ML091540204
| ML091540204 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/29/2009 |
| From: | West R Dominion Resources Services |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 74FR26440 00001, DG-1192, FOIA/PA-2011-0115 | |
| Download: ML091540204 (3) | |
Text
NRCREP Resource From:
Sent:
To:
Cc:
Subject:
Attachments:
Raymond.A.West@dom.com Friday, May 29, 2009 1:25 PM NRCREP Resource Wallace Norris Public Comment on Draft Guide DG-1 192 - Requesting Code Case N-513-3 be Approved for Use Code Case N-513-3 Public Comment.pdf
Dear Sir or Madam:
Attached is my comment letter on DG-1 192.
(See attached file: Code Case N-513-3 Public Comment.pdf)
Ray West Raymond (Ray) A. West Vice Chair, ASME Board on Nuclear Codes & Standards Dominion Resources Services, Inc.
Millstone Power Station Bldg 475/4, Route 156, Rope Ferry Road Waterford, CT 06385 Tele: (860) 447-1791 Ext. 2282 Fax: (860) 440-2140 E-mail: Ravmond.A.West(@dom.com 7$7A ~412~
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U(J CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.
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May 29, 2009 Attn: Rulemaking, Directives, and Editing Branch Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 NrcreP. resourcetanrc.qov
Subject:
Public Comment on Draft Requlatory Guide DG-1 192 - Request for Inclusion of ASME Code Case N-513 (Proposed Revision 16 of Regulatory Guide 1.147, dated October 2007)
Dear Sir or Madam:
This is a public comment submitted on my own behalf as a concerned citizen. Although, I work for a nuclear utility and I am a member of ASME this comment is strictly being submitted as my own opinion and may not necessarily reflect the opinion of ASME or my company.
Table 1 of the current Regulatory Guide 1.147 Rev. 15 and the Proposed Draft Guide DG-1 192, titled; "Table 1. Acceptable Section Xl Code Cases," lists Code Case Number N-513-2, "Evaluation Criteria for Temporary Acceptance of Flaws in Moderate Energy Class 2 or 3 Piping, Section X1, Division 1, date of Supplement/Edition 2/20/04. Thus, this Code Case is fully acceptable to the staff with no conditions required for its use.
Recently, in October 2008, 10 CFR 50.55a was changed to require the use of the 2004 Edition of Section XI as the latest approved and mandated version of Section Xl in 10 CFR 50.55a(b). Within the 2004 Edition of Section Xl, the following requirement exists:
"IWA-2441(b) Code Cases shall be applicable to the Edition and Addenda specified in the Inspection Plan."
For Licensees that have updated their ISI plans to meet the 2004 Edition of Section X1, they are no longer allowed to use Code Case N-513-2. The Code applicability for Code Case N-513-2 is limited to the 2003 Addenda of Section Xl.
To resolve this issue ASME has just recently published Code Case N-513-3 in Supplement 8 of the ASME Nuclear Code Cases Book and this revision now includes applicability up to the 2008 Addenda of Section XI alleviating the applicability issue from the ASME perspective.
However, because Code Case N-513-3 was just recently published by ASME it was not included in the proposed Draft Guide DG-1 192. This letter is a request to expedite the approval of Code Case N-513-3 into DG-1192 and ultimately into Reg. Guide 1.147 Rev.
16.
The first reason to allow this expedited approval of Code Case N-513-3 is to resolve the administrative applicability issue described above. The Code Case regardless of its revision has been proven to be a very valuable tool for the nuclear industry and the NRC Page 1 of 2
f.
in allowing flaws to be evaluated without plant specific and item specific relief requests being required. Use of this Code Case is an example of providing an acceptable alternative, while reducing burden on both the industry and the NRC, and at the same time maintaining an acceptable level of quality and safety as required under 10 CFR 50.55a(a)(3)(i). Additionally, in support of how valuable this Code Case is it currently included in the Regulatory Issue Summary (RIS) 2005-20, Rev. 1, "Revision to NRC Inspection Manual Part 9900 Technical Guidance, "Operability determinations &
Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality and Safety." The reference in this RIS allows the use of the original version of Code Case N-513 and future revisions of this Case as they are approved for use in Reg. Guide 1.147.
Secondly, not only was there an effort to increase the applicability of Code Case N-513-2 with its revision to N-513-3, but it was also revised to clear up some ambiguity in Code Case N-513-2. The documented statement for the revision of Code Case N-513-2 within ASME said, in part, it included:
"The proposed revision to Code Case N-513-2 provides significant clarifications for the user regarding the evaluation of through-wall, nonplanar flaws which is the flaw type most commonly dispositioned by the Code Case. Currently, no guidance is provided for nonplanar flaw combination and the two approaches for the evaluation of through-wall, nonplanar flaws (branch reinforcement and planar characterization) are not entirely clear. More specifically, the current branch reinforcement evaluation approach (based on ASME Section III Class 2 and 3 rules) provides an ambiguous acceptability criterion. The proposed revision to Code Case N-513-2 resolves this issue by specifying the required area of reinforcement be calculated in accordance with Class I rules (acceptance criteria provided in new equation in revision). Also, the depth at which a through-wall, nonplanar flaw is characterized for planar evaluation in both the axial and circumferential directions is made less restrictive in the proposed revision to account for NDE inspection capabilities."
In light of the reasons explained above it is requested with this comment that Code Case N-513-3 be included in DG-1192 and ultimately approved in the latest revision of Reg.
Guide 1.147, Rev. 16. If you have any questions about this comment letter please do not hesitate to contact me at (860) 447-1791 Ext. 2282 or by e-mail at Raymond.A.West(ddom.com.
Sincerely Yours, Raymond (Ray) A. West cc: W.E Norris, USNRC Research Wallace.Norris(anrc.gov Page 2 of 2