View source for ML19093A891

{{Adams
| number = ML19093A891
| issue date = 04/03/2019
| title = NRC Presentation for April 3 2019 OD Public Meeting
| author name = Marshall J
| author affiliation = NRC/NRR
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = Wilkins L, NRR/DLP, 415-1377
| document type = Slides and Viewgraphs
| page count = 13
}}

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{{#Wiki_filter:Operability Initiative Public Meeting NRC Staff Feedback Related To NEI 2/15/19 Presentation Jane Marshall Deputy Director, Division of Safety Systems Office of Nuclear Reactor Regulation April 3, 2019

Purpose & Agenda
* Provide feedback on the topics presented by NEI during the Feb 15 public meeting related to ASME Code & Operability
* Agenda
   - 12:00 - 12:15 Opening Comments/Intros
   - 12:15 - 02:00 NRC Presentation
   - 02:00 - 02:30 NRC/Industry Discussion
   - 02:30 - 02:45 Stakeholder Participation
   - 02:45 - 03:00 Actions Documented/Closing Remarks

Determination Of Operability Is Separate From Code Compliance
* Difference between Specified Safety Function (SSF) definitions used in draft NEI 18-03 and NRC Inspection Manual Chapter (IMC) 0326 leads to differing views
* NEI 18-03 does not include structural integrity as part of the SSF definition
* NRC Generic Letter (GL) 90-05 governs, therefore operational leakage and structural integrity issues apply to Operability, regardless of how discovered

Use Of Any Technically Acceptable Method
* Staff needs clarification regarding any technically acceptable method
* NRC is not clear that any technically acceptable method is applicable in all cases (Section XI)
* NRC suggesting a tabletop discussion using complex examples to achieve mutual understanding
* Seeking input from NRC Office of General Counsel (OGC) to ensure clear understanding of past and current regulatory positions

NRC Approval Of Alternate Methods Used
* NRC position directly related to previous slide
* Seeking input from OGC to ensure clear understanding of past and current regulatory positions

Restoration Of Compliance
* Staff agrees that restoration of compliance falls within the Corrective Action Program (CAP)
   - Regarding time requirements, licensees should plan and implement according to risk significance and ensure the requirements of IWA-4160 are met before returning systems to service that are not compliant with Section XI requirements.

Principles Were Used In The Following Sections:
* A.5 Piping and Piping Support Requirements
* A.6 Structural Requirements
* A.7 Technical Specification Operability vs.
ASME OM Code Criteria
* A.10 Flaw Evaluation

A.5 - Piping & Piping Support
* Staff agrees that the Operability Determination (OD) process is the licensees responsibility
* Inspector will utilize IMC 0326, Section C.11
* Changes to IMC 0326 Section C.11 to incorporate updated guidance
* Inspectors will continue to review the completeness and appropriateness of licensee operability determinations

A.6 - Structural Requirements
* Staff agrees that the OD process is the licensees responsibility
* Staff reiterates that NRC is always speaking to the IMC 0326 definition of SSF
* Licensees are expected to document and justify, consistent with any regulatory requirements, any standard or any value that deviates from the Current Licensing Basis (CLB)

A.7 - TS Operability vs. OM Code
* Staff disagrees with industrys position taken because Technical Specification (TS) incorporate In-Service Testing (IST) requirements
* TS have Surveillance Requirements (SR) and criteria that state that a licensee must comply with the IST program specifications
* The requirements of OM Code Sections ISTB-6200 and ISTC-5153 are to be followed for IST failures

A.10 - Flaw Evaluation
* Staff agrees that Operability SHALL be assessed when American Society Mechanical Engineers (ASME) Class 1, 2, or 3 components do not meet ASME or construction Code acceptance standards (this includes wall thinning)
* Staff agrees that operational leakage in ASME Class 1, 2, or 3 components are a deficient/non-conforming condition and that Reactor Coolant System (RCS) leakage is covered by TS

Future Endeavors
* Future Engagement
   - Public call to occur following input from OGC to ensure clear understanding of past and current regulatory positions
   - Tabletop exercises using complex examples provided by both industry and NRC staff (May timeframe at NRC HQ)
   - Public meeting to discuss open items/deltas and respective documents (June timeframe - Location TBD)
* Staff preparing revisions to IMC 0326
   - Final draft revision prepared - Sept 2019
   - Staff to schedule public meeting to solicit external stakeholder feedback
   - Final revision issued - Oct 2019

Discussion
* Clarification questions from industry?
* Comments from industry?
* Open Discussion
* Action items, if any, documented}}