ML23095A074
| ML23095A074 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/2023 |
| From: | Lois James Licensing Processes Branch |
| To: | Gerond George Licensing Processes Branch |
| Shared Package | |
| ML23095A094 | List: |
| References | |
| Download: ML23095A074 (1) | |
Text
April 21, 2023 MEMORANDUM TO: Gerond A. George, Branch Chief Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Lois M. James, Senior Project Manager /RA/
Licensing Projects Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF MARCH 23, 2023, PUBLIC MEETING WITH NUCLEAR ENERGY INSTITUTE AND INDUSTRY TO DISCUSS GENERAL VISUAL EXAMINATION OF CONTAINMENT SURFACES COVERED BY INSULATION On March 23, 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 March 2, 2023, are available in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML23061A014. A list of attendees is provided in Enclosure 1.
The slides presented for this public meeting by the NRC staff and NEI representatives are available in ADAMS under Accession Nos. ML23079A263 and ML23079A264, respectively. A list of presenters is included in Enclosure 2. The details of the meeting are discussed in .
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, or George Wang at (301) 415-5862 or by email at George.Wang@NRC.gov.
Enclosures:
- 1. List of Attendees
- 2. List of Presenters
- 3. Meeting Details
LIST OF ATTENDEES MARCH 23, 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)
Eric Benner NRC Paul Cataldo NRC Elise Eve NRC Nik Floyd NRC Megan Gangewere NRC Mel Gray NRC Gerond George NRC Todd Keene NRC Andrea Kock NRC Jeff Kulp NRC Shaohua Lai NRC Bryce Lehman NRC Siva Lingam NRC Eric Magnuson NRC Joon Park NRC Lionel Rodriguez NRC Eucherius Rosario NRC Ian Tseng NRC George Wang NRC Brian Wittick NRC Wijay Heinemann American Electric Power Andy Nettles Arkansas Nuclear One John Conly Certrec Bryce Babarsky Constellation Kristen Genson Constellation David Gullott Constellation Anthony Haney Constellation Mark Humphrey Constellation Thomas Loomis Constellation Rachel Luebbe Constellation Richard McCulloch Constellation Marcellus Ruff Constellation Ted Ryan Constellation Joshua Sarrafian Constellation Jacky Shoulders Constellation Patrick Simpson Constellation Enclosure 1
Name Affiliation Rebecca Steinman Constellation Richard Swart Constellation Mark Weis Constellation Mark Ferlisi Consultant Daniel Lamond Consultant Deanne Raleigh Curtis Wright Jonathan Cherry Dominion Energy (Services - 6)
Cindi Henderson Dominion Energy (Services - 6)
Austin Keller Duke Energy Mark Pyne Duke Energy Angela Staller Duke Energy Rolland Tedder Jr Duke Energy Kevin Allen Energy Harbor Levi Jones Energy Harbor Mike McCoy Energy Harbor Justin Truxall Energy Harbor Luke Twarek Energy Harbor Jacob Zbiegien Energy Harbor Howard Mahan Entergy Kevin Hall Iddeal Solutions Glenn Chatterton Indiana Michigan Power Company Douglas Jacobs NAC International Inc.
Thomas Basso Nuclear Energy Institute (NEI)
Andrew Mauer NEI Tim Riti NEI Donna Slivon NextEra Tom Roberts POMO18 Consult LLC Steve Mays SEM Consulting LLC Sarah Champion Southern Nuclear Company (SNC)
Hien Do SNC Aaron Mitchell Knighton SNC Matthew Ralstin SNC Scott Walden SNC Edwin Lyman Union of Concerned Scientists Nathan Fedora Xcel Energy Marty Murphy Xcel Energy Jim Annett Public Miranda Baumunkgray Public Jana Bergman Public Ron Clow Public Thomas Downing Public Russell Lidberg Public Garcia Heras Maria Luisa Public
LIST OF PRESENTERS MARCH 23, 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 (NRC)
Ian Tseng NRC Thomas Basso Nuclear Energy Institute Mark Ferlisi Consultant Enclosure 2
MEETING DETAILS MARCH 23, 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 further discuss general visual examination (VE) of containment surfaces covered by insulation after the public meeting held on January 19, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23024A262).
The discussion focused on divergent interpretations of the existing requirements and how the NRC staff can work to develop clarified inspection requirements that will ensure safety while not being overly burdensome on the nuclear industry.
The background information can be found in the January 19, 2023, meeting summary.
As a result of the January 19, 2023, 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.
Details Bryce Lehman and Ian Tseng of the NRC acknowledged that alignment was not reached on the interpretation of existing American Society of Mechanical Engineers (ASME) Code requirements during the January 19, 2023 public meeting, and they wanted to move beyond this impasse for this meeting to focus on technical solutions to the issue, not continuing to argue about the existing requirements. They presented the following topics:
The NRC reviewed NEI-provided examples of two licensees properly expanding the scope to inaccessible areas when degradation is identified in accessible areas.
The staff had additional discussions with inspectors and licensees, and found that some licensees are planning to remove insulation from readily accessible penetrations during upcoming outages. Further, some licensees have removed and are removing this insulation to conduct the ASME Section IWE general VEs, or have sought relief for not removing the insulation.
The Office of Nuclear Reactor Regulation (NRR) issued a memorandum to the regions on March 10, 2023, providing guidance on any identified issues during ongoing generic evaluation of this issue (ADAMS Accession No. ML23046A398).
Enclosure 3
The current staff position is that these areas need to be inspected on some frequency during the life of the plant. However, the staff acknowledges the NRC position needs additional technical review and clarification.
The NRC will engage stakeholders during the Title 10 of the Code of Federal Regulations (10 CFR) 50.55a rulemaking process and in ASME Code engagement to develop a solution that balances safety and risk.
The staff reviewed past containment liner degradation based on the operating experience.
The staff may consider a future condition related to inaccessible surfaces and paragraphs IWE-1232, Inaccessible Surface Areas, or IWE-1240, Surface Areas Requiring Augmented Examination.
Thomas Basso of NEI, and Mark Ferlisi, a consultant, provided their presentation summarizing industry positions as noted below:
Licensees have not removed containment insulation to perform 10 CFR Part 50, Appendix J examinations, or the IWE general VEs required by Table IWE-2500-1, Examination Category E-A, Item E1.11.
The ASME and NRC requirements are very specific where insulation removal is required for Section XI IWE examinations, while neither specify removal of insulation for IWE-2500-1 (E-A) general VE.
NEI found that 32 of 63 NRC outage inspections covering IWE for the past 10 years included some level of review of the IWE general VE with no questions, concerns, or observations for not removing insulation, nor unresolved issues or violations, except for Quad Cities Generating Station.
The NRCs recent position is new or different from the NRC-endorsed Code, approved interpretation and code clarification, decades of industry practice, and decades of NRC enforcement history. This imposes a new or different interpretation that will require changes to structures, systems, or components (SSCs) and plant procedures.
After the NRC and NEI presentations, a brainstorming discussion was held to share and capture participant viewpoints from NEI, industry, and NRC for consideration moving forward. The discussion was summarized on screen during the discussion, and that summarized transcription is provided below. No regulatory decisions were made at this meeting.
Where to inspect?
Licenses want to maximize the bang-for-the-buck of defining readily accessible penetrations, so they have a good reliable mutual understanding.
Perhaps the current scope is appropriate. Hard to fix the issue where we do not know the issue.
What is the degradation mechanism, and does it have a significant role in what we need to inspect.
Will need to follow-up with the Code committee to appropriately determine.
Some licensees have detailed procedures that inspect every penetration, which go well above and beyond what the Code describes.
When to inspect?
Internal debate, far from final, but NRC staff have considered:
o Perhaps once an interval.
o Perhaps one-time inspection before period of extended operation.
General Discussion / Questions Should IWE-1241(b) or IWE-1242 be clarified for whether owners need to document their inspections of augmented examinations occurring in areas that are not examined, like insulated penetrations?
If an insulated penetration is marked as inaccessible, inspector concern that there still needs to be eyes on it to make sure any indicating factors can be observed and documented to be followed. If insulation remains on, we need to make sure this is happening.
The environmental conditions are probably quite benign.
Up to an owner to justify whether some of these inaccessible areas need to be inspected.
These general VEs are not easy. They take weeks. Weve started using drones. The old plants have a lot of asbestos insulation. Not as easy as walking around and just looking around. Sometimes insulation is removed and then workers forget to replace the insulation which could lead to different degradation mechanisms. These inspections are taken very seriously.
A careful understanding of what is on the drawings is needed, specifically generic drawings that show the boundaries. Let us not apply that to defining what is easy to access. There are unintended consequences too, unless there is a reason to disturb it, there are problems that could be caused by disturbing it.
Licensees could frame out what is inspectable or not in their inspection plans, with what they do and why.
IWE is always credited for license renewal. For that, the bolted-on insulation is always removed. If these inspections have not been done for the life of the plant, is this sufficient. This should be followed up on subsequent license renewal (SLR) reviews.
Results of specific exams for penetrations could be beneficial. NEI is gathering the information that is out there.
Regarding license renewal and SLR, keep in mind the purpose of Section XI. The problems need to be identified. This might not have to be resolved in IWE space. The lines between them should not be blurred.
Next IWE meeting will be in May 2023. Code is ready to support.
General VE can contribute to both identify degradation, as well as to identify changing environments that could lead to additional / different degradation.
Path Forward The NRC staff will work with external stakeholders, in 10 CFR 50.55a rulemaking space and in ASME Code space, to come up with a safety-focused solution.
Eric Benner of the NRC briefly explained the NRCs intentions on the path forward during opening remarks and concluded the meeting with closing remarks emphasizing the same.
Package: ML23095A094 Meeting Notice: ML23061A014 Meeting Slides: ML23079A263 (NRC) and ML23079A264 (NEI)
Meeting Summary: ML23095A074 *by email OFFICE NRR/DORL/LPL4/PM* NRR/DEX/ESEB/TR* NRR/DORL/LLPB/LA*
NAME SLingam BLehman DHarrison DATE 04/03/2023 04/03/2023 04/12/2023 OFFICE NRR/DEX/ESEB/BC
- NRR/DORL/LLPB/BC* NRR/DORL/LLPB/PM*
NAME ITseng GGeorge LJames DATE 04/17/2023 04/19/2023 04/21/2023