ML19045A489
| ML19045A489 | |
| Person / Time | |
|---|---|
| Site: | Nuclear Energy Institute |
| Issue date: | 02/14/2019 |
| From: | Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| Wilkins L, NRR/DLP, 415-1377 | |
| References | |
| Download: ML19045A489 (10) | |
Text
©2018 Nuclear Energy Institute Relationship between Code Compliance and Operability Operability Determination February 15, 2019
©2018 Nuclear Energy Institute 2 Six areas identified to gain efficiency and predictability in the Operability Determination process Establishing that operability is the responsibility of the licensee Defining entry criteria Separating operability determination from CAP Aligning on definitions of terms, such as specified safety function Eliminating aspects not specifically tied to operability Ensuring the Operability Determination process is separate from Code compliance determinations Overview
©2018 Nuclear Energy Institute 3 Ensuring the Operability Determination process is separate from Code compliance determinations Determination of operability is separate from Code compliance Any technically acceptable method can be used to determine if a specified safety function can be met (alternate methods)
Licensed operator decision - NRC approval not required if technically defensible method used to determine operability Restoration of compliance falls under the Corrective Action Program and may require NRC approval NEI 18-03 Principles
©2018 Nuclear Energy Institute 4 These principles were used in the following sections.
A.5 Piping and Piping Support Requirements A.6 Structural Requirements A.7 Technical Specification Operability vs. ASME OM Code Criteria A.10 Flaw Evaluation NEI 18-03
©2018 Nuclear Energy Institute 5 A.5 Piping and Piping Support Requirements Provides helpful references consistent with IMC-0326 Operability is based on ability to perform the specified safety function Operability is the licensees determination NEI 18-03
©2018 Nuclear Energy Institute 6 A.6 Structural Requirements Provides references consistent with IMC-0326
These items may be helpful in the operability determination Operability is based on ability to perform the specified safety function Operability is the licensees determination NEI 18-03
©2018 Nuclear Energy Institute 7 A.7 Technical Specification Operability vs. ASME OM Code Criteria Made the distinction between operability and compliance with ASME OM Code.
Referenced section 4, Operability Determination Process when in-service testing (IST) performance data falls outside of the required action range.
Need to address TS SRs that rely on IST versus safety analysis as the acceptance criteria NEI 18-03
©2018 Nuclear Energy Institute 8 A.10 Flaw Evaluation Reinforced when ASME Code Class 1, 2, or 3 components do not meet ASME or construction Code acceptance standards, operability should be assessed
Emphasized the importance of ASME Code Class 1 pressure boundary components and impact on operability based on safety significance Operational leakage in ASME Class 1, 2, or 3 components are assessed as deficient conditions
TS limits typically exist for RCS leakage Operability is the licensees determination
Restoration of code compliance is addressed through the corrective action program NEI 18-03
©2018 Nuclear Energy Institute 9 The Operability Determination process is separate from Code compliance determinations
Determination of operability is separate from Code compliance
Any technically acceptable method can be used to determine if a specified safety function can be met (alternate methods)
Licensed operator decision - NRC approval not required if technically defensible method used to determine operability
Restoration of compliance falls under the Corrective Action Program and may require NRC approval Summary
©2018 Nuclear Energy Institute 10
- NRC feedback on Code Compliance/Operability
April 3rd at Region II HQ
- Align on plan going forward in preparations for final meeting targeted in June
NEI-18-03 comment resolution
IMC-0326 changes Next Steps