ML18178A585
| ML18178A585 | |
| Person / Time | |
|---|---|
| Issue date: | 06/26/2018 |
| From: | Joseph Holonich NRC/NRR/DLP/PLPB |
| To: | |
| Holonich J, NRR/DLP, 415-7297 | |
| References | |
| Download: ML18178A585 (7) | |
Text
Comparison of IMC 0326 (11/20/17) and NEI 18-03. Rev. F To aid in comparison, IMC sections in the first column have been highlighted in bold where:
the content has not been transferred in any form or the application of the IMC 0326 content has been significantly altered.
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments 326-01 Purpose N/A N/A Not contained in NEI 18-03.
The first three paragraphs describe IMC 0326 usage as an aid to the inspector.
326-01 Purpose 1 Introduction Transferred to NEI 18-03.
Fourth paragraph beginning with:
The licensees immediate and Last paragraph repeats the primary concern should be safe language of IMC 0326.
operation of the plant.
02.01 Scope of SSCs for Operability 2.1 Scope of SSCs for Operability Transferred to 18-03.
Determinations. Scope of Operability is provided in words rather than bulleted fashion.
02.02 Scope of SSCs for Functionality N/A N/A NEI 18-03 does not address Functionality.
03.01 Definition of Current Licensing 3.4 Licensing Basis Transferred to NEI 18-03.
Basis IMC 0326 definition is retained.
03.02 Definition of Defect (related to N/A N/A Not contained in NEI 18-03.
ASME Code compliance) Operability is distinct from ASME-code compliance.
(See Appendices C-12 and C.13 below.)
03.03 Definition of Degraded Condition 3.2 Deficient SSC Condition Not contained in NEI 18-03.
NEI 18-03 uses Three Required Treatment of ODP entry Criteria to define a subset of conditions differs from IMC Deficient Conditions for ODP entry. 0326.
1 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments 03.04 Definition of Design Basis 3.3 Design Bases Transferred to NEI 18-03.
Definition is retained and expanded Citation to Regulatory slightly, Guide 1.186 is also retained.
03.05 Definition of Flaw (related to ASME N/A N/A Not contained in NEI 18-03.
Code compliance) (See Definition 3.02 above.)
03.06 Definition of Fully Qualified N/A N/A Treatment of ODP entry conditions differs from IMC 0326.
03.07 Definition of Functional- N/A N/A NEI 18-03 does not Functionality address Functionality.
03.08, 09, Definitions of: N/A N/A Not contained in NEI 18-03.
10 High Energy Systems (See Definition 3.02 above Moderate Energy Systems and Appendices C.12 and NDE Indication C.13 below.)
03.11 Definition of Nonconforming 3.2 Deficient SSC Condition Not contained in NEI 18-03.
Condition NEI 18-03 uses Three Required Treatment of ODP entry Criteria to define a subset of conditions differs from IMC Deficient Conditions for ODP 0326.
entry.
03.12 Operability Declaration 1 and 4 Introduction Transferred to NEI 18-03.
Operability Determination Process First paragraphs of section 1 and section.4 03.13 Operable-Operability 3.7 Operable-Operability NEI 18-03 references the Standard Technical Specifications definition.
2 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments 03.13 Operable-Operability N/A N/A Not transferred to NEI 18-Last paragraph that contains: 03. NEI 18-03 is oriented In order to be considered operable, around the TS definition of an SSC must be capable of Operable.
performing the specified safety functions of its design:
03.14 Reasonable Expectation 3.10 Reasonable Expectation of Transferred to NEI 18-03.
Operability Contrasted with IMC Definition is repeated. A Presumption of Operability sentence relating Reasonable since that concept is Expectation to Presumption of closely linked to the ODP Operability has been added. entry criteria described in NEI 18-03.
03.15 Specified Function/Specified Safety 3.8 Specified Function/Specified Safety A new definition of Function Function specified safety function is A revised definition is included. provided. Expanded background information is provided in Appendix B.
0326-04 Operability Determination Process N/A N/A Largely inspector guidance.
First paragraph 04.01 Review Activities 4.1 Three Required Entry Criteria Less detail is provided First paragraph repeats regarding the potential continuous process. sources of information 04.02 Assessing Potential Degraded or 4.1 Three Required Entry Criteria The concept of TRC has Nonconforming Conditions Entry into the Operability replaced potential Determination Process is described degraded and/or as meeting the Three Required nonconforming conditions.
Criteria.
04.03 Presumption of Operability 3.9, 4.1 Presumption of Operability The wording has been A more concise definition is altered but the concepts provided in section 3.9 and a application is the same.
practical test is described in section TRC are utilized as a more 4.1. (See third paragraph.) objective standard.
3 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments 04.04 Scope of Operability 4.3.1 Sufficiency of Operability Use of Compensatory Determinations Determination Measures is included along This section generally repeats the with a pointer to the use of IMC information. a graded approach.
04.05 Circumstances Warranting 4.1 Three Required Entry Criteria The concept of TRC has Operability Determinations Entry into the Operability replaced potential Determination Process is described degraded and/or as involving Three Required nonconforming conditions.
Criteria.
04.06.01 Timing of Operability 4.2.1, 4.2.2 Immediate and Prompt Guidance is transferred to 04.06.02 Determinations Determination of Operability NEI 18-03.
04.07 Documentation 4.2 Documentation of Operability Guidance regarding the use Determinations of a checked box is expanded along with the application of a graded approach.
04.08 Operator Awareness and 4.0, Various sections No change in intent, but the Responsibilities 4.1,4.2.1, sections title has been 4.2.2,4.3.2 eliminated.
05.01, Functional, Nonfunctional N/A N/A NEI 18-03 does not 05.02 address Functionality.
06.01 Inoperable 5.1.1 SSC Inoperable Generally consistent.
06.02 Operable but Degraded or 5.1.2 SSC Operable Background information nonconforming and information regarding other regulations was not transferred.
06.03 Operability is Separate from Appendix Relationship Between Operability Information transferred to Corrective Action to Restore Full C.1 and the Corrective Action Program NEI 18-03.
Qualification 4 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments 06.04 Enforcement Discretion N/A N/A NEI 18-03 is not an instructional source of information on enforcement discretion. Information is not transferred to NEI 18-03.
07.01 The Current Licensing Basis and N/A N/A NEI 18-03 is not an 10 CFR Part 50, Appendix B instructional source of information on CLB and Appendix B. Corrective Action Program background information is not transferred to NEI 18-03.
07.02 Timing of Corrective Actions Appendix Timing of Corrective Actions Information is transferred to C.2 NEI 18-03. The main body of NEI 18-03 does not address Corrective Actions.
07.03 Compensatory Measures 3.1,4.2, Various Section titles. NEI 18-03 provides 4.3.1, They all provide consistent guidance consistent with Appendix guidance regarding the use of IMC 0326.
A.3 Compensatory Measures.
07.04 Final Corrective Action Appendices Final Corrective Action Information is transferred to 07.04.01 C.3, 4, and Change to Facility or NEI 18-03. The main body 07.04.02 5 Procedures in Lieu of of NEI 18-03 does not Restoration address Corrective Actions.
Acceptance of an As-Found Condition Appendix Operability During Technical A.8 Operability During Technical Selected information A.01 Specification Surveillances Specification Surveillances transferred to NEI 18-03.
Appendix System Configuration During A.8 Operability During Technical Selected information A.02 Surveillance and Operability Specification Surveillances transferred to NEI 18-03.
Testing 5 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments Appendix Missed Technical Specification N/A N/A Information was not A.03 Surveillance transferred to NEI 18-03.
Missed surveillances are not relevant to operability determinations Appendices Maintenance N/A N/A Information was not B.01, B.02, transferred to NEI 18-03.
B.03. B.04 (See immediately below.)
Appendix Reduced Reliability as a Degraded A.9 Reduced Reliability The concept has been B.04 or Nonconforming Condition 4.1 transferred to NEI 18-03.
The TRC incorporates reduced reliability.
Appendices Relationship Between the N/A N/A Information was not C.01, C.02, General Design Criteria (GDC) transferred to NEI 18-03.
and the Technical Specifications Single Failures Appendices Treatment of Consequential A.1, A.2 Consequential Failures in IMC 0326 Appendices were C.3, C.4 Failures in Operability Operability Determinations transferred to NEI 18-03.
Determinations Use of Alternative Analytical Use of Alternative Analytical Methods to Determine Methods in Operability Operability Determinations Appendix Use of Temporary Manual Action in A.3 Compensatory Actions Guidance has been C.05 Place of Automatic Action in integrated to Appendix A.3 Support of Operability Appendix Use of Probabilistic Risk A.4 Consideration of Probability and Transferred to NEI 18-03 C.06 Assessment in Operability Risk in Operability Determinations with minor changes Decisions discussing technical rigor.
Appendix Use of Seismic Margin Assessment N/A N/A Not contained in NEI 18-03.
C.07 in Operability Decisions Appendix Environmental Qualification N/A N/A Not directly contained in C.08 NEI 18-03.
6 6/26/2018
IMC 0326 NEI 18-03 Section Description/Words Section Description/Words Comments Appendix Technical Specification Operability A.7 Technical Specification Operability NEI 18-03 addresses C.09 vs. ASME OM Code Criteria vs. ASME Code Criteria relationship but is not consistent with IMC 0326.
Appendix Support System Operability A.11 Support System Operability Transferred to NEI 18-03.
C.10 3.6 Necessary Support Function Definition 3.6, Necessary Support Function, was added.
Appendix Piping and Pipe Support A.5 Piping and Pipe Support Citations of Regulatory C.11 Requirements Requirements Guide 1.199, ACI-349, and SQUG GIP-2 were transferred.
Appendix Piping and Pipe Support A.5 Piping and Pipe Support Guidance that links prior C.11 Requirements Requirements NRC approval to Operability was not transferred.
Appendices Flaw Evaluation A.10 Flaw Evaluation Guidance that links prior C-12 and C- Operational Leakage from ASME Class 1 boundaries are NRC approval and/or 10 13 ASME Code Class 1, 2, and 3 assessed as providing a required CFR 50.55a compliance to Components and necessary support function for Operability was not various ECCS systems. Code transferred.
Class 1 compliance is the acceptance criteria.
Appendix C- Structural Requirements A.6 Structural Requirements Transferred to NEI 18-03.
14 7 6/26/2018