ML21327A420

Comment (8) of Mark A. Richter on Acceptability of ASME Section XI, Division 2, 'Requirements for Reliability and Integrity Management (Rim) Programs for Nuclear Power Plants,' for Non-Light Water Reactors

ML21327A420
Person / Time
Site:	Nuclear Energy Institute
Issue date:	11/15/2021
From:	Richter M Nuclear Energy Institute
To:	Office of Administration
References
86FR54253 00008, DG-1383, NRC-2021-0166
Download: ML21327A420 (4)

Text

11/23/21, 12:21 PM blob:https://www.fdms.gov/bd7ef4cc-6d18-46df-af30-192350041ea3 SUNI Review Complete As of: 11/23/21 12:21 PM Template=ADM-013 Received: November 15, 2021 PUBLIC SUBMISSION E-RIDS=ADM-03 Status: Pending_Post ADD: Robert Roche- Tracking No. kw1-21l4-q3ye Rivera, Bridget Curran, Mary Neely Comments Due: November 15, 2021 Comment (8) Submission Type: Web Publication Date:

9/30/2021 Docket: NRC-2021-0166 Citation: 86 FR 54253 Acceptability of ASME Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants, for Non-Light Water Reactors Comment On: NRC-2021-0166-0001 Acceptability of ASME Code Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants, for Non-Light Water Reactors Document: NRC-2021-0166-DRAFT-0011 Comment on FR Doc # 2021-21295 Submitter Information Email: atb@nei.org Organization: Nuclear Energy Institute General Comment See attached file(s)

Attachments 11-15-21_NRC_Comments on DG-1383 blob:https://www.fdms.gov/bd7ef4cc-6d18-46df-af30-192350041ea3 1/1

MARK A. RICHTER, PH.D.

Technical Advisor, Decommissioning & Used Fuel 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8106 mar@nei.org nei.org November 15, 2021 Office of Administration ATTN: Program Management, Announcements and Editing Staff Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments on Draft Regulatory Guide (DG), DG-1383, Acceptability of ASME Code Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants, for Non-Light Water Reactors [Docket ID NRC-2021-0166]

Project Number: 689 Submitted via Regulations.gov

Dear Program Management,

Announcements and Editing Staff:

On behalf of the Nuclear Energy Institutes (NEI) 1 members (hereinafter referred to as industry), we appreciate the opportunity to provide comments on the U.S. Nuclear Regulatory Commissions (NRC) draft regulatory guide (DG), DG-1383, Acceptability of ASME Code Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants, for Non-Light Water Reactors. This DG endorses, with conditions, the 2019 edition of ASME BPV Code,Section XI, Division 2. It also describes a method that applicants can use to incorporate PSI and ISI programs into a licensing basis.

ASME BPV Code,Section XI, Division 2 provides a process for developing a RIM program similar to a traditional PSI and ISI program under ASME Code,Section XI, Division 1, Rules for Inspection and Testing of Components of Light-Water-Cooled Plants, but for non-LWR nuclear power plants.

We support the provisions enabling use of probabilistic risk assessment (PRA) to develop reliability targets for structures, systems, and components (SSCs) within the scope of the program, and establishing practices like monitoring, nondestructive examination, and repair and replacement to develop strategies informed by 1

The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Office of Administration November 15, 2021 Page 2 expert panels, inspection results and identified degradation mechanisms to maintain the reliability of SSC components. The attachment provides several specific comments.

Again, we appreciate the opportunity to provide these comments for NRC consideration. If you have any questions or require additional information, please contact me at 202-439-0954, mar@nei.org.

Sincerely, Mark A. Richter Attachment c: Timothy Lupold, Office of Nuclear Reactor Regulation, NRC Robert Roche-Rivera, Office of Nuclear Regulatory Research, NRC Stephen Philpott, Office of Nuclear Regulatory Research, NRC Meraj Rahimi, Office of Nuclear Regulatory Research, NRC

NEI Comments on DG-1383 Affected Section Comment/Basis Recommendation

1. Page 4, Background 1. Draft DG-1385 states (as does RG 1.232): These guidance statements may not be applicable

a. ARDC-14 states that the reactor coolant to an AR design that does not rely on the reactor boundary shall be tested so as to have an cooling system (and particularly the pressure extremely low probability of abnormal boundary) for safe shutdown and prevention of leakage, of rapidly propagating failure, large releases. While footnote 2 acknowledges the and of gross rupture. requirements are based on water-cooled plants, no

b. ARDC-30 indicates that the components basis is provided why these are applicable to what that are part of the reactor coolant may be non-safety components. Consider removing boundary shall be tested to the highest the statements, particularly references to pressure quality standards practical. boundary, and add clarification and basis for why

c. ARDC-32 provides that the components these ARDC statements were chosen to be that are part of the reactor coolant applicable.

boundary shall be designed to permit periodic inspection and functional testing of important areas and features to assess their structural and leaktight integrity.