ML19262A426
| ML19262A426 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/17/1976 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19262A419 | List: |
| References | |
| NUDOCS 7910290517 | |
| Download: ML19262A426 (6) | |
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EllCLOSURE 1 IIRC ST AFF GUIDA!!CE FOR C0itPLYIt!G HITH CERTAItt PROVISIO!1S OF 10 CFR 50.55a(a) "It! SERVICE I!1SPECTI0t1 RE0UIREfiE!!TS" 1.
INTRODUCTIO!!
Paragraph 50.55a(g) of 10 CFR Part 50 was revised on February 12, 1976 (41 FR 6256). Since then, a number of licensees have requested that the !!RC clarify several key previsions contained in the revised regulation.
These key provisions relate to:
(1) the require:nents to periodically update the inservice and testing programs to ccmply with later editions and addenda to the AS1E Code, (2) the requirement to confonn the Technical Specifications to a reviscj inservice inspection or testing program, and (3) the prccedures fo requesting and ootaining relief frca AS:iE Code requirements that t: a licensee considers to be impractical for his facility.
The purpose of this document is to briefly sucmarize the major provisions of the revised 550.55a(g) and to provide general guidance in these three key areas.
The document is in no way intended to encompass all aspects of attaining compliance with 550.55a(g).
II.
SUltt1ARY OF REGULATI0tl The revised 550.55a(g) contains provisions that require inservice inspec-tion and testing of AS!E Code Class 1, 2, and 3 nuclear power 01 ant ccm-ponents (including supports) to be cerfomed in accordance with Section XI of the ASME Boiler & Pressure Vessel. Code and aoplicable Addenda.
For operating facilities whose Ooerating' License (OL) was issued before March 1,1976, these provisions of the regulation apply at the start of the next regular 40-month inspection period af ter September 1,1976.
The start of the next 40-month period is determined by measuring a series of such periods beginning at the start of facility cccmercial coeration.
For facilities that received OL's on or after flarch 1,1976, these provisions of the regulation apply at the start of ccmmercial operation.
As a result of the February 1976 amendment, !50.55a(g) now specifies inservice inspection and testing requirements for all ocerating plants, including those that received a Construction Permit (CP) before January 1, 19'/1. Since plant designs and access provisions for inservice inspections have progressed over the years, the regulation provides recognition of this fact by grouping design requirements for component inspectability based on a facility's CP issuance date.
The regulation f >rther specifies that new inservice inspection
.1d testing requirements th tt beccme effec-tive in later editions and addt. Ma to the ASitE Code, shal' apply to all plants to the degree practical s cughout their service li'es.
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An important part of the revised 550.55a(g) is the incorporation of the ASME Code Setion XI requirements for testing pumps and valves for o:: era-This tional readiness along with the inservice inspection recuirements.
means that in adcition to a facility's inservice insection program, a periodic testing program of selected pumps and valves must also be instituted There are now provisions in 550.55a(g) for continued updating of requirements for testing pumps and valves and for inservice inspection. The inservice inspection program must be updated every 40 nonths while the pump and valve testing program must be upcated every 20 months. Furthemore, the regulation specifies action to be taken by a licensee when an updated inservice inscec-tion or testing program conflicts with the Technical Specifcations, or when a requirenent contained in a referenced AS!!E Code Edition or Addendum is deemed impractical by the licensee due to design, geccetry, or material considerations.
Other provisions in 550.55a(g) allow the flRC to grant relief frca AS!1E Code requirements that have been detemined to be impractical for a facility and specifically allow the ilRC to recuire a licensee to follow an augmented inservice inspection program on components for which added assurance of structural reliability is needec.
Selected provisions of the revised regulation are d:scussed belcw.
III.
General Guidance for Compliance wi'th Three Key Provisions of 50. 55a( g):
A.
Updating Inservice Insoection and Testino Programs
Paragraon 50.e5a t a )(4 ):
The inse vice inspection program for a facility must be updated at 40 conth ii. 4rvals, while the program for testing pumps and valves for operatioi.1 readiness must be updated every 20 months. A descri:tien of the upMed programs should be submitted to the IIRC for review and approval as ra.- in advance as possible of, but at least 90 days before, the start of each period.
The infor,1ation the !!RC will need for its review of updated prograns is identified in Appendix A (attached).
Under 550.55(g)(4), the revised inservice inspection and testing programs must, to the extent practical, comply wi th the reouirements in editions and addenda to the ASME Code that are "in effect" no rcre than 6 months before the start of the period for which the uod3ted program is applicaH e.
The tems "in ef fect" or " effective", as used in 550.55a(g)(4), identify those editions and addenda to the ASME Code that have been published by the ASi1E and that are also referenced in paragraph (b) of 150.55a.
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s Paragraph (b) of 550.55a is amended periodically to incorporate more recent AS!jE Code Editions and Addenda.
However, the regulations are not amended until after the published ASME Code Editions and Addenda have been reviewed and endorsed by the HRC.
Therefore, the ASME Code Edition and Addenda tnat are applicable to any inspection. period are those referenced in paragraph (b) of 550.55a on the date that corresponds to 6 months before the start of the period in question.
If amendments to paragraph (b) of 550.55a becone effective on a date that falls between the date that marks 6.onths before the start of a inspection period and the start date itself, the licensee is not required to cenply with the newly referenced ASME Code Editions and Addenda.
Under the regu-lation, the licensee need only ccmply with the ASME Code Editions and Addenda that were referenced in paragraph (b) of 150.55a 6 months befcre the start of the period in question.
On the other hand, the regulation does not preclude compliance with the later referenced editions and addenca if the licens?e chooses, but the document that describes each new inservice inspection or testing program should state which ASME Code Edition and Addenda will be us.ed.
An inservice inspection or testing program does not comply with 550.55a(g)(4) if it is based on an ASME Code Edition or Addendum which is not or has not been referenced in paragraph (b) of 550.55a.
B.
Conforning the Technical Snecifications to an Uodated Inservico Inscection or Testing Program ----- Paragrann 50.55a(c)(5)tii):_
If a revised (updated) inservice inspection or testi'ng pregram conflicts with the Techni:al Specifications for a facility, the licensee must prep;se changes to the Technical Specifications to confom then to the updated pec-This mus; be done at least 6 months before the start of the perioc gram.
in which the program becomes applicable.
Technical Specifications are considered to be "in conflict" only in cases where the requirements of the regulation (thus the requiremer.ts of the updated program) are more restrictive than the requirenents of the Tech-nical Specifications.
In such cases the licensee must prepose changes to conform the Technical Specifications to the revised program.
In cases where the updated progan is less restrictive than a particular Technical Scecifi-cation requirement, the licensee must continue to ccmply with the Technical Specifications until he requests and is issued a Technical Specificacion change. The NRC staff will review such a proposed technical Specification change to detemine if it is acceptable or whether the existing reqire-ment should be retained as an augmented requirement pursuant to 550. 55a( g) (6 )(ii).
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e In the flRC Staff's view, the most efficient way to eliminate existing or potential conflicts from the Technical Specifications is for licensees to propose Technical Specification changes that would suostitute standarc language referencing 50.55a(g) f r. tr# place of existinq inservice inspection and te:. ting requirenents.
?iis should be done at least 6 months before the start of the first 40-month inspection period for which 50.55a(g) is applicabie.
Sample language for this purpose was sent to licensees earlier t. is year.
The 11RC strongly recommends that licensees adopt the approach of referenc-ing 50.55a(g), because such referencing will sinolify the Technical Specifications by deleting any recuirements that are duplicated in the regulation.
It will also alleviate the need for changes whenever an inservice inspection or testing program is updated.
This approach has the added advantage of eliminating the scheduling pressures associated with neeting the 6 months submittal tice requirement for Technical Spec-ification changes proposals.of 50.55a(g)(2)(ii).
It will also sinplify the process by which licensees request, and the 11RC grants, relief from ASi1E Code requirements that have been determined to be impractical.
This is because license amendments (i.e., Technical Specification changes) will not be necessary to grant relief.
Relief from ASME Code requirements that are deemed impractical for a facility is further discussed below.
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C.
Obtainino Relief from ASl'E Code Renuirenents Determined to be Innractical -----
Paragrann 50.55a(c)(5)(iii) and (o)(i):
If certain ASME Code requirements are found to be inpractical by the licensee, the regulation requires him to notify the NRC and submit information to succort his findings.
The licensee should suonit requests for relief from ASME Code requirements tnat he has determined to be impractical at lent 00 days before the start of the applicable inspection period.
The information that is neeced by the 11RC Staff to evaluate requests for relief from requirements found to be inpractical is identified in Appendix B (attached).
The !!RC Staff will evaluate licensee requests for relief and will grant relief, if appropriate, pursuant to 50.55a(g)(6)(i). Unless a licensee is otherwise notified by the flRC, relief frc, ASME Code requirements will remain aoplicable until the end of each 120-month period.
At that time, the MRC will re-evaluate the basis for the determination that the recuirement is imoractical, pursuant to 50.55a(g)(5)(iv).
This re-evaluation will take into account any advances in the state-of-the-art of inservice inspection techniques that may have occurred since the relief was originally granted.
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Generally, the licensee will know well in advance of the beginning of any inspection period, whether or not a particular AS1E Code requirement will be impractical for his facility.
Thus, the licensee should request relief from ASME Code requirements as far as possible in advance of, but not less than 90 days before, the start of the inspection period.
Early submittals are particularly important for the first 40-month inservice inspection and 20-month pump and valve testing period because they will enable the 11RC staff to evaluate the information received from all licensees and determine which ADIE Code requirements may be generally impractical for various classes of plants.
Early submittals will thereby facilitate earlier feedback to licensees regarding the acceptability of their requests.
The !!RC Staff recognizes that it will not be possible in all cases for a licensee to detemine in advance that any particular ASME Code recuire-ment will be impractical for his facility.
In cases where, during the process of inspection of testing, certain requirements are found to be impractical due to unforseen circumstances, the licensee may request relief at that time.
These occurrences are not expected to be many and are expectec to result in only minor changes to an inservice inspection or testing progra7.
All relief from A5i1E Code requirements that are determined to be impractical for a facility will be granted in the fom of a. etter within the provisions l
of 550.55a(g)(6)(i). This written relief should be incorporated into the document describing the inservice inspection and testing progran retained by.the licensee.
- iotice of the granting of relief from ASME Code recuire-
,__. ments will. be published in the FEDERAL REGISTER, but the written relief...
___..itself will not become an explicit part of the facility. license or the Technical Specifications.
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APPENDIX A INFORi% TION REOUIRED FOR NRC REVIEW OF INSERVICE INSPECTION AND TESTING PROGRAMS
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Inservice Inspection Programs:
The information submitted for NRC review should include *, as a minimum:
Identification of the applicable ASME Boiler and Pressure Vessel a.
Code Edition and Addenda b.
The pa-iod for which the program is applicable Identification of all of the specific components and parts to be c.
examined for each ASME Code Class (i.e., each Quality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water, Steam
, and Radioactive-Maste-Containing Ccaponents of Nuclear Power Plants"), and the inspection intervals for each Class or Quality Group d.
For each specific component and part; specification of:
i) The examination category as defined in ASME Section XI
- 11) The examination method to be used 111) The repair requirements 2.
Pump and Valve Testing Programs The information submitted for NRC review should include *, as a minimum:
Identification of the applicable ASME Code Edition and Addenda a.
b.
The period for which the program is applicable c.
For Pump Testing: identi fy:
i) each pump to be tested (name and nund;r) ii) the test parameters that will be measured iii) the test intervals, i.e., monthly during operation, only during cold shutdown, etc,
- Specific written relief from the NRC is required to exclude any ASME Section XI Code requirements, 1484 159
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