Information Notice 1995-09, Use of Inappropriate Guidelines and Criteria for Nuclear Piping and Pipe Support Evaluation and Design

Use of Inappropriate Guidelines and Criteria for Nuclear Piping and Pipe Support Evaluation and Design

ML031060363
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane
Issue date:	01/31/1995
From:	Grimes B Office of Nuclear Reactor Regulation
To:
References
IN-95-009, NUDOCS 9501250429
Download: ML031060363 (7)

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UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C.

20555-0001

January 31, 1995

NRC INFORMATION NOTICE 95-09:

USE OF INAPPROPRIATE GUIDELINES AND CRITERIA

FOR NUCLEAR PIPING AND PIPE SUPPORT EVALUATION

AND DESIGN

Addressees

All holders of operating licenses or construction permits for nuclear power

reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information

notice to alert addressees to the use of guidelines and criteria for nuclear

piping and pipe support evaluation and design in a manner inconsistent with

published NRC staff guidance.

It is expected that recipients will review the

information for applicability to their facilities and consider actions, as

appropriate, to avoid similar problems.

However, suggestions contained in

this information notice are not NRC requirements; therefore, no specific

action or written response is required.

DescriDtion of Circumstances

By letter dated March 28, 1994, the Nuclear Energy Institute (NEI) submitted

several documents prepared by the Electric Power Research Institute (EPRI)

regarding piping and pipe support operability evaluations. These guidance

documents were intended to clarify the guidance in NRC Generic Letter (GL) 91-18, "Information to Licensees Regarding Two NRC Inspection Manual Sections

on Resolution of Degraded and Nonconforming Conditions and on Operability."

Although NEI submitted these documents for information only, a cursory review

by NRC staff indicated that the proposed operability criteria are inconsistent

with the guidance for the NRC staff contained in GL 91-18.

The EPRI documents

recommend the use of criteria that are different than the current endorsed

editions of the American Society of Mechanical Engineers (ASME) Code or other

guidance endorsed by the NRC staff.

Discussion

On November 7, 1991, the NRC issued GL 91-18 to all nuclear power reactor

licensees and applicants to inform them of guidance issued to ensure

consistency by the NRC staff during the review of licensee operability

determinations and resolution of degraded and nonconforming conditions.

Section 6.13, "Piping and Pipe Support Requirements," of the enclosure to

GL 91-18 gives guidance on operability determinations for piping and pipe

supports. This section references the criteria in NRC Inspection and

Enforcement (IE)Bulletins 79-02, "Pipe Support Base Plate Designs Using

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IN 95-09 January 31, 1995 Concrete Expansion Anchor Bolts," and 79-14, "Seismic Analysis for As-Built

Safety-Related Piping Systems," and the applicable revisions and supplements.

To further clarify the guidance in GL 91-18, EPRI prepared documents for

member utilities to use when evaluating piping and pipe support operability.

These documents include:

1. "Piping System Short-Term Operability Criteria," a report of

detailed technical criteria and methods for evaluating the

short-term operability of piping systems;

2. "Guideline for Operability Evaluations of Piping Systems," the

related implementation procedure guideline;

3. "Technical Criteria Report Commentary Short-Term Operability

Criteria for Piping Systems," the companion commentary explaining

the rationale for the detailed criteria; and

4. EPRI Report TR-101968, "Guidelines and Criteria for Nuclear Piping

and Support Evaluation and Design."

These documents were not submitted for a formal NRC staff review and

endorsement.

However, the staff performed a cursory review and concluded that

they contain operability criteria that are inconsistent with the guidance to

the NRC staff in GL 91-18.

For example, EPRI Report TR-101968, Section

5.2.1., "Piping," recommends the use of the higher allowable stresses for

seismic designs included in a draft ASME Section XI Code Case.

These higher

allowable stresses are also contained in a revision to the criteria in Section

III of the ASME Code. These increased allowable stresses have not been

endorsed by the staff. The EPRI report recommends the use of criteria in

Welding Research Council Bulletin 352, which also has not been endorsed by the

staff.

Because the staff has not reviewed the EPRI documents in detail, they

may contain other guidance that is inconsistent with GL 91-18, the ASME Code, or other staff guidance. The staff does not discourage the industry from

developing operability criteria and guidelines for situations that may not be

addressed by GL 91-18.

However, the staff cannot, without formally reviewing

the documents, verify that such guidance, methods, and criteria are consistent

with those previously endorsed by the staff. Therefore, NRC inspectors will

continue to review operability evaluations according to practices, methods and

criteria consistent with GL 91-18 and the current NRC staff-endorsed ASME Code

provisions.

The staff has learned that some EPRI member utilities are applying the EPRI

guidance discussed above. However, these operability criteria may be

inconsistent with previously issued guidance to resolve degraded and

nonconforming conditions. In GL 91-18, the staff discussed the use of the

criteria in Appendix F of Section III of the ASME Code for operability

determinations. Title 10 of the Code of Federal Regulations specifies

editions and addenda of the ASME Code that are formally endorsed by the NRC.

IN 95-09 January 31, 1995 Section 50.55a also incorporates by reference NRC Regulatory Guide 1.84,

"Design and Code Case Acceptability-ASME Section III Division 1," NRC

Regulatory Guide 1.85, "Materials Code Case Acceptability-ASME Section III

Division 1," and NRC Regulatory Guide 1.147, "Inservice Inspection Code Case

Acceptability-ASME Section XI Division 1." These regulatory guides list the

ASME Code Cases that have been determined suitable and are endorsed by the

staff for use by licensees.

The Director of the Office of Nuclear Reactor

Regulation (NRR) may authorize the use of other ASME Code Cases upon request

pursuant to 10 CFR 50.55a(a)(3).

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate NRR pr ect manager.

Brian K. Grimes, irector

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contact: Howard J. Rathbun, NRR

(301) 504-2787 Attachment:

List of Recently Issued NRC Information Notices

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<'Attachment

IN 95-09

January 31, 1995 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information

Date of

Notice No.

Subject

Issuance

Issued to

95-08

95-07

Inaccurate Data Obtained

with Clamp-On Ultrasonic

Flow Measurement Instruments

Radiopharmaceutical Vial

Breakage during Preparation

01/30/95

01/27/95

All holders of OLs or CPs

for nuclear power reactors.

All USNRC medical licensees

authorized to use byproduct

material for diagnostic

procedures.

95-06

Potential Blockage of

Safety-Related Strainers

by Material Brought Inside

Containment

01/25/95

All holders of OLs or CPs

for nuclear power reactors.

95-05

Undervoltage Protection

Relay Settings Out of

Tolerance Due to Test

Equipment Harmonics

01/20/95 All holders

Permits for

reactors.

of Construction

nuclear power

95-04

95-03

95-02

Excessive Cooldown and

Depressurization of the

Reactor Coolant System

Following a Loss of

Offsite Power

Loss of Reactor Coolant

Inventory and Potential

Loss of Emergency Mitiga- tion Functions While in

a Shutdown Condition

Problems with General

Electric CR2940 Contact

Blocks in Medium-Voltage

Circuit Breakers

01/19/95

01/18/95

01/17/95

All holders of OLs or CPs

for nuclear power reactors.

All holders of Ols or CPs

for nuclear power reactors.

All holders of OLs or CPs

for nuclear power reactors.

OL = Operating License

CP = Construction Permit

IN 95-09 January 31, 1995 Section 50.55a also incorporates by reference NRC Regulatory Guide 1.84,

"Design and Code Case Acceptability-ASME Section III Division 1,N NRC

Regulatory Guide 1.85, "Materials Code Case Acceptability-ASME Section III

Division 1," and NRC Regulatory Guide 1.147, "Inservice Inspection Code Case

Acceptability-ASME Section XI Division 1." These regulatory guides list the

ASME Code Cases that have been determined suitable and are endorsed by the

staff for use by licensees. The Director of the Office of Nuclear Reactor

Regulation (NRR) may authorize the use of other ASME Code Cases upon request

pursuant to 10 CFR 50.55a(a)(3).

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate NRR project manager.

Original signed by

Brian K. Grimes

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contact:

Howard J. Rathbun, NRR

(301) 504-2787 Attachment: N

List of Recently Issued NRC Information Notices

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ASME Code cases that have been determined suitable for use by the NRC.

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use of other ASME Code cases upon request pursuant to 10 CFR 50.55a(a)(3).

This information notice requires no specific action or written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate NRR project manager.

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contact:

Howard J. Rathbun, NRR

(301) 504-2787 Attachment:

List of Recently Issued NRC Information Notices

1/3/95 E-MAIL FROM JHCONRAN INDICATED THE IN'S WORDING IS ACCEPTABLE TO HIM.

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Acceptability-ASME Section XI Division 1."

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The

Director of the Office of Nuclear Reactor Regulation (NRR) may authorize the

use of other ASME Code cases upon request pursuant to 10 CFR 50.55a(a)(3).

This information notice requires no specific action or written response.

If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate NRR project manager.

Brian K. Grimes, Director

Division of Project Support

Office of Nuclear Reactor Regulation

Technical contact: Howard J. Rathbun, NRR

(301) 504-2787 Attachment:

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