ML101241227
| ML101241227 | |
| Person / Time | |
|---|---|
| Issue date: | 05/04/2010 |
| From: | Gurjendra Bedi NRC/NRR/DCI/CPTB |
| To: | Anthony Mcmurtray NRC/NRR/DCI/CPTB |
| Bedi G., NRR/DCI/CPTB, 415-1393 | |
| References | |
| Download: ML101241227 (4) | |
Text
May 4, 2010 MEMORANDUM TO: Anthony C. McMurtray, Chief Component Performance and Testing Branch Division of Component Integrity Office of Nuclear Reactor Regulation FROM: Gurjendra S. Bedi, Mechanical Engineer /RA/
Component Performance and Testing Branch Division of Component Integrity Office of Nuclear Reactor Regulation
SUBJECT:
STAFF EVALUATION AND RESOLUTION OF THE PUBLIC COMMENTS RELATED TO DRAFT REGULATORY ISSUE
SUMMARY
2010-XX, INSERVICE INSPECTION AND TESTING REQUIREMENTS OF DYNAMIC RESTRAINTS (SNUBBERS)
Enclosed is the staff evaluation and resolution of the public and Licensee Action Task Force Task comments received on proposed Generic Communication, Draft Regulatory Issue Summary 2010-XX, Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers), published in the Federal Register (Volume 74, No. 226, Page 61715) on November 25, 2009.
Enclosure:
As Stated Above CONTACT: Gurjendra S. Bedi, NRR/DCI (301) 415-1393
May 4, 2010 MEMORANDUM TO: Anthony C. McMurtray, Chief Component Performance and Testing Branch Division of Component Integrity Office of Nuclear Reactor Regulation FROM: Gurjendra S. Bedi, Mechanical Engineer /RA/
Component Performance and Testing Branch Division of Component Integrity Office of Nuclear Reactor Regulation
SUBJECT:
STAFF EVALUATION AND RESOLUTION OF THE PUBLIC COMMENTS RELATED TO DRAFT REGULATORY ISSUE
SUMMARY
2010-XX, INSERVICE INSPECTION AND TESTING REQUIREMENTS OF DYNAMIC RESTRAINTS (SNUBBERS)
Enclosed is the staff evaluation and resolution of the public and Licensee Action Task Force Task comments received on proposed Generic Communication, Draft Regulatory Issue Summary 2010-XX, Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers), published in the Federal Register (Volume 74, No. 226, Page 61715) on November 25, 2009.
Enclosure:
As Stated Above CONTACT: Gurjendra S. Bedi, NRR/DCI (301) 415-1393 DISTRIBUTION:
DCI R/F RidsNrrDci CSydnor SStuchell ADAMS ACCESSION NO.: ML101241227 OFFICE NRR/DCI/CPTB NAME GBedi DATE 05/4/10 OFFICIAL RECORD COPY
Staff Evaluation and Resolution of the Public and LATF Comments Received on Proposed Generic Communication, Draft Regulatory Issue Summary 2010-xx, Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers) published in the Federal Register Vol.74, No. 226, Page 61715 on November 25, 2009 (74 FR 61715)
No. Commenter Comment Response
- 1. M. J. Ajluni, Please clearly articulate the current regulatory requirements The previous and current regulation at 10 CFR 50.55a(g)(4) requires Southern Nuclear applicable for functional testing of snubbers and its linkage to that Throughout the service life of a boiling or pressurized water-cooled Operating Co, Inc. 10 CFR 50.55a. Describe any changes from previous nuclear power facility, components (including supports) which are regulatory requirements. (ML100540527) classified as ASME Class 1, Class 2, and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the editions of the ASME BPV Code and addenda. ASME Section XI, Article IWF-5000 requires inservice examination and testing of snubbers. Snubbers are supports, therefore, inservice examination and testing of snubbers are required by regulation 10 CFR 50.55a.
10 CFR 50.55a(b)(v) allows the optional use of the Subsection ISTD, Preservice and Inservice Examination and Testing of Dynamic Restraints (snuubers) in Light Water Reactor Nuclear Power Plants, in lieu of the ASME Section XI. This RIS only reminds licensees of the existing regulatory requirements of the inservice examination and testing of snubbers. This RIS does not change or update any regulatory requirements related to inservice examination and testing of snubbers.
- 2. Unknown I dont understand the sentence However, when these RIS paragraph is revised for clarity. Based on the NRC staff findings, (Received from documents represent an alternative to the code requirements the problem is not limited to one or two plants. This RIS does not Martin Murphy via incorporated by reference in 10 CFR 50.55a, they must be provide any new or additional requirements related to the inservice e-mail dated authorized by the NRC. Does this mean that some examination and testing of snubbers. This RIS reminds the licensees January 6, 2010) licensees have changed their snubber ISI code requirements in about the existing regulation 10 CFR 50.55a.
TRM since they think they control the TRM too? To change a TRM, the licensee has to go through 50.59, and all of the other Most licensees are following regulation 10 CFR 50.55a and include regulatory kickouts and considerations (50.54(p), etc.). I did snubbers in their 10-year interval. In 2009, NRC staff noted that some like to see this paragraph clarified. licensees were not following 10 CFR 50.55a for their snubbers inservice examination and testing, while implementing or updating their snubber Are there smoking guns, and I mean plural? RIS mentioned programs or procedures on the 10-year required periodicity. However, several instances. If this is a problem at only one or two the reported problems for snubbers have been limited in numbers and plants, I am not sure that the RIS is the best means for involved minimal safety issues. Most of the failed snubbers have been addressing it. I did use a compliance hammer. corrected or replaced in a timely manner and the nuclear industry has
- 3. Licensees Action (1) Specify, if NRC made any changes to the current snubber maintained good performance with their snubber programs. NRC staff Task Force (LATF) inservice examination and testing requirements as specified in concludes that this RIS, will provide the nuclear industry with an meeting on the current regulation 10 CFR 50.55a via this RIS. opportunity to update their snubber inservice examination and testing January 21, 2010. (2) Are there any licensees who are including snubbers in their programs, as required by 10 CFR 50.55a.
10-year interval?
(3) Industry does not fully agree that snubber testing is required in accordance with 10 CFR 50.55a.
Staff Evaluation and Resolution of the Public and LATF Comments Received on Proposed Generic Communication, Draft Regulatory Issue Summary 2010-xx, Inservice Inspection and Testing Requirements of Dynamic Restraints (Snubbers) published in the Federal Register Vol.74, No. 226, Page 61715 on November 25, 2009 (74 FR 61715)
No. Commenter Comment Response
- 4. Gary Park, This RIS will be outdated when the 2006 Addenda is The regulation 10 CFR 50.55a requires that ASME Section XI, 2004 NextEra Energy incorporated into 10 CFR 50.55a. As in the 2006 Addenda of Edition be used for inservice inspection and testing of snubbers with the LLC ASME Section XI, IWF-5000 was deleted (ML093430233). option to use Subsection ISTD of the ASME OM Code, 2004 Edition.
When 10 CFR 50.55a is updated to incorporate ASME Section XI, 2006 Addenda (which deletes snubber requirements), inservice inspection and testing of snubbers will be per the requirements of ASME OM, Subsection ISTD. Therefore, the requirements as specified in the RIS will never be eliminated or outdated.