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Category:Memoranda
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Text
December 14, 2009 Memorandum To: John A. Grobe, Deputy Director for Engineering and Corporate Support Office of Nuclear Reactor Regulation From: Michele G. Evans, Director /RA/
Division of Component Integrity Office of Nuclear Reactor Regulation
Subject:
COMPLETION OF DAVIS-BESSE LESSONS LEARNED TASK FORCE RECOMMENDATION 3.3.4(8)
The purpose of this memorandum is to document the completion of Davis-Besse Lessons Learned Task Force (DBLLTF) Recommendation 3.3.4(8) and the open Stress Corrosion Cracking Action Plan Milestones Part I-3, 6, and 8 and Part II-3 and 7. DBLLTF recommendation 3.3.4(8) states:
The Nuclear Regulatory Commission (NRC) should encourage American Society of Mechanical Engineers (ASME) Code requirement changes for bare metal inspections of nickel based alloy nozzles for which the code does not require the removal of insulation for inspections. The NRC should also encourage ASME Code requirement changes for the conduct of non-visual nondestructive examination (NDE) inspections of vessel head penetration nozzles. Alternatively, the NRC should revise 10 CFR 50.55a to address these areas.
Part I, Reactor Pressure Vessel Head Inspection Requirements, has three open action plan milestones.
Milestone 3 states continue to review future inspection results until permanent guidelines are issued. The staff has continued to review the results of reactor pressure vessel (RPV) head inspections. This was accomplished through Temporary Instruction 2515-150, Reactor Pressure Vessel Head and Vessel Head Penetration Nozzles, October 18, 2002, (ADAMS Accession Number ML022940597), and through review of requests for relaxation from the requirements of Order EA-03-009 and First Revised Order EA-03-009. Permanent inspection guidelines were established through the issuance of ASME Code Case N-729-1, Alternative Examination Requirements for PWR Reactor Vessel Upper Heads With Nozzles Having Pressure-Retaining Partial-Penetration WeldsSection XI, which was incorporated into Title 10 of the Code of Federal Regulations (10 CFR) Paragraph 50.55a. Use of Code Case N-729-1, with staff conditions, became mandatory on December 31, 2008. Code Case N-729-1 addresses inspection requirements for nozzle integrity as well as for potential boric acid corrosion of the reactor pressure vessel upper head.
CONTACT: Edmund J. Sullivan, NRR/DCI (301) 415-2796
J. Grobe Milestone 6 states participate in meetings and establish communications with appropriate stakeholders. This milestone directly relates to DBLLTF recommendation 3.3.4(8). NRC staff participated in meetings of the ASME Code Section XI held on this issue since August 6, 2004, when the Staff Requirements Memorandum was issued on SECY-04-115, Rulemaking Plan to Incorporate First Revised Order EA-03-009 Requirements into 10 CFR 50.55a. The Commission approved Option 3 of the rulemaking plan - evaluate the anticipated ASME reactor pressure vessel inspection requirements for incorporation into 10 CFR 50.55a. Thereafter, NRC staff participated in the development of ASME Code Case N-729 until it was approved by ASME on March 28, 2006. NRC staff participated in working level ASME meetings as well as at the standards committee level meetings where the code case was approved by ASME Section XI.
ASME meetings are open to the public. In addition, the NRC staff discussed conditions placed on this Code Case in 10 CFR 50.55a in detail with industry during these meetings and sent formal letters to Mr. Gary C. Park, Chairman, ASME Subcommittee on Nuclear Inservice Inspection, dated April 26, 2005 (ADAMS Accession Number ML051110358) and to Mr. James H. Riley, NEI, dated August 9, 2006 (ADAMS Accession Number ML062220594).
Milestone 8 states if revised ASME Code requirements are acceptable, establish a schedule to incorporate by reference into 10 CFR 50.55a. This milestone directly relates to DBLLTF recommendation 3.3.4(8). The NRC staff reviewed the adequacy of the requirements of ASME Code Case N-729-1 and determined them to be acceptable for incorporation into 10 CFR 50.55a subject to certain conditions contained in 10 CFR 50.55a(g)(6)(ii)(D). The technical basis was provided in the Federal Register notice for the proposed rule to incorporate ASME Code Case N-729-1 into 10 CFR 50.55a (Volume 72, Number 65, pages 16731 - 16741, April 5, 2007).
Part II - Boric Acid Corrosion has two open action plan milestones.
Milestone 3 states participate in meetings and establish communications with appropriate stakeholders. The NRC staff held public meetings with the Materials Reliability Program (MRP) to discuss inspection for potential reactor coolant pressure boundary (RCPB) sources of boric acid leaks (ML040280157, ML060580073). The staff subsequently requested that ASME Section XI develop inspection requirements to address potential boric acid corrosion by letter from B. W. Sheron to R. L. Gimple dated August 19, 2002 (ADAMS Accession Number ML022200152). The NRC staff participated in meetings of the ASME Code,Section XI, in late 2002, when work began on Code Case N-722, until it was approved by ASME on July 5, 2005.
Milestone 7 states complete and evaluate the results of ongoing research on materials degradation, engage external stakeholders and develop a plan to implement a proactive approach to manage degradation of the RCPB.
The industry has been supporting research on boric acid corrosion since October 2003 through testing programs conducted by the Southwest Research Institute and other investigators.
Testing to date includes evaluation of corrosion of a RPV head in the location of a leaking control rod drive mechanism (CRDM) nozzle. Based on that work, industry expanded the program to include full-scale mockup testing of CRDM nozzles and is planning to perform similar full-scale boric acid corrosion research on reactor vessel bottom mounted instrument nozzles. The NRC staff has attended periodic meetings held by industry to discuss the results of these programs. Evaluation of the results to date supports the adequacy of the inspection
J. Grobe requirements of ASME Code Cases N-729-1 and N-722 for addressing potential boric acid corrosion. The NRC staff will continue to review the results of research on materials degradation and, if appropriate, revise the inspection requirements.
Meetings to engage external stakeholders are discussed under Milestone 3 above. As noted above, the NRC staff pursued its approach to manage boric acid corrosion of the RCPB by requesting ASME Section XI to develop code inspection requirements. In response to the NRC staff request, ASME developed Code Case N-722. The NRC staff reviewed the adequacy of the requirements of Code Case N-722, along with Code Case N-729-1, and determined them to be acceptable to address potential boric acid corrosion. The technical basis was provided in the Federal Register notice for the proposed rule to incorporate ASME Code Cases N-722 and N-729-1 into 10 CFR 50.55a (Volume 72, Number 65, pages 16731 - 16741, April 5, 2007).
The staff implemented regulations to address potential boric acid corrosion by incorporating ASME Code Case N-729-1 and N-722, with limitations, into 10 CFR 50.55a(g)(6)(ii)(D) and 10 CFR 50.55a(g)(6)(ii)(E), respectively. The requirements of 10 CFR 50.55a(g)(6)(ii)(E) became mandatory on October 10, 2008.
Approved: /RA/
John A. Grobe, Deputy Director
ML093510192 OFFICE NRR/DCI NRR/DCI/CPNB NRR/DCI/CPNB NRR/DCI NRR JCollins TChan JTsao for NAME ESullivan MEvans JGrobe (by e-mail)
DATE 12/11/09 12/10/09 12/11/09 12/14/09 12/16/09
