ML20134D048
| ML20134D048 | |
| Person / Time | |
|---|---|
| Issue date: | 01/31/1997 |
| From: | Hoffman S NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-690 NUDOCS 9702040276 | |
| Download: ML20134D048 (77) | |
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'g NUCLEAR REGULATORY COMMISS!ON WASHINGTON, D.C. 205!M001 January 31, 1997 ORGANIZATION:
Nuclear Energy Institute (NEI)
SUBJECT:
SUMMARY
OF MEETING WITH NEI REGARDING THE NRC STAFF'S REGULATORY GUIDE AND NEI'S GUIDELINE FOR IMPLEMENTING THE LICENSE RENEWAL RULE On January 21, 1997, representatives of NEI met with the Nuclear Regulatory Commission (NRC) staff in Rockville, Maryland to present views on proposed guidance for inclusion in the final version of either the NEI " Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - the License Renewal Rule," NEI 95-10, or the NRC staff's Regulatory Guide (RG), " Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." The agenda for the meeting is provided in Attachment 1 and the attendees are listed in Attachment 2.
The NRC staff is currently preparing proposed revisions to its draft RG or to NEI 95-10, as applicable, to resolve the public comments received. Most of the topics for which additional guidance is needed are also known to NEI which is also developing proposed revisions to NEI 95-10.
Following were the views presented for each agenda topic:
License Renewal Demonstration Proaram lessons-Learned Reoorts The NRC staff issued NUREG-1568, " License Renewal Demonstration Program: NRC Observations and Lessons Learned," December 1996, to document the experience gained from participation in the demonstration program.
NEI requested clarification on whether the NRC staff intended to issue additional guidance on the intent of the rule for topics where the report states that the staff will. recommend additional guidance to meet the intent of the rule.
The staff stated that it is not treating these topics any differently than the other topics for which revised or additional guidance is needed. NEI may develop proposed revisions for these topics and submit them for NRC review.
NEI has not issued its lessons-learned report and will inform the staff of its schedule for issuing the report.
Clarification of Positions GhA (1) Dec. 24, 1996, NEI Letter - Active / Passive Determinations The NRC staff commented on the NEI letter dated December 24, 1996, which discussed the active versus passive determination of several electrical devices.
Fuses, transformers, and indicating lights were considered in the s
NEI letter to be active components and outside the scope of aging management 040050 BC RLE CffWs egpy pgc6 t#o i
9702040276 970131 PDR PROJ 690 PDR j
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review.
The NRC staff proposed that in addition to these components performing their other intended functions, maintaining electrical continuity in these components provides a basis for considering them passive and thus subject to aging management review. NEI disagreed with this staff interpretation and stated that they believe these components should be categorized as active based on the philosophy the staff used to specifically exclude components from aging management review in f 54.21(a)(1)(i) of the
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license renewal rule (e.g., the rule specifies that motors, breakers, switchgear, relays, switches, and others are excluded from the scope of review). The staff stated that it would consider the industry position and l
present its response in a letter to NEI.
(2) NEI Index Item No. 96-14: Bolting, Piece-Parts or Components NEI identified this topic as needing guidance in NEI 95-10 as Item No. 96-14 in Revision 7 of its Index of Questions / Topics submitted by letter dated December 6, 1996.
The staff requested clarification. NEI indicated that it intended to propose guidance for evaluating three categories of bolting that it had identified:
1.
Bolting in components within the scope of aging management review (passive) that contribute to maintaining an intended function (e.g.,
bolts en a manway gasket that contribute to maintaining the intended function of pressure boundary). NEI stated that an applicant would need to perform an aging management review for this category of bolting.
2.
Bolting in components not within the scope of aging management review (active).
NEI stated that an applicant would not need to perform an aging management review for this category as the bolting in this case is considered to be a piece-part of the component.
3.
Bolting on the portion of a component within the scope of aging management review that does not contribute to maintaining the passive intended function.of the component (e.g., bolting on the pump impeller which is considered outside the scope of aging management review whereas the pump casing is within the scope of review).
NEI stated tha;. an applicant would not need to perform an aging management review for this category.
This topic is not intended to address bolting associated with supports.
This i
bolting is evaluated along with the support members.
(3)
Industry Comments on the Regulatory Guide Implementation Plan The staff requested that NEI clarify the basis for its comment requesting revision of the implementation plan described in draft RG, DG-1047, Section C.I.
The coment requested deletion of all items except the list of tasks that will not be completed at the time the renewed license is issued and the schedule for their completion. NEI indicated that the remainder of the items requested are not needed in the application implementation plan because
[ commitments regarding aging management programs will be contained in the required Updated Final Safety Analysis Report (UFSAR) supplement.
Detailed lists of commitments are maintained in the applicant's onsite commitment tracking system.
NEI Presentation of Proposed Guideline Revisions NEI provided the following documents at the meeting:
Attachment:
3.
Complete rewrite of KI 95-10, Section 4.2, to address the requirements and level of detail in the application for aging management programs and the required demon nrations and to discuss crediting existing programs.
This submittal addresses NEI Index Item Nos. 96-04, 05, 06, 08, 15 (partial), and 21.
4.
Revision of NEI 95-10, Section 6.0, to address level of detail for the UFSAR supplement.
This submittal addresses NEI Index Item Nos. 96-08 and 09.
5.
Topic Paper:
License Renewal UFSAR Supplement Level of Detail Example:
UFSAR Supplement for License Renewal 6.
Topic Paper:
Level of Detail in an Application for a New Inspection Program Example:
Description of the Augmented Inspection for License Renewal of the Alloy 82/182 Clad Flow Meter Section 7.
Revision of NEI 95-10, Section 4.3, to address NEI Index Item No. 96-15 on application of inspections for license renewal 8.
Discussion on How Gaskets, Seals and Other Similar Consumables are Addressed in the Integrated Plant Assessment (IPA)
The NRC staff indicated that it would review the handouts and respond to NEI.
Proposed NRC Staff Resolution of Comments The NRC staff distributed Attachment 9 which contains proposed revisions to the draft RG and NEI 95-10 for the following:
(1) Response to NEI letter Dated December 24, 1996 The staff provided proposed revisions to changes made by NEI in the areas of scoping and timing for performing evaluations of time-limited aging analyses.
3
- (2) Matters Not Subject to Review The revisions reflect the staff's proposed acceptance of the public comments received.
(3)
Environmental and Editorial The proposed revisions reflect the staff's acceptance of the public comntents received. The staff also indicated that based on SECY-96-259, dated December 19, 1996, the current schedule for issuing the environmental RG addressing the requirements for implementing the license renewal rule is July 97, draft, and March 1998, final. The environmental standard review plan addressing implementation of the license renewal rule is scheduled for August 1997, draft, and August 1998, final.
(4) Quality Assumce Programs for Documentation The revisions reflect the staff's proposed acceptance of the public comments received.
Schedule (1)
Periodic Working Level and Senior Management Meetings Working level meetings between the NRC staff and NEI ar. scheduled for January 30; February 10, 20, and 27; and March 6, 1997.
NEI believes that senior management meetings between the NRC and NEI are beneficial and a potential meeting was discussed around February 14, 1997.
(2) Commission Briefing (and)
(3)
Issue Final Regulatory guide The schedule for issuing the final RG in August 1997 requires resolution of comments by February 14, 1997, and preparation of the final RG and NEI 95-10 for approval by March 14, 1997. A Commission briefing on the status of license ',enewal activities, which will include development of the final RG, is scheduled for the week of June 16, 1997.
The final RG will be submitted to the Commission for approval.
/
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Stephen T. Hoffman, Senior Project Manager License Renewal Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Project 690 Attachments: As stated cc w/atts:
See next page I
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NUCLEAR ENERGY INSTITUTE (NEI)
Project No. 690 cc: Mr. Dennis Harrison U.S. Department of Energy NE-42 Washington, DC 20585 Mr. Douglas J. Walters Nuclear Energy Institute 1776 I Street, NW Suite 300 Washington, DC 20006 Mr. Richard P. Sedano, Commissioner State liaison Officer State of Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, Vermont 05620-2601 4
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RZimmerman (RPZ)
TMartin (TTM)
DMatthews-(DBM) 4 SNewberry (SFN)
SHoffman (STH)
EJordan (JKR) i PShemanski (PCS) i BPrato (RJP2)-
PTKuo (PTK)-
JVora (JPV)-
SFlanders (SCF)
JMoulton (JPM1) i Slee (SSL1) 1 WLiu (WCL2)
JFCostello (JFC2)
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SDroggitis (SCD) m Glainus (GCL) t JCraig (JWCl).
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AGENDA JANUARY 21, 1997 NRC - NEI MEETING LICENSE RENEWAL REGULATORY GUIDE AND INDUSTRY IMPLEMENTATION GUIDELINE 1
j License renewal demonstration program lessons-learned reports (1) NRC: NUREG-1568 3
(2) NEI 1
Clarification of positions l
j i
(1)
Dec. 24, 1996, NEI letter - active / passive determinations j
(2) NEI Index Item No. 96-14: bolting, piece-parts or components (3)
Industry comments on the regulatory guide implementation plan 4
i NEI presentation of proposed guideline revisions Proposed NRC staff resolution of comments t
(1)
Response to NEI letter dated Dec. 24, 1996 1
(2) Matters not subject to review
}
{
(3)
Environmental and editorial l
(4) Quality assurance programs for documentation Schedule j
(1)
Periodic working level and senior management meetings (2) Commission briefing 1
(3)
Issue final regulatory guide 1
s
.i l
1 i
4
]
ATTACHMENT 1
1 ATTENDANCE LIST NRC MEETING WITH THE NUCLEAR ENERGY INSTITUTE JANUARY 21. 1997 HMiE ORGANIZAILQB 1.
Steve Hoffman NRC/NRR/DRPM/PDLR 2.
David Masiero GPU Nuclear 3.
Barry Tilden BGE 4.
Robert Gill Duke Power 5.
Doug Walters NEI 6.
Fred Polacki PECO Energy 7.
Ray Baker Southern Company 8.
Bill Mackay Entergy - AN0 9.
Paul Shemanski NRC/NRR/DRPM/PDLR 10.
Bob Prato NRC/NRR/DRPM/PDLR i
11.
P. T. Kuo NRC/NRR/DPPM/PDLR 12.
Jit Vora RES/EMMEB 13.
Scott Flanders-NRC/NRR/DRPM/PDLR 14.
John Moulton NRC/NRR/DRPM/PDLR 15.
Sam Lee NRC/NRR/DRPM/PDLR 16.
Winston W. C. Liu NRC/NRR/DRPM/PDLR 17.
J. F. Costello RES/DET 18.
Tricia Heroux for EPRI 19.
Alice Carson Bechtel 20.
Barry Sullivan NUS INF0 Services a
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4.2 -
Aging Management Reviews 3
4 Part 54 Reference 5
6 54.21(a)(3) 7.
8 (3)
For each structure and component identified in paragraph (a)(1) of this 9
section, demonstrate that the effects of aging will be adequately managed so that 10 the intended function (s) will be maintained consistent with the CLB for the period l
11_
of extended operation.
12 13 14 i
15 Although there are several approaches to performing an aging management review, two general 16 methods are described in this guideline. Each method can be used to demonstrate that the effects 17
. of aging are being managed such that the intended function of the stmeture or component is 18 maintained consistent with the CLB for the period of extended operation. Each method in this 19
. section is applicable to evaluations ofindividual stmetures, components or commodity groupings.
4 20 Although only two methods are included in this guideline, other methods may be acceptable 21 provided that the demonstration required by Section 54.21(a)(3) is accomplished.
22 l
23 The first method is an aging management review of a structure, component or commodity 24 grouping. If aging effects requiring management are identified, an aging management review will 25 typically identify one or more aging management programs, either existing or new to be credited i
26 in order to meet the requirements of 10CFR54.21(a)(3). Three different types of aging i
27 management programs are described. These are (1) preventive or mitigative aging management 28 programs, (2) condition monitoring, and (3) performance monitoring.
29 30 The second method utilizes the results of previous aging management reviews of a similar 31 component or structure. These aging management reviews may have been either found 32 acceptable by the NRC, or may be in other reports which have not been reviewed by the NRC.
33 Examples of aging management reviews found acceptable by the NRC include the license renewal 34 topical reports developed by the Nuclear Steam Supply System (NSSS) Owners' Groups and l
35 previous plant specific applications. Examples of reports which are valuable sources of 36 information, but which have not been reviewed by the NRC, are the DOE Aging Management 37 Guidelines. More information on use of previous reviews can be found in Section 4.3.
38.
39 The aging management review is developed by first understanding how the structure, component, 40 or commodity grouping performs its intended function (s). Second, the aging effects associated l
41' with the structure, component, or commodity grouping are identified. Third, it is determined if 4
42 analysis can be used to demonstrate that the results of the aging effect are such that the intended 43-function (s) is maintained during the period of extended operations. Finally, if needed, the j
44 applicable plant programs are identified, and the ability to detect, mitigate, or prevent the aging 45 effects are reviewed. It may be necessary to propme enhancements to existing programs or to i-1 ATTACHMENT 3
Tcbla Trccking Nos. 96-04, 96-05, 96-06,96-08 96-15(p;rtid) and 96-21 Draft January 21,1997 1
develop new aging management programs if existing programs are not adequate for managing the 2
effects of aging for the period of extended operation. The assembled information is then used to 3
demonstrate that the effects of aging will be managed so that the structure or component intended 4
function (s) will be maintained for the period of extended operation. (Figure 4.2-1 depicts this 5
process.)
6 7
8 4.2.1 Identify and Assess Aging Effects 9
10 In Section 3.2 of the guideline, the system, structure and component intended functions were 11 identified, and in Section 4.1 the structure's or component's intended function (s) were 12 determined. There are various techniques used to identify and assess aging effects. For some 13 stmetures and components, design margins and/or material properties are known and can be 14 reviewed. In such cases, an analysis may be sufficient to demonstrate that the effects of aging are 15 managed. For other stmetures and components, performance or maintenance history is available 16 and can be reviewed to assist in demonstrating that the efTects of aging are managed. These and 17 other considerations point to the need to determine the appropriate level of review for the type of 18 stmeture, component, or commodity grouping and plant-unique conditions.
19 20 Assessing the appropriate level of review involves examining information from various 21 investigations and developing a scope statement to describe the depth of review that is needed for 22 the'stmeture, component, or commodity grouping. As appropriate, the assessment should include 23 the following activities:
24 25 Assemble information relative to the stmeture or component material and service 26 environment. If the components are made from different materials or are subject to distinctly 27 different aging effects, a separate review of each may be needed.
28 29 Identify the aging effects potentially affecting the structures' and components' ability to 30 perform their intended function (s). This review is intended to identify potential aging effects 31 on the basis of assembled industry information, as well as plant specific determinations (e.g.
32 from maintenance histories.)
33 34 Review the design or material properties to determine if analysis can demonstrate that the 35 effects of aging are sufficiently managed to maintain the capability of the structure or 36 component to perform its intended function during the period of extended operation. Of 37 particular interest are parameters such as corrosion allowance, fatigue cycles, loading 38 conditions, fracture toughness, tensile strength, dielectric strength, radiation exposure, and 39 environmental exposure.
40 41 Review and assess the operating and maintenance history for the stmeture or component. The 42 focus of the review may include the service duty, operational transients, past failure, or 43 unusual conditions that affect the performance or condition of the structure or component. Of 44 panicular interest is how the performance or degraded condition of the structure or 2
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January 21,1997 1
component affects the capability of the structure or component to perform its intended 2
function and its risk significance. The review also may include an examination of repairs, 3
modifications, or replacements for relevance to aging considerations.
4 5
6 Identify design features that prevent or mitigate aging of the structure or component. The 7
plant may have been designed with equipment which serves to prevent age related degradation 8
of structures or components. These design features may be used as part of an analysis to 9
show that specific aging effects are not clausible.
10 11 Identify installation and maintenance practices that are accepted as preventing or mitigating 12 the aging effect of concern. Generally, the maturity of these maintenance practices is 13 sufficient that programmatic verification is not warranted.
14 15 To determine the aging effects of concern, the applicant should consider and address the 16 materials, environment, stressors, and industry operating experience that are associated with each 17 structure, component or commodity grouping under review. In many instances, the proper 18 selection of materials for the operating environment results in few, if any, aging effects of 19 concern. For example, loss of material due to erosion / corrosion is not an aging effect of concern 20 for stainless steel piping, while it could be for carbon steel pipe. Also, carbon steel pipe is subject 21 to loss of material due to general corrosion in a raw water environment, whereas certain stainless 22 steels are not. However, there should be various programs and activities available to manage the 23 loss of material in the carbon steel pipe.
24 25 In addition to the consideration of materials, environment, and stressors, the applicant should 26 consider and address the plant-specific CLB, plant operating experience, plant design features, 27 plant maintenance practices, and existing engineering evaluations in order to identify the aging 28 effects of concern for the structure or component subject to an aging management review. The 29 aging effects of concern are those that have been identified using the considerations described 30 above, and that adversely affect the structure and component such that the intended function (s) 31 may not be maintained consistent with the CLB for the period of extended operation. Aging 32 effects may not be plausible because of environmental conditioris, design features, or maintenance 33 practices. For example, cathodic protection is a design feature that can prevent external corrosion 34 of underground equipment, thus eliminating loss of material as a plausible aging effect. An 35 example of an installation or maintenance practice is the application of nonoxidizing compounds 36 to electrical cable terminations to prevent oxidation, thus preventing high electrical resistance 37 from occurring.
38 39 Water chemistry control practices, while effective at preventing loss of material due to corrosion 40 on the inside wall of pipe, are credited as a plant program to manage the effects of aging.
41 Although water chemistry control practices may be required by Technical Specifications and have 42 been im lemented for the life of the plant, they require positive actions by personnel and 43 equipme:a to maintain the water chemistry within specified limits. General corrosion could occur 44 if water chemetry parameters are outside of the allowed operating ranges.
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January 21,1997 1
2 By analysis, an applicant may be able to demonstrate that the results of an aging effect are such 3
that the intended function (s) of the structure or component' will be maintained under all CLB 4
design conditions. The demonstration ultimately should conclude that there is reasonable 5
assurance that the CLB will be maintained for the period of extended operation and therefore that 6
the effects of aging need not be managed. An inspection for license renewal, as discussed in 7
Section 4.4, may be utilized to verify specific design values, demonstrate that an aging effect is 8
occurring as anticipated, or that an aging effect is not significant. Monitoring industry experience, 9
such as the results ofinspections for license renewal at other plants, may also contribute to the 10 demonstration in these cases.
11 12 4.2.2 Identify Plant Aging Management Programs 13 14 Plant programs that apply to the structures, components, or commodity groupings should be 15 reviewed to determine if they include actions to detect, mitigate or prevent the effects of aging.
16 The Rule does not contain specific requirements for features of an acceptable aging management 17 program. These features will vary depending on the structure, component or commodity 18 grouping. Three types of aging management programs described in this document are (1) those 19 that prevent or mitigate aging effects, (2) those that monitor the condition of the structure or 20 component, and (3) those that monitor the performance of the stmeture or component. These are 21 described in sections 4.2.2.1,4.2.2.2, and 4.2.2.3, respectively. Aging management programs that 22 do not fit into one of these three types may also be acceptable, as long as the program is effective 23 in managing the effects of aging. Any program to be credited as an aging management program 24 for license renewal must be implemented in accordance with the plant's administrative procedures.
25 Corrective actions resulting from the aging management program may be controlled by the aging 26 management program or, more commonly, will be controlled by the plant's existing corrective 27 action program.
28 29 The review of the aging management program must include verification that the program is 30 sufficient to prevent, mitigate, or detect age related degradation so that the intended function (s) 31 will be maintained. This includes methods, techniques, alen values, action values, direction for 32 expanded sampling, etc. The details relating to these techniques for each aging management 33 program are further discussed below. This information should be included in the aging 34 management review.
35 36 37 4.2.2.1 Preventive or Mitigative Aging Management Programs 38 39 A preventive aging management program is one that will limit the degradation of the structure or 40 component to such small quantities that the degradation is not detectable. A preventive aging 41 management program may also be referred to as a program that precludes age related degradation 42 from occurring.
43 44 A mitigative aging management program is one that willlimit the degradation of the structure or 45 component to quantities that are detectable, but sufficiently small that the structure or component 4
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characteristic or property of concern will not be challenged during the lifetime of the plant. A 2
mitigative aging management program may also be referred to as a program that inhibits age 3
related degradation.
4 5
Other than the difference that aging is detectable in a mitigative program, as compared to a 6
preventive program, both types will have the same characteristics and attributes. They are 7
generally existing programs which have been in effect since the plant was initially operated, but j
8 may be new programs or enhancements to existing programs.
9 10 These programs are effective because they control the environment of the structure or component i
11 so that the environmental conditions needed for aging to occur do not exist. The environment of i
12 concern can include chemistry conditions inside a pipe, external environments, or use of coatings 13 to prevent the aging from occurring. Tb applicant must perform an assessment of the aging 14 effects and operating history and show that age related degradation can only be caused by l
15 adverse process fluid properties or environmental conditions. The program must include l
16 parameters of the environment (e.g. secondary water chemistry oxygen level) which are l
17 monitored periodically, and for which action and alert values have been established to restore the 18 environment to within specified limits in a timely manner when deviations from acceptable values 19 occur. The parameter that is monitored may either provide direct or indirect indication of the 20 condition of the component or structure. Indirect indications are used when the environment 21 being controlled cannot be visually observed or directly monitored (e.g. inside of pipe). Indirect 22 indications monitor chemical properties of the fluid or environmental conditions that are related to i
23 the aging effect of concern. Direct indications are used when the environment can be visually 24 observed or directly monitored (e.g. external surfaces).
25 26 Although an aging management program that is designed to prevent or mitigate the effects of 27 aging is expected to preclude or sufficiently inhibit the effects of aging, a verification of the 28 effectiveness of the preventive or mitigative aging management program may be needed. Some 29 manner of condition monitoring, such as an inspection to measure wall thickness of a pipe, may be 30 needed in conjunction with the preventive or mitigative aging management program to 31 demonstrate that the effects of aging are being adequately managed. An example of this is 32 feedwater chemistry control program, along with a one time inspection to determine wall 33 thickness of the feedwater piping.
34 35 An example of a preventive aging management program is control of the chemistry of the sodium 36 pentaborate solution in the standby liquid control system of a BWR to prevent corrosion of the 37 storage tank, piping, val's and pumps 38 39 Another example of a preventive aging management program is the application of coatings or 40 paint to a component to prevent degradation due to general corrosion. Specifically, this could be 41 the painting of the exterior of a heat exchanger that could experience external corrosion due to 42 condensation, caused by the cold cooling water on the shell side of the heat exchanger.
43 44 Refer to Table A for additional examples of preventive or mitigative aging management programs.
45 5
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1 4.2.2.2 Condition Monitoring Aging Management Programs 2
3 A condition monitoring program is one which monitors, inspects, tests, or measures the physical 4
condition of the SC to detect from direct information degradation due to the effects of aging. A 5
condition monitoring program performs an inspection of the physical property of the SC. The
)
6 inspection may or may not be intrusive. The inspection technique used by the condition 7
monitoring program may be any one of a wide range, including visual, ultrasonic measurement, 8
physical measurement of size, hardness measurement, radiographs, etc. The technique used must 9
be appropriate for the aging effect of concern, the SC being considered, the significance of the 10 aging effect, the rate of degradation, and the frequency of the inspection. The program may also 11 use a sampling approach. An example of an aging management program that demonstrates how 12 these considerations are properly factored in to the program is the erosion / corrosion program i
13 which monitors for loss of material in piping.
14 15 Condition monitoring programs range from sophisticated inspection techniques to very simple 16 inspections. The ultrasonic inspection for pipe cracking is an example of a sophisticated, 17 technically complex condition monitoring program. Visual inspection of piping supports under 18 ASME Section XI Subsection IWF is an example of a condition monitoring program using 19 relatively simple techmques.
20 21 Refer to Table B for additional examples of condition monitoring aging management programs.
22 i
23 24 4.2.2.3 Performance Monitoring Aging Management Programs 25 26 A performance monitoring program is one which monitors process parameters to provide an 27 indication of the condition of the system, structure, or component with respect to the aging effect 28 ofinterest. The performance monitoring program may be an aspect of nonnal plant operations, or 29 it may be a test that is performed periodically to ascertain the performance of a component or 30 structure. A performance monitoring program must include action or alert values, or the trending 31 of changes in parameter values, which will result in corrective action being initiated.
4 32 33 An example of an existing performance monitoring program is the technical specification testing 34 of the control room ventilation system to verify its flow capacity.
35 36 Two cases are discussed below where performance rnonitoring may be credited as an aging 37 management program. There may be other cases which are not discussed here.
4 6
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Case 1 2
i 3
For some components, the design of the plant, as delineated in the CLB, provides for the use of
'4 performance monitoring to detect degradation of camponents by monitoring system parameters.
5 An example of this is the leakage from the reactor coolant pressure boundary of a BWR. The 6
CLB provides for measurement of leakage from the RCPB by the rate of pump outs from the 7
containment sumps. Alert and action values are established in the technical specifications at levels 8
which result in corrective action (e.g. plant shutdown) before the degradation results in a i
9. condition that is outside the design of the plant systems. For this approach to be used, the CLB 10. must include allowances for degraded condition of the passive structure or component, while 11 allowing the intended function (s) to be accomplished. To establish this, the applicant will need to 12 develop the following information:
i 13
.1 14 Review the CLB and identify that the degraded performance or condition j
15 contemplated by the CLB considered the characteristics of the relevant aging effects, j
16 17 Perform an assessment of the aging effects, operating history, and attributes of the i
18 monitoring program and show that the degraded performance will be manifested over l-19 a time period where the aging effects will be detected by the monitoring program 20 activities, and
)
21
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22 Show that the considerations in the CLB are the basis for performance monitoring e
i l
23 criteria and that the criteria will result in timely corrective action so that the intended l
24 function (s) will be maintained consistant with the plant specific CLB design basis i
25 conditions, 26 l
27 Case 2
[
28 j
29 For some structures and components in the scope oflicense renewal, the design conditions for j
30 these structures and components do not include all of the loading conditions, including seismic, i
31 required for safety related systems. For example, the fire protection systems at some plants are 32 designed to National Fire Protection Association standards, and are not designed for seismic 33 conditions. For these structures and components, a less rigorous monitoring program is needed i-34 because the applicant must only be able to demonstrate system ftmetionality under normal l
35 operating conditions. In fact, performance monitoring will provide adequate demonstration of the 36 intended function of the system, structure or component in many cases. The following criteria 37 should be used by an applicant to determine if performance monitoring will provide adequate l
38 assurance that functionality is maintained:
4 39 40 e
Review the CLB and show that the design of the system, stmeture, or component was i
41 only required to consider nonnal loads, g
42 4
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January 21,1997 1
e Perform an assessment of the aging effects and attributes of the monitoring program l
2 and show that the program activities ensure that aging effects (such as leakage) l 3
affecting condition will be detected, 4
5 Show that the monitoring criteria will result in corrective action so that the system 6
intended function (s) will be maintained, and 7
8 Confirn that the operating history provides supportingjustification for the conclusion 9
that the performance monitoring program will detect the aging effects and result in 10 timely corrective action.
11 12 Refer to Table C for additional examples of performance monitoring aging management 13 programs.
14 15 16 4.2.3 emonstrate That the Effects of Aging Are Managed 17 18 The key part to a license renewal application is the demonstration that the effects of aging will be 19 adequately managed during the extended period of operation, as required by 10 CFR 54.21(a)(3).
20 The demonstration is the final conclusion, based on the technical work performed in the aging 21 management reviews, that the applicant will be able to adequately manage the effects of aging so 22 that the intended functions of the structures and components in the scope oflicense renewal will 23 be maintained consistent with the CLB. The demonstration should include the following five 24 elements:
25 26 The aging effect(s) of concern.
27 28 The aging management program (s) that is being or will be used to manage.ne aging effect.
29 30 The connection between the aging management program, the aging efTect and the intended 31 function. This is also described as "the link."
32 33 A description of how the aging management program has er will mitigate, prevent, or detect 34 t n etTect of aging so that the intended function will be maintained. More details on this 35 element are provided in sections 4.2.3.1 through 4.2.3.3 for the different types of aging 36 management programs.
37 38 A clear statement that the aging management program will manage the effects of aging in the 39 future so that the intended function will be maintained, including an explanation of the 40 justification.
l 41 l
42 When describing the aging management program, and how it is or will be effective at managing 43 the effects of aging, the demonstration may be made either from the viewpoint of actual j
44 operating experience, or from the view of attributes of the program. For an existing program that t
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is being credited as an aging management program, the use of plant operating experience is the 2
preferred approach, but either approach is acceptable. Actual experience (e.g. wall thickness 3
measurements and trend analysis) may be used for an existing program to demonstrate that the 4
effects of aging are being managed so that the intended function is maintained during the period of 5
extended operation.
6 7
Aging management programs that have been implemented as a result of rules, operating heense 8
conditions (including technical specifications), and industry codes have, in general, the following 9
attributes:
10 11 the requirements are generic and have been developed through an industry wide consensus 12
- process, i
13 14 the requirements have been in place many years and have been refmed over the years based on 15 actual operating experience; 16 17 regulatory guidance for implementing the requirements is available; 18 19 regulatory oversight via inspection and enforcement is prosided, 20 21 revisions to the generic requirements are made through an industry wide review and comment 22 process; 23 24 revisions to the plant specific programs are made within the bounds established by the generic 25 requirement; 26 27 difTerences between plant programs and the generic requirements are addressed via NRC 28 review of either exemptions or relief requests.
29 30 The level of detail required to demonstrate that these types of aging management programs are 31 effective is small in comparison to the other types of aging management programs described in the 32 following paragraphs because of the extensive regulatory oversight not only in the development of 33 the regulatory requirement, but also in the osersight of the plant specific implementation.
34 35 Aging management programs that have been implemented in response to NRC generic 36 communications have, in general, the following attributes:
37 38 the requested activity is communicated by either an NRC bulletin or Generic Letter which has 39 undergone substantialinternal NRC review and approval; 40 41 the NRC initially reviews many of the plant specific implemented programs; 42 43 ongoing regulatory oversight is provided by inspection and enforcement; 44 9
l Tebis Traking Nos. 96-04, 96-05, 96-06,96-08 96-15(partial) and 96-21 i
Craft January 21,1997 1
the licensee is responsible for the review and approval of changes to the implemented 2
programs in accordance with established plant procedures.
3 4
More detail is required in the demonstration that these types of programs are effective because of 5
the ability of the licensee to effect changes to the programs without direct regulatoy oversight.
6 7
Aging management programs that have been implemented by plant management and are not in 8
response to a regulatory requirement or communication have, in general, the following attributes:
9 10 little or no regulatory guidance; 11 12 little or no regulatory oversight; 13 14 program elements are based on plant and/or industry operating experience; e
15 16 revisions to the programs are made in accordance with established plant processes.
17 18 Even more detail is necessary in this type of program because of the limited regulatog 19 involvement in either the development of the initial program or in the ongoing oversight of the 20 program.
21 22 Aging management programs that are implemented as a result of the aging management reviews 23 being performed to develop a license renewal application are generally of two types: those that 24 are implemented and will continue as ongoing programs and those that are one-time activities. In 25 both instances, the demonstration requires that as complete a description of the aging 26 management program or activity as possible be included in the aging management review. This 27 information should be provided from the perspective of'what will be done.' In addition, 28 following the implementation of the program, the licensee may provide reports to the NRC, on an 29 agreed upon schedule, to document what has been done ad what results have been obtained.
30 31 For a new program that is being proposed for license renewal, because no data exists, the 32 attributes of the program will have to be used to demonstrate that the effects of aging will be 33 managed so that the intended function will be maintained. The attributes of the aging 34 management program can be demonstrated by several means:
35 36 demonstration that the techniques have been used successfully on similar SCs at the plant 37 38 demonstration that the techniques have been used successfully on similar SCs at other nuclear 39 power plants 40 l
41 if the techniques have not been used in similar situations before, *he applicant may have to e
42 demonstrate that the aging management program is capable of preventing, mitigating, or 43 detecting the aging efTect of concern.
44 10
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1 The last approach described may require development of equipment and procedures, testing, l
2 validation, verification, and training.
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4.2.3.1 Preventive or Mitigative Aging Management Pro; rams 6
t 7
To demonstrate that the effects of aging are being adequately managed by an existing aging 8
management program, the applicant must show that the aging management program has been and l
9 will continue to either prevent or mitigate the age related degradation. This can be done by using i
10 historical evidence either from the plant or from other nuclear plants that shows that the aging l
11 management program has been effective, and that the conditions under which the aging 12 management program has been effective in the past will be retained into the future.
13 14 For example, control of chemistry of the sodium pentaborate solution in the standby liquid control 15 system of a BWR is effective at preventing corrosion of the subcomponents in the system. Over 16 twenty years ofindustry experience has shown that with proper control of the chemistry of the 17 solution, there have been no age related failures of equipment on this system. Existing chemistry 18 monitoring programs have been and will continue to be adequate to properly maintain the solution 19 chemistry parameters within specified limits. No inspections of the equipment will be needed 20 because the existing aging management program is adequate to prevent age releted degradation.
l 21 22 23 For a new aging management program, the applicant must show that other aging management 24 programs that use this approach have been successful at preventing or mitigating the effects of I
25 aging. If this type of aging management program has never been implemented in the past, the 26 applicant will have to demonstrate how the techniques to be implemented will be able to prevent 27 or mitigate the effects of aging. The demonstration may have to include detailed information on 28 hov the aging management program works, and may have to include provisions for condition i
29 monitoring until the capabilities of the aging management program are demonstrated in the power 30 plant.
31 32 An example of a new preventive aging management program is the painting of the exterior of a 33 heat exchanger that has experienced external corrosion due to condensation, caused by the cold 34 cooling water on the shell side. The degradation has been monitored and is not severe enough to 35 cause concern with the operability of the heat exchanger presently. However, if the loss of 36 material would continue for the remaining life of the current license plus an additional twenty 37 years, the ability of the heat exchanger to perform its intended functions (i.e. pressure boundary) 38 could be questioned. To avoid this problem, the applicant could elect to paint the heat exchanger 39 to prevent further loss of material. The heat exchanger paint condition could be monitored by any 40 of several existing programs, such as system manager inspections, which would detect 41 deterioration of the paint before additional loss of material of the heat exchanger shell could l
42 occur. Deterioration of the paint would be corrected using the plant's corrective action program.
43 i
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4.2.3.2 Condition Monitoring Aging Management Programs 3
4 To demonstrate that the effects of aging are being adequately managed, the applicant must show 5
that the condition monitoring program is capable of detecting the effect of aging such that there is 6
reasonable assurance that the intended function of the structure or component will be maintained.
7 For existing programs, this can be shown by using actual results ofinspections performed in the 8
plant.
9 10 An example of an existing condition monitoring program is the inspections performed to identify 11 wall thinning of pipe in service water systems, in response to Generic Letter 89-13. These 12 inspection programs use various techniques (e.g. UT and RT) to detect loss of material of the 13 pipe wall, and include appropriate alert and action values, and criteria for additional sampling or 14 more frequent inspections based on actual results. Wall thinning wluch reaches alert or action 15 values initiates corrective actions in accordance with the direction in Generic Letter 89-13 and the 16 plant's existing corrective action programs.
17 18 For a new program, several approaches can be used. If the technique has been used on other 19 components, the applicant must show that the techniques can be used to detect degradation of the 20 component in question. For instance, the applicant may elect to perform an augmented ISI 21 inspection of a component which is not included in the scope of the Inservice Inspection Plan 22 using existing techniques and code requirements. If the technique has been used in other nuclear 23 power plants, but is new to the applicant, the applicant must show that the proposed techniques 24 are the same as used at other plants, and that other factors, such as material and environment, 25 support the use of this technique. Doing this will allow the applicant to credit the experience at 26 other plants. If the new program uses techniques that have not been used elsewhere before, the 27 applicant will have to demonstrate how the condition monitoring technique can detect the aging 28 effect. This may require actual demonstration to validate and verify the adequacy of the 29 technique. An example of this is the development of the ultrasonic techniques presently used to 30 detect cracks in piping, which had an ex,ensive testing, validation, verification and training 31 program.
32 33 For example, a new program that measures the thickness of the wall of an underground buried 34 tank, compares the wall thickness to alert values, and trends the data would be described in terms 35 of the attributes of the program, but no objective evidence could be provided in the demonstration 36 because the program had not yet been initiated.
37 38 The use of attributes to make the demonstration would also be acceptable for an existing 39 program, especially if the attributes of the program were well understood and the program had 40 been successful in the past at adequately managing the effects of aging. An example of an existing 41 program, similar to the previous paragraph, would be an existing inspection program for an 42 underground tank. The program could be described in terms of actual data or in terms of 43 attributes, because underground tank wall thickness measurem:nt using UT is a well understood 44 technique and is accepted as being able to detect degradation of the tank wall.
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Tcbb Trrcking Nos. 96-04, 96-05, 96-06,96-08 96-15(partial) cnd 96-21 Draft January 21,1997 1
Another example of a new condition monitoring program is the one-time volumetric inspection of 2
the Alloy 82/182 clad flow meter section of the hot leg in B&W plants. The inspection is needed 3
because the Alloy 82/182 cladding may have some susceptibility to primary water stress corrosion 4
cracking during the period of extended operation. The inspection will be performed for one flow 5
meter section in one plant during the fourth interval of the plant's Inservice Inspection Plan. This 6
augmented inspection will comply with the version of the ASME Code that has been approved by 7
the NRC and incorporated into 10 CFR Part 50.55a at the start of the founh inservice inspection 8
interval. Afler this inspection is complete, and assuming that no degradation is identified, other 9
applicants with similar components will be able to credit this inspection to demonstrate that stress 10 corrosion cracking is not a plausible aging effect. Further discussion of this example is provided 11 in Appendix C as Example XXXX.
12 13 14 4.2.3.3 Performance Monitoring Aging Management Programs 15 16 To demonstrate that the effects of aging are being adequately managed, the applicant must show 17 that the performance monitoring program is capable of detecting degradation due to aging such l
18 that the intended function is maintained, even when the degradation is considered. For some L
19 SSCs, this will mean that the system intended function is maintained, even when the component 20 has degraded. The applicant must be able to demon-trate the correlation between the parameter 21 being monitored and the effect of aging of concern Performance monitoring is useful where the 22 design of the plant provides for on line monitoring of parameters which are linked to the aging 23 effect of concern.
24 25 An example of an existing performance monitonng program is the technical specification testing 26 of the control room ventilation system which assures that the system flow requirements are 3
27 satisfied. The flow testing ensures that the control room ventilation system can provide sufficient
{
28 flow through the system, confirming that the duct work, expansion joints, and other components l
29 in the flow path are performing their intended function of directing air flow through the control i
30 room. Trending of the test results will identify any degradation of performance, and initiate any 31 needed corrective actions if performance should degrade. The control room ventilation system 32 can be demonstrated to maintain its intended function, even if degradation of components has 33 resulted in identified leakage from the system. A gasketed joint may be leaking, but the system 34 design has sufficient margin that even with the leakage from the gasketed joint, the system is j
35 capable of performing its intended function under all design conditions. The gasketed joint, when j
36 performing as designed, prevents leakage from the ductwork but does not perform any structural 37 functions.
38 39 40 For a new performance monitoring program, the applicant must be able to demonstrate that the 41 proposed performance monitoring program will be able to detect the degradation of concern.
42 Several approaches can be used for this. The applicant can show that the technique has been used 43 in similar applications at the plant, or elsewhere in the industry. Also, the applicant may chose to 44 show that the proposed program is capable of detecting the effects of aging by actual performance
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under simulated conditions to show the correlation between the parameters being monitored and
~ 2 the aging effect ofconcern.
3 4
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2 2
3 Table A 4
Examples of Preventive or Mitigative 5
Aging Management Programs 6
Initiator Preventive or Mitigative Rule, Operating License Condition, Technical Reactor Coolant System Chemistry Specification, Industry Code Secondary System Water Chemistry j
(PWR)
Feedwater Water Chemistry (BWR)
Oil / Fuel Oil Testing i
NRC Generic Communication: Bulletin or Bolting Degradation (GL 91-17), Resolution of Generic Letter GSI 29 Licensee Developed Bolting Maintenance Practices Coating Maintenance Ambient Temperature / Radiation Monitoring 7
8 9
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Tcblo Trccking Nos. 96-04, 96-05, 96-06,96-08 96-15(partial) cnd 96-21 Draft January 21,1997 2
Table B 3
Examples of Condition Monitoring 4
Aging Management Programs 5
6 Initiator Condition Monitoring Rule, Operating License Condition, Technical ASME B&PV Code,Section XI, including Specification, Industry Code IWE/IWL Tendon Surveillance Testing Reactor Vessel Integrity Reactor Vessel Internals Inspections Steam Generator Tube Inspections Reactor Vessel Neutron Embrittlement Specimens Surveillance Fatigue Monitoring Program NRC Generic Communication: Bulletin or Erosion-Corrosion (GL89-08)
Generic Letter Boric Acid Westage(GL88-05)
Corrosion of R.b/er Weter Piping Inspections (GL89-13)
Licensee Developed Service Water Liner Inspections Alloy 600 Inspectinns Reactor Vessel Internals Bolting Tank Inspections Cable Monitoring and Testing Structural Inspections inspections for License Renewal 7
8 9
10 11 16
Tcble Tracking Nos. 96-04, 96-05, 96-06,96-08 96-15(p rtial) and 96-21 Draft January 21,1997 1
Table C 4
2 Examples of Performance Monitoring 3
Aging Management Programs 4
1 Initiator Performance Monitoring Rule, Operating License Condition, Technical Ventilation System Testing Specification, Industry Code Leakage Monitoring (RCS and others)
Fire Protection Plan (System i
FunctionalTesting)
Maintenance Rule NRC Generic Communication. Bulletin or Service Water Heat Exchanger Performance Generic Letter Monitoring (GL89-13)
Boraflex Monitoring (GL96-04) Spent Fuel
}
Licensee Developed Performance Testing for License Renewal 5
6 7
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9 p:\\fwp\\lr\\ sect 4.2 new rev i 10
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4 17
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96-09 Draft
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January 21,1997
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TABLE 6.0-1
/
SAMPLE APPLICATION FORMAT GENERAL INFORMATION (54.17,.19) 1.
Name of Applicant ( 5 0.3 3 (a))
2.
Address of Applicant (50.33(b))
3.
Description of Business or Occupation of Applicant (50.3' )(c))
4.
Organization and Management of Applicant (50.33(d)) [ address also 5 4.17 (b)]
5.
Class of License Applied for, the use to which the facility will be put, the period of time for which the license is sought (50.33(e))
6.
Earliest and latest dates for alterations, if proposed (50.33(h))
7.
Listing of regulatory agencies having jurisdiction and appropriate news publications (50.33(i))
8.
Conforming changes to the standard indemnity agreement (54.19 (b))
9.
Restricted Data A-eement (54.17 (f, g))
- 10. Reference to Exhibits A, B, C, and D EXHIBIT A - TECHNICAL INFORMATION F4.21 (a)-(c))
1.0 Introduction 1.1 Scope 1.2 CLB changes during NRC review [54.21(b)]
1.3 Time Limited Aging Analysis Evaluation [54.21(c)]
1.3.1 TLAA [ identification & resolution]
1.3.2 Exemptions [ identification & resolution]
2.0 Integrated Plant Assessment - Structure / Component identification ( 54.21 (a)(1) - (2))
21 Introduction 2.2 Structure / Component Selection Process per 54.21(a)(2) 2.3 List and identify results per 54.21 (a)(1) 3.0 Integrated Plant Assessment - Demonstration that the Effects of Aging Will Be Adequately Managed ( 54.21 (a)(3))
3.1 Introduction 3.2 Demonstration that the Effects of Aging Will Be Adequately Managed EXHIBIT B - FS AR SUPPLEMENT (54.21 (d))
EXHIBIT C - TECHNICAL SPECIFICATIONS (54.22) 52 52 ATTACHMENT 4
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- O EXHIBIT D - ENVIRONMENTAL INFORMATION (54.23)(50.53(c))
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1 Draft January 21,1997 NEl 95-10 REVISION 0 1
t March 1,1996 i
2 1
6.1 Formal Application 2
2 3 The following information, required by 54.17 and 54.19 is consistent with the 4 information contained in the facility's original operating license application as delineated i
5 in IOCFR50.33(a)througb(e),(h),and(i):
6 7 1. Name of Applicant 4
8 2. Address of Applicant 9 3. Description of Business or Occupation of Applicant 10 4.
Organization and Management of Applicant l~
l1 Note that the license renewal rule prohibits anyperson who is a citizen, 12 national, or agent ofaforeign country, or any corporation, or other entity i
13 which the Commission knows or has reason to know is owned, controlled or 14 dominated by an alien, aforeign corporadon, or aforeign government, from 15 applyingfor and obtaining a renewed license.
16 5.
Class of License, the Use'of the Facility and the Period of Time for which the 17 License is Sought.
18 6.
Earliest and latest dates for alterations, if proposed 19 7.
Listing of regulatory agencies having jurisdiction and appropriate news 20 publications 21
- 8. Confomffig changes to the standard indemnity agreement 22
- 9. Restricted data agreement 23 Pursuant to St.17 69 and (g): Ifthe o~ plication contains Restricted Data or 24 other defense information, it must be prepared in such a manner that all 25 Restricted Data and other defense information are separatedfrom 26 unclassifiedinformationinaccordancewithlOCFR50.336). Aspartofits 27 application and in any event prior to the receipt ofrestrictedData or the 28 issuance ofa renewed license, the applicant shall agree in writing that it will 29 notpermit any individual to have access Jo Restricted Data until an 30 investigation is made and reported to the Commission on the character, 31 association, and loyalty of the individual and the Commission shall have 32 determined that permitting such persons to have access to Restricted Data 33 will not endanger the common defense and security. The agreement ofthe 34 applicant in this regard ispart ofthe renewed license, whether so stated or 35 not.
36
'l 0. Reference to Exhibits A, B, C, and D 37 38 The contents specified for the application are the minimum set required by the 39 regulations. Upon issuance of the renewal operating license, this part of the application 40 becomes an historical document with no fbrther revisions.
54 54
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NEl 95-10 REVISION 0 March 1,1996 l
6.2 Exhibit A - Technical Information 2
3 Exhibit A of the renewal application contains the technical information that the NRC staff 4
will review to determine if the effects of aging on certain long-lived passive stmetures 5
and components are being managed such that the associated intended function (s) is 6
maintained consistent with the CLB in the period of extended operation. The Technical 7
Information provided in Exhibit A must be of sufficient detailin order that the NRC may 8
make the finding that there is reasonable assurance that the activities authorized by the 9
renewal license will continue to be in accordance with the CLB (54.29(b)).
10 11 The application should contain clear and concise presentations of the required 12 information. Confusing or ambiguous statements and unnecessarily verbose descriptions 13 do not contribute to expeditious technical review. Claims of adequacy of aging 14 management review should be supported by technical bases. The information provided in the application must be of suflicient detail to support the demonstration that the effects of aging are being adequately managed for the period of extended operation. The level of detail needed will be influenced by the technical argument presented for the specific structure, component or commodity grouping being discussed. The level of detail must be sufficient so that the application clearly shows the relationship between the aging effect(s) of concern, how the aging management program will adequately manage the effects of aging, and how the intended function will be maintained. For an existing program that is well understood, less detail and information is needed than for a new program that has been developed for license renewal.
18 19 The information contained in the application is based on the information contained in 20 plant specific documentation as previously described in Sections 3.3,4.5, and 5.3 of this 21 guideline. The license renewal application is not a summary, or condensed version of the aging management reviews performed by the applicant. The license renewal application is a separate document that will contain the 56 56
Draft January 21,1997 information needed to demonstrate that the applicant will be able to manage the effects of aging for the structures and components subject to aging management review during the period of extended operation. The application may incorporate by reference other existing documents, such as the plant specific UFSAR, owners group reports and industry reports. Although the cpplication must contain sufficient detail, it will not include detailed procedures or calculations which were used in support of the aging management reviews i
performed as described in section 4.0.
23 24 The contents of this portion of the application parallel the requirements stated in 54.21 25 (a)-(c). Once the Renewal Operating License is issued by the NRC, this exhibit ofthe 26 application is a licensing historical document and is not required to be updated.
27 23 The information provided in Exhibit A will providc the basis of the changes made to both 29 the FSAR and the Technical Specifications. The FSAR Supplement and the Technical 30 Specifications changes are provided in Exhibits B and C, respectively.
31 32 Exhibit A is organized into three sections or chapters: Introduction, Integrated Plant 33 Assessment - Structure and Component Selection, and Integrated Plant Assessment -
34 Demonstrating That the Effects of Aging Will Be Adequately Managed.
. Guidance on each of these chapters is provided in the 35 following subsections.
36 37 6.2.1 Introduction j
38 39 The first Chapter of Exhibit A is the Introduction witich includes the following 40 subsections: Scope of Exhibit A, CLB Changes during NRC review, and Time Limited 41 Aging Analysis Evaluations.
42 57 57
Draft January 21,1997 NEI 95-10 REVISION 0 March 1,1996 1
The subsection Scope of Exhibit A identifies that Exhibit A will address requirements 7
from 54.21 (a) - (c).
3 4
6.2.1.1 Identify CLB Changes 5
6 7
Part 54 Reference 8
54.21/b) 9 CLB. anges during NRC review ojapplication. Eachyearfollowing submittal ofthe 10 license rer.c. val application and at least 3 months before scheduled completion of the 11 NRC review, an amendment to the renewal application must be rabmitted that identyies 12 any change to the CLB of thefacility that materially affects the contents of the license 13 renewal application, including the FSAR supplement.
14 15 16 The Rule requires that the application be updated yearly and at least three months before 17 scheduled completion of the NRC review, to identify any changes to the facility's current 18 licensing basis that materially affect the application. These changes are provided to the 19 NRC in the form of an amendment to the license renewal application. For the initial 20 renewal application submittal, this provision does not apply. It is a place holder.
21 22 The CLB Changes subsection will contain any CLB changes that occur during NRC l
23 review of the application that materially affect the contents of the license renewal l
24 application including the FSAR supplement.
25 26 6.2.1.2 Time Limited Aging Analysis Evaluations 27 28 The Time-Limited Aging Analyses subsection provides the information required by 29 54.21(c).
30 31 The application shall include a list of time-limited aging analyses, as defmed by 54.3.
32 The application should include the identification of the affected systems, structures, and 33 components, an explanation of the time dependent aspects of the calculation or analysis, 34 and a discussion of the TLAAs impact on the associated aging effect.
35 36 The application shall include a demonstration that (1) the analyses remain valid for the 37 period of extended operation, (2) the analyses have been projected to the end of the 38 period ot extended operation, or (3) the effects of aging on the intended function (s) will 39 be adequately managed for the period of extended operation.
40 41 The identification of the results of the time limited aging analysis review, which may be 4
58 58 i
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Draft January 21,1997 NEI 95-10 REVISION 0 March 1,1996 1
Demonstrating That The Effects of Aging Will Be Adequately Managed chapter where more details of the actual review and 2 disposition (as required by 54.21(c)(1)(i)-(iii)
) are located.
3 4
Summary descriptions of the evaluations of TI.AAs for the period of extended 5
operatian shall be included in the FSAR supplement (Exhibit B).
6 7
The application shall include a list of plant specific exemptions gianted pursuant to 8
50.12 and in effect that are based on TLAAs as defined in 54.3. The application shall 9
include an evaluation that justifies the continuation of these exemptions for th-ceriod of 10 extended operation.
I1 12 The text may reference approved topical reports or regulatory guides, as applicable.
13 14 6.2.2 Integrated Plant Assessment - Structure and Component Identification 15 16 The second chapter of Exhibit A contains information related to the identification of 17 structures and components subject to an aging management review as described 18 previously in Section 4.0 of this guideline.
19 20 The application shall identify and list the structures, components, or commodity 21 groupings subject to an aging management review.
22 23 Pursuant to 54.21 (a)(2), the application shall include a description and justification of 24 the methods used to identify and list those structures and components that are within the 25 scope oflicense renewal and subject to an aging management review.
26 27 Reference may be made to approved topical reports or regulatory guides as appropriate.
28 29 6.2.3 Integrated Plant Assessment - Demonstrating That The Effects of Aging Will Be Adequately Managed 30 31 In the third chapter, the applicant must demonstrate that the effects of aging will be adequately managed so that the intended function (s) will be maintained consistent with the CLB during the period of extended operation. The demonstration must be performed for all of the structures and components identified in the second chapter of Exhibit A. The information contained in this chapter will be based on the aging management reviews prepared as described in Section 4.0 of this guideline. However, the license renewal application is not a summary or condensation of the aging management reviews. The license renewal application is a separate document that will contain the information needed to demonstrate that the applicant will be able to manage the effects of aging for 60 60
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['
the structures and components within the scope oflicense renewal during the period of extended operation.
)
i 34 1
35 The following information on the aging management review should be included in the 36. renewal application:
Description of the structures and components being evaluated.' The description should be e
i_
adequate so that the reader can understand the functional purpose of the structure or component in the design and operation of the power plant. A listing of all functions of the component or stmeture is not required. The description may include component identification numbers, where applicable. For commodity groupings, the description should provide either a narrative description of the extent of the components included in the commodity grouping, or a listing of the components included in the commodity grouping. For example, if the commodity grouping is for building structural steel, the description should -
l include the listing of the buildings that are within the scope of the evaluation. If the component is pipe supports, the description should include information on the type of support j
(e. g. spring can hanger) and the systems included ( e.g. all systems, Residual Heat Removal).
l Reference to previous information filed with the NRC may be made, I
I
-e identification of the systems, structures, or component intended functions, as appropriate.
- i The intended function (s) are those that were determined as described in section 4.1.2.
i Identification and assessment of the aging effects (or mechanisms, if appropriate), including a description of materials of construction and service environment. The description of the i
materials of construction and service environment should provide sufficient detail to support the demonstration that the applicant will be able to adequately manage the effects of aging.
For example, if the aging effect is loss of material due to general corossion in' carbon steel pipe l
containing feedwater, the specific pipe schedule, pipe diameter, and pipe length will not i
influence the demonstration. However, the water chemistry conditions will be a consideration. Normal water chemistry conditions should be described in sufficient detail in this section to bound the conditions the feedwater pipe will experience. Operating experience should also be considered in order to identify applicable aging effects for the structures and l
components.
7 Identification and description of aging management programs necessary for renewal.
e L
The amount of detail needed to adequately describe the aging management program j
' will depend on the nature of the program. Existing programs which are well l
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understood by the industry, and which exist to manage the effects of aging of concern during the current term will need minimal description. New programs which are developed to support license renewal and which have not been implemented prior to submittal of the application, will require sufficient information to demonstrate that the program will be able to adequately manage the effects of aging during the period of extended operation. Section 4.2.3 provides more information on the demonstration for different types of aging management programs, and Appendix C provides examples.
Not needed in the application is information on administrative controls or corrective actions.
These will normally be implemented by existing plant administrative procedures and controls, as specified in the plant's technical specifications and UFSAR, and also in some cases, by the aging management program.
Consistent with the guidance in Section 4.2.3, suflicient information should be provided, or incorporated by reference, on the techniques and alert values to suppon the finding that the effects of aging will be adequately managed. However, the details of the program, such as details of the methods used and inspection techniques, and specific numerical alert values, are not needed in the application. This information is needed in the information retained on site by the applicant.
Demonstration that aging management programs, either new, existing or enhanced, will adequately manage the effects of aging such that the intended functions will be maintained consistent with the CLB for the period of extended operation. The key part to a license renewal application is the demonstration that the effects of aging will be adequately managed during the extended period of operation, as required by 10CFR54.21(a)(3). The demonstration is the final conclusion, based on the technical work performed in the aging management reviews, that the applicant will be able to adequately manage the effects of aging so that the intended functions of the stmetures and components in the scope oflicense renewal will be maintained consistent with the CLB. The demonstration should include the following five elements:
The aging effect(s) of concern.
The Aging Management Program (s) that is being or will be used to manage the aging effect. Alternately, the analysis that shows that there are no aging effects of concern should be summarized.
The connection between the Aging Management Program, the aging effect r.nd the intended function. This is also described as "the link."
A description of how the Aging Management Program has or will mitigate, prevent, or detect the effect of aging so that the intended function will be maintained. This should be a technical argument that the program is effective, but should not include actual values of alert or action parameters, calculations, corrective actions, detailed 62 62
6 Draft January 21,1997 descriptions ofinspection techniques, or other details that are not pertinent to the demonstration. More details on this are provided in section 4.2.3 for the different types of aging management programs.
A clear statement that the Aging Management Program will manage the effects of aging in the future so that the intended function will be maintained, including an explanation of the justification.
Section 4.2.3 provides more detailed information on the contents of the demonstration.
Summary descriptions of the programs and activities for managing the effects of aging shall be included in the FSAR supplement (Exhibit B) at a level of detail consistent with the current FSAR. The results included in Exhibit A cetermine and technically support the changes proposed to the FSAR in Exhibit B and the changes proposed to the plant technical specifications as contained in Exhibit C.
Time-limited aging analyses that have been identified pursuant to 54.21 (c) should be evaluated and the results may be provided with the appropriate structure or component.
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6.3 Exhibit B - FSAR Supplement 2
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Part 54 Reference 5
54.21(d) 6 7
An FSAR supplement. The FSAR supplementfor thefacility must 8
corain a summary description of the programs and activitiesfor managing the 9
effects ofaging and the evaluation of time-limited aging analysesfor the 10 period of extended operation determined by paragraphs (a) and (c) of this 11 section, respectively.
12 13 14 The contents of the FSAR supplement will be based on the material provided in Exhibit 15 A. Section 54.21 (d) of the Rule requires that a summary description of the programs and 16 activities for managing the effects of aging for the period of extended operation as 17 determined by the IPA review and the evaluation of time limited aging analyses for the 18 period of extended operation be included in the FSAR supplement.
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20 In some instances, summary descriptions of programs and activities already exist in the I
21 plant FSAR. The applicant may chose to incorporate these existing pages of the FSAR 22 by reference or may choose to include them in the application for the convenience of the j
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j 24 25 In addition, a brieflicensing summary of the license renewal proceeding may be loc ted -
.26 in the Introduction chapter of the FSAR. The renewal license application process is 27 historical information and the brief summary may be of assistance to future readers.
i 28 29 The process to review and approve this change to the plant FSAR should be the same as
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30 that which the applicant presently utilizes.
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32-Once the Renewal Operating License is approved by the NRC, the material contained in 33 Exhibit B should be incorporated into the FSAR. The FSAR is a living document' and I
34 should be maintained in accordance with applicable regulations and plant procedures.
Refer to Appendix D for examples of the level of detail needed in acceptable FS AR supplements.
6,4 Exhibit C - Technical Specifications No changes 6.5 Exhibit D - Environmental Information No changes 1
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6.0 RENEWAL OPERATING LICENSE APPLICATION FORMAT AND j_
2 CONTENT j
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A sample application format is presented in Table 6.0-1. Contents of the application are divided 5
into two parts. (1) general information required by 54.17 and 54.19 and (2) technical 6
information required by 54.21,54.22, and 54.23. As presented, the general information is the 7
formal part of the application with the technical information being attached as Exhibits. The 8
Exhibits are presented in the same order that they appear in the license renewal rule application.
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4 Topic Paper l
Licensee Renewal UFSAR Supplement i
Level of Detail January 2,1997 Introduction j
The License Renewal Rule,10 CFR 54,654.21 (d), requires that the renewal application include a Supplement to the Updated Final Safety Analysis Report (UFSAR) which will contain summary descriptions of the programs and activities for managing the effects of aging and the evaluations of time-limited aging analyses for the period of extended operation. These programs and activities form part of the basis for the f"mding the NRC will make when the renewal license is issued.
The objectives of placing summary descriptions in the UFSAR are twofold:
- 1) To make the credited programs and activities visible, and
- 2) To allow effective regulatory oversight i
i In addition, any changes to the UFSAR should be made such that a reader is able to readily identify where programs and activities credited to manage the effects of aging are described.
General guidance for the level of detail for the summary descriptions of aging management programs and time-limited aging evaluations in the Supplement to the UFS AR is provided j
in the following discussion. Following this general guidance, an example of a supplement to the UFSAR is provided.
1 Discussion Revisions to Chapter 1, which are considered optional, may be provided as an aid to the l
reader to tell the history of license renewal for the plant. The text may include a forward j-reference to Chapter 13, Conduct of Operations, where the summary descriptions of aging management programs will be provided in addition, the list of time-limited aging analyces may be taken from the application for renewal license and provided as an aid to identify where the actual evaluation results are provided elsewhere in the UFS AR.
l Reference may be made to the application and the NRC safety evaluation.
i The remaining chapters of the UFSAR should be revised to include updated time-limited aging analyses and minor editorial chariges to forward reference to the summary j
descriptions of aging management programs which will be contained in Chapter 13, Conduct of Operations. Reference should also be made to the pertinent sections of the application and the NRC safety evaluation. These references will provide the reader with 3
additional supporting information which has been submitted on the docket.
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ATTACHMENT 5
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If the results of the time-limited aging analysis currently exist in the UFSAR, then the UFSAR Supplement need only revise the existing information to reflect the evaluation for 1
license renewal. If the time-limited aging analysis does not currently exist, then a summary of the evaluation needs to be developed and included in the UFSAR Supplement.
The summary of the evaluation should contain enough information that the reader can obtain a general understanding of the evaluation. Reference to the pertinent sections of the renewal license application and the NRC safety evaluation will provide the reader with i
additionalinformation.
The exact location of the summary descriptions of credited aging management programs in the FSAR is plant specific. For this example, Chapter 13, Conduct of Operations has -
been chosen as the singular location for the summary descriptions of the credited aging j
management programs. A singular location is recommended in order to make the credited l
programs and activities more visible to the reader. Locating the summary descriptions in one location also reduces confusion to the reader, as many programs affect more than one system and having the summary description in each applicable chapter might result in inconsistencies in describing each program.
The level of detail in describing the credited aging management programs will vary depending on whether or not it is an existing program and what the regulatory document for the prog ~am is. Regulatory documents include:
l) result.tions, operating license condition, or plant technical specifications; and
- 2) plant commitments to generic letters and bulletins.
l Existing and new programs will be credited as required by the aging management review which is documented in the renewal application and reviewed and approved in the NRC safety evaluation. For each summary description of aging management program provided l
in the UFS AR Supplement, reference should be made to the pertinent sections of the j
renewal license application.
For aging management programs that are new or that have not been previously described
[
in docketed correspondence, a clear statement of the purpose of the program along with i
the scope of components included and the aging effects that will be managed should be included in the Supplement to the UFS AR. These programs will become enforceable due to their existence as commitments in the renewal application and in the UFSAR. If the implementation details are to be included in another document, such as an ASME Code Section XI Inservice inspection Plan, then this document may be referenced from the UFS AR. Reference should be made to the appropriate administrative controls program described in the UFSAR or the plant Technical Specifications. Reference should also be made to the pertinent sections of the renewal license application and the NRC safety evaluation for further details of the credited program.
5 For aging management programs established in response to regulations, operating license I
condition, or plant technical specifications, NRC review and approval of the actual program elements as well as regulatory oversight of the implementation, generally exists.
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These programs are enforceable due to their existence in regulatory documents as
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requirements. The summary description to be contained in the UFSAR Supplement should identify the program and reference the applicable regulation, license condition, or technical specification. Any further detailis not considered necessary as the regulation, operating license condition, or plant technical specification requirement would supersede any licensee statement made in docketed correspondence or the UFS AR. Reference should be made to the appropriate administrative controls program described in the 4
UFS AR or the plant Technical Specifications. Reference should also be made to the pertinent sections of the renewal license application and the NRC safety evaluation for further details of the credited program.
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For aging management programs created in response to generic letters or bulletins, the
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level of detail should be consistent with docketed statements provided in response to the generic lener or bulletin. These programs presently are enforceable due to their existence in licensing documents as commitments. The purpose of the program, scope of structures, l
systems and components mcluded, and the aging effects managed should be identified in the Supplement to the UFS AR. The emphasis of the description should be on what the objectives of the program are rather than precisely how the program objectives will be accomplished as the methods may change over time as technology changes. Reference i
should be made to the appropriate administrative controls program described in the UFS AR or the plant Technical Specifications. Reference should also be made to the
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pertinent sections of the renewal license application and the NRC safety evaluation for further details of the credited program.
The attachment to this topic paper provides several summary descriptions of aging management programs that would be included in the Supplement to the UFSAR.
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UFSAR Supplement for License Renewal Draft - C i
EXAMPLE UFSAR SUPPLEMENT for j
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[ plant]
UFSAR Supplement for License Renewal Draft - C Chanter i Section 1.1 Introduction - add paragraph describing the fact that [ plant] has received a Renewal Operating License and that the programs and activities to manage the effects of aging are identified at the beginning of appropriate chapters and sections and the summary descriptions are provided in Section 13. 7.
Add a table that summarizes the Time-Limited Aging Analyses (TLAA) that have been identified and shows where in the UFSAR the revised TLAA is located. TLAA will be described in the individual chapters associated with each structure and component.
Reference needs to be made to renewal license application and NRC safety evaluation.
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UFSAR Supplement for License Renewal Draft - C 1
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1 Table 1.x Time-Limited Aging Analyses
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i Structure, Component /:i Endandian Condusion UFSAR Section 4
TLAA (plant specific)
- 1..%ctor Failding Liner Existing analyses remain valid Plate and Penetrations /
for the period of extended
'Ihermal Fatigue operation.
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- 2. Reactor Building Evaluation in progress. Results l
Tendons / Loss of to be provided et a later date.
Prestress
- 3. Reactor Vessel /
Evaluation in progress. Results Embrittlement, Upper to be provided at alater date.
Shelf Energy Toughness, j
'Ihennal Shock, PTS, l
underclad crack growth.
- 4. Reactor Vessel Internals Evaluation in progress. Results l
/ Loss of fracture to be provided at alater date.
j toughness, fatigue
Evaluation in progress. Results i
Fatigue to be pruvided at a later date.
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- 6. Class 1 Components /
Evaluation in progress. Results l
Fracture Mechanics to be provided at a later date.
Analyses forISI reponable 4
indications (fatigue)
- 7. Once Through Steam Evaluation in progress. Results j
Generator / Vibration, to be provided at a later date.
lifetime
- 8. Reactor Coolant Pump Evaluation in progress. Results Flywheel / Fatigue to be provided at alater date.
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- 9. Non-Class 1 Piping /
Evaluation in progress. Results
'Ihermal Fatigue to be provided at a later date.
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- 10. Electrical Equipment /
Evaluation in progress. Results j
j Environmental ta be provided at a later date.
j Qualification i
- 11. Polar Crane / Fatigue, Evaluation in progress. Results heavy load cycles to be provided at alater date.
- 12. Spent Fuel Rack Boraflex Evaluation in progress. Results j
/ Aging of non-metallic to be provided at alater date, material i
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[ plant]
o-UFSAR Supplement for License Renewal Draft - C Chanter 13 Revise Section 13.1.1 to reflect the renewal of the [ plant] operating licenses.
i Add Section 13.7, Aging Management Programs, which provides the summary descriptions all of the programs and activities to manage the effects of aging of the structures and components within the scope of license renewal..This section would contain the list of commitments for future inspections that are required.
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13.7. AGING MANAGEMENT PROGRAMS An Integrated Plant Assessmert (IPA) has been conducted on [ plant] in accordance the requirements contained in 10 CFR Part 54. The results of this IPA were summarized in
[ plant] Application for a Renewal Operating License, which was submitted to NRC for l
review and subsequently approved [ reference]. On [date], a renewal operating license was l.
issued to permit [ plant] to continue operating until [date].
Summary descriptions of the programs credited for managing the effects of aging are l
required by 554.21(d) to be included in the UFSAR. The following summary descriptions are provided in response to this requirement. These programs and activities provide reasonable assurance that the effects of aging will be adequately managed so that the current licensing basis will be maintained throughout the licensed life of [ plant].
i 13.7.1 BORIC ACID CORROSION SURVEILLANCE PROGRAM The Boric Acid Corrosion Surveillance Program provides assurance that boric acid corrosion does not lead to excessive degradation of the RCS pressure boundary and the there will be a low likelihood of abnonnal leakage, rapidly propagating failure, or gross leakage. 'The program was established in response to Generic 1.etter 88-05 and the requirements of ASME Section XI. The program elements include:
- 1) determination of the principle locations where leakage could cause degradation -
of reactor coolant pressure boundary components:
- 2) procedures for locating small leaks;
- 3) procedures for evaluating boric acid induced corrosion;
- 4) and conective actions to prevent similar types of corrosion.
The program is implemented by written procedures that are maintained in accordance with administrative controls which are summarized in the [ plant] UFS AR, Section 13.5.
[ Reference Application Exhibit A Section x ]
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UFSAR Supplement for License Renewal Draft - C 13.7.2 CHEMISTRY PROGRAM 13.7.2.1 PRNARY d
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The Primary Water Chemistry Program provides controls for monitoring primary water chemistry to minimize the corrosion in the Reactor Coolant System. He program includes:
- 1. Specifications for each chemistry parameter;
- 2. Sampling frequency for each chemistry parameter:
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- 3. Corrective actions in the event established acceptance criteria are not met.
i The program is implemented by written procedures that are maintained in accordance with administrative controls which are summanzed in the [ plant] UFSAR, Section 13.5.
[ Reference Application Exhibit A, Section x ]
i 13.7.2.2 SECONDARY WATER CHEMISTRY l
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The Secondary Water Chemistry Program provides controls for monitoring secondary j
water chemistry to inhibit steam generator tube degradation. The required program elements are contained in [ plant] Technical Specification 5.5.11 (ITS). The Secondary l
Water Chemistry Program is implemented by written procedures'as required by (plant]
l Technical Specification 5.4.
[ Reference Application Exhibit A, Section x ]
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13.7.3 DIESEL FUEL OIL TESTING i
[ plant] Technical Specification 5.5.14 provides the requirements to establish, implement, and mainta' a Diesel Fuel Oil Testing Program and includes appropriate testing a
requirements. The L'iesel Fuel Oil Testing Program is iniplemented by written procedures as required by [ plant] Technical Specification 5.4.
[ Reference Application Exhibit A, Section x ]
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13.7.4 FIRE PROTECTION PROGRAM The Fire Protection Program has been established in accordance with the requirements
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contained in the [ plant] Facility Operating Licenses. The program is described in [ plant]
l UFSAR S xtion 9.5.1.
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[ Reference Application Exhibit A.Section x ]
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13.7.5 INSERVICE INSPECTION PROGRAM,10 CFR 550.55a(g) j The purpose of the [ plant] inservice inspection Program is to assure the continued l
structural integrity of ASME Code Class 1,2 and 3 components. Requirements have also 4
been established by ASME Section XI, Subsection IWE, for steelliners of concrete 5
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[ plant]
UFSAR Supplement for License Renewal Draft - C containments.(See Section 13.7.9 for a summary description of the [ plant] program.) in addition, requirements have been established by ASME Section XI, Subsection IWL, covering tendons and Reactor Building concrete inspections to assure their continue functioning.(See Section 13.7.11 for a summary description of the [ plant] program)
He [ plant] Inservice Inspection program is implemented and maintained in accordance with the requirements of 650.55a(g). The hiservice Inspection Program for each inspection interval is submitted to the NRC for review and approval prior to the start of each inspection interval. The inspection program is implemented by written procedures j
that are maintained in accordance with administrative controls which are summarized in the [ plant] UFSAR, Section 13.5.
[ Reference Application Exhibit A, Section x ]
5 13.7.5.1 ASME SECTION XI REQUIRED INSPECTIONS AND ACTivmES Re [ plant] Inservice Inspection Program has been established in accordance with the requirements of 10 CFR 650.55a(g; Inspections are being performed in accordance with the 1989 Edition of ASME Section XI, na addenda for ASME Code Class 1,2, and 3 components in [ plant]. The examinations are being performed to the extent practicable within the limitations of design, geometry and materials of construction and component.
13.7.5.2 AUGMENTED INSPECTIONS AND ACTivmES FOR LICENSE RENEWAL i
13.7.5.2.1 Hot leg flow nozzle Alloy 82/182 cladding inspection i
later (BAW-2243A, SER Section 4.1)
[ Reference Application Exhibit A, Section x ]
13.7.5.2.2 Small Bore RCS piping inspection later (BAW-2243A, SER Section 4.1)
[ Reference Application Exhibit A, Section x ]
13.7.6 INSPECTION PROGRAM FOR CIVIL ENGINEERING STRUCTURES AND COMPONENTS The purpose of the inspection Program for Civil Engineering Structures and Components is to monitor and assess the condition of civil engineering structures and components in order to assure that they are capable of performing their intended functions. The scope of 2
this inspection program includes, but is not linuted to:
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l UFSAR Supplement for License Renewal Draft - C
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- 1. nuclear safety-related structures which enclose, support, or protect nuclear safety-related systems and components, and
- 2. non-safety related stmetures whose failure may prevent a nuclear safety-related system or component from fulfilling its intended function.
Each structure included in the scope of the inspection program is visually inspected for signs of degradation or existing structural problems. The results of each inspection are compared by a qualified engineer to established acceptance criteria. If the results of the f
inspection are deemed to exceed the established acceptance criteria, then appropriate corrective actions are taken.
The inspection is performed on a nominal 5 year interval. The inspection interval may be adjusted to account for refueling outages. More frequent inspections may be performed 4
following unusual events such as flooding or seismic event.
The results of the inspection are documented in a report prepared by the personnel performing the inspections.
[ Reference Application Exhibit A, Section x ]
i 13.7.7 PIPE EROSION / CORROSION CONTROL PROGRAM i
The Pipe Erosion / Corrosion Control Program is an inspection and analysis program that assures the integrity of piping susceptible to erosion / corrosion. The program has these elements:
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- 1. The program focuses on the mtegnty of piping systems that are susceptible to erosion /
corrosion which includes, but is not limited to those within the scope of license renewal.
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- 2. Loss of material is detected before there is a loss of integrity of the piping pressure j
i boundary.
- 3. Inspection locations have been identified and acceptance criteria have been established for each location.
- 4. Monitoring and trending of the inspections results by the assigned station engineer provides predictability and timely preventive actions.
- 5. The program is implemented by procedures which are sub'
' administrative controls.
[ Reference Application Exhibit A, Section x; GL 89-08]
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UFSAR Supplement for License Renewal Draft - C 4
13.7.8 PRIMARY COOLANT SOURCES OUTSIDE CONTAINMENT i
1 his program provides controls to minimize leakage from those portions of systems outside containment that could contain highly radioactive fluids during serious transient or accident to levels as low as practicable. Piogram requirements are provided in [ plant]
Technical Specification 5.5.3. The program is implemented by written procedures as required by [ plant] Technical Specification 5.4.
[ Reference Application Exhibit A, Section x ]
I 13.7.9 REACTOR BUILDING CIVIL INSPECTION PROGRAM 1
The purpose of the Reactor Building Civil Inspection Program is to uncover any evidence j
of structural deterioration which may affect either the containment structural integrity or leak-tightness. Inspections of steel liners of concrete containments have been developed in i
accordance with the ASME Code Section XI, Subsection IWE,1992 Edition and addenda j
and as required by 61 FR 41303, August 8,1996. The examinations will be performed to i
the extent practicable within the limitations of design, geometry and materials of construction and component.
Instmetions are pmvided for performing visual inspections of accessible interior and exterior surfaces of the Reactor Building and its components. Appropriate acceptance criteria have been established and corrective act ons are taken when necessary. Previously i
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identified locations of deterioration are reinspected and a determination of effectiveness of i
the previous corrective actions is made. The program is implemented by written l
procedures that are maintained in accordance with administrative controls which are l
summarized in the [ plant] UFS AR, Section 13.5.
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[ Reference Application Exhibit A. Section x ]
13.7.10 REACTOR BUILDING LEAKAGE TESTING PROGRAM The purpose of the Reactor Building Leakage Testing Program is to provide assurance
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that leakage through the Reactor Building does not exceed allowable leakage rates, which are established in the (plant] Technical Specifications. The [ plant] Reactor Building Leakage Testing Program has been established in accordance with 10 CFR 50, Appendix J, Primary Reactor Containment 12akage Testing for Water-Cooled Power Reactors. The program is i.nplemented by written procedures that are maintained in accordance with administrative controls which are summarized in the [ plant] UFS AR, Section 13.5. The following subsections briefly describe the testing and inspections that are performed.
13.7.10.1 REACTOR BUILDING INTEGRATED LEAK RATE TEST Re purpose of the Reactor Building Integrated Leak Rate Test is to measure the overall integrated leakage rate at periodic intervals as specified in 10 CFR 50, Appendix J.
Leakage testing methods and additional testing requirements are also specified in Appendix J,Section III.A.
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UFSAR Supplement for License Renewal Draft - C
[ Reference Application Exhibit A, Section x ]
13.7.10.2 REACTOR BUR.DMG LOCAL LEAK RATE TEST The purpose of the Reactor Building Local Leak Rate Test is to measure leakage 1) across each Reactor Building pressure retaining penetration and 2) through containment j
isolation valves. Leakage testing is performed on intervals as specified in Appendix J.
Guidance is provided in Appendix J for identifying the appropriate test method for testing every penetration in the reactor Building. Additional testing requirements are also
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specified in Appendix J,Section III.B.
[ Reference Application Exhibit A, Section x ]
l 13.7.10.3 REACTOR BUILDMG CML INSPECTION FOR INTEGRATED LEAK RATE TEST l
The purpose of the Reactor Building Civil Inspection for Integrated Leak Rate Test is to l
uncover any evidence of structural deterioration which may affect either the containment j
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' structural integrity cr leak-tightness. [ Appendix J.Section V.A.] The [ plant] Reactor Building inspections are performed prior to each integrated leak rate test. Acceptance criteria have been established and corrective actions are taken in the event that degraded conditions are identified.
[ Reference Application Exhibit A, Section x ]
13.7.11 REACTOR BUILDING TENDON SURVEILLANCE PROGRAM The purpose of the Reactor Building Tendon Surveillance Program is to demonstrate the integrity of the post-tensioning system including the tendons, tendon end anchorage hardware, general and adjacent concrete, and the corrosion protection (grease) system.
The Reactor Building Tendon Surveillance Program meets, to the extent practical within the limitations of design, geometry and materials of construction and component, the requirements contained in ASME Section XI, Subsection IWL,1992 Edition through 1992 Addenda and 10 CFR 650.55a.
The Reactor Building Tendon Surveillance Program rnanages the aging effects of concern l
including loss of material due to wire breakage or corrosion, loss of grease, corrosion of i
end anchorages and cracking of adjacent concrete. Appropriate acceptance criteria are provided and corrective actions are taken as required. The program is implemented by i
written procedures that are maintained in accordance with administrative controls which are semmarized in the [ plant] UFSAR Section 13.5.
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[ Reference Application Exhibit A, Section x ]
13.7.12 REACTOR COOLANT SYSTEM, OPERATIONAL LEAKAGE j.
The purpose of the Reactor Coolant System Operational 1.cakage specification is to limit l
system operation in the presence of leakage from joint and valve interfaces to amounts j
that do not compromise safety. Technical Specification 3.4.13 (ITS) establishes the types 9
[ plant]
UFSAR Supplement for License Renewal Draft - C and amounts of allowable RCS leakage. Required actions in the event the leakage limits are exceeded are also provided. Surveillance requirements are also established. The i
program is implemented by written procedures that are maintained in accordance with j
administrative controls which are summarized in the [ plant] UFSAR Section 13.5.
]
[ Reference Application Exhibit A, Section x ]
i 13.7.13 REACTOR VESSEL MATERIAL SURVEILLANCE PROGRAM The Reactor Vessel Material Surveillance Program monitors changes in the fracture toughness properties of ferritic materials in the reactor vessel beltline region from exposure to neutron irradiation and thermal environment. The program meets the requirements contained in 10 CFR 50 Appendices G, H. The [ plant] Reactor Vessel Material Surveillance Program is described in [ plant] UFS AR Section 5.2.3.13.
[ Reference Application Exhibit A, Section x ]
13.7.14 SPENT FUEL RACK BORAFLEX MONITORING PROGRAM
'Ihe purpose of the Spent Fuel Rack Boraflex Monitoring program is to monitor the Boraflex to assure that the required.i% criticality margin is maintained for the lifetime of the spent fuel storage racks. The program includes:
- 1) Periodic neutron attenuation testing of a representative sample of actual Boraflex panel enclosures to established appropriate acceptance criteria;
- 2) Periodic sampling and analysis for silica in the spent fuel cooling water and the trending of results obtained;
- 3) Corrective actions to be taken in the event the Boraflex is no longer capable of maintaining the required suberiticality margin.
The program is implemented by written procedures that are maintained in accordance with administrative controls which are summarized in the [ plant] UFSAR Section 13.5.
[ Reference Application Exhibit A, Section x; GL %04]
13.7.15 TRANSIENT CYCLE MONITORING (ITS).
[ plant] Technical Specification 5.5.6 establishes the requirement to provide controls to track the number of UFSAR Section [icyclic and transient occurrences to assure that components are maintained within design limits. The Transient Cycle Monitoring Program is implemented by written procedures as required by [ plant] Technical Specification 5.4.
[ Reference Application Exhibit A, Section x ]
10
January 2.1997 Topic Paper Level of Detailin an Application for a New Inspection Program Introduction NEI 95-10, 64.3 provides guidance on the elements of an inspection program in:luding the use of sampling and timing of such inspections. A new inspection program.nay be appropriate in order to provide reasonable assurance that identified aging effects can be managed for the period of extended operation. The purpose of this topic paper is to provide an example of a new inspection program in the level of detail that would be included in a renewal license application. Prior to providing the example, background information is provided.
Background
In March 1995, the B&W Owners Group submitted BAW-2243," Demonstration of the Management of Aging Effects for the Reactor Coolant System Piping," for NRC staff review and approval. The NRC staff reviewed this report and documented the results of the review in a Safety Evaluation attached to a letter dated March 21,1996, entitled
" Acceptance for Referencing of Topical Report BAW-2243, Demonstration of the Management of Aging Effects for the Reactor Coolant System Piping."
One of the applicant action items that has been identified in the NRC Safety Evaluation concems the reactor coolant system flow meter section located in each hot leg of the reactor coolant system. Each flow meter section is a carbon steel piping section w hich contains a cladded flow meter element. The cladding material attached to the ctdm steel i
section is Alloy 82. Alloy 182 was used to connect Alloy 600 flow rings to the Alloy 82 cladding. This cladding is referred to as ' Alloy 82/182' hereafter. (Refer to Figure 2-4 of BAW-2243A attached.)
Alloy 82/182 cladding may have some susceptibility to pdmary water stress corrosion cracking, although Alloy 82 may have a lower susceptibility to primary water stress corrosion cracking than Alloy 182.
To detemiine the condition of the Alloy 82/182 clad flow meter section, the B&W Owners Group proposed, and the NRC agreed, that a one-time volumetric inspection of the Alloy 82/182 clad flow meter section of the hot leg' would be performed at one B&W plant at or near the end of the current license term. The schedule for the performance of this inspection at or near the end of the current license term is acceptable because there is no indication that the potential cracking is a safety concern during the current 40 year operating license.
3 The NRC safety evaluation refers to this item as the ' Alloy 82/182 clad hot leg segment'. Either terminology is acceptable as they refer to the same item.
1 ATTACHMENT 6
m. _...
i January 2.1997 De performance of the inspection at or near the end of the current license term will provide information on the condition of the Alloy 82/182 clad flow meter section. The B&W Owners Group deferred developing details of the inspection program until an applicant submits its renewal application.
He NRC staff safety evaluation requires that the details of the inspection plan for the Alloy 82/182 clad flow meter section of the hot leg be provided in the renewal application for staff review and approval. The following example is provided to illustrate the level of detail necessary in a renewal application to meet this requirement.
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January 2.1997 Eumpe f
(level of detail to be provided in an application)
Description of the Augmented Inspection for License Renewal ofthe-Alloy 82/182 Clad Row Meter Section of the Hot Leg Purpose The purpose of the augmented inspection for license renewal is to assess the condition of the Alloy 82/182 clad flow meter section in the hot leg. The Alloy 82/182 clad flow meter section of the hot leg will be inspected to provide reasonable assurance that the reactor coolant system piping pressure boundary integrity will be maintained consistent with the CLB for the period of extended operation. (Refer to Figure 2-4 of BAW-2243A attached.)
Methodology his proposed augmented inspection is being developed using the guidance contained in NEI 95-10,64.3 and is required to be submitted for NRC staff review arxl approval as part of the renewal application. Implementation of this proposed augmented inspection is 2
contingent upon NRC issuance of a renewed operating license for [ plant ),
ne augmented inspection will comply with the version of the ASME Code that has been approved by the NRC and incorporated into 650.55a prior to the start of the fourth inservice inspection interval. The fourth inservice inspection interval covers the last 10 years of operation in the initial operating license term. By using this edition of the ASME Code, the inspection requirements associated with this augmented inspection will be consistent with inspection requirements for the other ASME Code Section XI inspections being conducted during the fourth interval.
The Alloy 82/182 clad flow meter section of one hot leg will be inspected. In the event that there are multiple units on a single site, the augmented inspection may be performed on any one of the units,if all of the units are similar in design. An evaluation of the results of this inspection will determine whether additional inspections are warranted.
Scheduling of the specific inspection date will be specified in the (plant] Inservice Inspection Plan for the fourth interval. Performing this augmented inspection in the first or second period of the fourth inservice inspection interval meets the timing requirement contained in the NRC's Safety Evaluation dated March 21,1996 that the inspection be performed at or near the end of the current license. Performing the augmented inspection at this time also permits subsequent inspections to be performed,if necessary, prior to the end of the current operating license. The performance of this inspection at or near the end of the current license term is acceptable because there is no indication that the potential cracking is a concern during the current 40 year operating license.
' 'Ihe name of the specific plant which submits this augmented inservice inspection plan for license renewal should be inserted in locations indicated by square brackets: '[ ]*.
3
\\
5 January 2.1997
[ Plant] will perform the augmented inspection using ultrasonic techniques. Previous experience has shown that ultrasonic inspection techniques are effective in identifying indications in reactor coolant system piping. As required by ASME Code Section XI, an inspection calibration block will be manufactured in accordance with the edition of ASME Code Section XI specified for the fourth interval [ plant] Inservice Inspection Plan.
Appropriate acceptance criteria will be developed using the edition of ASME Code Section XI specified for the fourth interval [ plant] Inservice Inspection Plan. The results j
of the augmented inspection will be evaluated against the established acceptance criteria using methods considered acceptable to comply with the requirements of the specified edition of the ASME Code Section XI. All augmented inspection results will be reported to the NRC within 90 days after the completion of the outage in which the inspection was conducted, as currently required by ASME Code Se: tion XI, lWA-6230.
Corrective actions will be taken in accordance with the edition of the ASME Code Section XI applicable to the [ plant] Inservice Inspection Plan for the fourth interval. Indications may be determmed to be acceptable for the remaining life of the plant or may need to be repaired. If fracture mechanics analysis is performed to determine acceptance, then the analysis will be submitted to the NRC for review and approval prior to unit startup. The need for any further actions, including the need for any additional inspections, will be considered following the review of the results of the inidal inspections by [ plant].
Submittal of Augmented Inspection Plan for License Renewal Within 12 months after the issuance of a renewed operating license for [ plant], or as included in the (plant] Inservice inspection Plan for the Fourth Interval, whichever is later, a complete description of the proposed augmented inspection for license renewal of the Alloy 82/182 clad flow meter section of the hot leg, including the additional information to be specified later as noted above, will be submitted to NRC for review and approval.
4
1 Figure 2-4 Flow Meter Assembly Detail (Probes Not Shown)
Stainless Steel f
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h '/6 NEI 95-10 REVISION 0 March 1, 1996 1
4.3 Application ofInspections for License Renewal 2
3 Section 4.2 discusses options for performing an aging management review. If the applicant 4
concludes, after reviewing the options or implementing the option, that the demonstration has not 5
achieved reasonable assurance, an inspection program for license renewal may be appropriate.
6 This section provides guidance on the elements of an inspection program including the use of 7
sampling and the timing of such inspections.
4 8
9 4.3.1 Inspection Program 10 11 The Rule does not contain any requirements for features of an acceptable inspection program.
12 The elements of an inspection program may vary depending on the specific structure, component, 13 or commodity grouping that is subject to aging effects of concern. However, features to consider 14 are:
15
Purpose:
The inspection program should provide reasonable assurance that the specific 16 17 aging effect is adequately managed or need not be managed.
I8 Scope: The scope of the inspection program may be a specific component, stmeture, or 19 20 commodity grouping. The scope also may be a representative sample of a commodity 21 grouping ifjustified.
22 Inspection Methods: The programs should describe an inspection method that is capable 23 24 of either (1) detecting the effects of aging in sufficient time to ensure before the structure 25 or component would always maintain ten the ability to perform its intended function 26 under design conditions, or (2) demonstrate that the structure or component intended 27 function will be maintained during the period of extended operation without the need for 28 an aging management program.
29 Analysis of Results: The inspection program should include a methodology for analyzing 30 the result' of the inspection against applicable acceptance criteria. The methodology 31 s
32 should be capable of deternunmg the ability of the structure or component to perform its 33 intended function for the period of extended operation under design conditions required by 34 the plant-specific CLB. The results of the inspection also should be evaluated to assess 35 whether the sample size is adequate or ifit needs to be expanded.
36 Corrective and Follow-Up Actiors: The inspection program should discuss when 37 38 corrective actions and/or follow-up activities are implemented if appropriate. As 39 appropriate, consideration should be given to root cause analysis, actions to prevent 40 recurrence and repair / replacement.
41
==
Conclusion:==
The inspection program should include a final conclusion on whether the 42 43 purpose been achieved.
44 Aft %
ATTACHMENT 7
3 REVISION 0 March 1, 1996 i
1 i
2 4.3.2 Sampling 3
4 When the applicant determines an inspection is necessary, sampli~ng may be used to evaluate a 5
group of structures or components. If sampling is used, a program should be developed which 6
describes and justifies the methods used for selecting the population and the sample size.
7-l 8
4.3.2.1 Population 9
j 10 A population is the collection of the stmetures or components to be inspected under a sampling 11 plan. Selection of the population demands attention to similarity of material of construction, 12 fabrication, procurement, design, installation, operating environments, and aging effects.
13 14 4.3.2.2 Sample Size 15 l
16 A sample consists of one or more structures or components drawn from the population. The i
17 applicant must determine a sample size that is adequate to provide reasonable assurance that the j
18 effects of aging on the structure or component will net-prevent be limited to ensure the j
19 performance ofits intended function during the period of extended operation will be maintained.
20 The size of the sample should include consideration of the specific aging effect(s), location, l
21 existing technical information, materials of construction, service environment, previous failure i
22 history, etc. The sample should be biased towards locations most susceptible to the specific agmg 23 effect(s) of concern.
1 24 25 4.3.3 Timing ofInspections i
26 l
27 An inspection for license renewal may be performed at various times. It may be performed prior 28 to submittal of the license renewal application. The license renewal application may include a 29 commitment to perform'an inspection prior to the commencement of the period of extended 30 operation. There also maybe justification for performing the inspection during the period of 31 extended operation.
4 2
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NEI 95-10 REVISION 0 March 1, 1996
)
FIGURE 4.2-1 ASSURING THAT THE EFFECTS OF AGING WILL BE MANAGED
[5 54.21(a)(3))
Figure 4.1-1 l I Structure, component, or m
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the aging it i demonstrated Yes effects fully bybM N l
addressed by aging off M-wg analysis ?
will be adequately"-V managed No lf identify and review aging management programs
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Describe Will enhancements to the aging plant programs or 4
ffects be adeqystel estabush'a new managed?
program Yes lf lf lf l
Dmument the aging management review l
24
)
l Discussion on How Gaskets, Seals and Other Similar Consumables are Addressed in the j
IPA Comment %13:
Describe how gaskets, seals and other similar consumables are addressed in the Integrated Plant Assessment for aging process. Provide a basis for this approach.
Response
As shown in the below definitions, items such as gaskets, seals O-rings, valve packing and pump packing are generally classified as consumables under current plant component naming conventions. NCIG-17 Guidelines for the Safety Classification of Svstems. Components and Parts Used in Nuclear Power Plant Apolications defines
" component" and " consumable" as follows:
" Component - An assembly of parts that is viewed as an entity for purposes of design, operation and reporting. (IEEE 803) A component is usually assigned a plant unique identification number,
" Consumable" - Materials and supplies used in the process of component operation or maintenance:
items that are expended during the operation of components /subcomponents or that are routinely replaced during the maintenance (e.g. diesel fuel, calibration standards,0-rings, gaskets, hydraulic
{
fluid, lubricating oil, grease, packing, and paint);
items that are expended in maintaining the chemical control of system process fluids (e.g. resins,
=
additive chemicals and gases such as boron standard, pH buffer, branophenal blue and nitric acid); or items that are expended during maintenance, installation, and modification activities that are a
generally used throughout the plant and are not included in the above (e.g. solvents layout fluid, leak-testing fluid, tape, and penetrant testing materials)(NUREG-1000s The SOC a, the LR Rule is generally silent on how consumables should be treated in the IPA process. However, the SOC at 22477 provides the following guidance on what items should be excluded from the AMR.
However, the Commission does not believe that it can generically exclude structures and components that-(1) Do not have performance and ccadition characteristics that are as readily monitorable as active components: and (2) Are not subject to periodic, planned replacement. Unlike the extensive experience associated with the performance and condition monitoring of the active functions of structures and components,little experience has been gained from the evaluation oilong-term effects of aging on the passive functions of suuctures and components. The Commission considers that the detrimental effects of aging affecting passive functions of structures and components are less apparent than the detrimental effects of aging affecting the active functions of structures and components. Therefore, the Commission concludes that a generic exclusion for passive structures and components is inappropriate at this time, in applying this guidance to consumables, the following conclusions can be reached -
- 1) By the definition of consumable, these items are intended to be used during the normal operation and maintenance of the system and replaced. Therefore, consumables are subject to p. iodic planned replacement, but not at a calendar frequency or based on a qualified life.
2)'Ihe detrimental effects of aging on the intended function of gaskets, seals,0-rings and packing is readily apparent, i.e. observable leakage results before the deterioration proceeds to an unacceptable level (note that these parts do not support the structural integrity function of their parent component) and
- 3) Extensive experience has been gained with the aging of such materials since these materials are replaced routinely during the normal operation and maintenance of the plant equipment.
Based on the application of SOC guidance to consumables such as gaskets, seals,0-rings and packing, the conclusion can be reached that these consmnable items should not be subject to aging management review.
ATTACHMENT 8
Proposed NEIGuide Changes:
On page 21, section 4.1.1, insert the following paragraph after the paragraph on bolting which resulted from comment 9614.
"Similarly, some components which support the pressure retaining function of a system may include consumable parts such as gaskets, seals O-rings or packing. By definition, such consumable items are iritended to be used in the process of operating or maintaining system components. Additionally, these parts normally support the pressure retaining function only by limiting system leakage and the effects of aging are readily detectable by observing leakage before these effects would prevent the performance of the parent component's intended function. Therefore, the effects of aging on such consumable parts does not need to be considered during the AMR of the parent component."
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J ATTACHMENT 9
TRACKING TABLE NO. 96-01 i
12/24/96 DRAFT 3.0 IDENTIFY THE SSCs WITHIN THE SCOPE OF LICENSE RENEWAL AND THEIN INTENDED FUNCrlONS i
This section provides a process for determining which of the many systems, structwes, and cotwonents that make up a conunercial nuclear power plant are included within the scope of the Rule.
The scoping process described in this guideline is at the system and suucture level for the nnjority of the systems, structures, and components in subsequent sections, it is assumed that scoping is performed at the system and suucture levet This is not intended to imply that scoping at a component levelis not allowed by the Rule. In fact, for some plants it may be easier to scope at the componer !
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The scoping process spid ensu hat all sygcem, structures, and components " ' nah of the scoping criter$2r fix'3:!.
' necessary to make certain thaQll #the intended functiontef each system, structure and connponent acNeeduesd. (llgust 3.0 I is a p T
Ucess
[ diagram fnr this section.)
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's TRACKING TABLE NO. 96-07 12/24/96 DRAFT 5.1.4 Timing for Evaluation of TLAA In genc-J, tThe evaluation of TLAAs should be completed and submitted at the time of renewal application. Howev,ey, there may be instances when the ec npletien+Fthe evaluation of a TLAA.
he deferred until to a-tune after the issuance of the renewal license.
%' hen /n applicant c'ed te defc. a,mpZ..g ic =&Fier " ' * * -' 'h: Snc of renewal aplicatica, iL6 ap,/R:t sudd.~',...!' Se fe!!=dag i'" should4se--
provided m the renewal application to eTW. a c^n+rien +b ' i. A cf agbg MP-d by +'" T' ^ ^ ;c"! be r-n:.ged fer e ~p:;if.c -mimu m We....t-
.fg. 4 flo wi y t. Ta..e n o +;a e Coe sae 4 <e pso r n G, he er;f<<lo.
i Acceptance criteria [that will be used to judge the adequacy of the structure or component, consistent with the CLB, when the TLAA cvaluation or analysis is performed, i
Corrective actions that the applicant could perform to provide masonable assurance that the component in question will perform its intended function when called upon or will not be outside ofits design basis established by the plant's CLB, and Identification of when the completed TLAA evaluation will be submitted to ensure that the necessary evaluation will be performed before the structure or component in question would not he able to perform its intended functions established by the CLB.
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PROPOSED NRC STAFF RESOLUTION OF COMMENTS 4
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MATTERS NOT SUBJECT TO REVIEW 4
1 j
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However, an applicant for renewal is not relieved from addressing the issue j
relevant to the period of extended operation as part of its renewal application.
Section 54.30 does not require a general demonstration of compliance with the CLB as a prerequisite for issuing a renewed license. Section 54.30 discusses the applicant's responsibilities for addressing safety matters under its current license, which are not within the scope of the renewal review.
-Cer.ver;:!;,10 CP SiMn M d apprt the ;;iti:- t%t, [cause aging is a continuous process, aging management being performed on structures and components within the scope of license renewal d rggJhe current term 4e may $e.
3 acceptable for the period of extended operation.3 /he demonstrations required by the license renewal rule must still be provided for these aging management programs.
3.2 Resolution of Current Generic Issues Section 1.5 of NEl 95-10 provides general guidance on the resolution of generic issues related to aging management reviews for license renewal or on evaluation of TLAAs that have been identified by the NRC as unresclved safety issues (USIs) or generic safety issues (GSIs). USIs and GSIs are identified and tracked in the NRC's formal generic safety issues resolution process set j
forth in NUREG-0933, "A Prioritization of Generic Safety issues."'
During the preparation and review of a renewal application, an applicant or the NRC may become aware of an aging management or time-limited aging analysis issue that may be generically applicable to other nuclear plants.
If issues may have generic applicability (but are not yet part of the formal generic safety issues resolution process), an applicant must still address the issue in its application to demonstrate that the effects of aging are or will be adequately managed or that TLAAs have been evaluated for the period of extended operation.
'R. Emrit et al., "A Prioritization of Generic Safety Issues," NUREG-0933, January 1991.
Copies may be purchased at current rates from the U.S.
Government Printing Office, P.O. Box 37082, Washington, DC 20402-9328 (telephone (202)512-2249); or from the National Technical Information Service by writing NTIS at 5285 Port Royal Road, Springfield, VA 22161. Copies are available for inspection or copying for a fee from the NRC Public Document Room at 2120 L Street NW., Washington, DC; the PDR's mailing address is Mail Stop LL-6, Washington, DC 20555; telephone (202)634-3273; fax (202)634-3343.
9
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PROPOSED NRC STAFF RESOLUTION OF COMMENTS 1
ENVIRONMENTAL 1
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b Technical specification changes or additions that are necessary to manage tne effects of aging during the period of extended operation should be included or referenced and should comply with the applicable requirements of 10 CFR Part 50.
The justification for the changes or additions should also be included in the license renewal' application.
The NRC staff may include conditions or limitations on the renewed license in accordance with 10 CFR rwal oser.a licensee's commitmer.t will not be completed prior 54.33(b), for example when n to issuance of the licerfse or Mien the NRC staff determines that the additional g
regulatory control is warranted to ensure that the effects of aging will be ^$
f 1[A O) adequately managed N b /*
d'
- /'
The environmental information should be provided in a supplement to the environmental report that complies with the requirements of Subpart A of__10 CFR Part 51 as required by 10 CFR 54.23. f he for= t ud cr. tent of tre Q@ S otr1 a nf _ Q f, crt 'rr rtM re;m :r: ddre:::d in Regulatory Guide 4.2, " Preparation of Environmental Reports for Nuclear Power Stations."
To facilitate the NRC staff's ruiew of an application, an implementation plan should be provided.
The implementation plan is a summary of the commitments, activities, and schedules required from an applicant's license renewal reviews and evaluations and should include:
1.
A list of the commitments described in the license renewal application.
2.
A description of the administrative control programs used by the applicant to establish and maintain the commitments described above.
The administrative controls should ensure that activities to manage I
the effects of aging as part of an aging management program are identified and controlled so that changes are not made that could reduce the effectiveness of the program and so that any program modifications are adequately reviewed and approved.
3.
A list of tasks and task schedules pertaining to aging management programs and activities not yet in place that will be completed 4
during or prior to the pericd of extended operation. These tasks may include system design changes, replacements, inspections, program enhancements, and establishing new programs.
4.
A schedule for the specific actions that have been committed to be completed.
This schedule should be consistent with the evaluations 7
l l
NEl 95-10 REVISION 0 March 1, 1996 1
6.5 Exhibit D - Environmental Information
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2 i
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Part 54 Reference i
5 54.23 4
6 7
Each application must include a supplement to the environmental report 8
that complies with the requirements ofSubpart A of10 CFR Part $1 9
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t A rir cf Efth D im'd 5; bc;d dupplement I to Regulatory 15 Guide 4.2, " Preparation of Environmental Reports for Nuclear Power Plants". Sh:th D 16 me::: Se req"!re=== cf lf'.2L 17 18 Once the Renewal Operating License is issued by the NRC, the environmental 19 information contained in Exhibit D will be maintained in accordance with applicable 20 regulations and plant procedures.
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1/10/97 RG INSERT C.1-1 l
l The NRC staff is developing a reculatory guide and an environmental standard review plan that will provide guldance or implementing the requirements of Part 51 for license renewal. Until issued, an applicant should follow the format and content guidance contained...
l NEI 95-10 INSERT 6.5 A Supplement to the Environmental Report must be submitted that complies with the requirements of 651.53(c).
The supplement must address certain environmental impacts outlined in Appendix B to Subpart A of 10 CFR Part 51.
L The NRC staff is developing a regulatory guide and an environmental standard i
review plan that will provide guidance on implementing the requirements of i
Part 51 for license renewal. Until issued, an applicant should follow the format and content guidance contained in...
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PROPOSED NRC STAFF RESOLUTION OF COMMENTS i
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QUALITY ASSURANCE PROGRAMS FOR 1
j DOCUMENTATION 1
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NEI 95-10 REVISION 0 March 1, 1996 l
.. r' 3.3 Documenting the Scoping Process 2
3 Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all 4
information and documentation required by, or otherwise necessary to document compliance 1
5 with, the provisions of the Rule.
6 7
The results of the scoping determination should be documented in a format consistent with other 8
plant documentation practices. The information may be maintained in "hard-copy" or electronic 9
format. If available and appropriate, the information may be incorporated into an existing plant 10 database. ";; yy'L_. '_ _:2 _.:_ qdhy===:: p=;;:= h -m~ * 'M p!=: cien 4 ocumentinfthe results of the scoping process.
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,,Iel 13 The information to be documented by the applicant should include:
s,
,g 14 15 A designation of the plant systems, structures, and components that are safety-related 16
( 54.4 (a)(1)), meet the requirements of 54.4(a)(2), or meet the requirements of l
17 54.4(a)(3);
18 od
/
Identification of tMystem[, structurekand component 19 unctions that meet the 20 requirements of 54.4(b) and therefore are intended functions; and n
The information sources, used to accomplish the above, and any discussion needed to 23 clarify their use.
16
- - d NEI 95-10 REVISION 0 March 1, 1996 4.4 Documenting the Integrated Plant Assessment 2
i 3
Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all 4
information and documentation required by, or otherwise necessary to document compliance 5
with the provisions of the Rule.
6 7
The results of the IPA should be documented in a format consistent with other plant 8
documentation practices. The information may be maintained in "hard-copy" or electronic i
9 format. It may be appropriate to incorporate the information into an existing plant database if
_7 1,e t i
10 available. H.::pp!%: d: !d := S:fquality assurance progmm in e5:
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' A W * /'"# M @/" b:* t er p!=:4 opond I1 d
3 ocumenting the results of the IPA.
12 rAev l./ h vred 4 13 4.4.1 Documenting the Identification of Sc, ubject to an Aging Management 1
14 Review v e 4._-
i 15 16 The information to be documented and retained by the applicant should include:
17 5/*(*
I8 An identification and listing of structures and component ubject to an aging 19 management review and their intended functions.
20 A description andjustification of the methods used to determine the structures and components that are subject to an aging management review.
.!3 24 The information sources used to accomplish the above, and any discussion needed to 25 clarify their use.
26 27 The information documented and retained by the applicant will form the bases of the information 28 contained in the Application as further discussed in Section 6.0.
29 30 4.4.2 Documenting the Aging Management Review 31 32 The information to be documented by the applicant should include:
33 34 e
An identification of the applicable aging effects of concern for the structures and 35 components subject to an aging management review.
36 An identification of the specific programs or activities which will manage the effects of 37 e
38 aging for each structure, component, or commodity grouping listed.
39 40 A description of how the programs and activities will manage the effects of aging.
41 A discussion of how the determinations were made.
A list of substantiating references and source documents.
44 40
.J NEI 95-10 REVISION 0 March 1, 1996 i
5.3 Documenting the Evaluation of the Time Limited Aging Analyses and 2
Exemptions 3
4 Section 54.37(a) of the Rule requires applicants to retain in an auditable and retrievable form all 5
information and documentation required by, or otherwise necessary to document compliance 6
with the provisions of the Rule.
7 8
The results of the time-limited aging analyses and exemptions evaluation should be documented 9
in a format consistent with other plant documentation practices. The information may be l
10 maintained in "hard-copy" or electronic format. If available and appropriate, the information pg7 11 may be incorporated into an existing plant database. The g;!!=: icu!d =: S%uality l
12 assurance program ia "--' " -!r:
6,. d.;.;==~94e results of the.~ti.m. e-l_imited aging w
13 analyses and exemptions evaluation.
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14 15 The information to be documented by the applicant should include:
i 16 17 A list of the time-limited aging analyses and exemptions applicable to the plant.
I8 19 A description of the evaluation performed or to be performed on each plant specific TLAA 20 and exemption.
'l A general discussion of how the determinations were made.
2 23 24 A list of substar.tiating references and source documents.
25 26 A discussion of any assumptions or special conditions used in applying or interpreting the 27 source documents.
28 29 The information documented and retained by the applicant will form the bases of the information 30 contained in the Application as further discussed in Chapter 6.0.
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(2) Matters Not Subject to Review A
The revisions reflect the. staff's proposed accept'ance of the public' comments received.
(3) Environmental and Editorial I
The proposed revisions reflect the staff's acceptance of' the public comments received. The staff'also indicated that based on SECY-96-259,. dated December 19, 1996, the current schedule for issuing the environmental RG i
addressing the requirements for implementing the license renewal rule'is July 97, draft, and March 1998, final. The environmental standard review plan addressing implementation of the license renewal rule is scheduled for August j
1997, draft, and August 1998, final.
(4) Quality Assurance Programs for Documentation 4
The revisions reflect the staff's proposed acceptance of the public comments received.
Schedule l
(1). Periodic Working Level and Senior Management Meetings Working level meetings between the NRC staff and NEI are scheduled for January 30;. February 10, 20, and 27; and March 6, 1997. NEI believes that senior j
management meetings between the NRC and NEI are beneficial and a potential f
meeting was discussed around February 14, 1997.
(2) Commission Briefing (and)
(3)
Issue Final Regulatory guide The schedule for issuing the final RG in' August 1997 requires resolution of comments by February 14, 1997, and preparation of the final RG and NEI 95-10 i
for approval by March 14, 1997. A Commission briefing on the status of j
license renewal activities, which will include development of the final RG, is scheduled for the week of June 16, 1997. The final RG will be submitted to 1
j the Commission for approval.
i Original signed by:
1 Stephen T. Hoffman, Senior, Project Manager License Renewal Project Directorate Division of. Reactor, Program Management j
Office of Nuclear Reactor Regulation I
Project 690 4
Attachments: As stated i
cc w/atts: See next page
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