ML22172A079
| ML22172A079 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/2022 |
| From: | Charles Brown Advisory Committee on Reactor Safeguards |
| To: | |
| Brown, C, ACRS | |
| References | |
| NRC-1962 | |
| Download: ML22172A079 (107) | |
Text
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
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 FUELS, MATERIALS, AND STRUCTURES SUBCOMMITTEE 8 + + + + +
9 FRIDAY 10 MAY 20, 2022 11 + + + + +
12 The Subcommittee met via hybrid Video 13 Teleconference, at 8:30 a.m. EDT, Ronald Ballinger, 14 Chairman, presiding.
15 16 COMMITTEE MEMBERS:
17 RONALD G. BALLINGER, Chair 18 VICKI BIER, Member 19 CHARLES H. BROWN, JR. Member 20 VESNA DIMITRIJEVIC, Member 21 WALTER KIRCHNER, Member 22 DAVID PETTI, Member 23 JOY L. REMPE, Member 24 MATTHEW SUNSERI, Member 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 1 ACRS CONSULTANT:
2 DENNIS BLEY 3
4 DESIGNATED FEDERAL OFFICIAL:
7 ALSO PRESENT:
8 MICHELLE HAYES, NRR 9 BRUCE LIN, NRR 10 SCOTT MOORE, ACRS 11 STEPHEN PHILPOTT, NRR 12 MIKE TURNBOW, Public Participant 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 1 CONTENTS 2
3 Opening Remarks and Objectives . . . . . . . . . 4 4 Ronald Ballinger, Chair 5 Staff Opening Remarks . . . . . . . . . . . . . . 6 6 Michelle Hayes, Branch Chief, NRR 7 Staff Presentation - Overview of ASME 8 Section XI, Division 2 . . . . . . . . . . . . . 8 9 Bruce, Lin, NRR 10 Staff Presentation - Overview of 11 RG 1.246 and Resolution of Public Comments . . . 38 12 Stephen Philpott, NRR 13 Committee Discussion . . . . . . . . . . . . . . 70 14 Public Comments . . . . . . . . . . . . . . . . . 75 15 Mike Turnbow, Secretary, MANDE 16 working group under RIM, and 17 Chairman of the ANDE Project . . . . . . . 76 18 Closing Comments . . . . . . . . . . . . . . . . 77 19 Ronald G. Ballinger, Chair 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 1 P R O C E E D I N G S 2 8:30 a.m.
3 CHAIRMAN BALLINGER: The meeting will now 4 come to order.
5 This is a meeting of the Advisory 6 Committee on Reactor Safeguards, Subcommittee on 7 Fuels, Materials, and Structures. I'm Ron Ballinger, 8 chairing the Subcommittee meeting.
9 ACRS members present are myself, of 10 course; Vicki Bier; Dave Petti; Dennis Bley, our 11 consultant; Walt Kirchner; Matt Sunseri; Joy Rempe; 12 Vesna Dimitrijevic.
13 If I've missed somebody, please chime in.
14 Chris Brown is the ACRS, of the staff, 15 Designated Federal Official for this meeting.
16 It's an information briefing, by the way, 17 unless we decide something different, based on 18 discussions. The Subcommittee will receive a briefing 19 from the NRC staff regarding Reg. Guide 1.246, 20 "Acceptability of ASME Code Section XI, Division 2, 21 Requirements for Reliability and Integrity Management 22 Programs, RIM, for Nuclear Power Plants for Non-Light 23 Water Reactors."
24 The rules for participation in all ACRS 25 meetings, including today's, were announced in The 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 1 Federal Register on June the 13th, 2019.
2 The ACRS section of the U.S. NRC public 3 website provides our Charter, Bylaws, agendas, Letter 4 Reports, and full transcripts of all full and 5 subcommittee meetings, including slides presented 6 there. The meeting notice and agenda for this meeting 7 were posted there.
8 We have received no written statements or 9 requests to make oral statements from the public.
10 The Subcommittee will gather information, 11 analyze relevant issues and facts, and formulate 12 proposed positions and actions, as appropriate, for 13 deliberation by the full Committee.
14 The rules for participation in today's 15 meeting have been announced as part of the notice of 16 this meeting previously published in The Federal 17 Register.
18 Today's meeting will be held exclusively 19 over Microsoft Teams. A telephone bridgeline allowing 20 participation of the public over their computer using 21 Teams or by phone was made available.
22 A transcript of today's meeting is being 23 kept. Therefore, we request that meeting participants 24 on Teams and on the Teams call-in line identify 25 themselves when they speak, and to speak with 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 1 sufficient clarity and volume, so they can be readily 2 heard.
3 Likewise, we request that meeting 4 participants keep their computer and/or telephone 5 lines on mute when not speaking to minimize 6 disruptions.
7 The chat feature on Teams should not be 8 used for any technical exchanges.
9 Let's make sure that everybody has got 10 their phone on mute.
11 Now I think -- is Michelle Hayes, Branch 12 Chief, going to provide some opening remarks, or is 13 there another staff member that's going to do that?
14 MS. HAYES: I was going to provide some 15 opening remarks. This is Michelle Hayes.
16 CHAIRMAN BALLINGER: Sounds like a plan.
17 Very good. Let's proceed. Thank you.
18 MS. HAYES: Thank you.
19 So, good morning.
20 I'm Michelle Hayes, Chief of Advanced 21 Reactor Technical Branch 1 in the Office of Nuclear 22 Reactor Regulation.
23 As Chairman Ballinger mentioned, today's 24 discussion is on NRC's endorsement of ASME Code's 25 requirements for integrity management programs, or 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 1 RIM, that is found in Section XI, Division 2, of the 2 ASME Boiler and Pressure Vessel Code.
3 I'm excited that I get to make the opening 4 remarks because I think this project epitomizes NRR's 5 vision for advanced reactors. It makes the safe use 6 of advanced reactor technologies possible because it 7 offers the first NRC-endorsed process these vendors 8 can use to develop and implement a preservice and 9 inservice inspection program. It advances risk-10 informed and performance-based approaches and safety 11 reviews because RIM itself is a risk-informed, 12 performance-based program.
13 It leverages partnerships across the 14 agency because the endorsement team drew staff from 15 NRR, Research, and the Regions. This enabled us to 16 perform a diverse and comprehensive review of this new 17 approach to inspections of passive components.
18 Our interactions with ASME and vendors 19 demonstrated the importance of stakeholder engagement 20 and our commitment to endorsing consensus codes and 21 standards, and issuing this Reg. Guide improves the 22 efficiency and effective use of future reviews of 23 vendors that use RIM.
24 Before we get started, I want to highlight 25 one procedural point about the Reg. Guide. While the 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 1 copy you got is what we consider to be the final 2 version, it won't be issued until the end of June.
3 While RIM will not be incorporated into 10 CFR 50.55a, 4 one of the conditions in this Reg. Guide is to use the 5 2019 edition of RIM in conjunction with the 2019 6 edition of ASME Code,Section XI, Division 1, and any 7 applicable conditions in 10 CFR 50.55a. However, the 8 final 10 CFR 50.55a rule that incorporates the 2019 9 edition of ASME Section XI, Division 1, with the 10 respective conditions, won't be published until the 11 end of this June. So, we don't want to get ahead of 12 that.
13 Thanks in advance for your attention, and 14 we look forward to your questions.
15 I'll now turn it over to our in-house RIM 16 expert, Bruce Lin, to provide an overview of the 17 program.
18 MR. LIN: Okay. Good morning, everyone.
19 Thanks, Michelle.
20 So, I'm Bruce Lin. I'm one of the 21 Material Engineers with the Office of Regulatory 22 Research.
23 Again, thank you for the opportunity to 24 present today at the ACRS on the staff endorsement of 25 ASME Section XI, Division 2, the RIM program.
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9 1 I'm going to provide a very high-level 2 overview of what RIM is; go over the RIM process, and 3 basically, also the various sections in Section XI, 4 Division 2, just to give you a flavor of what's 5 included in the RIM standard.
6 In the next presentation, Steve Philpott 7 will discuss the staff review of the RIM standard and 8 the endorsement of Section XI, Division 2, and the 9 Regulatory Guide.
10 Next slide, please.
11 So, why is Section XI, Division 2, 12 developed? The industry had been using Section XI, 13 Division 1, for decades, and it's working and it's 14 effective. The problem is Division 1 is focused on, 15 essentially, boiling and pressurized light water 16 reactor technologies. So, under the current Division 17 1 rule, inservice inspections are specifically 18 described at specified frequencies for doing the 10-19 year inservice inspection intervals. So, this may not 20 be well-suited for some advanced non-light water 21 reactor designs, some with longer fuel cycles than the 22 typical PWR, you know, 18-to-24-month fuel cycles.
23 Also, some of the traditional, non-24 destructive examinations that are currently in use 25 today may not be effective in detecting some of the 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 1 degradation that is unique to some of the advanced 2 non-LWRs.
3 For some, this design may be more 4 effective to use, for example, on monitoring than 5 doing an inspection at the prescribed intervals.
6 So, Division 2 was developed to allow the 7 possibility for some of the new advanced reactor 8 designs to implement alternate strategies from Section 9 XI, Division 1, requirements. Division 2 RIM is 10 intended to be a technology-neutral code. So, it can 11 be applied to all reactors. It does have reactor-12 specific supplements to account for the difference in 13 reactor design. The supplement, basically, provides 14 the specific details related to, for example, the 15 degradation mechanism, all evaluations and acceptance 16 criterias for the specific reactor design.
17 Right now, the RIM standard has a 18 placeholder for six different reactor types, including 19 a high temperature gas reactor, nuclear metal 20 reactors, molten salt, light water reactors, and 21 fusion reactors.
22 Of course, many of the technology-specific 23 supplements are still under development. Right now, 24 only two have been completed so far.
25 Next slide.
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11 1 So, what is RIM? So, in a very high 2 level, it's a program to ensure that the passive 3 components are properly managed to meet the planned 4 recent reliability goals. It's based on the 5 philosophy of maintaining an adequate level of 6 reliability.
7 So, the objective of the RIM is to 8 implement strategies, I think including the 9 combination of design, fabrication, or inspection and 10 maintenance requirements that are necessary and 11 sufficient to ensure that the reliability targets are 12 defined and maintained throughout the life of the 13 plant.
14 CHAIRMAN BALLINGER: This is Ron, Ron 15 Ballinger.
16 MR. LIN: Yes?
17 CHAIRMAN BALLINGER: In the very 18 beginning, you specified that the code of record was 19 the 2019 version? There is a 2021 version.
20 MR. LIN: Right.
21 CHAIRMAN BALLINGER: And I haven't 22 compared the two. So, I don't know what the 23 differences are. But might there be an opportunity to 24 use that version? They don't come out with versions 25 that often.
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12 1 MR. LIN: Right.
2 CHAIRMAN BALLINGER: So, there may be an 3 opportunity to keep it up-to-date.
4 MR. LIN: The staff reviewed the 2019 5 edition of the Code, and that's the edition we're 6 endorsing. I think there are very minor changes 7 between the 2019 and 2021 editions, only editorial 8 changes.
9 CHAIRMAN BALLINGER: Okay. Thanks.
10 Also, while Division 1 has been in use for 11 a very, very, very long time, the industry has evolved 12 to the point where they're using online monitoring and 13 all kinds of other things. So, that it may be that in 14 the future Division 2 might actually be useful for 15 current LWRs.
16 MR. LIN: Yes. I mean, I think Division 17 2, again, right now, it's just a process. I think 18 there's going to be a lot more effort still required 19 to initially develop the program. So, Division 1, 20 again, it is very prescriptive and it's pretty easy to 21 follow, if you want to decide to use it. But Division 22 2 will require, in my opinion, significant effort 23 upfront as we develop the program.
24 CHAIRMAN BALLINGER: Yes, if you can get 25 by the 10-year ISI. That's very restrictive.
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13 1 Anyway, okay. Just my personal opinion.
2 Thank you.
3 MR. LIN: So, yes, this slide 4 covers/describes the RIM process philosophy. RIM 5 evaluates all SSCs for their impact in plant safety 6 and reliability and established the necessary 7 examination tests, operation or maintenance, including 8 repair and replacements, to ensure that all the 9 systems, structures, and components meet the plant 10 recent reliability goal.
11 This is meant to be an iterative process, 12 you know, during the design stage. So that, if a 13 performance target cannot be met through the 14 inspection or monitoring, the SSC, hopefully, can be 15 redesigned to include maybe a higher margin and the 16 desired operation can be changed to allow provision 17 for maybe replacement during operations.
18 So, this is very different from the 19 prescriptive approach used in Division 1. I mean, the 20 philosophy of Division 1 is to maintain a sufficient 21 number of tests and examinations to provide assurance 22 that the plant is safe. Division 1 uses the class 23 approach, like Class 1, Class 2, and Class 3, with 24 each class having sort of less rigorous criteria. And 25 it provides very prescriptive requirements, including 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 1 what you need to inspect; how often you need to 2 inspect, and the specific method to use. Whereas, in 3 Division 2, it doesn't really have a lot of specific 4 requirements. It's a process. They provide a process 5 for owners to develop their programs.
6 Okay. Next slide, please.
7 So, this slides shows the overall RIM 8 process. It started with, you know, we identified SSC 9 to be included in the program, and then, you conduct 10 a degradation assessment to identify and evaluate all 11 the potential degradations.
12 And the next step is you allocate the 13 reliability target to SSC, and once that's done, you 14 implement your strategies to make sure you meet those 15 target reliabilities. And you implement the program, 16 and then, you monitor and update a program as 17 necessary. I'll go through these steps in more detail 18 in the next few slides.
19 But the concept is very similar to the 20 recent for ISI, but I believe it's more than ISI. ISI 21 is just one of the strategies that can be used.
22 CHAIRMAN BALLINGER: This is Ron Ballinger 23 again.
24 Yesterday, I mentioned that there's a part 25 of the Part 53 discussion that the ASME Fitness-for-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 1 Service Code -- or there's a procedure, FFS-1 --
2 doesn't use the word "RIM," but that Fitness-for-3 Service document takes a quite similar approach.
4 Anyway, again, my personal opinion.
5 MR. LIN: Yes, I believe that's the 6 standard API 571, if I remember right.
7 CHAIRMAN BALLINGER: I think it's 589, 8 590, yes.
9 MR. LIN: Yes. I had a number, but --
10 yes.
11 As I said, I'll walk through these steps 12 in a very high level.
13 But let's go to the next slide.
14 Step 1 is, you know, determine the scope 15 of the SSC to be included in the program. Again, RIM 16 is limited to passive SSCs. So, the scoping core, the 17 passive SSCs whose failure could adversely affect 18 plant safety and reliability.
19 The step itself doesn't really provide a 20 lot of specific guidance on the requirement, on how 21 you, you know, what you need to go about, what SSCs 22 needed to be included in the RIM program. Basically, 23 it required the owner to document a specific list of 24 SSCs that is evaluated to be included in the program, 25 and it also required owners to document the bases for 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 1 excluding any SSCs from the program.
2 MEMBER KIRCHNER: Bruce, this is Walt 3 Kirchner.
4 MR. LIN: Yes?
5 MEMBER KIRCHNER: At a high level, what, 6 in practice -- one could use a PRA for defining the 7 scope, for example.
8 MR. LIN: Right.
9 MEMBER KIRCHNER: But, in practice, what 10 was the intent of the ASME Code Committee? Was it for 11 the entire plant? This says the entire life of the 12 plant and "each passive SSC that's in scope." But 13 what's the top-level discriminator for defining what's 14 in scope?
15 MR. LIN: Well, from my discussion with 16 the RIM Committee, I asked the question specifically.
17 I specifically asked the question. I think the scope 18 includes all SSCs in the plant. And I think the PRA 19 would help determine which SSC would have a 20 significant impact on recent reliabilities.
21 MEMBER KIRCHNER: So, reliability is one 22 thing and that impacts operability.
23 MR. LIN: Yes.
24 MEMBER KIRCHNER: And that has a 25 connection to safety. But is it, in your estimation, 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 1 is it really focused on those SSCs that are important 2 to safety or those --
3 MR. LIN: Yes, that's -- right.
4 MEMBER KIRCHNER: -- SSCs that are 5 important to reliability of the plant?
6 There is a big difference. Because the 7 first order, you know, I think most designs -- well, 8 I shouldn't say this, I guess. But, you know, the 9 secondary systems can be isolated from the primary 10 systems, and you can define your important-to-safety 11 envelope to the first order. It is that, you know, 12 those primary, NSSS system, or whatever the vendor 13 calls them, as the things that would be in scope. But 14 is this meant to have a scope that's broader, to 15 include the secondary plant, the balance of plant?
16 MR. LIN: Yes. That's why I wish the ASME 17 Committee would have provided more specific guidance.
18 I think that the scope, the standard bases, says all 19 SSCs that can adversely affect plant recent 20 reliability. So, it's very broad and -- yes. I 21 actually raised that question with the Committee.
22 MEMBER KIRCHNER: Yes, in that case, then, 23 the steam generator -- well, that's not a good 24 example. But, you know, all the rest of the balance-25 of-plant, then, comes within the scope, right?
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18 1 MR. LIN: Yes. Yes. So, the philosophy 2 is, you know, in Division 1 where we have Class 1, 3 Class 2, and Class 3 -- in RIM, there's really no 4 classification. It's all SSCs that can impact the 5 plant safety and reliabilities.
6 DR. BLEY: Well, this is Dennis Bley, 7 following up on Walt there.
8 Risk certainly is affected by the 9 reliability of the components. There ought to be some 10 kind of organization of how important the risk we're 11 talking about. You know, some of the secondary 12 systems are quite important; other ones not so much, 13 but maybe a little. And is it everything that has any 14 impact or is it just the things that are prominent or 15 maybe contribute 5 percent or more, something like 16 that? Is there any quantification of how important a 17 risk you consider in this process?
18 MR. LIN: Yes, right now, the study itself 19 doesn't really provide any quantification or specific 20 requirements. I would imagine this can have some tie-21 in with the Licensing Modernization Project, where the 22 LMPs will help you classify what component is 23 considered safety-significant; what components are not 24 safety-significant. And right now, that's not in the 25 Code. There's no specific guidance other than, you 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 1 know, you look at all components that can affect your 2 plant safety, and then, you identify the component 3 that they need to swing into the program.
4 DR. BLEY: Okay. Thanks. So, it at least 5 implies it's the ones that are the most important that 6 you pick up, or at least first?
7 MR. LIN: Yes. Yes, I wish the Code could 8 provide more specific requirements and guidance. So, 9 right now, there's only one paragraph that talks about 10 the scope, and basically, there wasn't a slide showing 11 the --
12 CHAIRMAN BALLINGER: Yes, this is Ron 13 again.
14 I don't think we should underestimate the 15 significance of Division 2 here. It represents an 16 opportunity for a very significant change and sort of 17 reorientation of outlook, if you will, on system 18 reliability. It's 150 pages long, but Division 1 is 19 like 600 pages.
20 MR. LIN: Right.
21 CHAIRMAN BALLINGER: Keep going.
22 MR. LIN: Okay. Let's go to the next 23 slide.
24 So, once the SSC is identified, the next 25 step is to evaluate all potential degradations that 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 1 can apply to the SSCs. You know, some things to 2 consider include design characteristics, including 3 materials; fabrication practice, including welding, or 4 what can also contribute to or introduce a degradation 5 mechanism, if it's not properly done.
6 Other conditions to consider include 7 degradation introduced by operating, and all transient 8 conditions, including temperature and pressure 9 excursions.
10 Also, a degradation mechanism based on 11 plant-specific or industry experience. You also need 12 to consider including recommendations from SSC 13 vendors.
14 Again, mandatory Appendix 7 identifies all 15 the potential degradation mechanisms that are 16 applicable to various reactor types. Again, many of 17 the supplements are still under development. And the 18 criteria that is used to identify and evaluate the 19 susceptibility of SSCs to degradation mechanisms would 20 need to be documented in the RIM program 21 documentation.
22 Next slide.
23 So, the next step in the process is to 24 identify the plant recent reliability topic for RIM.
25 Again, this just came out from RIM 2.4.1. The plant-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 1 level reliability goals are derived, basically, from 2 the regulatory limits on risk frequencies and 3 radiological consequences of licensing basis events, 4 as defined in the PRA.
5 The PRA model is also used to allocate or 6 to establish SSC-level reliabilities. The RIM 7 standard, again, doesn't really provide a lot of 8 detailed guidance on how to go about doing this. It 9 provides a general post or event in Appendix 2 on how 10 you divide component reliability from plant safety 11 requirements.
12 As you can see, the PRA plays a key role 13 in this step and it is important that the scope and 14 level of detail in the PRA is sufficient to support 15 the allocation of SSC reliability targets.
16 In RIM 2.43, it provides the requirements 17 regarding the technical accuracy and the scope of the 18 PRA, and it, basically, requires that the PRA needs to 19 meet the ASME/ANS RA-S-1.4 standards, which is the PRA 20 standard for advanced non-LWRs.
21 So, step four is, once you identify your 22 target reliability, the next step is to identify the 23 RIM strategies that are available to meet the 24 reliability targets. You know, you can use a single 25 reliability target -- or strategy I mean, or your 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 1 combination of strategies that's needed to meet the 2 targets.
3 The strategies could include design 4 strategies to reduce or eliminate the degradation 5 mechanism or you can use online leak detection or 6 perform inservice inspections or repair and 7 replacements, et cetera.
8 The impact of these RIM strategies on the 9 reliability target will need to be assessed.
10 Okay. Next slide.
11 So, after selecting the RIM strategies, 12 the next step is to evaluate the uncertainties. If 13 there are inherent, very large uncertainties in the 14 prediction of passive SSC reliability, some of those 15 uncertainties are plentiful in the allocation of 16 reliability targets, but the other source of 17 uncertainties is just difficult to quantify, such as 18 unknown degradation mechanisms, or just lack of 19 operating experience.
20 So, to account for some of these 21 uncertainties, you can implement multiple RIM 22 strategies over and above what's required in order to 23 provide additional assurance and, also, provide 24 defense-in-depth.
25 So, the next step is in advance you have 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 1 to program; you implement the program. And prior to 2 implementing the program, RIM program documentation is 3 developed. This documentation includes the results 4 from steps one to five, and includes the scope of the 5 SSC that is selected for the program; the result of 6 the degradation assessments; the reliability targets, 7 and the specific RIM strategies that you selected to 8 meet those reliability targets.
9 So, this is a very important document, as 10 you will hear from the later presentation. One of the 11 conditions in the Regulatory Guide endorsing RIM is to 12 require submittal of this information to NRC for 13 review and approval.
14 The other aspect of implementing a RIM 15 program includes -- some of the items are listed here 16 -- the inspection intervals. In RIM, the inspection 17 interval is determined by the RIM Expert Panel. I'll 18 briefly describe that panel in the next slide. But it 19 does have a limit of 12 years. The reason for that is 20 because we want to have a step when they have to 21 update the programs.
22 For several reasons, inspection is only 23 done if in some ways the inspection is selected as a 24 RIM strategy. So, you can have a baseline to start 25 with.
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24 1 RIM may also involve design requirements 2 to support a select RIM strategy, such as provisions 3 for an online leak detection system.
4 The other key aspect of the RIM program is 5 examination and inspection requirements. Again, 6 there's another Expert Panel that is responsible for 7 all aspects related to this, and it's the monitoring, 8 the NDE Panel. So, it's responsible for all things 9 related to NDE or inspections.
10 Okay. So, the final step in the RIM 11 program is to put in place a monitoring program that 12 will monitor the performance of the SSCs within the 13 program and update the RIM program to account for, for 14 example, a change in plant design, operations, 15 operating experience, and results from monitoring and 16 NDE, to update the PRA, or any other technical input 17 that you use in the initial RIM program.
18 So, this step is very similar to the risk-19 informed ISI program. So, you have to, basically, 20 continue to monitor your program and update, as 21 necessary. And the minimum frequency of update is 22 once per inspection interval.
23 Here, I mentioned there's two Expert 24 Panels already. They play a key role in implementing 25 the RIM program. The RIM Expert Panel is, basically, 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 1 responsible for the entire program, responsible for 2 the technical oversight, and the development and 3 implementation of the RIM program. So, this panel is 4 responsible for establishing the RIM scope, the 5 reliability targets, and identifying the RIM 6 strategies.
7 The Monitoring and NDE Expert Panel is 8 responsible for, basically, all things related to NDE.
9 They're responsible for developing, monitoring NDE 10 specifications; overseeing the quantification of NDE 11 methods and techniques.
12 And there are specific requirements in the 13 Code related to the qualification and who needs to 14 serve on these panels.
15 Next slide.
16 So, this slide just shows, and the next 17 couple of slides just walk you through, what's in RIM.
18 This slide shows the organization of RIM. The 19 structure is very similar to Division 1, except for 20 Article RIM-2, which is the RIM program. So, RIM-1 is 21 scope and responsibility. This section covers the 22 scope of RIM, the owner's responsibilities, and other 23 general requirements. It's very similar to Division 24 1 IWA-1000. As a matter of fact, a lot of the 25 descriptions will refer back to IWA for a lot of the 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 1 requirements.
2 And Article RIM-2 is the RIM program, 3 which is -- I covered the process.
4 RIM-3 is acceptance standard, and it 5 refers to Appendix 7 for acceptance standards for each 6 reactor type.
7 And RIM-4 covers repair and replacement 8 activities and is done -- essentially, it refers back 9 to IWA-4000, which is the rules for repair and 10 replacement activities, with a couple of exceptions.
11 One is related to preservice inspection, and then, the 12 other exception is related to pressure testing.
13 And RIM-5, basically, provides rules for 14 leakage monitoring and leak detections -- retesting.
15 And RIM-6 covers reporting requirements 16 and is similar to Division 1, IWA-6000.
17 DR. BLEY: Bruce?
18 MR. LIN: Yes?
19 DR. BLEY: RIM-3, is that expected to get 20 expanded, as people consider different reactor types?
21 MR. LIN: Yes. Well, right now, RIM-3, 22 basically, refers the user to Appendix 7. Appendix 7 23 will, basically, have reactor-specific requirements or 24 reactor-specific acceptance standards. So, for each 25 reactor type, they'll have their own acceptance 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 1 standards.
2 DR. BLEY: Okay. And I'm assuming that's 3 not complete and will have to be expanded, if new 4 types are brought forward.
5 MR. LIN: Right. Right. Right now, only 6 two reactor types are complete, including the high 7 temperature gas reactors --
8 DR. BLEY: Uh-hum.
9 MR. LIN: -- and the Gen III or above 10 light water reactors.
11 DR. BLEY: Okay. Thank you.
12 MEMBER KIRCHNER: Bruce?
13 MR. LIN: Yes?
14 MEMBER KIRCHNER: This is Walt Kirchner.
15 Along those lines of Dennis' question, it 16 seems to me that -- I'm speculating, to be candid --
17 that these implements for each reactor type really are 18 driven by the coolant choice. I mean, the ASME is in 19 the pressure vessel business, so to speak.
20 MR. LIN: Right.
21 MEMBER KIRCHNER: So, the defining 22 characteristic probably is a combination of the 23 coolant type and the temperature-pressure ranges that 24 are expected for the reactor type. Is that a 25 reasonable assessment of what's coming for the 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 1 supplements? I can't imagine doing a supplement --
2 you know, you could have someone do one variation of 3 a molten salt reactor, and someone else do another 4 variation, but, in general, the pressure vessels don't 5 know that it's a different reactor. You know what I 6 mean?
7 If you need to use a pressure vessel of 8 some kind for a molten salt reactor, it doesn't care 9 whether it has pebbles in it or not.
10 MR. LIN: Right.
11 MEMBER KIRCHNER: So, is that the way it's 12 going? Is it more like that or you're trying to go 13 with the Gen IV and DOE designs that are being 14 supported?
15 MR. LIN: Yes, I --
16 MEMBER KIRCHNER: It seems to me there 17 might be an opportunity to make this more technology-18 neutral in terms of the details of the reactor design 19 and focus on what the pressure vessel, boiler and 20 pressure vessel code is all about, which is 21 maintaining the integrity of the component, not 22 picking sides about reactor types.
23 MR. LIN: Right. I think the strategy is 24 that the RIM process itself is technology-neutral.
25 You can use the process on any reactor type. And the 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 1 idea with Appendix 7 is, you know, some of the 2 degradation mechanism is unique to the reactor design.
3 Like, for example, you choose different coolant; that 4 has different degradation mechanisms. So, if you 5 operate at high temperature, then you maybe have to 6 worry about creep and other high-temperature 7 degradation mechanisms.
8 So, Appendix 7 is supposed to have 9 reactor-specific degradation mechanisms, reactor-10 specific evaluation standards, and acceptance 11 standards that are all based on the unique design, 12 right? For some of those reactors, they could be 13 operated at atmospheric pressure. So, it's different 14 than the traditional requirement for RPVs. So, they 15 will have their own acceptance standards and unique, 16 their own lists of degradation mechanisms. It depends 17 on the reactor type.
18 DR. BLEY: Bruce, this is Dennis Bley 19 again.
20 We had a session yesterday on Part 53 21 where we're looking at different approaches. And some 22 of those approaches, they require principal design 23 criteria and others they don't.
24 This Reg. Guide is anchored to a set of 25 advanced reactor design criteria that specifies 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 1 certain kinds of testing that need to be done.
2 I suppose, even if someone uses this new 3 Part 53 and does not define their own Principal Design 4 Criteria, that, at least for most of the designs we 5 expect to see, the ARDC will probably be reasonable.
6 So, that shouldn't cause a problem. But if some new 7 reactor type comes in that would require different 8 design criteria, I guess that changes this whole 9 process. But that's what the appendices will make 10 clear, I'm guessing?
11 MR. LIN: Right. I mean, I think, like I 12 said, the process itself is very technology-neutral.
13 I would imagine each reactor vendor or designer would 14 have to go through the process and develop their own 15 unique RIM program. You know, maybe for one reactor, 16 it's reasonable to inspect every five years, but they 17 may not incorporate for other reactor designers for 18 the same components, because they operate in a 19 different environment. So, I think each reactor 20 design, a unique design, will probably have their own 21 unique RIM program.
22 DR. BLEY: Okay. Thanks.
23 I guess, for Dave, if you're on the line, 24 we had that discussion yesterday about not needing 25 principal design criteria. Well, here we're bumping 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 1 into a place where you need almost the equivalent to 2 come out of the process, to be able to use this Reg.
3 Guide and the new standard. So, something to think 4 about.
5 MEMBER PETTI: Yes. No, I think that may 6 have just been almost semantic. I still think Part 53 7 requires design criteria. They used the word 8 "principal" because it was tied back to 50 or 52.
9 But, yes, your point is noted.
10 MEMBER KIRCHNER: Well, Dave, this is 11 Walt.
12 Given the importance of reliability to 13 support the PRA results through the life of one of the 14 plants that goes through the LMP process in 53, do you 15 see this being invoked directly by 53, or it would be 16 through guidance?
17 MEMBER PETTI: I mean, right now, probably 18 guidance. And what's in there, you know, is 19 acceptable codes and standards, right?
20 MEMBER KIRCHNER: Yes.
21 MEMBER PETTI: And this is one that's been 22 accepted by the staff.
23 MEMBER KIRCHNER: Yes. I'm just trying to 24 think through the wording in 53. Is there any 25 requirement for a reliability program to support the 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 1 PRA through the life cycle of the plant?
2 MEMBER DIMITRIJEVIC: Walt, do you have a 3 draft? This isn't connected to the passive 4 components. So, let's sort of like step back a 5 little. You know, the passive components, you know, 6 like if it's related to risk-informed ISI, which I'm 7 very familiar with, that is related to just the 8 typings of the different class, which are usually not 9 in the PRA directly, but can be connected to the 10 active components. Several of the passive components, 11 like a check-well, is added in the PRA. This is 12 limited. Most of those things can cause initiating 13 events, and from that perspective, you know, like 14 steam line breaks, feedwater line breaks that lock.
15 So, the active components, which most of 16 the PRA consists of, are in the RAP program. I mean, 17 that's in the FSAR. You know, it would be part of the 18 ITAAC items.
19 MEMBER KIRCHNER: Yes, I get that, Vesna.
20 I was just trying to think through. So, say, you 21 know, this program is to actually maintain the 22 reliability, so that you don't challenge the 23 assumptions. But, you know, from the PRA standpoint, 24 don't you look at the possibility -- I mean, an 25 initiating event would be a break in a passive 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 1 component.
2 MEMBER DIMITRIJEVIC: Yes, that's true.
3 But, you know, you have ITAAC items which cover 4 testing, inservice inspections, the RAP program, which 5 is directly connected reliability. It has the same 6 panels that's already part of the FSAR.
7 MEMBER KIRCHNER: Right. No, I understand 8 that. I'm just thinking -- I'm trying to think 9 through the life-cycle impact of doing this.
10 Basically, it's there to ensure that --
11 MEMBER DIMITRIJEVIC: Well, currently, you 12 have (audio interference) actions. You have intent, 13 yes, testing the valves, which are part of ITAAC.
14 Currently, all the plants, almost all the plants in 15 like the states are doing risk-informed inservice 16 inspections.
17 So, I mean, you know, I don't think we 18 have to worry will that be covered. You know, that's 19 what I was trying to respond to your question. It's 20 a part of the ITAAC problem, yes.
21 MEMBER PETTI: I think the place to look 22 will probably be in TCAP and RCAP, where commitments 23 are made. I don't know which one; I don't recall.
24 But that's, you know, that's basically the content of 25 applications. It's somewhere in there the applicant 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 1 would commit to this kind of program.
2 MEMBER KIRCHNER: Would this -- Dave, I'm 3 also thinking through. We didn't do Subpart F 4 yesterday. But would this show up in operations?
5 MEMBER PETTI: It might. I just don't --
6 I don't remember. I don't recall in Subpart F if this 7 is touched on. I'd have to go back and look.
8 MR. PHILPOTT: Good morning.
9 This is Steve Philpott. I'm a Project 10 Manager in DANU. I'm going to be your next speaker.
11 But I would just add in that part, there 12 is a section in Part 53, in the preliminary proposed 13 rule language -- and I'm not sure what subpart it is; 14 in operations I believe, 53.870 -- that would include 15 a requirement for integrity assessment programs. And 16 so, this lines up well with some of that language now.
17 It would be a way of, you know, a method for 18 addressing that section.
19 MEMBER KIRCHNER: Yes, that's what I was 20 thinking. Thank you.
21 MEMBER PETTI: Yes. Okay. Thanks.
22 MR. PHILPOTT: And there is also, in the 23 RCAP program that you're referring to, there is an ISG 24 that we're working on developing to release that is 25 specific to inservice inspection and inservice testing 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 1 both. It covers both LWRs and non-LWRs.
2 And that also, for the non-LWR ISI portion 3 of that, it does refer to RIM as a method to address 4 the information in the application.
5 MEMBER KIRCHNER: Great. Okay. Thank 6 you.
7 MR. PHILPOTT: Sure.
8 CHAIRMAN BALLINGER: This is Ron again.
9 The industry has been bound by Section XI, 10 Division 1, from the beginning. But, as a practical 11 matter, within Division 1, the inspection regimes, the 12 use of risk information, and all of that, has evolved 13 to the point where they don't call it RIM, but, in 14 effect, that's what the industry has been doing for 15 the last 10 or more years.
16 And so, it's not that big a jump, as a 17 practical matter, from Division 1 to Division 2. And 18 I look at it as Division 2, while it's applicable to 19 non-light water reactors, and everything, it's an 20 outgrowth of the, if you want to call it, lessons 21 learned from dealing with Division 1 and the 22 degradation in our systems.
23 Maybe that's a simplistic way of looking 24 at it, but, you know, I look at this as, basically, a 25 codifying of what, in effect, people have been doing 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 1 all along, or evolved to be doing now in the light 2 water reactor business.
3 MEMBER KIRCHNER: I think you got it 4 right, Ron.
5 MEMBER PETTI: Yes, I think that's right.
6 The biggest difference is the materials are different; 7 the service conditions are different. So, the damage 8 mechanisms are different. And so, that may in the 9 details change, you know, the nature of the 10 inspection. You know, what you look for and how you 11 look for it might change because of all of those 12 things.
13 CHAIRMAN BALLINGER: Yes.
14 MEMBER PETTI: But, at a higher level, I 15 agree with you, yes.
16 CHAIRMAN BALLINGER: I mean, this is, 17 basically, a codified way of doing, what I would call 18 in the information theory business, surprise.
19 MEMBER DIMITRIJEVIC: But this is very 20 important to the monitoring program because, you know, 21 when you start those inspections, you can discover 22 degradation mechanisms which you didn't really 23 anticipate. So, for this new-type monitoring program 24 for that, new degradations are very important.
25 CHAIRMAN BALLINGER: Yes, in our business, 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 1 surprise has cost us a lot of money.
2 Okay. Could we keep going? This is very 3 good discussion, actually.
4 MR. LIN: So, I think this is my last 5 slide.
6 RIM also has seven non-mandatory -- or 7 mandatory appendices and two non-mandatory appendices.
8 I'm not going to go through the list, but I'll just 9 mention a few that I haven't talked about.
10 Like Appendix 4, Monitoring NDE 11 Qualifications, basically, provides requirements for 12 qualification of monitoring NDE methods and addresses 13 qualification of NDE personnel, procedures, and 14 equipment.
15 Appendix 6, the qualifications and 16 requirements for the RIM Expert Panel.
17 Again, the big appendix is this Appendix 18 7, which is a supplement for the type of nuclear 19 plant. So, right now, the Code itself has a 20 placeholder for six different reactor types and two 21 have been developed. As I mentioned before, high 22 temperature gas reactors and Gen III or above light 23 water reactor supplements are done. The others are 24 under development.
25 And two non-mandatory cover alternative 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 1 requirements NDE and monitoring and, basically, 2 administrative requirements for --
3 DR. BLEY: Can you tell us anything about 4 that Appendix A? What kind of alternatives are they 5 talking about?
6 MR. LIN: Appendix A, basically, provides 7 a process that you can go through to use different NDE 8 and monitoring techniques. I tried to figure it out, 9 because I think this is that there is a code case that 10 was issued before RIM was published, and this Appendix 11 A, basically, is that code case. It provides, it 12 tells you how you go about doing probabilistic 13 assessment to develop different NDE methods. To me, 14 it's really no different than what's in RIM. I don't 15 know why it's in the non-mandatory appendices.
16 (Laughter.)
17 DR. BLEY: Okay.
18 MR. LIN: It's, essentially, it's part of 19 the RIM. It could be part of the RIM process that you 20 can go through and using different RIM strategies. It 21 was put in there, I think, from what I understand --
22 and I wasn't involved with the development of the code 23 -- there was a code case. I think it was code case 24 875 was issued before RIM was accomplished, and the 25 information from the code case got put into this 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 1 Appendix A.
2 DR. BLEY: Okay. Thanks.
3 MR. LIN: Okay. So, I think that's it, 4 and I'll turn it over to Steve Philpott to discuss the 5 staff review of the RIM standard and the Regulatory 6 Guides.
7 MR. PHILPOTT: Okay. Well, thank you, 8 Bruce.
9 As Bruce mentioned, my name is Steve 10 Philpott. I'm a Project Manager in the Division of 11 Advanced Reactors and Nonpower Production Utilization 12 Facilities. I was the Lead Project Manager for most 13 of the review of RIM.
14 I'm thankful and excited to be here to 15 give you an overview. My goal here is to give you an 16 overview of the review process and the review that we 17 did, but, mostly, give you a summary of what the Reg.
18 Guide is; how it's structured, and touch on some of 19 the conditions, and a summary of the public comments 20 that we received when we issued the Draft Guide, and 21 how we resolved those. We'll step through it for you 22 here.
23 So, go ahead and go to the next slide, 24 please.
25 So, a little bit about the background of 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 1 RIM and our review. ASME sent a letter to the NRC and 2 requested that NRC endorse RIM, the Standard XI, 3 Division 2, in October of 2091. And they specifically 4 asked that we endorse it via 50.55a.
5 We put some staff together to start 6 reviewing it and met with our NRC Design and 7 Inspection Steering Committee in both the spring and 8 summer of 2020. After we had some time to review it, 9 it went to them with recommendations.
10 We recommended, and the decision was made, 11 to not endorse by 50.55a, because that would require 12 the use of RIM, typically, if we encoded it in 50.55a, 13 which we did not think was appropriate at this stage.
14 But, rather, we formed a working group to endorse it 15 via a Reg. Guide, as to make it an option for 16 applicants to use, applicants and licensees. So, I'll 17 talk about that a little bit further in the 18 presentation when we get into some of the public 19 comments.
20 So, we responded; we formed a review 21 working group, and we responded to ASME. Once we 22 decided to go ahead and review it for endorsement via 23 a Reg. Guide, we sent a letter back to ASME and 24 responded in August of 2020.
25 That working group that we developed was 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 1 made up of a team of experienced NRC staff in 2 Component Integrity, Inspection Testing, Codes and 3 Standards, and PSI and ISI programs, and that included 4 some senior technical staff from the DANU Division, 5 the Division of Advanced Reactors, as I mentioned --
6 I'm just going to use that DANU acronym for the rest 7 of the way -- as well as, as you saw from Bruce, from 8 the Office of Research and their Division of 9 Engineering. We had staff from Region II and Region 10 IV included in the working group with experience in 11 inspections, inservice inspections, and testing, as 12 well as other Divisions in NRR as well, the Division 13 of Engineering there as well. And at times throughout 14 the review, we also consulted with other senior 15 technical staff in the Division of New Reactor 16 Licensing and some of the senior advisors in Research 17 as well.
18 I guess one point to note is we had one of 19 our senior staff, along with Bruce, who I definitely 20 would consider an expert, we had, also, a Senior 21 Mechanical Engineer, Tim Lupold, who was our NRC 22 representative on the ASME Working Group for the 23 Development of RIM. He was also a lead technical 24 reviewer and did a lot of heavy lifting and worked 25 with us. He recently retired. So, we got to use his 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 1 skills and his expertise right up until the end, and 2 even through the comment resolution period.
3 Oh, and I should also mention that the 4 Office of General Counsel, you know, while not part of 5 the working group, we did get a lot of effort and a 6 lot of good support from OGC, as we worked through 7 some of kind of the unique licensing aspects of this 8 as well and working through the comment resolution as 9 well. So, we're definitely appreciative of that as 10 well.
11 So, we, then proceeded to conduct a 12 review, a very thorough, detailed review of Section 13 XI, Division 2, for this, developing the Reg. Guide 14 for endorsement. And we specifically did this review 15 for applicability to non-light water reactors, as that 16 was the near-ter need that we saw. The light water 17 reactors are required to use 50.55a, or under 50.55a, 18 are required to use Division 1. And frankly, where we 19 saw the most immediate need was in the non-light water 20 reactors.
21 DR. BLEY: So, a quick question about 22 that.
23 MR. PHILPOTT: Yes? Uh-hum.
24 DR. BLEY: The Reg. Guide is specific to 25 non-light water reactors. The standard itself, 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 1 though, is not, is that correct?
2 MR. PHILPOTT: That's correct.
3 DR. BLEY: Okay.
4 MR. PHILPOTT: The standard is written to 5 be technology-neutral and to apply across 6 technologies. That was a strategic decision at the 7 beginning, that we were going to focus our review on 8 the non-light water reactors. So, it is specifically 9 endorsing it for non-light water reactor applications.
10 And, you know, that may change over time, 11 but at this stage, you know, I think you were alluding 12 to before, RIM is very much a paradigm shift, right?
13 It's a big shift from Division 1. And so, you know, 14 I think we see this as an exciting win moving forward 15 for these non-light water reactors in terms of being 16 able to provide this as an option for the non-lights.
17 We understand that --
18 MEMBER KIRCHNER: This is Walt Kirchner.
19 MR. PHILPOTT: Yes.
20 MEMBER KIRCHNER: But, if I understand 21 correctly, of the two supplements in place, one is for 22 advanced LWRs.
23 MR. PHILPOTT: The two supplements? I'm 24 sorry, are you talking about Appendix 7?
25 MEMBER KIRCHNER: Yes, in the actual --
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44 1 MR. PHILPOTT: In the RIM, the Appendix 7, 2 where they have the plant-specific criteria, yes. One 3 of them is for LWRs, and another one -- several of 4 those are blank, right, they're yet to be developed.
5 There is one --
6 MEMBER KIRCHNER: No, I understand that --
7 MR. PHILPOTT: yes.
8 MEMBER KIRCHNER: -- but I don't 9 understand why you're restricting it. Is this 10 viewgraph accurate of what you're -- are you only 11 endorsing it for non-LWRs?
12 MR. PHILPOTT: We are only endorsing it 13 for non-LWRs, yes, that is correct.
14 MEMBER KIRCHNER: Why is that?
15 MR. PHILPOTT: Well, primarily because 16 50.55a(g) requires a light water reactor applicant to 17 use Division 1 in that paragraph of 50.55a. So, a 18 light water reactor, by regulation, is required to use 19 Division 1.
20 Now, we understand that, for some advanced 21 on the light water side, that this could be -- that 22 Division 1 would be very difficult to apply for some 23 of the advanced light water reactors that we see 24 coming down the road. And they do have an option to 25 use RIM, but they would have to use the exemption 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 1 process to do that, because of the requirement in 2 50.55a. And we understand that that may happen.
3 So far, we're not seeing a lot of interest 4 yet from the LWRs. So, we focused our efforts on 5 endorsing this for non-light water reactors. We do 6 understand that there may be some future light water 7 reactors that do want to use it, and we do know of 8 one, in particular, that does, but their process to do 9 that would be through an exemption from 50.55a(g), and 10 then, we do a plant-specific review in that case.
11 DR. BLEY: This is Dennis again.
12 MR. PHILPOTT: Uh-hum.
13 DR. BLEY: The ASME asked you to review it 14 under part of the regulations where it can't fit 15 unless you change the regulation, basically, is the --
16 MR. PHILPOTT: Right.
17 DR. BLEY: Okay. So, you would have had 18 to do a change to the reg to do that and make it 19 applicable.
20 MR. PHILPOTT: That's correct.
21 DR. BLEY: Nothing in your review would 22 have precluded LWRs from using this, except for the 23 regulation?
24 MR. PHILPOTT: Right. Yes. And I think 25 that's, generally, safe to say; that's generally true.
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46 1 I mean, nothing that -- no, there was nothing that 2 stood out in our review that would specifically 3 exclude LWRs. It's just we did not review it with 4 that focus, and it primarily is the regulation, yes.
5 We would have to do a rulemaking effort to 6 modify the regulations. You know, we did consider 7 that during the review period, you know, different 8 rulemaking options. But, ultimately, we decided, when 9 we went back to the Steering Committee and the 10 Management Oversight Committee, we did decide that 11 that was not the appropriate pursuit at this point, 12 given the level --
13 DR. BLEY: I'm just curious. Has anyone 14 requested a rulemaking on this issue to include it for 15 LWRs?
16 MR. PHILPOTT: Yes, actually. And 17 actually, I'll touch on that briefly when we get to a 18 few --
19 DR. BLEY: Okay.
20 MR. PHILPOTT: -- slides later in some of 21 the comments.
22 DR. BLEY: Fine.
23 MR. PHILPOTT: Yes. And, yes, I neglected 24 to mention, in terms of the review group that we did 25 and the working group, we did also guide and meet 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 1 frequently -- as part of the project plan for this 2 review, there was an established Management Oversight 3 Group at the Branch Chief level that we would meet 4 with on a frequent basis and provide updates, and were 5 guided by some of our decisions that way. And then, 6 we did periodic followups with the Steering Committee 7 on some of the key decisions as well. So, we worked 8 through all those type of questions and issues in 9 those meetings.
10 CHAIRMAN BALLINGER: This is Ron Ballinger 11 again.
12 I mean, again, there's a regulatory fence 13 between the two --
14 MR. PHILPOTT: Uh-hum.
15 CHAIRMAN BALLINGER: -- Division 1 and 16 Division 2, but, as a practical matter, within 17 Division 1, the industry has been doing or evolved to 18 doing what is, in effect, a lot of it is in Division 19 2.
20 So, an exemption request would probably be 21 pretty easy.
22 MR. PHILPOTT: It may be. I mean, I guess 23 it remains to be seen. But, yes, we understand that, 24 clearly, some of the new light water reactors, 25 Division 1 is not going to be their preferred path, 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 1 right?
2 CHAIRMAN BALLINGER: Yes.
3 MR. PHILPOTT: But you're right, we're 4 going to have to review that through the exemption 5 process in this case.
6 And that could evolve -- you know, 7 obviously, the regulatory framework for this could 8 evolve; I expect it probably will evolve over time, 9 right? We were reviewing this based on this submittal 10 and kind of our view of the landscape at the time that 11 we conducted this review.
12 But RIM is, you know, as I think you've 13 kind of seen, there's still a lot of development to 14 do. We don't have any experience with plants using 15 RIM or submitting RIM programs to us, obviously. So, 16 over time, we do expect to try to gain, you know, to 17 hope to gain more of that experience and see what's 18 involved, and see how it could be applicable 19 otherwise.
20 Okay. I think we can go to the next 21 slide.
22 Okay. So, this just kind of provides a 23 timeline of the work that we did. Not a lot of 24 details to share with you here, but, essentially, once 25 we formed that working group from that early initial 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 1 stage, August to December of 2022, we did an initial 2 review with the working group and developed our 3 initial staff positions.
4 And the focus there was to do a first cut, 5 and we confirmed that information in the Code was 6 adequate and it was appropriate to be endorsed. We 7 certainly identified some areas that would likely 8 require conditions, which we did end up having, but we 9 went back to the Steering Committee at that point and 10 received the decision to move forward with a more 11 detailed review and focus on endorsing it via the Reg.
12 Guide.
13 So, in 2021, most of the first nine months 14 of 2021 is when we did the detailed review, went step 15 by step through each of the positions and paragraphs 16 within RIM. Reached out to other technical experts in 17 the agency, and as I mentioned Tim Lupold was on the 18 working group with RIM development. So, during 19 meetings with that working group, he was able to reach 20 back out to them to help get answers to questions and 21 things that weren't clear to us, as we did that 22 initial review. So, all that.
23 We developed the Reg. Guide, Regulatory 24 Guide, in that time period, and then, we published it 25 for public comment right near the end of September 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 1 2021. And we published it with a 45-day comment 2 period. And since that point, since November, we've 3 been working on the comment resolution and finalizing 4 the Regulator Guide.
5 We are on track to publish it. It's ready 6 to go. For the most part, we've got that it will now 7 be published in June of 2022.
8 As Michelle mentioned in her opening 9 remarks, it's tied into, there is some reference in 10 the Reg. Guide to conditions in Section XI, Division 11 1, the 2019 edition. So, in order to not get ahead of 12 that, we are waiting for the rulemaking to be 13 finalized for Division 1 to be incorporated. So, this 14 will be published as soon as that rulemaking is 15 finalized.
16 Okay. Next slide, please.
17 This is just a brief overview of the 18 structure the Reg. Guide. I think this is pretty 19 standard for Reg. Guides. So, I just kind of point it 20 up here to note a few points about the way the 21 Regulatory Guide is laid out. And these are the main 22 points I just want to make.
23 Section A, obviously, addresses the 24 purpose of the Regulatory Guide, which describes an 25 acceptable approach for the development of an 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 1 implementation of a PSI and ISI program for non-light 2 water reactors by endorsing this.
3 The other point of that to note here is it 4 also describes a method that applicants can use to 5 incorporate their preservice inspection and inservice 6 inspection programs into a licensing basis. So, I'll 7 touch on that a little bit later.
8 But the main point there is the current 9 regulations in 50 and 52 don't specifically call out 10 a requirement for a non-LWR to have an inservice 11 inspection program. So, they do, in content of 12 applications sections, they do mention needs for 13 periodic testing of structures and maintenance and 14 surveillance, and that sort of thing.
15 But the license condition, again, this is 16 an area that we worked with OGC quite a bit and 17 determined that the best way at this point to make 18 sure that an inservice inspection program is part of 19 an non-LWR license basis was to include a license 20 condition with the application. And the Reg. Guide 21 provides a sample license condition that an applicant 22 can use to do that.
23 It addresses the applicability very 24 briefly. Of course, as I mentioned, it's specifically 25 applicable to non-LWR applicants or licensees for an 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 1 operating license or a combined operating license 2 under Parts 50 and 52.
3 This is one of the guidance documents, one 4 of several that will eventually support Part 53, when 5 that becomes final, but, again, it's one of the many 6 documents that will be reviewed for conforming changes 7 and updates to make it applicable to Part 53 as well, 8 when we get to that stage in the Part 53 process.
9 We touched on the applicable regulations 10 and related guidance. As I started to mention, the 11 current regulations don't specifically mandate an ISI 12 for non-LWRs. There's 50.34 and 52.79 sections in the 13 content of applications that require those 14 applications to include plans for conducing normal 15 operations, including maintenance accounts, periodic 16 testing of structures, systems, and components.
17 The Reg. Guide gets into a discussion of 18 the General Design Criteria -- it's Appendix A of Part 19 50 -- and how those can be adapted or can provide some 20 guidance for non-light water reactors or reactor 21 designs other than the light water reactors.
22 And then, we do point out, and the Reg.
23 Guide includes, a bit of discussion on Reg. Guide 24 1.232, which is guidance for developing the Principal 25 Design Criteria for the non-light water reactors. And 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 1 then, the Reg. Guide spells out a number of the 2 applicable ARDCs, Advanced Reactor Design Criteria, 3 that relate to SSC testing and provide some basis for 4 this approach.
5 So, Section B provides a lot of the 6 background of how we developed the regulatory basis 7 for it. It, again, discusses that, what I just 8 mentioned, in terms of the regulations in more detail; 9 the fact that they prescribe specific preservice and 10 inservice inspection only for boiling and pressurized 11 water reactors, and it goes through that discussion 12 and develops that process.
13 It highlights several of the ARDCs, as I 14 mentioned, from Reg. Guide 1.232 that reflect the 15 importance of inspection. It briefly summarizes the 16 RIM process for developing a PSI and ISI program, and 17 again notes the purpose and scope of the staff's 18 review.
19 And then, the bases, kind of the meat of 20 the Reg. Guide is the bases for the NRC staff's 21 positions. So, that part goes through the staff's 22 positions or the staff regulatory guidance or the 23 conditions for the use of RIM. And it goes through in 24 detail each of those conditions and provides the 25 background of the staff's review and the reasoning for 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 1 those conditions. There are 15 conditions overall in 2 the Regulatory Guide, and I'll get to those as well.
3 Section C, it is the more brief, concise 4 listing of the specific conditions or guidance 5 positions.
6 Okay. Next slide, please.
7 And I apologize, I'm a little under the 8 weather today. So, I'm going to sip some water from 9 time to time as we go.
10 Okay. The Regulatory Guide conditions.
11 Just as I mentioned, there are 15 conditions total 12 listed within the Regulatory Guide. Many are, I would 13 say some are just maybe minor or more kind of focused 14 and more specific, not maybe as significant. So, I 15 don't intend to go through all 15, but we'll do a bit 16 of an overview and a summary. And I do have, the next 17 slides, I do list what those are in general.
18 But, starting with Condition 1, was the 19 first one, and this is where we provide two things.
20 Condition 1 does two things. It calls out the need 21 for the license condition. It mentions that 22 applicants intending to use RIM should use a license 23 condition. And as I mentioned, it gives you an 24 example of a license condition they can use.
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55 1 that should be included with their application as an 2 initial application. So, this is when they're coming 3 in with their initial application and to describe 4 their RIM program.
5 So, in order to support our finding that 6 they meet those 50.34 and 52.79 content of application 7 requirements, we ask them -- in the Reg. Guide, it 8 provides a list of -- a review summary of the RIM 9 program, and it gives some specific examples of what 10 that should include: things like listing of the SSCs 11 that are in the RIM program. We ask them to describe 12 the methodology for establishing the reliability 13 targets; the methodology for determining that the 14 reliability targets will be satisfied by the 15 registered strategies. So, we ask them to identify 16 what those reliability targets are, things like flaw 17 evaluation acceptance criteria, et cetera. So, that 18 all would be included in their initial summary of RIM.
19 And then, there's a number of other 20 requirements that, as we've gone through the review, 21 are highlighted in the specific conditions throughout 22 the rest of the particular sections, where there are 23 certain things that we ask them to provide. So, 24 things like qualification and certification programs 25 and justification for their PRA, et cetera. Any 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 1 alternatives that they're taking to actual Section XI, 2 Division 2, we would like them to identify that in the 3 application.
4 Condition 4 is where we address any 5 changes to a RIM program after they've had their 6 program submitted to us and it's been reviewed and 7 approved by the staff. In Condition 4, we talk about 8 they can make changes to their program without 9 identifying or without notifying us, but we list some 10 specific areas where we do require submittal to the 11 NRC for review and approval. So, there are some 12 things that we ask them to provide for review and 13 approval; other things that should be submitted to the 14 NRC just for information that we can follow up on, if 15 needed.
16 For review and approval, this focuses on 17 things like changes to the methods to establish the 18 reliability targets and the methods that they use to 19 demonstrate that the reliability targets will be met; 20 any other alternatives to the Code. Again, if they 21 want to implement a new alternative to the Code, they 22 need to send that to us for review and approval. Any 23 changes involving alternate examination methods would 24 need to be submitted for review and approval as well.
25 And then, things like submitting for 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 1 information or Owner's Activity Report forms submitted 2 to us, and then, the Reg. Guide talks about the 3 periodicity for that, and things like that, and a few 4 other things.
5 One other one I wanted to highlight is 6 Condition 10. It's not necessarily a real 7 technically-significant condition, or I would say not 8 a lot of background meat to it, but I just wanted to 9 note that there are provisions in RIM that are listed 10 as "in the course of preparation or otherwise under 11 development." And this largely refers to the 12 technology-specific or plant-specific appendices.
13 And so, we make a note or condition in 14 there that, obviously, if someone is coming in with a 15 RIM program, and the 2019 standard listed as "in the 16 course of preparation and development," we need the 17 applicant to develop that information and provide it 18 to us for review.
19 Next slide, please.
20 So, the next couple of slides, I list 21 briefly the other conditions. Again, there's 15 of 22 them. I don't think we need to go through them all in 23 detail. Some are more minor and relatively minor.
24 One, the top one is we want them to use, 25 if they're using the 2019 edition of RIM, they should 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 1 use that and correspond with the 2019 edition of 2 Section XI, Division 1. Or, basically, if they go to 3 a future edition of RIM, it needs to be the 4 corresponding edition of Division 1.
5 Another one is ANDE. For personnel 6 qualification, RIM mentions or includes use of ANDE-1, 7 which is not an approved qualification standard yet by 8 the NRC. So, we did have to make a note that it's not 9 approved yet at this point. Let's see. And that 10 condition does identify the NRC-approved standard, the 11 CP-189, as well as the standard for performance 12 demonstration that is approved by the NRC.
13 Things like not overriding the 14 construction code by using RIM. Because RIM would 15 prevent or -- sorry -- would permit using some 16 alternate examinations methods in lieu of the 17 examination requirements specified in the construction 18 code. So, we wanted to make sure that they are not, 19 in their use of RIM, they are not overriding the 20 construction code that's approved for that.
21 Next slide, please.
22 Again, a few more high-level ones, 23 summaries. Again, these are some of our more minor, 24 even some minor editorial errors that we noted in the 25 standard; we included that.
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59 1 Preservice inspection for repair and 2 replacement, the timing. RIM lacked information 3 related to the timing for completion of the preservice 4 examinations that may be needed due to activities such 5 as repair and replacement, modifications that may add 6 components or changes that may add existing components 7 into the scope. So, those weren't specifically called 8 out in terms of needing preservice inspection before 9 going into service. So, we noted that there.
10 Another, stress relaxation credit was a 11 degradation mechanism that we felt should be 12 considered after discussing with the technical experts 13 within the NRC as well.
14 Okay. Next slide, please.
15 Okay. So, moving on, I want to just give 16 you a summary of the public comments that we had, and 17 some of the revisions that we made to the Regulatory 18 Guide, based on those comments.
19 We did receive comments from eight 20 distinct comment submissions or submitters, and that, 21 all told, it was approximately 35 individual comments.
22 We say, "approximately" because some of them were kind 23 of broad and, you know, sending in information just 24 for consideration; didn't actually have an actual 25 suggestion or recommended change to them. So, it's 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 1 some of them were fairly lengthy, but, roughly, there 2 were about 35 individual comments that we had to 3 address or we addressed.
4 And we received some very good comments.
5 Some of those commenters, they came from 6 representatives of industry. Three of them came from 7 people who were contributors to the development of 8 RIM, as well as some retired industry, and even one 9 retired NRC member.
10 Like I said, many of those comments led to 11 some good clarifications in the document that I'll 12 describe for you here in the next couple of slides.
13 We reviewed the comments very carefully 14 one by one; went through; you know, in some cases, 15 again, went back and consulted with some of our senior 16 technical advisors, and then, also had very good 17 discussions with OGC support to work through the 18 changes to the Reg. Guide as well.
19 We did not eliminate or add any conditions 20 as a result of the comments. And lastly, we did 21 clarify some of the -- the highlights of the things we 22 clarified are the applicability, because we did 23 receive a number of comments on the applicability, as 24 well as some of the information to be submitted for 25 review, and some of the other staff positions.
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61 1 Okay. Next slide, please.
2 So, on the next few slides, which are my 3 last few slides, I'm just going to highlight some of 4 the main public comments that we addressed and some of 5 the changes that we made, based on those comments.
6 The first one is really the biggest one.
7 The main one that was most significant was we had four 8 of the comments suggested that the Regulatory Guide 9 should be revised to allow LWRs to use RIM. Or a 10 different twist on this same theme, the same idea, in 11 some cases, they said the Reg. Guide should explain 12 the regulatory paths for light water reactors to use 13 RIM.
14 As I kind of mentioned, well, did mention 15 before, light water reactors are required to use, in 16 accordance with 50.55a(g), they are required to use 17 Section XI, Division 1, for inservice inspections.
18 So, you know, the bottom line is it was not 19 appropriate for the Regulatory Guide to address means 20 for light water reactors to counter the actual 21 regulation that's in place. So, we do agree that RIM 22 was developed for any type of reactor design, but we 23 don't, in this Regulatory Guide, we don't take a 24 position on the technical adequacy of RIM for light 25 water reactors, is essentially what we commented in 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 1 the commenter response.
2 And we did not review this standard for 3 light water reactors. So, again, we just reconfirmed 4 that the applicability for this Regulatory Guide is 5 for non-light water reactors.
6 Addressing light water reactors and 7 including information about a process for light water 8 reactors to use it, whether it's through exemptions or 9 alternatives, would be outside the scope of the 10 Regulatory Guide. However, we did include a footnote, 11 which I've listed here for you, just acknowledging 12 that we understand that RIM is developed for any type 13 of reactor design. Again, we state -- you see the 14 language there -- we state the reasoning why this 15 Regulatory Guide does not address light water reactors 16 in the applicability, and we identify the exemption 17 process as the path that they could use.
18 Okay. Next slide, please.
19 In this one, I just wanted to highlight --
20 like I said, several of the comments did provide, 21 particularly from the developers of RIM, did provide 22 some good clarifications that we considered and that 23 did result in some clarification changes in how we 24 mention, for example, Position 1, which, again, 25 discusses all the information that we ask them to 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 1 submit as part of the initial application. We did 2 make some changes to provide more clarity on what 3 we're looking for, and we did get some good 4 suggestions.
5 So, things like listing of the SSCs; in 6 particular, SSCs included in the scope of the RIM, 7 where previously we just asked for kind of the basis 8 of the scope. You know, kind of clarifying on how 9 certain factors are considered in use of the RIM 10 strategies. We clarified the justification for flaw 11 evaluation acceptance criteria, temperature limits.
12 And then, there were some clarifications 13 that we made that applied to both Position 1 and 14 Position 4. They rightly noted that there's no need 15 for this NIS-2 form, which is, basically, a completion 16 of repair and replacement activities. It doesn't 17 include specific information that would be helpful 18 that is not already covered, or would be covered, in 19 the OAR, the Oversight Activity Report. So, we agreed 20 no need. We took out reference to that.
21 Someone rightly pointed out that we 22 previously had a reference to a refueling outage, and 23 we changed that. Obviously, they made the point that 24 some advanced reactors won't have refueling. So, 25 that's more of a terminology clarification there.
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64 1 Okay. The next slide, please.
2 Okay. Position 5, this one relates a bit 3 to -- well, we did add a clarification for the use of 4 CP-189 for qualification and certification of NDE 5 personnel. We added the caveat that any conditions 6 that are listed in 50.55a(b)(2) should be applied for 7 that use, and that made sense.
8 This came in, this comment tied in with --
9 we did receive several or a few comments that related 10 to they wanted the Reg. Guide to provide a path or 11 allow the use of ANDE-1 for NDE personnel 12 qualification. That is a standard that we've been 13 following and working with the developers there, but 14 that is not a standard that we feel is sufficient to 15 be approved by the NRC yet at this point. So, we 16 disagree with the comment that this should include 17 guidance on how to get approval for use of ANDE-1 at 18 this stage.
19 So, the Reg. Guide does, again, clarify 20 specifically the standards that we have that are 21 approved for Division. We did include the comment 22 that we don't see -- personnel qualification is not 23 technology-dependent. So, if ANDE-1 later gets -- in 24 the comment resolution; we didn't include this in the 25 Reg. Guide -- but if ANDE-1 later gets approved for 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 1 use for LWRs, then it should be applicable to non-2 light water reactors also. But, again, this isn't 3 what we're going to state in the Regulatory Guide at 4 this stage.
5 Let's see. Some clarifications on 6 performance demonstration. Again, we added a 7 reference to the appropriate Section XI, Division 1, 8 portion for a performance demonstration, for the 9 approved standards for performance demonstration, in 10 addition, came from that comment.
11 And there were various other kind of more 12 minor clarification changes that we made throughout.
13 And that really is my last slide. I guess 14 the one thing I would finish with was, you know, I 15 think this was a very productive review. As I 16 mentioned before, we see this as really a positive --
17 it's filling a significant need for the advanced 18 reactor community, for the non-light water reactor 19 community.
20 We do see, as we start to get more 21 information from applicants, as they start to use it, 22 I'm sure we'll learn more about RIM programs and how 23 they're developed, and how they're provided. But 24 this, basically, provides a process.
25 As we mentioned before, it's very much a 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 1 paradigm shift from Division 1, but, again, we think 2 this, the ability to get this Regulatory Guide out and 3 provide this as an option for licensees and 4 applicants, I think is a very good thing at this 5 stage.
6 So, let me stop there. That is my last 7 slide. So, I'm happy to take any questions.
8 CHAIRMAN BALLINGER: This is Ron 9 Ballinger.
10 Can we go back to the first main public 11 comment?
12 MR. PHILPOTT: Sure.
13 CHAIRMAN BALLINGER: I forget the slide 14 number. Yes, that will do it.
15 You can probably guess where the comments 16 came from in this area.
17 MR. PHILPOTT: Right.
18 CHAIRMAN BALLINGER: And it kind of makes 19 you wonder whether or not there might be a path 20 forward for Revision X for the Reg. Guide, where you 21 do deal with the 50.55a part for light water reactors, 22 just regular light water reactors.
23 Is there any kind of plan for the future 24 for this?
25 MR. PHILPOTT: So, I guess I would say, I 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 1 would start by saying, yes. I mean, not a specific 2 plan for changing our course.
3 But, you know, it was a strategic decision 4 to not try to change 50.55a at this stage. One of the 5 issues, it would be very complicated to try to weave 6 Division 2 requirements into 55a in parallel with the 7 Division 1 requirements. And so, it would be a 8 significant effort to take that under.
9 One of the things we are doing within the 10 Division of New Reactors is that they are kind of 11 pulsing and looking at some of the light water, 12 potential light water reactor applicants and trying to 13 gauge their interest in the use of RIM. So far, 14 they've only identified the one key player in the use 15 of RIM.
16 So, there are maybe one or two others that 17 are kind of monitoring it and seeing how it goes for 18 the advanced reactor community or for other light 19 water reactors, but more of the interest really seems 20 to be in the non-light water reactors right now. So, 21 basically, what that tells us right now is, from a 22 resource standpoint, it wouldn't make sense to try to 23 do that now.
24 Now that could change once maybe someone 25 implements it or they start to see it implemented. We 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 1 don't currently see any, or at least the word I saw 2 was that we haven't seen any expressed interest from 3 the operating fleet, for example, at this stage to use 4 RIM. But, if that changes, then it becomes, you know, 5 a much bigger potential resource than we do -- and as 6 RIM evolves, you know, we could evaluate that and 7 reconsider that decision in terms of going forward 8 with rulemaking.
9 CHAIRMAN BALLINGER: Thanks.
10 MR. PHILPOTT: Uh-hum.
11 CHAIRMAN BALLINGER: Questions from the 12 members or consultants?
13 MR. TURNBOW: This is --
14 CHAIRMAN BALLINGER: Whoever you are, 15 we're breaking up.
16 MR. TURNBOW: Can you hear me now?
17 CHAIRMAN BALLINGER: Yes.
18 MR. TURNBOW: Okay, good. I'm just 19 switching from mute over.
20 This is Mike Turnbow.
21 Concerning the response to the CP-189 ANDE 22 comments that were just made, that's disappointing 23 because we, the industry, built ANDE at, basically, 24 the request of the NRC, the letter we received from 25 you guys back several years ago about how poor NDE 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 1 personnel performance was. And it is incredibly 2 documented how poor it is.
3 And it continues to this day. CP-189, and 4 even the appendices in Section XI, has done nothing to 5 change it. The failure rate at EPRI for PDI first-6 timers still hovers around 50 percent, which makes no 7 sense.
8 So, I --
9 CHAIRMAN BALLINGER: Excuse me. Excuse 10 me. I don't know who you are. I'm guessing that 11 you're a member of the public. If that's the case, we 12 will entertain comments from members of the public 13 after we get comments from members of the Committee, 14 or the Subcommittee. Excuse me.
15 So, if this is not the case, then I 16 apologize, but can you -- if you are what we would 17 call a member of the public, would you wait just a few 18 minutes until we go around the table, in effect, with 19 members of the Subcommittee?
20 MR. TURNBOW: Okay. I'm a member, I'm a 21 working group member of RIM, just so you know. But if 22 you want me to wait, I'll be glad to wait.
23 CHAIRMAN BALLINGER: Okay. So now, you're 24 in the gray area.
25 MR. TURNBOW: Yes, I'm always in the gray.
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70 1 Matter of fact, all of it's gray.
2 CHAIRMAN BALLINGER: Okay. Let's get 3 comments from Subcommittee members first, and then, 4 we'll --
5 MR. TURNBOW: Okay.
6 CHAIRMAN BALLINGER: Okay.
7 MEMBER REMPE: Ron?
8 MEMBER KIRCHNER: Ron?
9 CHAIRMAN BALLINGER: Yes, sir or ma'am.
10 MEMBER REMPE: Go ahead, Walt.
11 MEMBER KIRCHNER: Ron, I'm thinking about 12 the presentation we heard, and if I understood Steve 13 correctly, the way that non-LWRs would -- let me 14 choose my words carefully -- be required to do 15 inservice inspection is through the content of 16 application requirements of 50 or 52, but not through 17 any direct regulatory requirement, such as exists in 18 55a(g).
19 And so, what I'm thinking -- and I know 20 Dave is on the line -- I'm thinking ahead to our 21 deliberations about 53, and if you don't have required 22 Principal Design Criteria or just design criteria per 23 se, which would invoke such a requirement for purposes 24 of, for example, pressure vessels, whether they are 25 low or high pressure doesn't matter. Is that a gap or 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 1 is that something that we should be thinking about 2 when we get to Subpart F of 53? So, it's just an 3 observation. It's not a question.
4 CHAIRMAN BALLINGER: I think Dave is 5 probably much more qualified to respond to that.
6 Dave?
7 (No response.)
8 Well --
9 MEMBER PETTI: Did you ask me something, 10 Ron? I'm sorry, but --
11 CHAIRMAN BALLINGER: I just fingered you 12 as being the expert for --
13 MEMBER PETTI: Oh, the cleaning lady just 14 knocked on my door and looked in. So --
15 (Laughter.)
16 What were you saying?
17 MEMBER KIRCHNER: Well, Dave, it was Walt.
18 I made an observation that it seems to me --
19 MEMBER PETTI: Yes, yes, I got the off-20 tech piece, yes.
21 MEMBER KIRCHNER: Yes, yes.
22 MEMBER PETTI: I mean, it's something to 23 look at in Subpart F, I guess, on operations.
24 MEMBER KIRCHNER: Yes, it seems to me, 25 without getting as prescriptive as what's in 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 1 50.55a(g), one would want to demonstrate an equivalent 2 level of safety for a non-LWR, inservice inspections.
3 I'll just leave it at that high, general level without 4 trying to resolve how one obtains that result.
5 MEMBER DIMITRIJEVIC: Well, it will be 6 interesting what would this be in the, you know, non-7 PRA framework, you know, for selection of the SSCs.
8 So, again, I think we will have to monitor how this 9 goes in the 53.
10 MR. PHILPOTT: Uh-hum. And as I mentioned 11 earlier, I'm certainly not a Part 53 expert. So, I 12 don't want to speak for that team in great detail, 13 other than to note that they have written in a section 14 related to integrity assessment programs where this 15 would tie in, but not -- I don't see that -- that 16 doesn't necessarily specifically require ISI programs 17 or have that specificity that 50.55a(g) does. It's a 18 different approach, but -- okay.
19 CHAIRMAN BALLINGER: Did I hear --
20 MEMBER PETTI: So, just to be clear, 21 before we go to a different topic, I have opened up 22 the draft of Part F, and there's a whole section on 23 maintenance, repair, and inspection programs. So, 24 there's words in there -- "performance," "condition 25 monitoring." I'm just skimming.
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73 1 But I'll look at it, you know, offline, 2 but I think at least there's a hook. It may need to 3 be noodled, but it's there. There's something there 4 to start with.
5 MEMBER KIRCHNER: Yes. Yes. Yes, thanks, 6 Dave.
7 The other thing I'm thinking is the Reg.
8 Guide is guidance, and that's different than 55a(g),
9 which is a requirement.
10 MEMBER PETTI: Right. This is in the rule 11 text, 53.715, the draft rule text.
12 MEMBER REMPE: So, Ron, are we ready for 13 another topic?
14 CHAIRMAN BALLINGER: Yes, I was about to 15 -- I assumed that that was your voice that I heard.
16 MEMBER REMPE: Okay, yes, this is Joy.
17 I'm hoping I'll get my comment out. I got 18 kicked off twice in the last 20 minutes.
19 But, anyway, I'm thinking about path 20 forward. And in July, we had a reservation for a 21 possible letter, which I think is not going to be a 22 letter on this, because the staff even told us today 23 they're going to issue this in June.
24 CHAIRMAN BALLINGER: Yes, the intent was 25 for this to be just an information briefing.
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74 1 MEMBER REMPE: And I think that's a good 2 intent.
3 On the other hand, I know that Dave has a 4 Part 53 letter scheduled for July. And we heard 5 yesterday that what we get on Part 53 at the upcoming 6 Subcommittee is not a sure bet.
7 And so, I wanted to put out there that I'm 8 thinking that we should definitely have a letter on 9 Part 53, but it might be, you know, whatever we get 10 with respect to Part F and Track B, or whatever option 11 B is, as well as maybe a section on guidance. We've 12 heard some good things today, that there might be a 13 worthwhile paragraph, and then, talking about how it 14 interacts with the rulemaking language. And there's 15 some issues about guidance that might need 16 clarification and how important that is. But we're 17 monitoring the staff progress on guidance to support 18 non-LWR licensing.
19 And I guess I'm throwing that out there 20 for the Committee to consider, you as well as Dave, 21 since it's his letter that he's leading.
22 What do others think?
23 MEMBER PETTI: No, I think it's a good 24 idea, because there's a couple of things in my head 25 that are not necessarily part of 53, but may be better 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 1 in guidance. So, it would just be a little section, 2 like you said, where we could put some ideas together.
3 Because, you know, the guidance in many areas hasn't 4 been developed, but these would just be some of our 5 thoughts to make sure that we have them on the record 6 for the staff to think about.
7 MEMBER REMPE: Yes, in earlier letters, we 8 talked about that. That was one of the things we 9 highlighted, that we needed to have an idea of the 10 guidance and its progress.
11 So, anyway, that's kind of like I thought 12 it would be good, before we end this discussion, to 13 have clarity. We're not going to have any more 14 presentations or letter in July, and that topic will 15 go off the July agenda, which hasn't been published 16 yet. But Dave's letter will have more certainty, 17 which wasn't very certain yesterday after what we had 18 heard from the staff.
19 CHAIRMAN BALLINGER: Okay. Other comments 20 from members?
21 (No response.)
22 Okay. Hearing none, now we can -- it's 23 the appropriate time to get comments from members of 24 the public, and even the gray area of the public 25 members.
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76 1 So, Members of the Public, if you would 2 like to make a comment, please state your name and 3 make your comment.
4 MR. TURNBOW: Okay. This is Mike Turnbow 5 again. And I'm Secretary of the working group, MANDE, 6 under RIM; also, the Chairman of the ANDE Project, 7 when we wrote the standard the first time, which 8 included NRC representation throughout the entire 9 process. I now chair the implementation piece of 10 ANDE.
11 And my comment is, as I've stated -- just 12 to go back over it one more time -- it's a little 13 disappointing because we started the project at the 14 request of the NRC several years ago. NRC sent us a 15 letter; ASME telling us that the NDE, basically, was 16 broke, was what the letter said, in my terms, and it 17 should be addressed. And we committed to it, and now 18 we've done it.
19 And it's still in accordance with the same 20 process that -- these are power plant operators, the 21 systematic approach to training through INPO. So, we 22 followed that same, exact process with the NRC staff, 23 taxpayers' money and utility money. We spent about 24 $2.5 million building this.
25 And so, we're at a point of implementing 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 1 it. And it seemed like, since RIM is a new document 2 coming out -- so is ANDE a new document coming out --
3 it seemed it would be a perfect marriage; plus, it's 4 performance-based, which the RIM folks are very 5 interested in.
6 Since the beginning, since CP-189 was 7 introduced, and all the appendices in Section XI, 8 around '92, the pass rate at EPRI has hovered around 9 50 percent. And all the things we've done in the Code 10 and adding these other caveats to CP-189, still 11 results today in a 50 percent pass rate. Basically, 12 we've done nothing to fix that, except we've built a 13 -- so, I'm going to stop there.
14 I know we're not going to resolve this 15 today, but we'll just have to continue to work 16 together and see if we can't realize we probably have 17 the best solution on the planet right here.
18 CHAIRMAN BALLINGER: Thank you.
19 MR. TURNBOW: Thank you.
20 CHAIRMAN BALLINGER: Other members of the 21 public that would like to make a comment?
22 (No response.)
23 Hearing none, then I think we are pretty 24 much done.
25 I would like to thank the staff -- and I'm 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 1 sure the rest of the Committee members would be the 2 same -- for a presentation.
3 I believe -- and this is one person's 4 opinion -- that this is a very significant change. I 5 would, for one, would like to -- again, I keep saying 6 that the industry has been moving in this direction 7 within the confines of Division 1, anyway. Anybody 8 that's been familiar with environmental degradation of 9 materials knows this, and anybody that's read MRP-227, 10 I think it is, or even the newest version of that, 11 will agree.
12 But I thought it was a great presentation.
13 And absent any additional comments from members, we 14 would like to thank you very much for the 15 presentation.
16 And with that being said, we are 17 adjourned.
18 (Whereupon, at 10:12 a.m., the 19 Subcommittee was adjourned.)
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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, 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
- 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
- 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).
24
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