ML12114A010

Nuclear Regulatory Commission Regulatory Issue Summary 2012-08: Developing Inservice Testing and Inservice Inspection Programs Under 10 CFR Part 52

ML12114A010
Person / Time
Issue date:	07/16/2012
From:	Laura Dudes, Mcginty T NRC/NRO/DE/CIB, Division of Policy and Rulemaking
To:
Steingass T
References
RIS-12-008
Download: ML12114A010 (8)

See also: RIS 2012-08

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NEW REACTORS

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, DC 20555-0001

July 16, 2012

NRC REGULATORY ISSUE SUMMARY 2012-08: DEVELOPING INSERVICE TESTING

AND INSERVICE INSPECTION

PROGRAMS UNDER 10 CFR PART 52

ADDRESSEES

All current and potential applicants for and holders of a combined license (COL) or standard

design certification for a nuclear power plant under the provisions of Title 10 of the Code of

Federal Regulations (10 CFR) Part 52, Licenses, Certifications, and Approvals for Nuclear

Power Plants.

INTENT

The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)

to describe an acceptable approach for COL holders (licensees) with respect to the

requirements in 10 CFR 50.55a, Codes and standards, regarding development of inservice

inspection (ISI) and inservice testing (IST) programs during the initial 120-month program

interval following plant startup. In addition, this RIS discusses acceptable approaches for

developing preservice inspection programs and Risk-Informed ISI and IST programs. This RIS

does not transmit any new requirements and does not require any specific action or written

response.

BACKGROUND INFORMATION

The regulations in 10 CFR 50.55a(f)(4)(i) and (g)(4)(i) require, in part, that inservice tests to

verify the operational readiness of safety-related pumps and valves and inservice examinations

of components and system pressure tests conducted during the initial 120-month testing and

inspection interval must comply with the requirements in the latest edition and addenda of the

American Society of Mechanical Engineers (ASME) Boiler & Pressure Vessel Code (B&PV

Code) and ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code)

incorporated by reference in 10 CFR 50.55a, on the date that occurs 12 months before the date

scheduled for initial loading of fuel under a COL issued under 10 CFR Part 52 (or the optional

ASME Code cases listed in NRC Regulatory Guide (RG) 1.147, Inservice Inspection Code

Case Acceptability, ASME Section XI, Division 1, and RG 1.192, Operation and Maintenance

Code Case Acceptability, ASME OM Code, that are incorporated by reference in 10 CFR 50.55a).

In addition, the NRC regulations in 10 CFR 52.47(a)(3)(i) require, in part, that a design

certification application must contain the principal design criteria for the facility. Appendix A,

General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50 establishes minimum

requirements for the principal design criteria. General Design Criteria (GDC) 32, 36, 37, 39, 40,

42, 43, 45, and 46 require that components and systems important to safety shall be designed

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to permit appropriate periodic inspection of important components to assure their integrity and

capability of the system and to permit periodic pressure and functional testing to assure (1) the

structural and leak-tight integrity of its components, (2) the operability and performance of the

active components of the system, and (3) the operability of the system as a whole. The periodic

inspections and testing programs are required to meet the ASME B&PV and OM Codes,

respectively, in accordance with 10 CFR 50.55a.

Lastly, the NRC regulations in 10 CFR 52.79(a)(11) require that the COL applicant describe the

programs (such as ISI and IST programs) and their implementation, necessary to ensure that

the systems and components meet the requirements in the ASME OM Code and ASME B&PV

Code,Section XI. These operational programs are required to be fully described when the COL

application is submitted to the NRC for review.

During the NRC staffs review of design certification and COL applications, several applicants

expressed concerns in being able to fully comply with the above three NRC regulations because

they perceived the requirements as providing overlapping requirements on establishing the

applicable editions and addenda of the ASME B&PV and OM Codes to be used for the initial

120-month ISI and IST program intervals. This RIS describes how the NRC staff, design

certification applicants, and COL applicants have addressed these requirements in the reviews

of design certification and COL applications under 10 CFR Part 52.

SUMMARY OF ISSUE

The NRC regulations in 10 CFR Part 52 allow a two-step process for licensing new nuclear

power plants where a Standard Design Certification is granted with subsequent issuance of a

COL referencing the certified design. Under this process, the regulations in 10 CFR 52.47

require the design certification application to contain a level of design information sufficient to

enable the Commission to judge the applicants proposed means of assuring that construction

conforms to the design and to reach a final conclusion on all safety questions associated with

the design before the certification is granted. A Design Control Document (DCD) supporting a

design certification application may provide general information on operational programs (such

as ISI and IST programs) with allowance for flexibility by the COL applicant when developing

plant-specific operational programs. The NRC staff reviews the general description of the

operational programs in the DCD to ensure an adequate foundation for the plant-specific

operational programs to be developed by COL applicants. With respect to IST programs, the

NRC staff review of the DCD focuses on accessibility for the performance of IST activities. To

reduce the amount of information needed in subsequent COL applications, some design

certification applicants provide more detailed descriptions of ISI and IST operational programs in

their DCDs than required by the NRC regulations for a design certification application.

The NRC regulations in 10 CFR 52.79(a)(11) require a COL applicant to provide, in its safety

analysis report, a description of the programs and their implementation, necessary to ensure

that the systems and components meet the requirements of the ASME B&PV and OM Codes in

accordance with 10 CFR 50.55a at a level sufficient to enable the NRC to reach a final

conclusion on all safety matters that must be resolved before COL issuance. In SECY-05-0197,

Review of Operational Programs in a Combined License Application and General Emergency

Planning Inspections, Tests, Analyses, and Acceptance Criteria [ITAAC], (Agencywide

Documents Access and Management System (ADAMS) Accession No. ML052770257) dated

October 28, 2005, the NRC concluded that operational programs (such as ISI and IST

programs) could be fully described in a COL application and recognized that some operational

programs would not be available at the time of COL issuance. In accordance with this

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guidance, the description of the program would contain the information necessary for the NRC

staff to make a reasonable assurance finding on the acceptability of the operational program in

the review of a COL application. This information would specify an edition and addenda of the

ASME B&PV and OM Codes that would be the basis for the ISI and IST program described in

the COL application. The NRC staff developed license conditions to provide certainty as to

when the operational programs would be implemented in support of plant startup.

Following COL issuance, the NRC regulations in 10 CFR 50.55a(f)(4)(i) and (g)(4)(i) require, in

part, that inservice tests to verify the operational readiness of safety-related pumps and valves

and inservice examinations of components and system pressure tests conducted during the

initial 120-month testing and inspection interval must comply with the requirements in the latest

edition and addenda of the ASME B&PV and OM Codes incorporated by reference in

10 CFR 50.55a, on the date that occurs 12 months before the date scheduled for initial loading

of fuel under a COL issued in accordance with 10 CFR Part 52 (or the optional ASME Code

cases listed in NRC RG 1.147 and RG 1.192 that are incorporated by reference in 10 CFR 50.55a).

Several years may elapse between the time when a design certification is granted and when a

COL application is submitted referencing that certified design. Further, the construction of a

nuclear power plant will require several years from the time of COL issuance until the

commencement of fuel loading. Therefore, design certification and COL applicants and holders

need to be aware of the interrelated requirements in 10 CFR 50.55a and 10 CFR Part 52

regarding the development and implementation of ISI and IST programs for nuclear power

plants to be licensed under 10 CFR Part 52.

Design Certification and COL Applicants

The NRC regulations in 10 CFR 52.79(a)(11) require that the COL applicant describe the ISI

and IST programs and their implementation, necessary to ensure that the systems and

components meet the requirements in the ASME B&PV Code,Section XI and ASME OM Code.

NRC RG 1.206, Combined License Applications for Nuclear Power Plants (LWR Edition), and

SECY-05-0197 provide guidance for COL applicants in describing their ISI and IST programs in

support of the COL applications. As part of its description of the ISI and IST programs, the COL

applicant must identify the edition and addenda of the ASME B&PV Code,Section XI and

ASME OM Code, to be used in developing its ISI and IST programs, respectively. In some

cases, it may be the same edition and addenda used in the design certification. In other cases,

it may be the latest edition and addenda of the ASME OM Code or ASME B&PV Code, Section

XI, incorporated by reference in 10 CFR 50.55a at the time of the COL application. In

describing ISI and IST programs, COL applicants should recognize that the NRC regulations in

10 CFR 50.55a require updating of ISI and IST programs prior to fuel loading. Design

certification applicants should also be aware of this 10 CFR 50.55a requirement when

describing ISI and IST programs in their DCDs for reference by COL applicants.

COL Licensees

After the COL is issued, the COL licensee will initiate development of the ISI and IST programs

to allow implementation of those programs in preparation for plant operation. During

development of the ISI and IST programs, the COL licensee should be aware of the NRC

regulations under 10 CFR 50.55a(f)(4)(i) and (g)(4)(i) that require the COL licensee to develop

its initial 120-month interval ISI and IST programs using the latest edition and addenda of the

ASME B&PV Code,Section XI and ASME OM Code, incorporated by reference in

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10 CFR 50.55a(b) on the date that occurs 12 months before the date scheduled for initial

loading of fuel. Therefore, the COL licensee should anticipate that the ASME B&PV and OM

Codes might be revised to incorporate industry operating experience and technological

advances prior to fuel loading for its nuclear power plant.

NRC Staff Position

The NRC staff recognizes that a COL licensee might encounter significant logistical and

scheduling issues when converting its ISI and IST programs from the edition and addenda of

the ASME B&PV and OM Codes specified in the COL application to the edition and addenda of

these codes incorporated by reference in 10 CFR 50.55a on the date that occurs 12 months

before fuel loading.

The NRC regulations in 10 CFR 50.55a(a)(3) allow alternatives to the requirements of 10 CFR 50.55a to be used if the applicant demonstrates that (1) the proposed alternative would provide

an acceptable level of quality and safety, or (2) compliance with the specified requirements of

10 CFR 50.55a would result in hardship or unusual difficulty without a compensating increase in

the level of quality and safety. Therefore, a COL licensee may request authorization by the

NRC staff to use an edition and addenda of the ASME OM Code for developing its initial

120-month IST program that is earlier than that required under 10 CFR 50.55a(f)(4)(i) and,

similarly, to use an edition and addenda of the ASME B&PV Code,Section XI, for developing its

initial 120-month ISI program that is earlier than that required under 10 CFR 50.55a(g)(4)(i).

One acceptable approach would be for the COL licensee to submit to the NRC a request to

authorize, as an alternative, the use of the same edition and addenda of the ASME OM Code or

ASME B&PV Code,Section XI, that was specified in the design certification or COL application

for the initial 120-month IST and ISI programs. In its request for authorization of an alternative,

the COL licensee would need to demonstrate that it meets one of the conditions described in

10 CFR 50.55a. In addition, a COL licensee may request exemptions or departures for ISI and

IST programs in accordance with Section VIII, Processes for Changes and Departures which

is located in each of the Appendices A-D of Part 52.

When evaluating a proposed alternative under 10 CFR 50.55a, the NRC staff will compare the

ISI and IST provisions in the proposed code edition and addenda to the required edition and

addenda of these codes incorporated by reference in 10 CFR 50.55a on the date that occurs

12 months before fuel loading. As part of its review, the NRC staff will evaluate the differences

between the ISI and IST provisions in those respective code editions and addenda. The NRC

staff will also consider whether the alternative enables the testing and inspections applicable to

NUREG-0933 generic safety issues and operational lessons learned that are incorporated into

the design under 10 CFR 52.47(a)(21)and (22). Therefore, the design certification and COL

applicants should consider the edition and addenda of the ASME OM Code and ASME B&PV

Code,Section XI, specified in the descriptions of the IST and ISI programs in their design

certification and COL applications, and whether those code editions and addenda reflect

lessons learned from operating experience at nuclear power plants (including IST and ISI

activities) and industry and regulatory research programs that will be incorporated into later

code addenda and editions.

Preservice Inspection Using ASME B&PV Code,Section III

The NRC staff has received inquiries from design certification and COL applicants about the

edition and addenda of ASME B&PV Code,Section III that they should use for developing a

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preservice inspection (PSI) program. The NRC regulations in 10 CFR 50.55a(g)(3)(i) and (ii)

require, in part, that Class 1, 2, and 3 components and their supports must meet the preservice

examination requirements set forth in the editions and addenda of Section III or XI of the ASME

B&PV Code (or ASME OM Code for snubber examination and testing) incorporated by

reference in 10 CFR 50.55a that apply to the construction of the particular component. A design

certification applicant may specify the edition and addenda of Section III of the ASME B&PV

Code that has been incorporated by reference in 10 CFR 50.55a for the design of its Class 1, 2,

and 3 components. A COL licensee may use this same edition and addenda of Section III to

develop its PSI program. However, COL applicants may also specify the latest edition and

addenda of ASME B&PV Code,Section III that is incorporated by reference in 10 CFR 50.55a

to minimize the differences in preservice examination requirements when developing the ISI

program pursuant to 10 CFR 50.55a(c)(3), (d)(2), and (e)(2).

For its initial 120-month interval, a COL licensee may submit to the NRC a request to authorize

an alternative to use a different edition and addenda of ASME B&PV Code,Section XI, than that

required by 10 CFR 50.55a(g)(3)(i), for developing its PSI program. According to 10 CFR 50.55a, the COL licensee would need to demonstrate that (1) this edition and addenda of ASME

B&PV Code,Section XI, would provide an acceptable level of quality and safety, or

(2) compliance with the specified requirement to use the latest edition and addenda would result

in hardship or unusual difficulty without a compensating increase in the level of quality and

safety.

Risk-Informed ISI and IST Programs

On several occasions, the NRC staff has been asked to define its position on Risk-Informed IST

and ISI program submittals during the COL application process. A COL applicant or licensee

may submit Risk-Informed ISI and IST programs for NRC staff review and authorization as an

alternative to the regulations as described in 10 CFR 50.55a. The COL applicant or licensee

will need to satisfy the requirements for authorization of an alternative as specified in

10 CFR 50.55a.

The NRC staff recommends that a conventional ISI or IST program be in place or developed

before preparing a Risk-Informed ISI or IST program to facilitate the evaluation of the

acceptability of the alternative program. This recommendation is based solely on the fact that

the existing design certification applications, the Standard Review Plan acceptance criteria, the

applicable NUREG documents, and the COL applications conform to the premise that

conventional ISI/IST programs have been developed prior to a Risk-Informed program. No

regulation requires that a conventional ISI or IST program be developed prior to a Risk-Informed

ISI or IST program submission as an alternative. However, the NRC staff considers this

approach to provide the most expedient course for review and approval of a Risk Informed ISI

or IST program.

BACKFIT DISCUSSION

This RIS clarifies current regulatory requirements and provides voluntary options that a COL

licensee may propose. The RIS imposes no new requirements and necessitates no action or

written response. Therefore, it does not constitute a backfit under 10 CFR 50.109, Backfitting,

and the staff did not perform a backfit analysis.

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FEDERAL REGISTER NOTIFICATION

A notice of opportunity for public comment on this RIS was published in the Federal Register

(77 FR 12089) on 02/28/2012. No public comments were received.

CONGRESSIONAL REVIEW ACT

In accordance with the Congressional Review Act, the NRC has determined that this action is

not a major rule and has verified this determination with the Office of Information and Regulatory

Affairs of the Office of Management and Budget (OMB).

PAPERWORK REDUCTION ACT STATEMENT

This RIS does not contain new or amended information collection requirements that are subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing requirements were

approved by the OMB, approval numbers 3150-0011 and 3150-0151.

PUBLIC PROTECTION NOTIFICATION

The NRC may not conduct or sponsor, and a person is not required to respond to, an

information collection unless the requesting document displays a currently valid OMB control

number.

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CONTACT

Please direct any questions about this matter to the technical contact listed below or to the

appropriate Office of New Reactors project manager.

/RA/ /RA/

Laura A. Dudes, Director Timothy J. McGinty, Director

Division of Construction Inspection Division of Policy and Rulemaking

and Operational Programs Office of Nuclear Reactor Regulation

Office of New Reactors

Technical Contact: Timothy K. Steingass, NRO

301-415-3312

E-mail: timothy.steingass@nrc.gov

Note: NRC generic communications may be found on the NRC public Web site,

http://www.nrc.gov, under NRC Library/Document Collections.

ML12114A010 *via e-mail NRO-002/ME5784

OFFICE NRO/DE/CIB2* Tech Editor* NRO/DE/CIB2/BC* NRR/DCI/CPTB/BC* OE* OIS*

NAME TSteingass JDougherty MNorato AMcMurtray NHilton (GGulla for) TDonnell

DATE 01/11/12 05/19/11 08/22/11 01/11/12 09/09/11 08/30/11

OFFICE NRO/PMDA* NRR/PMDA* NRR/DORL/D* NRO/DE/CIB/BC* NRO/DE/D OGC (NLO)

TBergman (MShuaibi

NAME BGusack LHill JGiitter DTerao GMizuno

for)

DATE 09/07/11 08/25/11 09/06/11 01/11/12 05/17/12 06/04/12

NRR/DPR/PGCB

OFFICE NRR/DPR/LA* NRR/DPR/PGCB/PM NRR/DPR/LA NRO/DCIP/D NRR/DPR/D

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NAME CHawes ARussell DPelton CHawes LDudes TMcGinty

DATE 07/03/12 07/05/12 07/11/12 07/11/12

07/13/12 07/16/12