ML17256A004

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NEI Public Meeting Slides - Industry Perspectives on Draft Service Life Regulatory Issue Summary, September 14, 2017
ML17256A004
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Site: Nuclear Energy Institute
Issue date: 09/14/2017
From:
Nuclear Energy Institute
To:
Office of Nuclear Regulatory Research
DiFrancesco N
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Download: ML17256A004 (22)
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INDUSTRY PERSPECTIVES September 14, 2017 ON DRAFT SERVICE LIFE REGULATORY ISSUE

SUMMARY

TODAYS AGENDA

  • Introduction of industry team
  • Evolution of industry concerns with Service Life RIS
  • Context and overarching industry concerns
  • Potential issues with current draft
  • Over-reliance on vendor maintenance recommendations
  • Insufficient consideration of Preventative Maintenance Programs and Maintenance Rule
  • Failure to address existing findings and inspection activity
  • Closing remarks from industry executives

Jerry Bonanno Associate General Counsel, CONTEXT &

Nuclear Energy Institute OVERARCHING Darani Reddick Regulatory Affairs Manager & INDUSTRY Assistant General Counsel, Exelon Corporation CONCERNS

CONTEXT

  • Regulatory Issue Summaries used to communicate and clarify NRC technical or policy positions on regulatory matters that have not been communicated to or are not broadly understood by the nuclear industry. . . .*
  • Given the evolution of the regulatory issues addressed by the RIS, review of the document should focus on whether it adequately communicates and clarifies the agencys positions

OVERARCHING INDUSTRY CONCERN

  • Traditionally, from a backfitting perspective, review focused on identifying explicit statements communicating new or different staff positions
  • But lack of clarity on key regulatory issues can also result in the imposition of unanalyzed backfits in the field

OVERARCHING INDUSTRY CONCERN

  • Imposition of new or different staff positions on the treatment of vendor replacement or refurbishment information could result from lack of clarity regarding:
  • Appropriate classification of vendor information
  • Misclassifying vendor information as design basis or supporting design basis information affects the regulatory consequences of not conforming to vendor recommendations.
  • Relevance of established preventative maintenance programs
  • An overly narrow view of relevant programs and requirements can result in evolving standards regarding the need to conform to vendor recommendations, as well as the level of documentation and formality of evaluations required to disposition such recommendations.

Steve Meyer Regulatory Affairs VENDOR Functional Area Manager, STARS Alliance MAINTENANCE Mike McBrearty RECOMMENDATIONS Manager, Licensing TVA - Sequoyah Jaime McCoy Vice President, Engineering Wolf Creek

VENDOR MAINTENANCE RECOMMENDATIONS

  • Draft RIS conflates vendor recommendations with plant design information
  • Consequence - An incorrect conclusion can be reached that deviations from vendor recommendations results in a loss of quality unless the licensee has performed a technical evaluation to justify the deviation
  • Consequence - An incorrect conclusion can be reached that vendor recommendations are required to be followed in order to maintain ongoing qualification of components in mild environments

VENDOR MAINTENANCE RECOMMENDATIONS Original Equipment Vendor Recommendations Not Specific to Application or Service Condition Original Vendor Vendor Recommendations Recommendations Specific to Based on Test Application and Results Service Conditions Safety Related SSC Vendor Service No Vendor Advisories or Recommendations Technical Bulletins

EXAMPLES OF RECOMMENDATIONS

  • The frequency of the inspection and maintenance operations required should be determined by each operating company and will depend on the application of the breakers and the operating conditions.
  • Factors which should be considered are: Importance to overall plant or system operation; number of operations and magnitude of currents switched by breaker; frequency of fault interruptions; and the atmospheric conditions in which the breaker normally operates.
  • Breakers used for switching arc furnaces or capacitors will require more frequent and more detailed inspection and maintenance because of the repetitive nature of the applications.
  • Examples where no vendor replacement or refurbishment recommendations are provided.

PERSPECTIVE & EXAMPLES SEQUOYAH VIOLATION Mike McBrearty Manager, Licensing TVA - Sequoyah

PERSPECTIVE & EXAMPLES WOLF CREEK VIOLATION Jaime McCoy Vice President, Engineering Wolf Creek Nuclear Operating Corporation

INDUSTRY RECOMMENDATION The RIS should explicitly state that vendor information is not generally considered plant design information and is not subject to the same treatment by the licensee or consideration by inspectors.

Marty Murphy Director, EXISTING Nuclear Regulatory Affairs & Licensing Xcel Energy LICENSEE Vince Bacanskas PROGRAMS Director/Chief Engineer Entergy Services, Inc.

Jaime McCoy Vice President, Engineering Wolf Creek

PREVENTATIVE MAINTENANCE PROGRAMS

  • Preventive maintenance schedules should be developed to specify lubrication schedules, inspection of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.
  • A preventive maintenance programshall be established and maintained. A preliminary program based on service conditions and experience with comparable equipment should be developed. The program should be revised and updated as experience is gained with the equipment.
  • NQA-1, 1994, Subpart 2.18
  • Equipment shall be evaluated to determine its preventive maintenance requirements. That evaluation shall include vendor recommendations as delineated in their Technical Manual and Bulletins, applicable industry standards and operational experience, and maintenance experience and equipment history files. Equipment shall be monitored and evaluated for degradation of performance because of age, as appropriate.

EQUIPMENT IN MILD ENVIRONMENTS

  • A well-supported maintenance/surveillance program, in conjunction with a good preventive maintenance program, is sufficient to ensure that equipment that meets the design/purchase specifications is qualified for the designed life.
  • Conclusion - Industry Preventive Maintenance Programs are consistent with existing regulatory guidance and practices.
  • Conclusion - Vendor recommendations are not required to be performed to maintain ongoing qualification of components in mild environments

MAINTENANCE RULE

  • Compliance with 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," and associated guidance in Regulatory Guide 1.160 are sufficient to provide reasonable assurance that environmental considerations established during design are reviewed every refueling outage and maintained on a continuing basis to ensure that the qualified design life has not been reduced by thermal, radiation, and/or cyclic degradation resulting from unanticipated operational occurrences or service conditions. Modification to the replacement program and/or replacement of equipment should be based on the review of maintenance/surveillance data.

Inputs to PM Strategies PM Change 10CFR50.49 Monitoring & Trending Review and Evaluations Approval Industry Standards Preventive Vendor Input Maintenance Strategies Industry Operating Experience PM PM Work Equipment Maintenance Scheduling Instructions History Software PM Feedback Preventive Maintenance Failure Modes & Effects Analysis Activities

ENTERGY INSPECTION EXPERIENCE Vince Bacanskas Director and Chief Engineer Entergy Services

INDUSTRY RECOMMENDATION The RIS should explicitly state that acceptable and inspectable methods for ensuring appropriate equipment replacement schedules include these existing programs.

CLOSING REMARKS

INDUSTRY PERSPECTIVES September 14, 2017 ON DRAFT SERVICE LIFE REGULATORY ISSUE

SUMMARY

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