ML19106A001
| ML19106A001 | |
| Person / Time | |
|---|---|
| Issue date: | 04/16/2019 |
| From: | Stewart Schneider Office of Nuclear Material Safety and Safeguards |
| To: | |
| Schneider, Stewart | |
| References | |
| 10 CFR part 50, NRC-2017-0151, RIN 3150-AK07 | |
| Download: ML19106A001 (17) | |
Text
Reactor Vessel Material Surveillance Program Requirements Rulemaking Status Public Meeting April 30, 2019 ADAMS Accession No. ML19106A001
Agenda
- Welcome/Introductions/Logistics
- Meeting Purpose
- Background
- Direct Final Rule Process
- Rulemaking Status
- Regulatory Considerations
- Schedule
- Public Questions and Discussion
- Closure April 30, 2019 Reactor Vessel Surveillance Program Requirements 2 Public Meeting
Announcements
- Category 3 Public Meeting
- Teleconference Number 1-888-560-6530 passcode: 7959565
- Webinar https://attendee.gotowebinar.com/register/6542737 797754813955
- If you are participating via phone, please send an email to Stewart.Schneider@nrc.gov confirming your attendance April 30, 2019 Reactor Vessel Surveillance Program Requirements Public Meeting
Meeting Purpose Provide information to the public on the status and scope of the rulemaking activity to revise Appendix H to 10 CFR Part 50 April 30, 2019 Reactor Vessel Surveillance Program Requirements 4 Public Meeting
Background
June 2017: NRC held a public meeting to discuss three rulemaking options and solicited public input (ML17173A081)
- Option A: Status Quo - No revision
- Option B: Retain ASTM E185-82 and limited revisions
- Eliminate inclusion and testing of certain specimens
- Maximize cost reduction
- Option C: Incorporate ASTM E185-16 & E2215-16 and extensive revisions
- Include Option B cost reductions
- Substantial number of conditions to remove requirements having limited benefit NRC recommended Option B and stakeholders agreed April 30, 2019 Reactor Vessel Surveillance Program Requirements 5 Public Meeting
Commission Communication
- COMSECY-18-0016 (August 2018, ML18057A000)
Requested Commission approval to:
- Publish the regulatory basis
- Use the direct final rule process to revise the testing and reporting requirements in Appendix H
- SRM-COMSECY-18-0016 (January 2019, ML19009A513)
- Commission approved regulatory basis publication and use of the direct final rule process
- Clarify the specific edition of ASTM E185 applicable to reactor vessels purchased after 1982 April 30, 2019 Reactor Vessel Surveillance Program Requirements 6 Public Meeting
Direct Final Rule Process
- Used for non-controversial regulatory amendments
- No significant technical or policy issues involved
- Issue direct final rule with a companion proposed rule
- Expedites the rulemaking process:
- Revised requirements become effective sooner
- Provides the benefits of the rule change sooner
- Minimizes the use of NRC resources
- Provides an opportunity for public comment on the rule
- No significant and adverse public comments anticipated April 30, 2019 Reactor Vessel Surveillance Program Requirements 7 Public Meeting
Effective Date Timeline April 30, 2019 Reactor Vessel Surveillance Program Requirements 8 Public Meeting
Rulemaking Status
- Regulatory Basis (RB) published on April 4, 2019
- Federal Register notice of availability (84 FR 12876)
- Federal Register notice of administrative correction
- 84 FR 14845; April 12, 2019
- ADAMS Accession No. ML19038A477
- Direct Final Rule underway to:
- Eliminate the requirements to test weld heat-affected zone specimens and examine thermal monitors
- Reduce the number of tensile specimens that require testing
- Specify that testing correlation monitor material is optional
- Increase the reporting period from one year to 18 months The direct final rule would continue to ensure adequate protection of public health and safety and the environment April 30, 2019 Reactor Vessel Surveillance Program Requirements 9 Public Meeting
Additional Regulatory Consideration (Commission-Directed)
- Surveillance Program Criteria (Section III.B.1)
- Clarify the specific edition of ASTM E 185 that applies to the design of surveillance programs and withdrawal schedules for reactor vessels purchased after 1982
- Basis
- Potential to misinterpret Appendix H as requiring the use of an ASTM standard not currently incorporated by reference
- Direct Final Rule provides an opportunity to clarify the requirement
- Resolution
- Revise Section III.B.1 to clarify that ASTM E185-82 must be used when designing a surveillance program for reactor vessels purchased after 1982
- Consistent with NRC practice April 30, 2019 Reactor Vessel Surveillance Program Requirements 10 Public Meeting
Other Regulatory Considerations
- Cumulative Effects of Regulation (CER)
- Recognizes the challenges that licensees face when implementing multiple complex regulatory positions, programs, or requirements within a limited implementation period and with available resources and technical expertise
- NRC staff does not anticipate any CER concerns because the Appendix H rulemaking would reduce the regulatory burden on reactor licensees for testing and reporting
- Backfitting and Issue Finality
- Proposed revisions would provide a non-mandatory relaxation
- Proposed revisions would be voluntary; licensees would not be required to eliminate or reduce certain tests nor extend the period to report results
- Therefore, Appendix H rulemaking would not constitute backfitting or violate issue finality April 30, 2019 Reactor Vessel Surveillance Program Requirements 11 Public Meeting
Rulemaking Schedule
- NRC staffs goal is to submit the direct final rule package to the Commission for review and approval by January 2020
- Direct Final Rule would become effective in late 2020 April 30, 2019 Reactor Vessel Surveillance Program Requirements 12 Public Meeting
Questions April 30, 2019 Reactor Vessel Surveillance Program Requirements 13 Public Meeting
Where to Find Information April 30, 2019 Reactor Vessel Surveillance Program Requirements 14 Public Meeting
How did we do?
- NRC Public Meeting Feedback Form April 30, 2019 Reactor Vessel Surveillance Program Requirements 13 Public Meeting
NRC Contacts Stewart Schneider Rulemaking Project Manger 301-415-4123 Stewart.Schneider@nrc.gov On Yee Technical Lead 301-415-1905 On.Yee@nrc.gov April 30, 2019 Reactor Vessel Surveillance Program Requirements 14 Public Meeting
Thank You April 30, 2019 Reactor Vessel Surveillance Program Requirements 15 Public Meeting