ML19329B692
| ML19329B692 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/09/1976 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19329B683 | List: |
| References | |
| NUDOCS 8002060705 | |
| Download: ML19329B692 (8) | |
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ENCLOSURE 1 r.
WPC STAFF GUIDANCE FOR COMPLYIhG WITH CERTAIN PROVISIONS _OF 10 CCR 50.55a(gl "IrlSERVICE INSPECTION RE0UIREPENTS" I.
INTRODUC, TION 12, 1976 Paragraph 50.55a(g) of 10 CFR Dart 50 was revised on February (41 FR 6256). Since then, a number of licensees have requested that the NRC clarify several key provisions contained in the revised regulation.
(1) the requirements to periodically These key provisions relate to:
update the i7serrice 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 progran, and (3) the procedures for requesting and cotaining relief from ASME Code requirements that the licensee considers to be impractical for The purpose of this document is to briefly summarize his facility.
the major provisions of the revised 550.55a(g) and to provide general The document is in no way intended guidance in these three key areas.
to encompass all aspects of attaining compliance with 550.55a(g).
II.
SUMMARY
OF REGULATION Th6 revised 550.55a(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 performe'd in accordance with Section XI For of the ASME Boiler & Pressure Vessel Code and applicable Addenda.
operating facilities whose Operating License (OL) was issued before March 1,1976, these provisions of the regulation apply at the start of the The next regular 40-month inspection period af ter Septemoer 1,1976.
start of the next 40-month period is detemined by measuring a series ofFor such periods beginning at the start of facility commercial operation.
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, Since plant designs ano access previsions for inservice inspections 1971.
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 their service lives.
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2-An importar t rir t of tne revised $0.55a(g) is the incorporation of the ASME Code Secti n XI requiremaats ic" testing pumps and valves for opera-This tional reaeiness along with the inservice inspection reouirenents.
addition to a fccility's inservice ir.section program, a means that !q periodic testing program of selected pumps and valves must also be instituted.
There are now provisio'is in 550.55t(g) for continued updating of requirements The inservice for testing pumps and valves and for inservice inspection.
inspection program must be updated every 40 mor.ths while the pump and valve testing program must be epoated every 20 months. Furthermore, the regulation specifies acti:n to be t3 ken by a licensee when an updated inservice inspec-tion or testing progran conflicts witt, the Technical Specifcations, or when a requirement contained in a referenced ASME Code Edition or Addendum is deemed impractical by tne licensee due to design, geometry, or material considerations.
Other provisions'in 550.55a(g) allow the NRC to grant relief from ASME Code requirements that have been determined to be impractical for a facility and specifically allow the NRC to require a licensee to follcw an augmented inservi:e inspection program on components for which added assurance of structural reliability is needed.
Selected provisions of the revised regulation are discussed below.
III. General Guidance for Compliance with Three Key Provisions of 550.55a(g):
A.
Updating Inservice Insoection and Testing Programs
P aragrann 50.55 ai g )(a );
The inservice 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 suonitted to the NRC for review and approvsi as far in advance as possible of, but at least 90 days before, the start of each period. The information the NRC will need for its review of updated programs is identified in Appendix A (attached).
Under $50.55(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 aoplicable. The tenns "in effect" or "ef fective", as used in 550.55a(g)(4), identify those editions and addenda to the ASME Code that have been published by the ASitE and that are also referenced in paragraph (b) of 550.55a.
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Paragruch (b) of 550.55a is amenM peri:dically to incorporate more recent.
ASME Cod 9 Editions and Addenda. However, the regulations are not amended until af ter i;he published ASME Code Editiens and Addenda have been reviewed Thert. fore, the ASME Code Edition and Addenda that and endorsed by t.he NRC.
are appif( d>1e to any inspect on period are those referenced in paragraph (t,)
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,of $50.55a on the date that corresponds to 6 months before the start of the period in question.
If amendments to paragraph (b) of 550.55a become effective on a date thit falls between the date that narks 6 months before the start of a inspection period and the start date itself, the licensee is not required to comply Under the regu-with the nawly referenced ASME Code Editions and Addenda.
lation, tne licensee need only comply with the ASME Code Editions and Addenda that were referenced in paragraph (p of 550.55a 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 wnich ASME Code Edition and Addenda will be used.
An inservice inspection or testing progran does n'ot 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 550.55a.
Conforming the Technical Soecifications to an Uodated Inservice Inspection B.
or Testing Program ----- Paragraon 50.55at g)(5 )(ii):
If a revised (updated) inservice inspection or testing program conflicts with the Technical Scecifications for a facility, the licensee must propose changes to the Technical Specifications to conform them to the updated pro-This must be done at least 6 months before the start of the period gram.
in which the program becanes applicable.
Technical Specifications are considered to be "in conflict" only in cases where the requirements of the rehulation (thus the requirements of the updated prograin) are more restrictive than the requirements of the Tech-nical Specifications.
In such cases the licensee must propose changes to In cases where conform the Technical Specifications to the revised program.
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 detennine if it is acceptacle or wnether tne existing reqire-ment should be retained as an augmented requirement pursuant to 150.55a(g)(6)(ii).
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In the NRC Staffs view, the most ef4.ts from the Technical Sp rd h nges that would substitute standa Efi lace of existing inservice
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potential c -propose Technical Specification c a I
This should be done at least language referencing 550.55a(g) in the p y
40-month inspection period inspection and testing requirments.6 months before p
r for which 550.55a(g) is applicable.adopt the approach of referenc-T i
ear.
was sent to licensees earlier th s y i
ill simplify the Technical The NRC strongly reccrnmends that licensees ts that are duplicated in the i
ing 550.55a(g), because such referenc ng es whenever an Specifications by deleting any requiremen This approach has scheduling pressures associated is updated.
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inservice inspection or testing program l time requirement for Technical Soec-f regul ation.
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h the added advantage of eliminating t eIt will also simplify with meeting the i months submittanposals of 50.55a(g)(2)(ii).
and the NRC grants, reliefdete K
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ification changes :
the process by whic.i licensees reoves,
from ASME Code requirements that have beenTechnica l
This is because license amenaments (i.e., re d t relief.
changes) will not be necessary to gran j
Relief from ASME Code recuireme is further discussed below.
C. 'Obtainino Relief from ASME Code Reou r d to be impractical by the licensee,
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Paracraci 50.55atc)(5)(iii) and (6)(1 pport ify the NRC and submit infomation to If certain ASME Code requirements are foun impractical at least 90 days before the regulation requires him to notThe licensee should submit re The infomation that is nee requirements that he has detemined to be relief frcn requirements found to his findings, period.
i the start of the applicable inspect on B (attached).
impractical is identified in Appencix ise
)(6)(i). Unless a licensee is ot The NRC Staff will evaluate licensee reque i ble E Code requirements will re if appropriate, pursuant to 150.55a(g notified by the NRC, relief from ASet ant he requirement is impractical, pursu until the end of each 120-month period.
This re-evaluation will take into accouinsp the basis for the detemination that t to 550.55a(g)(5)(iv).
in the state-of-the-art of inserviceoccurred si lly granted.
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s,ie licensee wilI know well in advance of the beginning of any Genera'.iy inspection paried, whether cr not a particula AS'1E Code requirement wil' be ie.,rsctic,si for his faci'ity. Thus, the licensee should request relief from AS"E (. ode 'ecuirements at far as pnssible in advance of, but not less than 90 days befcre, the s*. art of the inspection period.
Early submittals are ps.rticularly important for tt:e first 40-month inservice inspection and 20-month pump and valve testing period because they will enable the HRC staff to evaluate the infomation received from all licensees and detemine whict AS4E Code requirements may be generally impractical for various classes of plants.
Early submittals will thereby f acilitate 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 detemine 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, tne 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 detemined to be impractical for a facility will be granted in the fom of a letter within the provisions of 550.55a( g)(5 )(ii. This written relief should be incorporated into the document describing tne inservice inspection and testing progran retained
.by the licensee. Notice of the grantino of relief from ASME Code require-ments wiii be published in the : FEDERAL REGISTFR, but the written relief itself will net become an explicit part of the facility license or the Technical Specificaticns.
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, APPENDIX A INFCRMATION RE0VIRED FOR NRC REVIEW OF INSERVICE, INSPECTION AND TESTING PROGRAFG 1.
Inservice Inspection Programs:
The infonaation submitted for NRC review should include *, as a minimum:
a.
Identification of the applicable ASiE Boiler and Pressure Yessel Code Edition and Adcenda b.
The period for which the program is applicable c.
Identification of all of the specific components and parts to be examinea for each ASSE Code Class (i.e., each Quality Group as defined in Regulatory Guide 1.26, " Quality Group Classifications and Standards for Water, Steam, and Radioactive-Waste-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 ii) The examination method to be used tii) The repair requirements 2.
Pump and Yalve Testing Programs The inforuation 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: identi fy:
i) 'each pump to be tested (name and number) 11) the test parameters that will be measured iii) the test intervals, i.e., monthly during operation, only during cold shutdown, etc,
- Specific written elief fran the WRC is recuired to exclude any AStE Section XI Code requires.ent -
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For 'ialee Testing; identi fy:
esch valve in ASME Sectioit XI Categories A & B that will be il exer:1.:ed wery 3 months during noimal plant operation (indicate whecner partial or full stroke exercise).
ii) each valve in Au!E Section XI Category A that will be leak tested during refueling outages.
iii) all valves in ASME Section XI Categories C, 0, and E, that will For check be tested, the type of test and the test frequency.
valves, identify tnose that will be exercised every 3 months and those that will only be exercised during cold shutdown.
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APPENDIX B INFORMATION REQUIRED FOR No.C REVTE'4 0F REOUESTS BE IMPRACTICAL
__SME Ci.JE S$CTIC;1 XI RE0ili?.Er.ELTS DiTE?MD:ED TO A
1.
Identify ccaponent for which relief is requested:
1.
Name and number as given in FSAR b.
Function c.
ASME 3ection III Code Class d.
For valve testing, also specify the ASME Section XI valve category as defined in IWY-2000.
Specifically identify the ASME Code requirement that has been determined to 2.
be impractical for component.
Provide information to support the determination that the requirement in (2) 3.
is impractical; i.e., state and explain the basis for requesting relief.
Specify the inservice inspection (or testing) that will be performed in lieu 4.
of the ASME Code Section XI requirements that have been catermined to be impractical.
Provide the schedule for implementation of the procedure (s) in (4) abcVe.
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