ML17262A065

NEI Public Meeting Final Slides - Industry Perspectives on Draft Service Lift Regulatory Issue Summary, September 14, 2017

ML17262A065
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/14/2017
From:	Nuclear Energy Institute
To:	Office of Nuclear Regulatory Research
DiFrancesco N
References
Download: ML17262A065 (23)

Text

INDUSTRY PERSPECTIVES September 14, 2017 ON DRAFT SERVICE LIFE REGULATORY ISSUE

SUMMARY

TODAYS AGENDA

• Introduction of industry team

• Context and overarching industry concerns

• Evolution of industry concerns with Service Life RIS

• Potential issues with current draft

• Over-reliance on vendor maintenance recommendations

• Insufficient consideration of Preventative Maintenance Programs and Maintenance Rule

• Station and fleet perspectives

• Closing remarks 2

Jerry Bonanno Associate General Counsel, CONTEXT &

Nuclear Energy Institute OVERARCHING Darani Reddick Regulatory Affairs Manager & INDUSTRY Assistant General Counsel, Exelon Corporation CONCERNS

CONTEXT

• Regulatory Issue Summaries used to communicate and clarify NRC technical or policy positions on regulatory matters that have not been communicated to or are not broadly understood by the nuclear industry. . . .*

• Given the evolution of the regulatory issues addressed by the RIS, review of the document should focus on whether it adequately communicates and clarifies the agencys positions

• https://www.nrc.gov/reading-rm/doc-collections/gen-comm/reg-issues/

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OVERARCHING INDUSTRY CONCERN

• Traditionally, from a backfitting perspective, review focused on identifying explicit statements communicating new or different staff positions

• But lack of clarity on key regulatory issues can also result in the imposition of unanalyzed backfits in the field 5

OVERARCHING INDUSTRY CONCERN

• Imposition of new or different staff positions on the treatment of vendor replacement or refurbishment information could result from lack of clarity regarding:

• Appropriate classification of vendor information

• Misclassifying vendor information as design basis or supporting design basis information affects the regulatory consequences of not conforming to vendor recommendations

• Relevance of existing programs and requirements

• An overly narrow view of relevant programs and requirements can result in evolving standards regarding the need to conform to vendor recommendations, as well as the level of documentation and formality of evaluations required to disposition such recommendations 6

Steve Meyer Regulatory Affairs VENDOR Functional Area Manager, STARS Alliance MAINTENANCE RECOMMENDATIONS

VENDOR MAINTENANCE RECOMMENDATIONS

• Draft RIS discusses the time period that a safety-related SSC is installed which continues a message from withdrawn TIA 2014-01 regarding vendor recommendations:

• inspectors identified examples of structures, systems, and components that were in operation beyond the service life specified in vendor manuals

• TIA documents the existing regulatory position regarding safety-related SSCs that have been in service longer than their documented service life, as specified in the licensees 10 CFR 50.2 design bases or supporting design information

• when a safety-related SSCs service life has been exceeded or the licensee becomes aware of information that challenges the documented or licensee presumed service life, the licensee must promptly address and document this nonconforming condition 8

VENDOR MAINTENANCE RECOMMENDATIONS

• Draft RIS conflates vendor recommendations with plant design information

• Consequence - An incorrect conclusion may be reached that deviations from vendor recommendations results in a loss of quality unless the licensee has performed a technical evaluation to justify the deviation

• Consequence - An incorrect conclusion may be reached that vendor recommendations are required to be followed in order to maintain ongoing qualification of components in mild environments 9

VENDOR MAINTENANCE RECOMMENDATIONS Original Equipment Vendor Recommendations Not Specific to Application or Service Condition Original Vendor Recommendations No Vendor Specific to Recommendations Application and Service Conditions Safety Related SSC Vendor Vendor Service Recommendations Advisories or Based on Test Technical Bulletins Results 10

EXAMPLES OF RECOMMENDATIONS

• The frequency of the inspection and maintenance operations required should be determined by each operating company and will depend on the application of the breakers and the operating conditions.

• Factors which should be considered are: Importance to overall plant or system operation; number of operations and magnitude of currents switched by breaker; frequency of fault interruptions; and the atmospheric conditions in which the breaker normally operates.

• Breakers used for switching arc furnaces or capacitors will require more frequent and more detailed inspection and maintenance because of the repetitive nature of the applications.

• Examples where no vendor replacement or refurbishment recommendations are provided.

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INDUSTRY RECOMMENDATION The RIS should explicitly state that vendor information is rarely considered plant design information and should not be treated as such. Insinuation that 10 CFR 50.2 and Criterion III applies to vendor information should be removed.

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Marty Murphy Director, EXISTING Nuclear Regulatory Affairs & Licensing Xcel Energy LICENSEE Vince Bacanskas PROGRAMS Director and Chief Engineer Entergy Services, Inc.

Jaime McCoy Vice President, Engineering Wolf Creek Nuclear Operating Corporation

EXISTING LICENSEE PROGRAMS

• Draft RIS fails to consider pertinent programs which implement regulatory requirements and guidance for maintenance of SSCs

• Consequence - The RIS may impose a new staff position which negates existing positions on the adequacy of preventive maintenance and surveillance activities to maintain equipment in mild environments

• Consequence - An incorrect conclusion may be reached that vendor-provided information should be given greater consideration than actual, performance-based component performance history 14

QUALITY ASSURANCE

• Reg Guide 1.33, Rev. 2, Appendix A, 9.b

• Preventive maintenance schedules should be developed to specify lubrication schedules, inspection of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.

• ANSI N18.7-1976

• A preventive maintenance programshall be established and maintained. A preliminary program based on service conditions and experience with comparable equipment should be developed. The program should be revised and updated as experience is gained with the equipment.

• NQA-1, 1994, Subpart 2.18

• Equipment shall be evaluated to determine its preventive maintenance requirements. That evaluation shall include vendor recommendations as delineated in their Technical Manual and Bulletins, applicable industry standards and operational experience, and maintenance experience and equipment history files. Equipment shall be monitored and evaluated for degradation of performance because of age, as appropriate.

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EQUIPMENT IN MILD ENVIRONMENTS

• NUREG-0800 Section 3.11

• A well-supported maintenance/surveillance program, in conjunction with a good preventive maintenance program, is sufficient to ensure that equipment that meets the design/purchase specifications is qualified for the designed life.

• This represents the current staff position that existing quality assurance programs for preventative maintenance ensure the reliability of SSCs in mild environments.

• Vendor information is an element of a well-supported maintenance program to ensure reliability, but not an input to maintain ongoing qualification of components in mild environments.

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MAINTENANCE RULE

• NUREG-0800 Section 3.11

• Compliance with 10 CFR 50.65, "Requirements for monitoring the effectiveness of maintenance at nuclear power plants," and associated guidance in Regulatory Guide 1.160 are sufficient to provide reasonable assurance that environmental considerations established during design are reviewed every refueling outage and maintained on a continuing basis to ensure that the qualified design life has not been reduced by thermal, radiation, and/or cyclic degradation resulting from unanticipated operational occurrences or service conditions. Modification to the replacement program and/or replacement of equipment should be based on the review of maintenance/surveillance data.

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Inputs to PM Strategies PM Change 10CFR50.49 Monitoring & Trending Review and Evaluations Approval Industry Standards Preventive Vendor Maintenance Recommendations Strategies Industry Operating Experience PM PM Work Equipment Maintenance Scheduling Instructions History Software PM Feedback Preventive Maintenance Failure Modes & Effects Analysis Activities

INDUSTRY RECOMMENDATION The RIS should explicitly state that A well-supported maintenance/surveillance program, in conjunction with a good preventive maintenance program, is sufficient to ensure that equipment that meets the design/purchase specifications is qualified for the designed life.

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Mike McBrearty Manager, Licensing STATION & FLEET TVA - Sequoyah PERSPECTIVES Jaime McCoy Vice President, Engineering Wolf Creek Nuclear Operating Corporation Vince Bacanskas Director and Chief Engineer Entergy Services, Inc.

CLOSING REMARKS

INDUSTRY RECOMMENDATIONS The RIS should explicitly state that:

• Vendor information is rarely considered plant design information and should not be treated as such.

Insinuation that 10 CFR 50.2 and Criterion III applies to vendor information should be removed.

• A well-supported maintenance/surveillance program, in conjunction with a good preventive maintenance program, is sufficient to ensure that equipment that meets the design/purchase specifications is qualified for the designed life.

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INDUSTRY PERSPECTIVES September 14, 2017 ON DRAFT SERVICE LIFE REGULATORY ISSUE