA, JOHN 165-166 Duke Power COLAIANNI, PAUL 53, 115-116, 118, 164,167,177, 179 80, 182-185 EPRI CAREY, JOHN 97, 135, 154 EPRI NICKELL, BOB 76-78, 96-97 ERPA & LIGHT MINIKOFF, TONY 171-172 Florida Power and Light MENOCAL, ANTONIO 132, 144-145, 161 GPUN, Inc., TMI GURICAN, GREG 60,150-152 Hopkins and Sutter STENGER, DAN 49, 90, 91,100-101 INEEL RAY, NEAL 53-55, 68-69 Inservices Engineering DYLE, ROBIN 82-83, 187, 196 NEI WALTERS, DOUG 16-20, 34, 51-52, 65-66, 83-86, 92, 109-113, 123-125, 138-139, 182, 199-203 New York Power Authority GRAY, JACK 189-190 Northern States Power PICKENS, TERRY 102 NRC/NRR/DE BAGCHI, GOUTAM 81-82, 86, 91, 98, 101 NRC/NRR/DE/EEIB SHEMANSKI, PAUL 87-89,112-117 NRC/NRR/DE/EMCB COFFIN, STEPHANIE 121-153, 162-163 NRC/NRR/DE/EMCB DAVIS, JIM 130, 137-138 NRC/NRR/DE/EMCB ELLIOT, BARRY 16,47, 52, 61-77 NRC/NRRIDE/EMCB HERMANN, ROBERT 133-134, 141-142, 148-149, 166-168 NRC/NRRIDE/EMCB PARCZEWSKI, CHRIS 161-162 NRC/NRRIDRIP/RLSB GRIMES, CHRIS Moderator: comments throughout NRC/NRRIDRIP/RLSB LEE, SAM 36-52, 61, 67, 80-83, 90, 99, 103-5, 126, 132, 138-9, 142, 152, 163-164, 171,180-182, 185 NRC/NRR/DRIP/RLSB LIU, WINSTON 177 NRC/NRR/OD COLLINS, SAM 6-16, 45-46 NRC/RES/DET VORA, JIT 53-55, 155-160, Nuclear Information &

GUNTER, PAUL 46-48, 59-60, 73-76 Resource Service PECO Energy POLASKI, FRED 106-108, 191-195 Sargent and Lundy SANWARWALLA, 71,114,116,172-173,186-187 MANSOOR Southern California Edison SIMPSON, JOE 191 Union of Concerned LOCHBAUM, DAVE 20-27, 35, 44-46, 57-58, 79, 98, 127 Scientists 128, 133, 149-150, 188-189 September 2000 10

4.

COMMENTS IN NUCLEAR ENERGY INSTITUTE (NEI) OPENING REMARKS SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Walters NEI 4.1 GALL is outgrowth of policy issue discussed in SECY 16 summer'99 concerning credits for existing programs99-148 for license renewal.

Walters NEI 4.2 What process controls will be used to prevent 17 attribute creep, or attribute shrink? How will stakeholder disagreements over the scope of these attributes be resolved?

Walters NEI 4.3 If GALL says further evaluation is needed, the basis GALL 18 needs to be well documented.

Walters NEI 4.4 Thorough review of GALL by all stakeholders is GALL 19 necessary. The quality should not be sacrificed for the schedule.

Walters NEI 4.5 The purpose of GALL should be to identify where GALL 19-20 aging effects on the structures and components within the scope of renewal that are not adequately managed by existing CLB programs.

• Throughout this report: ISS# is the comment identifier, DOC is the document to which the comment applies, T-Pg. references the page number that the comment is found in the December 6, 1999 License Renewal Workshop Official Transcript.

September 2000 11

5.

COMMENTS IN UNION OF CONCERNED SCIENTISTS (UCS) OPENING REMARKS

(

Reference:

"Existing Aging Management Programs for License Renewal", 11 viewgraphs)

SPEAKER AFFIL ISS#

COMMENTS DOC.

T-Pg.

Lochbaum UCS 5.1 Different plants are assumed identical credit for GALL 25 varying conformance with CLB; no credit should be given for programs that do not exist; "one size fits all" approach should not be used unless proved to be bounding.

Lochbaum UCS 5.2 Approach to GALL seems one-directional, with 21-26 apparently simplifying statements to reduce the level of effort, reducing the testing intervals for much equipment seems contradictory with increasing license renewal activities (license renewal cannot proceed in a vacuum)

Lochbaum UCS 5.3 Approach to aging management assumes all licensees 25 will meet all requirements & implement all administrative programs; penalties should be very harsh for licensees failing to conform to conditions of their licenses.

Lochbaum UCS 5.4 NRC appears to use GALL to trim scope of future GALL 25 license renewal application reviews. Findings must trigger proper extent-of-condition evaluations.

Lochbaum UCS 5.5 No credit for programs that do not exist (such as GALL 21 electrical bus inspection program)

Lochbaum UCS 5.6 Boilerplate is not appropriate for nuclear safety 10 CFR 22-23 documents. Design and license can't be assumed to 54.29 be sacrosanct.

September 2000 12

6.

OVERVIEW OF GALL, SRP-LR, AND REGULATORY GUIDE ON NEI 95-10 6.1

SUMMARY

OF NRC PRESENTATION NRC described the NRC vision of the GALL report, the SRP-LR and the draft Regulatory Guide on NEI 95-10. NRC also described the groupings of the existing aging management programs and the attributes used in the GALL report and SRP-LR for evaluation of the aging management programs. The ten attributes of aging management programs are:

Scope of program Preventive actions Parameters monitored or inspected Detection of aging effects Monitoring and trending Acceptance criteria Corrective actions Confirmation process Administrative Controls Operating Experience 6.2 PARTICIPANT COMMENTS September 2000

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Walters NEI 6.1 What will be NRC's responsiveness in GALL 34 incorporating participant comments and modifying the GALL report?

Lochbaum UCS 6.2 Given the draft schedule (on vugraf) for 35 approving GALL and SRP-LR, is it possible that new license renewal applications will not be accepted until rules are better defined?

Lochbaum UCS 6.3 GALL should perhaps acknowledge a more GALL 44-46 expansive resource base (aging-related reports written by other organizations and authors (such as UCS, NIRS, Public Citizen's, Bob Pollard, Jim Riccio))...the perception is that stakeholders are being patronized.

Gunter NIRS 6.4 Validity of data treatment techniques, especially Part 50, 46-48 related to crack growth rate mechanisms, 10-pt intergranular stress corrosion cracking.... industry program and the regulator need a better understanding of crack growth rate mechanisms.

Stenger Hopkins &

6.5 Are all 10 stipulated attributes necessary for an GALL 49 Sutter existing program to be adequate for license renewal?

13

September 2000 Walters NEI 6.6 How was the experience from the review of GALL 51-52 Calvert and Oconee integrated into the preparation of GALL? How was the SER integrated or used in preparation of GALL?

Colaianni Duke 6.7 Referencing procedure in GALL could perhaps be GALL 53 Power improved and made more consistent (example of cables area).

Ray INEEL 6.8 Are the NPAR findings addressed and referenced?

GALL 53-55 Does GALL address new international findings of cracking or leakage?

Lochbaum UCS 6.9 Mechanism of proposed appeal process (3-4 tiered 2.206 57-58 appeal process), if a stakeholder didn't agree with information on some aging issue or some license renewal issue - process should be fairer for public appeal.

14

7.

EXAMIPLES OF REGULATED PROGRAMS 7.1

SUMMARY

OF NRC PRESENTATION NRC presented examples of regulated aging management programs, i.e., programs required by regulations or subject to other regulatory requirements such as technical specifications.

Examples of regulated aging management programs include environmental qualification of electrical equipment (50.49), maintenance rule (50.65), inservice inspection (50.55a),

containment inservice inspection (50.55a), containment leak rate test (50, Appendix J), quality assurance (50, Appendix B), reactor vessel integrity (50, Appendices G and H), fire protection (50.48), and steam generator tube inspection (technical specification).

7.2 PARTICIPANT COMMENTS SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Gunter NIRS 7.1 When will GALL be in the PDR?

GALL 59-60 Gurican TMI 7.2 Is there special consideration in the development of GALL, 60 the SRP-LR and/or the GALL report for non-SRP SRP-LR licensees, and also licensees who are not ISTS holders?

Walters NEI 7.3 What standard are you applying to determine that GALL 65 ISI is not adequate? Where ISI may not be adequate, does GALL identify enhancements needed?

Walters NEI 7.4 Is it correct that 10 CFR Part 50, Appendix H 10 CFR 66 expires after forty-yr. plant operating life?

Part 50, App. H Ray INEEL 7.5 Some plants, based on their current surveillance 10 CFR 68-69 capsule program, should be viable to 60 years Part 50, without making any significant change, and should App. H be able to qualify or disqualify various screening criteria...complications with possible variability in PTS data.

Sanwarwalla Sargent 7.6 What is the balance in considering plant-specific GALL 71

& Lundy operating experience and GALL related to future licensing renewal procedures?

Gunter NIRS 7.7 What will be the interval of withdrawing and GALL 73-76 testing surveillance capsules when going for a 20yr extension? Will GALL address this?

Nickell EPRI 7.8 Scope of components that need to be evaluated for 10 CFR 76-78 aging management... For materials beyond the Part 50, conventional beltline, will GALL have guidelines

PTS, to help the applicant make a decision about how to. App. G do calculations to show that those additional materials are not limiting?

September 2000 15

Lochbaum UCS 7.9 How are changes that are made to the existing

FSAR, 79 programs or new programs that are developed for 10 CFR aging, captured within the licensing basis? The Part 50 NRC staff has indicated that the FSAR might be the best repository for that information. The industry has suggested that the existing license commitment tracking systems might be the more appropriate vehicle. "I guess if we are voting on that, we would vote on the FSAR, and following 50.71 (e), that seemed to be a good time to follow that rule."

So AEP 7.10 Referencing the discussion concerning in-service GALL 80-82 inspection program and Attribute Number 4, where it was mentioned that detection of aging effects are not being taken care of by some of these traditional regulator programs. What direction or what additional augmented examples are considered?

Will the GALL report give further guidance as far as what components will be examined? There is a question about sampling/inspection of inaccessible areas.

Dyle In-7.11 Will GALL indicate what edition of the code is 10 CFR 82-83 service used to make the assessments of the adequacy of 50 Engineer current ISI programs and to what degree do App. A

-ing augmented programs that are currently required by regulation get factored into that assessment?

Questions exist about enhancing the adequacy of the ongoing ISI. Is it clear where we start with the review and what the comments ought to be? It would be valuable to the ASME committees that might work on trying to resolve this.

Walters NEI 7.12 Tutorial on how the maintenance rule fits into a GALL 83-86 license renewal review. (The maintenance rule ensures functionality of equipment, the same end result that we are looking for in license renewal, and we ought to get credit for what we do under the maintenance rule).

Stenger Hopkins 7.13 Does NRC have a standard used for determining GALL 90

& Sutter whether an existing program would be modified or augmented? Is there some threshold that applies or is it up to the individual reviewer's discretion?

How does that work?

Stenger Hopkins 7.14 How could the maintenance rule program be GALL 91

& Sutter utilized for license renewal purposes?

Walters NEI 7.15 How were the 10 attributes developed; why 10, not GALL 92 15 or 6? What is it about those 10 attributes that lead to the conclusion that an enhancement is necessary?

September 2000 16

Nickell EPRI 7.16 Looking at accessible areas in order to make a GALL 96-97 determination where one might want to inspect inaccessible areas is an acceptable approach...

should avoid requiring inspection of inaccessible areas where there is no evidence of a problem in an accessible area.

Carey EPRI 7.17 IWE/IWL is sufficient for license and doesn't need ASME 97 to be augmented.

Code Lochbaum UCS 7.18 Guidelines in the '96 ASME Code should be

'96 98 considered for the license renewal review.

ASME Basically this program is acceptable, and Part Code 54.21.c.1.3.i allows somebody to look at the program results on a continuous basis, the best way to ensure containment integrity.

Morante BNL 7.19 (BNL was responsible for the GALL tables GALL 98 covering containment),... the issue of inaccessible areas is still considered open and is not resolved by following 50.55.a. That will be subject to further discussion between the NRC staff and industry.

So AEP 7.20 Clarification appreciated of use of later edition of ASME 99 the ASME code to satisfy requirements (example Code 100 cited of prestressed and post-tensioning conditions).

Stenger Hopkins 7.21 Acceptability of IWE/IWL for ASME 100

& Sutter licensing.... surprised that the SRP-LR implied

Code, 101 there was some question of cataloging what IWE Part 54 and IWL do for aging management programs, and to determine a need for any augmentation of those activities.

Pickens NSP 7.22 Prospect of plants taking credit for programs that, 102 although all designed to respond to aging or degradation in some way, may not have the same original intent.

Pickens NSP 7.23 Will GALL identify how extended aging differs so GALL 104 that operators can assess whether changes to the program are adequate to address that change?

Polaski PECO 7.24 Some regulatory programs listed by Elliot of NRC ASME 106 Energy have their basis in other codes beyond the NRC

Code, 108 regulations. If there is a determination made that ASTM

.the program or the code is not adequate >40 yr., is Code it NRC's intent to go back through the code process

& process for changing regulations and get the codes and regulations updated, to specify what 60 yr. requirements are? That would provide the ultimate stability for license renewal if the regulations and the codes address the interval out to +60 years.... and also help avoid reg. creep, more likely going through GALL with individual licensees making determinations.

September 2000 17

September 2000 Walters NEI 7.25 If a regulation is not a program, when we see 10 CFR 109 GALL, and we see an evaluation of, say, EQ, was 50.49 112 the evaluation done actually on the regulation, or was it done looking at the implementing guidance documents for the regulation and trying to assess how a program would be crafted to address that regulation? What was really reviewed and what is the evaluation really focusing on?

Walters NEI 7.26 The focus for renewal, at least on EQ, is primarily GALL 113 in the reanalysis area. Is the reanalysis accounted for in the regulation?

Sanwarwalla Sargent 7.27 Will NRC endorse the standard in the IEEE 323 IEEE 323 114

& Lundy 1983 edition (now in process of being revised) related to 40 years testing plus analysis, to extend the life of these EQ components?

Colaianni Duke 7.28 Programs related to EQ in the 10-attributes list. It GALL 115 Power appears from the GALL draft that EQ wasn' used 116 as a driver since seven of the attributes would not have to be addressed for EQ.

Sanwarwalla Sargent 7.29 For license renewal, we have gone back and done 10 CFR 116

& Lundy reanalysis to try to justify extension of the life to 50.49 60 years. Will the NRC go back and endorse the same philosophy to extend the life of components that have short lives right now?.

Colaianni Duke 7.30 License renewal was very visible focusing on 10 CFR 118 Power extension from 40 to 60 years but it is the same 50.49 practice under the current regulation that has been taking place for short-lived components outside of license renewal. Reanalysis has been done since the beginning of the regulation.

18

8.

EXAMPLES OF REACTIVE PROGRAMS 8.1

SUMMARY

OF NRC PRESENTATION NRC presented examples of reactive aging management programs that typically resulted from NRC Bulletins, Generic Letters, regulations, rules, as well as technical specifications. Examples include boric acid corrosion inspection program developed in response to GL 88-05, service water program (GL 89-13), erosion/ corrosion program (Bulletin 87-01, GL 89-08), bolting program (Bulletin 82-02), control rod drive mechanism nozzle and other closure head penetration nozzles (GL 97-01), and coating program (GL 98-04).

8.2 PARTICIPANT COMMENTS SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Walters NEI 8.1 Why doesn't GALL focus first on what NRC asked GL 89-13 123 of the licensee? For purposes of GALL, could we 125 focus on GL requests? (GL89-13 should be credited as acceptable AMP because it specifically identifies significant fouling occurring as a result of age-related in-leakage and corrosion or erosion).

Lochbaum UCS 8.2 Discussion on reactive programs implies that the GALL 127 GALL process includes either some formal 128 mechanism to review emerging issues, or that the NRC is going to stop being reactive -which? Is there a management directive that governs GALL or similar processes? Does GALL process have formal mechanism to view reactive mode output?

Bowman CNS 8.3 It is necessary for GALL to clearly define what is GALL 128 different (when there is something different) for 129 license renewal,... concerning implementation, the plant stakeholders need to understand clearly when a program can be credited for license renewal.

Menocal Florida 8.4 The section reviewed of the draft GALL report GALL 132 Power appeared to have a format based on systems and and Light then on component level - are both internal and external aging mechanisms/effects addressed for each component?

Lochbaum UCS 8.5 Would the 50.54(f) request (10/96) be an example 10 CFR 133 of a reactive program?

50.54(")

Carey EPRI 8.6 (What is necessary beyond current regulatory GALL 135 requirements?) Define other areas where existing programs required further evaluation?

Walters NEI 8.7 Does GALL focus on original scope of program GALL 138 (such as AMP) and related GLs & Bulletins? Is 139 expanded scope of a program (such as results from Calvert or Oconee license renewal) considered?

September 2000 19

Morante BNL 8.8 Additional guidelines for managing aging of Reg.

139 Category I structures (such as water control Guide 140 structures) are provided by Regulatory Guides, 1.127 such as 1.127 and provide foundation for license renewal (even though not defined as a reactive program). RegGuide 1.127 is identified for license renewal as an acceptable methodology for managing aging for water control structures.

Bowman CNS 8.9 Are existing plant inspection programs (such as GALL 142 erosion-corrosion) being examined in the context of assessing or addressing the adequacy of a particular licensee's existing programs?

Menocal Florida 8.10 What is the significance of plant-specific GALL 144 Power experience in terms of demonstrating the adequacy 145 and Light of an existing program in the aging management review process? Implementation of effective program shouldn't require additional enhancement.

Bowman CNS 8.11 Example of extended reactive program (although GALL 147 an aging management enhancement, not directly a 148 license renewal commitment) was illustrated by the modification of the existing Alloy 600 program to extend to non-pressure boundary components to provide both safety and economic improvements.

Lochbaum UCS 8.12 Another example of a GL applicable for reactive GL 88-14 149 program would be the one concerning instrument 150 error, air dryers, and continuous monitoring of moisture carryover.

Gurican TMI 8.13 How will NRC treat TLAAs (such as ref. Bull.88-Bull.

150 05, Thermal Stratification...) & EQs within the 88-11 151 license renewal application? When addressing either reactive or mandated programs under TLAA, what is NRC expectation regarding 10 attributes?

Is it correct that GALL will wind up with a revised NEI 95-10, providing guidance on license renewal applications?

Gurican TMI 8.14 Clarify the intent of the GALL report; will it result NEI 151 in revised industry guidelines? Is it thus internal 95-10 152 guidance for acceptance criteria?

Carey EPRI 8.15 MRP has substantial program examining thermal Bull.

154 stratification; unsteady thermal stratification 88-08 (unanticipated transient) in attached piping is not really aging issue. NRC has inadequate data to claim that thermal stratification events have significant environmental effects.

September 2000 20

9.

EXAMPLES OF GENERAL PRACTICE PROGRAMS 9.1

SUMMARY

OF NRC PRESENTATION NRC presented examples of general practice aging management programs (such as crane inspections, surveillance, condition monitoring, maintenance, record keeping, replacement, refurbishment); preventive maintenance (periodic preventive maintenance, predictive or planned maintenance), and environmental modification (such as water chemistry control). Plant operators have implemented many of these programs which could be credited as a general practice aging management program. Questions to be addressed include how to embrace general practice programs with good track records and how to give credit to these programs for effectively managing aging during the license renewal period. The goal of this session is to determine where credit for the existing general practice programs to manage detrimental effects of aging should be recognized, and where the existing general practice programs should be augmented to ensure confidence of program effectiveness to manage age-related degradation during both the current license period and also for the extended life consideration.

9.2 PARTICIPANT COMMENTS SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Menocal Florida 9.1 The section of the draft GALL report related to GALL 161 Power secondary plant systems recommended one-time and Light inspections to validate the chemistry control program for certain systems. (a)What was the basis for that recommendation? (b)When would it apply? (c) If the parameters are controlled, why is the one-time inspection needed?

Colaianni Duke 9.2 Hopefully routine maintenance won't be regulated GALL

164, Power although routine maintenance may indirectly affect 167 some equipment aging aspects. Regulating routine maintenance would increase regulatory creep into almost every aspect of the plant. How do you distinguish preventive maintenance from routine maintenance?

Rycyna CNS 9.3 Using air-system piping at Calvert Cliffs as an GALL 165 example, where positive operating experience has 166 been confirmed and documented on plant records, the amount of effort committed to doing age related degradation inspection will be reduced.

Plant operators should take the opportunity when doing maintenance to document positive operating experience that can subsequently be put on the license renewal application for a particular plant.

September 2000 21

Bowman CNS 9.4 Continuing question (see Issue 9.2) about overlap GALL 168 between regulatory space and preventive 169 maintenance (PM). Where it becomes complicated to credit an existing PM task, because of the regulatory burden, instead of crediting a preventive maintenance task, he suggests creating a new task that's unique to license renewal space. (example:

electrical panels). Frequent, routine maintenance should perhaps be separated from infrequent PM related to license renewal aging-specific considerations.

Minikoff ERPA &

9.5 In the draft GALL section concerning auxiliary GALL 171 Light feed water systems, pump IST was referenced.

172 Was that to look for external leakage? Normally one wouldn't associate that test with troubleshooting for passive failure or performance of passive equipment.

Sanwarwalla Sargent 9.6 When trying to take credit for certain general GALL 172

& Lundy practice programs (such as temperature monitoring 173 program), under what category would these programs fall? Would they now be regulated programs?

So AEP 9.7 Will GALL provide guidance about the extent of GALL 174 augmentation needed to demonstrate adequacy of 177 programs such as ISI and IST, which have the main objective of monitoring degradation/aging of equipment? What will be the guidelines for demonstrating, for license renewal purposes, no degradation of certain pumps and valves, no leakage in Class-I system, and a reasonable assurance of adequate equipment lasting longer than 40 years?

Colaianni Duke 9.8 During Oconee license renewal activities, new GALL 177 Power programs were usually not needed, however adding new regulatory documentation framework to existing activities drives up cost, which we 'would like to draw the line against.'

September 2000 22

10.

CLOSING COMMENTS FROM PARTICIPANTS SPEAKER AFFIL.

ISS#

COMMENTS DOC.

T-Pg.

Colaianni Duke 10.1 Will the GALL report consider the situation GALL 179 Power where the plant-specific applicants could show 180 that all the potential aging effects for a given component might not be applicable to that particular plant? Would these components then fall out of the license review process, because failures of them would be hypothetical? Is that discussion evident in the front of GALL?

Walters NEI 10.2 Are other TLAAs, besides EQ in Ch. 7 evaluated GALL 182 in GALL?

Colaianni Duke 10.3 Will all the TLAAs eventually be in the GALL

GALL, 182 Power report (for the sake of consistency)? Fatigue GSI-168 183 should be treated in the same way as EQ (ref GSI 168).

Colaianni Duke 10.4 Program description in GALL should sometimes GALL 184 Power be improved to better provide actual guidance on 185 how to monitor system integrity (example monitoring integrity of cable ground conductor, VI).

Sanwarwalla Sargent 10.5 When and how will GALL be formally issued?

GALL 186

& Lundy How frequently will it be revised?

187 Dyle Inservice 10.6 How will branches of NRC decide if an aging GALL 187 Engineer issue has been correctly resolved? What is the

-ing relationship in this program between license renewal branch and technical branches as final arbitrators?

Lochbaum UCS 10.7 Appeal rights of applicants and other general 10 CFR, 188 stakeholders. Frustrating process of submitting 2.206 189 allegations and appeals.

Gray NY 10.8 With both regulated and reactive programs, the GALL 189 Power bottom-line is to make sure that the systems, 190 Authority structures, and components will perform their intended functions, including whatever adverse aging effects may occur over a period of time.

There should be a fairly substantial threshold before the NRC does not accept one of those programs as being adequate for license renewal.

NRC has written guidance on what an acceptable licensee response is or on what the results of an acceptable inspection should be. So the acceptance criteria for these different programs should already be enumerated and we should be evaluated against them. The NRC should adopt the very substantial threshold for rejection before asking for more.

September 2000 23

Simpson S. Cal.

10.9 Will the draft GALL be posted on the Web? Is it GALL 191 Edison possible to get an electronic version?

Polaski PECO 10.10 Contention that all programs, regulated, reactive, GALL 191 Energy and others not listed, are effectively AMPs. Every 195 program in a powerplant manages aging. The current approach to license renewal (credit for existing programs?) could be the best or worst thing to happen to license renewal.

Dyle Inservice 10.11 Risk informing regulations are being developed 10 CFR 50 196 Engineer that consider safety impacts measured from a risk

-ing perspective and pilot programs are being developed and applied (such as the risk-based ISI program). Can risk be used to address aging management issues? Has that been factored into future work?

Bowman CNS 10.12 Both the maintenance rule and the licensing 10 197 renewal rule related to intended functions are CFR50.65 198 focused on the same result. Hopefully, these two rules will be integrated in this program rather than creating redundant, duplicative activity. If the focus remains on how aging affects intended functions, the number of new programs (defined as a combination of function, material, environment, and aging effect) for license renewal should be kept small.

Walters NEI 10.13 Care should be taken in turning the 10 attributes NEI 95-10 199 into requirements. That was never the intention of 200 NEI 95-10.

Walters NEI 10.14 The focus should be on program enhancements; 10 CFR, 200 but a standard should be developed to determine 50.55a when enhancements are needed. There's no new aging that occurs only after year 39. Reactive programs are generally accepted because they consider age, but 10 CFR, Part 50 does not.

Walters NEI 10.15 The focus in GALL is on enhancements and it GALL 201 should be clear that this is for managing aging to ensure functionality. The key determinant to the success of the license renewal activities will be how all the effort put into GALL gets integrated into the SRP-LR. There should be a very well documented, clear and solid basis for why any enhancement is needed, explaining why the program is inadequate, providing information about aging and the renewal period that somehow renders that program not satisfactory. Is the enhancement needed for a technical reason or is it merely a procedural reason (not meeting the 10 attributes)? If it's a process issue, then I think we need to give serious consideration to changing the process.

September 2000 24

September 2000 Walters NEI 10.16 The industry's expectation is that GALL will GALL 202 produce results much like we have in the GEIS, 203 where we have category one environmental impacts that are generically resolved. The analysis is provided in the GEIS. But for the license renewal applicant, it's resolved. That's where the predictability and stability comes into the process. And then you have category two issues, where you've identified the delta or the enhancement or - you know, there's some basis given for why it couldn't be generically resolved.

And that's where we think we ought to end up with in GALL and that's where we're committed to work towards and we look forward to doing that with not only the NRC, but also all the stakeholders.

25

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKERI AFFIL 2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Walters NEI 4.01 GALL is outgrowth of policy issue discussed in summer'99 The current draft GALL report builds on a previous report, NUREG/CR

p. 16 concerning credits for existing programs for license renewal.

6490, "Nuclear Power Plant Generic Aging Lessons Learned" (GALL),

which is a systematic compilation of plant aging information. This effort is the result of the policy issue discussed in SECY 99-148, "Credit for Existing Programs for License Renewal."

No change to the GALL report is recommended.

Walters NEI 4.02 What process controls will be used to prevent attribute creep, This question addresses the credit for existing programs and how the

p. 17 or attribute shrink? How will stakeholder disagreements over GALL report will address when program attributes need to be enhanced.

the scope of these attributes be resolved?

The GALL report evaluates existing programs generically to document the basis for determining when existing programs are adequate without change and when existing programs should be augmented for license renewal. When further evaluation is needed, it is documented in the last column of GALL tables. If the licensee does not agree with the GALL recommendations, then the licensee has the option of submitting their own aging management program with attributes for staff review.

No change to the GALL report is recommended.

Walters NEI 4.03 If GALL says further evaluation is needed, the basis for this If the evaluation determines that a program is adequate to manage

p. 18 needs to be well documented.

certain aging effects for a particular structure and component without change, the "Further Evaluation" entry would indicate that no further staff evaluation is recommended for license renewal. Otherwise, it would recommend area(s) where the staff should focus its review.

Examples of this are provided in the last column in the tables in the GALL report.

No change to the GALL report is recommended.

26 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS4 PARTICIPANT COMMENT NRC RESPONSE T-page I

Walters NEI 4.04 Thorough review of GALL by all stakeholders is necessary.

The draft GALL report is available in the Public Document Room and

p. 19 The quality should not be sacrificed for the schedule, on the NRC license renewal website (http://www.nrc.gov/NRC/REACTOR/LR/index.html). Copies of the draft GALL report were also distributed to attendees in the afternoon of December 6, 1999 public workshop. The draft GALL report will also be issued for formal public comment in August 2000. Adequate review time (over 9 months) should provide for the thorough review by the shareholders.

No change to the GALL report is recommended.

Walters NEI 4.05 The purpose of GALL should be to identify where aging The purpose of the GALL report is to specify if a change would be pp. 19-20 effects on the structures and components that are in the needed and define the change in the program as it is credited for scope of renewal are not adequately managed by existing renewal. The GALL report provides guidance for the acceptability of CLB programs.

existing programs.

No change to the GALL report is recommended.

Lochbaum UCS 5.01 Different plants are given identical credit for varying The purpose of the GALL report is to capture the generic aging lessons

p. 25 conformance with CLB; no credit should be given for learned and apply them to the review of license renewal applications.

programs that do not exist; "one size fits all" approach The application of GALL to specific plants recognizes the bounding should not be used unless proved to be bounding.

limits on system, components, materials, environment, aging effects, operating experience, and helps identify any outliers for further evaluation. The applicant also has to ensure that the material listed in the GALL report is applicable to the specific plant involved.

No change to the GALL report is recommended.

Lochbaum UCS 5.02 Approach to GALL seems one-directional, with apparently The staff does not believe that GALL is one-directional. GALL builds

p. 21-26 simplifying statements to reduce the level of effort, reducing on its predecessor, NUREG/CR-6490, "Nuclear Power Plant Generic the testing intervals for much equipment seems contradictory Aging Lessons Learned (GALL)" that covered over 500 documents with increasing license renewal activities (license renewal addressing aging and license renewal. GALL also has the benefit of can not proceed in a vacuum),

experience from the NRC staff members who conducted the review of initial license renewal applications. The GALL report evaluates existing programs against 10 attributes for acceptance as an aging management program. In many cases existing programs need to be augmented or new programs need to be implemented to address aging effects or aging mechanisms.

No change to the GALL report is recommended.

27 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SiPiEAKEiR AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Lochbaum UCS 5.03 Approach to aging management assumes all licensees will Licensees are responsible to conform to the condition of their licenses.

p. 25 meet all requirements & implement all administrative The requirements on aging management for license renewal are defined programs; penalties should be very harsh for licensees in 10 CFR Part 54. Penalties are in accordance with Federal Regulations failing to conform to conditions of their licenses, of Enforcement provided in 10 CFR 50.110 and 10 CFR 50.111.

No change to the GALL report is recommended.

Lochbaum UCS 5.04 NRC appears to use GALL to trim scope of future license The purpose of GALL is to focus the review on existing programs that

p. 25 renewal application reviews. Findings must trigger proper need to be enhanced or new programs, not to trim scope. The scope of extent-of-condition evaluations, license renewal application is defined in 10 CFR Part 54. The GALL report is the technical basis document to the SRP-LR that provides staff guidance in reviewing license renewal application.

No change to the GALL report is recommended.

Lochbaum UCS 5.05 No credit for programs that do not exist (such as electrical Programs are evaluated in the tables to demonstrate the types of

p. 21 bus inspection program).

activities that would be considered acceptable for managing aging of various components. An applicant cannot reference a program evaluated in the GALL report if that particular program is not applicable to its plant.

No change to the GALL report is recommended.

Lochbaum UCS 5.06 Boilerplate is not appropriate for nuclear safety documents.

When referencing the GALL report in a license renewal application, an pp. 22-23 Design and license can't be assumed to be sacrosanct, applicant needs to verify that its plant is bounded by the GALL report.

No change to the GALL report is recommended.

Walters NEI 6.01 What will be NRC's responsiveness in incorporating NRC will consider all comments submitted. The GALL report was

p. 34 participant comments and modifying the GALL report?

modified as a result of the analysis of participant comments.

The staff is also soliciting stakeholder comments on the current version of GALL. The staff will consider changes to the GALL report based on these comments.

No direct change to the GALL report is recommended as a result of this sentence on its own.

28 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL 2 ISS#1 PARTICIPANT COMMENT NRC RESPONSE T-page I

Lochbaum UCS 6.02 Given the draft schedule (on vugraf) for approving GALL A moratorium on license renewal has not been considered. The

p. 35 and SRP, is it possible that new license renewal applications guidance in the SRP (97 Working Draft) seemed to work reasonably will not be accepted until rules are better defined?

well in the first two applications. The current emphasis is on making an improvement in that process and focusing feedback to more clearly articulate the basis for findings and how to proceed with licensing actions for the future.

No change to the GALL report is recommended.

Lochbaum UCS 6.03 GALL should perhaps acknowledge a more expansive The analysis of an expansive resource base has been emphasized in the pp. 44-46 resource base (aging-related reports written by other preparation of GALL. The current GALL draft builds on a previous organizations and authors (such as UCS, NIRS, Public report, NUREG/CR-6490, "Nuclear Power Plant Generic Aging Lessons Citizen's, Bob Pollard, Jim Riccio))...the perception is that Learned (GALL)", which is a systematic compilation of plant aging stakeholders are being patronized.

information. NUREG/CR-6490 was based on information from >500 documents including NPAR reports, NEI and NUMARC industry reports. Other information reviewed and referenced included LERs, information notices, generic letters, and bulletins. Additional industry references identified during the License Renewal application reviews are included. Comments concerning the GALL report are solicited from stakeholders as well as industry. In a letter dated May 5, 2000, the UCS provided 5 reports for staff consideration. These reports were reviewed to identify any additional components or aging mechanisms that may need to be incorporated into the GALL report. Based on the UCS reports, the jet pump sensing line and the separator support ring was added to the August GALL report. Other components provided by UCS are still under evaluation.

Incorporated comment in GALL Gunter NIRS 6.04 Validity of data treatment techniques, especially related to Some data treatment techniques are bounding, while others are based on pp. 46-48 crack growth rate mechanisms, intergranular stress corrosion statistical models. Data treatment falls under attribute #5, "monitoring cracking.... industry and the regulator need a better

& trending," in the 10-attribute aging management program. Data understanding of crack growth rate mechanisms.

treatment is also reflected in the acceptance criteria or the detection methods.

No change to the GALL report is recommended.

29 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#'

PARTICIPANT COMMENT NRC RESPONSE T-page Stenger Hop-6.05 Are all 10 stipulated attributes necessary for an existing Current experience indicates that these attributes are found in most

p. 49 kins &

program to be adequate for license renewal?

programs, but sometimes they crosscut. In general, all ten elements Sutter should be present in an effective AMP. Some individual programs standing alone may not have all ten elements, but there is a synergy between different programs and with feedback from operating experience.

If an attribute does not apply, the GALL report describes the basis.

No change to the GALL report is recommended.

Walters NEI 6.06 How was the experience from the review of Calvert and GALL identifies aging management programs for specific aging effects

p. 51-52 Oconee integrated into the preparation of GALL? How was related to specific components. GALL contains generic information on the SER integrated or used in preparation of GALL?

"one-way" to manage aging. Site-specific procedures are intentionally not references in GALL. An applicant always has options to demonstrate aging management of certain components on a plant specific basis. The experience from the review of Calvert Cliffs and Oconee, including the staff SER preparation, is factored into the GALL report. Many of the aging management programs in the Calvert Cliffs and Oconee applications are included in GALL.

No change to the GALL report is recommended.

Colaianni Duke 6.07 Referencing procedure in GALL could perhaps be improved The GALL review is performed at the program attribute level against 10

p. 53 Power and made more consistent (example of cables area).

standardized elements. Site-specific procedures are intentionally not referenced in GALL. The current GALL draft builds on a previous report, NUREG/CR-6490, "Nuclear Power Plant Generic Aging Lessons Learned", which is a systematic compilation of plant aging information.

NUREG/CR-6490 was based on information from >500 documents including NPAR reports, NEI and NUMARC industry reports. Other information reviewed and referenced included LERs, information notices, generic letters, and bulletins. Additional industry references identified during the License Renewal application reviews are included.

If other appropriate references are identified during the public review, then they will be considered for incorporation into the final GALL report. This comment is general and no specific action by the staff is recommended.

No change to the GALL report is recommended.

30 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Ray INEEL 6.08 Are the NPAR findings addressed and referenced? Does The current GALL draft builds on a previous report, NUREG/CR-6490, pp. 53-55 GALL address new international findings of cracking or "Nuclear Power Plant Generic Aging Lessons Learned (GALL)", which leakage?

is a systematic compilation of plant aging information. NUREG/CR 6490 was based on information from >500 documents including NPAR reports, NEI and NUMARC industry reports. The current draft builds upon the NPAR reports with other references from many sources including international findings.

No change to the GALL report is recommended.

Lochbaum UCS 6.09 Mechanism of proposed appeal process (3-4 tiered appeal The staff has had several discussions with the license renewal steering pp. 57-58 process), if a stakeholder didn't agree with information on committee regarding the appeal process. The staff plans to incorporate some aging issue or some license renewal issue - process the appeals process and other lessons learned into a revision of office should be fairer for public appeal. There are questions about letter 805, "License Renewal Application Review Process." It is the 2.206 or allegation process.

envisioned that the office letter will provide guidance for an appeal process for license renewal issues with generic implications and not for resolving issues identified during plant-specific reviews. The public appeal process for these issues is the same as for industry, which is separate from the processes for formal petitions under 2.206, issues pursued through the allegation process or issues pursued through differing professional opinions.

For plant-specific reviews, a notice of opportunity for a hearing is required to be published in accordance with 10 CFR 54.27. This is in addition to the 2.206 and allegation processes, and the public meetings that are held near the site to solicit public comments on plant-specific license renewal applications.

Because this process issue is outside the scope of the GALL report, no change to this report is recommended.

Gunter NIRS 7.01 When will GALL be in the PDR?

The draft GALL report is currently available in the Public Document pp. 59-60 Room and NRC website. Copies of the draft GALL report were also distributed to attendees during the afternoon of the December 6, 1999 public workshop.

No change to the GALL report is recommended.

31 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#I PARTICIPANT COMMENT NRC RESPONSE T-page Gurican

GPUN, 7.02 Is there special consideration in the development of the SRP The draft GALL report does not make that distinction. The GALL report

p. 60 Inc.

and/or the GALL report for non-SRP licensees, and also evaluates programs regardless of the type of licensee (such as non-SRP licensees who are not ISTS holders?

and ISTS). Similarly, the SRP-LR is being developed without specific consideration of the licensing basis for particular plants. The draft SRP is available on the web (http://www.nrc.gov/NRC/REACTOR/LR/SRP/srp toc.html).

No change to the GALL report is recommended.

Walters NEI 7.03 What standard are you applying to determine that ISI is not As indicated in the GALL report, the evaluation of aging management

p. 65 adequate? Where ISI may not be adequate, does GALL programs is based on 10 attributes or elements. The NRC reviewer identify enhancements needed?

must make the connection between the 10 attributes or elements. In the GALL report, program attributes are evaluated for their adequacy in managing certain aging effects for particular structures and components.

The evaluation is based on the review of these 10 attributes: scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience. If the evaluation determines that a program is adequate to manage certain aging effects for a particular structure and component without change, the "Further Evaluation" entry would indicate that no further staff evaluation is recommended for license renewal. Otherwise, it would recommend area(s) where the staff should focus its review. Examples of this are provided in the last column in the tables in the GALL report.

No change to the GALL report is recommended.

Walters NEI 7.04 Is it correct that 10 CFR Part 50, Appendix H expires after Appendix H is part of the current licensing basis. See item 7.7 for the

p. 66 forty years of a plant's operating life?

response on the reactor surveillance program.

The GALL report has been changed to provide further guidance on the reactor surveillance program in Chapter XI.

32 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL 2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Ray INEEL 7.05 Some plants, based on their current surveillance capsule See item 7.7 pp. 68-69 program, should be viable to 60 years without making any significant change, and should be able to qualify or disqualify various screening criteria...complications with The GALL report has been changed to provide further guidance on the possible variability in pressurized thermal shock (PTS) data.

Reactor Surveillance program in chapter XI.

Sanwarwalla Sargent 7.06 What is the balance in considering plant-specific operating The GALL report recommends that the operating experience of AMPs,

p. 71 experience and GALL related to future licensing renewal including past corrective actions resulting in program enhancements or Lundy procedures?

additional programs, be reviewed. A past failure would not necessarily invalidate an AMP because feedback from operating experience should have resulted in appropriate program enhancements or new programs.

The operating experience information can show where an existing program has succeeded and where it has failed, if any, in intercepting aging degradation in a timely manner. The operating experience should provide objective evidence to support that the effects of aging will be adequately managed so that the structure and component intended function(s) will be maintained during the period of extended operation.

An applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness.

No change to the GALL report is recommended.

Gunter NIRS 7.07 What will be the interval of withdrawing and testing The Reactor vessel surveillance program is plant-specific, depending on pp. 73-76 surveillance capsules when going for a 20 yr. extension?

parameters such as, limiting materials, availability of surveillance Will GALL address this?

capsules, and projected fluence levels. In accordance with Appendix H to 10 CFR Part 50, an applicant must submit its proposed withdrawal schedule for approval prior to implementation. Thus further staff evaluation is required for license renewal.

The GALL report has been changed to provide further guidance on the Reactor Surveillance program in chapter XI.

33 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Nickell EPRI 7.08 Scope of components that need to be evaluated for aging Neutron embrittlement should be managed for components with fluence pp. 76-78 management... For materials beyond the conventional

>1017 n/cm2, E>I MeV. The applicant must determine the beltline, will GALL have guidelines to help the applicant susceptibility of CASS components to thermal aging embrittlement make a decision about how to do calculations to show that based on casting method, Mo content, and percent ferrite. GALL those additional materials are not limiting?

provides references to appropriate guidelines as available.

GALL was revised to provide further guidance on determining the susceptibility of components to Neutron Irradiation Embrittlement and is contained in Chapter XI.

Lochbaum UCS 7.09 How are changes that are made to the existing programs or 10 CFR, Part 50.71 (e) requires that the final safety analysis report

p. 79 new programs that are developed for aging, captured within (FSAR) is the repository of the critical safety functions and compliance the licensing basis? The NRC staff has indicated that the matters. License renewal requires summary descriptions of programs in FSAR might be the best repository for that information. The FSAR supplements.

industry has suggested that the existing license commitment tracking systems might be the more appropriate vehicle. 'I No change to the GALL report is recommended.

guess if we are voting on that, we would vote on the FSAR, and following 50.71(e), that seemed to be a good time to follow that rule."

So AEP 7.10 Referencing the discussion concerning inservice inspection The GALL report identifies components of concern and what aging pp. 80-82 program and Attribute Number 4, where it was mentioned effects need to be managed. If the existing program can not satisfy all that detection of aging effects are not being taken care of by 10 elements then guidance is provided in the GALL report. In this case, some of these traditional regulator programs. What direction the item is clearly identified in GALL as "YES" in the further evaluation or what additional augmented examples are considered?

column.

Will the GALL report give further guidance as far as what components will be examined? There are questions about GALL also provides guidance for inaccessible areas.

sampling/inspection of inaccessible areas.

No change to the GALL report is recommended.

34 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL' ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Dyle In-7.11 Will GALL indicate what edition of the code is used to make The GALL report is based on the 1989 edition of the Code with respect pp. 82-83 services the assessments of the adequacy of current ISI programs and to ASME section XI (ISI) concerns and the 1992 edition with respect to Engin-to what degree are the augmented programs that are containment inspection. However, there is a 10 CFR 50.55 process to eering currently required by regulation factored into that have later editions of the code approved. When future editions of the assessment? Questions exist about enhancing the adequacy ASME Code are incorporated into the NRC regulations by the 10 CFR of the ongoing IST. Is it clear where we start with the review 50.55 rulemaking, the staff will perform an evaluation of these later and what the comments ought to be? It would be valuable to editions for their adequacy for license renewal using the 10-element the ASME committees that might work on trying to resolve program evaluation described in GALL as part of the 10 CFR 50.55a this.

rulemaking.

If ISI is to be enhanced by another program then the enhanced program is identified.

The staff is working with ASME committees to address how section XI might change.

The GALL report was changed to specify the edition of the code that GALL was based or later edition as approved in 10 CFR 50.55a.

Walters NEI 7.12 Tutorial on how the maintenance rule fits into a license NRC's ultimate goal in regulatory coherence is to keep plants safe. The pp. 83-86 renewal review. (The maintenance rule ensures functionality "Maintenance Rule," 10 CFR 50.65, is intended to monitor the of equipment, the same end result that we are looking for in effectiveness of maintenance activities in nuclear power plants. It license renewal, and we ought to get credit for what we do focuses on the adequacy of preventive and corrective maintenance as under the maintenance rule),

well as inspection activities. The maintenance rule program is evaluated in the GALL report. For example, structures monitoring programs developed to meet the requirements of 10 CFR 50.65 are evaluated for addressing aging management of structures and structural components to meet the requirements of 10 CFR Part 54 (license renewal). An applicant may integrate the GALL recommendations into their existing maintenance rule program to avoid redundant duplicate activities.

No change to the GALL report is recommended.

35 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Stenger Hop-7.13 Does NRC have a standard used for determining whether an As indicated in the GALL report, the evaluation of aging management

p. 90 kins &

existing program would be modified or augmented? Is there programs is based on 10 attributes or elements. The NRC reviewer Sutter some threshold that applies or is it up to the individual must make the connection between the 10 attributes or elements. In the reviewer's discretion? How does that work?

GALL report, program attributes are evaluated for their adequacy in managing certain aging effects for particular structures and components.

The evaluation is based on the review of these 10 attributes: scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience. If the evaluation determines that a program is adequate to manage certain aging effects for a particular structure and component without change, the "Further Evaluation" entry would indicate that no further staff evaluation is recommended for license renewal. Otherwise, it would recommend area(s) where the staff should focus its review. Examples of this are provided in the last column in the tables in the GALL report.

No change to the GALL report is recommended.

Stenger Hop-7.14 How could the maintenance rule program be utilized for The "Maintenance Rule," 10 CFR 50.65, is intended to monitor the

p. 91 kins &

license renewal purposes?

effectiveness of maintenance activities in nuclear power plants. It Sutter focuses on the adequacy of preventive and corrective maintenance as well as inspection activities. The maintenance rule program is evaluated in the GALL report. For example, structures monitoring programs developed to meet the requirements of 10 CFR 50.65 are evaluated for addressing aging management of structures and structural components to meet the requirements of 10 CFR 54 (license renewal).

An applicant may integrate GALL recommendations into their existing maintenance rule program to avoid redundant duplicate activities.

No change to the GALL report is recommended.

Walters NEI 7.15 How were the 10 attributes developed; why 10, not 15 or 6?

NRC developed this set of program attributes (scope of program,

p. 92 What is it about those 10 attributes that lead to the preventive actions, parameters monitored or inspected, detection of conclusion that an enhancement is necessary?

aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience) based on extensive experience from nuclear plant aging research. The earlier work established the initial SRP and the first 2 renewal application reviews.

No change to the GALL report it recommended.

36,

September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL' ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Nickell EPRI 7.16 Looking at accessible areas in order to make a determination GALL addresses the issue of inaccessible areas. Inspections in

p. 96-97 where one might want to inspect inaccessible areas is an accessible areas are used to provide an indication of possible problems acceptable approach...should avoid requiring inspection of occurring in inaccessible areas. The GALL report recommends inaccessible areas where there is no evidence of a problem in examination of inaccessible areas in some cases. NUREG-1611 an accessible area.

recommends that aging management is necessary for potential corrosion in inaccessible areas of steel liners, steel containment shells, and common steel components when conditions in accessible areas may not indicate the effect of degradation in similar inaccessible areas. The applicant's aging management program to address this issue must be evaluated.

No change to the GALL report is recommended.

Carey EPRI 7.17 IWE/IWL is sufficient for license and doesn't need to be Inspection of PWR and BWR steel structures and liner plate and

p. 97 augmented.

prestressed or concrete containments are currently based on ASME Section XI, Subsections IWE and IWL examinations in accordance with 10 CFR 50.55a. However, IWE and IWL exempt from examination portions of the structures and containments that are inaccessible (e.g.,

embedded portions of steel liners and steel containment shells, basemat, exterior walls below grades, and concrete covered by liner). To cover the inaccessible areas, 10 CFR 50.55a(b)(2)(ix) requires that the licensee shall evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas. The GALL report states that IWE/IWL and the requirements of 10 CFR 50.55a(b)(2)(ix) are adequate for managing the aging effects, except for inaccessible areas when there are no indications of degradation for accessible areas.

No change to the GALL report is recommended.

Lochbaum UCS 7.18 Guidelines in the 1996 ASME Code should be considered See comment 7.11

p. 98 for the license renewal review. Basically this program is acceptable, and Part 54.2l.c.1.3.i allows somebody to look at the program results on a continuous basis, the best way to The GALL report has been revised to specify the 1992 edition or as ensure containment integrity.

approved by 10 CFR 50.55a 37 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Morante BNL 7.19 (BNL was responsible for the GALL tables covering GALL addresses the issue of inaccessible areas. Inspections in

p. 98 containment),... the issue of inaccessible areas is still accessible areas are used to provide an indication of possible problems considered open and is not resolved by following 50.55.a.

occurring in inaccessible areas. The GALL report recommends That will be subject to further discussion between the NRC examination of inaccessible areas in some cases. NUREG-1611 staff and industry recommends that aging management is necessary for potential corrosion in inaccessible areas of steel liners, steel containment shells, and common steel components when conditions in accessible areas may not indicate the effect of degradation in similar inaccessible areas. The applicant's aging management program to address this issue must be evaluated.

I No change to the GALL report is recommended.

So AEP 7.20 Clarification appreciated of use of later edition of the ASME See item 7.11 pp.99-100 code to satisfy requirements (example cited of prestressed and post-tensioning conditions).

The GALL report was changed to reflect the edition of the code that GALL was based or later edition as approved in 10 CFR 50.55a.

Stenger Hop-7.21 Acceptability of IWE/IWL for licensing.... surprised that the The GALL report identifies structures and components and their aging pp. 100-101 kins &

SRP implied there was some question of cataloging what effects. For the containment, the GALL report evaluates 1WE/IWL to Sutter IWE and IWL do for aging management programs, and to manage the identified aging effects for the containment structure and determine a need for any augmentation of those activities, components. The GALL report documents when augmentation is recommended.

No change to the GALL report is recommended.

Pickens NSP 7.22 Prospect of plants taking credit for programs that, although NRC had determined, by 1995, that aging effects are not unique to the

p. 102 all designed to respond to aging or degradation in some way, licensing period. There are varying degrees to which regulated may not have the same original intent, programs effectively manage aging effects. The GALL report indicates when existing programs are adequate without change and when existing programs should be augmented for license renewal.

No change to the GALL report is recommended.

Pickens NSP 7.23 Will GALL identify how extended aging differs so that The NRC has not said that aging differs after 40 years. Programs

p. 104 operators can assess whether changes to the program are (examples: EQ, reactor vessel assurance) use certain methodologies to adequate to address that change?

extend the analysis from 40 to 60 years. The NRC is looking for a self correcting process, a system that looks for trends, root causes, and adjusts the program accordingly (example: reliance on prompt and effective corrective action in Appendix B). A feedback loop is expected in any of these programs.

1 No change to the GALL report is recommended.

38 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL 2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Polaski PECO 7.24 Some regulatory programs listed by Elliot of NRC have their The NRC has proceeded forward by "addressing the deltas" rather than pp. 106-108 basis in other codes beyond the NRC regulations. If there is going back and changing codes or regulations.

The NRC participates a determination made that the program or the code is not in code activities. The code-making bodies have the option to address adequate for beyond 40 years, is it the NRC's intent to go such "deltas."

back through the code process and the process for changing regulations and get the codes and regulations updated, so they specify what the requirements are for 60 years? That would provide the ultimate stability for license renewal if the regulations and the codes address the interval out to 60 years, and maybe even beyond.... and also help avoid regulatory creep, which is more likely when just going through the GALL process with individual licensees making determinations.

No change to the GALL report is recommended.

Walters NEI 7.25 If a regulation is not a program, when we see GALL, and we A program (such as EQ) is that collection of procedures, activities, pp. 109-112 see an evaluation of, say, EQ, was the evaluation done practices, and standards that are conveniently related to one objective.

actually on the regulation, or was it done looking at the The focus should be underlying implementing guidance and its features implementing guidance documents for the regulation and and how those implementing guidance or practices satisfy the needs of trying to assess how a program would be crafted to address managing aging effects for particular components within the scope of that regulation? What was really reviewed and what is the renewal. The issue is not if there is compliance with 10 CFR 50.49, but evaluation really focusing on?

rather how does the practice of complying with 50.49 provide for managing aging effects for systems, structures and components within the scope of license renewal. In the case of EQ, both the regulation and guidance documents were reviewed to determine if EQ could be considered an acceptable AMP. It is understood that the program actually implemented will meet the requirements of the regulation.

No change to the GALL report is recommended.

Walters NEI 7.26 The focus for renewal, at least on EQ, is primarily in the Reanalysis is included in the regulation as an acceptable option for

p. 113 reanalysis area. Is the reanalysis accounted for in the extending qualified life. This is addressed in the GALL tables.

regulation?

No change to the GALL report is recommended.

Sanwarwalla Sargent 7.27 Will the NRC endorse the standard in the IEEE 323 1983 The IEEE 323 1983 edition is being revised; NRC is represented on the

p. 114 edition (now in process of being revised) related to 40 years associated working group. NRC has not endorsed the IEEE 323 1983 Lundy testing plus analysis, to extend the life of these EQ edition.

components?

No change to the GALL report is recommended.

Colaianni Duke 7.28 Programs related to EQ in the 10-attributes list. It appears EQ was not used as the driver for establishing the 10-attributes for an pp. 115-116 Power from the GALL draft that EQ wasn't used as a driver since acceptable aging management program. However, that does not impact seven of the attributes would not have to be addressed for the technical content in the Chapter VI tables of the GALL report.

EQ.

I No change to the GALL report is recommended.

39 September 2000

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PARTICIPANT COMMENT NRC RESPONSE T-page I

Sanwarwalla Sargent 7.29 For license renewal, we have gone back and done reanalysis Components with qualified lives of 40 years or less are short-lived and

p. 116 to try to justify extension of the life to 60 years. Will the outside the scope of license renewal. Extending the qualified life of Lundy NRC go back and endorse the same philosophy to extend the components is considered only for those that are currently qualified for life of components that have short lives right now?

40 years. Typically the Arrhenius methodology is used; if the licensee could show that the operating environment temperature is lower than used in calculations, qualified life extension is likely. TLAA falls into 3 categories: (1) already qualified for 60 years, (2) modified to have a 60 year qualified life, (3) future management. It will be necessary to judge the adequacy of procedures and practices used to develop conclusions for analyses regardless of when the analyses are done.

No change to the GALL report is recommended.

Colaianni Duke 7.30 License renewal was very visible focusing on extension from Reanalysis has always been a part of the regulation and has been used in

p. 118 Power 40 to 60 years but it is the same practice under the current the past for short-lived components. However, past reanalyses have regulation that has been taking place for short-lived focused on small incremental increases in qualified life. In the case of components outside of license renewal. Reanalysis has been license renewal, significantly larger increases in qualified life are being done since the beginning of the regulation.

requested for which uncertainties and assumptions become more critical.

Therefore, more detailed supporting information for license renewal reanalysis calculations is warranted.

No change to the GALL report is recommended.

Walters NEI 8.01 Why doesn't GALL focus first on what NRC asked of the GALL does evaluate Generic Letter (GL) programs. Examples include pp. 123-125 licensee? For purposes of GALL, could we focus on GL GL 89-13, 89-08, 98-04, and 88-05.

requests? (GL 89-13 should be credited as acceptable AMP because it specifically identifies significant fouling occurring as a result of age-related in-leakage and corrosion or erosion)

No change to the GALL report is recommended.

Lochbaum UCS 8.02 Discussion on reactive programs implies that the GALL GALL evaluated reactive programs such as GL 89-13, 89-08, 98-04, 88 pp. 127-128 process includes either some formal mechanism to review

05. NRC staff will consider updating GALL and SRP based on future emerging issues, or that the NRC is going to stop being operating experience.

reactive -which? Is there a management directive that governs GALL or similar processes? Does GALL process have formal mechanism to view reactive mode output?

No change to the GALL report is recommended.

40 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISSiW PARTICIPANT COMMENT NRC RESPONSE T-page I

Bowman CNS 8.03 It is necessary for GALL to clearly define what is different This comment seems to suggest that the GALL report should clearly pp. 128-129 (when there is something different) for license define how a program might change to be credited for renewal. The renewal,... regarding implementation, the plant stakeholders concern is that if the GALL report does not clearly define that now, the need to understand clearly when a program can be credited question of whether or not there is a difference in the program, and what for license renewal.

that difference is, will be very difficult to resolve at the time of implementation. The purpose of the GALL report is to specify if a change would be needed and define the change in the program as it is credited for renewal. Therefore, this comment is addressed by the GALL report.

No change to the GALL report is recommended.

Menocal Florida 8.04 The specific section reviewed from the draft GALL report The GALL report addresses both external and internal aging effects for

p. 132 Power appeared to have a format based on systems and then on each SSC, as appropriate. The environment is described in which the and component level - are both internal and external aging aging effect applies. If aging effects are not identified for both the Light mechanisms/effects addressed for each component?

internal and external environment, then only the appropriate environment associated with the aging effect is listed.

No change to the GALL report is recommended.

Lochbaum UCS 8.05 Would the 50.54(f) request (10/96) be an example of a NRC would consider 10 CFR 50.54(f) Commission's request ("for

p. 133 reactive program?

written statements, signed under oath or affirmation, to enable the Commission to determine whether or not the license should be modified, suspended, or revoked") a reactive program to the extent that NRC expressed a concern about how design basis is being maintained. The scope of LR application is defined in 10 CFR Part 54. The GALL report is the technical basis document to the SRP-LR that provides staff guidance in reviewing LR applications. In 10 CFR 54.30 Matters Not Subject to a Renewal Review, it is stated that "if the reviews required by 54.21(a) or (c) show that there is not a reasonable assurance during the current license term that licensed activities will be conducted in accordance with the CLB, then the licensee shall take measures under its current license, as appropriate, to ensure that the intended function of those systems, structures or components will be maintained in accordance with the CLB throughout the term of its current license."

Thus, these concerns are with the CLB and not with the period of extended operation and are not reflected in GALL.

No change to the GALL report is recommended.

41 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKERi AFFIL2 ISS#'

PARTICIPANT COMMENT NRC RESPONSE T-page I

Carey EPRI 8.06 Define other areas where existing programs required further As indicated in the GALL report, the evaluation of aging management

p. 135 evaluation?

programs is based on 10 attributes or elements. The NRC reviewer must make the connection between the 10 attributes or elements. In the GALL report, program attributes are evaluated for their adequacy in managing certain aging effects for particular structures and components.

The evaluation is based on the review of these 10 attributes: scope of program, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process, administrative controls, and operating experience. If the evaluation determines that a program is adequate to manage certain aging effects for a particular structure and component without change, the "Further Evaluation" entry would indicate that no further staff evaluation is recommended for license renewal. Otherwise, it would recommend area(s) where the staff should focus its review. Programs requiring further evaluation are indicated by a yes in the further evaluation column of GALL. Examples requiring additional evaluation include programs to manage fatigue and void swelling.

No change to the GALL report is recommended.

Walters NEI 8.07 Does GALL focus on original scope of program (such as The GALL review is performed at the program attribute level against 10 pp. 138-139 AMP) and related GLs and Bulletins? Is expanded scope of standardized elements. Site-specific procedures are intentionally not a program (such as results from Calvert Cliffs or Oconee referenced in GALL. GALL references GLs and Bulletins (example of license renewal) considered?

GLs addressing particular aging effect on particular component, cracking of control rod drive mechanism). Existing programs address operating experience. The GALL report does address changes in scope for changed vendor materials (e.g., Alloy 600 vs. Alloy 690 for mechanical plugs in steam generator tubes).

No change to the GALL report is recommended.

Morante BNL 8.08 Additional guidelines for managing aging of Category I The GALL report evaluated applicable regulatory guidance such as pp. 139-140 structures (such as water control structures) are provided by Regulatory Guide 1.127, Revision 1, Inspection of Water-Control Regulatory Guides, such as 1.127 and provide foundation for Structures Associated with Nuclear Power Plants, March 1978.

license renewal (even though not defined as a reactive program). Reg. Guide 1.127 is identified for license renewal as an acceptable methodology for managing aging for water control structures.

No change to the GALL report is recommended.

Bowman CNS 8.09 Are existing plant inspection programs (such as erosion-The GALL report provides a generic evaluation of the acceptability of

p. 142 corrosion) being examined in the context of assessing or existing programs. An applicant should review its particular program addressing the adequacy of a particular licensee's existing and may reference the GALL report if the program is bounded by the programs?

GALL report.

No change to the GALL report is recommended.

42 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Menocal Florida 8.10 What is the significance of plant-specific experience in terms Operating experience of the aging management program, including past pp. 144-145 Power of demonstrating the adequacy of an existing program in the corrective actions resulting in program enhancements or additional and aging management review process? Implementation of programs, should provide objective evidence to support that the effects Light effective program shouldn't require additional enhancement.

of aging will be adequately managed so that the structure and component intended function(s) will be maintained during the period of extended operation.

No change to the GALL report is recommended.

Bowman CNS 8.11 Example of extended reactive program (although an aging This appears to be a general comment that does not require resolution.

pp. 147-148 management enhancement, not directly a license renewal Management of Alloy 600 is discussed in the GALL report.

commitment) was illustrated by the modification of the existing Alloy 600 program to extend to non-pressure boundary components to provide both safety and economic No change to the GALL report is recommended.

improvements.

Lochbaum UCS 8.12 Another example of a GL from '88 or '89 applicable for The GALL Report references the NRC Generic Letter 88-14, Instrument pp. 149-150 reactive program would be the one concerning instrument Air Supply System Problems Affecting Safety-Related Equipment, error, air dryers, and continuous monitoring of moisture August 8, 1988. The AMP for piping and fitting for compressed air carryover.

systems in auxiliary systems, based on GL 88-14 relies on improved system inspections, maintenance, and testing. Inservice testing is recommended, based on guidelines of GL 88-14, to verify proper air quality, and that maintenance practices, emergency procedures, and training are adequate to ensure that the intended function of the air system is maintained. Most plants continuously monitor moisture carryover and certain parameters are checked frequently to identify possible instrument error. This appears to be a general comment that does not require resolution.

No change to the GALL report is recommended.

43 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL 2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Gurican

GPUN, 8.13 How will NRC treat TLAAs (such as ref. Bull.88-05, The three options on TLAA include (I) showing that TLAA is adequate pp. 150-151 Inc.

Thermal Stratification...) and environmental qualifications for 60 years, (2) ensuring that the aging analysis has been extended to 60 (EQs) within the license renewal application? When years, and (3) relying on an aging management program. NRC expects addressing either reactive or mandated programs under the use of 10 attributes in its evaluation of aging management programs, TLAA, what are the NRC's expectations regarding ten whether it is a regulated (mandated) or reactive program. NEI is attributes? Is it correct that GALL will wind up with a revising NET 95-10. Plans are to endorse NET 95-10 in a regulatory revised NET 95-10, providing guidance on license renewal guide, if acceptable.

applications?

No change to the GALL report is recommended.

Gurican

GPUN, 8.14 Clarify the intent of the GALL report; will it result in revised GALL will result in revisions to the SRP (97 Working Draft), and pp. 151-152 Inc.

industry guidelines? Is it thus internal guidance for corresponding changes are also expected in the NEI guidelines. The acceptance criteria?

intent of GALL is to evaluate existing programs generically to document the basis for determining when existing programs are adequate without change and when existing programs should be augmented for license renewal. The GALL report would be referenced in the SRP as a basis for determining the adequacy of the existing program.

No change to the GALL report is recommended.

Carey EPRI 8.15 The MRP has a substantial program examining thermal Numerous references were reviewed to conclude that Thermal

p. 154 stratification; unsteady thermal stratification (unanticipated Stratification has a potential aging effect, therefore it is listed in GALL.

transient) in attached piping is not really aging issue. NRC An example of the references reviewed includes "On the Mechanism of has inadequate data to claim that thermal stratification events Environmental Cracking Introduced by Cyclic Thermal Loading" by have significant environmental effects.

Kussmaul, Rintamaa, et. El.

No change to GALL is recommended.

Menocal Florida 9.01 The section of the draft GALL report related to secondary Both Calvert Cliffs and Oconee proposed one-time inspections.

p. 161 Power plant systems recommended one-time inspections to validate Although they had rigorous chemistry control programs, there were and the chemistry control program for certain systems. What possibly specific unrefreshed chemical regimes in systems. The one Light was the basis for that recommendation? When would it time inspections were designed to examine areas most susceptible to apply? If the parameters are controlled, why is the one-time crevice or pitting and verify their assumptions. Because corrosion inspection needed?

cannot be ruled out, the GALL report identified that there might be a need for inspection to at least verify adequate chemistry control. A one time inspection to verify that an aging effect does not need to be managed is a reasonable action to take where there is some uncertainty about the occurrence of an aging effect.

No change to the GALL report is recommended.

44 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKERi AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page II Colaianni Duke 9.02 Hopefully routine maintenance won't be regulated although The Code of Federal Regulations 10 CFR 54.21(d) requires that an

p. 164, 167 Power routine maintenance may indirectly affect some equipment FSAR supplement for the facility must contain a summary description of aging aspects. Regulating routine maintenance would the programs and activities for managing the effects of aging and the increase regulatory creep into almost every aspect of the evaluation of time-limited aging analyses for the period of extended plant. How do you distinguish preventive maintenance operation determined by paragraphs 10 CFR 54.2 1(a) and 10 CFR from routine maintenance?

54.21(c), respectively. If the Licensee takes credit for using a PM task to manage the effects of aging in the FSAR supplement, then the PM becomes a regulatory commitment. Thus, the PM tasks taken credit for in the FSAR supplement by the applicant become commitments.

License Renewal will result in additional licensee commitments and should not be viewed as "regulatory creep."

No change to the GALL report is recommended.

Rycyna CNS 9.03 Using air-system piping at Calvert Cliffs as an example, This appears to be a general comment that does not require resolution.

pp. 165-166 where positive operating experience has been confirmed and Operating experience is one of the 10 elements being evaluated in the documented on plant records, the amount of effort GALL report.

committed to doing age-related degradation inspection will be reduced. Plant operators should take the opportunity when doing maintenance to document positive operating experience that can subsequently be put on the license renewal application for a particular plant.

No change to the GALL report is recommended.

Bowman CNS 9.04 Continuing comment (see Issue 9.2) about overlap between The applicant has the option of taking credit for existing PM programs pp. 168-169 regulatory space and preventive maintenance (PM). Where it or creating new PM tasks. The choice is theirs as long as the PM becomes complicated to credit an existing PM task, because effectively manages aging.

of the regulatory burden, instead of crediting a PM task, he suggests creating a new task that's unique to license renewal space (example: electrical panels). Frequent, routine maintenance should perhaps be separated from infrequent PM related to license renewal aging-specific considerations.

No change to the GALL report is recommended.

Minikoff Florida 9.05 In the draft GALL section concerning auxiliary feed water The IST program generally addresses the active functions of pp. 171-172 Power systems, pump IST was referenced. Was that to look for components and therefore was removed from GALL.

and external leakage? Normally one wouldn't associate that test Light with troubleshooting for passive failure or performance of The GALL report has been revised to remove references to IST.

passive equipment.

Sanwarwalla Sargent 9.06 When trying to take credit for certain general practice If credited general-purpose programs are relied on to demonstrate aging pp. 172-173 programs (such as temperature monitoring program), under effects, they will be documented as a commitment in the FSAR Lundy what category would these programs fall? Would they now supplement.

be regulated programs?

No change to the GALL report is recommended.

45 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS rSPEAKER' AFFIL 2 ISSS#

PARTICIPANT COMMENT NRC RESPONSE.

Tf-page____I So AEP 9.07 Will GALL provide guidance about the extent of The GALL report identifies specific systems and components for which pp. 174-177 augmentation needed to demonstrate adequacy of programs the current ISI programs require augmentation for license renewal, and such as ISI and IST, which have the main objective of it provides some general guidance on the nature of that augmentation.

monitoring degradation/aging of equipment? What will be GALL has tried to catalogue programs relied on to manage aging effects the guidelines for demonstrating, for license renewal for those structures and components in the scope of license renewal.

purposes, no degradation of certain pumps and valves, no The GALL report has identified the attributes of those programs and leakage in Class-I system, and a reasonable assurance of where further enhancement with respect to managing aging is warranted.

adequate equipment lasting longer than 40 years? Is it IST was determined to address active functions of components and possible to have concurrence that when there is no therefore was removed from GALL.

degradation of pumps & valves and when a VT2 examination per Section XI requirement demonstrates no leakage in class-I system, there is reasonable assurance the The IST program was removed from GALL.

equipment will last longer than 40 years?

Colaianni Duke 9.08 During Oconee license renewal activities, new programs The applicant must demonstrate reasonable assurance that new, existing,

p. 177 Power were usually not needed, however adding new regulatory or augmented programs will be effective in managing effect of aging on documentation framework to existing activities drives up structures and components in the period of extended operation. This cost, which we 'would like to draw the line against.'

process has been developed to allow the applicant to take credit for existing programs but some new documentation may be added by the regulatory process to provide appropriate control.

No change to the GALL report is recommended.

Colaianni Duke 10.01 Will the GALL report consider the situation where the plant-GALL identifies aging management programs for specific aging effects pp. 179 -180 Power specific applicants could show that all the potential aging related to specific components; thus such a discussion is probably not effects for a given component might not be applicable to that evident. GALL contains generic information on "one-way" to manage particular plant? Would these components then fall out of aging. An applicant always has options to demonstrate aging the license review process, because failures of them would management of certain components on a plant-specific basis.

be hypothetical? Is that discussion evident in the front of GALL?

No change to the GALL report is recommended.

Walters NEI 10.02 Are other TLAAs, besides EQ in Ch. 7 evaluated in GALL?

See item 10.03

p. 182 Some TLAA's were removed from GALL and placed in the SRP-LR Colaianni Duke 10.03 Will all the TLAAs eventually be in the GALL report (for TLAAs that may be applicable to a plant must be identified by the pp. 182 -183 Power the sake of consistency)? Fatigue should be treated in the applicant. However, the GALL and SRP-LR report contains several same way as EQ (ref GSI-168).

generic TLAAs as lessons learned from the review of license renewal applications. Metal fatigue and EQ are examples of AMPs under 10 CFR 54.21(c)(1)(iii) and are included in chapter X of GALL. Other TLAAs are provided in the SRP-LR.

No change to the GALL report is recommended.

46 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS40 PARTICIPANT COMMENT NRC RESPONSE T-page Colaianni Duke 10.04 Program description in GALL should sometimes be The GALL report describes and evaluates program attributes.

pp. 184-185 Power improved to better provide actual guidance on how to Stakeholders may comment if the GALL description of a program may monitor system integrity (example monitoring integrity of be improved. This is a general comment.

cable ground conductor).

No change to the GALL report is recommended.

Sanwarwalla Sargent 10.05 When and how will GALL be formally issued? How The schedule currently indicates that GALL will be formally issued in pp. 186-187 frequently will it be revised?

March 2001. The obligation to the Commission is to produce a Generic Lundy Aging Lessons Learned (GALL) report and a revised SRP (http://www.nrc.gov/NRC/REACTOR/LRISRP/srp-toc.html).

NRC staff will produce GALL to reflect consensus opinion, or at least highlight areas of controversy, and request that the Commission approves it. How and when GALL is updated will be considered after the Commission approves the initial issuance.

No change to the GALL report is recommended.

Dyle In-10.06 How will branches of NRC decide if an aging issue has been The license renewal branch and technical branches in NRR and RES are

p. 187 services correctly resolved? What is the relationship in this program involved in developing the GALL report. No one individual in the Engin-between license renewal branch and technical branches as NRC bears the entire responsibility for the decision-making process.

eering final arbitrators?

The ultimate arbitrator is the Commission and then the courts.

Individual opinions do not represent an agency opinion until a formal position is made on an application or licensing matter.

No change to the GALL report is recommended.

Lochbaum UCS 10.07 Appeal rights of applicants and other general stakeholders.

This appears to be a general comment that does not require resolution in pp. 188-189 Frustrating process of submitting allegations and appeals.

the GALL report. Concerns about appeal rights are addressed separately from license renewal, because these comments apply to the overall regulatory process.

No change to the GALL report is recommended.

47 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL2 ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page I

Gray New 10.08 With both regulated and reactive programs, the bottom-line For a program to be adequate for the period of extended operation it pp. 189-190 York is to make sure that the systems, structures, and components should satisfy the 10 attributes. If the existing program satisfies these Power will perform their intended functions, including whatever attributes or threshold then it is not necessary to modify the existing Author-adverse aging effects may occur over a period of time.

program. However if the existing program does not satisfy the 10 ity There should be a fairly substantial threshold before the attributes then it should be augmented to manage aging for the period of NRC does not accept one of those programs as being extended operation.

adequate for license renewal. NRC has written guidance on what an acceptable licensee response is or on what the results of an acceptable inspection should be. So the acceptance criteria for these different programs should already be enumerated and we should be evaluated against them. The Commission should adopt the very substantial threshold for rejection before asking for more.

No change to the GALL report is recommended.

Simpson So. Cal.

10.09 Will the draft GALL be posted on the Web? Is it possible to The GALL report is on the NRC website

p. 191 Ed.

get an electronic version?

(http://www.nrc.gov/NRC/REACTOR/LR/index.htmi).

No change to the GALL report is recommended.

Polaski PECO 10.10 Contention that all programs, regulated, reactive, and others The vast majority of programs that are being relied upon for license pp. 191-195 not listed, are effectively AMPs. Every program in a power renewal are existing programs. The license renewal rule requires the plant manages aging. The current approach to license applicant to provide a demonstration that aging effects will be renewal (credit for existing programs?) could be the best or adequately managed to ensure the intended function for the period of worst thing to happen to license renewal, extended operation. The GALL report provides a generic evaluation.

No change to the GALL report is recommended.

Dyle In-10.11 Risk informing regulations are being developed that consider The NRC recognizes that aging management has emphasized an

p. 196 services safety impacts measured from a risk perspective and pilot essentially deterministic basis, while the agency is moving towards risk Engin-programs are being developed and applied (such as the risk-informing the regulations. The underlying system operability standards eering based ISI program). Can risk be used to address aging are evolving as part of the CLB. Progress is being made towards risk management issues? Has that been factored into future considerations helping to guide regulations. For now, traditional work?

techniques will be used for judging the effectiveness of aging management programs for license renewal.

No change to the GALL report is recommended.

48 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS SPEAKER' AFFIL' ISS#3 PARTICIPANT COMMENT NRC RESPONSE T-page Bowman CNS 10.12 Both the maintenance rule and the licensing renewal rule NRC's ultimate goal in regulatory coherence is to keep plants safe. The pp. 197-198 related to intended functions are focused on the same result.

"Maintenance Rule" 10 CFR 50.65 is intended to monitor the Hopefully, these two rules will be integrated in this program effectiveness of maintenance activities in nuclear power plants. It rather than creating redundant, duplicative activity. If the focuses on the adequacy of preventive and corrective maintenance as focus remains on how aging affects intended functions, the well as inspection activities. The maintenance rule program is number of new programs (defined as a combination of evaluated in the GALL report. For example, structures monitoring function, material, environment, and aging effect) for license programs developed to meet the requirements of 10 CFR 50.65 are renewal should be kept small.

evaluated for addressing aging management of structures and structural components to meet the requirements of 10 CFR 54 (license renewal).

An applicant may integrate the GALL recommendations into their existing maintenance rule program to avoid redundant duplicate activities.

No change to the GALL report is recommended.

Walters NET 10.13 Care should be taken in turning the 10 attributes into For a program to be adequate for the period of extended operation it pp. 199-200 requirements. That was never the intention of NET 95-10.

should satisfy 10 attributes. The GALL report provides a basis when certain attributes are not applicable to specific programs. If the existing program satisfies these attributes then it is not necessary to modify the existing program. However if the existing program does not satisfy the 10 attributes then it should be augmented to manage aging for the period of extended operation, as appropriate.

No change to the GALL report is recommended. Revision 2 of NET 95 10 incorporated the 10 elements and plans are to endorse this document by Regulatory Guide (DG 1104 is currently out for public comment).

Walters NEI 10.14 The focus should be on program enhancements; but a If the existing program does not satisfy the 10 attributes, recommended

p. 200 standard should be developed to determine when for a program to be adequate for the period of extended operation, then enhancements are needed. There's no new aging that occurs it should be augmented to manage aging for the period of extended only after year 39. Reactive programs are generally operation. The GALL report provides a basis when certain attributes are accepted because they consider age, but 10 CFR, Part 50 not applicable to specific programs. If the existing program satisfies does not.

these attributes then it is not necessary to modify the existing program.

I No change to the GALL report is recommended.

49 September 2000

11. ANALYSIS OF PARTICIPANT COMMENTS '

SPEAKER' AFFIL2 ISSIP PARTICIPANT COMMENT NRC RESPONSE T-page Walters NEI 10.15 The focus in GALL is on enhancements and it should be The GALL report provides a basis when certain attributes are not

p. 201 clear that this is for managing aging to ensure functionality, applicable to specific programs. For a program to be adequate for the The key determinant to the success of the license renewal period of extended operation it should satisfy 10 attributes. If the activities will be how all the effort put into GALL gets existing program satisfies these attributes then it is not necessary to integrated into the SRP. There should be a very well modify the existing program. However if the existing program does not documented clear and solid basis for why any enhancement satisfy the 10 attributes then it should be augmented to manage aging for is needed, explaining why the program is inadequate, the period of extended operation, as appropriate.

providing information about aging and the renewal period that somehow renders that program not satisfactory. Is the enhancement needed for a technical reason or is it merely a procedural reason (not meeting the 10 attributes)? If it's a process issue, then I think we need to give serious consideration to changing the process.

No change to the GALL report is recommended.

Walters NEI 10.16 The industry's expectation is that GALL will produce results As indicated in the comment, the GALL report is similar to the Generic pp. 202-203 much like we have in the GETS, where we have category one Environmental Impact Statement (GEIS), except that the GETS is part of environmental impacts that are generically resolved. The the Part5l rule and the GALL report has not been endorsed through analysis is provided in the GELS. But for the license renewal rulemaking.

applicant, it's resolved. That's where the predictability and stability comes into the process. And then you have category two issues, where you've identified the delta or the enhancement or -- you know, there's some basis given for why it couldn't be generically resolved. And that's where we think we ought to end up with in GALL and that's where we're committed to work towards and we look forward to doing that with not only the NRC, but also all the stakeholders.

No change to the GALL report is recommended.

50 September 2000

12.

REFERENCES Official Transcript of Proceedings, United States of America, Nuclear Regulatory Commission, Public Meeting License Renewal Workshop, 205 pp., Publisher Ann Riley & Associates, Ltd. (also available on the Internet at http://www.nrc.gov/NRC/REACTOR/LR/index.html ).

License Renewal Section of NRC Website http ://www.nrc.gov/NRC/REACTORILRlindex.html Transcripts and Summaries from License Renewal Workshops and Meetings of NRC Website http://www.nrc.gov/NRC/REACTOR/LR/index.html Generic Aging Lessons Learned (GALL), Dec. 6, 1999 Draft Report, NRC/NRR (also available on the Internet at http://www.nrc.gov/NRC/REACTORILR/index.html).

ASME Boiler and Pressure Vessel Code,Section XI, Rules for In-Service Inspection of Nuclear Power Plant Components, American Society of Mechanical Engineers, 1989; including Subsection IWE (1992 Edition with 1992 Addenda),

Requirements for Class MC and Metallic Liners of Class CC Components of Light-Water Cooled Plants, and Subsection IWL (1992 Edition with 1992 Addenda), Requirements for Class CC Concrete Components of Light-Water Cooled Plants.

Code of Federal Regulations 10 CFR, PART 2 - Rules of Practice for Domestic Licensing Procedures and Issuance of Orders, Subpart B -- Procedure for Imposing Requirements by Order, or for Modification, Suspension, or Revocation of a License,or for Imposing Civil Penalties -- Section 2.206, Requests for action under this subpart.

Code of Federal Regulations 10 CFR, Part 50, Domestic Licensing of Production and Utilization Facilities.

Code of Federal Regulations 10 CFR, Part 50, -- Appendix B (Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants), Appendix G (Fracture Toughness Requirements), Appendix H (Reactor Vessel Material Surveillance Program Requirements), Appendix J (Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors).

Code of Federal Regulations 10 CFR, Part 50, "Domestic Licensing of Production and Utilization Facilities" -- 50.48, Fire Protection.

Code of Federal Regulations 10 CFR, Part 50, "Domestic Licensing of Production and Utilization Facilities" --50.49, Environmental qualification of electrical equipment Important to Safety for Nuclear Power Plants.

Code of Federal Regulations 10 CFR, Part 50, "Domestic Licensing of Production and Utilization Facilities" -- 50.54, Conditions of Licenses.

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Code of Federal Regulations 10 CFR, Part 50, "Domestic Licensing of Production and Utilization Facilities" - 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants.

Code of Federal Regulations 10 CFR, Part 50, "Domestic Licensing of Production and Utilization Facilities" - 50.71, Maintenance of Records, Making of Reports including 50.71(e) guidance to make sure that the FSAR is the repository of the critical safety functions and compliance matters.

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Code of Federal Regulations 10 CFR, Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants, Section 54.30, Matters Not Subject to a Renewal Review.

September 2000 51

GSI-168 (Generic Safety Issue 168), Environmental Qualification of Electrical Equipment, USNRC, Revision 1, June 30, 1995.

GSI-190 (Generic Safety Issue 190), Fatigue Evaluation of Metal Components for 60-Year Plant Life, USNRC, September 1995.

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NRC Bulletin 88-1I: Pressurizer Surge Line Thermal Stratification, December 20, 1988.

NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, March 17, 1988.

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NRC Generic Letter 89-08, Erosion/Corrosion-Induced Pipe Wall Thinning, May 2, 1989.

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September 2000 52

Regulatory Guide 1.90, Inservice Inspection of Prestressed Concrete Containment Structures with Grouted Tendons, August 1977.

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Standard Review Plan (SRP-LR) for the Review of License Renewal Applications for Nuclear Power Plants, Draft, USNRC-NRR, Draft-April2l, 2000 (4/21/00 draft also available on the NRC license renewal web site at (http://www.nrc.gov/NRCIREACTOR/LR/SRP/srp toc.html).

September 2000 53