ML23191A843

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:
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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.

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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.

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.).

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ARD Procedure and Guidance 5

IP 71111.21N.04 Objective

• 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 age-related degradation for plant SCs are appropriately identified, addressed, and corrected.

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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.

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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.

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

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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.

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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.

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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.

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Scenario Discussion

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

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Q & A Session 20

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