ML25078A179
| ML25078A179 | |
| Person / Time | |
|---|---|
| Site: | Electric Power Research Institute |
| Issue date: | 05/09/2025 |
| From: | Lois James Licensing Processes Branch |
| To: | Jennivine Rankin Licensing Processes Branch |
| References | |
| EPID L-2025-LRM-0030 pre-app | |
| Download: ML25078A179 (1) | |
Text
MEMORANDUM TO:
Jennie Rankin, Acting 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 MEETING ON TOPICAL REPORT FOR INDUSTRYS PROPOSAL FOR A CONSOLIDATED APPROACH TO PERFORMANCE MONITORING FOR THE OPTIMIZATION OF NONDESTRUCTIVE EXAMINATION REQUIREMENTS FOR PRESSURIZED WATER REACTOR STEAM GENERATORS AND PRESSURIZERS (EPID L-2025-LRM-0030)
On April 2, 2025, the U.S. Nuclear Commission (NRC) staff met with Electric Power Research Institute to discuss Industrys Proposal for a Consolidated Approach to Performance Monitoring for the Optimization of Nondestructive Examination Requirements for Pressurized Water Reactor Steam Generators and Pressurizers. The meeting summary is Enclosure 1 and the list of attendees is Enclosure 2.
If you have any questions or comments, please contact me via e-mail at Lois.James@nrc.gov.
Docket No. 99902021
Enclosures:
1.
Meeting Summary 2.
List of Attendees CONTACT: Lois M. James, NRR/DORL/LLPB 301-415-3306 May 9, 2025 Signed by James on 05/09/25
U.S. Nuclear Regulatory Commission Public Meeting Summary
Title:
Pre-Submittal Meeting for the Topical Report on the Industrys Proposal for a Consolidated Approach to Performance Monitoring for the Optimization of Nondestructive Examination (NDE) Examination Requirements for Pressurizer Water Reactor Steam Generators and Pressurizers Date of Meeting: April 2, 2025, 1:00 pm - 5:00 pm Location:
Hybrid Type of Meeting: This was an Observation Meeting in which attendees were given an opportunity to observe the U.S. Nuclear Regulatory Commission (NRC) performing its regulatory function or discussing regulatory issues. Attendees had an opportunity to ask questions of the NRC staff and to make comments about the issues discussed following the business portion of the meeting; however, the NRC was not actively soliciting comments toward regulatory decisions at this meeting.
Purpose of the Meeting: To discuss the industrys proposal for a consolidated approach to performance monitoring for the optimization of nondestructive examination (NDE) requirements for pressurized water reactor (PWR) steam generators (SGs) and pressurizers General Details: The NRC staff held a public, observational meeting with Electric Power Research Institute (EPRI) to discuss industrys proposal for a consolidated approach to performance monitoring for the optimization of NDE examination requirements for PWR SGs and pressurizers. The meeting began at 1:00 pm and ended at 3:40 pm. There were twenty-four NRC staff, three EPRI representatives and contractor, seven industry representatives, and four members of the public. The meeting began with introductions of the NRC staff and EPRI representatives.
Summary of Meeting:
EPRI representatives began the presentation by stating that the objective of the topical report (TR) is to present the comprehensive performance monitoring inspection plan for the U.S. nuclear industry for optimizing the SG and pressurizer components American Society of Mechanical Engineer (ASME) inservice inspections (ISIs). EPRI representatives explained that, based on 61 operating units with an average operating age of 40 years, the U.S. nuclear industry has approximately 2400 years of operating experience under the ASME ISI which are specified regiment of examinations for both the SG and pressurizer for each operating unit.
Based on this extensive operating experience, EPRI conducted research into how to optimize these examinations over the U.S. nuclear fleet, instead of over a single unit or utility. EPRI representatives stated that this research has led to this TR and the optimization of the ASME code inspections. EPRI representatives stated that the U.S. nuclear industry started with pilot plant applications to assess the feasibility of the technical bases and request for alternative process. EPRI made these technical bases document publicly available:
EPRI 3002014590, Technical Bases for Inspection Requirements for PWR Steam Generator Feedwater and Main Steam Nozzle-to-Shell Welds and Nozzle Inside Radius Sections (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19347B107)
EPRI 3002015906, Technical Bases for Inspection Requirements for PWR Steam Generator Class 1 Nozzle-to-Vessel Welds and Class 1 and Class 2 Vessel Head, Shell, Tubesheet-to-Head, and Tubesheet-to-Shell Welds (ADAMS Accession No. ML20225A141)
EPRI 3002023713, Technical Bases for Inspection Requirements for PWR Steam Generator Auxiliary Feedwater Nozzle-to-Shell Welds (publicly available on EPRI.com)
EPRI 3002015905, Technical Bases for Inspection Requirements for PWR Pressurizer Vessel Head, Shell -to-Head, and Nozzle-to-Vessel Welds (ADAMS Accession No. ML21021A271)
In addition, EPRI representatives explained that to establish that baseline of inspection schedules, they needed to understand where each unit was within their ASME ISI interval, the inspections each unit performed, and what ASME ISI inspection each unit has remaining through their current operating license.
EPRI representatives highlighted two criteria used to develop an optimized ISI inspection over the U.S. nuclear fleet:
Using the binomial distribution model which produced roughly a 25 percent sampling criterion of the current baseline for ISI inspections.
Having sufficient continuous collection of examination data points across the operating fleets licensing period for the current operating license.
EPRI representatives explained that they conducted a survey of the current operating units to gather the necessary information to aggregate, compile, and tabulate the numbers that are necessary to satisfy or to meet the two criteria previously noted. EPRI representatives further explained that in order to ensure the U.S. nuclear fleet ISI inspections do not fall below the binomial distribution model of roughly 25 percent, they established a goal of 38 percent to add conservatism.
EPRI representatives stated that the NDE optimization analysis to be submitted in the upcoming TR stops at 80 years of plant operation. The analysis could be recalculated using 100 or 120 years of plant operation to see if the number of ISI inspections fall outside the bounds of that safety benchmark.
EPRI representatives explained that to implement the NDE optimization, licensees will need to submit a license amendment request (LAR). EPRI anticipates using the first few applications to develop an LAR template to aid future licensees in their submittals.
EPRI representatives explained that the TR itself will provide the technical basis and methodology for the fleet ISI optimization schedule. EPRI representatives further explained that the letter addendum will provide the actual schedule, including details on the inspection to be completed by each licensee during ASME ISI inspection intervals. In this way, EPRI does not see the need to update the TR on a regular basis, but will update the letter addendum based on changes.
The NRC staff described the generic TR review schedule and key assumptions:
Baseline schedule is 18 months which includes an audit and one round of requests for additional information (RAIs). The schedule can be extended or shortened based on complexity of the TR.
EPRI response times for RAIs, proprietary review of the safety evaluation, and approved version of the TR is 90 days.
The Advisory Committee on Reactor Safeguards will request subcommittee and full committee meetings.
EPRI representatives stated that they would like a 12-month schedule and believe they can reduce their response times from 90 days to 30 days. EPRI representatives further stated that they anticipate submitting the TR on June 9, 2025.
Public Participation Themes:
No member of the public spoke on the webinar.
Action Items/Next Steps:
The NRC staff will prepare and issue a meeting summary.
Attachments:
Meeting description and agenda - ADAMS Accession No. ML25092A033 Vendor slide presentation - ADAMS Accession No. ML25091A103
U.S. Nuclear Regulatory Commission Public Meeting - Attendees List April 2, 2025
Title:
Pre-Submittal Meeting for the Topical Report on the Industrys Proposal for a Consolidated Approach to Performance Monitoring for the Optimization of Nondestructive Examination Examination Requirements for Pressurizer Water Reactor Steam Generators and Pressurizers Name U.S. Nuclear Regulatory Commission (NRC) Participants Michael Benson NRC Angie Buford NRC Stephen Cumblidge NRC Robert Davis NRC James Delosreyes NRC David Dijamco NRC Emma Haywood NRC Raj Iyengar NRC Lois James NRC Varoujan Kalikian NRC Steven Levitus NRC Carol Moyer NRC Demetrius Murray NRC Eric Palmer NRC Cory Parker NRC David Rudland NRC Kris Smetana NRC Robert Tregoning NRC John Tsao NRC Christopher Ulmer NRC Sunil Weerakkody NRC Dan Widrevitz NRC John Wise NRC On Yee NRC Electric Power Research Institute (EPRI) Participants Name Affiliation James Cirilli EPRI Grizzi, Robert EPRI Garry Young EPRI Industry Participants Name Affiliation Jesse Brown Constellation Energy Jana Bergman Curtiss Wright Enclosure Mary H Miller Dominion Energy Thomas Basso Nuclear Energy Institute (NEI)
Kelli Voelsing Nuclear Energy Institute (NEI)
Nat Cofie Structural Integrity Aaron Guckenberger Xcel Energy Public Participants Name Affiliation Jacob Fakory Public Veena Gubbi Public Jonathan Zeitz Public One not identified Public
ML25078A179 (memo, (summary, Attendees) (slides are listed in summary)
^via eConcurrence
- via e-mail NRR-106 OFFICE DORL/LLPB/PM DORL/LLPB/LA DNRL/NVIB/BC DORL/LLPB/BC NAME LJames DHarrison ABuford JRankin DATE 04/15/2025 04/17/2025 04/17/2025 04/22/2025 OFFICE DORL/LLPB/PM NAME LJames DATE 5/9/2025