ML19064B404

Summary of Meeting Between the NRC Staff and the Nuclear Energy Institute Regarding Nei'S Perspective of ASME Code Compliance and Operability Determinations

ML19064B404
Person / Time
Site:	99902028
Issue date:	03/13/2019
From:	Lynnea Wilkins NRC/NRR/DLP/PLPB
To:	Dennis Morey Division of Licensing Projects
Wilkins L, NRR/DLP, 415-1377
Shared Package
ML19043A746 -Pkg.	List: ML19064B403 ML19064B404 ML19064B405
References
Download: ML19064B404 (3)

Text

March 13, 2019 MEMORANDUM TO: Dennis C. Morey, Chief Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation FROM: Lynnea Wilkins, Project Manager /RA/

Licensing Processes Branch Division of Licensing Projects Office of Nuclear Reactor Regulation

SUMMARY

OF FEBRUARY 15, 2019, MEETING TO DISCUSS NEI's PERSPECTIVE OF ASME CODE COMPLIANCE AND OPERABILITY DETERMINATIONS On February 15, 2019, the U.S. Nuclear Regulatory Commission (NRC) staff held a Category 2 meeting with representatives from the Nuclear Energy Institute (NEI) and industry. The purpose of the meeting was for NEI to present its perspective regarding ASME code compliance and operability determinations. All information related to this meeting and discussed in this summary can be found in the ADAMS package under Accession No. ML19043A746.

The NRC opened the meeting by reiterating that the NRC is not formally reviewing or endorsing NEI 18-03, Operability Determination, but rather using it as a tool to become more efficient, effective and clear while internally discussing possible revisions to IMC 0326, Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety. The goal is to find alignment and understanding on how utilities will address operability determinations if they adopt NEI 18-03 and how NRC inspectors will review those operability determinations based on the guidance contained in IMC 0326.

NEIs presentation (ADAMS Accession No. ML19045A489) can be summarized as the following principles:

• Determination of Operability is separate from Code Compliance,

• Any technically acceptable method can be used to determine is a specified safety function can be performed (alternative methods),

• Licensed Operator decision - NRC approval not required if technically defensible method is used to determine Operability, and

• Restoration of compliance falls under the Corrective Action Program and may require NRC approval.

D. Morey NEIs presentation stated those 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, and

• A.10 Flaw Evaluation.

Following NEIs presentation, the NRC staff and industry engaged in clarification discussions.

The following actions were identified during these discussions:

1) NRC staff will review the sections listed above in NEI 18-03, Operability Determination to determine whether any changes to IMC 0326 are warranted;

2) NRC requested NEI to identify areas where code interjects operability or regulations; and

3) NRC requested NEI to include case examples with deficient conditions and impact.

NRC will provide its complete feedback during the April 2019 public meeting. NRC and NEI also discussed holding joint tabletop discussions to walk through specific examples.

A member of the public submitted comments which can be found in ADAMS Accession No ML19064B403.

CONTACT: Lynnea Wilkins, NRR/DLP 301-415-1377 Docket No.: 99902028

Summary: ML19064B404; Package: ML19043A746

• concurred via email NRC-001 OFFICE DLP/PLPB/PM* R-III/DRS* DSS/DD* DLP/PLPB/PM DLP/PLPB/PM NAME LWilkins KO'Brien JMarshall DMorey LWilkins DATE 03/07/19 03/06/2019 03/06/2019 3/11/2019 3/13/2019