ML17317A442
| ML17317A442 | |
| Person / Time | |
|---|---|
| Issue date: | 10/17/2018 |
| From: | Mark Notich NRC/NRO/DNRL |
| To: | |
| Notich M | |
| Shared Package | |
| ML17355A155 | List: |
| References | |
| Download: ML17317A442 (12) | |
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RESPONSE TO PUBLIC COMMENTS ON DRAFT STANDARD REVIEW PLAN SECTION 14.3.3, PIPING SYSTEMS AND COMPONENTS - INSPECTIONS, TESTS, ANALYSES AND ACCEPTANCE CRITERIA On September 11, 2017, a Notice of Opportunity for Public Comment was published in the Federal Register (82 FR42709) on the proposed revision to NUREG-0800, Standard Review Plan (SRP), Section 14.3.3,Piping Systems and Components - Inspections, Tests, Analyses, and Acceptance Criteria. Comments were received from:
Unknown Commenter Nuclear Energy Institute 1201 F Street, NW, Suite 1100 Washington, D. C., 20004 The comments can be found in ML17312A276 and ML18081A241 respectively.
The NRCs staff review and disposition of the comments are provided in the following table.
No. Reference Comment Submission NRC Resolution 1 General Nearly 8 million acres have burned in 2017, Comment is out of scope. No revisions to the such wildfires will release thousands of tons of SRP were made.
greenhouse gas emissions and other harmful air pollutants." impact of wildfires on the atmosphere. After smoke from the Chetco Bar Fire forced the Ashland Shakespeare Festival to cancel performances last month due to smoke and haze, Rep. Greg Walden declared, "Enough is enough." Newspaper report, 2007 said California wildfires pumped nearly 8 million metric tons of climate-warming carbon dioxide into the atmosphere, nov 29 201\6 Wildfire smoke can result in significant air quality impacts to_ public health. Then we have 2017 wildfire again. Another report from Scientists study estimated that Fires in US release millions 1
No. Reference Comment Submission NRC Resolution metric tons of carbon dioxide per year. Wildfires can produce more greenhouse gas (GHG) emissions then gas and oil, therefore we should manage forest better by stopping the regulations against clear cutting to help prevent co2 from mass wildfires in western states. US Forest service page; fuels buildup to unnatural levels and forests become overcrowded. This led to forests being more susceptible to insects and disease outbreaks, but also to unnaturally large fires on the landscape. Another report:,
"Forest fires may produce as. much co2 as half of all fossil-.fuels burned", U~ orest Service page, 2015 Pacific Northwest wildfire season Washington 130,000 tons Oregon 90,000 tons of fine particulate matter The greenhouse gas emissions alone were equivalent to more than 8.5 million passenger vehicles driven for a year or heating 3. 7 million homes. government charge or fine califomia for Co2 wildfire pollutants? US forest service page wildfire report on 2015 year reported on greatest threat to many endangered species and their habitat is catastrophic WILDFIRE leads to susceptible to insects and disease outbreaks ... MUST do thinning forest to protect habitat and more resistant to insect predation. concentration of trees and underbrush amounts to 45 tons of dry fuel per acre, potential for catastrophic fire ......
Currently, even utility crews must receive Congressional approval before preforming regular maintenance or the repairing of damaged power lines. When a right-of-way is not properly maintained, a tree can grow into or fall on to a power line, causing fires . 201 7 Mr 2
No. Reference Comment Submission NRC Resolution Secretary Zinke accumulation and thickening of vegetation exacerbates fuel conditions and often leads to larger and higher-intensity fires," .. *
... 2015 USFS Chief Dave Bosworth Said, "We Do Not Have A Fire Problem On Our Nation's
. Forests; We Have A Land Management Problem" LITIGATION has had a profound impact on mismanagement of our national forests, Need to update or repeal the Equal Access to Justice Act (EAJA) of 1980, subsection of EAJA, codified at 28 U.S.C. 2412(d) section 2412 (b).
2 II.1 - Generic This section describes the five ITAAC that relate The NRC staff will reformat the ITAAC description Piping Design, p. 6 to piping design. Consistent with the as suggested by NEI.
subsections under Verification of Components and Systems, the SRP should identify the NRC-proposed standard ITAAC.
3 II.2.C - Hydrostatic Consistent with other sections of this SRP, this As discussed in paragraph II.2.C, Pressure Test, Test, p. 10 section should identify the NRC-proposed in SRP Section 14.3.3, the NRC staff has not standard ITAAC language for hydro testing. proposed a standardized ITAAC for pressure testing of piping systems. The pressure test is typically addressed as part of the standard ITAAC for ASME BPV Code,Section III, Code Class 1, 2, and 3 Data Reports discussed in paragraph II.1, Generic Piping Design. In addition, instances of the phrase hydrostatic test have been replaced with the more generic phrase pressure test to include the option of pneumatic testing in accordance with ASME BPV Code requirements.
4 II.2.C - Hydrostatic Editorial - the word also in the second The NRC staff will make the editorial change as Test, p. 10 sentence lacks context. suggested by NEI.
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No. Reference Comment Submission NRC Resolution 5 II.2.D - Equipment It is a general principle of ITAAC and historical The NRC staff disagrees with the NEI Seismic and practice that Acceptance Criteria should not recommendation. In design certification reviews, Dynamic refer to industry codes and standards or NRC the NRC staff has considered the seismic Qualification, p. 10 regulatory guidance. Instead, references to qualification methods and standards to be Tier 1 codes, standards and regulatory guidance are information, but has allowed applicants to specify provided in Tier 2 of the DCD along with related this information as Tier 2* in design certification design information. Acceptance Criterion (i) for rulemaking. To minimize the use of Tier 2* as seismic EQ violates this principle/practice as discussed in Commission Paper SECY-17-0075, well as specific guidance provided in Section II.1 the NRC staff has provided guidance in SRP of this SRP under Regulations, Codes and Section 14.3.3 to specify IEEE 344-2004 and Standards. That guidance states that ASME QME-1-2007 (as accepted in RG 1.100, references to Codes and Standards should be Revision 3) in the ITAAC description to eliminate minimized and identifies references to the the need for this Tier 2* item in the design ASME BPV Code as an exception. certification rulemaking. An applicant may propose alternative ITAAC to address the Tier 1 information for seismic qualification methods and standards.
For example, the applicant might include a table in Tier 1 specifying the seismic qualification methods and standards.
6 II.2.D - Equipment The format of this section makes it hard to The NRC staff will reformat the ITAAC description Seismic and discern that there are two Acceptance Criteria consistent with descriptions of other ITAAC in SRP Dynamic for seismic EQ. Section 14.3.3.
Qualification, p. 10 7 II.2.D - Equipment Starting from, In some instances, the The NRC staff agrees with NEI that the reference Seismic and paragraph becomes confusing and adds little to a basic configuration ITAAC might be confusing Dynamic value beyond the discussion already presented. and will delete basic configuration from Qualification, p. 11 For example, there is a reference to basic paragraph II.2.D, Equipment Seismic and configuration ITAAC in SRP 14.3, App. D, that Dynamic Qualification. In addition, the staff will does not exist. In addition, the discussion of Tier clarify the discussion of Tier 2* information at the 2* information does not reflect updated NRC end of the paragraph. The staff discusses the practice in the wake of SECY-17-0075. ITAAC references to ASME QME-1-2007 and RG Furthermore, as discussed in Comment [5], 1.100 (Revision 3) for seismic qualification 4
No. Reference Comment Submission NRC Resolution above, it is inappropriate to suggest that methods and standards in response to Comment references to ASME QME-1 and RG 1.100 5.
should be included in ITAAC.
8 II.2.F.1.a - Pump Refer to Comment [5], above, concerning The NRC staff disagrees with the NEI and Valves, p. 12 avoiding reference in ITAAC to industry codes recommendation to remove the reference to ASME and standards or NRC regulatory guidance. The Standard QME-1-2007 from the guidance in SRP requirement that Functional Qualification Section 14.3.3 for ITAAC for pump and valve Reports be prepared in accordance with ASME qualification. The NRC staff has considered the QME-1/RG 1.100 is appropriate to include in qualification of power-operated valves and/or Tier 2 of the DCD. motor-operated valves in new reactors to be Tier 1 information based on lessons learned from inadequacies in the design and qualification of valves in current nuclear power plants. Rather than Tier 1 requirements, the staff has allowed design certification applicants to specify this information as Tier 2* in the design certification rulemaking. To minimize the use of Tier 2*
information consistent with Commission Paper SECY-17-0075, SRP Section 14.3.3 provides guidance to address the qualification of pumps and valves in ITAAC by specifying the acceptable methodologies provided in ASME Standard QME-1-2007 as accepted in RG 1.100 (Revision 3). An applicant could propose an alternative method to the guidance in SRP Section 14.3.3 to address this Tier 1 information. For example, the applicant might include a table in Tier 1 specifying the pump and valve qualification standards.
9 II.2.F.1.a - Pumps The discussion of Tier 2* information does not The NRC staff disagrees with the NEI and Valves, p. 13 reflect updated NRC practice in the wake of recommendation to delete the last two sentences SECY-17-0075. Moreover, it is inappropriate to under subparagraph (a) of paragraph II.2.F.1.
suggest that references to ASME QME-1 and Commission Paper SECY-17-0075 states that based on consideration of the advantages and 5
No. Reference Comment Submission NRC Resolution RG 1.100 should be included in ITAAC. Refer disadvantages of the potential alternatives, the also to Comment [7], above. NRC staff intends to continue use of the Tier 2*
designation in design certifications. Therefore, the NRC staff guidance in SRP Section 14.3.3 is consistent with the NRC staff position in SECY 0075. As discussed in response to Comment 8, the NRC staff has considered the qualification of power-operated valves and/or motor-operated valves in new reactors to be Tier 1 information based on lessons learned from inadequacies in the design and qualification of valves in current nuclear power plants. Rather than Tier 1 requirements, the staff has allowed design certification applicants to specify this information as Tier 2* in the design certification rulemaking. To minimize the use of Tier 2* information, SRP Section 14.3.3 provides guidance to address the qualification of pumps and valves in ITAAC by specifying the acceptable methodologies provided in ASME Standard QME-1-2007 as accepted in RG 1.100 (Revision 3). An applicant could propose an alternative method to the guidance in SRP Section 14.3.3 to address this Tier 1 information. For example, the applicant might include a table in Tier 1 specifying the pump and valve qualification standards.
10 II.2.F.2 - Pump and Editorial: The NRC staff will include this editorial correction.
Valve Preop Add pumps and so the second sentence Testing, p. 14 reads:
for verification of the performance of these pumps and valves.
11 II.2.F.2.b.i, iii, iv - There is no basis in NRC regulations or NRC The NRC staff disagrees with the NEI Valve Preop guidance to require preoperational diagnostic recommendations to delete diagnostic data from Testing, p. 15-16 test data to correlate valve test results to valve the ITAAC for valve preoperational testing, and to 6
No. Reference Comment Submission NRC Resolution design basis capability. This has not been a delete the requirement for analyses correlating requirement in either Tier 1 or Tier 2 of any preoperational test results to design-basis previous DCD. As indicated by the vague capability. ASME Standard QME-1-2007 requirement for sufficient diagnostic data, there establishes the qualification requirements to is no approved methodology for correlating demonstrate the functional capability of the valve preop results to design basis capability. actuator assembly over the full range of pressure, Moreover, an Acceptance Criterion that requires temperature, and flow conditions using diagnostic sufficient data violates the key tenet that data. ASME QME-1-2007 also requires post-ITAAC be clear and objective with respect to installation verification and IST baseline testing demonstrating Acceptance Criteria are met. under representative fluid conditions to collect diagnostic data to verify the production valve assembly meets the functional requirements of the Qualification Specification. The guidance in SRP Section 14.3.3 describes an acceptable ITAAC for valve preoperational testing that will satisfy the provisions in ASME Standard QME-1-2007 for post-installation testing. The staff accepts the NEI recommendation to delete the word sufficient as not necessary in the ITAAC requirement.
12 II.2.G - Installed The Installed Configuration ITAAC envisioned The NRC staff disagrees with the NEI Configuration, p. 17 by this SRP is ambiguous, unbounded, recommendation to delete paragraph G in SRP unverifiable, and completely unnecessary. It is 14.3.3 describing the Installed Configuration redundant to other ITAAC that provide ITAAC. The NRC regulations in 10 CFR 52.80, reasonable assurance that SSCs are properly Contents of applications; additional technical installed and will operate as designed. It is also information, require in paragraph (a) that a redundant to the Quality Assurance Program combined license (COL) application must contain which is approved and overseen by the NRC the proposed inspections, tests, and analyses, and assures that quality-related activities including those applicable to emergency planning, associated with plant design, procurement, that the licensee shall perform, and the acceptance fabrication, construction, testing (including use criteria that are necessary and sufficient to provide of appropriate and calibrated tools) and reasonable assurance that, if the inspections, operation are implemented properly and in tests, and analyses are performed and the accordance with licensee procedures, applicable acceptance criteria met, the facility has been codes and standards and NRC regulations. QAP constructed and will be operated in conformity with 7
No. Reference Comment Submission NRC Resolution implementation as well as turnover and the COL, the provisions of the Atomic Energy Act, commissioning testing confirm the proper and the NRCs rules and regulations. This configuration and performance of systems. regulation requires the licensee to implement ITAAC and the QAP have distinct, yet ITAAC that verify that the nuclear power plant was complementary roles. While the QAP assures built in accordance with the certified design and will the proper implementation of quality-related be operated safely. The licensees completion of activities, ITAAC focus on verifying that as- the Installed Configuration ITAAC (also referred to built SSCs satisfy the top level design and as Functional Arrangement ITAAC) will verify that performance standards specified in the COL. the installation of the nuclear power plant The envisioned Installed Configuration ITAAC components and piping is consistent with the would not maintain the vital distinction between requirements specified in the final safety analysis the roles of ITAAC and the QAP and report. Other ITAAC focus on attributes of specific significantly expand the scope of Tier 1 and components (such as structural integrity or ITAAC to include matters that have historically, operation) or systems (such as flow rates or effectively and appropriately been addressed in hydrostatic testing), but do not verify that the Tier 2. installation aspects (such as component orientation and piping slope) have been completed in Inclusion of this ITAAC would negate the accordance with the certified design requirements.
extensive efforts expended to ensure the clarity Therefore, the Installed Configuration ITAAC are and focus of every other ITAAC, as well as the part of the overall set of ITAAC used to verify that important distinction between verifying the top- the nuclear power plant is constructed and will level design and performance characteristics of operate in accordance with the COL. The NRC will Tier 1 versus the balance of design information rely on its sample inspections of the licensees in Tier 2. The unbounded nature of this ITAAC completion of the Tier 1 ITAAC, including the renders it essentially unverifiable under the Installed Configuration ITAAC, to support the NRC ITAAC closure process. This is precisely the finding in 10 CFR 52.103(g). To verify that the reason for the distinction between ITAAC and licensee has completed the ITAAC required by 10 the QAP and the why the ITAAC process relies CFR 52.80, multiple inspections under NRC upon - and does not repeat - QAP activities that Inspection Manual Chapter (IMC) 2503, assure the proper implementation of quality- Construction Inspection Program: Inspections of related activities. Inspections, Tests, Analyses and Acceptance For these reasons, no functional arrangement, Criteria (ITAAC) Related Work, will be conducted installed configuration, or similar ITAAC is to sample the licensees activities to verify the included in the standardized ITAAC developed installed configuration or functional arrangement of for use by KHNP, NuScale or future design plant systems consistent with those ITAAC. For 8
No. Reference Comment Submission NRC Resolution certification applicants, and none should be example, AP1000 ITAAC Family 14A, As-Built called for anywhere in SRP 14.3. Complex Systems with Multiple Components, includes functional arrangement ITAAC for the Reactor Coolant System (RCS) in ITAAC 2.1.2.1, Passive Core Cooling System (PXS) in ITAAC 2.2.3.1, and Protection and Safety Monitoring System (PMS) in ITAAC 2.5.2.1. The primary IMC 2503 inspection procedures for this ITAAC family include Inspection Procedure (IP) 65001.A, ITAAC Attributes for As-Built Inspection, IP 65001.03, Inspection of ITAAC-Related Installation of Piping, IP 65001.06, Inspection of ITAAC-Related Installation of Mechanical Components, IP 65001.07, Inspection of ITAAC-Related Installation of Valves, IP 65001.10, Inspection of ITAAC-Related Installation of Instrument Components and Systems, and IP 65001.14, Inspection of ITAAC-Related Installation of Complex Systems with Multiple Components. For example, IP 65001.A specifies that the inspector will verify that the licensee has approved implementing procedures that describe administrative controls, work processes, and inspection requirements; and will observe work activities to verify that the construction and installation work is being accomplished under controlled conditions and in conformance with design requirements. The inspection of the as-built characteristics will include verification of location, alignment, orientation, dimensions, and functionality. IP 65001.06 addresses installation of mechanical components, including installation requirements, removal of packing material, use of special tools, correct work procedures, and lifting and rigging. Also, IP 65001.07 addresses 9
No. Reference Comment Submission NRC Resolution installation of valves, including verification of Code nameplate requirements, check valve diversity, and orientation of valve and actuator. The licensee QA program and NRC QA inspections might overlap in some respects with, but cannot replace, the Installed Configuration ITAAC because the QA program and associated inspections do not verify all of the items to be addressed by the completion of those ITAAC. The NRC staff has established the ITAAC inspection process for the Vogtle Units 3 and 4 AP1000 nuclear power plant to include sample inspections to verify the completion of the Installed Configuration (or Functional Arrangement) ITAAC. Contrary to the NEI position, the NRC staff considers this ITAAC to be necessary to verify the installed configuration of the applicable components and systems, based on the NRC inspection procedures and guidance provided to NRC inspectors. However, the staff agrees with NEI that the Installed Configuration ITAAC should be modified to focus on the geometric installation features of the applicable components and systems. Therefore, the staff will revise SRP Section 14.3.3 to update the guidance for the preparation of the Installed Configuration ITAAC.
13 II.2.H - RTNSS, p. Existing guidance and practice makes clear that The NRC staff disagrees with the NEI 17 Tier 1 and ITAAC must cover the entirety of the recommendation to delete paragraph H on the SSCs within the scope of the certified design (an ITAAC for RTNSS equipment. SECY-90-016, essentially complete design), and that the level Evolutionary Light Water Reactor (LWR) of detail provided in Tier 1 is based on a graded Certification Issues and their Relationship to approach, including both safety-related and Current Regulatory Requirements; SECY-93-087, safety-significant SSCs. Thus RTNSS SSCs are Policy, Technical, and Licensing Issues Pertaining already considered and evaluated for inclusion to Evolutionary and Advanced Light-Water Reactor in Tier 1/ITAAC as appropriate, and it is (ALWR) Designs; SECY-94-084, Policy and 10
No. Reference Comment Submission NRC Resolution unnecessary and potentially confusing to add Technical Issues Associated with the Regulatory SRP guidance calling for ITAAC on equipment Treatment of Non-Safety Systems (RTNSS) in within the scope of the RTNSS program. Passive Plant Designs; and SECY 95-132, Policy and Technical Issues Associated with the Regulatory Treatment of Non Safety Systems (RTNSS) in Passive Plant Designs (SECY 084), discuss the Commission policy and technical issues associated with RTNSS equipment in new passive nuclear power plant designs. These Commission papers indicate that some new nuclear power plants have ALWR designs that use passive safety systems that rely on natural forces, such as density differences, gravity, and stored energy to supply safety injection water and to provide reactor core and containment cooling. The papers note that active systems in passive ALWR designs are categorized as non-safety systems with limited exceptions. Active systems in passive ALWR designs provide the first line of defense to reduce challenges to the passive systems in the event of a transient at the nuclear power plant.
Active systems that provide a defense-in-depth function in passive ALWR designs need not meet all of the acceptance criteria for safety-related systems. The Commission papers specify that there should be a high level of confidence that these active systems will be available and reliable when needed. Therefore, design certification applications should include ITAAC for RTNSS equipment consistent with the Commission policy for nuclear power plants with passive core cooling systems. With respect to the specific NEI comment, the staff has found that public meeting discussions of standardized ITAAC focus on safety-related SSCs whereas nonsafety-related 11
No. Reference Comment Submission NRC Resolution SSCs with high safety significance (such as RTNSS equipment) are often omitted during those discussions. To avoid confusion by applicants during the development of proposed ITAAC, the staff considers that SRP Section 14.3.3 should include guidance to provide assurance that design certification and COL applicants are aware that ITAAC need to address nonsafety-related SSCs with high safety significance in addition to ITAAC for safety-related SSCs.
14 II.2.I - DRAP, p.17 During discussions on development of The NRC has not adopted the position that DRAP standardized ITAAC, NRC concluded that DRAP ITAAC are not necessary. The content of this SRP ITAAC was not necessary in future design is consistent with current agency position, so the certifications and would not be included as a content will remain unchanged.
standard ITAAC. Agreement that DRAP should be addressed as a Tier 2 matter only was based in part on experience indicating that implementing DRAP ITAAC for AP1000 has provided little or no value. This SRP should be revised to reflect this conclusion.
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