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{{#Wiki_filter:Inspection Procedure 71111.21N.04 Age-Related Degradation Inspection Public Workshop Amar Patel and Douglas Bollock U.S. Nuclear Regulatory Commission July 18, 2023
{{#Wiki_filter:Inspection Procedure 71111.21N.04 Age-Related Degradation Inspection Public Workshop


ARD Public Meeting Agenda
Amar Patel and Douglas Bollock U.S. Nuclear Regulatory Commission July 18, 2023 ARD Public Meeting Agenda
* Why we are Inspecting Age-Related Degradation (ARD)
* Why we are Inspecting Age-Related Degradation (ARD)
* ARD Inspection Procedure Requirements and Guidance
* ARD Inspection Procedure Requirements and Guidance
Line 23: Line 23:
* Run through inspection scenarios
* Run through inspection scenarios
* Industry comments/Public Comments
* Industry comments/Public Comments
* Question and Answer Period 2
* Question and Answer Period


Why Are We Inspecting ARD?
2 Why Are We Inspecting ARD?
* NRCs engineering inspection working group in 2017 identified aging-related degradation as an overall gap in the engineering inspections.
* NRCs engineering inspection working group in 2017 identified aging-related degradation as an overall gap in the engineering inspections.
* This inspection is meant to cover age related degradation in both active and passive components and address gaps and recommendations originally identified by the working group.
* This inspection is meant to cover age related degradation in both active and passive components and address gaps and recommendations originally identified by the working group.
* ARD is important to ensure structures and components continue to meet their safety function.
* ARD is important to ensure structures and components continue to meet their safety function.
* Operating experience indicates issues exist regarding age related degradation.
* Operating experience indicates issues exist regarding age related degradation.
3


Applicable Regulations
3 Applicable Regulations
* 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (also known as the Maintenance Rule) help to assure proper plant maintenance and enhanced plant safety, particularly as plants age.
* 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (also known as the Maintenance Rule) help to assure proper plant maintenance and enhanced plant safety, particularly as plants age.
* NRC also has many individualized requirements relative to maintenance (e.g., 10 CFR 50.34(b)(6)(iv) final safety analysis report (FSAR), 10 CFR 50.36 technical specifications (TS), 10 CFR 50.49 environmental qualifications for electrical equipment, 10 CFR 50.55a inservice testing (IST) and inservice inspection (ISI) requirements, 10 CFR Part 50 Appendix B quality assurance, 10 CFR Part 50 Appendix J primary reactor containment leakage testing, etc.).
* NRC also has many individualized requirements relative to maintenance (e.g., 10 CFR 50.34(b)(6)(iv) final safety analysis report (FSAR), 10 CFR 50.36 technical specifications (TS), 10 CFR 50.49 environmental qualifications for electrical equipment, 10 CFR 50.55a inservice testing (IST) and inservice inspection (ISI) requirements, 10 CFR Part 50 Appendix B quality assurance, 10 CFR Part 50 Appendix J primary reactor containment leakage testing, etc.).
4


ARD Procedure and Guidance 5
4 ARD Procedure and Guidance


IP 71111.21N.04 Objective
5 IP 71111.21N.04 Objective
* IP 71111.21.04 Age-Related Degradation, objectives:
* IP 71111.21.04 Age-Related Degradation, objectives:
* To verify that engineering performance and maintenance activities to address age-related degradation for structures and components (SCs) are being conducted in a manner that provides reasonable assurance of the safe operation of the plant.
* To verify that engineering performance and maintenance activities to address age-related degradation for structures and components (SCs) are being conducted in a manner that provides reasonable assurance of the safe operation of the plant.
* To verify that age-related degradation for plant SCs are appropriately identified, addressed, and corrected.
* To verify that age-related degradation for plant SCs are appropriately identified, addressed, and corrected.
6


General Guidance Section 02.01 Sample Selection
6 General Guidance Section 02.01 Sample Selection
* The Inspectors will request the licensee to make available:
* The Inspectors will request the licensee to make available:
  - Site specific functional failures, performance indicators, and corrective action documents associated with components failures related to aging, age-related, wear, abnormal wear, etc.
- Site specific functional failures, performance indicators, and corrective action documents associated with components failures related to aging, age-related, wear, abnormal wear, etc.
in the past 5 years.
in the past 5 years.
  - See Enclosure 1 to the ARD inspection procedure
- See Enclosure 1 to the ARD inspection procedure
* With the information provided, the inspection team lead will select 12 to 24 ARD structures or components to sample.
* With the information provided, the inspection team lead will select 12 to 24 ARD structures or components to sample.
7


General Guidance Section 02.01 Sample Selection The inspectors will consider the following for selection of an ARD sample for detailed inspection review:
7 General Guidance Section 02.01 Sample Selection
  - System Risk
  - ARD SCs with potential to be susceptible to the effects of aging, that have indicators that they have age-related issues, or are susceptible to age-accelerating phenomenon
  - SCs focused: addressing active, passive, long-lived, short-lived SSCs; focusing on those with the greatest risk significance, susceptibility to aging, and history of degradation
  - Operational Experience (industry, NRC, site specific) 8


Pre-Inspection Activities
The inspectors will consider the following for selection of an ARD sample for detailed inspection review:
- System Risk
- ARD SCs with potential to be susceptible to the effects of aging, that have indicators that they have age-related issues, or are susceptible to age-accelerating phenomenon
- SCs focused: addressing active, passive, long-lived, short-lived SSCs; focusing on those with the greatest risk significance, susceptibility to aging, and history of degradation
- Operational Experience (industry, NRC, site specific)
 
8 Pre-Inspection Activities
* Discuss inspection with licensee staff and obtain information needed to perform inspection.
* Discuss inspection with licensee staff and obtain information needed to perform inspection.
* Potential bagman trip to site.
* Potential bagman trip to site.
* Coordinate inspection logistics (site access, badging, inspection team space) with licensee.
* Coordinate inspection logistics (site access, badging, inspection team space) with licensee.
* Early, open communications between NRC inspection staff and licensee staff is key to successful and efficient inspection implementation.
* Early, open communications between NRC inspection staff and licensee staff is key to successful and efficient inspection implementation.
9


Inspection Process Flow One month before         On-site activities Three months before     the inspection, the         begin, ARDs the inspection   team leader visits the  inspected. Estimated begins, the licensee site/dedication facility    direct inspection receives information     to coordinate the      effort is two weeks request             inspection          on site, one week office review Issues reviewed by       Exit meeting held, Report issuance-regional              preliminary estimated 45 days management and         observations and after exit meeting finding review panel     findings presented 10
9 Inspection Process Flow
 
One month before On-site activities Three months before team leader visits the the inspection, the begin, ARDs the inspection site/dedication facility inspected. Estimated begins, the licensee to coordinate the direct inspection receives information inspection effort is two weeks request on site, one week office review
 
Report issuance-Issues reviewed by Exit meeting held, estimated 45 days management and regional observations and preliminary after exit meeting finding review panel findings presented


EQ/POV Inspection Lessons Learned 11
10 EQ/POV Inspection Lessons Learned


EQ Lessons carried into ARD inspections
11 EQ Lessons carried into ARD inspections
* Included background guidance and regulatory basis and regulatory guidance in the inspection procedure.
* Included background guidance and regulatory basis and regulatory guidance in the inspection procedure.
* Ensured inspectors were properly interpreting each nuclear power units unique licensing basis.
* Ensured inspectors were properly interpreting each nuclear power units unique licensing basis.
* Ensured consistent communication between inspectors and NRR technical/program office.
* Ensured consistent communication between inspectors and NRR technical/program office.
* Considered the minor/more-than-minor screening examples contained in NRC guidance.
* Considered the minor/more-than-minor screening examples contained in NRC guidance.
12


POV Lessons carried into ARD inspections
12 POV Lessons carried into ARD inspections
* Identified technical and programmatic points-of-contact within the NRC.
* Identified technical and programmatic points-of-contact within the NRC.
* Enhanced training for inspectors was developed (technical/process and inspection implementation focused.)
* Enhanced training for inspectors was developed (technical/process and inspection implementation focused.)
* Tabletop dry runs performed using minor/more-than-minor examples.
* Tabletop dry runs performed using minor/more-than-minor examples.
* Findings review panel established proactively for at least the first 6 months of implementation for consistency, then as needed.
* Findings review panel established proactively for at least the first 6 months of implementation for consistency, then as needed.
13


FAQs
13 FAQs
* Q: What has been communicated to stakeholders?
* Q: What has been communicated to stakeholders?
* A: ROP monthly public meetings since July 2022
* A: ROP monthly public meetings since July 2022
  - ARD inspections is the next FEI beginning after July 2023
- ARD inspections is the next FEI beginning after July 2023
  - NRC incorporated lessons learned from EQ and POV inspection implementation 14
- NRC incorporated lessons learned from EQ and POV inspection implementation


FAQs
14 FAQs
* Q: What is publicly available in regards to ARD material?
* Q: What is publicly available in regards to ARD material?
* A: Publicly available:
* A: Publicly available:
  - Inspection Procedure IP71111.21N.04 (ML22210A107)
- Inspection Procedure IP71111.21N.04 (ML22210A107)
  - ARD implementation training (ML23138A285) 15
- ARD implementation training (ML23138A285)


FAQs
15 FAQs
* Q: What are the NRC resources uses per CGD inspection?
* Q: What are the NRC resources uses per CGD inspection?
* A: 3 NRC inspectors, 2 weeks onsite
* A: 3 NRC inspectors, 2 weeks onsite
  - 210 hrs of direct inspection 16
- 210 hrs of direct inspection


FAQs
16 FAQs
* Q: Will each operating reactor site receive an ARD Inspection?
* Q: Will each operating reactor site receive an ARD Inspection?
* A: Yes.
* A: Yes.
17


FAQs
17 FAQs
* Q: Will there be other public workshops?
* Q: Will there be other public workshops?
* A: Staff is open to date and location and will consider any input received.
* A: Staff is open to date and location and will consider any input received.
  - This is the second public workshop.
- This is the second public workshop.
18


Scenario Discussion
18 Scenario Discussion
* Discuss 2 scenarios of ARD issues and how the NRC staff would assess them.
* Discuss 2 scenarios of ARD issues and how the NRC staff would assess them.
19


Q & A Session 20
19 Q & A Session
 
20 For additional information, contact
 
Amar Patel Amar.Patel@nrc.gov
 
Doug Bollock Douglas.Bollock@nrc.gov


For additional information, contact Amar Patel Amar.Patel@nrc.gov Doug Bollock Douglas.Bollock@nrc.gov 21}}
21}}

Revision as of 19:26, 13 November 2024

Age-Related Degradation July 18, 2023 Public Meeting Presentation Slides
ML23191A843
Person / Time
Issue date: 07/18/2023
From: Douglas Bollock, Amar Patel
NRC/NRR/DRO/IRIB
To:
References
Download: ML23191A843 (1)


Text

Inspection Procedure 71111.21N.04 Age-Related Degradation Inspection Public Workshop

Amar Patel and Douglas Bollock U.S. Nuclear Regulatory Commission July 18, 2023 ARD Public Meeting Agenda

  • Why we are Inspecting Age-Related Degradation (ARD)
  • ARD Inspection Procedure Requirements and Guidance
  • Lessons Learned from Previous Inspections
  • Run through inspection scenarios
  • Industry comments/Public Comments
  • Question and Answer Period

2 Why Are We Inspecting ARD?

  • NRCs engineering inspection working group in 2017 identified aging-related degradation as an overall gap in the engineering inspections.
  • This inspection is meant to cover age related degradation in both active and passive components and address gaps and recommendations originally identified by the working group.
  • ARD is important to ensure structures and components continue to meet their safety function.
  • Operating experience indicates issues exist regarding age related degradation.

3 Applicable Regulations

  • 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (also known as the Maintenance Rule) help to assure proper plant maintenance and enhanced plant safety, particularly as plants age.

4 ARD Procedure and Guidance

5 IP 71111.21N.04 Objective

  • To verify that engineering performance and maintenance activities to address age-related degradation for structures and components (SCs) are being conducted in a manner that provides reasonable assurance of the safe operation of the plant.
  • To verify that age-related degradation for plant SCs are appropriately identified, addressed, and corrected.

6 General Guidance Section 02.01 Sample Selection

  • The Inspectors will request the licensee to make available:

- Site specific functional failures, performance indicators, and corrective action documents associated with components failures related to aging, age-related, wear, abnormal wear, etc.

in the past 5 years.

- See Enclosure 1 to the ARD inspection procedure

  • With the information provided, the inspection team lead will select 12 to 24 ARD structures or components to sample.

7 General Guidance Section 02.01 Sample Selection

The inspectors will consider the following for selection of an ARD sample for detailed inspection review:

- System Risk

- ARD SCs with potential to be susceptible to the effects of aging, that have indicators that they have age-related issues, or are susceptible to age-accelerating phenomenon

- SCs focused: addressing active, passive, long-lived, short-lived SSCs; focusing on those with the greatest risk significance, susceptibility to aging, and history of degradation

- Operational Experience (industry, NRC, site specific)

8 Pre-Inspection Activities

  • Discuss inspection with licensee staff and obtain information needed to perform inspection.
  • Potential bagman trip to site.
  • Coordinate inspection logistics (site access, badging, inspection team space) with licensee.
  • Early, open communications between NRC inspection staff and licensee staff is key to successful and efficient inspection implementation.

9 Inspection Process Flow

One month before On-site activities Three months before team leader visits the the inspection, the begin, ARDs the inspection site/dedication facility inspected. Estimated begins, the licensee to coordinate the direct inspection receives information inspection effort is two weeks request on site, one week office review

Report issuance-Issues reviewed by Exit meeting held, estimated 45 days management and regional observations and preliminary after exit meeting finding review panel findings presented

10 EQ/POV Inspection Lessons Learned

11 EQ Lessons carried into ARD inspections

  • Included background guidance and regulatory basis and regulatory guidance in the inspection procedure.
  • Ensured inspectors were properly interpreting each nuclear power units unique licensing basis.
  • Ensured consistent communication between inspectors and NRR technical/program office.
  • Considered the minor/more-than-minor screening examples contained in NRC guidance.

12 POV Lessons carried into ARD inspections

  • Identified technical and programmatic points-of-contact within the NRC.
  • Enhanced training for inspectors was developed (technical/process and inspection implementation focused.)
  • Tabletop dry runs performed using minor/more-than-minor examples.
  • Findings review panel established proactively for at least the first 6 months of implementation for consistency, then as needed.

13 FAQs

  • Q: What has been communicated to stakeholders?
  • A: ROP monthly public meetings since July 2022

- ARD inspections is the next FEI beginning after July 2023

- NRC incorporated lessons learned from EQ and POV inspection implementation

14 FAQs

  • Q: What is publicly available in regards to ARD material?
  • A: Publicly available:

- Inspection Procedure IP71111.21N.04 (ML22210A107)

- ARD implementation training (ML23138A285)

15 FAQs

  • Q: What are the NRC resources uses per CGD inspection?
  • A: 3 NRC inspectors, 2 weeks onsite

- 210 hrs of direct inspection

16 FAQs

  • Q: Will each operating reactor site receive an ARD Inspection?
  • A: Yes.

17 FAQs

  • Q: Will there be other public workshops?
  • A: Staff is open to date and location and will consider any input received.

- This is the second public workshop.

18 Scenario Discussion

  • Discuss 2 scenarios of ARD issues and how the NRC staff would assess them.

19 Q & A Session

20 For additional information, contact

Amar Patel Amar.Patel@nrc.gov

Doug Bollock Douglas.Bollock@nrc.gov

21