NUREG-1482, 1-NUREG-1482 Rev-3 Comments Resolution May 25 -2020 (Finai) .Doc
| ML20153A761 | |
| Person / Time | |
|---|---|
| Issue date: | 06/01/2020 |
| From: | Gurjendra Bedi NRC/NRR/DEX/EMIB |
| To: | |
| Gurjendra Bedi 415-1393 | |
| References | |
| NUREG-1482 R3 | |
| Download: ML20153A761 (12) | |
Text
Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section 1 Glenn Weiss, Exelon Section 1. With regard to the new words added to Section 2.1.2.8 and Section to 2.1.2.9 the Condition on Valve Position 4.2.7 in NUREG-1482 Tom Scarbrough, Indication (2.1.2.9), will the NUREG be provide additional guidance dated December 13, 2019 expanding on the bases or intent of for Valve Position Indication.
these new words?
- 2. Does the proposed words allow for use Section 4.2.7 in NUREG-of Appendix J testing frequency to be 1482 indicates that licensees applied to Supplemental Position will need to submit a request Indication? [Your response was that the in accordance with 10 CFR wording is changing and will not be as 50.55a(z) if application of a shown in the Draft. An Alternate licensee program (such as Request will need to be submitted.] Appendix J leakage testing) is proposed as an alternative to 10 CFR 50.55a(b)(3)(xi).
- 3. Does the addition wording added to the Section 4.2.7 in NUREG-last sentence referencing mandatory 1482 provides guidance for appendices and their verification the application of the methods and frequencies also apply to provisions in Appendices II, Appendix II - Check Valve Conditioning III, and IV to satisfy 10 CFR Monitoring. [I believe your response 50.55a(b)(3)(xi).
was yes - you dont see why it wouldnt.]
2 Mir Maqsood, CADU Is NUREG 1482 applicable to CANDU NUREG-1482 provides to Plants? guidance for U.S. nuclear Bob Wolfgang power plant licensees in dated December 10, 2019 implementing their inservice testing (IST) programs to Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section satisfy 10 CFR 50.55a.
3 Rick Portmann, Duke- I understand the below will not be in the next In NUREG-1482, Revision 3, Energy to rulemaking and not sure if it will be removed the NRC staff can only Gurjendra Bedi or modified for this Rev. 3, but when it gets provide guidance for dated December 11, 2019 next discussed I believe we need to remove satisfying the current the words ASME Class 1, 2, and 3, since requirements in 10 CFR this is not the true OM Code Scope and 50.55a. The NRC staff will leads to confusion. Removing it just leaves consider these suggestions the OM Scope as the requirements. Thanks, as part of a future proposed Rick 10 CFR 50.55a rulemaking.
10 CFR 50.55a(f)(7), Inservice Testing Reporting Requirements. Inservice Testing Program Test and Examination Plans (IST Plans) for components required by the ASME OM Code must be submitted to the NRC (Rockville, MD, location) in accordance with 10 CFR 50.4. All required IST Plan submittals must be made within 90 days of their implementation. Electronic submission is preferred. In addition to the IST Plans for the preservice test period, initial inservice test interval, and successive inservice test intervals specified in the ASME OM Code, interim IST Plan updates that involve changes for components to the following must be submitted when the final safety analysis report for the nuclear power plant is updated:
- 4. John Bogza, Region III, to Page 1. IMC 0326 does contain the terms of Section 2.1.4 in NURG-1482 Gurjendra Bedi via e-mail 2-10 nonconforming or degraded conditions, has been replaced by the dated October 22, 2019 Section and they are referenced on page 2-10 guidance in Section 08.09, Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section 2.1.4 under Section 2.1.4 of NUREG-1482, Technical Specification Revision 3. Please revise. Operability vs. ASME OM Code Criteria, in IMC 0326 (September 30, 2019).
Page 2. On page 2-10, Section 2.1.4 of NUREG- Section 2.1.4 in NUREG-2-10 1482, Revision 3, uses the term TS 1482 has been replaced by Section [Technical Specification] function, but it the guidance in Section 2.1.4 may be more accurate to describe as TS 08.09, Technical specified safety function (component Specification Operability vs.
that has a specified safety function as ASME OM Code Criteria, in defined in license or TS) or even use the IMC 0326 (September 30, term specified safety function. Please 2019).
revise accordingly.
Pages 3. The information related to Reference corrected 3-14 preconditioning on pages 3-14, 3-15 and throughout NUREG-1482.
3-15 3-18 (Section 3.5.4) is not contained 3-18 within IMC 0326 and appears to come from Part 9900 Technical Guidance Section Maintenance - Preconditioning of 3.5.4 Structures, Systems, and Components Before Determining Operability. Please revise NUREG-1482, Revision 3, to include the correct reference if preconditioning discussion will remain.
Page 4. The term immediate safety issue is used Term deleted from NUREG-2-10 on page 2-10 under Section 2.1.4 of 1482.
Section NUREG-1482, Revision 3. Is the term 2.14 immediate safety issue defined in NRC regulations? Please confirm. If not defined anywhere, I recommend removing the term.
Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section
- 5. If referencing IMC 0326, use the latest ADAMS number corrected in ML which is ML19273A878. NUREG-1482.
Section Third 6. It is not clear whether Section 2.1.4 Section 2.1.4 in NUREG-2.1.4 para. (third paragraph) is consistent with IMC 1482 has been replaced by 0326, Section C.09, titled, Technical the guidance in Section Specification Operability vs. ASME OM 08.09, Technical Code Criteria. Please review and Specification Operability vs.
revise accordingly. ASME OM Code Criteria, in IMC 0326 (September 30, 2019).
5 Public Meeting Participant 4.1.8 Provide additional guidance on bidirectional Additional guidance provided December 10, 2019 testing of check valves. in Section 4.1.8 of NUREG-1482 on the basis for bidirectional testing of check valve with a safety function in only one direction.
- 6. Public Meeting Participant 4.4.3.2 Clarify reference to beyond design-basis Section 4.4.3.2 of NUREG-December 10, 2019 events in discussing the IST program. 1482 clarified that IST program requirements might not apply to beyond design-basis events.
7 Public Meeting Participant 3.3 Provide guidance regarding 12-month Section 3.3 in NUREG-1482 December 10, 2019 requirement in ISTA-3200 in comparison to modified to indicate that new 18-month requirement in 10 CFR licensees will need to submit 50.55a. a request in accordance with 10 CFR 50.55a(z) to apply the 18-month provision for successive IST programs rather than the 12-month provision specified in ISTA-3200, until the ASME OM Code is updated.
8 Bret Collier 2.2.1 10 CFR 50.55a(f) should require all pumps NUREG-1482 cannot modify Via e-mail to Bob Wolfgag and valves within the ASME OM Code the 10 CFR 50.55a Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section dated January 4, 2020. scope (Code Class and non-Code Class) to requirements. This satisfy the OM Code provisions or submit a suggestion will be considered request for relief or an alternative to the OM as part of a future 10 CFR Code provisions. 50.55a proposed rulemaking.
9 Bret Collier 2.4 The following sentence does not appear to This sentence has been Via e-mail to Bob Wolfgag be grammatically correct: updated in NUREG-1482.
dated January 4, 2020 In future, ASME proposed to delete the requirement of ISTA-3200(a) to submittal of IST plant to regulatory authorities, and this submittal requirement has been added in 10 CFR 50.55a(f)(7) as follows:
10 Bret Collier 2.4.2 Should reference to Subsection ISTA-2000 The various references to Via e-mail to Bob Wolfgag in the OM Code be of the OM Code? sections and paragraphs of dated January 4, 2020 the OM Code have been corrected in NUREG-1482.
Subsection ISTA should be of the OM Code while Section ISTA-2000 should be in the OM Code.
11 Bret Collier 2.5 OM Code has removed reference to light- NUREG-1482 updated to Via e-mail to Bob Wolfgag water reactors so NUREG-1482 should correct light-water to water-dated January 4, 2020 also. cooled where appropriate.
12 Bret Collier 2.5 Reference to 10 CFR 50.55a(z) should Sentence corrected in Via e-mail to Bob Wolfgag specify that licensees shall not implement NUREG-1482.
dated January 4, 2020 proposed alternatives until NRC staff completes its evaluation.
13 Bret Collier 2.7 NUREG-1482 is not consistent regarding NUREG-1482 will be Via e-mail to Bob Wolfgag references to ASME OM Code and OM reviewed for consistency in dated January 4, 2020 Code. reference to the OM Code.
14 Bret Collier 2.7 NUREG-1482 refers to Vogtle FSAR and NUREG-1482 references the Via e-mail to Bob Wolfgag Vogtle FSER. Check references. Vogtle FSAR in some dated January 4, 2020 instances and Vogtle FSER in other instances. NUREG-Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section 1482 reviewed to verify applicable references.
15 Bret Collier 4.2.7 NUREG-1482 should not mention ASME Reference to ASME effort to Via e-mail to Bob Wolfgag efforts to develop Code Case on valve develop Code Case on valve dated January 4, 2020r position indication. position indication deleted from NUREG-1482.
16 Brett Collier 4.4.3.2 Beyond Design Basis Events should not be Sentence referencing beyond Via e-mail to Bob Wolfgag discussed in NUREG-1482. design basis events in dated January 4, 2020 Section 4.4.3.2 of NUREG-1482 has been corrected.
17 Brett Collier Via e-mail to Various VEGP should be defined. NUREG-1482 corrected to Bob Wolfgag dated define VEGP in Section 2.7.
January 4, 2020
- 18. Glen Palmer Various Appendix- Various Editorial comments on Draft Report NUREG-1482, Appendix A, Via e-mail to Bob Wolfgang A for of NUREG-1482, Revision 3, Appendix A, corrected as appropriate.
dated January 7, 2020 Snubbers for snubbers
- 19. NRC Region III comments Various via e-mail to Stew Bailey dated January 14, 2020 as follows 20 1.2 Comment #RL1, ADAMS already spelled Corrected out.
21 1.3.1 Comment # RL2. Last sentence is hard to Changed as follows:
read. Clarify the last sentence: In addition, ASME also has a This process, when considered along with process for developing and ASMEs own process for developing and publishing the OM Code.
approving the OM Code, provides Therefore, there is confidence that the NRC approves for use confidence that ASME OM only those new and revised OM Code Code editions and addenda editions and addenda (with conditions as incorporated by reference in necessary), that provide reasonable 10 CFR 50.55a (including assurance of adequate protection of public necessary conditions) health and safety and that do not have provide reasonable Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section significant adverse impacts on the assurance of adequate environment. protection of public health and safety with respect to inservice testing of pumps, valves, and dynamic restraints (snubbers) in nuclear power plants.
22 2.1.4 Comment # RL3. Last paragraph should be Section 2.1.4 in NUREG-consistent with the latest issue of IMC 0326. 1482 has been replaced with the guidance in Section 08.09, Technical Specification vs. ASME OM Code Criteria, in IMC 0326 (September 30, 2019).
23 2.1.4 Comment # RL4. Second paragraph, Same as Comment #RL3 second sentence should be consistent with above.
latest issue of IMC 0326.
24 2.2 Comment # RL5. In first paragraph, first Changed to important to sentence, components that are necessary safety.
for safe operation should be changed to important to safety and/or safety related.
25 Page Comment # RL6. In fourth paragraph, Deleted Repetitive 2-12 second line, this is repetitive and should be information Section removed since the regulation was included 2.2.1 two paragraphs (last sentence) above.
26 2.2.3 Comment # RL7. Last paragraph, last Deleted sentence as beyond sentence, states Such document should be scope of NUREG-1482.
available for NRC staff inspection at plant This should state why documentation is expected. For example, in accordance with 10 CFR 50, Appendices A and B, requirements, or licensee procedures.
27 2.5.4 Comment # RL8. First paragraph, starting Deleted confusing sentences.
Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section from fourth line should be revised. This example is very confusing and may provide incorrect reasoning. Per 10 CFR 50.59(c)(4), the provisions of this section do not apply to changes to the facility or procedures when the applicable regulations establish more specific criteria for accomplishing such changes. 10 CFR 50.55a(f)(5) and 10 CFR 50.55a(z) are more applicable regulations; therefore, 10 CFR 50.59 would not apply. 10 CFR 50.59 may cover other items in the TRM not covered by 10 CFR 50.55a, but the snubbers would be covered therefore 10 CFR 50.59 would not apply. Unless Im missing something.
28 2.5.5 Comment # RL9. Verify and correct the LIC-102, Revision 3, has ADAMS number for LIC-102. been issued. ADAMS Accession Number included in NUREG-1482.
29 2.6 Comment # RL10. In last paragraph, first Changed to alternative in sentence, 10 CFR 50.55a(z) relates to the sentence.
alternatives. I thought reliefs were covered by 10 CFR 50.55a(f)(5)-(6). Should it reference either regulations, or just (z)?
30 Table Comment #RL11. Table 2.2, First row. How Added SRV/ADV valves to 2.2 about SRV/ADS valves? Should these be table.
within scope?
3.5 Section 3.5, Preconditioning for Pumps and Valves. Comments as below:
31 3.5.2 Comment # RL12. Section 3.5.2, NRC Section revised to delete Guidance, Second Paragraph, Second reference to IMC-0326, and Bullet. IMC 0326 ADAMS number should be to update information about Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section updated. Part 9900 document related to preconditioning.
32 3.5.2 Comment # RL13. Section 3.5.2, NRC IP71111, ADAMS number Guidance, Second Paragraph, Third Bullet. updated and corrected in IP71111 ADAMS number should be updated Reference section.
33 3.5.2 Comment #RL14, Section 3.5.2, IMC-0326 has been deleted Preconditioing, paragraph: IMC 0326 does from this section and correct not define preconditioning as far as I can information provided tell. It actually points back to this NUREG, throughout Section 3.5.2.
for the definition.
34 3.5.2 Comment #RL15, Section 3.5.2, IMC-0326 has been deleted Unacceptable Preconditioning, first from this section and correct paragraph and first line: IMC 0326 does not information provided define this. IP 71111.22 does define throughout Section 3.5.2.
unacceptable preconditioning, but it should NUREG-1482, describes be defined officially in this NUREG. unacceptable precondtioning as provided in IP 71111.22.
This IP is referenced in NUREG-1482 with more details found in the IP.
NUREG-1482 does not replace IP 71111.22.
35 3.5.2 Comments #RL16 and RL17, Section 3.5.2, IMC-0326 has been deleted Unacceptable Preconditioning, second and from this section and correct third paragraphs. Requirements are not in information provided IMC 0326. throughout Section 3.5.2.
36 Page Comment# RL18, Item 2 the pump IMC-0326 has been deleted 3-16 examples of pump venting and draining: from this section and correct Section Per new training on IMC 0326, an operability information provided 3.5.2 evaluation is not required by regulatory throughout Section 3.5.2.
requirements. It may be a self-imposed requirement. A more proper way of stating it would be, as assessment of operability may be needed.
Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section 37 Page Comment # RL19, Item 3, the pump IMC-0326 has been deleted 3-16 examples of pump venting and draining. Per from this section and correct Section new training on IMC 0326, an operability information provided 3.5.2 evaluation is not required by regulatory throughout Section 3.5..
requirements. It may be a self-imposed requirement however. A more proper way of stating it would be, as assessment of operability may be needed.
38 Page Comment # RL20, Section 3.5.4, NRC IMC-0326 has been deleted 3-18 Recommendation, first paragraph, second from this section and correct Section line: these are not in new IMC 0326. information provided 3.5.2 throughout Section 3.5.2.
39 Section Comment # RL21, Last pargraph, Second Added full name. ASME 4.1.4 sentence, NQA-1, Recommend that entire NQA-1, Quality Assurance reference name of NQA-1 should be kept. Program Requirements for Nuclear Facilities 40 Section Comment # RL22, Section 4.1.5.2, Listed Deleted Listed Systems 4.1.5.2 Systems, paragraph, first line, need to be section.
consistent with the use of language. Its either reverse flow or backflow.:
41 Section Comment # RL23, Section 4.1.5.2, Listed Deleted Listed Systems 4.1.5.2 System, first line: Those examples appear section.
lined out and removed. Need to make sure to either keep them, or remove this sentence 42 Section Comment # RL24, Section 4.2, Power 10 CFR 50.55a uses ASME 4.2 Operated Valve. I believe reference ASME BPV. Therefore, no change BPV, right way to write is ASME B&PV in needed.
the Code.
43 Section Comment # RL25, ASME B&PV seems right No change needed. See 4.2.11 way. response to Comment No. 42 above.
44 Section Comments # RL24 and RL25, Section 4.3.1, No change needed. See 4.3.1 Scope, Paragraph, third and fourth uses. response to Comment No. 42 Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section ASME BPV; ASME B&PV seems right. above 45 Section Comment # RL28, Section 5.5.2, NRC Corrected and deleted +/- 1/2.
5.5.2 Recommendation; with +/- 1/2, I believe there is some thing missing 46 Section Comment # RL29, Section 5.5.4, fourth line No change needed, see 5.5.4 ASME BPV: B&PV seems right response to Comment No. 42 above.
47 Section Comment # RL30, Standard Technical NUREG-1430 thru NUREG-6 Specification, last line, Ive noticed licensees 1434 contain Administrative have been removing this from their Controls Specification with Technical Specifications. This section may Inservice Testing Program no longer be warranted in the NUREG. Information. Some plant TS have this information. Most of the plants TS state that the Inservice Testing Program will be developed per 10 CFR 50.55a(f).
Therefore, this information will be retained in this revision.
48 Tom Robinson Section I just have one comment identified since the Sentence modified to indicate Cooper Power Plant 2.4.2 December meeting concerning Draft that containment isolation Via e-mail to Bob Wolfgang NUREG 1482, revision 3. I would valves (except where always g dated January 15, 2020 recommend deleting (or clarifying) the closed) are considered following sentence from section 2.4.2. active.
Containment isolation valves (except where always locked closed) are always considered to be active components based on their safety function to prevent release of radioactive material from containment.
Staff Evaluation and Resolution of the Public Comments on Proposed Draft NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants No. Comment Submitted by Page/ Paragraph Comment Response Section This statement, as written, appears to be inconsistent with the ISTA definitions for active and passive valves. If a containment isolation valve remains in the closed position at all times, whether it is locked closed or not, would still be considered passive per the following ISTA definitions.
valves, active: valves that are required to change obturator position to accomplish a specific function in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident.
valves, passive: valves that maintain obturator position and are not required to change obturator position to accomplish the required function(s) in shutting down a reactor to the safe shutdown condition, maintaining the safe shutdown condition, or mitigating the consequences of an accident