ML20073B321
| ML20073B321 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 04/15/1991 |
| From: | Evers K WISCONSIN PUBLIC SERVICE CORP. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| CON-NRC-91-051, CON-NRC-91-51, FRN-56FR3796, FRN-57FR34666, RULE-PR-50 56FR3796-00018, 56FR3796-18, AD05-2-040, AD5-2-40, NUDOCS 9104240131 | |
| Download: ML20073B321 (6) | |
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600 North Adams e P.O Box 19002 n Green Boy, WI 54307 9002 T1 APR 22 All:15 crciet y sur,iirr UCCET NG *. t! ' Y"J m v. O I
April 15,1991
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Secretary of the Commission l
Attention Docketing and Service Branch
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L U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
I Docket 50-305 1
' Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on Prooosed Amendment to 10 CPR 50.55a
Reference:
" Federal Register, Vol. 56, No. 21, Thursday, January 31,1991, pp. 37963804 In the January 31,1991 Federal Reelster (Reference 1), the Nuclear Regulatory Commission
-(NRC) proposed an amendment to 10 CFR 50.55a. This amendment would incorporate by
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reference the 1986 1988 Addenda and 1989 Edition of Secdon III and Section XI (with a a
specified_ modification) of the American Society of Mechanical Rag % (ASME) Boiler and Pressure Vessel Code into_ regulation. b resulting regulation would impose augmented examination of reactor vessel shell welds. In addition, it would also separate in the reguladans
'the inservice testing requirements from the inservice inspection requirements by placing the inservice testing requirements in a wparate paragraph. Wisconsin Public Service Corporation (WPSC), the licensee for the Kewaunee Nuclear Power Plant (KNPP), reviewed comments submitted to the NRC by the Nuclear Management and Resources Council (NUMARC) regarding the proposed amendment to 10 CFR 50.55a. Although WPSC is in general support of NUMARC's comments, we offer the attached additional comments to stress our most I
significant areas of concern. WPSC requests that the NRC consider'these comments prior to finalissuance of the regulation.
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...,. c Secretary of the Commission April 15,1991 Page 2
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Manager - Nuclear Power j
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- Attach, cc - US NRC - Region HI Mr. Patrick Castleman, US NRC i
US NRC Document Control Desk UC\\NRC\\N473 L
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ATTACHMENT To letter fmm K. H. Evers (WPSC) to Dockedag and Service Branch (NRC)
Dated April 15,1991 l
Secretary of the Commission April 15,1991 Attachment Page 1 hiornine ASME Cndae NUMARC has supported the proposed endorsement oflater addenda and editions of the ASME Boller and Pressure Vessel Code, Sections III and XI, Wisconsin Public Service Corporation (WPSC) generally concurs that this is a positive step on the part of the NRC and that endorsing new code editions and addenda is necessary as new technologies and testing methods are developed. However, implementing new requirements carries with it a significant burden.
Therefore, WPSC does not agree with the NRC's conclusion that endorsing later editions and addenda of section XI of the ASME Code is not a backfit simply because updated section XI requirements are an integral part of the longstanding 10 CFR 50.55a(g)(4)(ii) requirements.
While the regulations require that licensees update their program to the latest edition endorsed L
by the NRC, the regulations do not require the Commission to update their endorsed code.
Clearly, specifying new code editions imposes new requirements on licensees and therefore is -
p subject to the provisions of 10 CFR 50,109. Therefore, prior to endorsing a new edition of the code, a backfit analysis should be performed to determine if the direct and indirect costs of implementation would be justified in view of the potentialincreased protection of the public health and safety.
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Secretary of the Commission April 15,1991 Attachment Page 2 Inmarvice T***ing Reauiremente WPSC concurs with the proposed amendment to separate the requirements for inservice inspection (ISI) and inservice testing (IST). Separating the reguladaan would more clearly distinguish the requirements for ISI and IST. In addition, since the requirements for IST are currently a subset of the ISI Requirements, the IST pmgram could be viewed as less important.
Placing ISI and IST requirements in separate sections places equal emplasis on the importance of both programs. WPSC recognized that it was prudent to separate the ISI Plan from the IST Plan prior to entering the KNPP second inspection interval. As a result, each program is its own entity and responsibility for implementation of inservice testing and inservice inspections are assigned independently.
WPSC does not agree with the proposed regulation in 10 CFR 50.55a(f)(6)(ii). This allows the Corn 11ssion to require the licensee to follow an augmented inservice test program for pumps and valves for which the Commission deems that added assurance of operational readiness is necessary. WPSC contends that this rule allows the Commission too much latitude in imposing additional testing requirements and bypasses tie contmla pmvided in 10 CPR 50.109. Tojusefy the piW augmented reactor vessel exams, a beckfit analysis was performed although the current regulation does not require it. To ensure consistency, the regulations should state that the provisions of 10 CFR 50.109 will be implemented prior to imposing any augmented tests or inspections.
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Secretary of the Commission April 15,1991 Attachment Page 3 Containment 1_anistian Valve Tate WPSC agrees with the NUMARC position that 10 CFR 50, Appendix J provides an adequate basis for testing containment isolation valves (CIVs). 'Ihe, Kewaunee Appendix J testing program has established advisory action levels and mandatory actim levels, based on effective penetration size, for each type C tested penetration The ability of containment, isolation valves or groups of containment isolation valves to perform their interAed function is demonstrated by this testing method. If the Commission determines that it is remry to retain the aquirements of leakage rate analysis and corrective action for CIVs, it is more appropriate to ircayerde these requirements into Appendix J of 10 CFR 50, Therefore, it is WPSC's opinion that retaining the requirements of Subsection IWV for leakage rate analysis and corrective action for specific valves is not necessary.
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