ML22172A079

Transcript of the Advisory Committee on Reactor Safeguards Fuels, Materials, and Structures - RG 1.246 Subcommittee Meeting, May 20, 2022, Page 1-107 (Open)

ML22172A079
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Issue date:	05/20/2022
From:	Charles Brown Advisory Committee on Reactor Safeguards
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards Fuels, Materials, and Structures Subcommittee Docket Number:

(n/a)

Location:

teleconference Date:

Friday, May 20, 2022 Work Order No.:

NRC-1962 Pages 1-78 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1716 14th Street, N.W.

Washington, D.C. 20009 (202) 234-4433

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1

1 2

3 DISCLAIMER 4

5 6

UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8

9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.

15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.

19 20 21 22 23

1 UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION 2

+ + + + +

3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4

(ACRS) 5

+ + + + +

6 FUELS, MATERIALS, AND STRUCTURES SUBCOMMITTEE 7

+ + + + +

8 FRIDAY 9

MAY 20, 2022 10

+ + + + +

11 The Subcommittee met via hybrid Video 12 Teleconference, at 8:30 a.m. EDT, Ronald Ballinger, 13 Chairman, presiding.

14 15 COMMITTEE MEMBERS:

16 RONALD G. BALLINGER, Chair 17 VICKI BIER, Member 18 CHARLES H. BROWN, JR. Member 19 VESNA DIMITRIJEVIC, Member 20 WALTER KIRCHNER, Member 21 DAVID PETTI, Member 22 JOY L. REMPE, Member 23 MATTHEW SUNSERI, Member 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

2 ACRS CONSULTANT:

1 DENNIS BLEY 2

3 DESIGNATED FEDERAL OFFICIAL:

4 CHRISTOPHER BROWN 5

6 ALSO PRESENT:

7 MICHELLE HAYES, NRR 8

BRUCE LIN, NRR 9

SCOTT MOORE, ACRS 10 STEPHEN PHILPOTT, NRR 11 MIKE TURNBOW, Public Participant 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

3 CONTENTS 1

2 Opening Remarks and Objectives 4

3 Ronald Ballinger, Chair 4

Staff Opening Remarks..............

6 5

Michelle Hayes, Branch Chief, NRR 6

Staff Presentation - Overview of ASME 7

Section XI, Division 2 8

8 Bruce, Lin, NRR 9

Staff Presentation - Overview of 10 RG 1.246 and Resolution of Public Comments

... 38 11 Stephen Philpott, NRR 12 Committee Discussion

.............. 70 13 Public Comments................. 75 14 Mike Turnbow, Secretary, MANDE 15 working group under RIM, and 16 Chairman of the ANDE Project

....... 76 17 Closing Comments

................ 77 18 Ronald G. Ballinger, Chair 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

4 P R O C E E D I N G S 1

8:30 a.m.

2 CHAIRMAN BALLINGER: The meeting will now 3

come to order.

4 This is a meeting of the Advisory 5

Committee on Reactor Safeguards, Subcommittee on 6

Fuels, Materials, and Structures. I'm Ron Ballinger, 7

chairing the Subcommittee meeting.

8 ACRS members present are myself, of 9

course; Vicki Bier; Dave Petti; Dennis Bley, our 10 consultant; Walt Kirchner; Matt Sunseri; Joy Rempe; 11 Vesna Dimitrijevic.

12 If I've missed somebody, please chime in.

13 Chris Brown is the ACRS, of the staff, 14 Designated Federal Official for this meeting.

15 It's an information briefing, by the way, 16 unless we decide something different, based on 17 discussions. The Subcommittee will receive a briefing 18 from the NRC staff regarding Reg. Guide 1.246, 19 "Acceptability of ASME Code Section XI, Division 2, 20 Requirements for Reliability and Integrity Management 21 Programs, RIM, for Nuclear Power Plants for Non-Light 22 Water Reactors."

23 The rules for participation in all ACRS 24 meetings, including today's, were announced in The 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

5 Federal Register on June the 13th, 2019.

1 The ACRS section of the U.S. NRC public 2

website provides our Charter, Bylaws, agendas, Letter 3

Reports, and full transcripts of all full and 4

subcommittee meetings, including slides presented 5

there. The meeting notice and agenda for this meeting 6

were posted there.

7 We have received no written statements or 8

requests to make oral statements from the public.

9 The Subcommittee will gather information, 10 analyze relevant issues and facts, and formulate 11 proposed positions and actions, as appropriate, for 12 deliberation by the full Committee.

13 The rules for participation in today's 14 meeting have been announced as part of the notice of 15 this meeting previously published in The Federal 16 Register.

17 Today's meeting will be held exclusively 18 over Microsoft Teams. A telephone bridgeline allowing 19 participation of the public over their computer using 20 Teams or by phone was made available.

21 A transcript of today's meeting is being 22 kept. Therefore, we request that meeting participants 23 on Teams and on the Teams call-in line identify 24 themselves when they speak, and to speak with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

6 sufficient clarity and volume, so they can be readily 1

heard.

2

Likewise, we request that meeting 3

participants keep their computer and/or telephone 4

lines on mute when not speaking to minimize 5

disruptions.

6 The chat feature on Teams should not be 7

used for any technical exchanges.

8 Let's make sure that everybody has got 9

their phone on mute.

10 Now I think -- is Michelle Hayes, Branch 11 Chief, going to provide some opening remarks, or is 12 there another staff member that's going to do that?

13 MS. HAYES: I was going to provide some 14 opening remarks. This is Michelle Hayes.

15 CHAIRMAN BALLINGER: Sounds like a plan.

16 Very good. Let's proceed. Thank you.

17 MS. HAYES: Thank you.

18 So, good morning.

19 I'm Michelle Hayes, Chief of Advanced 20 Reactor Technical Branch 1 in the Office of Nuclear 21 Reactor Regulation.

22 As Chairman Ballinger mentioned, today's 23 discussion is on NRC's endorsement of ASME Code's 24 requirements for integrity management programs, or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

7 RIM, that is found in Section XI, Division 2, of the 1

ASME Boiler and Pressure Vessel Code.

2 I'm excited that I get to make the opening 3

remarks because I think this project epitomizes NRR's 4

vision for advanced reactors. It makes the safe use 5

of advanced reactor technologies possible because it 6

offers the first NRC-endorsed process these vendors 7

can use to develop and implement a preservice and 8

inservice inspection program. It advances risk-9 informed and performance-based approaches and safety 10 reviews because RIM itself is a risk-informed, 11 performance-based program.

12 It leverages partnerships across the 13 agency because the endorsement team drew staff from 14 NRR, Research, and the Regions. This enabled us to 15 perform a diverse and comprehensive review of this new 16 approach to inspections of passive components.

17 Our interactions with ASME and vendors 18 demonstrated the importance of stakeholder engagement 19 and our commitment to endorsing consensus codes and 20 standards, and issuing this Reg. Guide improves the 21 efficiency and effective use of future reviews of 22 vendors that use RIM.

23 Before we get started, I want to highlight 24 one procedural point about the Reg. Guide. While the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

8 copy you got is what we consider to be the final 1

version, it won't be issued until the end of June.

2 While RIM will not be incorporated into 10 CFR 50.55a, 3

one of the conditions in this Reg. Guide is to use the 4

2019 edition of RIM in conjunction with the 2019 5

edition of ASME Code,Section XI, Division 1, and any 6

applicable conditions in 10 CFR 50.55a. However, the 7

final 10 CFR 50.55a rule that incorporates the 2019 8

edition of ASME Section XI, Division 1, with the 9

respective conditions, won't be published until the 10 end of this June. So, we don't want to get ahead of 11 that.

12 Thanks in advance for your attention, and 13 we look forward to your questions.

14 I'll now turn it over to our in-house RIM 15 expert, Bruce Lin, to provide an overview of the 16 program.

17 MR. LIN: Okay. Good morning, everyone.

18 Thanks, Michelle.

19 So, I'm Bruce Lin. I'm one of the 20 Material Engineers with the Office of Regulatory 21 Research.

22 Again, thank you for the opportunity to 23 present today at the ACRS on the staff endorsement of 24 ASME Section XI, Division 2, the RIM program.

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9 I'm going to provide a very high-level 1

overview of what RIM is; go over the RIM process, and 2

basically, also the various sections in Section XI, 3

Division 2, just to give you a flavor of what's 4

included in the RIM standard.

5 In the next presentation, Steve Philpott 6

will discuss the staff review of the RIM standard and 7

the endorsement of Section XI, Division 2, and the 8

Regulatory Guide.

9 Next slide, please.

10 So, why isSection XI, Division 2, 11 developed? The industry had been using Section XI, 12 Division 1, for decades, and it's working and it's 13 effective. The problem is Division 1 is focused on, 14 essentially, boiling and pressurized light water 15 reactor technologies. So, under the current Division 16 1 rule, inservice inspections are specifically 17 described at specified frequencies for doing the 10-18 year inservice inspection intervals. So, this may not 19 be well-suited for some advanced non-light water 20 reactor designs, some with longer fuel cycles than the 21 typical PWR, you know, 18-to-24-month fuel cycles.

22 Also, some of the traditional, non-23 destructive examinations that are currently in use 24 today may not be effective in detecting some of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

10 degradation that is unique to some of the advanced 1

non-LWRs.

2 For some, this design may be more 3

effective to use, for example, on monitoring than 4

doing an inspection at the prescribed intervals.

5 So, Division 2 was developed to allow the 6

possibility for some of the new advanced reactor 7

designs to implement alternate strategies from Section 8

XI, Division 1, requirements. Division 2 RIM is 9

intended to be a technology-neutral code. So, it can 10 be applied to all reactors. It does have reactor-11 specific supplements to account for the difference in 12 reactor design. The supplement, basically, provides 13 the specific details related to, for example, the 14 degradation mechanism, all evaluations and acceptance 15 criterias for the specific reactor design.

16 Right now, the RIM standard has a 17 placeholder for six different reactor types, including 18 a high temperature gas reactor, nuclear metal 19 reactors, molten salt, light water reactors, and 20 fusion reactors.

21 Of course, many of the technology-specific 22 supplements are still under development. Right now, 23 only two have been completed so far.

24 Next slide.

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11 So, what is RIM? So, in a very high 1

level, it's a program to ensure that the passive 2

components are properly managed to meet the planned 3

recent reliability goals. It's based on the 4

philosophy of maintaining an adequate level of 5

reliability.

6 So, the objective of the RIM is to 7

implement strategies, I

think including the 8

combination of design, fabrication, or inspection and 9

maintenance requirements that are necessary and 10 sufficient to ensure that the reliability targets are 11 defined and maintained throughout the life of the 12 plant.

13 CHAIRMAN BALLINGER: This is Ron, Ron 14 Ballinger.

15 MR. LIN: Yes?

16 CHAIRMAN BALLINGER:

In the very 17 beginning, you specified that the code of record was 18 the 2019 version? There is a 2021 version.

19 MR. LIN: Right.

20 CHAIRMAN BALLINGER: And I haven't 21 compared the two. So, I don't know what the 22 differences are. But might there be an opportunity to 23 use that version? They don't come out with versions 24 that often.

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12 MR. LIN: Right.

1 CHAIRMAN BALLINGER: So, there may be an 2

opportunity to keep it up-to-date.

3 MR. LIN: The staff reviewed the 2019 4

edition of the Code, and that's the edition we're 5

endorsing. I think there are very minor changes 6

between the 2019 and 2021 editions, only editorial 7

changes.

8 CHAIRMAN BALLINGER: Okay. Thanks.

9 Also, while Division 1 has been in use for 10 a very, very, very long time, the industry has evolved 11 to the point where they're using online monitoring and 12 all kinds of other things. So, that it may be that in 13 the future Division 2 might actually be useful for 14 current LWRs.

15 MR. LIN: Yes. I mean, I think Division 16 2, again, right now, it's just a process. I think 17 there's going to be a lot more effort still required 18 to initially develop the program. So, Division 1, 19 again, it is very prescriptive and it's pretty easy to 20 follow, if you want to decide to use it. But Division 21 2 will require, in my opinion, significant effort 22 upfront as we develop the program.

23 CHAIRMAN BALLINGER: Yes, if you can get 24 by the 10-year ISI. That's very restrictive.

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13 Anyway, okay. Just my personal opinion.

1 Thank you.

2 MR.

LIN:

So,

yes, this slide 3

covers/describes the RIM process philosophy. RIM 4

evaluates all SSCs for their impact in plant safety 5

and reliability and established the necessary 6

examination tests, operation or maintenance, including 7

repair and replacements, to ensure that all the 8

systems, structures, and components meet the plant 9

recent reliability goal.

10 This is meant to be an iterative process, 11 you know, during the design stage. So that, if a 12 performance target cannot be met through the 13 inspection or monitoring, the SSC, hopefully, can be 14 redesigned to include maybe a higher margin and the 15 desired operation can be changed to allow provision 16 for maybe replacement during operations.

17 So, this is very different from the 18 prescriptive approach used in Division 1. I mean, the 19 philosophy of Division 1 is to maintain a sufficient 20 number of tests and examinations to provide assurance 21 that the plant is safe. Division 1 uses the class 22 approach, like Class 1, Class 2, and Class 3, with 23 each class having sort of less rigorous criteria. And 24 it provides very prescriptive requirements, including 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

14 what you need to inspect; how often you need to 1

inspect, and the specific method to use. Whereas, in 2

Division 2, it doesn't really have a lot of specific 3

requirements. It's a process. They provide a process 4

for owners to develop their programs.

5 Okay. Next slide, please.

6 So, this slides shows the overall RIM 7

process. It started with, you know, we identified SSC 8

to be included in the program, and then, you conduct 9

a degradation assessment to identify and evaluate all 10 the potential degradations.

11 And the next step is you allocate the 12 reliability target to SSC, and once that's done, you 13 implement your strategies to make sure you meet those 14 target reliabilities. And you implement the program, 15 and then, you monitor and update a program as 16 necessary. I'll go through these steps in more detail 17 in the next few slides.

18 But the concept is very similar to the 19 recent for ISI, but I believe it's more than ISI. ISI 20 is just one of the strategies that can be used.

21 CHAIRMAN BALLINGER: This is Ron Ballinger 22 again.

23 Yesterday, I mentioned that there's a part 24 of the Part 53 discussion that the ASME Fitness-for-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

15 Service Code -- or there's a procedure, FFS-1 --

1 doesn't use the word "RIM," but that Fitness-for-2 Service document takes a quite similar approach.

3 Anyway, again, my personal opinion.

4 MR. LIN: Yes, I believe that's the 5

standard API 571, if I remember right.

6 CHAIRMAN BALLINGER: I think it's 589, 7

590, yes.

8 MR. LIN: Yes. I had a number, but --

9 yes.

10 As I said, I'll walk through these steps 11 in a very high level.

12 But let's go to the next slide.

13 Step 1 is, you know, determine the scope 14 of the SSC to be included in the program. Again, RIM 15 is limited to passive SSCs. So, the scoping core, the 16 passive SSCs whose failure could adversely affect 17 plant safety and reliability.

18 The step itself doesn't really provide a 19 lot of specific guidance on the requirement, on how 20 you, you know, what you need to go about, what SSCs 21 needed to be included in the RIM program. Basically, 22 it required the owner to document a specific list of 23 SSCs that is evaluated to be included in the program, 24 and it also required owners to document the bases for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

16 excluding any SSCs from the program.

1 MEMBER KIRCHNER: Bruce, this is Walt 2

Kirchner.

3 MR. LIN: Yes?

4 MEMBER KIRCHNER: At a high level, what, 5

in practice -- one could use a PRA for defining the 6

scope, for example.

7 MR. LIN: Right.

8 MEMBER KIRCHNER: But, in practice, what 9

was the intent of the ASME Code Committee? Was it for 10 the entire plant? This says the entire life of the 11 plant and "each passive SSC that's in scope." But 12 what's the top-level discriminator for defining what's 13 in scope?

14 MR. LIN: Well, from my discussion with 15 the RIM Committee, I asked the question specifically.

16 I specifically asked the question. I think the scope 17 includes all SSCs in the plant. And I think the PRA 18 would help determine which SSC would have a 19 significant impact on recent reliabilities.

20 MEMBER KIRCHNER: So, reliability is one 21 thing and that impacts operability.

22 MR. LIN: Yes.

23 MEMBER KIRCHNER: And that has a 24 connection to safety. But is it, in your estimation, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

17 is it really focused on those SSCs that are important 1

to safety or those --

2 MR. LIN: Yes, that's -- right.

3 MEMBER KIRCHNER: -- SSCs that are 4

important to reliability of the plant?

5 There is a big difference. Because the 6

first order, you know, I think most designs -- well, 7

I shouldn't say this, I guess. But, you know, the 8

secondary systems can be isolated from the primary 9

systems, and you can define your important-to-safety 10 envelope to the first order. It is that, you know, 11 those primary, NSSS system, or whatever the vendor 12 calls them, as the things that would be in scope. But 13 is this meant to have a scope that's broader, to 14 include the secondary plant, the balance of plant?

15 MR. LIN: Yes. That's why I wish the ASME 16 Committee would have provided more specific guidance.

17 I think that the scope, the standard bases, says all 18 SSCs that can adversely affect plant recent 19 reliability. So, it's very broad and -- yes. I 20 actually raised that question with the Committee.

21 MEMBER KIRCHNER: Yes, in that case, then, 22 the steam generator -- well, that's not a good 23 example. But, you know, all the rest of the balance-24 of-plant, then, comes within the scope, right?

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18 MR. LIN: Yes. Yes. So, the philosophy 1

is, you know, in Division 1 where we have Class 1, 2

Class 2, and Class 3 -- in RIM, there's really no 3

classification. It's all SSCs that can impact the 4

plant safety and reliabilities.

5 DR. BLEY: Well, this is Dennis Bley, 6

following up on Walt there.

7 Risk certainly is affected by the 8

reliability of the components. There ought to be some 9

kind of organization of how important the risk we're 10 talking about. You know, some of the secondary 11 systems are quite important; other ones not so much, 12 but maybe a little. And is it everything that has any 13 impact or is it just the things that are prominent or 14 maybe contribute 5 percent or more, something like 15 that? Is there any quantification of how important a 16 risk you consider in this process?

17 MR. LIN: Yes, right now, the study itself 18 doesn't really provide any quantification or specific 19 requirements. I would imagine this can have some tie-20 in with the Licensing Modernization Project, where the 21 LMPs will help you classify what component is 22 considered safety-significant; what components are not 23 safety-significant. And right now, that's not in the 24 Code. There's no specific guidance other than, you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

19 know, you look at all components that can affect your 1

plant safety, and then, you identify the component 2

that they need to swing into the program.

3 DR. BLEY: Okay. Thanks. So, it at least 4

implies it's the ones that are the most important that 5

you pick up, or at least first?

6 MR. LIN: Yes. Yes, I wish the Code could 7

provide more specific requirements and guidance. So, 8

right now, there's only one paragraph that talks about 9

the scope, and basically, there wasn't a slide showing 10 the --

11 CHAIRMAN BALLINGER: Yes, this is Ron 12 again.

13 I don't think we should underestimate the 14 significance of Division 2 here. It represents an 15 opportunity for a very significant change and sort of 16 reorientation of outlook, if you will, on system 17 reliability. It's 150 pages long, but Division 1 is 18 like 600 pages.

19 MR. LIN: Right.

20 CHAIRMAN BALLINGER: Keep going.

21 MR. LIN: Okay. Let's go to the next 22 slide.

23 So, once the SSC is identified, the next 24 step is to evaluate all potential degradations that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

20 can apply to the SSCs. You know, some things to 1

consider include design characteristics, including 2

materials; fabrication practice, including welding, or 3

what can also contribute to or introduce a degradation 4

mechanism, if it's not properly done.

5 Other conditions to consider include 6

degradation introduced by operating, and all transient 7

conditions, including temperature and pressure 8

excursions.

9 Also, a degradation mechanism based on 10 plant-specific or industry experience. You also need 11 to consider including recommendations from SSC 12 vendors.

13 Again, mandatory Appendix 7 identifies all 14 the potential degradation mechanisms that are 15 applicable to various reactor types. Again, many of 16 the supplements are still under development. And the 17 criteria that is used to identify and evaluate the 18 susceptibility of SSCs to degradation mechanisms would 19 need to be documented in the RIM program 20 documentation.

21 Next slide.

22 So, the next step in the process is to 23 identify the plant recent reliability topic for RIM.

24 Again, this just came out from RIM 2.4.1. The plant-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

21 level reliability goals are derived, basically, from 1

the regulatory limits on risk frequencies and 2

radiological consequences of licensing basis events, 3

as defined in the PRA.

4 The PRA model is also used to allocate or 5

to establish SSC-level reliabilities. The RIM 6

standard, again, doesn't really provide a lot of 7

detailed guidance on how to go about doing this. It 8

provides a general post or event in Appendix 2 on how 9

you divide component reliability from plant safety 10 requirements.

11 As you can see, the PRA plays a key role 12 in this step and it is important that the scope and 13 level of detail in the PRA is sufficient to support 14 the allocation of SSC reliability targets.

15 In RIM 2.43, it provides the requirements 16 regarding the technical accuracy and the scope of the 17 PRA, and it, basically, requires that the PRA needs to 18 meet the ASME/ANS RA-S-1.4 standards, which is the PRA 19 standard for advanced non-LWRs.

20 So, step four is, once you identify your 21 target reliability, the next step is to identify the 22 RIM strategies that are available to meet the 23 reliability targets. You know, you can use a single 24 reliability target -- or strategy I mean, or your 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

22 combination of strategies that's needed to meet the 1

targets.

2 The strategies could include design 3

strategies to reduce or eliminate the degradation 4

mechanism or you can use online leak detection or 5

perform inservice inspections or repair and 6

replacements, et cetera.

7 The impact of these RIM strategies on the 8

reliability target will need to be assessed.

9 Okay. Next slide.

10 So, after selecting the RIM strategies, 11 the next step is to evaluate the uncertainties. If 12 there are inherent, very large uncertainties in the 13 prediction of passive SSC reliability, some of those 14 uncertainties are plentiful in the allocation of 15 reliability targets, but the other source of 16 uncertainties is just difficult to quantify, such as 17 unknown degradation mechanisms, or just lack of 18 operating experience.

19 So, to account for some of these 20 uncertainties, you can implement multiple RIM 21 strategies over and above what's required in order to 22 provide additional assurance and, also, provide 23 defense-in-depth.

24 So, the next step is in advance you have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

23 to program; you implement the program. And prior to 1

implementing the program, RIM program documentation is 2

developed. This documentation includes the results 3

from steps one to five, and includes the scope of the 4

SSC that is selected for the program; the result of 5

the degradation assessments; the reliability targets, 6

and the specific RIM strategies that you selected to 7

meet those reliability targets.

8 So, this is a very important document, as 9

you will hear from the later presentation. One of the 10 conditions in the Regulatory Guide endorsing RIM is to 11 require submittal of this information to NRC for 12 review and approval.

13 The other aspect of implementing a RIM 14 program includes -- some of the items are listed here 15

-- the inspection intervals. In RIM, the inspection 16 interval is determined by the RIM Expert Panel. I'll 17 briefly describe that panel in the next slide. But it 18 does have a limit of 12 years. The reason for that is 19 because we want to have a step when they have to 20 update the programs.

21 For several reasons, inspection is only 22 done if in some ways the inspection is selected as a 23 RIM strategy. So, you can have a baseline to start 24 with.

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24 RIM may also involve design requirements 1

to support a select RIM strategy, such as provisions 2

for an online leak detection system.

3 The other key aspect of the RIM program is 4

examination and inspection requirements. Again, 5

there's another Expert Panel that is responsible for 6

all aspects related to this, and it's the monitoring, 7

the NDE Panel. So, it's responsible for all things 8

related to NDE or inspections.

9 Okay. So, the final step in the RIM 10 program is to put in place a monitoring program that 11 will monitor the performance of the SSCs within the 12 program and update the RIM program to account for, for 13 example, a change in plant design, operations, 14 operating experience, and results from monitoring and 15 NDE, to update the PRA, or any other technical input 16 that you use in the initial RIM program.

17 So, this step is very similar to the risk-18 informed ISI program. So, you have to, basically, 19 continue to monitor your program and update, as 20 necessary. And the minimum frequency of update is 21 once per inspection interval.

22 Here, I mentioned there's two Expert 23 Panels already. They play a key role in implementing 24 the RIM program. The RIM Expert Panel is, basically, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

25 responsible for the entire program, responsible for 1

the technical oversight, and the development and 2

implementation of the RIM program. So, this panel is 3

responsible for establishing the RIM scope, the 4

reliability

targets, and identifying the RIM 5

strategies.

6 The Monitoring and NDE Expert Panel is 7

responsible for, basically, all things related to NDE.

8 They're responsible for developing, monitoring NDE 9

specifications; overseeing the quantification of NDE 10 methods and techniques.

11 And there are specific requirements in the 12 Code related to the qualification and who needs to 13 serve on these panels.

14 Next slide.

15 So, this slide just shows, and the next 16 couple of slides just walk you through, what's in RIM.

17 This slide shows the organization of RIM. The 18 structure is very similar to Division 1, except for 19 Article RIM-2, which is the RIM program. So, RIM-1 is 20 scope and responsibility. This section covers the 21 scope of RIM, the owner's responsibilities, and other 22 general requirements. It's very similar to Division 23 1 IWA-1000. As a matter of fact, a lot of the 24 descriptions will refer back to IWA for a lot of the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

26 requirements.

1 And Article RIM-2 is the RIM program, 2

which is -- I covered the process.

3 RIM-3 is acceptance standard, and it 4

refers to Appendix 7 for acceptance standards for each 5

reactor type.

6 And RIM-4 covers repair and replacement 7

activities and is done -- essentially, it refers back 8

to IWA-4000, which is the rules for repair and 9

replacement activities, with a couple of exceptions.

10 One is related to preservice inspection, and then, the 11 other exception is related to pressure testing.

12 And RIM-5, basically, provides rules for 13 leakage monitoring and leak detections -- retesting.

14 And RIM-6 covers reporting requirements 15 and is similar to Division 1, IWA-6000.

16 DR. BLEY: Bruce?

17 MR. LIN: Yes?

18 DR. BLEY: RIM-3, is that expected to get 19 expanded, as people consider different reactor types?

20 MR. LIN: Yes. Well, right now, RIM-3, 21 basically, refers the user to Appendix 7. Appendix 7 22 will, basically, have reactor-specific requirements or 23 reactor-specific acceptance standards. So, for each 24 reactor type, they'll have their own acceptance 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

27 standards.

1 DR. BLEY: Okay. And I'm assuming that's 2

not complete and will have to be expanded, if new 3

types are brought forward.

4 MR. LIN: Right. Right. Right now, only 5

two reactor types are complete, including the high 6

temperature gas reactors --

7 DR. BLEY: Uh-hum.

8 MR. LIN: -- and the Gen III or above 9

light water reactors.

10 DR. BLEY: Okay. Thank you.

11 MEMBER KIRCHNER: Bruce?

12 MR. LIN: Yes?

13 MEMBER KIRCHNER: This is Walt Kirchner.

14 Along those lines of Dennis' question, it 15 seems to me that -- I'm speculating, to be candid --

16 that these implements for each reactor type really are 17 driven by the coolant choice. I mean, the ASME is in 18 the pressure vessel business, so to speak.

19 MR. LIN: Right.

20 MEMBER KIRCHNER: So, the defining 21 characteristic probably is a combination of the 22 coolant type and the temperature-pressure ranges that 23 are expected for the reactor type. Is that a 24 reasonable assessment of what's coming for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

28 supplements? I can't imagine doing a supplement --

1 you know, you could have someone do one variation of 2

a molten salt reactor, and someone else do another 3

variation, but, in general, the pressure vessels don't 4

know that it's a different reactor. You know what I 5

mean?

6 If you need to use a pressure vessel of 7

some kind for a molten salt reactor, it doesn't care 8

whether it has pebbles in it or not.

9 MR. LIN: Right.

10 MEMBER KIRCHNER: So, is that the way it's 11 going? Is it more like that or you're trying to go 12 with the Gen IV and DOE designs that are being 13 supported?

14 MR. LIN: Yes, I --

15 MEMBER KIRCHNER: It seems to me there 16 might be an opportunity to make this more technology-17 neutral in terms of the details of the reactor design 18 and focus on what the pressure vessel, boiler and 19 pressure vessel code is all about, which is 20 maintaining the integrity of the component, not 21 picking sides about reactor types.

22 MR. LIN: Right. I think the strategy is 23 that the RIM process itself is technology-neutral.

24 You can use the process on any reactor type. And the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

29 idea with Appendix 7 is, you know, some of the 1

degradation mechanism is unique to the reactor design.

2 Like, for example, you choose different coolant; that 3

has different degradation mechanisms. So, if you 4

operate at high temperature, then you maybe have to 5

worry about creep and other high-temperature 6

degradation mechanisms.

7 So, Appendix 7 is supposed to have 8

reactor-specific degradation mechanisms, reactor-9 specific evaluation standards, and acceptance 10 standards that are all based on the unique design, 11 right? For some of those reactors, they could be 12 operated at atmospheric pressure. So, it's different 13 than the traditional requirement for RPVs. So, they 14 will have their own acceptance standards and unique, 15 their own lists of degradation mechanisms. It depends 16 on the reactor type.

17 DR. BLEY: Bruce, this is Dennis Bley 18 again.

19 We had a session yesterday on Part 53 20 where we're looking at different approaches. And some 21 of those approaches, they require principal design 22 criteria and others they don't.

23 This Reg. Guide is anchored to a set of 24 advanced reactor design criteria that specifies 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

30 certain kinds of testing that need to be done.

1 I suppose, even if someone uses this new 2

Part 53 and does not define their own Principal Design 3

Criteria, that, at least for most of the designs we 4

expect to see, the ARDC will probably be reasonable.

5 So, that shouldn't cause a problem. But if some new 6

reactor type comes in that would require different 7

design criteria, I guess that changes this whole 8

process. But that's what the appendices will make 9

clear, I'm guessing?

10 MR. LIN: Right. I mean, I think, like I 11 said, the process itself is very technology-neutral.

12 I would imagine each reactor vendor or designer would 13 have to go through the process and develop their own 14 unique RIM program. You know, maybe for one reactor, 15 it's reasonable to inspect every five years, but they 16 may not incorporate for other reactor designers for 17 the same components, because they operate in a 18 different environment. So, I think each reactor 19 design, a unique design, will probably have their own 20 unique RIM program.

21 DR. BLEY: Okay. Thanks.

22 I guess, for Dave, if you're on the line, 23 we had that discussion yesterday about not needing 24 principal design criteria. Well, here we're bumping 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

31 into a place where you need almost the equivalent to 1

come out of the process, to be able to use this Reg.

2 Guide and the new standard. So, something to think 3

about.

4 MEMBER PETTI: Yes. No, I think that may 5

have just been almost semantic. I still think Part 53 6

requires design criteria. They used the word 7

"principal" because it was tied back to 50 or 52.

8 But, yes, your point is noted.

9 MEMBER KIRCHNER: Well, Dave, this is 10 Walt.

11 Given the importance of reliability to 12 support the PRA results through the life of one of the 13 plants that goes through the LMP process in 53, do you 14 see this being invoked directly by 53, or it would be 15 through guidance?

16 MEMBER PETTI: I mean, right now, probably 17 guidance. And what's in there, you know, is 18 acceptable codes and standards, right?

19 MEMBER KIRCHNER: Yes.

20 MEMBER PETTI: And this is one that's been 21 accepted by the staff.

22 MEMBER KIRCHNER: Yes. I'm just trying to 23 think through the wording in 53. Is there any 24 requirement for a reliability program to support the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

32 PRA through the life cycle of the plant?

1 MEMBER DIMITRIJEVIC: Walt, do you have a 2

draft? This isn't connected to the passive 3

components. So, let's sort of like step back a 4

little. You know, the passive components, you know, 5

like if it's related to risk-informed ISI, which I'm 6

very familiar with, that is related to just the 7

typings of the different class, which are usually not 8

in the PRA directly, but can be connected to the 9

active components. Several of the passive components, 10 like a check-well, is added in the PRA. This is 11 limited. Most of those things can cause initiating 12 events, and from that perspective, you know, like 13 steam line breaks, feedwater line breaks that lock.

14 So, the active components, which most of 15 the PRA consists of, are in the RAP program. I mean, 16 that's in the FSAR. You know, it would be part of the 17 ITAAC items.

18 MEMBER KIRCHNER: Yes, I get that, Vesna.

19 I was just trying to think through. So, say, you 20 know, this program is to actually maintain the 21 reliability, so that you don't challenge the 22 assumptions. But, you know, from the PRA standpoint, 23 don't you look at the possibility -- I mean, an 24 initiating event would be a break in a passive 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

33 component.

1 MEMBER DIMITRIJEVIC: Yes, that's true.

2 But, you know, you have ITAAC items which cover 3

testing, inservice inspections, the RAP program, which 4

is directly connected reliability. It has the same 5

panels that's already part of the FSAR.

6 MEMBER KIRCHNER: Right. No, I understand 7

that. I'm just thinking -- I'm trying to think 8

through the life-cycle impact of doing this.

9 Basically, it's there to ensure that --

10 MEMBER DIMITRIJEVIC: Well, currently, you 11 have (audio interference) actions. You have intent, 12 yes, testing the valves, which are part of ITAAC.

13 Currently, all the plants, almost all the plants in 14 like the states are doing risk-informed inservice 15 inspections.

16 So, I mean, you know, I don't think we 17 have to worry will that be covered. You know, that's 18 what I was trying to respond to your question. It's 19 a part of the ITAAC problem, yes.

20 MEMBER PETTI: I think the place to look 21 will probably be in TCAP and RCAP, where commitments 22 are made. I don't know which one; I don't recall.

23 But that's, you know, that's basically the content of 24 applications. It's somewhere in there the applicant 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

34 would commit to this kind of program.

1 MEMBER KIRCHNER: Would this -- Dave, I'm 2

also thinking through. We didn't do Subpart F 3

yesterday. But would this show up in operations?

4 MEMBER PETTI: It might. I just don't --

5 I don't remember. I don't recall in Subpart F if this 6

is touched on. I'd have to go back and look.

7 MR. PHILPOTT: Good morning.

8 This is Steve Philpott. I'm a Project 9

Manager in DANU. I'm going to be your next speaker.

10 But I would just add in that part, there 11 is a section in Part 53, in the preliminary proposed 12 rule language -- and I'm not sure what subpart it is; 13 in operations I believe, 53.870 -- that would include 14 a requirement for integrity assessment programs. And 15 so, this lines up well with some of that language now.

16 It would be a way of, you know, a method for 17 addressing that section.

18 MEMBER KIRCHNER: Yes, that's what I was 19 thinking. Thank you.

20 MEMBER PETTI: Yes. Okay. Thanks.

21 MR. PHILPOTT: And there is also, in the 22 RCAP program that you're referring to, there is an ISG 23 that we're working on developing to release that is 24 specific to inservice inspection and inservice testing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

35 both. It covers both LWRs and non-LWRs.

1 And that also, for the non-LWR ISI portion 2

of that, it does refer to RIM as a method to address 3

the information in the application.

4 MEMBER KIRCHNER: Great. Okay. Thank 5

you.

6 MR. PHILPOTT: Sure.

7 CHAIRMAN BALLINGER: This is Ron again.

8 The industry has been bound by Section XI, 9

Division 1, from the beginning. But, as a practical 10 matter, within Division 1, the inspection regimes, the 11 use of risk information, and all of that, has evolved 12 to the point where they don't call it RIM, but, in 13 effect, that's what the industry has been doing for 14 the last 10 or more years.

15 And so, it's not that big a jump, as a 16 practical matter, from Division 1 to Division 2. And 17 I look at it as Division 2, while it's applicable to 18 non-light water reactors, and everything, it's an 19 outgrowth of the, if you want to call it, lessons 20 learned from dealing with Division 1 and the 21 degradation in our systems.

22 Maybe that's a simplistic way of looking 23 at it, but, you know, I look at this as, basically, a 24 codifying of what, in effect, people have been doing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

36 all along, or evolved to be doing now in the light 1

water reactor business.

2 MEMBER KIRCHNER: I think you got it 3

right, Ron.

4 MEMBER PETTI: Yes, I think that's right.

5 The biggest difference is the materials are different; 6

the service conditions are different. So, the damage 7

mechanisms are different. And so, that may in the 8

details change, you know, the nature of the 9

inspection. You know, what you look for and how you 10 look for it might change because of all of those 11 things.

12 CHAIRMAN BALLINGER: Yes.

13 MEMBER PETTI: But, at a higher level, I 14 agree with you, yes.

15 CHAIRMAN BALLINGER: I mean, this is, 16 basically, a codified way of doing, what I would call 17 in the information theory business, surprise.

18 MEMBER DIMITRIJEVIC: But this is very 19 important to the monitoring program because, you know, 20 when you start those inspections, you can discover 21 degradation mechanisms which you didn't really 22 anticipate. So, for this new-type monitoring program 23 for that, new degradations are very important.

24 CHAIRMAN BALLINGER: Yes, in our business, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

37 surprise has cost us a lot of money.

1 Okay. Could we keep going? This is very 2

good discussion, actually.

3 MR. LIN: So, I think this is my last 4

slide.

5 RIM also has seven non-mandatory -- or 6

mandatory appendices and two non-mandatory appendices.

7 I'm not going to go through the list, but I'll just 8

mention a few that I haven't talked about.

9 Like Appendix 4,

Monitoring NDE 10 Qualifications, basically, provides requirements for 11 qualification of monitoring NDE methods and addresses 12 qualification of NDE personnel, procedures, and 13 equipment.

14 Appendix 6,

the qualifications and 15 requirements for the RIM Expert Panel.

16 Again, the big appendix is this Appendix 17 7, which is a supplement for the type of nuclear 18 plant. So, right now, the Code itself has a 19 placeholder for six different reactor types and two 20 have been developed. As I mentioned before, high 21 temperature gas reactors and Gen III or above light 22 water reactor supplements are done. The others are 23 under development.

24 And two non-mandatory cover alternative 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

38 requirements NDE and monitoring and, basically, 1

administrative requirements for --

2 DR. BLEY: Can you tell us anything about 3

that Appendix A? What kind of alternatives are they 4

talking about?

5 MR. LIN: Appendix A, basically, provides 6

a process that you can go through to use different NDE 7

and monitoring techniques. I tried to figure it out, 8

because I think this is that there is a code case that 9

was issued before RIM was published, and this Appendix 10 A, basically, is that code case. It provides, it 11 tells you how you go about doing probabilistic 12 assessment to develop different NDE methods. To me, 13 it's really no different than what's in RIM. I don't 14 know why it's in the non-mandatory appendices.

15 (Laughter.)

16 DR. BLEY: Okay.

17 MR. LIN: It's, essentially, it's part of 18 the RIM. It could be part of the RIM process that you 19 can go through and using different RIM strategies. It 20 was put in there, I think, from what I understand --

21 and I wasn't involved with the development of the code 22

-- there was a code case. I think it was code case 23 875 was issued before RIM was accomplished, and the 24 information from the code case got put into this 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

39 Appendix A.

1 DR. BLEY: Okay. Thanks.

2 MR. LIN: Okay. So, I think that's it, 3

and I'll turn it over to Steve Philpott to discuss the 4

staff review of the RIM standard and the Regulatory 5

Guides.

6 MR. PHILPOTT: Okay. Well, thank you, 7

Bruce.

8 As Bruce mentioned, my name is Steve 9

Philpott. I'm a Project Manager in the Division of 10 Advanced Reactors and Nonpower Production Utilization 11 Facilities. I was the Lead Project Manager for most 12 of the review of RIM.

13 I'm thankful and excited to be here to 14 give you an overview. My goal here is to give you an 15 overview of the review process and the review that we 16 did, but, mostly, give you a summary of what the Reg.

17 Guide is; how it's structured, and touch on some of 18 the conditions, and a summary of the public comments 19 that we received when we issued the Draft Guide, and 20 how we resolved those. We'll step through it for you 21 here.

22 So, go ahead and go to the next slide, 23 please.

24 So, a little bit about the background of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

40 RIM and our review. ASME sent a letter to the NRC and 1

requested that NRC endorse RIM, the Standard XI, 2

Division 2, in October of 2091. And they specifically 3

asked that we endorse it via 50.55a.

4 We put some staff together to start 5

reviewing it and met with our NRC Design and 6

Inspection Steering Committee in both the spring and 7

summer of 2020. After we had some time to review it, 8

it went to them with recommendations.

9 We recommended, and the decision was made, 10 to not endorse by 50.55a, because that would require 11 the use of RIM, typically, if we encoded it in 50.55a, 12 which we did not think was appropriate at this stage.

13 But, rather, we formed a working group to endorse it 14 via a Reg. Guide, as to make it an option for 15 applicants to use, applicants and licensees. So, I'll 16 talk about that a little bit further in the 17 presentation when we get into some of the public 18 comments.

19 So, we responded; we formed a review 20 working group, and we responded to ASME. Once we 21 decided to go ahead and review it for endorsement via 22 a Reg. Guide, we sent a letter back to ASME and 23 responded in August of 2020.

24 That working group that we developed was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

41 made up of a team of experienced NRC staff in 1

Component Integrity, Inspection Testing, Codes and 2

Standards, and PSI and ISI programs, and that included 3

some senior technical staff from the DANU Division, 4

the Division of Advanced Reactors, as I mentioned --

5 I'm just going to use that DANU acronym for the rest 6

of the way -- as well as, as you saw from Bruce, from 7

the Office of Research and their Division of 8

Engineering. We had staff from Region II and Region 9

IV included in the working group with experience in 10 inspections, inservice inspections, and testing, as 11 well as other Divisions in NRR as well, the Division 12 of Engineering there as well. And at times throughout 13 the review, we also consulted with other senior 14 technical staff in the Division of New Reactor 15 Licensing and some of the senior advisors in Research 16 as well.

17 I guess one point to note is we had one of 18 our senior staff, along with Bruce, who I definitely 19 would consider an expert, we had, also, a Senior 20 Mechanical Engineer, Tim Lupold, who was our NRC 21 representative on the ASME Working Group for the 22 Development of RIM. He was also a lead technical 23 reviewer and did a lot of heavy lifting and worked 24 with us. He recently retired. So, we got to use his 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

42 skills and his expertise right up until the end, and 1

even through the comment resolution period.

2 Oh, and I should also mention that the 3

Office of General Counsel, you know, while not part of 4

the working group, we did get a lot of effort and a 5

lot of good support from OGC, as we worked through 6

some of kind of the unique licensing aspects of this 7

as well and working through the comment resolution as 8

well. So, we're definitely appreciative of that as 9

well.

10 So, we, then proceeded to conduct a 11 review, a very thorough, detailed review of Section 12 XI, Division 2, for this, developing the Reg. Guide 13 for endorsement. And we specifically did this review 14 for applicability to non-light water reactors, as that 15 was the near-ter need that we saw. The light water 16 reactors are required to use 50.55a, or under 50.55a, 17 are required to use Division 1. And frankly, where we 18 saw the most immediate need was in the non-light water 19 reactors.

20 DR. BLEY: So, a quick question about 21 that.

22 MR. PHILPOTT: Yes? Uh-hum.

23 DR. BLEY: The Reg. Guide is specific to 24 non-light water reactors. The standard itself, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

43 though, is not, is that correct?

1 MR. PHILPOTT: That's correct.

2 DR. BLEY: Okay.

3 MR. PHILPOTT: The standard is written to 4

be technology-neutral and to apply across 5

technologies. That was a strategic decision at the 6

beginning, that we were going to focus our review on 7

the non-light water reactors. So, it is specifically 8

endorsing it for non-light water reactor applications.

9 And, you know, that may change over time, 10 but at this stage, you know, I think you were alluding 11 to before, RIM is very much a paradigm shift, right?

12 It's a big shift from Division 1. And so, you know, 13 I think we see this as an exciting win moving forward 14 for these non-light water reactors in terms of being 15 able to provide this as an option for the non-lights.

16 We understand that --

17 MEMBER KIRCHNER: This is Walt Kirchner.

18 MR. PHILPOTT: Yes.

19 MEMBER KIRCHNER: But, if I understand 20 correctly, of the two supplements in place, one is for 21 advanced LWRs.

22 MR. PHILPOTT: The two supplements? I'm 23 sorry, are you talking about Appendix 7?

24 MEMBER KIRCHNER: Yes, in the actual --

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

44 MR. PHILPOTT: In the RIM, the Appendix 7, 1

where they have the plant-specific criteria, yes. One 2

of them is for LWRs, and another one -- several of 3

those are blank, right, they're yet to be developed.

4 There is one --

5 MEMBER KIRCHNER: No, I understand that --

6 MR. PHILPOTT: yes.

7 MEMBER KIRCHNER: -- but I don't 8

understand why you're restricting it. Is this 9

viewgraph accurate of what you're -- are you only 10 endorsing it for non-LWRs?

11 MR. PHILPOTT: We are only endorsing it 12 for non-LWRs, yes, that is correct.

13 MEMBER KIRCHNER: Why is that?

14 MR. PHILPOTT: Well, primarily because 15 50.55a(g) requires a light water reactor applicant to 16 use Division 1 in that paragraph of 50.55a. So, a 17 light water reactor, by regulation, is required to use 18 Division 1.

19 Now, we understand that, for some advanced 20 on the light water side, that this could be -- that 21 Division 1 would be very difficult to apply for some 22 of the advanced light water reactors that we see 23 coming down the road. And they do have an option to 24 use RIM, but they would have to use the exemption 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

45 process to do that, because of the requirement in 1

50.55a. And we understand that that may happen.

2 So far, we're not seeing a lot of interest 3

yet from the LWRs. So, we focused our efforts on 4

endorsing this for non-light water reactors. We do 5

understand that there may be some future light water 6

reactors that do want to use it, and we do know of 7

one, in particular, that does, but their process to do 8

that would be through an exemption from 50.55a(g), and 9

then, we do a plant-specific review in that case.

10 DR. BLEY: This is Dennis again.

11 MR. PHILPOTT: Uh-hum.

12 DR. BLEY: The ASME asked you to review it 13 under part of the regulations where it can't fit 14 unless you change the regulation, basically, is the --

15 MR. PHILPOTT: Right.

16 DR. BLEY: Okay. So, you would have had 17 to do a change to the reg to do that and make it 18 applicable.

19 MR. PHILPOTT: That's correct.

20 DR. BLEY: Nothing in your review would 21 have precluded LWRs from using this, except for the 22 regulation?

23 MR. PHILPOTT: Right. Yes. And I think 24 that's, generally, safe to say; that's generally true.

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46 I mean, nothing that -- no, there was nothing that 1

stood out in our review that would specifically 2

exclude LWRs. It's just we did not review it with 3

that focus, and it primarily is the regulation, yes.

4 We would have to do a rulemaking effort to 5

modify the regulations. You know, we did consider 6

that during the review period, you know, different 7

rulemaking options. But, ultimately, we decided, when 8

we went back to the Steering Committee and the 9

Management Oversight Committee, we did decide that 10 that was not the appropriate pursuit at this point, 11 given the level --

12 DR. BLEY: I'm just curious. Has anyone 13 requested a rulemaking on this issue to include it for 14 LWRs?

15 MR. PHILPOTT: Yes, actually. And 16 actually, I'll touch on that briefly when we get to a 17 few --

18 DR. BLEY: Okay.

19 MR. PHILPOTT: -- slides later in some of 20 the comments.

21 DR. BLEY: Fine.

22 MR. PHILPOTT: Yes. And, yes, I neglected 23 to mention, in terms of the review group that we did 24 and the working group, we did also guide and meet 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

47 frequently -- as part of the project plan for this 1

review, there was an established Management Oversight 2

Group at the Branch Chief level that we would meet 3

with on a frequent basis and provide updates, and were 4

guided by some of our decisions that way. And then, 5

we did periodic followups with the Steering Committee 6

on some of the key decisions as well. So, we worked 7

through all those type of questions and issues in 8

those meetings.

9 CHAIRMAN BALLINGER: This is Ron Ballinger 10 again.

11 I mean, again, there's a regulatory fence 12 between the two --

13 MR. PHILPOTT: Uh-hum.

14 CHAIRMAN BALLINGER: -- Division 1 and 15 Division 2, but, as a practical matter, within 16 Division 1, the industry has been doing or evolved to 17 doing what is, in effect, a lot of it is in Division 18 2.

19 So, an exemption request would probably be 20 pretty easy.

21 MR. PHILPOTT: It may be. I mean, I guess 22 it remains to be seen. But, yes, we understand that, 23 clearly, some of the new light water reactors, 24 Division 1 is not going to be their preferred path, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

48 right?

1 CHAIRMAN BALLINGER: Yes.

2 MR. PHILPOTT: But you're right, we're 3

going to have to review that through the exemption 4

process in this case.

5 And that could evolve -- you know, 6

obviously, the regulatory framework for this could 7

evolve; I expect it probably will evolve over time, 8

right? We were reviewing this based on this submittal 9

and kind of our view of the landscape at the time that 10 we conducted this review.

11 But RIM is, you know, as I think you've 12 kind of seen, there's still a lot of development to 13 do. We don't have any experience with plants using 14 RIM or submitting RIM programs to us, obviously. So, 15 over time, we do expect to try to gain, you know, to 16 hope to gain more of that experience and see what's 17 involved, and see how it could be applicable 18 otherwise.

19 Okay. I think we can go to the next 20 slide.

21 Okay. So, this just kind of provides a 22 timeline of the work that we did. Not a lot of 23 details to share with you here, but, essentially, once 24 we formed that working group from that early initial 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

49 stage, August to December of 2022, we did an initial 1

review with the working group and developed our 2

initial staff positions.

3 And the focus there was to do a first cut, 4

and we confirmed that information in the Code was 5

adequate and it was appropriate to be endorsed. We 6

certainly identified some areas that would likely 7

require conditions, which we did end up having, but we 8

went back to the Steering Committee at that point and 9

received the decision to move forward with a more 10 detailed review and focus on endorsing it via the Reg.

11 Guide.

12 So, in 2021, most of the first nine months 13 of 2021 is when we did the detailed review, went step 14 by step through each of the positions and paragraphs 15 within RIM. Reached out to other technical experts in 16 the agency, and as I mentioned Tim Lupold was on the 17 working group with RIM development. So, during 18 meetings with that working group, he was able to reach 19 back out to them to help get answers to questions and 20 things that weren't clear to us, as we did that 21 initial review. So, all that.

22 We developed the Reg. Guide, Regulatory 23 Guide, in that time period, and then, we published it 24 for public comment right near the end of September 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

50 2021. And we published it with a 45-day comment 1

period. And since that point, since November, we've 2

been working on the comment resolution and finalizing 3

the Regulator Guide.

4 We are on track to publish it. It's ready 5

to go. For the most part, we've got that it will now 6

be published in June of 2022.

7 As Michelle mentioned in her opening 8

remarks, it's tied into, there is some reference in 9

the Reg. Guide to conditions in Section XI, Division 10 1, the 2019 edition. So, in order to not get ahead of 11 that, we are waiting for the rulemaking to be 12 finalized for Division 1 to be incorporated. So, this 13 will be published as soon as that rulemaking is 14 finalized.

15 Okay. Next slide, please.

16 This is just a brief overview of the 17 structure the Reg. Guide. I think this is pretty 18 standard for Reg. Guides. So, I just kind of point it 19 up here to note a few points about the way the 20 Regulatory Guide is laid out. And these are the main 21 points I just want to make.

22 Section A, obviously, addresses the 23 purpose of the Regulatory Guide, which describes an 24 acceptable approach for the development of an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

51 implementation of a PSI and ISI program for non-light 1

water reactors by endorsing this.

2 The other point of that to note here is it 3

also describes a method that applicants can use to 4

incorporate their preservice inspection and inservice 5

inspection programs into a licensing basis. So, I'll 6

touch on that a little bit later.

7 But the main point there is the current 8

regulations in 50 and 52 don't specifically call out 9

a requirement for a non-LWR to have an inservice 10 inspection program. So, they do, in content of 11 applications sections, they do mention needs for 12 periodic testing of structures and maintenance and 13 surveillance, and that sort of thing.

14 But the license condition, again, this is 15 an area that we worked with OGC quite a bit and 16 determined that the best way at this point to make 17 sure that an inservice inspection program is part of 18 an non-LWR license basis was to include a license 19 condition with the application. And the Reg. Guide 20 provides a sample license condition that an applicant 21 can use to do that.

22 It addresses the applicability very 23 briefly. Of course, as I mentioned, it's specifically 24 applicable to non-LWR applicants or licensees for an 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

52 operating license or a combined operating license 1

under Parts 50 and 52.

2 This is one of the guidance documents, one 3

of several that will eventually support Part 53, when 4

that becomes final, but, again, it's one of the many 5

documents that will be reviewed for conforming changes 6

and updates to make it applicable to Part 53 as well, 7

when we get to that stage in the Part 53 process.

8 We touched on the applicable regulations 9

and related guidance. As I started to mention, the 10 current regulations don't specifically mandate an ISI 11 for non-LWRs. There's 50.34 and 52.79 sections in the 12 content of applications that require those 13 applications to include plans for conducing normal 14 operations, including maintenance accounts, periodic 15 testing of structures, systems, and components.

16 The Reg. Guide gets into a discussion of 17 the General Design Criteria -- it's Appendix A of Part 18 50 -- and how those can be adapted or can provide some 19 guidance for non-light water reactors or reactor 20 designs other than the light water reactors.

21 And then, we do point out, and the Reg.

22 Guide includes, a bit of discussion on Reg. Guide 23 1.232, which is guidance for developing the Principal 24 Design Criteria for the non-light water reactors. And 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

53 then, the Reg. Guide spells out a number of the 1

applicable ARDCs, Advanced Reactor Design Criteria, 2

that relate to SSC testing and provide some basis for 3

this approach.

4 So, Section B provides a lot of the 5

background of how we developed the regulatory basis 6

for it. It, again, discusses that, what I just 7

mentioned, in terms of the regulations in more detail; 8

the fact that they prescribe specific preservice and 9

inservice inspection only for boiling and pressurized 10 water reactors, and it goes through that discussion 11 and develops that process.

12 It highlights several of the ARDCs, as I 13 mentioned, from Reg. Guide 1.232 that reflect the 14 importance of inspection. It briefly summarizes the 15 RIM process for developing a PSI and ISI program, and 16 again notes the purpose and scope of the staff's 17 review.

18 And then, the bases, kind of the meat of 19 the Reg. Guide is the bases for the NRC staff's 20 positions. So, that part goes through the staff's 21 positions or the staff regulatory guidance or the 22 conditions for the use of RIM. And it goes through in 23 detail each of those conditions and provides the 24 background of the staff's review and the reasoning for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

54 those conditions. There are 15 conditions overall in 1

the Regulatory Guide, and I'll get to those as well.

2 Section C, it is the more brief, concise 3

listing of the specific conditions or guidance 4

positions.

5 Okay. Next slide, please.

6 And I apologize, I'm a little under the 7

weather today. So, I'm going to sip some water from 8

time to time as we go.

9 Okay. The Regulatory Guide conditions.

10 Just as I mentioned, there are 15 conditions total 11 listed within the Regulatory Guide. Many are, I would 12 say some are just maybe minor or more kind of focused 13 and more specific, not maybe as significant. So, I 14 don't intend to go through all 15, but we'll do a bit 15 of an overview and a summary. And I do have, the next 16 slides, I do list what those are in general.

17 But, starting with Condition 1, was the 18 first one, and this is where we provide two things.

19 Condition 1 does two things. It calls out the need 20 for the license condition. It mentions that 21 applicants intending to use RIM should use a license 22 condition. And as I mentioned, it gives you an 23 example of a license condition they can use.

24 Secondly, it identifies the information 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

55 that should be included with their application as an 1

initial application. So, this is when they're coming 2

in with their initial application and to describe 3

their RIM program.

4 So, in order to support our finding that 5

they meet those 50.34 and 52.79 content of application 6

requirements, we ask them -- in the Reg. Guide, it 7

provides a list of -- a review summary of the RIM 8

program, and it gives some specific examples of what 9

that should include: things like listing of the SSCs 10 that are in the RIM program. We ask them to describe 11 the methodology for establishing the reliability 12 targets; the methodology for determining that the 13 reliability targets will be satisfied by the 14 registered strategies. So, we ask them to identify 15 what those reliability targets are, things like flaw 16 evaluation acceptance criteria, et cetera. So, that 17 all would be included in their initial summary of RIM.

18 And then, there's a number of other 19 requirements that, as we've gone through the review, 20 are highlighted in the specific conditions throughout 21 the rest of the particular sections, where there are 22 certain things that we ask them to provide. So, 23 things like qualification and certification programs 24 and justification for their PRA, et cetera. Any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

56 alternatives that they're taking to actual Section XI, 1

Division 2, we would like them to identify that in the 2

application.

3 Condition 4 is where we address any 4

changes to a RIM program after they've had their 5

program submitted to us and it's been reviewed and 6

approved by the staff. In Condition 4, we talk about 7

they can make changes to their program without 8

identifying or without notifying us, but we list some 9

specific areas where we do require submittal to the 10 NRC for review and approval. So, there are some 11 things that we ask them to provide for review and 12 approval; other things that should be submitted to the 13 NRC just for information that we can follow up on, if 14 needed.

15 For review and approval, this focuses on 16 things like changes to the methods to establish the 17 reliability targets and the methods that they use to 18 demonstrate that the reliability targets will be met; 19 any other alternatives to the Code. Again, if they 20 want to implement a new alternative to the Code, they 21 need to send that to us for review and approval. Any 22 changes involving alternate examination methods would 23 need to be submitted for review and approval as well.

24 And then, things like submitting for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

57 information or Owner's Activity Report forms submitted 1

to us, and then, the Reg. Guide talks about the 2

periodicity for that, and things like that, and a few 3

other things.

4 One other one I wanted to highlight is 5

Condition

10.

It's not necessarily a

real 6

technically-significant condition, or I would say not 7

a lot of background meat to it, but I just wanted to 8

note that there are provisions in RIM that are listed 9

as "in the course of preparation or otherwise under 10 development." And this largely refers to the 11 technology-specific or plant-specific appendices.

12 And so, we make a note or condition in 13 there that, obviously, if someone is coming in with a 14 RIM program, and the 2019 standard listed as "in the 15 course of preparation and development," we need the 16 applicant to develop that information and provide it 17 to us for review.

18 Next slide, please.

19 So, the next couple of slides, I list 20 briefly the other conditions. Again, there's 15 of 21 them. I don't think we need to go through them all in 22 detail. Some are more minor and relatively minor.

23 One, the top one is we want them to use, 24 if they're using the 2019 edition of RIM, they should 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

58 use that and correspond with the 2019 edition of 1

Section XI, Division 1. Or, basically, if they go to 2

a future edition of RIM, it needs to be the 3

corresponding edition of Division 1.

4 Another one is ANDE. For personnel 5

qualification, RIM mentions or includes use of ANDE-1, 6

which is not an approved qualification standard yet by 7

the NRC. So, we did have to make a note that it's not 8

approved yet at this point. Let's see. And that 9

condition does identify the NRC-approved standard, the 10 CP-189, as well as the standard for performance 11 demonstration that is approved by the NRC.

12 Things like not overriding the 13 construction code by using RIM. Because RIM would 14 prevent or -- sorry -- would permit using some 15 alternate examinations methods in lieu of the 16 examination requirements specified in the construction 17 code. So, we wanted to make sure that they are not, 18 in their use of RIM, they are not overriding the 19 construction code that's approved for that.

20 Next slide, please.

21 Again, a few more high-level ones, 22 summaries. Again, these are some of our more minor, 23 even some minor editorial errors that we noted in the 24 standard; we included that.

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59 Preservice inspection for repair and 1

replacement, the timing. RIM lacked information 2

related to the timing for completion of the preservice 3

examinations that may be needed due to activities such 4

as repair and replacement, modifications that may add 5

components or changes that may add existing components 6

into the scope. So, those weren't specifically called 7

out in terms of needing preservice inspection before 8

going into service. So, we noted that there.

9 Another, stress relaxation credit was a 10 degradation mechanism that we felt should be 11 considered after discussing with the technical experts 12 within the NRC as well.

13 Okay. Next slide, please.

14 Okay. So, moving on, I want to just give 15 you a summary of the public comments that we had, and 16 some of the revisions that we made to the Regulatory 17 Guide, based on those comments.

18 We did receive comments from eight 19 distinct comment submissions or submitters, and that, 20 all told, it was approximately 35 individual comments.

21 We say, "approximately" because some of them were kind 22 of broad and, you know, sending in information just 23 for consideration; didn't actually have an actual 24 suggestion or recommended change to them. So, it's 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

60 some of them were fairly lengthy, but, roughly, there 1

were about 35 individual comments that we had to 2

address or we addressed.

3 And we received some very good comments.

4 Some of those commenters, they came from 5

representatives of industry. Three of them came from 6

people who were contributors to the development of 7

RIM, as well as some retired industry, and even one 8

retired NRC member.

9 Like I said, many of those comments led to 10 some good clarifications in the document that I'll 11 describe for you here in the next couple of slides.

12 We reviewed the comments very carefully 13 one by one; went through; you know, in some cases, 14 again, went back and consulted with some of our senior 15 technical advisors, and then, also had very good 16 discussions with OGC support to work through the 17 changes to the Reg. Guide as well.

18 We did not eliminate or add any conditions 19 as a result of the comments. And lastly, we did 20 clarify some of the -- the highlights of the things we 21 clarified are the applicability, because we did 22 receive a number of comments on the applicability, as 23 well as some of the information to be submitted for 24 review, and some of the other staff positions.

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61 Okay. Next slide, please.

1 So, on the next few slides, which are my 2

last few slides, I'm just going to highlight some of 3

the main public comments that we addressed and some of 4

the changes that we made, based on those comments.

5 The first one is really the biggest one.

6 The main one that was most significant was we had four 7

of the comments suggested that the Regulatory Guide 8

should be revised to allow LWRs to use RIM. Or a 9

different twist on this same theme, the same idea, in 10 some cases, they said the Reg. Guide should explain 11 the regulatory paths for light water reactors to use 12 RIM.

13 As I kind of mentioned, well, did mention 14 before, light water reactors are required to use, in 15 accordance with 50.55a(g), they are required to use 16 Section XI, Division 1, for inservice inspections.

17 So, you know, the bottom line is it was not 18 appropriate for the Regulatory Guide to address means 19 for light water reactors to counter the actual 20 regulation that's in place. So, we do agree that RIM 21 was developed for any type of reactor design, but we 22 don't, in this Regulatory Guide, we don't take a 23 position on the technical adequacy of RIM for light 24 water reactors, is essentially what we commented in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

62 the commenter response.

1 And we did not review this standard for 2

light water reactors. So, again, we just reconfirmed 3

that the applicability for this Regulatory Guide is 4

for non-light water reactors.

5 Addressing light water reactors and 6

including information about a process for light water 7

reactors to use it, whether it's through exemptions or 8

alternatives, would be outside the scope of the 9

Regulatory Guide. However, we did include a footnote, 10 which I've listed here for you, just acknowledging 11 that we understand that RIM is developed for any type 12 of reactor design. Again, we state -- you see the 13 language there -- we state the reasoning why this 14 Regulatory Guide does not address light water reactors 15 in the applicability, and we identify the exemption 16 process as the path that they could use.

17 Okay. Next slide, please.

18 In this one, I just wanted to highlight --

19 like I said, several of the comments did provide, 20 particularly from the developers of RIM, did provide 21 some good clarifications that we considered and that 22 did result in some clarification changes in how we 23 mention, for example, Position 1, which, again, 24 discusses all the information that we ask them to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

63 submit as part of the initial application. We did 1

make some changes to provide more clarity on what 2

we're looking for, and we did get some good 3

suggestions.

4 So, things like listing of the SSCs; in 5

particular, SSCs included in the scope of the RIM, 6

where previously we just asked for kind of the basis 7

of the scope. You know, kind of clarifying on how 8

certain factors are considered in use of the RIM 9

strategies. We clarified the justification for flaw 10 evaluation acceptance criteria, temperature limits.

11 And then, there were some clarifications 12 that we made that applied to both Position 1 and 13 Position 4. They rightly noted that there's no need 14 for this NIS-2 form, which is, basically, a completion 15 of repair and replacement activities. It doesn't 16 include specific information that would be helpful 17 that is not already covered, or would be covered, in 18 the OAR, the Oversight Activity Report. So, we agreed 19 no need. We took out reference to that.

20 Someone rightly pointed out that we 21 previously had a reference to a refueling outage, and 22 we changed that. Obviously, they made the point that 23 some advanced reactors won't have refueling. So, 24 that's more of a terminology clarification there.

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64 Okay. The next slide, please.

1 Okay. Position 5, this one relates a bit 2

to -- well, we did add a clarification for the use of 3

CP-189 for qualification and certification of NDE 4

personnel. We added the caveat that any conditions 5

that are listed in 50.55a(b)(2) should be applied for 6

that use, and that made sense.

7 This came in, this comment tied in with --

8 we did receive several or a few comments that related 9

to they wanted the Reg. Guide to provide a path or 10 allow the use of ANDE-1 for NDE personnel 11 qualification. That is a standard that we've been 12 following and working with the developers there, but 13 that is not a standard that we feel is sufficient to 14 be approved by the NRC yet at this point. So, we 15 disagree with the comment that this should include 16 guidance on how to get approval for use of ANDE-1 at 17 this stage.

18 So, the Reg. Guide does, again, clarify 19 specifically the standards that we have that are 20 approved for Division. We did include the comment 21 that we don't see -- personnel qualification is not 22 technology-dependent. So, if ANDE-1 later gets -- in 23 the comment resolution; we didn't include this in the 24 Reg. Guide -- but if ANDE-1 later gets approved for 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

65 use for LWRs, then it should be applicable to non-1 light water reactors also. But, again, this isn't 2

what we're going to state in the Regulatory Guide at 3

this stage.

4 Let's see. Some clarifications on 5

performance demonstration. Again, we added a 6

reference to the appropriate Section XI, Division 1, 7

portion for a performance demonstration, for the 8

approved standards for performance demonstration, in 9

addition, came from that comment.

10 And there were various other kind of more 11 minor clarification changes that we made throughout.

12 And that really is my last slide. I guess 13 the one thing I would finish with was, you know, I 14 think this was a very productive review. As I 15 mentioned before, we see this as really a positive --

16 it's filling a significant need for the advanced 17 reactor community, for the non-light water reactor 18 community.

19 We do see, as we start to get more 20 information from applicants, as they start to use it, 21 I'm sure we'll learn more about RIM programs and how 22 they're developed, and how they're provided. But 23 this, basically, provides a process.

24 As we mentioned before, it's very much a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

66 paradigm shift from Division 1, but, again, we think 1

this, the ability to get this Regulatory Guide out and 2

provide this as an option for licensees and 3

applicants, I think is a very good thing at this 4

stage.

5 So, let me stop there. That is my last 6

slide. So, I'm happy to take any questions.

7 CHAIRMAN BALLINGER:

This is Ron 8

Ballinger.

9 Can we go back to the first main public 10 comment?

11 MR. PHILPOTT: Sure.

12 CHAIRMAN BALLINGER: I forget the slide 13 number. Yes, that will do it.

14 You can probably guess where the comments 15 came from in this area.

16 MR. PHILPOTT: Right.

17 CHAIRMAN BALLINGER: And it kind of makes 18 you wonder whether or not there might be a path 19 forward for Revision X for the Reg. Guide, where you 20 do deal with the 50.55a part for light water reactors, 21 just regular light water reactors.

22 Is there any kind of plan for the future 23 for this?

24 MR. PHILPOTT: So, I guess I would say, I 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

67 would start by saying, yes. I mean, not a specific 1

plan for changing our course.

2 But, you know, it was a strategic decision 3

to not try to change 50.55a at this stage. One of the 4

issues, it would be very complicated to try to weave 5

Division 2 requirements into 55a in parallel with the 6

Division 1 requirements. And so, it would be a 7

significant effort to take that under.

8 One of the things we are doing within the 9

Division of New Reactors is that they are kind of 10 pulsing and looking at some of the light water, 11 potential light water reactor applicants and trying to 12 gauge their interest in the use of RIM. So far, 13 they've only identified the one key player in the use 14 of RIM.

15 So, there are maybe one or two others that 16 are kind of monitoring it and seeing how it goes for 17 the advanced reactor community or for other light 18 water reactors, but more of the interest really seems 19 to be in the non-light water reactors right now. So, 20 basically, what that tells us right now is, from a 21 resource standpoint, it wouldn't make sense to try to 22 do that now.

23 Now that could change once maybe someone 24 implements it or they start to see it implemented. We 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

68 don't currently see any, or at least the word I saw 1

was that we haven't seen any expressed interest from 2

the operating fleet, for example, at this stage to use 3

RIM. But, if that changes, then it becomes, you know, 4

a much bigger potential resource than we do -- and as 5

RIM evolves, you know, we could evaluate that and 6

reconsider that decision in terms of going forward 7

with rulemaking.

8 CHAIRMAN BALLINGER: Thanks.

9 MR. PHILPOTT: Uh-hum.

10 CHAIRMAN BALLINGER: Questions from the 11 members or consultants?

12 MR. TURNBOW: This is --

13 CHAIRMAN BALLINGER: Whoever you are, 14 we're breaking up.

15 MR. TURNBOW: Can you hear me now?

16 CHAIRMAN BALLINGER: Yes.

17 MR. TURNBOW: Okay, good. I'm just 18 switching from mute over.

19 This is Mike Turnbow.

20 Concerning the response to the CP-189 ANDE 21 comments that were just made, that's disappointing 22 because we, the industry, built ANDE at, basically, 23 the request of the NRC, the letter we received from 24 you guys back several years ago about how poor NDE 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

69 personnel performance was. And it is incredibly 1

documented how poor it is.

2 And it continues to this day. CP-189, and 3

even the appendices in Section XI, has done nothing to 4

change it. The failure rate at EPRI for PDI first-5 timers still hovers around 50 percent, which makes no 6

sense.

7 So, I --

8 CHAIRMAN BALLINGER: Excuse me. Excuse 9

me. I don't know who you are. I'm guessing that 10 you're a member of the public. If that's the case, we 11 will entertain comments from members of the public 12 after we get comments from members of the Committee, 13 or the Subcommittee. Excuse me.

14 So, if this is not the case, then I 15 apologize, but can you -- if you are what we would 16 call a member of the public, would you wait just a few 17 minutes until we go around the table, in effect, with 18 members of the Subcommittee?

19 MR. TURNBOW: Okay. I'm a member, I'm a 20 working group member of RIM, just so you know. But if 21 you want me to wait, I'll be glad to wait.

22 CHAIRMAN BALLINGER: Okay. So now, you're 23 in the gray area.

24 MR. TURNBOW: Yes, I'm always in the gray.

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70 Matter of fact, all of it's gray.

1 CHAIRMAN BALLINGER: Okay. Let's get 2

comments from Subcommittee members first, and then, 3

we'll --

4 MR. TURNBOW: Okay.

5 CHAIRMAN BALLINGER: Okay.

6 MEMBER REMPE: Ron?

7 MEMBER KIRCHNER: Ron?

8 CHAIRMAN BALLINGER: Yes, sir or ma'am.

9 MEMBER REMPE: Go ahead, Walt.

10 MEMBER KIRCHNER: Ron, I'm thinking about 11 the presentation we heard, and if I understood Steve 12 correctly, the way that non-LWRs would -- let me 13 choose my words carefully -- be required to do 14 inservice inspection is through the content of 15 application requirements of 50 or 52, but not through 16 any direct regulatory requirement, such as exists in 17 55a(g).

18 And so, what I'm thinking -- and I know 19 Dave is on the line -- I'm thinking ahead to our 20 deliberations about 53, and if you don't have required 21 Principal Design Criteria or just design criteria per 22 se, which would invoke such a requirement for purposes 23 of, for example, pressure vessels, whether they are 24 low or high pressure doesn't matter. Is that a gap or 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

71 is that something that we should be thinking about 1

when we get to Subpart F of 53? So, it's just an 2

observation. It's not a question.

3 CHAIRMAN BALLINGER: I think Dave is 4

probably much more qualified to respond to that.

5 Dave?

6 (No response.)

7 Well --

8 MEMBER PETTI: Did you ask me something, 9

Ron? I'm sorry, but --

10 CHAIRMAN BALLINGER: I just fingered you 11 as being the expert for --

12 MEMBER PETTI: Oh, the cleaning lady just 13 knocked on my door and looked in. So --

14 (Laughter.)

15 What were you saying?

16 MEMBER KIRCHNER: Well, Dave, it was Walt.

17 I made an observation that it seems to me --

18 MEMBER PETTI: Yes, yes, I got the off-19 tech piece, yes.

20 MEMBER KIRCHNER: Yes, yes.

21 MEMBER PETTI: I mean, it's something to 22 look at in Subpart F, I guess, on operations.

23 MEMBER KIRCHNER: Yes, it seems to me, 24 without getting as prescriptive as what's in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

72 50.55a(g), one would want to demonstrate an equivalent 1

level of safety for a non-LWR, inservice inspections.

2 I'll just leave it at that high, general level without 3

trying to resolve how one obtains that result.

4 MEMBER DIMITRIJEVIC: Well, it will be 5

interesting what would this be in the, you know, non-6 PRA framework, you know, for selection of the SSCs.

7 So, again, I think we will have to monitor how this 8

goes in the 53.

9 MR. PHILPOTT: Uh-hum. And as I mentioned 10 earlier, I'm certainly not a Part 53 expert. So, I 11 don't want to speak for that team in great detail, 12 other than to note that they have written in a section 13 related to integrity assessment programs where this 14 would tie in, but not -- I don't see that -- that 15 doesn't necessarily specifically require ISI programs 16 or have that specificity that 50.55a(g) does. It's a 17 different approach, but -- okay.

18 CHAIRMAN BALLINGER: Did I hear --

19 MEMBER PETTI: So, just to be clear, 20 before we go to a different topic, I have opened up 21 the draft of Part F, and there's a whole section on 22 maintenance, repair, and inspection programs. So, 23 there's words in there -- "performance," "condition 24 monitoring." I'm just skimming.

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73 But I'll look at it, you know, offline, 1

but I think at least there's a hook. It may need to 2

be noodled, but it's there. There's something there 3

to start with.

4 MEMBER KIRCHNER: Yes. Yes. Yes, thanks, 5

Dave.

6 The other thing I'm thinking is the Reg.

7 Guide is guidance, and that's different than 55a(g),

8 which is a requirement.

9 MEMBER PETTI: Right. This is in the rule 10 text, 53.715, the draft rule text.

11 MEMBER REMPE: So, Ron, are we ready for 12 another topic?

13 CHAIRMAN BALLINGER: Yes, I was about to 14

-- I assumed that that was your voice that I heard.

15 MEMBER REMPE: Okay, yes, this is Joy.

16 I'm hoping I'll get my comment out. I got 17 kicked off twice in the last 20 minutes.

18 But, anyway, I'm thinking about path 19 forward. And in July, we had a reservation for a 20 possible letter, which I think is not going to be a 21 letter on this, because the staff even told us today 22 they're going to issue this in June.

23 CHAIRMAN BALLINGER: Yes, the intent was 24 for this to be just an information briefing.

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74 MEMBER REMPE: And I think that's a good 1

intent.

2 On the other hand, I know that Dave has a 3

Part 53 letter scheduled for July. And we heard 4

yesterday that what we get on Part 53 at the upcoming 5

Subcommittee is not a sure bet.

6 And so, I wanted to put out there that I'm 7

thinking that we should definitely have a letter on 8

Part 53, but it might be, you know, whatever we get 9

with respect to Part F and Track B, or whatever option 10 B is, as well as maybe a section on guidance. We've 11 heard some good things today, that there might be a 12 worthwhile paragraph, and then, talking about how it 13 interacts with the rulemaking language. And there's 14 some issues about guidance that might need 15 clarification and how important that is. But we're 16 monitoring the staff progress on guidance to support 17 non-LWR licensing.

18 And I guess I'm throwing that out there 19 for the Committee to consider, you as well as Dave, 20 since it's his letter that he's leading.

21 What do others think?

22 MEMBER PETTI: No, I think it's a good 23 idea, because there's a couple of things in my head 24 that are not necessarily part of 53, but may be better 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

75 in guidance. So, it would just be a little section, 1

like you said, where we could put some ideas together.

2 Because, you know, the guidance in many areas hasn't 3

been developed, but these would just be some of our 4

thoughts to make sure that we have them on the record 5

for the staff to think about.

6 MEMBER REMPE: Yes, in earlier letters, we 7

talked about that. That was one of the things we 8

highlighted, that we needed to have an idea of the 9

guidance and its progress.

10 So, anyway, that's kind of like I thought 11 it would be good, before we end this discussion, to 12 have clarity. We're not going to have any more 13 presentations or letter in July, and that topic will 14 go off the July agenda, which hasn't been published 15 yet. But Dave's letter will have more certainty, 16 which wasn't very certain yesterday after what we had 17 heard from the staff.

18 CHAIRMAN BALLINGER: Okay. Other comments 19 from members?

20 (No response.)

21 Okay. Hearing none, now we can -- it's 22 the appropriate time to get comments from members of 23 the public, and even the gray area of the public 24 members.

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76 So, Members of the Public, if you would 1

like to make a comment, please state your name and 2

make your comment.

3 MR. TURNBOW: Okay. This is Mike Turnbow 4

again. And I'm Secretary of the working group, MANDE, 5

under RIM; also, the Chairman of the ANDE Project, 6

when we wrote the standard the first time, which 7

included NRC representation throughout the entire 8

process. I now chair the implementation piece of 9

ANDE.

10 And my comment is, as I've stated -- just 11 to go back over it one more time -- it's a little 12 disappointing because we started the project at the 13 request of the NRC several years ago. NRC sent us a 14 letter; ASME telling us that the NDE, basically, was 15 broke, was what the letter said, in my terms, and it 16 should be addressed. And we committed to it, and now 17 we've done it.

18 And it's still in accordance with the same 19 process that -- these are power plant operators, the 20 systematic approach to training through INPO. So, we 21 followed that same, exact process with the NRC staff, 22 taxpayers' money and utility money. We spent about 23

$2.5 million building this.

24 And so, we're at a point of implementing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

77 it. And it seemed like, since RIM is a new document 1

coming out -- so is ANDE a new document coming out --

2 it seemed it would be a perfect marriage; plus, it's 3

performance-based, which the RIM folks are very 4

interested in.

5 Since the beginning, since CP-189 was 6

introduced, and all the appendices in Section XI, 7

around '92, the pass rate at EPRI has hovered around 8

50 percent. And all the things we've done in the Code 9

and adding these other caveats to CP-189, still 10 results today in a 50 percent pass rate. Basically, 11 we've done nothing to fix that, except we've built a 12

-- so, I'm going to stop there.

13 I know we're not going to resolve this 14 today, but we'll just have to continue to work 15 together and see if we can't realize we probably have 16 the best solution on the planet right here.

17 CHAIRMAN BALLINGER: Thank you.

18 MR. TURNBOW: Thank you.

19 CHAIRMAN BALLINGER: Other members of the 20 public that would like to make a comment?

21 (No response.)

22 Hearing none, then I think we are pretty 23 much done.

24 I would like to thank the staff -- and I'm 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

78 sure the rest of the Committee members would be the 1

same -- for a presentation.

2 I believe -- and this is one person's 3

opinion -- that this is a very significant change. I 4

would, for one, would like to -- again, I keep saying 5

that the industry has been moving in this direction 6

within the confines of Division 1, anyway. Anybody 7

that's been familiar with environmental degradation of 8

materials knows this, and anybody that's read MRP-227, 9

I think it is, or even the newest version of that, 10 will agree.

11 But I thought it was a great presentation.

12 And absent any additional comments from members, we 13 would like to thank you very much for the 14 presentation.

15 And with that being said, we are 16 adjourned.

17 (Whereupon, at 10:12 a.m.,

the 18 Subcommittee was adjourned.)

19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com

Overview of ASME Section XI, Division 2, Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants May 20, 2022 Bruce Lin, Materials Engineer Reactor Engineering Branch Division of Engineering Office of Nuclear Regulatory Research

ASME Section XI ASME Section XI, Division 1 was developed and evolved over 40+ years but focused on existing PWR and BWR light water reactor (LWR) technology Consequently, the use of ASME Section XI, Division 1 may not be well suited for advanced Non-LWR reactor designs ASME Section XI, Division 2 Reliability and Integrity Management (RIM) was developed to be a technology neutral inservice code that can be applied to all reactor types RIM has technology-specific supplements intended to account for different reactor designs Many of the technology-specific supplements are still under development 2

What is RIM?

A program to ensure that passive component reliability and integrity are properly managed Based on achieving an acceptable level of reliability Implement strategies to ensure that Reliability Targets for SSCs are defined, achieved, and maintained throughout the plant lifetime 3

RIM Process Philosophy RIM evaluates all SSCs for their impact to plant safety and reliability RIM establishes the examination, tests, operation, monitoring, and maintenance requirements to ensure the SSCs meet the plant risk and reliability goals This contrasts the prescriptive approach used by Division 1 which uses Class 1, Class 2 and Class 3 approach to ISI with each Class having less rigorous criteria 4

RIM Process Overview Step 1: Determine Scope of SSCs for RIM Program Step 2: Evaluate SSC Damage Mechanisms Step 3: Determine Plant and SSC Level Reliability and Capability Requirements Step 4: Identify and Evaluate RIM Strategies to Achieve Reliability Targets Step 5: Evaluate Uncertainties in Reliability Performance Step 6: Implement RIM Program Step 7: Monitor SSC Reliability Performance and Update RIM Program 5

Step 1: RIM Scope

• Applicable over the entire life of the plant and each passive SSC that is in scope [RIM-1.1]

• The Owner shall document the specific list of SSCs to be evaluated for inclusion within the scope of the RIM Program [RIM-2.2]

• The scope shall include SSCs whose failure could adversely affect plant safety and reliability [RIM-2.2]

6

Step 2: Degradation Mechanisms Assessment The potential active degradation mechanisms for the SSCs within the RIM Program scope shall be identified and evaluated [RIM 2.3]

- Design characteristics

- Operating experience and research experience

- Results of preservice and in-service examinations

- Recommendations by SSC vendors

- Applicable degradation mechanisms including those identified in the applicable Plant Type Mandatory Appendix The criteria used to identify and evaluate the susceptibility of each SSC to degradation mechanisms shall be specified in the RIM program documentation 7

Step 3: Plant and SSC Reliability Plant Level Risk and Reliability Targets [RIM-2.4.1]

- Plant level reliability shall be derived from regulatory limits on the risks, frequencies, and radiological consequences of licensing basis events that are defined in the probabilistic risk assessment (PRA)

- Plant level RIM goals may include additional goals to meet plant availability SSC Level Reliability Target [RIM-2.4.2]

- Allocation of SSC level Reliability Targets from PRA

- Mandatory Appendix II provides a general approach Scope, Level of Details, and Technical Adequacy of PRA [RIM-2.4.3]

- PRA shall meet the requirements of the ASME/ANS RA-S-1.4 8

Step 4: RIM Strategies The RIM Expert Panel (RIMEP) shall identify the RIM strategies and evaluate and select combinations of strategies that will meet and maintain the Reliability Targets [RIM-2.5]

- RIM strategies may include design strategies, operating practices, inservice inspection, repair and replacement practices, etc.

- The RIM strategies shall account for the potential for specific damage mechanisms applicable to each SSC

- Impact of each RIM strategy on the reliability of each SSC shall be assessed against the SSC-level Reliability Targets 9

Step 5: Evaluate Uncertainties

• Evaluation of Uncertainties [RIM-2.6]

- Lack of service experience

- Unknown degradation mechanisms

- Uncertainties in the prediction of SSC reliability

• Use of multiple strategies to address uncertainties 10

Step 6: RIM Implementation RIM Program Documentation

- Scope of SCCs selected for inclusion in RIM program

- Results of degradation mechanisms assessment

- Plant level risk and reliability goals and SCC reliability targets

- Specific RIM strategies and their impact on SCC reliability performance

- Evaluation of uncertainties RIM Program Implementation [RIM-2.7]

- Inspection Interval

- Preservice Inspections

- Design Requirements for RIM

- Leak Detection System Requirements for RIM

- Examination and Inspection Requirements for RIM 11

Step 7: RIM Program Updates Performance Monitoring and RIM Program Updates [RIM-2.8]

- RIM program shall be re-evaluated to incorporate results from SSC performance monitoring and new information affecting implementation of the program

- Examples may include changes to plant design, operating and maintenance practices, plant, industry and research experience, monitoring or examination results, regulatory requirements, PRA updates, etc.

Minimum frequency of updates - Once per inspection interval 12

Expert Panels RIM Expert Panel (RIMEP)

- RIMEP is responsible for the technical oversight and direction of the risk-informed aspects of RIM program development and implementation.

• Establishes RIM Scope

• Establishes Reliability Targets

• Identifies RIM Strategies Monitoring and NDE Expert Panel (MANDEEP)

- Responsible for all things NDE

• Develops MANDE specifications

• MANDE qualification

• Specific examination requirements

• Minimum criteria of MANDE 13

Section XI, Division 2 Organization RIM-1 Scope and Responsibility - Similar to Div. 1 IWA-1000 RIM-2 Reliability and Integrity Management (RIM) Program - This article covers RIM program implementation RIM-3 Acceptance Standards - Appendix VII will have acceptance standards for each reactor type RIM-4 Repair/Replacements Activities - Done in accordance with Div. 1 IWA 4000 with a few exceptions RIM-5 System Leak Monitoring and Periodic Tests - Provides rules for leakage monitoring and leak testing RIM-6 Records and Reports - Similar to Div. 1 IWA-6000 RIM-7 Glossary 14

Section XI, Division 2 Organization Mandatory Appendices Appendix I, RIM Decision Flowcharts Appendix II, Derivation of Component Reliability Targets From Plant Safety Requirements Appendix III, Owners Record and Report for RIM Program Activities Appendix IV, Monitoring and NDE Qualification Appendix V, Catalog of NDE Requirements and Areas of Interest Appendix VI, Reliability and Integrity Management Expert Panel Appendix VII, Supplements for Types of Nuclear Plants Nonmandatory Appendices Appendix A, Alternate Requirements for NDE and Monitoring Appendix B, Regulatory Administrative Provisions for Nuclear Plants Using RIM Program 15

Overview of RG 1.246 Endorsement of ASME Section XI, Division 2, and Resolution of DG-1383 Public Comments May 20, 2022 Steve Philpott, Project Manager / Acting Branch Chief Advanced Reactor Technical Branch 2 Division of Advanced Reactors and Non-Power Production and Utilization Facilities Office of Nuclear Reactor Regulation

=

Background===

ASME issued Section XI, Division 2 Requirements for Reliability and Integrity Management (RIM) Programs for Nuclear Power Plants in the 2019 Edition of the BPV Code.

ASME requested NRC endorsement in October 2019.

NRC responded to ASME in August 2020 and formed a review working group.

Staff working group reviewed Section XI, Division 2 for endorsement via regulatory guide for applicability to non-light water reactors (Non-LWRs).

17

RIM Review Summary

• Reviewed code and developed initial staff positions:

Aug - Dec 2020 o confirmed RIM is appropriate to endorse with conditions

• Developed staff positions and draft regulatory guide (DG-1383): Jan - Sep 2021

• Published DG-1383 in Sep 2021: 45-day public comment period

• Comment resolution and concurrence review:

Nov 2021 - Apr 2022

• Publish Final RG: Jun 2022 18

RG 1.246 Structure

• Section A o Purpose o Applicability (Non-LWRs) o Applicable Regulations and Related Guidance

• Section B o Background o Bases for NRC Staff Positions

• Section C o Staff Regulatory Guidance (Conditions) 19

RG 1.246 Conditions Condition 1: Applicants intending to use RIM should include a license condition / Identifies information to be included in their application Condition 4: Changes to a RIM program and information to be provided to the NRC for review and approval / for information Condition 10: RIM provisions in the course of preparation or otherwise under development 20

RG 1.246 Conditions Additional conditions:

Use with 2019 Edition of Section XI-Division 1 Document how aspects of Section XI-Division 2 are considered ANDE-1 not approved for personnel Qualification Editions of supporting standards acceptable for use Justify acceptability of the PRA in RIM program Cannot override construction code NDE without approval 21

RG 1.246 Conditions Additional conditions:

Preservice inspections for repair and replacement Appendix V to be considered for low pressure applications Records retention to be IAW QA program requirements Stress relaxation to be considered as a degradation mechanism Liquid leak test clarifications and hold time limits Minor errata type corrections 22

DG-1383 Public Comments

• Received 8 distinct comment submissions

• Approximately 35 individual comments

• No additional or eliminated conditions

• Clarified applicability, information to be submitted for review, and other staff positions 23

DG-1383 Public Comments 24 Change in Applicability: Multiple comments suggested that RG 1.246 should include applicability to LWR designs. For some LWR cooled /

moderated advanced reactors, it would be difficult to implement Section XI, Division 1. RIM is intended to be technology neutral.

• One commenter recommended rulemaking to amend 50.55(a).

• Rulemaking is outside the scope of this RG Staff reviewed and is endorsing ASME BPV Code,Section XI, Division 2 only for use by non-LWRs.

10 CFR 50.55a(g) mandates the use of the ASME BPV Code,Section XI, Division 1 for boiling and pressurized water-cooled reactors.

Staff agrees that RIM was developed for any type of reactor design.

Added footnote in Background section in the RG:

RIM was developed for any type of reactor design. However, 10 CFR 50.55a(g) mandates the use of the ASME Code,Section XI, Division 1 for boiling and pressurized reactors. If a boiling or pressurized water-cooled reactor licensee or applicant wishes to use RIM, they would need to request an exemption under 10 CFR 50.12 or 10 CFR 52.7 from 10 CFR 50.55a(g).

DG-1383 Public Comments Clarifications of Regulatory Guidance Positions Position 1 o Listing of SSCs included in the scope of the RIM program rather than a summary of the bases for the scope o Description of the types of factors from RIM-2.5.1 used in the RIM strategies o Clarified justification for flaw evaluation acceptance criteria temperature limits to be consistent with the temperature limits of the applicants construction code Positions 1 and 4 o Removed the need to submit the NIS-2 form and removed references to the NIS-2 o The term refueling outage was removed and changed to use the term scheduled outage to be consistent with Appendix B of ASME Code,Section XI, Division 2 25

DG-1383 Public Comments Clarifications of Regulatory Guidance Positions Position 5 o For use of ANSI/ASNTCP189 - added including any conditions applied under 10 CFR 50.55a(b)(2) o Added clarification for performance demonstration of NDE methods and techniques o

Performance demonstration is beyond the scope of ANSI/ASNT CP189 and ANDE-1 o

Use Section XI, Division 1 Appendix VIII Additional clarification changes 26

Acronyms/Abbreviations ANDE ASME Non-destructive Examination ANS American Nuclear Society ASME American Society of Mechanical Engineers ANSI/ASNT American National Standards Institute / American Society for Nondestructive Testing BPV Boiler and Pressure Vessel BWR Boiling Water Reactor CFR Code of Federal Regulations DG Draft Guide / Draft Regulatory Guide ISI Inservice Inspection LWR Light Water Reactor NDE Non-destructive Examination Non-LWR Non-Light Water Reactor MANDE Monitoring and NDE MANDEEP Monitoring and NDE Expert Panel PRA Probabilistic Risk Assessment PWR Pressurized Water Reactor RIM Reliability and Integrity Management RIMEP RIM Expert Panel SSCs Structures, Systems, and Components 27