ML23283A120
| ML23283A120 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2023 |
| From: | Joseph Sebrosky NRC/NRR/DANU/UARP |
| To: | |
| Shared Package | |
| ML23283A092 | List: |
| References | |
| DANU-ISG-2022-07 | |
| Download: ML23283A120 (1) | |
Text
Month Year Analysis of Public Comments on Draft ISG DANU-ISG-2022-07 Advanced Reactor Content of Application Project Risk-Informed Inservice Inspection/Inservice Testing Programs for Non-LWRs Comments on the draft interim staff guidance (ISG) are available electronically at http://www.nrc.gov/reading-rm/adams.html. From this page, the public can access the Agencywide Documents Access and Management System (ADAMS), which provides text and image files of the U. S.
Nuclear Regulatory Commission (NRC) public documents. The following table lists the comments the NRC received on the draft ISG.
Comment Number ADAMS Accession Number Commenter Affiliation Commenter Name NRC-2022-0080 - DRAFT 0002 ML23167A092 Hybrid Power Technologies LLC Michael F. Keller NRC-2022-0080 - DRAFT 0003 ML23194A205 Hybrid Power Technologies LLC Michael F. Keller NRC-2022-0080 - DRAFT 0004 ML23205A052 POMO 18 Consult LLC A. Thomas Roberts III NRC-2022-0075 - DRAFT 0004 ML23234A052 X Energy, LLC Travis Chapman NRC-2022-0074 - DRAFT 0006 ML23234A039 Nuclear Energy Institute Ben Holtzman Comment Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0080 -
DRAFT 0002 - 1 Regulations.gov Site Not Applicable Include in regulations.gov, as downloadable files, all documents for which public comments are being solicited The NRC staff responded to the request as documented in ML23174A004. The response states in part:
the regulations.gov website identifies the documents (the Advanced Reactor Content of Application Project (ARCAP) ISGs and the Technology Inclusive Content of Application
2 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response Project (TICAP) Draft Guide (DG)) for which the NRC staff is seeking public comment.
While the Federal Register notices for the ARCAP ISGs reference NRC-issued, approved, or endorsed documents, the NRC staff is only requesting comment on the ARCAP ISGs proposed use of the referenced documents, and not the referenced documents themselves. As such, the NRC staff will not be providing documents referenced in the ARCAP ISGs on regulations.gov as this could imply that the NRC staff is seeking comments on these documents.
DRAFT 0002 - 1 Extension of Comment Period Not Applicable Alter the Federal Register notices to establish a reasonable, staggered schedule for document review and comment by the public.
The NRC staff responded to the request as documented in ML23174A004. As a result of this request and request from the Nuclear Energy Institute (NEI) (ML23171B098), the NRC staff extended the comment period for nine interim staff guidance documents and DG-1404, revision 0, from July 10, 2023, to August 10, 2023.
NRC-2022-0080 DRAFT-0003-1a (Cover letter)
Application of Industry Codes and Standards General Staff guidance should identify the applicable industry codes and standards while stating that the staff review shall be limited to the applicants conformance with the industry codes and standards. Why does NRC have to endorse industry codes and standards?
The NRC staff disagrees with the comment.
NRC staff guidance does identify applicable NRC-endorsed industry codes and standards.
For example, see page 8 of the ISG which references American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code,Section XI, Division 2. NRC endorsement of codes/standards, which can include specific conditions, is necessary as a way to acknowledge agreement with and, if
3 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response necessary, modify the code/standard to resolve specific issues not adequately addressed in the code/standard. The NRC staff review is not limited to conformance with codes and standards because there may be topics outside the scope of the code/standard that are relevant to safety.
No change has been made to the ISG.
NRC-2022-0080 DRAFT -
0003 - 1 Future versions of ASME codes Pg 3-1st para Proposed revision of 1st sentence to reference applicable ASME codes, list applicable topic areas and delete reference to future versions of ASME OM-2.
The NRC staff agrees that listing up front the applicable ASME codes would highlight the prominent role of the codes in the ISG.
The first paragraph on page 3 of the ISG has been modified as follows to list ASME Code used in the ISG. Add the following after the first sentence in the paragraph:
The ISG utilizes and supplements the requirements contained in ASME Code:
Section XI, Division 2, Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants, for risk-informed ISI programs.
Reference to future ASME OM-2 is only intended to alert future reviewers to check and use the latest version of the code, when issued.
NRC-2022-0080 ISI purpose statement Pg 3-2nd para Delete paragraph and replace with The purpose of ISI program is to maintain the operation of nuclear power plants and return The NRC staff partially agrees with the comment.
4 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response DRAFT-0003 - 2 the plants to service following plant outages.
The ISI program provides evidence to adequately manage deterioration and aging effects.
This sentence comes from the ASME code.
Do not agree with deleting 2nd paragraph. It provides context regarding the scope and approach being taken in the ISG. Adding the suggested sentence to the 2nd paragraph is acceptable since it provides the ASME perspective.
The suggested sentence was added to the 2nd paragraph as follows:
The purpose of a risk-informed ISI program is to maintain the operation of nuclear power plants and return the plants to service following plant outages. The ISI program provides evidence to adequately manage deterioration and aging effects. This is done by periodically monitoring and tracking degradation (defects, corrosion, erosion) in welds and base metal of components and component supports within the programs scope to determine their suitability for continued operation, consistent with the plant-specific probabilistic risk assessment (PRA).
NRC-2022-0080 DRAFT-0003 - 3 IST purpose statement Pg 3-3rd para Delete 3rd paragraph and replace with The purpose of an IST program is to provide adequate evidence of power plant operational readiness.
The NRC staff partially agrees with the comment.
Do not agree with deleting 3rd paragraph. It provides context regarding the scope and approach being taken in the ISG. Agree with adding an additional sentence to the 3rd paragraph for consistency with ASME Section XI, Division 2.
5 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response Additional sentence added after the 1st sentence in the 3rd paragraph as follows:
In addition, the IST [Inservice Testing]
Program provides a portion of the evidence utilized to confirm operational readiness.
NRC-2022-0080 DRAFT-0003-4 Passive components Pg 4-1st section Delete section Components that Control Fluid without Mechanically Interacting with the Fluid. ASME establishes ISI requirements. Introduction of staff versions of ASME Code elements is potentially problematic.
The NRC staff disagrees with the comment.
This section addresses a topic not specifically addressed by ASME, but is important for non-light water reactors (non-LWRs) that use passive or non-conventional means to accomplish active safety functions.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003-5 Personnel hazards Pg 4-2nd section Delete section ISI/IST Personnel Hazards for Some Non-LWR Designs. The ASME code covers this issue.
The NRC staff disagrees with the comment.
ASME does not address Inservice Inspection (ISI) for non-LWRs in a prescriptive fashion, but rather allows the applicant develop the program in accordance with Section XI, Division 2. ASME has not issued guidance for non-LWR IST. This section is intended to highlight a safety concern regarding personnel safety when developing their ISI/IST programs.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003-6 Risk information Pg 4-3rd section Delete section Use of Risk Information.
The ASME Code covers this issue.
The NRC staff disagrees with the comment.
This section does not detract from or modify the ASME Code. It is intended to highlight the
6 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response importance of using risk information in the development of the ISI/IST programs.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003-7 Use of 50.69 Pg 5-1st para Replace entire paragraph with a simple reference to 10 CFR 50.69 and caution that the applicant must establish safety classes, level of risk and linkage to inservice programs. Appears staff is setting to impose in-service requirements that are well removed from proportionate radiation risk to the public.
The NRC staff disagrees with the comment.
Paragraph provides an explanation as to how 50.69 can be used in the development of a risk-informed ISI program. Paragraph is intended to avoid confusion and, thus, improve efficiency of the review, not impose unjustified requirements.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003-8 Limited performance data Pg 5-2nd para Replace the paragraph addressing limited performance data with reference to applicable specific section of ASME Code.
The NRC staff disagrees with the comment.
Paragraph does not modify what is in the code. It only highlights the need to address cases where there is limited performance data.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003 - 9 RIS 2012-08 Pg 6-2nd para Cite the specific section of the ASME Code in lieu of citing RIS 2012-08. RIS 2012-08 cannot be used to impose requirements outside of industry codes and standards.
The NRC staff disagrees with the comment.
The reference to RIS 2012-08 is to assist the NRC reviewer by highlighting previously identified issues, not impose new requirements.
No change has been made to the ISG.
7 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0080 DRAFT-0003-10 and 11 Paragraphs relating to ISI application content Pg 7-2nd thru 5th para plus Pg 8-1st 3 para and 1st 2 para under Staff Review Guidance Delete these paragraphs and cite applicable sections of the ASME Code. Introduction of staff versions of ASME Code elements is potentially problematic.
The NRC staff disagrees with the comment.
The paragraphs in question endorse the use of ASME BPV Code,Section XI, Division 2, for developing an ISI program for non-LWRs.
They also provide guidance with respect to the use of ASME BPV Code,Section XI, Division 2, by discussing the expected scope, use of risk information and review of inspection results when using Section XI, Division 2.
This is intended to clarify the information to be included in the safety analysis report (SAR), not revise Section XI, Division 2.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003 - 12 PRA Standard Pg 9-Item (1)
Add citation of industry PRA standard The NRC staff disagrees with the comment.
If an applicant does not use the industry standard, justification must be provided.
Change made to item (1) to reference industry non-LWR probabilistic risk assessment (PRA) standard and require review of justification for any deviation from the standard as follows:
Is the application based on the use of an NRC-endorsed PRA standard, such as described in RG 1.247 and ASME/ANS RA-S-1.4-2021? Are any deviations from the RG or standard described and justified?
8 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0080 DRAFT-0003 - 13, 14, 15 and 16 ISI Review guidance Pg 9-Items (2) thru (10)
Delete. For items (2), (3) and (4) there are no such requirements in the applicable portions of the ASME Code. For items (5),
(6) and (7) requiring such detail serves no useful purpose and imposes unjustified cost.
Items (8) and (9) are included in the ASME Code and item (10) imposes requirements via a RG.
The NRC staff disagrees with the comment.
These items describe expected SAR content for the reviewer. They do not change the code, only specify the information the reviewer should identify and consider. A RG does not impose requirements. Its use is voluntary.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003 - 17 ISI Review guidance Pg 10-1st 3 para Delete and cite specific ASME Code sections. Introduces staff versions of the ASME Code.
The NRC staff disagrees with the comment.
These paragraphs describe what the reviewer should identify and consider and do not introduce staff versions of the code.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0003-18 and 19 IST Application content Pg 11 Add new paragraph after 2nd paragraph citing applicable sections from ASME OM-
- 2. Replace 3rd, 4th and 5th paragraphs with citations to ASME Code. Introduces staff versions of ASME Code.
The NRC staff disagrees with the comment.
The referenced text provides guidance, since currently, ASME OM-2 has not been formally issued.
No change has been made to the ISG at present time. Consider change when OM-2 formally issued.
NRC-2022-0080 DRAFT-0003-20 IST Application content Pg 12-1st thru 4th para Replace paragraphs with citation to specific sections of ASME OM-2. The level of detail being requested is inappropriate for general licensing information. Documentation details are governed by the programmatic provisions of the ASME Code.
The NRC staff disagrees with the comment.
ASME OM-2 has not been formally issued.
Therefore, the paragraphs in question are necessary to describe the information expected in the SAR.
9 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response No change has been made to the ISG at the present time. Consider change when OM-2 formally issued.
NRC-2022-0080 DRAFT-0003-21 and 22 IST scope statement Pg 13-1st and 2nd para Replace 1st paragraph with The scope of the IST program should include those items defined by the applicant as needed to protect the public from hazardous radiation - these items are safety-related, but may also include items of a lower safety functional level, as deemed appropriate and justified by the applicant. The applicants program should identify the major systems and components subject to IST. Alternatively, cite the applicable industry codes/standards.
Use of the term Safety-Significant is open ended and only loosely connected to risk-informed. Delete 2nd paragraph - cite applicable sections of the ASME Code.
The NRC staff disagrees with the comment.
The purpose of TICAP/ARCAP is to allow non-LWR applicants to design their plants using the Licensing Modernization Project (LMP) process while seeking a license under Parts 50/52. Application of the LMP process will identify the safety-related structures, systems, and components (SSCs) and other items to be included in the IST program. The term safety-significant is defined in NEI 18-
- 04. In addition, there is no applicable ASME Code to reference. OM-2 has not been officially issued, thus, the ISG needs to provide a description of the scope of the IST program.
No change has been made in the ISG at the present time. Consider change when OM-2 formally issued.
NRC-2022-0080 DRAFT-0003-23, 24, 25, 26 and 27 IST review guidance Pg 13-4th para Delete items (2) thru (9) and replace with citations to applicable provisions of the ASME Code. ASME Code already covers these items.
The NRC staff disagrees with the comment.
The OM-2 code has not been issued yet.
Nevertheless, the NRC staff notes that the OM-2 code as envisioned will allow the use of risk insights but will not be prescriptive on the use of these insights. For this reason, the NRC
10 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response staff concludes that the items requested to be deleted will remain to aid applicants in the preparation of applications and the NRC staff in the review of applications in this area.
No change has been made in the ISG at this time.
NRC-2022-0080 DRAFT-0003-28 IST review guidance Pg 14-1st thru 5th para Add citations to ASME Code in each paragraph. Introduction of staff versions of ASME Code elements is problematic.
The NRC staff disagrees with the comment.
Since ASME OM-2 has not been officially issued, the ISG needs to specify what the reviewer should look at.
No change has been made in the ISG at this time. Consider change when OM-2 formally issued.
NRC-2022-0080 DRAFT-0003-29 Organization responsibility Pg 15 Organizational Responsibilities - Add citations to applicable specific provisions of the ASME Code. Unclear why the provisions of the ASME Code that govern these activities are omitted.
The NRC staff disagrees with the comment.
ASME OM-2 has not been officially issued.
No change has been made in the ISG at this time. Consider change when OM-2 formally issued.
NRC-2022-0080 DRAFT-0003-30 Backfitting Pg 16 Backfitting and Issue Finality - appears NRC is attempting to use the ISG for backfitting considering the large number of new requirements outside the existing ASME Code requirements.
The NRC staff disagrees with the comment.
This ISG is applicable to future applications, which does not constitute backfitting. In addition, it does not add new requirements, but only provides flexibility for non-LWR designs to do what is appropriate for their
11 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response design and technology. At the present time, ASME OM-2 has not been issued.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0004-1 Exclusion of LWRs Pg 2 -
Footnote 2 ASME BPV Code,Section XI, Division 2, and ASME OM-2 are applicable to LWRs and non-LWRs. Why does Footnote 2 exclude LWRs? It adds confusion.
The NRC staff disagrees with the comment.
The scope of the ISI/IST ISG is limited to non-LWRs for consistency, since the foundational documents (NEI 18-04, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development, and RG 1.233, Guidance for a Technology-Inclusive, Risk-Informed, and Performance-Based Methodology to Inform the Licensing Basis and Content of Applications for Licenses, Certifications, and Approvals for Non-Light Water Reactors) supporting the risk-informed approach an d this ISG are limited to non-LWRs. At some point in the future, the ISG may be revised to include LWRs. However, the intent of Footnote 2 is to allow LWR applicants to propose using the current ISI/IST ISG now, without waiting for a future revision.
No change has been made to the ISG.
NRC-2022-0080 DRAFT-0004-2 Submittal of operational material Pg 4 - last sentence This sentence seems to imply that operational criteria (e.g., maintenance programs, aging management criteria) are to be submitted as well as the ISI/IST program material.
The NRC staff agrees with the comment.
There is an inconsistency in the wording of the sentence. The intent is for the application to describe the interface between the ISI/IST
12 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response programs and other programs that are relevant to the same SSCs, not require submittal of the interfacing programs.
Page 5 of the ISG revised to clarify that the SAR only needs to describe the interface, if any, between the ISI/IST programs and other programs by adding the following sentence at the end of the partial paragraph at the top of the page:
The intent is to identify the interfaces between the ISI/IST programs and other programs that have incorporated some aspects of ISI/IST, but does not require the other programs be submitted as part of the ISI/IST submittal.
NRC-2022-0080 DRAFT-0004-3 Use of 50.69 Pg 5-First full para The last sentence in this paragraph states For non-LWR applicants that propose to use 10 CFR 50.69 to risk-inform their ISI/IST programs, justification must be provided showing how the resulting RISC-3 and 4 SSCs were derived from the PRA. It is not obvious how the criteria of 50.69 would be applied to a risk-informed ISI program developed using ASME BPV Code,Section XI, Division 2. Also, the paragraph includes reference to 10 CFR 50.55a requirements, which are for LWRs.
Additional guidance is needed to explain how to implement this paragraph.
The NRC staff disagrees with the comment.
As indicated in 10 CFR 50.69(b), the NRC regulations in 10 CFR 50.69 are focused on water-cooled reactors with references to several special treatment requirements in various parts and sections of Title 10 of the Code of Federal Regulations. The paragraph in the ISG is intended to alert non-LWR applicants to the 10 CFR 50.69 approach for applying risk insights for the treatment of SSCs in nuclear power plants. A non-LWR applicant would need to determine whether an approach similar to that described in 10 CFR 50.69 might be justifiable for application to its specific non-LWR design.
13 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response No change has been made to the ISG.
NRC-2022-0080 DRAFT 0004-4 RIS 2012-08 Pg 6 - 2nd full para a) RIS 2012-08 is referred to in the paragraph. RIS 2012-08 applies to applications submitted under Part
- 52. Is it intended that RIS 2012-08 also be applied to applications under Part 50?
b) The paragraph includes snubbers in the components to be considered when reviewing RIS 2012-08. Why are snubbers the only components mentioned? What about other load carrying devices such as, flexible pipe supports, and slidding shoe supports that might be critical for safe operation?
a) The NRC staff agrees with the comment.
ISG modified to state that the guidance in RIS 2012-08, Developing inservice testing and inservice inspection programs under 10 CFR Part 52, applies to both Part 50 and Part 52 applicants.
b) The NRC staff agrees with the comment. The Note in the ISG is a reminder that RIS 2012-08 can be applied to various components beyond pumps and valves. The note has been reworded to read as follows: Note:
the reviewer should consider all the components described in RIS 2012-
- 08.
NRC-2022-0080 DRAFT 0004-5(A) and 5(B)
Use of term Safety-Significant Pg 7 - 3rd and 4th para These paragraphs use the term safety-significant. The use of this term should either be withdrawn or clarified by defining it.
The NRC staff agrees with the comment.
The term is defined in NEI 18-04, Risk-Informed Performance-Based Technology Inclusive Guidance for Non-Light Water Reactor Licensing Basis Development.
The first use of safety-significant in the ISG has been revised to reference NEI 18-04 for the definition.
14 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response NRC-2022-0080 DRAFT 0004-5(C)
Actions if degradation detected Pg 7 - last para This paragraph contains guidance on the process to be followed when the ISI program identifies degradation has occurred.
ASME BPV Code,Section XI, Division 2, already provides guidance in this area. Is the ISG attempting to augment the ASME standard?
The NRC staff disagrees with the comment.
The paragraph is to provide the general requirements for the process when the degradation is identified. Following this general discussion, the next paragraph points out that ASME,Section XI, Division 2, provides guidance in this area.
No change has been made to the ISG.
NRC-2022-0080 DRAFT 0004-6(A)
(Is misnumbered as 4(A) in the comment letter)
Clarification needed in 2nd para Pg 8 - 2nd para When discussing the use of ASME BPV Code,Section XI, Division 2, this paragraph contains the statement Section XI, Division 2, does not call for a specific risk-informed ISI program to be implemented. The purpose of this statement is not clear and is confusing.
The NRC staff agrees with the comment.
Sentence has been modified to read:
Section XI, Division 2, allows the applicant to propose a program specific to the design and technology of the non-LWR, based on input from expert panels and considering the degradation mechanisms relevant to the materials and operating conditions of the design.
NRC-2022-0080 DRAFT 0004-6(B)
(Is misnumbered as 4(B) in the comment letter)
Temperature range for flaw evaluation Pg 8 - 3rd para This paragraph notes that the acceptance criteria specified in ASME BPV Code,Section XI, Division 2, for flaw evaluation only applies to the temperature range allowed in ASME BPV Code,Section III.
ASME will soon issue a flaw evaluation Code Case extending the acceptance criteria into the elevated temperature range. This should be acknowledged in the ISG.
The NRC staff agrees with the comment.
The third paragraph on page 8 has been modified to note the future Code Case.
NRC-2022-0080 ISI scope statement Pg 8 - 4th para The ISI scope statement provided in this paragraph does not provide insight for The NRC staff disagrees with the comment.
15 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response DRAFT 0004-6(C)
(Is misnumbered as 4(C) in the comment letter) anticipated critical SSCs which are not pressure retaining nor are classic supports.
The critical SSCs which are not pressure retaining nor are classic supports are covered by the piping or other components whose failure could prevent SSCs from performing their safety functions and all safety-related and safety-significant piping and components. Critical SSCs vary with different designs. The ISG is not intended to provide specific information about these components.
No change has been made to the ISG.
NRC-2022-0080 DRAFT 0004-6(E) (Is misnumbered as 4(E) in the comment letter)
Too much LWR orientation Pg 8 - 5th para Some aspects of the ISG were drafted in consideration of the historic LWR ISI framework. For example, there is emphasis on examining welds, which is relevant for LWRs. Non-LWR degradation mechanisms may affect other aspects of the design due to the higher temperatures and use of corrosive coolants. It is suggested that the language used in the ISG be restructured so as not to limit the technical basis to LWR experience.
The NRC staff agrees with the comment.
The fifth paragraph on page 8 has been revised as follows:
The reviewer should confirm that the PRA models all of the SSCs that are part of the ISI program and consider the degradation mechanisms associated with the materials, temperature, and coolant used in the design models the piping in segments to identify the most risk significant piping sections and welds.
NRC-2022-0080 DRAFT 0004-6(D)
(Is misnumbered as 4(D) in Addition of other materials to the ISI prog.
General ASME BPV Code,Section III, Division 5, permits the use of graphite and ceramic composite materials for structural application during construction. Non-LWRs may use some of these materials and they should be an integral part of the ISI program.
The NRC staff disagrees with the comment.
The ISG does not exclude the inspection of graphite and ceramic composite materials, which is an integral part of the ISI program. It is the applicant's responsibility to use the
16 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response the comment letter) results from the licensing modernization project (LMP) process in accordance with NEI 18-04, revision 1 and RG 1.233 to identify whether the graphite and ceramic composite materials in their design warrants an ISI program and to identify the ISI needed to ensure that the graphite and ceramic composite materials continues to meet their intended function throughout the life of the plant.
No change has been made to the ISG.
NRC-2022-0080 DRAFT 0004-7 (Is misnumbered as 4 in the comment letter)
Use of NQA-1 Pg 9 -
Item (9)
This item implies the use of 10 CFR Part 50, Appendix B, for QA. ASME BPV Code,Section XI, Division 2, requires the use of NQA-1. Does the ISG intend that Appendix B should be used in lieu of NQA-1? If so, would an exemption to Section XI, Division 2, be required?
The NRC staff agrees with the comment.
The NRC regulations in 10 CFR 50.55a(b)(1)(iv), (b)(2)(x), and (b)(3)(i) for ASME BPV Code, Sections III and XI, and the ASME OM Code, respectively, indicate that where NQA-1 does not address the commitments contained in the licensees Appendix B quality assurance program description, the commitments must be applied to the ASME Code activities. In accepting the use of ASME BPV Code,Section XI, Division 2, NRC RG 1.246 states in Regulatory Position 6 that licensees should use an edition of ASME NQA-1 endorsed by the NRC in RG 1.28 and the ASME/ANS RA-S-1.4-2021 edition endorsed with conditions in Trial Use RG 1.247. The ISG is intended to be consistent with these regulatory requirements and guidance.
17 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response Item # 9 on page 9 of the ISG has been changed to read as follows: Is the QA to be applied to the program in accordance with 10 CFR Part 50, Appendix B, or NQA-1 as endorsed by RG 1.246, Regulatory Position 6?
NRC-2022-0080 DRAFT 0004-8 (Is misnumbered as 5 in the comment letter)
Timely ISG updates General ASME is working to issue OM-2 this year and to issue other relevant guidance to address gaps in the existing Section XI, Division 2. How does NRC intend to provide timely reviews of new ASME code documents and issue timely revisions of the ISG?
The NRC staff is currently working to review the ASME OM-2 Code for acceptance in a new regulatory guide as soon as the new Code is available. The staff will update the ISG as needed with the issuance and acceptance of new ASME code documents in a timely manner.
NRC-2022-0075 DRAFT 0004-33 Use of future codes Pg 3-Guidance The ISG acknowledges that ASME is developing code OM-2 for IST in non-LWRs. In addition, on page 11, it is stated that a CP application should identify the regulations, RGs, NUREGs, standards and other guidance the applicant intends to follow at the OL stage.
Add guidance that CP applicants may follow the ISG and, at their own risk, identify codes not yet issued to be followed at the OL stage.
The NRC staff agrees with the comment.
The first paragraph on page 3 under Guidance has been revised to allow construction permit (CP) applicants, at their own risk, to identify codes not yet issued to be followed at the operating license (OL) stage, provided the applicant is not asking for design finality in the areas affected by the draft codes. The following sentences have been updated to provide additional clarification:
CP applicants may use codes and standards the NRC staff has not endorsed at their own risk. Nonetheless, a subsequent OL application must reference NRC staff-approved codes and standards or justify the use of codes and standards the NRC staff has not previously approved. Further, the NRC staff will consider
18 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response granting design finality requested for unendorsed codes or standards in a CP application only if the application includes information sufficient for the NRC staff to approve the use the code or standard for the purpose requested in the application. Any areas of the design affected by the draft codes is not eligible for a design finality determination.
NRC-2022-0074 DRAFT 0006-1 Applicability to LWRs General This comment is identical to comment NRC-2022-0074 - DRAFT 0006-1 on the Roadmap ISG.
See response to comment NRC-2022-0074 -
DRAFT 0006-1 on the Roadmap ISG.
NRC-2022-0074 DRAFT 0006-2 Design Considerations General There are a few references to design considerations of the facility to allow ISI/IST activities to be performed when operating. Recommend that design specifics be placed in the applicable GDCs and not an inservice testing/inspection document.
The NRC staff disagrees with the comment.
Applicants are to propose principal design criteria (PDCs) applicable to their designs and the PDCs are to consider operation. If an applicant needs the design to incorporate provisions for ISI/IST during operation, the PDCs should reflect that. NRC cannot pre-determine the PDC content.
No change has been made to the ISG.
NRC-2022-0074 DRAFT 0006-3 Guidance for ISI/IST for ML applicants General ISI/IST are operating reactor programs and, therefore, not directly applicable to MLs which do not address operation. However, the ISG could provide guidance on using the PRA to identify the SSCs that would be part of the ISI program which would then be used in the design to ensure adequate accessibility for inspection.
The NRC staff agrees with the comment.
The following sentence has been added to the paragraph titled Use of Risk Information on page 4 of the ISG:
For ML [manufacturing license] applicants, the application can be limited to describing how the risk information will be used to
19 Comment Identifier Topic Section of Document Specific Comments NRC Staff Response identify the SSCs to be included in the ISI/IST programs, the most risk-significant locations for ISI and ensure the design incorporates sufficient access for ISI/IST equipment and personnel.
NRC-2022-0074 DRAFT 0006-4 Use of Future Codes Pg 3 This is the same as comment NRC-2022-0080 DRAFT-0004-1 above.
See response to comment NRC-2022-0080 DRAFT-0004-1 above.
NRC-2022-0074 DRAFT 0006-5 Multi-Module Plants Pgs 4+5 For plants that are factory built and scalable, it would be beneficial to only have a single IST program that is also scalable, assuming the PRA is generic to the design.
The NRC staff agrees with the comment.
No specific change was proposed. However, to address the comment, the following sentence has been added to the Use of Risk Information paragraph on page 4:
For multi-module plants, where the PRA and design are identical for each module, the ISI/IST programs developed need only be submitted once and can be applied to each module.
NRC-2022-0074 DRAFT 0006-6 Use of ASME Codes Pg 7 This is the same as comment 0004-5(C) above.
See response to comment 0004-5(C) above.