Albert Wong
Division of License Renewal
Office of Nuclear Reactor Regulation
The NRC has recently published two draft documents intended to guide the staff’s review of “subsequent license renewal” applications – renewals that would allow commercial nuclear power plants to operate beyond 60 years. We’ll use public comments we receive on these to develop final guidance as we prepare to receive the first “SLR” application sometime in 2019.
As we discussed in an earlier blog post, the NRC licenses plants to operate for 40 years, and the licenses can be renewed for up to 20 years at a time. To date, the agency has renewed the licenses of 81 reactors (two of which have since permanently shut down).
As industry looks to operate some plants beyond 60 years, we’re getting ready to assess the particular challenges to keeping the plants safe. That’s where these draft guidance documents come in.
The documents address material aging and degradation a plant’s structures, systems and components may experience when operating more than 60 years. They also detail aging management programs acceptable to the NRC for licensees to use during the subsequent license renewal period. They incorporate lessons learned and knowledge gained by the staff from recent plant operating experience and previous license renewal reviews.
Long-term operation research sponsored by the NRC, the Electric Power Research Institute, the Department of Energy’s national laboratories and international organizations also informs the guidance.
Public comments on the draft guidance documents will be accepted through February 29. The staff will hold public meetings at NRC headquarters in Rockville, Md., on January 21, January 22 and February 23 to present the reports and receive comments. The final documents should be published by mid-2017.
The draft reports are available on the NRC’s License Renewal Guidance webpage.
NOTE: Comments posted here will NOT be considered public comments on the draft guidance documents. To have your comments considered by the staff as it develops the final guidance documents, please use the federal government’s rulemaking website www.regulations.gov, using Docket ID NRC-2015-0251. Comments may also be mailed to Cindy Bladey, Office of Administration, Mail Stop: OWFN-12-H08, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. Comments are accepted through February 29, 2016.
U.S. NRC Blog 
David – I am in violation of myself, I am still speaking, but this is the last (but, truly happy that you interacted) – This is the peril in which NRC finds it selves in, when units operate under “(Un) timely renewal.” You have to answer to the public, on operational issues in a “post pending timely renewal” mode. I happened to read (honest – after my post), a staff’s recommendation to commission (SECY-2014-0016, enclosure 1, pp 2), when they raised the very same item on “timely renewal” for SLR. It was killed with some motherhood statements (by the commission). Whereas, the right thing was to have recommended the Rule Making. The NRC has to face such problems head on practically scientifically, and not stick its head in the sand; otherwise, you are going to be moderating endless numbers of blogs, such as this one!
Mr. Mulligan – I’m not sure I quite follow the thread of your comment, but I can distill this question: When a license renewal review extends for quite some time, as Indian Point’s has, does the NRC rely on inspections that took place early on, or does the agency look again to ensure that systems, structures or components haven’t degraded in the meantime?
When the NRC renews a reactor license, we perform an inspection before the plant enters the period of extended operation (the 40-60 year period). Our inspectors verify the licensee’s implementation of the NRC-approved aging management programs required under the renewed license. That’s how we ensure the aging management programs are current and consistent with earlier inspection findings. In essence, those early inspections as part of the license renewal review are not the last word.
Although Indian Point’s licenses for Units 2 and 3 have not been renewed, the plants continue to operate under “timely renewal” while we continue our review of the license renewal application. Entergy voluntarily implemented the aging management programs that would be required under renewed licenses. Consistent with our practice, we conducted inspections prior to the original license expiration dates and verified that Entergy had properly implemented these programs. In addition, Entergy updated the Indian Point Final Safety Analysis Reports to incorporate those programs; this makes the changes subject to inspection and enforcement under the Reactor Oversight Process.
David McIntyre
I was talking recently to the NRC about parts of Indian Point’s license renewal. Had issues with the plants flooding analyses associated with the flooding analysis in the SBO safety switchgear room. Issues with fire water and service water piping reliability. I noticed the license renewal manager kept talking about the NRC’s 2013 relicense inspections that didn’t uncovered any issue with fire water or service water piping reliability issues in the relicensing inspection report. Entergy point is the NRC basically passed their piping integrity program…corrosion and leaks. There has been some recent back and forth between Entergy and the NRC over piping corrosion issues and leaks. The Dec 29, 2014 leak in unit 1’s fire water system piping and resulting shutdown in units 2 ‘s fire water system to fix the leak is particularly perturbing to the NRC. Basically a pin hole leak was discovered in unit 1’s a fire water pipe in 2008. Then it got lost in their paperwork bureaucracy until the pipe burst late 2014. They got a contractor to replace the weakened pin hole area, cut out piping and replaced with new for this specific leak…but the dopes replaced piping in the wrong area. So the 2008 pin hole leak was never fixed until it burst. This is sentinel issue to learn from mistakes in the bureaucracy and it could include other areas. It is very perplexing why Entergy wasn’t force to submit a license event report (LER) on this Dec 29, 2014 event. Why do some fire and service water piping leaks get reported in LERs and others need not get reported? So Entergy irritated the NRC with their renewal responses on the fire water and service water reliability issues. This is why the NRC recently notified Entergy of a audit on the fire water and service water leaks and corrosion problems. The OEs.
I better get back to licensing renewal issue at some point. Would historical documentation be more important in the second twenty year license renewal? The eighty year license?
You know where I am going here. Most of OEs and renewals inspections revolve around doing studies and analysis on plant LERs. Very few of the plant events ever gets written up in LERs, as this Dec 29, 2014 major fire waterpipe leaks shows. Is it really a comprehensive license renewal if only LERs are the foundation for relicensing…or a major component of relicensing?
So the major nrc renewal inspection activities at Indian Point 2 occurred in the 2013 timeframe as the Indian Point’s renewal manger recently referenced. One wonders if the dead space between NRC’s licensing renewal inspection (2013-2016something) and finally getting relicensed even counts? Does the NRC relicensing inspections ever expire?
Let’s say the relicensing process at one plant eventually takes five to ten years. Maybe the NRC turns relicensing into an infinite process. So in this exaggerated example, you going to relicense a plant based on NRC renewal inspections that are almost ten years old. In a contested and controversial prolonged license renewal, how do you keep the renewal NRC inspections fresh and up to date?
Oh Boy, this is going to be one of my greatest stupid questions.
Event Report Guidelines 10 CFR 50.72 and 50.73: “In 1983, partially in response to lessons from the accident at Three Mile Island Nuclear Station, the NRC revised its immediate notification requirements through the emergency notification system (ENS) in 10 CFR 50.72 and modified and codified its written licensee event report (LER) system requirements in 10 CFR 50.73.”
Was anyone even thinking about licensing renewals in 1983? The program was certainly in its infancy in 1983. Does 10 CFR 50:72 and 50:73 take into consideration that LERs will eventually be used in licensing renewals? Would the LER reporting requirements be different or set lower if LER reporting also was specifically considered for the definitive plant historical record in licensing renewal? LERs are a primary tool for plant licensing renewals. Should the LER system be specifically engineered or shaped for license renewal? It certainly wasn’t newly post TMI and in 1983.
Mike Mulligan
Hinsdale, NH
The post by Mr. Brenner left me with the impression that there is an unexplained reluctance on the part of NRC subject matter experts to actively participate here. I hope you’re not being pressured by anyone – elected or otherwise – to avoid even the appearance of being critical of those who so frequently denigrate your reputation. I encourage greater interaction here by NRC. Anything you can do to help raise the signal-to-noise ratio on this site would be greatly appreciated.
Thanks for weighing in again NRC even though you won’t always do so.
My apologies to David, I thought he had a real job with the NRC.
David McIntyre is a public affairs officer with the NRC.
A recent blog post by Public Affairs Director Eliot Brenner specifically addressed the NRC’s stance in regards to responding to blog comments. This is what he wrote: We will continue to try to address direct questions posed in comment, and to occasionally point out factual errors in comments. We will continue to refrain, however, from weighing in on every comment discussion. We feel it more appropriate for the blog visitors to be given the opportunity to share their views civilly with us and each other.
Moderator
Dialogue Appreciated
I have at last found a point that I can agree with from the few who choose to bother with supporting what the pro-nuclear power NRC has to say.
Most of the time these few repeat nuke power advocates say they do not even bother to set us evil anti-nuke folks straight because our comments do not rise to a level, in their opinion, that even deserve a response.
But indeed I noted that the NRC Moderator (David) did respond to provide feedback to this particular blog response. I noted a good push back comment in what David had to say. David, in a nice way, noted that “a keen observer will note significant differences”. Yes I would agree that not all of us commenters are “keen” observers.
I also believe David was not in the NRC PR department because the post was responsive, informative, and to the point.
Another David also noted the following…
“Thanks David, it’s good to see a response from a moderator. Wish it would happen more frequently.”
I could not agree more!
I think, NRC, if you do respond to comments I think it will make for a much more interesting and appealing blog site.
I know the downside is that it will encourage us “anti-nukes” to make even more “keen less” comments but doesn’t that go with the turf on a good blog site?!
David – I am satisfied; but I would not quite broad brush it with years of operational experience to show the program is effectiveness; for, charpy V-notch measures the ductile-to-brittle transition of material and is there to condition monitor with an objective to prevent catastrophic failure. Remember, Titanic sinking and to connect the iceberg to notch toughness, took years of research – we don’t know what imponderables are involved with radiation fluence. At best, we have to be modest to say it is progressive. We are pioneers in this venture with the aging fleet. I will stop here. – Anonymous
Thanks David, it’s good to see a response from a moderator. Wish it would happen more frequently.
On the contrary. While there are indeed several similarities between the GALL-SLR and the original GALL and its 2010 revision, a keen observer will note significant differences. The similarities are there for a simple reason: Those programs work. We have several years of operational experience to show the Reactor Vessel Surveillance Aging Management Program is effective. Including it in the new guidance makes sense. Other aging management programs were changed significantly. For example, the Pressurized Water Reactor Vessel Internals Aging Management Program was eliminated in favor of plant-specific programs. For Boiling Water Reactor Vessel Internals, related components will now require further evaluation of irradiation-induced effects. We will hold public meetings in February to outline the new guidance and changes from the previous GALL and Standard Review Plan. Additional changes to the guidance may be included based on the comments we receive.
As for timely renewal, this is a requirement established by Congress in the Administrative Procedures Act, Section 558:
When the licensee has made timely and sufficient application for a renewal or a new license in accordance with agency rules, a license with reference to an activity of a continuing nature does not expire until the application has been finally determined by the agency.
And don’t forget: The NRC has authority to address safety issues at any time, regardless of the status of a license renewal application.
David McIntyre
@Anon
So, let’s say the utility complies with regulations and files a license extension request the minimum required 5 years prior to expiration. And then the review process is prolonged by circumstances beyond the utility’s control – let’s say, for example, by an endless stream of unsubstantiated contentions filed by professional interveners whose sole purpose is run up the cost to the utility in the form of staff review hours, or in the case of IPEC 3, the deferral of approval pending completion of the revised Waste Confidence Rule. What is the plant supposed to do at the hour of expiration (he asked rhetorically)? Just go to cold shutdown and defuel the reactor while the artificially protracted review cycle runs its course? Don’t bother replying – we already know your answer.
This new guidance (NUREG-1800 and 1801, reissued under new NUREG number) are exactly identical to the one issued in 2005 and taken credit for reissuance in 2010! Pragmatically, a keen observer cannot see any sensible difference or anything new in the SLR guidance now issued for comments. For example, see a vital Aging Managing Program guidance on Reactor Vessel Material Surveillance. Except for one cosmetic and editorial change, such as change to “40-year license term” there is nothing new! This is one vital program that monitors neutron embrittlement properly accounted for, where structural properties are being altered (notch toughness) when subjected to peak neutron fluence at the end of the design life (40 years) which is already past. We are moving from 40 to 60 years to 80 years in 20 year increment and you are so callous that you cut-and-paste a previous program “as is.” It is appalling.
Do one thing in the least – shut the “Timely Renewal Clause routine” out of the new rule when writing SLR guidance, and not enable slick operators like Entergy secure a backdoor entry and continue to operate units (case in point Indian Point 2 and 3) without an official renewal being accorded.
As the wicked Witch said in the (original) Wizard of Oz, “These things must be done delicately”…
I’m happy to see that the NRC is providing until the end of February 2016 for public comments on what may very well be, one of the most important decisions the NRC will be making. Hopefully by then, many comments from the public will have posted comments that help the NRC determine how to best fulfill its role as the Regulator of a Nuclear Industry that feels it not only knows best but needs far less regulation.