LR-N22-0027, Comment (7) of David J. Mannai on Operational Leakage
| ML22075A100 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 03/15/2022 |
| From: | Mannai D Public Service Enterprise Group |
| To: | Office of Administration |
| References | |
| 87FR2361 00007, LR-N22-0027, NRC-2021-0173 | |
| Download: ML22075A100 (5) | |
Text
3/16/22, 8:34 AM blob:https://www.fdms.gov/f32a1493-2b93-4ecf-8d36-1d1726b3e604
SUNI Review CompleteAs of: 3/16/22 8:34 AM Template=ADM-013 Received: March 15, 2022 E-RIDS=ADM-03 PUBLIC SUBMISSION Status: Pending_Post ADD: Brian Benny, Tracking No. l0s-wf46-8jny Mary Neely Comment (7) Comments Due: March 15, 2022 Publication Date: Submission Type: Web 1/14/2022 Citation:87 FR 2361 Docket: NRC-2021-0173 Operational Leakage
Comment On: NRC-2021-0173-0002 Operational Leakage
Document: NRC-2021-0173-DRAFT-0007 Comment on FR Doc # 2022-00686
Submitter Information
Email: harry.balian@pseg.com Organization: PSEG Nuclear, LLC
General Comment
PSEG Nuclear, LLC respectfully submits the attached comments regarding 87 FR 2361, Operational Leakage.
Attachments
LR-N22-0027 PSEG Nuclear Comments Operational Leakage
blob:https://www.fdms.gov/f32a1493-2b93-4ecf-8d36-1d1726b3e604 1/1 PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038- 0236
NRC-2021- 0173
LR-N22-0027
March 15, 202 2
Office of Administration U.S. Nuclear Regulatory Commission Mail Stop: TW FN-7-A60M ATTN: Program Management, Announcements and Editing Staff Washington DC 20555-0001
Salem and Hope Creek Ge nerating Stations Renewed Facility Operating Licenses DPR-70, DPR-75, and NPF-57 NRC Docket Nos. 50-272, 50- 311, and 50- 354
Subject:
Docket ID NRC-2021- 0173 Draft regulatory issue summary (RIS) Operational Leakage
References:
(1) 87 FR 2361, 10 CFR Chapter I [NRC-2021- 0173] Operational Leakage; (2) ASME BPVC Section XI, American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPVC) Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.
PSEG Nuclear, LLC (PSEG) offers comments on Reference (1) and respectfully requests that the Nuclear Regulatory Commission (NRC) withdraw the proposal. PSEG endorses comments the Nuclear Energy Institute (NEI) is concurrently submitting on this matter.
In Reference (1), the NRC defines operational leakage and through wall. NRC asserts that 10 CFR 50.55a(g) requires only those methods described in the provisions of the applicable in -service inspection requirements to demonstrate operability of through-wall operational leakage from ASME BPVC Class 1, 2, or 3 structures, systems and components ( SSCs). Moreover, the NRC states operational leakage must be Office of Administration Page 2 LR-N22-0027
addressed in the same manner as leakage detected during an ASME BPVC,Section XI, pressure test.
PSEG agrees that the presence of operational leakage requires evaluation of technical specification operability. Technical specifications for the Hope Creek and Salem Generating Stations prohibit any pressure boundary leakage from the reactor coolant system (ASME BPVC Class 1). However, with respect to ASME BPVC Class 2 or 3 SSCs, PSEG cannot find regulatory requirement s limiting operability determinations to only those methods authorized for leakage detected during an ASME BPVC,Section XI, pressure test. It is contradictory to first distinguish operational leakage from pressure test leakage and then to require application of the same evaluation methods to both types of leakage.
Reference (2) prescribes approved methods to evaluate or repair leaks discovered during ISI examination. However, leaks discovered during operation are, as the NRC points out, distinct from pressure test leakage subject to Reference (2) requirements.
The nuclear power industry has established methods to evaluate oper ability when degraded conditions are present. These methods demonstrate whether a SSC can perform specified safety functions - that is whether a SSC required to be operable by plant technical specifications is operable.
The draft RIS is inconsistent with NRC values embodied in the Principles of Good Regulation. For example, imposing ASME BPVC,Section XI methods to operability determinations is not commensurate with the perceived risk reduction. W e disagree with the draft RISs contention on how operability must be assessed. Contrary to the language used in the draft RIS, there are no regulatory requirements in Section XI of the ASME BPV Code, 10 CFR 50.55a, or the Technical Specifications (TS) that require use of Section XI flaw acceptance and evaluation methods to evaluate the structural integrity of Class 2 and 3 SSCs to determine operability in response to operational leakage. The established operability decision-making process is a proven and effective process that can safely allow productive nuclear generating stations to continue operating if existing ASME/NRC approved evaluation methods mandated by the RIS are impractical to apply.
Further, the proposed RIS imposes heightened regulatory requirements without the openness provided by form al rulemaking that the agency previously considered both appropriate and necessary for this new requirement. NRC subsequently withdrew the proposed rule change while unilaterally asserting there is no change in NRC position or Office of Administration Page 3 LR-N22-0027
interpretation. See, 86 FR 16087. This proposed RIS circumvents the formal rulemaking process the agency initially considered both necessary and appropriate for this new requirement. Additionally, it would also constitute unanalyzed back -fitting, contrary to the requirements of 10 CFR 50.109.
In closing, PSEG reiterates its endorsement of NEI comments on the RIS proposed by Reference (1). Thank you for your attention to this matter.
There are no regulatory commitments contained in this letter.
Please contact Mr. Harry Balian at (856) 339 - 2173 if you have any questions.
Sincerely,
David J. Mannai Senior Director, Regulatory Affairs and Nuclear Oversight PSEG Nuclear, LLC Office of Administration Page 4 LR-N22-0027
cc: USNRC Document Control Desk USNRC Regional Administrator Region 1 USNRC NRR Project Manager - Salem & Hope Creek USNRC Senior Resident Inspector - Salem USNRC Senior Resident Inspector - Hope Creek NJ Department of Environmental Protection, Bureau of Nuclear Engineering
President & Chief Nuclear Officer, PSEG Nuclear Senior Vice President, PSEG Nuclear Operations Site Vice President - Salem Plant Manager - Salem Site Vice President - Hope Creek Plant Manager - Hope Creek Vice President, PSEG Nuclear Engineering Senior Director, Regulatory Operations & Nuclear Oversight Director - Regulatory Affairs Manager - Licensing Manager - Nuclear Oversight Corporate Commitment Coordinator, PSEG Nuclear, LLC Records Management