ML20338A553
| ML20338A553 | |
| Person / Time | |
|---|---|
| Site: | 99902028 |
| Issue date: | 12/11/2020 |
| From: | Leslie Fields Licensing Processes Branch |
| To: | Dennis Morey Licensing Processes Branch |
| Fields L, NRR/DORL/LLPB, 415-1186 | |
| Shared Package | |
| ML20342A144 | List: |
| References | |
| Download: ML20338A553 (5) | |
Text
December 11, 2020 MEMORANDUM TO:
Dennis C. Morey, Chief Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Leslie C. Fields, Senior Project Manager /RA/
Licensing Processes Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE SEPTEMBER 24, 2020, PUBLIC MEETING ON THE PROPOSED RULE TO CLARIFY REQUIREMENTS FOR OPERATIONAL LEAKAGE On September 24, 2020, the U.S. Nuclear Regulatory Commission (NRC) held a public meeting with representatives of the Nuclear Energy Institute (NEI) to discuss NRCs proposed rule to clarify requirements for operational leakage. The meeting topics related to operational leakage included: 1) license requirements, 2) NRC policy, 3) history of interactions between NRC, NEI, and American Society of Mechanical Engineers (ASME), and 5) rulemaking activities. Public information related to this meeting, including the meeting notice and presentation slides can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession Nos. ML20268A157, ML20267A541, and ML20267A486. A list of meeting attendees is enclosed.
This public meeting was requested by NEI to provide information based on NRCs public meeting previously held on August 21, 2020 (ADAMS Accession No. ML20265A083), regarding the proposed items to be included in the ASME Code Edition Update Rulemaking activity.
NEI presented its main concerns related to the new proposed operational leakage requirements from the NRC. Since the proposed condition is still in the NRCs preliminary review stage of the rulemaking activity, NRC staff could not discuss the exact language that will be available in the future proposed rule. However, with this limitation the NRC staff tried to address the concerns by providing the near 30-year history of the basis for proposed conditions to meet the structural integrity requirements of the original license, including the flexibility through various policy and guidance documents. The NRC staff explained that the proposed rule language would not change the current guidance, but only provide clarity and efficiency for both stakeholders and the NRC in addressing operational leakage.
CONTACT: Leslie Fields, NRR/DORL 301-415-1186
The NEI representatives gave multiple presentations that raised four main points: 1) current NEI 18-03, Operability Determination, is sufficient to address operational leakage; (2) the ASME Boiler and Pressure Vessel (BPV) Code does not pertain to operational leakage conditions during plant operation (but only during in service inspection (ISI) activities); (3) any condition referring to Risk-Informed Steering Committee-1 (RISC-1) or RISC-3 components as defined in Title 10 of the Code of Federal Regulations 50.69, Risk Informed Categorization of Structures, Systems and Components (10 CFR 50.69) might inadvertently revoke the risk-informed reduction in requirements for RISC-3 ASME Code Class 2 and 3 components allowed by 10 CFR 50.69; and (4) any condition related to operational leakage is a backfit.
The NRC staff provided some feedback on the issues presented. The NRC staff stated that it understands ASMEs position, specifically that ASME BPV Section XI requirements only apply to ASME Code required pressure tests. However, the NRC noted that the ASME position does not bound current NRC regulatory requirements, and with respect to the original license and NRC policy, the proposed requirements for licensees to address operational leakage will not be changed by the proposed rule language. Further, the NRC staff explained that in the proposed rule when operational leakage is identified, the requirement for RISC-3 classified systems, structures, and components in systems (required by technical specifications for operability) is to ensure structural integrity by performing a repair/replacement activity or alternative in accordance with 10 CFR 50.69. The NRC staff confirmed that the objective of the rule clarification is not to impose a backfit and the proposed language does not change longstanding policy and requirements. As such, no backfit is anticipated or intended. The NRC staff finished the discussion by recognizing the concerns raised and confirmed that through the rulemaking process, the NRC would consider the feedback from the public meeting to ensure the proposed rule language would not cause any unintended consequences or undermine the 10 CFR 50.69 regulations.
In response to the public meeting comments, the NRC staff will review the current proposed rule language to assure that unintended consequences will not occur as a result of the regulatory action. The NRC staff informed meeting attendees that the upcoming rule will be available for public comments in the future (usually a 75-day period) and the overall rulemaking process is expected to last 2 years.
Docket No. 99902028
SUMMARY
OF THE SEPTEMBER 24, 2020 PUBLIC MEETING PROPOSED RULE TO CLARIFY REQUIREMENTS FOR OPERATIONAL LEAKAGE ATTENDANCE SHEET Name Organization Email Leslie Fields NRC leslie.fields@nrc.gov Jay Collins NRC jay.collins@nrc.gov Matthew Mitchell NRC matthew.mitchell@nrc.gov Anna Bradford NRC anna.bradford@nrc.gov Keith Hoffman NRC keith.hoffman@nrc.gov David Rudland NRC david.rudland@nrc.gov Thomas Scarbrough NRC thomas.scarbrough@nrc.gov Victoria Huckabay NRC victoria.huckabay@nrc.gov Caroline Tilton NRC caroline.tilton@nrc.gov Eric Reichelt NRC eric.reichelt@nrc.gov Stephen Cumblidge NRC stephen.cumblidge@nrc.gov Michael Benson NRC michael.benson@nrc.gov Bob Caldwell NRC bob.caldwell@nrc.gov Robert Taylor NRC robert.taylor@nrc.gov Allen Hiser NRC allen.hiser@nrc.gov Sheldon Clark NRC sheldon.clark@nrc.gov Ali Rezai NRC ali.rezai@nrc.gov John Honcharik NRC john.honcharik@nrc.gov Roger Kalikian NRC roger.kalikian@nrc.gov Robert Davis NRC robert.davis@nrc.gov Tom Basso NEI tbb@nei.org Tim Riti NEI txr@nei.org Jerry Bonanno NEI jxb@nei.org James Slider NEI jes@nei.org John Sullivan TVA jhsullivan@tva.gov
2
SUMMARY
OF THE SEPTEMBER 24, 2020 PUBLIC MEETING PROPOSED RULE TO CLARIFY REQUIREMENTS FOR OPERATIONAL LEAKAGE ATTENDANCE SHEET Name Organization Email Adam Keyser TVA aekeyser@tva.gov Deann Raleigh Curtiss-Wright draleigh@curtisswright.com Dan Lamond True North Consulting dlamond@tnorthconsulting.com Cheryl Gayheart Southern Co cgayhear@southernco.com Martin Murphy Xcel Energy marty.murphy@xcelenergy.com Richard Deopere Xcel Energy richard.a.deopere@xcelenergy.com Shannon Rafferty-Czincila Exelon shannon.rafferty-czincila@exeloncorp.com Roy Linthicum Exelon roy.linthicum@exeloncorp.com Mark E. Weis Exelon mark.weis@exeloncorp.com Brendan Casey Exelon brendan.casey@exeloncorp.com
Package: ML20342A144 Notice: ML20268A157 Summary: ML20338A553 NRC Presentation: ML20267A486 NEI Presentation: ML20267A541 NRC-001 OFFICE NRR/DORL/LLPB/PM NRR/DORL/LLPB/LA NRR/DNRL/NPHP NRR/DORL/LLPB/BC NAME LFields DHarrison MMitchell DMorey DATE 12/8/2020 12/8/2020 12/11/2020 12/11/2020