ML14310A289
| ML14310A289 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force |
| Issue date: | 08/07/2014 |
| From: | Jason Huang Division of Engineering |
| To: | |
| M Honcharik, 301-415-1774 | |
| Shared Package | |
| ML14310A286 | List: |
| References | |
| Download: ML14310A289 (6) | |
Text
1 COMPONENT PERFORMANCE, NDE, AND TESTING BRANCH AND REVIEW COMMENTS ON TSTF-545, REV.1 Comment #1 Subsection 2.1, Background of Section 2, DETAILED DESCRIPTION Last sentence of the 1st paragraph on page 2 of the TSTF-545, Rev.1, states that:
10 CFR 50.55a, paragraph (a)(3)(i) allows licensees to request the use of ASME Code Cases that are not referenced in the current version of Regulatory Guide (RG) 1.192.
NRC comment RG 1.192, Rev. 0, Operation and maintenance Code Case Acceptability, ASME OM Code,
was published in June 2003, and in 2004, was incorporated by reference in 10 CFR 50.55a.
The licensees may apply only those Code Cases listed in RG 1.192, Rev. 0 without prior NRC approval subject to certain exceptions specified in 10 CFR 50.55a(b)(6).
NRC is currently reviewing recently published ASME OM Code Cases including Code Case OMN-20. For Code Cases that are found acceptable by NRC, they will be referenced and listed in RG 1.192, Rev.1, which will be subsequently incorporated by reference into 10 CFR 50.55a.
10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements of paragraph (f) may be used, when authorized by the NRC, if the applicant demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Note that 10 CFR 50.55a(a)(3)(i) or (ii) applies to all requests including the use of ASME OM Code Cases that have not yet been incorporated by reference in 10 CFR 50.55a.
Prior to the issuance of RG 1.192, Rev. 1, use of Code Cases not listed in Rev. 0, e.g., Code Case OMN-20, may be requested pursuant to (a)(3)(i) or (a)(3)(ii). Recently, pursuant to (a)(3)(ii), not (a)(3)(i), NRC issued authorization to use OM Code Case OMN-20 for Quad Cities, North Anna and Susquehanna.
After the issuance of RG 1.192, Rev.1, but prior to its incorporation into 10 CFR 50.55a, the licensees may request to use ASME OM Code Case OMN-20 pursuant to (a)(3)(i).
Comment #2 Subsection 2.1, Background of Section 2, DETAILED DESCRIPTION The second paragraph on page 2 of the TSTF-545, Rev.1 states that:
2 The OM Code was developed and is maintained by the ASME OM Committee. The ASME publishes a new edition of the OM Code every three years and a new addendum every year.
The latest editions and addenda of the OM Code that have been approved for use by the NRC are referenced in 10 CFR 50.55a(b). The ASME also publishes OM Code Cases yearly. Code Cases provide alternatives developed and approved by ASME or explain the intent of existing Code requirements.
NRC comment Beginning in 2012, a new edition of the OM Code will be published by ASME OM Committee every two years on even years. New approved or modified Code Cases will be published every two years along with the new edition of the OM Code.
The latest editions and addenda of the OM Code that have been approved for use by the NRC are referenced in 10 CFR 50.55a(b) needs to be clarified as follow:
The latest editions and addenda of the OM Code that have been incorporated by reference in 10 CFR 50.55a(b) are normally not the latest editions and addenda of the OM Code that have been approved and published by ASME.
Comment #3 Subsection 2.2, Proposed Change, of Section 2, DETAILED DESCRIPTION First sentence of the paragraph of Section 2.2 on page 6 of the TSTF-545, Rev. 1 states that:
The proposed change eliminates the Inservice Testing Program from TS Section 5.5.
NRC Comment This paragraph should include a summary or a clear description of the TS changes resulting from the elimination of the IST Program from TS Section 5.5. The TS changes should spell out the removal of the following requirements from the TS 5.5 IST program:
- a. Reference of ASME OM Code and applicable Addenda for IST activities and testing frequencies applicable to the ASME OM Code and applicable Addenda,
- b. Application of the provisions of SR 3.0.2 applicable to the required frequencies and to other normal and accelerated frequencies specifies as 2 years or in the IST program for performing IST activities,
3
- d. TS requirements that conflict with the requirements of 10 CFR 50.55a, i.e., nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.
Comment #4 Subsection 2.2, Proposed Change of Section 2, DETAILED DESCRIPTION The sentence in the middle of the fourth paragraph on page 6 of the TSTF-545, Rev. 1 states that:
Examples of where SR 3.0.2 does not apply are the [Primary] Containment Leakage Rate Testing Program required by 10 CFR 50, Appendix J, and the American Society of Mechanical Engineers (ASME) Code inservice testing required by 10 CFR 50,55a.
NRC Comment Replace the American Society of Mechanical Engineers (ASME) Code inservice testing required by 10 CFR 50,55a. with the IST of pumps and valves in accordance with applicable ASME OM Code as required by10 CFR 50,55a.
Comment #5 Section 3.1, Technical Evaluation of the Proposed Change to the Technical Specification, of Section 3, TECHNICAL EVALUATION; on page 7 of the TSTF-545, Rev.1 NRC comment Section 3.1 should be reorganized into subsections, e.g., 3.1.1, 3.1.2, 3.1.3, and 3.1.4, to address respectively the evaluations and bases for accepting the following TS changes proposed in TSTF-545, Rev.1:
- a. Deletion of the reference of ASME OM Code and applicable Addenda for IST activities and testing frequencies applicable to the ASME OM Code and applicable Addenda,
- b. Deletion of the application of provisions of SR 3.0.2 are applicable to to the required frequencies and to other normal and accelerated frequencies specifies as 2 years or in the IST program for performing IST activities,
- d. Deletion of the TS requirements that conflict with the requirements of 10 CFR 50.55a, i.e., nothing in the ASME OM Code shall be construed to supersede the requirements of any TS.
4 Briefly, the reasons for deletions for a and b above are that they are duplicative of requirements of ASME OM Code and Code Case OMN-20. The reasons for deletions for c and d are that they are contrary to NRC regulatory requirements of 10 CFR 50.55a.
Comment #6 Subsection 3.1, Technical Evaluation of the Proposed Change to the Technical Specification, of Section 3, TECHNICAL EVALUATION of the TSTF-545, Rev.1 The last sentence of the last paragraph under subtitle of The Code case does not address failure to perform an Inservice Test within its required period, on page 8 of the TSTF-545, Rev.
1 states that:
Although SR 3.0.3 will continue to apply to TS LCOs and associated surveillance requirements that reference the IST Program, the SR 3.0.3 allowance will not apply to non-TS inservice testing requirements.
NRC Comment The provisions of SR 3.0.3 cannot be applied to all IST program components even if they are TS SR associated because they do not apply to missed 10 CFR 50.55a(f) tests. As stated in EGM 12-001, failure to either perform or meet an inservice test program for tests associated with 10 CFR 50.55a(f) results in nonconformance with the OM Code requirements and should be resolved as discussed in RIS 2005-20, Revision 1.
Comment #7 Section 4.1, Applicable Regulatory Requirements/Criteria, of Section 4, REGULATORY EVALUATION OF THE PROPOSED TS CHANGE of the TSTF-545, Rev.1 Last two sentences of the first paragraph of Section 4.1 on pages 10 and 11 of the TSTF-545, Rev. 1 states that:
10 CFR 50.55a, paragraph (a)(3)(i) allows licensees to request the use of the ASME Code Cases that are not referenced in current version of Regulatory Guide 1.192. The use of the approved ASMEOM Code Case OMN-20 is consistent with this regulation.
NRC Comment 10 CFR 50.55a, paragraph (a)(3)(i) allows licensees to submit alternative request including the use of the ASME Code Cases that are not referenced in current version of Regulatory Guide 1.192. The use of the approved ASME OM Code Case, e.g., OMN-20, may fall into three categories:
5 The First Category, The Code Case was approved by NRC and referenced in RG 1.192, and the RG 1.192 was later incorporated by reference in 10 CFR 50.55a. RG 1.192, Rev.0 was published in June 2003, and incorporated by reference in 2004 in 10 CFR 50.55a. Licensees are allowed to apply those Code Cases listed in RG 1.192, Rev. 0 without prior NRC approval. OR However, for certain Code Cases, (e.g., Code Case OMN-20) that are made available as an interim condition in 10 CFR 50.55a, the licensees are also allowed to apply them without prior NRC approval.
The Second Category, The Code Case was approved by NRC and referenced in a published version of RG 1.192, but this published version has not been incorporated by reference into 10 CFR 50.55a. Pursuant to 10 CFR 50.55a(a)(3)(i), licensees may request to use the Code Case as an acceptable alternative to the OM Code requirements.
The Third Category, The Code Case has not been approved and referenced in a published version of RG 1.192.
Pursuant to 10 CFR 50.55a(a)(3)(i), or (a)(3)(ii), the licensees may also propose to use the Code Case if the licensee can demonstrate that the proposed alternative provide an acceptable level of quality or compliance would result in hardship or unusual difficulty without compensating increase in the level of quality or safety.
Code Case OMN-20 is currently in the third Category, and the proposed use of Code Case OMN-20 has been authorized by NRC in accordance with 10 CFR 50.55a(a)(3)(ii), not (a)(3)(i).
Comment #8 Section 4.1, Applicable Regulatory Requirements/Criteria, of Section 4, REGULATORY EVALUATION OF THE PROPOSED TS CHANGE; of the TSTF-545, Rev.1 The last two sentences of first paragraph on pages10 and 11 of Section 4.1 states that:
10 CFR 50.55a, paragraph (a)(3)(i) allows licensees to request the use of ASME Code Cases that are not referenced in the current version of Regulatory Guide 1.192. The use of the approved ASME OM Code Case OMN-20 is consistent with these regulations.
NRC Comment
6 Use of Code Case OMN-20 as an alternative to the OM Code has been authorized by NRC pursuant to 10 CFR 50.55a(a)(3)(ii) for Quad Cities, North Anna, and Susquehanna. Quad Cities was referenced in the precedents section of this Attachment.
Pursuant 10 CFR 50.55a(a)(3)(ii), not (a)(3)(i), NRC has authorized the use of OMN-20 for Quad Cities in a letter dated February 14, 2013 (ML13042A348), and for North Anna in a letter dated March 27, 2014 (ML14084A407). The alternative request submittal for North Anna is an updated version for requesting the use of Code Case OMN-20, and therefore, should be used as a model alternative request. Reference of the Quad Cities should be replaced by North Anna in the precedents section..