ML19308B006
| ML19308B006 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 11/30/1976 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
| ML19308B004 | List: |
| References | |
| NUDOCS 7912120764 | |
| Download: ML19308B006 (8) | |
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ENCLOSURE 1 NRC STAFF GUIDANCE FOR COMPLYING WITH CERTAIN PROVISIONS OF 10 CFR 50.55a(g) " INSERVICE _ INSPECTION RE0VIREMENTS" I.
INTRODUCTION 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 HRC clarify several key provisions contained in the revised regulation.
These key provisions relate to:
(1) the requirements to periodically update the inservice and testing programs to comply with later editions and addenda to the ASME Code, (2) the requirement to confom the Technical Specifications to a revised inservice inspection or testing program, and (3) the procedures for requesting and obtaining relief from ASME Code requirements that the licensee considers to be impractical for his facility. The purpose of this document is to briefly summarize 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.
SUMMARY
OF REGULATION The revised 150.55a(g) contains provisions that require inservice inspec-tion and testing of ASME Code Class 1, 2, and 3 nuclear power plant con-ponents (including supports) to be perfomed in accordance with Section XI of the ASME Boiler & Pressure Vessel Code and applicable Addenda. For operating #acilities whose Operating License (OL) was issued before tiarch 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 detemined by measuring a series of such periods beginning at the start of facility commercial operation. For facilities that received OL's on or after March 1,1976, these provisions of the regulation apply at the start of commercial operation.
As a result of the February 1976 amendment, 550.55a(g) now specifies inservice inspection and testing requirements for all operating plants, including those that received a Construction Pemit (CP) before January 1, 1971. 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 further specifies that new inservice inspection and testing requirements that become effec-tive in later editions and addenda to the ASME Code, shall apply to all plants to the degree practical throughout the,1r sery;ce lives.
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. An important part of the revised 50.55a(g) is the incorporation of the ASME Code Section XI requirenents for testing pumps and valves for opera-tional readiness along with the inservice inspe'. tion requirements. This means that in addition 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 150.55a(g) for continued updating of requirements for testing pumps and valves and for inservice inspection. The inservice inspection program must be updated every 40 months while the pump and valve testing program must be updated every 20 months. Furthemore, the regulation specifies action to be taken by a licensee when an updated inservice inspec-tion or testing program conflicts with the Technical Specifcations, or when a requirement contained in a referenced ASME Code Edition or Addendum is deemed impractical by the licensee due to design, gecmetry, or material considerations.
Other provisions in 550.55a(g) allow the NRC to grant relief fro,n ASME Code requirements that have been determined to be impractical for a facility and specifically allow the NRC to require a licensee to follow an augmented inservice inspection program on components for which added assurance of structural reliability is needed.
Selected provisions of the revised regulation are discussed below.
III. Geneol Guidance for Compliance with Three Key Provisions of 550.55a(g):
A.
Updating Inservice Inspection and Testing Programs
Paragrapn 50.55a( g)(4 ):
The freervice inspection program for a facility must be updated at 40 month intervals, while the program for testing pumps and valves for operational readiness must be updated every 20 months. A description of the updated programs should be submitted to the !RC for review and approval as far in advance as possible of, but at least 90 days before, the start of each period. The infomation the NRC will need for its review of updated programs is identified in Appendix A (attached).
Under 150.55(g)(4), the revised inservice inspection and testing programs must, to the extent practical, comply with the requirements in editions and addenda to the ASME Code that are "in effect" no more than 6 months before the start of the period for which the updated program is applicable. The tems "in effect" or " effective", as used in ISO.55a(g)(4), identify those editions and addenda to the ASME Code that have been published by the ASME and that are also eferenced in paragraph (b) of 150.55a.
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. Paragraph (b) of 150.55a is auended periodically to incorporate more recent ASME 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 NRC. Therefore, the ASME Code Edition and Addenda that are applicable to any inspection period are these referenced in paragraph (b) of 150.55a on the date that corresponds to 6 months before the start of the period in question.
If amendments to paragraph (b) of 150.55a become ef fective on a date that falls between the date that marks 6 months before the start of a inspection period and the start date itself, the licensee is not required to comply with the newly referenced ASME Code Editions and Addenda. Under the regu-lation, the licensee need only comply with the ASME Code Editions and Addenda that were referenced in paragraph (3) of 150.55a 6 months before the start of the period in question. On the other hand, the regulation does not preclude compliance with the later referenced editions and addenda if the licensee chooses, but the document that describes each new inservice inspection or testing program should state which ASME Code Edition and Addenda will be used.
An inservice inspection or testing program does not comply with 550.55a(g)(4) if it is based on an AS4E Code Edition or Addendum which is not or has not been referenced in paragraph (b) of 150.55a.
B.
Conforming the Technical Specifications to an Updated Inservice Insoection or Testing Program ----- Paragraph 50.55a(g)(5)(ii):
If a revised (updated) inservice inspection or testing program conflicts with the Technical Specifications for a facility, the licensee must propose changes to the Technical Specifications to conform them to the updated pro-gram. This must be done at least 6 months before the start of the period 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 requirements of the updated program) are more restrictive than the requirements of the Tech-nical Specifications.
In such cases the licensee must propose changes to conform the Technical Specifications to the revised program.
In cases where the updated progam is less restrictive than a particular Technical Specifi-cation requirement, the licensee must continue to comply with the Technical Specifications until he requests and is issued a Technical Specification change. The NRC staff will review such a proposed technical Specification change to detemine if it is acceptable or whether the existing reqire-1 ment should be retained as an augmented requirement pursuant to 150. 55a( g)(6 )( fi).
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. In the NRC 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 substitute standard language referencing 150.55a(g) in the place of existing inservice inspection and testing requi enents. This should be done at least 6 months before the start of '5e first 40-month inspection period for which 150.55a(g) is applicable. Sample language for this purpose was sent to licensees earlier this year.
The NRC strongly recommends that licensees adopt the approach of referenc-i'ng 550.55a(g), because such referencing will simplify the Technical Specifications by deleting any requirements that are duplicated in the regul ation.
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 wi th meeting the 6 months submittal time requirement for Technical Spec-ification changes proposals of 50.55a(g)(2)(fi).
It will also simplify the process by which licensees request, and the NRC grants, relief from ASME 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.
C.
Obtaining Relief from ASME Code Reouirements Determined to be Imoractical -----
Paragraph 50.55a(g)(5)(iii) and (6)(1):
If certain ASME Code requirements are found to be impractical by the licensee, the regulation requires him to notify the NRC and submit information to support his findings. The licensee should submit reauests for relief from ASME Code requirements that he has determined to be impractical at least 90 days before the start of the applicable inspection period. The information that is needed by the NRC Staff to evaluate requests for relief from requirements found to be impractical is identified in Appendix B (attached).
The NRC Staff will evaluate licensee requests for relief and will grant relief, if appropriate, pursuant to 150.55a(g)(6)(i). Unless a licensee is otherwise notified by the NRC, relief from ASME Code requirements will remain applicable until the end of each 120-month period. At that time, the NRC will re-evaluate the basis for the determination that the reouirement is impractical, pursuant to 150.55a(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 licer.see will know well in advance of the beginning of any inspection period, whether or not a particular ASME Code requirement will be impractical for his facility. Thus, the licensee should request relief frcm ASME Code requirements as far as possible in advance of, but not less than 90 days before, the start of the inspection period. Early suomittals are particularly important for the first 40-month inservice inspection and 20-month pump and valve testing period because they will enable the NRC staff to evaluate the information received from all licensees and determine which ASME 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 NRC Staff recognizes that it will not be possible in all cases for a licensee to detennine in advance that any particular ASME Code require-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 expected to result in only minor changes to an inservice inspection or testing program.
All relief from ASME Code requirements that are determined to be impractical for a facility will be granted in the form of a letter within the provisions of 150.55a( g)(6)(i). This written relief should be incorporated into the document describing the inservice inspection and testing program retained by the licensee. Notice of the granting of relief from ASME Code te. quire-ments will be published in the FEDERAL REGISTFR., 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 INFORMATION REOUIRED FOR NRC REVIEW OF INSERVICE INSPECTION AND TESTING PROGRAMS 1.
Inservice Inspection Programs:
The infccmation submitted for NRC review should include *, as a minimum:
a.
Identification of the applicable ASME Boiler and Pressure Vessel Code Edition and Addenda b.
The period for which the program is applicable c.
Identification of all of the specific components and parts to be examined for each ASME Code Class (i.e., each Quality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Wa.ter, Steam, and Radioactive-%aste-Containing Components of Nuclear Power Plants"), and the inspection intervals for each Class or Quality Group d.
For each specific component and part; specification of:
- 1) The examination category as defined in ASME Section XI
- 11) The examination method to be used iii) The repair requirements 2.
Pump and Valve Testing Programs The information submitted for NRC review should include *, as a minimum:
a.
Identification of the applicable ASME Code Edition and Addenda b.
The period for which the program is applicable c.
For Pump Testing: identify:
i) each pump to be tested (name and number) it) the test parameters that will be measured iii) the test intervals, i.e., monthly during. operation, only durirg cold shutdown, etc,
- Specific written relief fran the NRC is recuired to exclude any2A91E Section XI Code requirements.
- d.
For Valve Testing; identify:
i) each valve in ASME Section XI Categories A & B that will be exercised every 3 months during normal plant operation (indicate whether partial or full stroke exercise).
- 11) each va~ e in ASME Section XI Category A that will be leak tested during r2 fueling outages.
iii) all valves in ASME Section XI Categories C, D, and E, that will be tested, the type of test and the test frequency. For check valves, identify those that will be exercised every 3 months and those that will only be exercised during cold :hutdown.
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APPENDIX B INFORMATION REOUIRED FOR HRC REVIEW OF RE00ESTS FOR RELIEF FROM ASME CODE SECTICH XI REOUIREMENTS DETERMINED TO BE IPPRACTICAL 1.
Identify component for which relief is requested:
a.
Name and number as given in FSAR b.
Function c.
ASME Section III Code Class d.
For valve testing, also specify the ASME Section XI valve category as defined in IWV-2000.
2.
S'pecifically identify the ASME Coce reouf rement that has been determined to be impractical for component.
3.
Provide information to support the detemination that the requirement in (2) is impractical; i.e., state and explain the basis for requesting relief.
4.
Specify the inservice inspection (or testing) that will be perfomed in lieu of the ASME Code Section XI requirements that have been determined to be impractical.
5.
Provide the schedule for implementation of the procedure (s) in (4) above.
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