LR-N980149, Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis

Comment on Proposed Rule 10CFR50 Re Industry Codes & Stds. Comments Address Use of Engineering Judgment,Limitations on Use of Later ASME III Code Editions for Weld Leg Dimensions & Seismic Analysis

ML20217K684
Person / Time
Site:	Salem, Hope Creek
Issue date:	03/30/1998
From:	Dawn Powell Public Service Enterprise Group
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR63892, RULE-PR-50 62FR63892-00031, 62FR63892-31, LR-N980149, NUDOCS 9804070288
Download: ML20217K684 (5)

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. O PSEG 00CKETED Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit MAR 3 01998 c Or_

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i U.S. Nuclear Regulatory Commission Secretary Washington, DC 20555 DOCKETNUMBER os Attn: Rulemaking and Ajudications Staff PROPOSED RULE rn 60 ,

COMMENTS ON NRC PROPOSED CHANGES TO 10 CFR 50.55a SALEM AND HOPE CREEK GENERATING STATIONS 3/

DOCKET NOS. 50-272, 50-311 AND 50-354

Dear Sir:

Enclosed are the Public Service Electric & Gas (PSE&G) comments on the proposed' rule changes to 10 CFR 50.55a, Industry Codes and Standards. The comments address the use of Engineering Judgment, limitations on the use af later ASME III Code editions for weld leg dimensions and seismic analysis, use of ASME published code interpretations, use of NOA-1 and the six month accelerated implementation of ASME XI Appendix VIII with the proposed limitations on examination specimens.

If you have any questions or require additional information, please' contact Mr. Dennis V. Hassler at (609) 339-1989 Sincerely,

, o i I ctu uf l D. R. Powell Director - /

Licensing / Regulation and Fuels Attachment 9804070288 980330 PDR PR

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I MAR 30.mgg Secretary - NRC 2 LR-N980149 C Mr. H. J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Mr. R. Ennis, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 14E21 11555 Rockville Pike Rockville, MD 20852 Ms. M. Evans (X24)

USNRC Senior Resident Inspector - Salem Mr. S. Morris (X24)

USNRC Senior Resident Inspector - Hope Creek Mr. K. Tosch, Manager IV, Bureau of Nuclear Engineering PO Box 415 Trenton, NJ 08625 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 David J. Modeen Director, Engineering Nuclear Generation NEI Suite 400 1776 I Street, NW Washington, DC 20006-3708 i

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r LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A 1

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1. The proposed change that requires a Licensee to seek formal NRC approval when employing " Engineering Judgment" for every activity or evaluation that is not directly addressed by the ASME Code (i.e., ASME Section III or Section XI) is unreasonable. The Code intrinsically relies on the professional judgment of an engineer, based upon his knowledge, education and experience to apply the requirements of the Code in day-to-day situations.

Imposing regulation that mandates the attainment of formal NRC acceptance for engineering judgments that are essential in using the ASME Code, effectively stops activities in areas where the ASME Code has jurisdiction. The impacts of requestinc NRC approval for Engineering Judgments are potential schedule delays, additional burden on the NRC and Licensee staffs, as well as additional costs.

2. ASME Section XI requires that technical provisions (e . g . , design, fabrication, ?xamination, etc.) be reconciled when employing the use of later editions / addenda of the ASME Code (s). The reconciliation of technical Code requirements can be analytically resolved (e.g., load combinations, fatigue usage factors, allowable stresses, etc.); however, to impose Rulemaking which mandates reconciling administrative requirements (i.e., N Stamping, Authorized Inspection Agency involvement, Code Data Reports, etc.)

which is noted in the proposed rule as " Owner's Requirements" places the Owner in a situation where such decisions require subjective engineering judgment. Under the proposed rule, this would require NRC approval and would add a large administrative burden to utility and NRC resources. Administrative requirements do not directly contribute to the structural integrity, functional reliability or inherent safety margins of components or systems.

Expenditure of utility and NRC resources to address non-safety significant administrative matters is inappropriate and distracts efforts that should be focused on nuclear safety.

3. In the Summary of Proposed Revision to 50.55a, the NRC discusses proposed limitations on the use of ASME published interpretations.

However, the proposed rule does not contain information on the use of ASME published interpretations. The proposed rule is silent on this issue and creates a situation that is impracticable. Since the NRC has no formal mechanism to specifically identify which ASME interpretations are perceived as being in conflict with NRC "

regulation, it will be difficult enough for a Licensee to meet this propose'd rule. However, since the 10 CFR 50.55a Rule only applies 1

6 LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A to Licensees and Construction Permit Holders, the application of an ,

ASME interpretation by an ASME Certificate Holder, during the construction of'a component, will not be subject to this Rulemaking limitations. The use of an ASME interpretation by an ASME Certificate Holder is not required to be captured or documented in design or construction records. Consequently, additional controls i will need to be established to validate whether an ASME interpretation was utilized by a Certificate Holder to construct a replacement component for the Licensee use. These additional i controls will result in additional time and cost considerations for the Licensee without a defined benefit.

4. The proposed Rulemaking's limitation on the use of NOA-1, suggests that NOA-1 does not satisfy l'0 CFR 50 Appendix B Quality Assurance requirements. This condition will create procurement constraints throughout the industry. ASME Certificate Holders are obligated to meet the latest published Code for QA Program provisions (e.g.,

ASME Section III), under ASME Accreditation requirements, even though that Certificate Holder uses earlier versions of ASME Section III, approved for use by the NRC through 10 CFR 50.55 (a), l to construct items for a specific Licensee. Therefore, at the present time, an ASME Certificate Holder is already authorized to use NQA-1 provisions that the Rulemakir' suggests may not be acceptable.

Certificate Holders are not lawfully obligated to meet 10 CFR 50.55(a) limitations, since these rules apply only to Licensees and Construction Permit Holders. Consequently, to procure a replacement item or a safety related service from an ASME Certificate Holder will result in the Licensee imposing additional 10 CFR 50 Appendix B provisions on future procurements in order to meet the proposed regulations and satisfy Appendix B QA requirements. While this is possible, many ASME Certificate Holder QA Programs are presently qualified through efforts such as Nuclear Utility Procurement Committee (NUPIC). If the proposed Rulemaking i is' implemented as written, there is the potential that ASME  :

accredited organizations that are presently presumed to be qualified, will require individual Licensees to review all.present l and near.past procurements to determine if an ASME Certificate l Holders' QA Program has been deemed as unacceptable, due to the limitations created by the Rulemaking. These reviews will result in i additional time and cost considerations for the Licensee without a  ;

l defined benefit.

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6 LR-N980149 ATTACHMENT 1 PSE&G COMMENTS ON PROPOSED CHANGES TO 10 CFR 50.55A

5. The six month accelerated implementation of ASME Section XI and Appendix'VIII provisions, along with the proposed rule limitations to employ cracks and replicate micro-structure in test specimens will create severe hardships for the industry and specifically PSE&G. Only a small number of vendors / personnel currently meet the Appendix VIII criteria, and not all UT techniques governed by these Appendices have been qualified to date. Further, the proposed limitation to use actual cracks and replicate microstructure in test specimens will effectively reduce or eliminate many of the vendors / personnel presently qualified.

The lack of available qualified resources to perform UT examinations will result in ISI outage examination (s) delays. If the proposed rule is implemented as it is written, including the accelerated six month schedule for compliance, there will likely be no personnel qualified to perform the ISI UT examinations of the Hope Creek Core Reactor dissimilar welds which are scheduled to be performed during 1999 Hope Creek refueling outage. To avoid outage impacts, exemptions will be required which will impact NRC and Licensee staffs.

6. The proposed Rulemaking limitations to use the 1989 Edition of ASME Section III requirements for weld leg dimensions and seismic design (i.e., reversing dynamic loads), even though the remainder of the proposed rule will adopt up to the 1996 Addenda of ASME Section III is not consistent with the intent of the Code which is intended to be utilized as a complete set of requirements contained within one edition or addenda. The use of mixed versions of ASME Section III, that the rule mandates, promotes a poor practice in applying the Code, sometimes referred to as " cherry picking.

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