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{{Adams
#REDIRECT [[NUREG-1800, Proprosed Revision of Chapters II & III of Generic Aging Lessons (Gall) Report on Aging Management of Concrete Elements]]
| number = ML013300440
| issue date = 11/23/2001
| title = Proprosed Revision of Chapters Ii & Iii of Generic Aging Lessons (Gall) Report on Aging Management of Concrete Elements
| author name = Grimes C I
| author affiliation = NRC/NRR/DRIP/RLSB
| addressee name = Lochbaum D A, Nelson A P
| addressee affiliation = Nuclear Energy Institute (NEI), Union of Concerned Scientists
| docket = PROJ0690
| license number =
| contact person = Kang P J, NRR-RLSB, 415-2279
| case reference number = +KBR1SISP20050608, NUREG-1800, NUREG-1801
| document type = Letter, Report, Miscellaneous
| page count = 6
}}
 
=Text=
{{#Wiki_filter:November 23, 2001Mr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400 Washington, DC  20006-3708Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919
 
==SUBJECT:==
PROPOSED REVISION OF CHAPTERS II AND III OF GENERIC AGINGLESSONS LEARNED (GALL) REPORT ON AGING MANAGEMENT OF CONCRETE ELEMENTS
 
==Dear Messrs. Nelson and Lochbaum:==
The purpose of this letter is to provide you with the opportunity to comment on the proposedrevision of Chapters II (Containment) and III (Structures) of the GALL report. The need for the proposed clarification on concrete in these GALL chapters was discussed with the Nuclear Energy Institute (NEI) during the lessons learned meeting on the license renewal demonstration project held on October 11, 2001. This issue is listed as item No. 3.9 in the letter to Alan Nelson of NEI, from Christopher Grimes of NRC, dated October 3, 2001. This process is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry as outlined in NRR Office Letter No. 805, "License Renewal Application Review
 
Process."The staff has revised sections of Chapters II and III of the GALL report and a brief descriptionof the basis for the clarification and its changes is provided in Enclosure 1. Since the proposed changes also affect other parts of the guidance documents, all pertinent changes in Chapters II and III of GALL Volume 2 and Table 5 of GALL Volume1 (NUREG-1801), and Table 3.5-1 of Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) have been included as Enclosure 2. We are requesting your comments on the proposed markup, and we request that you submitcomments within 45 days following the date of this letter to ensure a timely resolution of this issue. The staff plans on incorporating this position into the improved renewal guidance documents in a future update. If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.Sincerely,/RA/Christopher I. Grimes, ChiefLicense Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject No. 690
 
==Enclosures:==
As stated cc w/encl: See next pageMr. Alan NelsonNuclear Energy Institute 1776 I Street, NW., Suite 400Washington, DC  20006-3708 Mr. David LochbaumUnion of Concerned Scientists 1707 H Street, NW Suite 600 Washington, DC 20006-3919
 
==SUBJECT:==
PROPOSED REVISION OF CHAPTERS II AND III OF GENERIC AGINGLESSONS LEARNED (GALL) REPORT ON AGING MANAGEMENT OF CONCRETE ELEMENTS
 
==Dear Messrs. Nelson and Lochbaum:==
 
The purpose of this letter is to provide you with the opportunity to comment on the proposedrevision of Chapters II (Containment) and III (Structures) of the GALL report. The need for the proposed clarification on concrete in these GALL chapters was discussed with the Nuclear Energy Institute (NEI) during the lessons learned meeting on the license renewal demonstration project held on October 11, 2001. This issue is listed as item No. 3.9 in the letter to Alan Nelson of NEI, from Christopher Grimes of NRC, dated October 3, 2001. This process is consistent with our goal to more efficiently resolve license renewal issues identified by the staff or the industry as outlined in NRR Office Letter No. 805, "License Renewal Application Review
 
Process."The staff has revised sections of Chapters II and III of the GALL report and a brief descriptionof the basis for the clarification and its changes is provided in Enclosure 1. Since the proposed changes also affect other parts of the guidance documents, all pertinent changes in Chapters II and III of GALL Volume 2 and Table 5 of GALL Volume1 (NUREG-1801), and Table 3.5-1 of Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) have been included as Enclosure 2. We are requesting your comments on the proposed markup, and we request that you submitcomments within 45 days following the date of this letter to ensure a timely resolution of this issue. The staff plans on incorporating this position into the improved renewal guidance documents in a future update. If you have any questions regarding this matter, please contact Peter Kang at 301-415-2779.Sincerely,/RA/Christopher I. Grimes, ChiefLicense Renewal and Standardization Branch Division of Regulatory Improvement Programs Office of Nuclear Reactor RegulationProject No. 690
 
==Enclosures:==
As stated cc w/encl: See next page Distribution: See next pageDOCUMENT NAME:C:\Program Files\Adobe\Acrobat 4.0\PDF Output\GALL CC lessons learned.wpdOFFICERLSBLA(A)RLSB:SCNAMEPkangEHyltonJ Nakoski DATE 11/20/0111/20/0111/20/01 OFFICEDE:DRLSB:BC NAMEJStrosniderCGrimes DATE11/21/0111/23/01OFFICIAL RECORD COPY DISTRIBUTION
:Package: ML013300426 HARD COPY RLSB RFE. HyltonE-MAIL:PUBLICJ. Johnson W. Borchardt D. Matthews C. Carpenter C. Grimes B. Zalcman
 
J. Strosnider (RidsNrrDe)
F. Eltawila G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski S. Rosenberg G. Holahan B. Boger D. Thatcher G. Galletti B. Thomas J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis N. Dudley RLSB Staff
 
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A. Thadani R. Zimmerman C. Julian R. Gardner D. Chyu M. Modes J. Vora NUCLEAR ENERGY INSTITUTE Project No. 690
 
cc:Mr. Joe BartellU.S. Department of Energy NE-42 Washington, D.C. 20585Mr. Richard P. Sedano, CommissionerState Liaison Officer Department of Public Service 112 State Street Drawer 20 Montipelier, Vermont 05620-2601Mr. Stephen T. HaleFlorida Power & Light Company 9760 S.W. 344 Street Florida City, Florida 33035Mr. William CorbinVirginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia  23060Mr. Frederick W. PolaskiManager License Renewal Exelon Corporation 200 Exelon Way Kennett Square, PA 19348Mr. Robert GillDuke Energy Corporation Mail Stop EC-12R P.O. Box 1006 Charlotte, NC  28201-1006Mr. Charles R. PierceSouthern Nuclear Operating Co.
40 Inverness Center Parkway BIN B064 Birmingham,  AL 35242Mr. Paul GunterDirector of the Reactor Watchdog Project Nuclear Information & Resource Service
 
1424 16 th Street, NW, Suite 404Washington, DC 20036Hugh JacksonPublic Citizen's Critical Mass Energy &
Environment Program 215 Pennsylvania Ave. SE Washington DC 20003 Description of the Basis for the Clarification and Changes for Concrete Elements(Item No. 3.9 in a letter to NEI dated October 3, 2001)
Basis:The staff position is that aging of concrete elements of the containment and other Class 1structures should be managed. Contrary to this position, the staff observed during review of the Nuclear Energy Institute (NEI) license renewal demonstration project that the participants misinterpreted the staff's license renewal guidance on this issue and determined that there were no aging effects requiring management for concrete elements for the above structures. The reasons for the misinterpretation were that:  (1) applicable aging management programs (AMPs) for concrete elements in the current Generic Aging Lessons Learned (GALL) report were not clearly stated and (2) some inconsistencies were found between Chapters II and III of the GALL report for the concrete elements. During the review, all participants agreed that each AMP should be divided into accessible and inaccessible areas that are addressed separately. The staff agreed that applicable AMPs for degradation of concrete should be clarified in the GALL report and the Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) of the improved renewal guidance documents.Changes:Under the "Aging Management Program (AMP)," column for concrete elements in thecontainment and Class 1 structures in Chapter II of the GALL report, the staff replaced thecurrent AMP with a new AMP that addresses accessible and inaccessible areas separately based on:  (1) the inspection for accessible areas would be required to be performed in accordance with ASME section XI, Subsection IWL under the requirements of 10 CFR 50.55a (existing mandated program) and (2) a plant-specific aging management program is required for inaccessible areas if the below grade environment is found to be aggressive or exposed to flowing water. Therefore, with the existing mandated program, the plant-specific AMP for concrete elements in the containment and Class 1 structures is only required to address inaccessible areas. For Chapter III, the staff again replaced thecurrent AMP with a new AMP that addresses accessible and inaccessible areas separately.
The inspection for accessible areas would be required in accordance with a "Structural Monitoring Program" based on the requirement of 10 CFR 50.65 (Maintenance Rule), while a similar plant-specific program would be required for inaccessible areas by closely following the Chapter II example. The staff chose not to change the answer in the "Further Evaluation" column of the GALLreport, but has clarified when further evaluation is required following the "Yes" or "No response. The staff has determined this was an efficient and effective method for updating the license renewal guidance documents.Enclosure 1}}

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