ML23073A150
| ML23073A150 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2023 |
| From: | Gascot-Lozada R NRC/RES/DE/RGDB |
| To: | |
| References | |
| RG 1.163 Rev 1 DG-1391 | |
| Download: ML23073A150 (18) | |
Text
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 On November 10, 2022, the U.S. Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (87 FR 69052) announcing that Draft Regulatory Guide (DG)-1391 (proposed Revision 1 of Regulatory Guide 1.163) was available for public comment. The public comment period closed on December 19, 2022, and the NRC staff received the following comments:
Mr. Harrison Bourgoin Mr. James Bradford Mrs. Glenda Patzsch-Velasquez Xcel Energy Southern Company DTE Energy Telephone: (651) 267-7320 Telephone: (706) 836-8549 Telephone:
Email: harrison.d.bourgoin@xcelenergy.com Email: jrbradfo@southernco.com Email: glenda.patzsch-ADAMS Accession No.: ML22354A236 ADAMS Accession No.: ML22354A237 velasquez@dteenergy.com ADAMS Accession No.: ML22354A241 Mr. Thomas Basso Mr. Mark Gowin Appendix J Owners Group NEI ISI Email: appendixj@gmail.com Telephone: (484) 366-7534 Telephone: (423)-503-5931 ADAMS Accession No: ML22354A245 Email: tbb@nei.org Email: mgowin@isi-ist.com ADAMS Accession No: ML22354A242 ADAMS Accession No: ML22354A244 The comments below are repeated from the comment letters as stated, unless noted otherwise.
No. Commenter Comment NRC Resolution 1 Mr. Harrison In multiple locations there is the following error statement that The NRC staff agreed with this comment. The Bourgoin will need to be corrected: reference error has been corrected.
Xcel Energy Error! Reference source not found."
2 Mr. Harrison Clarification on what happens if a plant is already on 3A is The NRC staff partially disagreed with this comment.
Bourgoin required, what actions are required? If a plants technical specifications (TS) already Xcel Energy Recommending that if a site has already adopted 94-01 Rev 3A reference NEI 94-01 Revision 3-A but not Regulatory then no additional information needs to Guide (RG) 1.163, Revision 1, the licensee would still need to submit a license amendment request (LAR) if
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution be submitted to the NRC and the affected site may update the it wishes to adopt RG 1.163, Revision 1, into the TS APP J program to utilize ANS 56.8 - 2020 App J program.
without further submittals or NRC approval.
However, regulatory position 1 has been revised to Recommend that if a plant is already on 94-01 3A no additional include verbiage that ANSI/ANS-56.8-2020 as submittal (LAR) or NRC approval is required to adopt DG- approved by the RG may be used in lieu of 1391. ANSI/ANS 56.8-2002 without a LAR if (1) the Recommend updating conditions specifying that no additional licensees TS incorporate NEI 94-01, Revision 3-A action required if already adopted 3A. and (2) the licensees TS do not explicitly reference the 2002 ANSI/ANS standard and there is no other license provision that would necessitate a LAR to use ANSI/ANS-56.8-2020. This position is based on the provision in NEI 94-01, Revision 3-A Section 8.0 allowing the use of other alternative testing methods that have been approved by the NRC, which would include ANSI/ANS-56.8-2020 as approved by RG 1.163, Revision 1, and subject to the condition stated in the RG.
3 Mr. Harrison Some plants have been granted alternates to 10 CFR Part 100. The NRC staff agreed with this comment, which it Bourgoin Does language need to be added to address this potential gap. understands to refer to plants that have been granted Xcel Energy alternates to 10 CFR Part 100 for calculating allowable leakage rates. The RG has been revised as follows: Maximum allowable leakage rates (La) are calculated in accordance with 10 CFR Part 100, Reactor Site Criteria, (Ref. 7) except where alternates have been granted .
4 Mr. Harrison The maximum allowable leakage rates (La) are typically stated The NRC staff agreed with this comment. The RG has Bourgoin in Tech Specs as a mass leakage rate (percent weight per day) been revised to state: Maximum allowable leakage Xcel Energy rather than a volume leakage rate. rates (La) are calculated in accordance with 10 CFR Part 100, Reactor Site Criteria. (Ref. 7) and are specified in licensee site specific Technical Specifications.
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution 5 Mr. Harrison Recommend deletion/removal of condition 3: This condition is The NRC staff partially disagreed with the Bourgoin a new condition with respect to the APP J and not part of NEI deletion/removal recommendation. This is not a new Xcel Energy 94-01. This condition appears to appl[y] more to ASME condition. The main objective of this condition isSection XI IWE inspection program and conditions should discussed in the safety evaluation (SE) for NEI 94-01 reside in documents directing the performance of the IWE Revision 2A. However, it was just expounded on in inspections. This document already states under the DG-1391 to provide more detail and guidance. The containment inspection section (Section B, Containment RG has been changed to clarify that this condition inspections) that, " Based upon operating experience, the refers to the general use of the ASME Code as follows instances of through-wall corrosion and fatigue degradation of (changed portions in italics): Specifically, the metallic liners and shells that have occurred have been detected licensee should describe its IWE/IWL Containment by visual examinations under the IWE program, not by Inservice Inspection program, which implements the ILRTs.", indicating that the current IWE program is sufficient requirements of the ASME,Section XI, Subsections and any changes to or conditions to should be not be applied IWE and IWL, as required by 10 CFR 50.55a.
via the APP J RG. The report ORNL/NRC/LTR-02/02 will be added as a reference for inspection of inaccessible areas of the plant.
6 Mr. Harrison Recommend Revision to condition 4 to incorporate language The NRC staff agreed with this comment to Bourgoin from 94-01 2A SER section 3.1.4. to account for NRC incorporate language from Section 3.1.4 of the SE for Xcel Energy condition for major and minor modifications. Clarifying that NEI 94-01, Revision 2A on major and minor Type A test is not required if the condition specified in revision modifications. For major modifications, the following 2-A SER condition 3.1.4. [in italics] have been incorporated into the RG: In general, the NRC staff considers the cutting of a large hole in the containment for replacement of steam generators or reactor vessel heads, or replacement of large penetrations, as major repair or modifications to the containment structure. The RG has also been revised to add regulatory position 4 the following:
For minor modifications (e.g., replacement or addition of a small penetration), or modification of attachments to the pressure retaining boundary (i.e.,
repair/replacement of steel containment stiffeners),
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution leakage integrity of the affected pressure retaining areas should be verified by a LLRT.
7 Mr. Harrison Recommend deletion/removal of condition 6: This condition is The NRC staff disagreed with the recommendation to Bourgoin duplicate and is not needed since 94-01 3A already addresses delete regulatory position 6. This regulatory position Xcel Energy the initial test intervals for all test types A, B, and C which should remain in place to provide clarity on when NEI ensures appropriate satisfactory performance history for all test 94-01 Revision 3-A may be adopted by new reactor types. applicants given the activities necessary to demonstrate the applicability of NEI 94-01 Revision 3-A to the new facility.
8 Mr. Harrison Recommend deletion/removal of condition 11 through 14: The NRC staff agreed with this comment. Regulatory Bourgoin These conditions are duplicate to the 94-01 3A SER topical positions 11 through 14 are redundant to the Xcel Energy report conditions 4.1 and 4.2 (ML12221A202). Limitation and Conditions identified in the safety evaluation appended to NEI 94-01, Revision 3-A.
These regulatory positions will be removed from the RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
9 Mr. James Recommend the guide to be revised to allow utilities who have The NRC staff agrees that in appropriate Bradford adopted NEI 94-01 Rev 3A to allow usage of ANSI/ANS 56.8- circumstances, licensees whose TS reference NEI 94-Southern 2020 without submitting a LAR. 01, Revision 3A, may use ANSI/ANS 56.8-2020 Company without submitting a LAR as discussed in the response to Comment 2, above. Regulatory position 1 has been revised accordingly.
10 Mrs. Glenda Page 4, Section B. Discussion, last sentence of Paragraph 3. The NRC staff agreed with this comment. The system Patzsch- Error! Reference source not found. Error! Reference source reference error has been corrected. The reference Velasquez not found. Is this error referring to reference source source referred in the comment is correct.
DTE Energy ANSI/ANS-56.8-2020 edition? If not, what reference source is this sentence referring to?
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution 11 Mrs. Glenda Page 6, Section Containment Inspection, last sentence of The NRC staff agreed there is an error. The reference Patzsch- Paragraph 2. Error! Reference source not found. Which error has been corrected.
Velasquez reference source is this sentence referring to?
DTE Energy 12 Mrs. Glenda Page 8, Section C. Staff Regulatory Guidance, last sentence The NRC staff agreed there is an error. The reference Patzsch- of C.3. Error! Reference source not found. Which reference error has been corrected.
Velasquez source is this sentence referring to?
DTE Energy 13 Mr. Thomas While we believe the endorsement provided in DG-1391 The NRC staff disagreed with the suggestion to Basso presents an opportunity to facilitate the use of a remove regulatory position 3 but is revising some NEI performance-based approach to leakage-rate testing, we have language in the regulatory position. As revised, the several comments regarding condition 3 in Section C of the NRC staff has determined that the language is not draft regulatory guide. Specifically, as written, condition 3 is vague or overbroad.
vague, potentially overbroad, and raises potential forward-fitting concerns that have not been addressed in DG-1391. Regulatory position 3 is not a new condition. The main objective of this condition is discussed in the SE Condition 3 begins by stating, The LAR should address the for NEI 94-01 Revision 2A. However, it was just areas of the containment structure potentially subject to expounded in DG-1391 to provide more detail and degradation. This requirement is overbroad because it would guidance. But the NRC has revised regulatory apply to almost any and every structure, no matter the position 3 to refer to the general use of the ASME likelihood and severity of any such degradation and its safety Code for addressing the areas of the containment significance. Inspections of structures or components structure potentially subject to degradation. With the susceptible to minor to almost no degradation, or that perform relatively longer intervals allowed for performing the no safety function would provide no safety benefit and impose ILRTs and LLRTs, the containment inspections play significant costs on licensees and applicants. an important role in ensuring the leak tightness of containments between the tests.
The condition goes on to state that the licensee should identify inaccessible areas of containment and describe consideration of The ASME Code has identified areas that need to be inspections or viable, commercially available nondestructive specifically addressed during the IWE and IWL examination (NDE) to monitor these areas for degradation. It inspections, including a number of containment is not clear if the agency considers all inaccessible areas as pressure-retaining boundary components (e.g., seals subject to degradation and, thus, requiring inspection or and gaskets of mechanical and electrical penetrations,
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution nondestructive testing; or whether the agency is referring to bolting, penetration bellows) and a number of the only those inaccessible areas that have a potential for accessible and inaccessible areas of the containment degradation. The former is beyond the current requirements in structures (e.g., moisture barriers, steel shells, and 10 CFR 50.55a, which have proven for decades to provide liners backed by concrete, inaccessible areas of ice reasonable assurance of adequate protection in maintaining the condenser containments that are potentially subject to integrity of the containment structures. corrosion).
The draft regulatory guide then further specifies that,
[s]pecific areas identified that should be addressed include a Regulatory position 3 already stated that it applies to number of containment pressure-retaining boundary the areas of the containment structure potentially components (e.g., seals and gaskets of mechanical and subject to degradation, and the staff has further electrical penetrations, bolting penetration bellows) and a clarified this scope by referencing the relevant ASME number of the accessible and inaccessible areas of the containment structures (e.g., moisture barriers, steel shells, and Code provisions for inspecting such areas.
liners backed by concrete, inaccessible areas of ice-condenser containments that are potentially subject to corrosion). But the draft guide does not recognize that many of these specified components are inaccessible for the purpose of protecting them The NRC staff disagrees with the forward fitting (e.g., via guard pipes or permanent insulation) and that actions comment because (a) issuance of guidance for to facilitate inspections of such structures and components voluntary use by applicants and licensees does not could have more negative safety consequences, than the actual constitute forwarding fitting, and (b) the comment safety benefit of the inspection. suggests that the RG might be used in a way that constitutes forward fitting, but this is speculative, and The vagueness and overbreadth of condition 3 also raises the RG states, "The staff also does not intend to use forward fitting concerns that are not addressed in the guidance to support NRC staff actions in a manner DG-1391. The vague and overbroad nature of condition 3 that constitutes forward fitting as that term is defined creates the potential for the imposition of forward fits during and described in Management Directive 8.4."
implementation of the guidance. If the NRC intends the guidance provided in condition 3 to be interpreted broadly to include the assumption that all inaccessible areas are subject to degradation and, thus, must be subject to inspection or nondestructive testing, then the implementation of that guidance will likely involve forward fitting. In that case, the
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution direct nexus and essentiality factors described in MD 8.4 must be addressed. In addition, unless the forward fit is necessary to ensure adequate protection, some consideration of cost would be required.
NEI recommends the NRC consider removing condition 3 from DG-1391, or significantly modifying it to provide more assessment criteria for those structures and components that should be inspected, particularly those structures categorized as inaccessible.
14 This guide appears to be aimed at licensees that have not yet The NRC staff partially agreed with this comment.
Mr. Mark Gowin adopted NEI 94-01, Revision 3-A. Considering there are a The guide is aimed to licensees that have not adopted significant number of licensees that have already adopted NEI NEI 94-01, Revision 3-A. If a plants TS already 94-01, Revision 3-A, it would beneficial to the industry if the references Revision 3-A but not Regulatory Guide guide were revised to address updated information that could (RG) 1.163, Revision 1, the licensee would still need be incorporated into licensee programs that already conform to to submit a LAR if it wishes to adopt RG 1.163, NEI 94-01, Revision 3-A. See comments 4 [17]1, 7 [20] and 10 Revision 1, into the TS App J program.
[23] below for cases where this would be beneficial.
Also, regulatory position 1 has been revised to state that, in appropriate circumstances, licensees whose TS reference NEI 94-01, Revision 3A, may use ANSI/ANS 56.8-2020 without submitting a LAR as discussed in the response to Comment 2, above.
15 Mr. Mark Gowin Section A, Applicable Regulations, 2nd sub bullet The NRC staff agreed with this comment. The following italicized edits have been incorporated into 10 CFR 50.55a specifies requirements for more than inservice the RG: 10 CFR 50.55a specifies requirements for inspection programs. It also specifies requirement for inservice inservice inspection programs, inservice testing testing programs [10 CFR 50.55a (f)] and protective and safety programs, and protection and safety systems.
systems requirements [10 CFR 50.55a(h)].
1 The numbers in brackets refer to the comment numbers in this document.
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution 16 Mr. Mark Gowin Multiple locations. First example is in Section B, Reason for The NRC staff agreed with this comment. The Revision, 3rd paragraph reference error has been corrected.
It is not clear what text or reference was intended where the bold cross reference error is shown which states, Error!
Reference source not found. Error! Reference source not found.
17 Mr. Mark Gowin Section B, Reason for Revision, 4th (last) The NRC staff partially disagreed with this comment.
Paragraph If a plants TS already reference NEI 94-01 Revision This section endorses the use of NEI 94-01, Rev 3-A, EPRI 3-A but not RG 1.163, Revision 1, the licensee would Report No. 1009325, and ANS 56.8 - 2020. However, the last still need to submit a LAR if it wishes to adopt RG paragraph of this section requires submittal of a LAR to use the 1.163, Revision 1, into the TS App J program.
provision of RG 1.163, Revision 1. Recommend the guide to be revised to specifically address those licensees who have However, the NRC staff agrees that in appropriate already adopted NEI 94-01, Revision 3-A to allow those circumstances, licensees whose TS reference NEI 94-licensees to also adopt ANS 56.8 - 2020 without submitting a 01, Revision 3A, may use ANSI/ANS 56.8-2020 LAR and simply referencing this guide. A significant number without submitting a LAR as discussed in the of US licensees have already been granted permission to the response to Comment 2, above. Regulatory position 1 use NEI 94-01, Revision 3-A through the LAR process. The has been revised accordingly.
typical LAR language that licensees have used to adopt NEI 94-01, Revision 3-A does not specifically address the edition of ANS 56.8. Therefore, it is feasible for NRC to specifically endorse the use of ANS 56.8 - 2020 for those licensees which are already approved to use NEI 94-01, Revision 3-A. Revision of this guide to simply state that ANS 56.8 - 2020 may be used in lieu of ANS 56.8
- 2002 for those licensees already approved to use NEI 94-01, Revision 3-A.
18 Mr. Mark Gowin Section B, Background, 2nd paragraph: The maximum The NRC staff agreed with this comment. The RG has allowable leakage rates (La) are typically stated in Tech Specs been revised to state: Maximum allowable leakage as a mass leakage rate (percent weight per day) rather than a rates (La) are calculated in accordance with 10 CFR volume leakage rate. It may be best to revise this paragraph to Part 100, Reactor Site Criteria. (Ref. 7) and are
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution eliminate the units of measure all together to eliminate any specified in licensee site specific Technical confusion. For example, the paragraph could say: Maximum Specifications.
allowable leakage rates (La) are calculated in accordance with 10 CFR Part 100, Reactor Site Criteria. (Ref. 7) and are specified in licensee site specific Technical Specifications.
19 Mr. Mark Gowin Section B, Background, Containment Inspections The RG has been changed to point to the general use It is this commentors opinion that the purpose of the original of the ASME Code as follows (changed portions in 10 CFR 50, Appendix J required containment inspection was to italics): Specifically, the licensee should describe its ensure there were no indications that could lead to containment IWE/IWL Containment Inservice Inspection program, structure failure when containment is pressurized for the Type which implements the requirements of the ASME, A test. This opinion is based on the fact that the original visual Section XI, Subsections IWE and IWL, as required by examination was required to be performed just before the Type 10 CFR 50.55a.
A test, the person responsible for the visual examination had to be cognizant of containment design, and there were no other specific qualification requirements such as visual acuity, lighting, etc. When 10 CFR 50, Appendix J was revised to include the performance-based Option and RG 1.163, Revision 0 was published to provide the industry with a regulatory approved method to implement Option B, the guide added additional containment visual examinations to occur prior to the Type A and two other refueling outages before the next Type A (Regulatory Position 3). The stated purpose of these additional containment visual examinations was to allow for early uncovering of evidence of structural deterioration.
However, 10 CFR 50.55a endorsement of ASME Section XI, Subsections IWE and IWL also provided similar requirements for containment visual examination intervals. These requirements are very specific with respect to frequency, personnel qualifications, and methods for implementation (e.g.,
lighting, etc.).
The containment visual examination requirements in
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution RG 1.163, Revision 0, Regulatory Position 3 are nonspecific other than frequency and purpose - they do not provide requirements or qualifications for implementation.
The containment visual examination requirements in DG-1391 (RG 1.163, Revision 1) are a less-specific duplication of containment visual examination requirements specified in 10 CFR 50.55a.
Recommend removing the containment visual examination requirements from DG-1391 (RG 1.163, Revision 1) and simply point to 10 CFR 50.55a for containment visual examination requirements. This approach will eliminate any duplication and confusion that may be caused by differences in wording between the two regulatory requirements.
20 Mr. Mark Gowin Section C, No. 1 The NRC staff agrees that in appropriate Recommend revising Position 1 those licensees already circumstances, licensees whose TS reference NEI 94-approved to use NEI 94-01, Revision 3-A to use ANS 56.8 - 01, Revision 3A, may use ANSI/ANS 56.8-2020 2020 in lieu of ANS 56.8 - 2002 (referenced in NEI 94-01, without submitting a LAR as discussed in the Revision 3-A) response to Comment 2, above. Regulatory position 1 has been revised accordingly.
21 Mr. Mark Gowin Section C, No. 2 The NRC staff disagreed with this comment.
Regulatory position 2 should remain. Though a This paragraph is not necessary. The proposed description of the supplemental inspection provisions requirements is already provided in NEI 94-01, Revision 3-A is provided in NEI 94-01 Revision 3-A, there is no mention of providing a schedule of these inspections as part of the LAR submittal.
22 Mr. Mark Gowin Section C, No. 3 The NRC staff disagreed with the recommendation to See Comment Item 6 [19]. Recommend deleting this paragraph delete this regulatory position. The regulatory position in its entirety. As stated in Comment Item 6, there is should remain in place. Containment inspections play duplication between regulatory requirements of DG-1391 (RG an important role in ensuring the leak tightness of 1.163, Revision 1) and 10 CFR 50.55a. Also, and more containments between the tests. No new requirements importantly, this paragraph adds significant burden to the are added with this regulatory position. The NRC
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution licensee and is not justified. For example, this paragraph revised regulatory position 3 in the RG to point to the describes new and burdensome requirements for inaccessible use of the ASME Code, as required by 10 CFR 50.55a areas. This guide, the previous revision of RG 1.163, and NEI for addressing the areas of the containment structure 94-01 do not define or describe accessible or inaccessible potentially subject to degradation.
areas. Adding new requirements in this guide for inaccessible areas not justified by industry OE with respect to containment The ASME Code has identified areas that need to be integrity. specifically addressed during the IWE and IWL inspections, including a number of containment If this new requirement for inaccessible areas is not removed pressure-retaining boundary components (e.g., seals from the guide, then please provide adequate justification for and gaskets of mechanical and electrical penetrations, the increased burden. In addition, if this requirement remains bolting, penetration bellows) and a number of the then additional clarification is needed to define accessible and accessible and inaccessible areas of the containment inaccessible areas and guidelines to assist licensees in structures (e.g., moisture barriers, steel shells, and determining the extent to which inspection of inaccessible liners backed by concrete, inaccessible areas of ice areas are expected. The new requirements for inaccessible condenser containments that are potentially subject to areas, as written in this guide, are much too vague and do not corrosion).
provide enough information for licensees to implement the requirements in a consistent manner or as NRC expects. Regulatory position 3 already stated that it applies to the areas of the containment structure potentially subject to degradation, and the staff has further clarified this scope by referencing the relevant ASME Code provisions for inspecting such areas.
23 Mr. Mark Gowin Section C, No. 4 The NRC staff disagreed with this comment that a 10 It would be helpful to the industry if this paragraph could be CFR 50.55a alternative is not needed for short revised or a new one added to include the language from the duration tests. The staff agrees to add discussion from Safety Evaluation, Section 3.1.4, for NEI 94-01, Revision 2-A Safety Evaluation, Section 3.1.4, for NEI 94-01, regarding major and minor containment repair and Revision 2-A on major and minor containment repairs modifications. Specifically, add the descriptions of major and and modifications. The following edits (in italics) minor containment repairs and modification and also clarify have been incorporated into the RG: any major that if the elements of a short duration structural test of the containment modification or repair/replacement must containment are satisfied for a major repair or modification, be followed by a Type A test to provide assurance of then a Type A test is not required and there is no need to both containment structural integrity and leak tight
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution submit an exemption or request for alternative to use the short integrity prior to returning to service. In general, the duration structural test in lieu of a Type A test. NRC staff considers the cutting of a large hole in the containment for replacement of steam generators or reactor vessel heads, or replacement of large penetrations, as major repair or modifications to the containment structure. The revisions to the Type A interval described in NEI 94-01, Revision 3-A and this RG are limited to Type A testing for the purposes of satisfying Appendix J, and if licensees intend to depart from 50.55a(b)(2)(ix)(J) (i.e., a short duration structural test of the containment), then licensees should submit an alternative request before implementation in accordance with 10 CFR 50.55a(z).
The RG has also been revised to add to regulatory position 4 the following: For minor modifications (e.g., replacement or addition of a small penetration),
or modification of attachments to the pressure retaining boundary (i.e., repair/replacement of steel containment stiffeners), leakage integrity of the affected pressure retaining areas should be verified by a LLRT.
24 Mr. Mark Gowin Section C, No. 6 The NRC staff disagreed with the recommendation to delete regulatory position 6. This regulatory position Recommend deletion of this paragraph in its entirety. should remain in place to provide clarity on when NEI NEI 94-01, Revision 3-A already adequately addresses the 94-01 Revision 3-A may be adopted by new reactor requirements for initial and subsequent test applicants given the activities necessary to intervals for Type A, B, and C tests demonstrate the applicability of NEI 94-01 Revision 3-A to the new facility.
25 Mr. Mark Gowin Section C, No. 11 and 12 The NRC staff agreed with this comment. Regulatory positions 11 and 12 are redundant to the Limitation
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution These paragraphs are a duplicate of NRC Condition 1 in and Conditions identified in the safety evaluation Section 4.0 of the SER for NEI 94-01, Revision 3-A appended to NEI 94-01, Revision 3-A. These (ML12221A202) regulatory positions will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
26 Mr. Mark Gowin Section C, No. 13 and 14 The NRC staff agreed with this comment. Regulatory These paragraphs are a duplicate of NRC Condition 2 in positions 13 and 14 are redundant to the Limitation Section 4.0 of the SER for NEI 94-01, Revision 3-A and Conditions identified in the safety evaluation (ML12221A202) appended to NEI 94-01, Revision 3-A. These regulatory positions will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
27 Appendix J Section A, Applicable Regulations, 2nd sub bullet 10 CFR The NRC staff agreed with this comment. The Owners Group 50.55a specifies requirements for more than inservice following italicized edits has been incorporated into inspection programs. the RG: 10 CFR 50.55a specifies requirements for inservice inspection programs, inservice testing Recommend clarifying that it also includes: inservice programs, and protection and safety systems.
testing programs [10 CFR 50.55a (f)] and protective and safety systems requirements [10 CFR 50.55a(h)].
28 Appendix J Section B, Reason for Revision, 3rd The NRC staff agreed with this comment. The Owners Group reference error has been corrected.
Paragraph; Section B, Containment Inspections, 3rd Paragraph; Section C, Staff Regulatory Guidance, Condition 3 This message appears in the document - Error!
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution Reference source not found. Error! Reference source not found. It is not clear what these references are or how they impact the document.
Recommend correcting link.
29 Appendix J Section B, Reason for Revision, 4th (last) paragraph The NRC staff partially disagreed with this comment.
Owners Group If a plants TS already reference NEI 94-01 Revision It appears this draft guide is directed at plants that have not 3-A but not RG 1.163, Revision 1, the licensee would adopted NEI 94-01. Rev 3-A. A significant number of US still need to submit a LAR if it wishes to adopt RG licensees have already been granted permission to the use NEI 1.163, Revision 1, into the TS App J program.
94-01, Revision 3-A through the LAR process.
However, the NRC staff agrees that in appropriate This section endorses the use of NEI 94-01, Rev 3-A, EPRI circumstances, licensees whose TS reference NEI 94-Report No. 1009325, and ANS 56.8 - 2020. 01, Revision 3A, may use ANSI/ANS 56.8-2020 without submitting a LAR as discussed in the However, the last paragraph of this section requires submittal response to Comment 2, above. Regulatory position 1 of a LAR to use this provision of RG 1.163, has been revised accordingly.
Revision 1.
Recommend the guide to be revised to specifically address those licensees who have already adopted NEI 94-01, Revision 3-A and allow them to adopt ANS 56.8 - 2020 without submitting a LAR. Request clarification that ANS 56.8 - 2020 may be used in lieu of ANS 56.8 - 2002 for those licensees already approved to use NEI 94-01, Revision 3-A.
30 Appendix J Section B, Background, 2nd paragraph- The NRC staff agreed with this comment. The RG has Owners Group The maximum allowable leakage rates (La) are typically stated been revised to state: Maximum allowable leakage in Tech Specs as a mass leakage rate (percent weight per day) rates (La) are calculated in accordance with 10 CFR rather than a volume leakage rate. Part 100, Reactor Site Criteria. (Ref. 7) and are specified in licensee site specific Technical Specifications.
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution Recommend aligning units with standard language or revise this paragraph to eliminate the units of measure all together to eliminate any confusion 31 Appendix J Section B, Background, 2nd paragraph- The NRC staff partially disagreed with this comment.
Owners Group This is not a new condition. The main objective of The containment visual examination requirements in RG 1.163, this condition is discussed in the NEI 94-01 Revision Revision 0, Regulatory Position 3 are nonspecific other than 2A SE. However, it was just expounded on in DG-frequency and purpose - they do not provide requirements or 1391 to provide more detail and guidance.
qualifications for implementation. NEI 94-01 does not mention or define inaccessible areas. The NRC staff disagreed with the apparent recommendation to delete this regulatory position.
The containment visual examination requirements in DG-1391 The regulatory position should remain in place.
(RG 1.163, Revision 1) appear to be a duplication of Containment inspections play an important role in containment visual examination requirements specified in 10 ensuring the leak tightness of containments between CFR 50.55a. the tests. No new requirements are added with this regulatory position. Consistent with the comment, the Recommend removing the containment visual examination NRC revised regulatory position 3 in the RG to point requirements from DG-1391 (RG 1.163, to the use of the ASME Code, as required by 10 CFR Revision 1). Detailed containment visual inspection 50.55a for addressing the areas of the containment are performed in accordance with IWE per 10 CFR structure potentially subject to degradation.
50.55a for containment visual examination requirements. This approach will eliminate any duplication and confusion that may The ASME Code has identified areas that need to be be caused by differences in wording between the two specifically addressed during the IWE and IWL regulatory requirements. inspections including a number of containment pressure-retaining boundary components (e.g., seals and gaskets of mechanical and electrical penetrations, bolting, penetration bellows) and a number of the accessible and inaccessible areas of the containment structures (e.g., moisture barriers, steel shells, and liners backed by concrete, inaccessible areas of ice condenser containments that are potentially subject to corrosion).
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution Regulatory position 3 already stated that it applies to the areas of the containment structure potentially subject to degradation, and the staff has further clarified this scope by referencing the relevant ASME Code provisions for inspecting such areas.
32 Appendix J Section C, No. 1 The NRC staff agrees that in appropriate Owners Group circumstances, licensees whose TS reference NEI 94-See Comment Item 3. 01, Revision 3A, may use ANSI/ANS 56.8-2020 Recommend revising Position 1 to specifically address those without submitting a LAR as discussed in the licensees who have already adopted NEI 94-01, response to Comment 2, above. Regulatory position 1 Revision 3-A and allow them to adopt ANS 56.8 - 2020 has been revised accordingly.
without submitting a LAR.
33 Appendix J Section C, No. 3 The NRC staff disagreed with the recommendation to Owners Group Recommend deleting this paragraph in its entirety. As delete this regulatory position. The regulatory position stated in Comment Item 5 [31], there is duplication between should remain in place. Containment inspections play regulatory requirements of DG-1391 (RG an important role in ensuring the leak tightness of 1.163, Revision 1) and 10 CFR 50.55a. containments between the tests. No new requirements are added with this regulatory position, as explained in response to comment 22. In the regulatory position, the staff provides examples of specific containment pressure-retaining boundary components and area of the containment structures that should be addressed.
34 Appendix J Section C, No. 4 The NRC staff disagreed with this comment.
Owners Group Revise this paragraph to clarify NEI 94-01, Rev 2 SER 10 CFR 50.55a states in part that a Type A test should Condition which points to 3.1.4 for major and minor be performed following any major modifications to maintenance / modifications. the containment. If a licensee wants to perform an Recommend this paragraph endorse the use of 3.1.4 alternative test (i.e. short duration test), then an without need to licensee to submit request for alternative request is needed. Additional language for exemption to 10 CFR 50 Appendix J or request for
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution alternative to ASME Section XI, Subsections IWE and major and minor modifications was added, as IWL discussed in the response to Comment 6.
35 Appendix J Section C, No. 6 The NRC staff disagreed with the recommendation to Owners Group Recommend deletion. NEI 94-01 3A already delete regulatory position 6. This regulatory position addresses the initial test intervals for all test types A, should remain in place to provide clarity on when NEI B, and C which ensures appropriate satisfactory performance 94-01 Revision 3-A may be adopted by new reactor history for all test types applicants given the activities necessary to demonstrate the applicability of NEI 94-01 Revision 3-A to the new facility.
36 Appendix J Section C, No. 11 The NRC staff agreed with this comment. Regulatory Owners Group Recommend deletion. Duplication of SER for NEI 94- position 11 is redundant to the Limitation and 01, Revision 3-A (ML12221A202) Topical Report Conditions identified in the safety evaluation Condition 1. appended to NEI 94-01, Revision 3-A. This regulatory position will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
37 Appendix J Section C, No. 12 The NRC staff agreed with this comment. Regulatory Owners Group Recommend deletion. Duplication of SER for NEI 94- position 12 is redundant to the Limitation and 01, Revision 3-A (ML12221A202) Topical Report Conditions identified in the safety evaluation Condition 1. appended to NEI 94-01, Revision 3-A. This condition will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
38 Appendix J Section C, No. 13 The NRC staff agreed with this comment. .
Owners Group Recommend deletion. Duplication of SER for NEI 94- Regulatory position 13 is redundant to the Limitation 01, Revision 3-A (ML12221A202) Topical Report and Conditions identified in the safety evaluation Condition 2. appended to NEI 94-01, Revision 3-A. This condition
Response to Public Comments on Draft Regulatory Guide (DG)-1391, Performance-Based Containment Leak-Test Program Proposed Revision 1 of Regulatory Guide 1.163 No. Commenter Comment NRC Resolution will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.
39 Appendix J Section C, No. 14 The NRC staff agreed with this comment. Regulatory Owners Group Recommend deletion. Duplication of SER for NEI 94- position 14 is redundant to the Limitation and 01, Revision 3-A (ML12221A202) Topical Report Conditions identified in the safety evaluation Condition 2 appended to NEI 94-01, Revision 3-A. This condition will be removed from this RG, and the RG will be revised to state that users of the RG should follow the limitations and conditions in the SE for NEI 94-01, Revision 3-A in addition to the regulatory positions in the RG.