ML20059A928
| ML20059A928 | |
| Person / Time | |
|---|---|
| Issue date: | 08/16/1990 |
| From: | Richardson J Office of Nuclear Reactor Regulation |
| To: | Hodges M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| GL-90-05, GL-90-5, NUDOCS 9008240153 | |
| Download: ML20059A928 (5) | |
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NUCLEAR REGULATORY COMMISSION a
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MIG 16 fg MEMORANDUM FOR:
M. Wayne Hodges, Director Division of Reactor Safety, RI Albert F. Gibson, Director Division of Reactor Safety RII Hubert J. Miller, Director Division of Reactor Safety RIII Leonard J. Callan Director Division of Reactor Safety. RIV Roy Zimmerman, Director Division of Reactor Safety and Projects, RV FROM:
James E. Richardson, Director Division of Engineering Technology, NRR
SUBJECT:
FOLLOW-UP GN GENERIC LETTER 90-05 REGARDING GUIDANCE FOR PERFORMING TEMPORARY NON-CODE REPAIR OF ASME CODE-CLASS 1, 2, AND 3 PIPING Since the issuance of Generic Letter 90-05 on June 15, 1990, the staff l
received numerous telephone inquiries from licensees for clarifications of the Generic Letter.
From these discussions, it appears that the industry is not fully aware of the regulations in 10 CFR 50.55a(g), when perfoming a repair t
l that deviates from Section XI of the ASME Code.
Enclosed for your information are some discussions relating to the regulations and the Generic Letter that l
may be of use to the regional staff.
The staff finds repairs of code Class 1, 2, and 3 piping and components performed using methods other than those allowed by the ASME Code unacceptable without specific written relief granted by the NRC.
If the regional staff determines that methods other than those allowed by the ASME Code are used, we assume appropriate enforcement actions will be taken to ensure compliance of 10 CFR 50.55a(g)Section XI of the ASME Code, and plant-Technical Specifications.
After 6 months, the staff will evaluate the effectiveness of the guidance in Generic Letter 90-05.
At that time, we will consider, after discussions with
Contact:
S. Lee, DET/EMCB 492-0771 A
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e Multiple Addressees the Regions, what, if any, modifications to-requirements and procedures need
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to be implemented.
Ort.inal Stgned Bf.
James E. RichardBUR James E. Richardson, Director Division of Engineering Technology, NRR
Enclosure:
As stated cc:
T. Mur?ey F. Miraglia W. Russell J, Partlow F. Gillespie E. Jordan, CRGR J. Lieberman, OE C. Rossi C. Berlinger i
R.-Capra D. Oudinot L. Marsh Distribution:
Central Files DET RF EButcher EBaker EMCB RF RHermann KWichman Slee PDR0 i
- DET/EMCB
- DET/EMCB
- DET/EMCB.
- DET/EMCB
- 0E/DD Slee KWichman RHermann CYCheng EBaker 08 08/13/90-08/13/90 p
/13/90 08/13/90 08/13/90
- See previous concurrences
- PMAS/ILPB DET/DIR EButcher JERicha on 08/14/90 08/j@/9 0FFICIAL RECORD COPY (5520documentname:
Lee 813)
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ENCLOSURE-DISCUSSIONS RELATING TO THE REGULATIONS AND GENERIC LETTER 90-05 MATERIALS AND CHEM: CAL ~ ENGINEERING BRANCH DIVISION OF ENGIHEERING TECHNOLOGY OFFICE OF NUCLEAR REACTOR REGULATION INTRODUCTION Since the issuance of Generic Letter 90-05 entitled " Guidance for Performing Temporary Non-Code Repair of ASME Code Class:1, 2, and 3 Piping" on June 15, 1990, the staff received numerous telephone inquiries from licensees for clarifications of the Generic Letter.. From these discussions, it appears that the industry is 'not fully aware of the regulations in 10 CFR 50.55a(g), when performing a repair that deviates from Section XI of the ASME Code.
REGULATIONS 10CFR 50.55a(c)
Article IWA-4000 of Section XI provides rules for perfonning repairs on ASME Code Class piping.
However, the required code repair may be impractical for a flaw detected during plant o eration unless.the facility is shut down.
Pursuant to 10 CFR 50.55a(g)p(5)(1), the Comission will evaluate determinations of impracticality of code requirements, and may grant relief and may impose alternative requirements'.
There are different interpretations of the regulations by the licensees relating to temporary non-code repairs.
Because Section XI addresses only permanent repairs, some licensees interpret this to mean there are no requirements for temporary repairs.
Some other licensees contend that if they perform a structural integrity evaluation of the flawed piping, even those-with flaws exceeding the acceptance limits in Section XI, they are'in compliance with ~Section XI.
The staff finds no acceptable interpretation of the regulations by the liceasees to permit"the temporary non-code repair of code Class piping without prior staff review and approval.
As stated in Generic Letter 90-05, the staff continues to find temporary non-code repairs of code Class 1, 2, and 3 piping, regardless of pipe size, unacceptable without specific written relief granted by the NRC.
Although Generic Letter 90-05 deals exclusively with code Class piping, the regulations in 10 CFR 50.55a(g) also require licensees.to request relief prior to perfonning temporary non-code repairs of code Class components, such as pump casings and valve bodies.
GENERIC LETTER 90-05 Generic Letter 90-05 addresses temporary non-code repairs for flaws detected during plant operation.
If flaws are detected during scheduled plant shutdown, a code repair is required before restart.
Furthermore, if relief has been granted for a temporary non-code repair, the temporary non-code repair has to be replaced with a code repair at the next scheduled outage
Enclost:re.1 exceeding 30 days, but no later than the next refueling outage.
in Generic Letter 90-05 provides guidance for the staff in evaluating relief requests for temporary non-code repair of code Class 3 piping.
STOPGAP MEASURES TO LIMIT LEAKAGE WHILE PREPARING A RELIEF REQUEST If a licensee discovers a leak in Class 3 moderate energy piping and is l
preparing a relief request for a temporary non-code repair in accordance with Generic Letter 90-05, the licensee may use stopgap measures to limit leakage from the flawed piping.
However, the stopgap leakage-limiting measures must not affect the structural integrity of the flawed piping and must be reversible, that is, the flawed piping can be returned to the as-found flawed condition.
For example, a rubber patch attached to the flawed' piping by clamps does not alter the condition of the flawed piping and is reversible; however, welding may further degrade the flawed piping and is irreversible.
The licensee shall submit a request for relief proposing a temporary non-code repair, which may or may not be the stopgap leakage-limiting measure, on an expeditious basis to obtain NRC approval.
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