ML19093A891

NRC Presentation for April 3 2019 OD Public Meeting

ML19093A891
Person / Time
Issue date:	04/03/2019
From:	John Marshall Office of Nuclear Reactor Regulation
To:
Wilkins L, NRR/DLP, 415-1377
References
Download: ML19093A891 (13)

Text

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