ML23024A262
| ML23024A262 | |
| Person / Time | |
|---|---|
| Issue date: | 01/26/2023 |
| From: | Siva Lingam Licensing Processes Branch |
| To: | Cindy Rosales-Cooper Licensing Processes Branch |
| Siva Lingam 301-415-1564 | |
| Shared Package | |
| ML23024A264 | List: |
| References | |
| Download: ML23024A262 (7) | |
Text
January 26, 2023 MEMORANDUM TO: Cindy Rosales-Cooper, Acting Branch Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Siva P. Lingam, Project Manager /RA/
Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF JANUARY 19, 2023, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE AND INDUSTRY TO DISCUSS GENERAL VISUAL EXAMINATION OF CONTAINMENT SURFACES COVERED BY INSULATION On January 19, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff held an observation public meeting with representatives from the Nuclear Energy Institute (NEI) and industry to discuss general visual examination of containment surfaces covered by insulation. The meeting notice and agenda dated December 22, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML22356A111. A list of attendees is provided in Enclosure 1.
The slides presented for this public meeting by NEI and NRC are available in ADAMS under Accession Nos. ML23012A138 and ML23012A221, respectively. A list of presenters is included in Enclosure 2. The details of the meeting are discussed in Enclosure 3.
No comments were provided by members of the public. No meeting feedback forms from the attendees were received.
No regulatory decisions or commitments were made at the meeting.
Please direct any inquiries to me at (301) 415-1564 or by e-mail at Siva.Lingam@nrc.gov, or Bryce Lehman at (301) 415-1626 or by e-mail at Bryce.Lehman@nrc.gov.
Enclosures:
- 1. List of Attendees
- 2. List of Presenters
- 3. Meeting Details
LIST OF ATTENDEES JANUARY 19, 2023, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE AND INDUSTRY TO DISCUSS GENERAL VISUAL EXAMINATION OF CONTAINMENT SURFACES COVERED BY INSULATION Name Affiliation Nestor Feliz Adorno U.S. Nuclear Regulatory Commission (NRC)
Gurjendra Bedi NRC Eric Benner NRC Paul Cataldo NRC Matthew Domke NRC Nik Floyd NRC Mel Gray NRC Christopher Hunt NRC Jeff Kulp NRC Bryce Lehman NRC Siva Lingam NRC Eric Magnuson NRC Joon Park NRC Andrew Prinaris NRC George Thomas NRC Ian Tseng NRC Brian Wittick NRC Wijay Heinemann American Electric Power John Conly Certrec Mirza Baig Constellation Timothy Beck Constellation Kristen Genson Constellation Jonathan Grennier Constellation David Gudger Constellation David Gullott Constellation Anthony Haney Constellation Abul Hasanat Constellation Mark Humphrey Constellation Scott Kvasnicka Constellation Peter Lautensack Constellation Rachel Luebbe Constellation Steve Miller Constellation Daniel Moreno Constellation Sailaja Mukkapati Constellation James Leuellyn Newcomb II Constellation Darani Reddick Constellation Angel Reyes-Cruz Constellation Enclosure 1
Name Affiliation Rebecca Rice Constellation Marcellus Ruff Constellation Ted Ryan Constellation Michael Salley Constellation Brian Sholly Jr Constellation Rebecca Steinman Constellation Richard Swart Constellation Mark Weis Constellation Christian Williams Constellation Mark Ferlisi Consultant Daniel Lamond Consultant Jim Boughman Duke Energy Anna Winslett Ginn Duke Energy Austin Keller Duke Energy Antoaneta Koleva Duke Energy Mark Pyne Duke Energy Angela Staller Duke Energy Kaitlyn Sullivan Duke Energy Rolland Tedder Jr Duke Energy Phil Couture Entergy Glenn Chatterton Indiana Michigan Power Company Douglas Jacobs NAC International Inc.
Thomas Basso Nuclear Energy Institute (NEI)
Jerry Bonanno NEI Aladar Csontos NEI Tim Riti NEI Steve Catron NextEra Brian OCallahan NextEra Donna Slivon NextEra Michelle Alger Southern Nuclear Company (SNC)
Tanner Cauthen SNC Sarah Champion SNC Marie Darling SNC Hien Do SNC Aaron Mitchell Knighton SNC Asif Patel SNC Matthew Ralstin SNC Scott Walden SNC Adam Keyser Tennessee Valley Authority (TVA)
Matt White TVA Jana Bergman Public Garcia Heras Maria Luisa Public
LIST OF PRESENTERS JANUARY 19, 2023, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE AND INDUSTRY TO DISCUSS GENERAL VISUAL EXAMINATION OF CONTAINMENT SURFACES COVERED BY INSULATION Name Affiliation Bryce Lehman U.S. Nuclear Regulatory Commission Thomas Basso Nuclear Energy Institute David Gullott Constellation Mark Ferlisi Consultant Enclosure 2
MEETING DETAILS JANUARY 19, 2023, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE AND INDUSTRY TO DISCUSS GENERAL VISUAL EXAMINATION OF CONTAINMENT SURFACES COVERED BY INSULATION Purpose The purpose of this public meeting between the U.S. Nuclear Regulatory Commission (NRC) staff, and representatives from the Nuclear Energy Institute (NEI) and industry was to discuss general visual examination (VE) of containment surfaces covered by insulation.
During this meeting, the NEI representatives raised concerns of what they see as a sudden change in NRCs position requiring licensees to remove the insulation for VEs. The discussion focused on differing interpretations of the requirements documented in the American Society of Mechanical Engineers (ASME) Code by NRC and industry.
Background
On September 30, 2022, the NRC completed an inspection at Quad Cities Nuclear Power Station (Agencywide Documents Access and Management System (ADAMS) under Accession No. ML22307A161).
On November 3, 2022, the NRC issued the inspection report with a non-cited violation (NCV) and stated that the licensees failure to perform a general VE of the accessible flued head component surface areas of containment penetrations specified in ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Table IWE-2500-1, Examination Categories of Subsection IWE, Examination and Pressure Test Requirements, Examination Category E-A, Containment Surfaces, was contrary to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(4) and was a performance deficiency. Because the insulation obstructed visual access by line of sight when performing general visual examinations, the inspectors determined the licensee was not performing the general visual examinations required by Subsection IWE, Table IWE-2500-1 (E-A).
A similar item was identified at Fitzpatrick Nuclear Power Plant and a similar NCV is being considered.
However, the industry feels that the NRCs issued violation for not removing insulation from penetrations for these general VEs have no clear regulatory bases. Further, the industry believes, based on a review of the different containment designs currently in service in the U.S.,
that at least one-third of the operating units contain process piping penetrations, which are insulated. Per industrys estimate, insulation removal is estimated to cost over $500,000 per unit for each inspection interval.
Enclosure 3
Details Bryce Lehman of the NRC presented the topics addressing the following:
NRC and NEI have differing positions regarding removable insulations.
In March 2014, ASME issued an interpretation saying that there is no need for removing the insulation for general VEs. The insulation should be removed for augmented inspections only. However, the NRC staff does not agree with this ASME interpretation, and states that insulation should be removed for general VEs unless the insulated area is sealed to prevent moisture intrusion.
NRC should consider revising 10 CFR 50.55a, Codes and standards condition for better clarity to the industry.
NRC may consider clarifying its position prior to the ASME Section XI, 2023 Edition rulemaking through generic communication.
NRC should continue to engage industry and public via possible future public meetings.
Thomas Basso of NEI, David Gullott of Constellation, and Mark Ferlisi, a consultant, provided their presentation summarizing industry positions as noted below:
NCVs are not supported by the requirements of ASME Section XI or 10 CFR 50.55a.
Surface areas covered by insulation are considered inaccessible for general VEs based on review of ASME Code and the requirements of 10 CFR 50.55a.
There is no ASME or NRC requirement to remove insulation to make the surfaces accessible for IWE-2500-1 (E-A) general VE.
Path Forward As a result of the meeting, industry committed to providing additional information on how licensees are implementing the Code, and the NRC staff committed to review the information that industry provided during the meeting. The NRC staff plans to conduct future meetings to further understand the different interpretations and identify the appropriate regulatory path forward.
Eric Benner of NRC briefly explained the NRCs intentions on the path forward during opening remarks and concluded the meeting with closing remarks emphasizing the same.
Package: ML23024A264 Meeting Notice: ML22356A111 Meeting Slides: ML23012A138 (NEI) and ML23012A221 (NRC)
Meeting Summary: ML23024A262 *by e-mail OFFICE NRR/DORL/LLPB/PM* NRR/DEX/ESEB/TR* NRR/DORL/LLPB/LA*
NAME SLingam BLehman DHarrison DATE 01/24/2023 01/24/2023 01/24/2023 OFFICE NRR/DEX/ESEB/BC
- NRR/DORL/LLPB/BC (A)* NRR/DORL/LLPB/PM*
NAME ITseng CRosales-Cooper SLingam DATE 01/26/2023 01/26/2023 01/26/2023