ML20196G436
| ML20196G436 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1998 |
| From: | Stewart Magruder NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| PROJECT-689 NUDOCS 9812080008 | |
| Download: ML20196G436 (16) | |
Text
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g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20$65-0001 o
November 23, 1998 MEMORANDUM TO: Thomas H. Essig, Acting Chief Generic Issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation FROM:
Stewart L. Magruder, Project Manager Jwd 6 N d f
Generic issues and Environmental Projects Branch i
Division of Reactor Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF OCTOBER 8,1998, MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) REGARDING RISK-INFORMED INSERVICE INSPECTION On October 8,1998, representatives of the Nuclear Energy Institute (NEI) met with reprasentatives of the Nuclear Regulatory Commission (NRC) at the NRC's offices in Rockville, Maryland. Attachment 1 provides a list of meeting attendees.
The purpose of the meeting was to discuss issues related to risk-informed inservice inspection.
Risk-informed inservice inspection (RI-ISI) programs categorize components and apply ISI requirements in a manner commensurate with that risk categorization. Industry pilot activity in the RI-ISI area focuses on the use of two RI-ISI methodologies, one developed by the i
Westinghouse Owners Group (WOG) and the other developed by the Electric Power Research Institute (EPRI). The WOG methodology is contained in WCAP-14572; the EPRI methodology is detailed in EPRl/TR-106706. ASME Code Cases (N-560, N-577, and N-578) incorporating the insights of the pilot activity, but not directly referencing the EPRI or WOG methodologies, are also under development.
On August 27,1998, NEl sent a letter to the staff responding to staff's proposal for the use of the " acceptable alternative" provision of 10 CFR 50.55a(a)(3) to implement RI-ISI upon approval of the WOG and EPRI topicals. This meeting was a followup to that letter. provides the meeting agenda proposed by the staff.
The staff opened the meeting by stating that their goals for the meeting were to (1) review the status of the industry submittals, (2) discuss the content of licensee submittals after the pilots
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The staff noted that, except for ANO-1, all the pilots will be finished by the end of this year. The review of the WOG topical should also be finished by the end of this year. The ANO-1 pilot and the EPRI topical review are scheduled to be completed within the next year. The EPRI J,,
U representative stated that responses to staff RAls will be submitted by the end of October 1998 'D V and a revision to the EPRI topical will be submitted by the end of January 1999.
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T. Essig The NEl representatives next briefly summarized their proposals from the August 27th letter regarding implementing RI-ISI. A representative from the NRC's Office of the General Counsel stated that the NRC would need an application from each licensee and that each licensee would need an approval letter from the staff before they could implement the program. This lead to a group consensus about the need to make the topical reports detailed enough to allow the NRC staff to understand how the methodology could be applied. The staff noted that the higher the quality of the topicals, the easier the staff review of individual applications will be. In response, the WOG and EPRI representatives stated that their topicals will contain guidance on what information licensees will need to submit to the staff if they reference one of the reports.
The group next discussed the ASME Code Case approach. The staff noted that the Code Cases would have to be endorsed by the NRC and incorporated into 10 CFR 50.55a before licensees could reference them. Ultimately. if the staff does this, licensees would not be required to submit anything to the staff before implementing a RI-ISI program. If the staff endorses the Code Cases via Regulatory Guide (RG)1.147, licensees may reference them but would still have to reference a topical report. Based on the ASME schedule of revising the Code Cases by the end of 1999, the staff expects to endorse the Code Cases in RG 1.147 by September 2000.
A representative of ASME next gave a presentation on ASME efforts regarding RI-ISI. A copy of his presentation materials are included as Attachment 3. He noted that ASME is moving forward with the Code Cases in response to interest from many parties outside the U.S. and that widespread international usage is expected. The ASME representative stated that ASME plans to revise Code Cases N-560, N-577, and N-578 by the end of 1999 to incorporate lessons learned from the review of the pilot submittals ar.d topical reports. However, ASME will not reference topical reports in the Code Cases and will not provide the same level of detail as is contained in the topical reports.
The NRC next discussed a proposed Information Notice that, if issued, would discuss a process that licensees could follo'n to request a 2 year delay in the start of the next 10 year ISI interval imposed by ASME Code Section XI. The staff noted that the intent is to allow plants that intend to pursue RI-ISI time to shift their programs. After a short discussion, the industry consensus at the meeting was that several plants would probably take advantage of this opportunity and that it would be possible to fit all the required inspections in the remaining 8 years of the 10 year window.
The industry asked about the status of Regulatory Guide 1.178, "An Approach for Plant Specific, Risk-Informed Decision Making: Inservice inspection of Piping," and Standard Review Plan Section 3.9.8," Review of Risk-informed Inservice Inspection of Piping." The staff stated that each will be issued for trial use soon. The staff also stated that these documents will not become impediments to the process.
The staff and the industry next discussed, and agreed on, a list of items that will be included in submittals that reference the WOG methodology and the list of retrievable onsite documentation g
for potential NRC audits of licensees that seek to utilize the RI-ISI methodology l
l T. _ Essig l l
for their ISI program for piping. The staffs expectation is that the submittals will be brief (6-10 pages) and that additional details well be available as retrievable onsite documentation for potential NRC audits. The agreed on list is provided as Attachment 4. The NEl and EPRI representatives agreed to develop a short guidance document for licensees considering i
referencing one of the topical reports based on this list.
Project No., 689 Attachments: As stated cc w/att: See next page i
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DISTRIBUTION: See attached page A /
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cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy institute Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Alex Marion, Director Mr. Charles B. Brinkman, Director i
Programs Washington Operations
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Nuclear Energy Institute ABB-Combustion Engineering, Inc.
i Suite 400 12300 Twinbrook Parkway, Suite 330 1776 i Street, NW Rockville, Maryland 20852 Washington, DC 20006-3708 Mr. David Modeen, Director Mr. Robert R. Campbell, President Engineering Nuclear HVAC Utilities Group Nuclear Energy Institute Tennessee Valley Authority Suite 400 1101 Market Street, LP4J-C 1776 i Street, NW Chattanooga, TN 37402-2801 Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Mr. Dennis Adams Licensing Nuclear HVAC Utilities Group Nuclear Energy Institute Comed j
Suite 400 1400 Opus Place 1776 l Street, NW Downers Grove, IL 60515 Washington, DC 20006-3708 Mr. Nicholac J. Liparuto, Manager Nuclear Safety and Regulatory Activ' ties Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. Jim Davis, Director Operations Nuclear Energy Institute Suite 400 1776 i Street, NW l
Washington, DC 20006-3708 l
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e NEl/NRC MEETING ON RISK-INFORMED ISI 10/8/98 List of Attendees Name Oraanization Mark Pyne Duke Energy Theresa Sutter Bechtel Stanley Levinson Framatome Technology Tim Abney TVA-Browns Ferry
. Christopher Smith -
NUSIS Dennis Weakland WOG/Duquesne Light Stephen Dinsmore NRC/NRR Syed Ali NRC/NRR Jack Strosnider NRC/NRR Scott Newberry NRC/NRR Gus Lainas NRC/NRR Richard Barrett NRC/NRR Geary Mizuno NRC/OGC Tony Pietrangelo NEl Biff Bradley NEl Jeff Mitman EPRI Dick Wessman NRC/NRR Ken Balkey Westinghouse Goutam Bagchi NRC/NRR Raymond West ASME/ Northeast Utilitites Jack Guttmann NRC/RES Debbie Jackson NRC/RES Michael Markley NRC/ACRS
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Nancy Closky Westinghouse Robin Graybeal Enertech i
L.J. Victory Jr.
Enertech Alex McNeill Virginia Power Patrick O'Regan Duke Engineering & Services Mark Cunningham -
NRC/RES Jocelyn Mitchell NRC/EDO Stu Magruder NRC/NRR i
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4 AGENDA FOR OCT 8.1998 MEETING WITH NEl/ INDUSTRY ON RISK-INFORMED INSERVICE INSPECTION l
1.
NEl/ INDUSTRY PLANS FOR RI-ISI SUBMITTALS l
2.
STATUS OF EPRI TOPICAL REPORT i
3.
COORDINATION BETWEEN ASME AND INDUSTRY TO REVISE CODE CASES l
4.
INDUSTRY SUGGESTED CONTENTS OF RI-ISI SUBMITTALS BASED ON WOG METHODOLOGY 5.
NRC'S SCHEDULE OF REVIEW OF CURRENT RI-ISI SUBMITTALS NRC'S LONG-RANGE PLAN FOR REVIEW OF RI-ISI SUBMITTALS 6.
7.
INFORMATION NOTICE ON EXEMPTION TO DELAY IMPLEMENTATION OF NEXT 10-YEAR ISI PROGRAM BY TWO YEARS 8.
NRC SUGGESTED CONTENTS OF RI-ISI SUBMITTALS BASED i
ON WOG METHODOLOGY 9.
CONCLUSIONS / ADJOURNMENT i
FILE MTGOCT8.98 1
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ASME EFFORTS REGARDING RISK-INFORMED INSERVICE INSPECTION (RI-ISI) OF PIPING Code Case Revision Update anc High L
Priority Support for Industry Implementation October 8,1998 Meeting With XR!O@
- ,G, pce; PresentedBy k) h N
y Raymond A. West
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RI-ISI ASME Code Case Status
+ CASE N-560, Alternative Examination Requirements for Class 1, Category B-J Piping Welds, (PublishedandSupported.By EPRI Topical Report - Pilot Plant Vermont Yankee)
+ CASE N-560-1, Alternative Examination Requirements for Class 1, Category B-J Piping Welds, (Now Outfor Board On Nuclear Codes & Standards (BNCS) Ballot Includes Methods A & Bfor Limited Scope Applications Supported By EPRI and WOG Topical Reports)
+ CASE N-577, Risk-Informed Requirements for Classdy2 andkqh 3 Piping, Method A, (PublishedandSupportedBy WOG [$
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Report - Pilot Plant Suny Unit 1) y ;m -
CASE N-578, Risk-Informed Requirements for Clqss 1,'2,4nd j
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3 Piping, Method B, (Published and SupportedBy EPRI Tofical i
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Report - Pilot Plant ANO-2)
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Proposed Revision Content Of Code Cases
+ Eaca Code Case Listed on the Previous Slide Will Be Revised to Include Lessons Learned From the Pilot Plants and Cpdates Made to the Topica Reports
+ The Code Case Revisions Will Most Likely Never Be As Prescriptive As the Indu eesna
. 9 p" Topical Reports or The Conditions og
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Conjectural ASME Schedule For Code Case Revisions
+ Monta 0 Action = Drafts and Support Docionents to Working Group (WG),
Subgroup (SG), and Subconunittee (SC) a Month Before Meeting (April 17,1999).
+ Month 1.0 Action = WG Meeting: Approves Proposals; SG, SC Both Vote.
+
Mont:a ~.5 Action = 2 Weeks After Meeting, SG and SC Negatives (IfAiry g
ReceivedandDistributed.
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+ Mont:a 2.0 Sev.
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,7-i Action = Responses Developed: Proposals, Support Docu}
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and SC Negatives. Responses to SC Negatives All Go to Maili[
- l Conunittee (MC) Secretary For MC Pre-Meeting Ballot and BNCS
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r Conjectural ASME Schedule For Code Case Revisions - Cont.
+ Month 3.0 Action = MC Negatives and Comments, BNCS Objections and Conunents Go to SC Secretaryfor Distribution Back to WG.
+ Month 3.75 Action = Responses DevelopedFor Pre-Meeting MC Ballot Negatives and Conunents, BNCS Objections and Conunents. MC Negatives and Conunents Reviewed With Negative Balloters Before MC Meeting.
+ Month 4.0 yy?gg Action = ProposalPresentedat MCfor Reaffirmation, Voi dif ote. y h; yvd
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+ Month 4.5 t.
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Action = MC Vote Final,2 Weeks.
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Conjectural ASME Schedule For Code Case Revisions - Cont.
+ Month 5.5 Action = BNCS Reviews For ProceduralDiscrepancies, Releases For Announcement in Mechanical Engineering Magazine, and Publication.
SPECIAL NOTE: From Owen F. Hedden (Chairman OfASME Section XI)
With the new process, with its written ballots, there has to be a lot of concentrated effort to prepare and redistribute the responses to those ballots. We (SCXI) have not done very well on that so far. Note the rush before the MC meeting at Month 3.75, when we have toPy ^~ %^^h document replies to MC and SC as well as BNCS. It will bebryEs'f to get pushed into another review cycle. But the process is[d$f[get in [
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stone. I think we can meet the schedule.
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s ASNIE Standard Efforts To l'
Support PRA Quality For RI-ISI
+ The ASME Standarc For Risk Assessment For Nuclear Power Plant Applications Is Presently L nder Development.
+ This Standard Will Provide the Peer / Review Requirements Necessary to Determine the Quality of the PRA for RI-ISI.
ys;r w p g Industry Approaches L sed Now to /$"Cf/
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+
Determine PRA Quality Should Be RsEdcd,,,)
y E ntil The Standard Is Available.
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Summary
+ ASME Codes & Standards Is Put:ing The Highest Priority Possible On the Activities Neec ed To Support the L se of Risk-Informed Applications
+ Active Redesign of":he ASME Approval Process Is Being L sed To the Maximum Extent Possible, But In No Case Will,flf6*
i Qua:ity Of Codes & Standards Be dd,,,f f, Compromised by a Schedule
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REQUIRED DOCUMENTATION Submittal Contents (1) justification for statement that PRA is of sufficient quality l
l (2). summary of risk impact l.
(3) current inspection Code (4) impact on previous relief requests
~(5) revised FSAR pages impacted by the change (6) process followed (WCAP, Code Case, and exceptions to methodology, if any)
(7) summary of results of each step (e.g., number of segments, number of HSS and LSS l
l segments, number of locations to be inspected, etc.)
)
l (8) a statement that RG principles are met (or any exceptions) i (9) summary of changes from current ISI program j
(10) summary of any augmented inspections that would be impacted Retrievable Onsite Documentation for Potential NRC Audit (1) scope definition
- (2) segment definition l
(3) failure probability assessment (4) consequence evaluation i
(5)
PRA model runs for the RI-ISI program l
L (6) ' risk evaluation (7). structural element /NDE selection (8) change in risk calculation (9)
PRA quality review (10) continual assessment forms as program changes in response to inspection results (11) documentation required by ASME Code (including inspection personnel qualification,-
inspection results, and flaw evaluations) i l
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