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NRC Section XI Report - February 2003

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Presented By: Mr. Wally Norris, United States Nuclear Regulatory Commission

NRC Report
Section XI
February 2003

1. Amendments to 10 CFR 50.55a

The final amendment to 10 CFR 50.55a incorporating the 1997 Addenda through 2000 Addenda by reference was published on September 26, 2002 (67 FR 60520) and is available at the Office of Federal Register website: http://www.access.gpo.gov/su_docs/fedreg/a010803c.html

The NRC staff has nearly completed its formal review of the changes to the ASME Code incorporated into the 2001 Edition/Addenda and the 2002 Addenda. A formal schedule for publication to receive public comments is not yet available, but it is anticipated that the proposed rule will be published in the last quarter of CY03.

2. ASME Code Cases - Rulemaking/Regulatory Guides

Four draft regulatory guides were published for public review on December 28, 2001: DG-1090, (Proposed Revision 32 to Regulatory Guide 1.84), "Design, Fabrication, and Materials Code Case Acceptability, ASME Section III; DG-1089, "Operation and Maintenance Code Case Acceptability," ASME OM Code; DG-1091, (Proposed Revision 13 to Regulatory Guide 1.147), "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1; and DG-1112, "ASME Code Cases Not Approved for Use." The guides address Supplement 4 to the 1992 Edition through Supplement 11 to the 1998 Edition, and OMN-1 through OMN-13. Fifteen comment letters were received on the draft guides, and eight letters were received on the proposed rule. The staff has completed its proposed responses and revised the rule and guides accordingly. The final package is being reviewed by NRC management. The Committee to Review Generic Requirements (CRGR) and Advisory Committee on Reactor Safeguards (ACRS) reviews are being scheduled. It is anticipated that the final rule and guides will be published in May 2003.

The NRC staff has completed its review of the Code Cases in Supplement 12 to the 1998 Edition through Supplements 1, 2, and 3 to the 2001 Edition. Proposed Revision 33 to Regulatory Guide 1.84, Proposed Revision 14 to Regulatory Guide 1.147, and Proposed Revision 1 to RG XXX, "ASME Code Cases Not Approved for Use," are in office review. These draft guides are scheduled to be published in June 2003.

Supplements 4 and 5 to the 2001 Edition are presently under review.

3. ASME PRA Standard

Draft Regulatory Guide DG-1122, "An Approach for Determining the Technical Adequacy of PRA Results for Risk-Informed Activities," which provides the NRC’s proposed positions on consensus PRA standards and industry PRA documents, has been published for public review and comment (comment period ends on February 28, 2003). A second public workshop will be held at NRC headquarters on March 11, 2003. Several changes to the PRA Standard have been made, and the ASME plans on issuing an addendum.

4. Risk-Informed Activities

The NRC website contains information at http://www.nrc.gov/what-we-do/regulatory/rulemaking/risk-informed/reactor-safety.html relative to risk-informed activities in the Reactor Safety Arena.

Recent activities in the application of RI-ISI methodology include the extension of the RI-ISI methodology as an alternative to augmented inspection programs for break exclusion region (BER) requirements typically identified in Standard Review Plan Sections 3.6.1 and 3.6.2. piping. Both EPRI and WOG have developed methodologies to expand their current RI-ISI methodologies for this application. The staff has approved the use of the EPRI methodology to change the BER programs (ML021790158). If the BER program is described in the final safety analysis report, licensees may implement changes to the BER program according to the provisions of 10 CFR 50.59. Review of the WOG methodology is continuing.

The staff met with NEI and other industry representatives in November 2002 to discuss "living program" guidance for risk-informed in service inspection (RI-ISI) programs. RI-ISI programs must be updated to reflect changes in the plant, and general industry experience that might impact the program. The schedule and extent of such changes is under development. NEI stated that it intends to complete guidance on this process and to provide it to the staff for review and comment by the Spring of 2003. There are currently no plans for the staff to approve the guidance.

The staff is in the process of updating the RI-ISI Regulatory Guide 1.178 and SRP Section 3.9.8 and plans to issue the updated guidelines by the summer of 2003. Minimal changes are needed or planned. A public workshop is tentatively scheduled for March, 2003, and a presentation to the ACRS is tentatively scheduled for May 2003.

5. Generic Activities on PWR Alloy 600/182/82 PWSCC

The Davis-Besse Lessons Learned Task Force report was issued on September 30, 2002. The full 96 page report (plus attachments) is available on the NRC’s web site at: http://www.nrc.gov/reactors/operating/ops-experience/vessel-head-degradation/news.html.

The Office of the Inspector General (OIG) on December 30, 2002, issued Report 02-03S, "NRC’s Regulation of Davis-Besse Regarding Damage to the Reactor Vessel Head." This report can be found on the OIG webpage. On January 8, 2003, Chairman Meserve wrote a memorandum to Hubert T. Bell, Inspector General, regarding the report, which can be found on the News and Correspondence page.

On January 14, 2003, Gary Holahan, Director of the Division of Systems Safety and Analysis (DSSA) issued a memorandum to the Commission and the Executive Director for Operations titled "Comments in Defense of the Risk-Informed Decision Making Process and on the OIG Event Inquiry, "NRC's Regulation of Davis Besse Regarding Damage to the Reactor Vessel Head." This memorandum can be found at http://www.nrc.gov/reactors/operating/ops-experience/vessel-head-degradation/news.html.

On February 4, 2003, the staff briefed the Commission on "Lessons Learned: Davis-Besse Reactor Vessel Head Degradation." The purpose of the meeting was to focus on the actions by the licensee and the industry. The Commission was interested in the actions taken by the licensee since the identification of the vessel head degradation to restore the facility, to address the issues identified in the root cause evaluation, and to demonstrate compliance with NRC requirements. A third panel consisted of various stakeholders with an interest in the Davis-Besse incident. A copy of the slides and transcript can be found at: http://www.nrc.gov/reading-rm/doc-collections/commission/tr/2003/.

On February 11, 2003, an Order titled, "Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors," was issued (EFFECTIVE IMMEDIATELY). Many of the licensees' responses to Bulletin 2002-02 did not describe long-term inspection plans nor a schedule to submit such descriptions. The Order requires specific inspections of the reactor pressure vessel (RPV) head and associated penetration nozzles at pressurized water reactors (PWRs). It has been determined that the current RPV head visual inspection requirements are not sufficient to reliably detect circumferential cracking of RPV head nozzles and corrosion of the RPV head. The Order establishes interim requirements to ensure that licensees implement and maintain appropriate measures to inspect and, as necessary, repair RPV heads and associated penetration nozzles. The long-term resolution of this issue is expected to involve changes to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) and will involve changes to the NRC regulations in 10 CFR 50.55a, "Codes and standards."

On February 24, 2003, a meeting was held at NRC headquarters to discuss the Orders. Slides for the meeting are posted on the NRC web site.

6. Future Reactor Licensing Activities - Advanced Reactor Infrastructure Assessment

In response to Staff Requirements Memorandum (SRM) for COMJSM-00-0003, the staff prepared and issued information paper, "Future Licensing and Inspection Readiness Assessment [FLIRA]," SECY-01-0188, dated October 12, 2001. The FLIRA committed the staff to perform an advanced reactor Infrastructure Assessment (IA), to set directions for research programs, and to identify necessary tools and expertise necessary to support the regulation of new reactor designs. In response to that commitment, the staff identified technology gaps and Agency needs in the form of methods, tools, data, and expertise. These needs are primarily associated with non-LWRs.

There continues to be significant interest and activity on new reactor licensing topics. On March 28, 2002, Westinghouse Electric Company (Westinghouse) submitted its application for final design approval and standard design certification for the AP1000. The staff is currently reviewing the AP1000 design certification application and has six other designs in various stages of preapplication review (most notably the ESBWR and Gas Turbine-Modular Helium Reactor (GT-MHR) designs). General Atomics met with the staff and interested stakeholders on January 28 and 29, 2003, to discuss issues related to technology and preapplication activities. In addition, preapplication discussions are taking place in preparation for three early site permit applications expected in 2003. Proposed changes to 10 CFR Part 52 have been forwarded to the Commission. ESP pre-application public meetings, discussing key issues with NEI and the expected applicants have been initiated. The staff has also begun conducting public meetings in the vicinity of expected sites to inform the public about the ESP process and opportunities for public participation.

In SECY-02-0139, "Plan for Resolving Policy Issues Related to Licensing Non-light Water Reactors," July 22, 2002, the staff identified issues with potential policy implications resulting from efforts to date. The Advisory Committee on Reactor Safeguards (ACRS) was briefed on October 10, 2002, and a public workshop was held on October 22-23, 2002, to discuss key issues and options for resolution. The staff presented key issues and preliminary recommendations to the ACRS on December 6, 2002. On January 8, 2003, SECY-03-0005, "Semiannual Update of the Status of New Reactor Licensing Activities," was transmitted to the Commission. This paper informs the Commission of the staff’s new reactor licensing activities since the issuance of SECY-02-0076, "Semi-Annual Update of the Future Licensing and Inspection Readiness Assessment," dated May 8, 2002.

The staff will issue the draft safety evaluation for the AP1000 design certification in June 2003. Pre-application review for the ESBWR and GT-MHR designs will continue, with additional pre-application reviews for the ACR-700, SWR 1000, and IRIS designs starting. Technical and regulatory infrastructure development will continue, with the goal of improving the efficiency, effectiveness, and realism of staff review, and ensuring that an appropriate level of safety is maintained for new reactor and site licenses.

7. Risk-Informing 10 CFR Part 50 (Option 2)

The NRC staff has prepared a proposed rule, 10 CFR 50.69, "Risk-Informed Treatment of Structures, Systems, and Components," under Option 2 of the NRC’s initiative to incorporate risk insights into its regulations. The Commission has sought for a number of years to find various ways to use the risk insights gained to shape the NRC’s regulatory system in new ways. Option 2 was to focus on the requirements dealing with safety-related structure systems and components (SSC's). Consistent with Commission direction, the staff made its preliminary rule language publicly available on the NRC website on November 29, 2001. The staff reviewed the comments received on the draft rule and posted a revision to the draft rule dated April 3, 2002. Comments on the revised draft rule were received from NEI in a letter dated May 15, 2002, and from ASME in letters dated June 3 and 17, 2002. A public meeting was held on June 18, 2002, to discuss the NEI and ASME comments. The NRC staff considered the comments and posted a further revised draft rule dated July 31, 2002. NEI is preparing guideline document NEI 00-04, "Option 2 Implementation Guidance."

On Thursday November 21, 2002, a Commission briefing was held on risk informing special treatment requirements (the proposed rule and Differing Professional Views [DPV]on the proposed 10 CFR 50.69 rule package are available at http://www.nrc.gov/reading-rm/doc-collections/commission/slides/2002/20021121/. The filers of the DPV believe that the treatment of RISC-3 components is not sufficient to maintain safety and protect the public health and safety. The staff has focused its review of NEI 00-04 on categorization, and did not plan to develop or endorse regulatory guidance for treatment of RISC-3 components. NEI submitted a draft of NEI 00-04 on June 28, 2002. On August 14, 2002, the NRC staff provided comments to NEI on the guidance document (ADAMS Accession No. ML022270004). The NRC staff plans to complete a regulatory guide that would endorse NEI 00-04 with clarifications and exceptions, as necessary. At the present time, there are a number of issues that need further discussion and development before NRC can complete such a document.

Pilot plant activities at Wolf Creek, Surry, Quad Cities, and Palo Verde were conducted to evaluate the proposed NEI Option 2 implementing guidance (NEI 00-04). The staff plans to use the lessons learned from these efforts to improve the NEI guidance and the Option 2 regulatory framework. There are issues that remain to be resolved in the implementation guidance.

8. Monthly Operating Reports (MORS)

Representatives from the licensees, the Institute of Nuclear Power Operations (INPO), the Nuclear Energy Institute (NEI), and staff from NRR and RES met on February 13, 2003, to discuss alternatives to licensees submitting MOR data. Specifically, the meeting discussed the possible use of the Consolidated Data Entry (CDE) system being developed by INPO. In 2004, utilities will input data to CDE; the CDE system will then develop data for the Reactor Oversight Process (ROP), WANO indicators, MORs, and the Equipment Performance and Information Exchange system (EPIX). Current plans are for the ROP and MOR data developed by CDE to then be submitted to NRC.

The meeting also discussed 1) eliminating any MOR data that may not be needed by NRC, 2) the frequency of reporting MOR data, and 3) eliminating the requirement in the Technical Specifications to report these data. The attendees agreed to pursue the option of having MOR data input to CDE and submitted electronically on a quarterly basis (instead of monthly) to the NRC as part of the ROP reporting process. This option will be discussed further at the next meeting of the Licensing Action Task Force (LATF) and possibly at an external meeting prior to the LATF meeting.

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