HL-5602, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds

Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds

ML20216C681
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	04/03/1998
From:	Sumner H SOUTHERN NUCLEAR OPERATING CO.
To:	Hoyle J NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR63892, RULE-PR-50 62FR63892-00062, 62FR63892-62, HL-5602, LCV-1205, NUDOCS 9804150009
Download: ML20216C681 (4)

Text

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Lewis Swaner Southern Nuclear i Vee President Operating Company, loc.

• - Hatch Project Support 40 invomess Parkway Post Office Box 1295 D0 METED Binningham. Alabama 35201 USNRC Tel 205.992.7279 ,

Fax 205.992.0341

% APR 13 P2 :57 s o MuMm em u m

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Pfl0 POSED RULE Pfl 50 Apr n 3, 1998 & j f f . E y/ d"~ 5 - *'"' l

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Docket Nos. 50-348 50-321 50-424' liL-5602' 4 50-364 50-366 50-425 LCV-1205 I

Mr. John C. Iloyle, Secretary U. S. Nuclear Regulatory Commission ATTN: Rulemakings and Adjudication's Staff Washington, D. C. 20555-0001 Comments on 10 CFR 50.55(a) Proposed Rule," Industry Codes and Standards" (62 Federal Register 63892 dated December 3.1997)

Dear Sir:

Southern Nuclear Operating Company has reviewed the proposed rule " Industry Codes and Standards," published in the Federal Register on December 3,1997. In accordance with request for comments, Southern Nuclear Operating Company (Southern Nuclear) is in total agreement with the NEI comments which are to be provided to the NRC. Southern Nuclear is also enclosing additional comments.

Respectfully submitted, 1

i

11. L. Sumner '

ills /JDB Enclosure 9804150009 980403 PDR PR 50 62FR63892 PDR

d U. S. Nuclear Regulatory Commission - Page Two I'

cc: Southern Nuclear Ooerating Comnany Mr. R. D. Ilill, General Manager - Plant Farley Mr. P. II. Wells,' General Manager - Plant llatch Mr. J. B. Beasley, General Manager - Vogtle Electric Generating Plant Mr. D. N. Morey, Vice President - Plant Farley Mr. C. K. McCoy, Vice President - Plant Vogtle U. S. Nuclear Regulatory Commission. Washington. DC Mr. J.1. Zimmerman, Licensing Project Manager - Farley Mr. L. N. Olshan, Project Manager - 11atch Mr. D.11. Jaffe, Senior Project Manager _- Vogtle U. S. Nuclear Regulatory Commission. Region 11 ,

Mr. L. A. Reyes', Regional Administrator Mr. T. M. Ross, Senior Resident Inspector - Farley Mr. B. L. IIolbrook, Senior Resident Inspector - Ilatch Mr. J. Zeiler, Senior Resident Inspector - Vogtle i

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L IIL-5602 LCV-1205 l

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O Enclosure Comments on 10 CFR 50.55(a) Proposed Rule," Industry Codes and Standards" The NRC is proposing to amend 10 CFR 50.55(a), which defines the requirements for applying industry codes and standards to nuclear power plants. Below are Souhrn Nuclear's comments.

23.2.5.1 Stroke Time Testing It is unnecessary to make the GL 89-10 and GL 96-05 programs part of the IST programs and thus require them to satisfy the same requirements (e.g., QA, ANil review) as the IST program.

2.4.1 Appendix Vill Implementation of Appendix Vill and all supplements is not possible within a six month time frame and would impose an unnecessary hardship. Further, Southern Nuclear believes that some examinations could not be performed since there has been no performance demonstrations for Supplements 5,7 and 10. With this time constraint, no one would be qualified for specific examinations and it is possible that many units could be forced to shut down because they would r ..eet Section XI ISI requirements.

2.4.1.1.1 Appendix VillPersonnelQualification The Appendix Vil-4240 training requirement of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is adequate instead of the NRC proposed 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.

2.4.1.1.2 Appendix VillSpecimen Set Cracks Southern Nuclear feels that the requirement for not allowing the use of fabrication flaws or notches is impractical. The use of fabrication flaws is essential for the RPV examinations, since these items are commonly detected and sized during normal ISI examinations. Personnel and procedure qualifications would become invalid if these are not allowed to be used in performance demonstrations. Also, the PDI program has utilized notches when it was essential to control the size of the flaw. The cost for the replacement of the samples (approx. $4 million), the time for the vendors to requalify, and whether it would be practical to use cracks only, should dictate the use of fabrication flaws and notches.

2.4.1.13 Appendix VIIISpecimen Set Microstructure The requirement,"that all specimens for single side tests contain microstructures like the components to be inspected and flaws with non-optimum characteristics consistent with field experience that provide realistic challenges to the UT technique." is neither reasonable nor

! practical. No criteria is given on how to determine microstructure in the field.

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Page Two . _ '

10 CFR 50.55(a) ' .

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' 2.4.2 Generic Letter on Appendix Vill The NRC stated that they strongly disagreed that " Appendix Vill and Appendix Vill as , ,

implemented by PDI should be approved as an alternative to the current Code." Presently, members of the PDI committee along with members of the ASME code committee are re-writing

. Appendix Vill.- The NRC should ensure that their review and comments are included in the're-write of Appendix Vill.

, 2.5.2 Section XI (VoluntaryImplementation)

' incorporation of acceptable Code Cases in 50.55(a) is a significant change from the previous methods of endorsing Code Cases (i.e., RG 1.147). Endorsing the use of Code Cases in the rule

- now suggests another mechanism for approval and seems contrary to the previous initiative by the NRC that would result in acceptance of all Code Editions and Addenda and Code Cases 6-'

months after issue. Revising RG 1.147 presently takes too long and using 50.55a to endorse -

Code Cases will cause even longer delays and unnecessary burden on licensees.

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1 2.5.3.3 Subse a ISTD ' ,

50.55a(bX2Xv. would allow Licensees to amend their Technical Specifications and adopt the ASME OM Code, Subsection ISTD, for the visual examination and functional testing of snubbers. Many licensees have adopted the Improved Technical Specifications (ITS), which removed snubber requirements from the Technical Specifications and incorporated them into a 1  : Tecimical Requirement Manual. The rule change should include provisions that would allow Licensees with ITS to adopt ISTD by changing their TRM which is accomplished via a 50.59'

- evaluation, 2.6 ASMECodeInterpretations in light of NRC's involvement with the ASME Code Committees, Southern Nuclear feels that the NRC should be proactive in assuring that the working relationship with the ASME is such that sissued Code interpretati onshave b een approved jointly by the Code Committees and the

? Regulators alike as opposed to including a generic disclaimer in 50.55a.

L i i Additionally,10 CFR 50.55a(bX2Xxv),which is a requirement for Pressurized Water Reactors j

[ only, should reflect the following:

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" Class 1 piping volumetric examination. When performing weld examinatiot ' liigh Pressure i Safety injection Systems, as required by Table IWB-2500-1, Examination Category B-J, item l Numbers B9.20, B9.21, and B9.22, all licensees of pressurizedw' ater reactor facilities shall

. perform volumetric examination of butt weldedfoints in the Class 1 portion of the system after  !

[ insert 6 months from the date of the final rule]." i I

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