ML20132B389
| ML20132B389 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1996 |
| From: | Carpenter C NRC (Affiliation Not Assigned) |
| To: | Wichman K NRC (Affiliation Not Assigned) |
| References | |
| TAC-M91898, TAC-M93925, NUDOCS 9612170191 | |
| Download: ML20132B389 (24) | |
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UNITED STATES j_
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NUCLEAR REGULATORY COMMISSION i
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WASHINGTON, D.C. 30666 4 001 h *'.... $'
l December 10, 1996 i
MEMORANDUM TO: Keith R. Wichman, Acting Chief p
Materials & Chemical Engineering Branch Division of Engineering
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l Office of Nuclear Reactor Regulation FRON:
C. E. Carpenter, Jr., Lead Project Manager Materials & Chemical Engineering Branch
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i Division of Engineering Office of Nuclear Reactor Regulation k
SUBJECT:
MEETING SUPMARY FOR OCTOBER 15, AND OCTOBER 28, 1996, MEETINGS WITH BOILING WATER REACTORS VESSEL AND INTERNALS PRO (BWRVIP) REGARDING INTENTION TO PETITION FOR RULEMAKING, AND CLARIFICATION OF LICENSE RENEWAL RULE (TAC NOS. M93925 M91898)
Petition for Rulemakino 4
A meeting was held at the U.S. Nuclear Regulatory Commission's (NRC) One White j
Flint North offices in Rockville, Maryland, on October 15, 1996, with NRC 1
staff and members of the BWR Vessel and Internals Project (BWRVIP). By letter dated September 20, 1996, the BWRVIP informed the NRC staff of its intent to petition for rulemaking, and requested a meeting with the NRC staff to discuss the proposed Petition. Attachment 1 is a list of attendees. Attachment 2 is the BWRVIP's meetir" :lides.
the meeting, and were collected by the BWRVIP at the end of the m By letter dated September 28, 1995, the BWRVIP submitted the proprietary Electric Power Research Institute (EPRI) report TR-105697, "BWR Vessel and Internals Project, BWR Reactor Pressure Vessel Shell Weld Inspection Recommendations (BWRVIP-05)," dated September 1995, for NRC staff review.
This report evaluates the current inspection requirements for reactor pressure for BWR shell welds, and presents results from performing pro fracture mechanics (PFM) analyses based on an enhanced PFM code, VIPER, to justify a proposed alternative scope of inspections.
Under the existing augmented vessel inspection requirements in Section 50.55a to Title 10 of the Code of federal Regulations (10 CFR 50.55a(g)(6)(ii)(A)), all licensees must
/
perform one time examinations of " essentially 100%" of the circumferential and longitudinal reactor vessel shell welds. Among its other recommendations, I
BWRVIP-05 proposes to revise these requirements in 10 CFR 50.55a(g)(6)(ti)(A) l }
to inspect 50% of RPV shell longitudinal seam welds, and 0% of RPV shell circumferential seam welds.
(yf'/t[j[//M/5 CONTACT:
C. E. Carpenter, Jr.
301-415-2169 AB ~/o- /
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Keith R. Wichman
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To aid the NRC staff's review of this document, the NRC staff issued two Requests for Additional Information (RAIs), the first on April 2,1996, and the second on May 20, 1996.
By letter dated June 24, 1996, the BWRVIP responded to the two RAls with supplemental information. Further, in response to the request from the BWRVIP Executive Oversight Committee (EOC), NRC managerial and technical staff met with the BWRVIP EOC management and technical staff in a public meeting held at the NRC offices in Rockville, i
Maryland, on July 11, 1996. The meeting summary, dated July 23, 1996, included several requests for additional clarifications from the BWRVIP of issues that the NRC staff identified during this meeting.
j The BWRVIP members presented its Petition format, and requested clarification j
as to what information needs to be provided to expedite review of the proposed Petition.
The NRC staff discussed with the BWRVIP members the timing and l
steps required to be taken for Rulemaking activities. The NRC staff cautioned l
the BWRVIP members that rulemaking even if expedited, is still a laborious process that takes two or more year,s to complete. While it is possible to j
reduce this by several months, the NRC staff is doubtful that Rulemaking could i
proceed in a timely enough fashion to address the BWRVIP concerns.
j The NRC staff agreed to provide the BWRVIP with a description of the Rulemaking process, which is included as Attachment 3 to this meeting summary.
1 h
The question was raised as to whether the revised reactor vessel examination scope, as proposed in the BWRVIP-05 report, could be considered an alternative to 10 CFR 50.55a(g)(6)(ii)(A), pursuant to 10 CFR 50.55a(a)(3).
Section 50.55a(a) to the req (3) to 10 CFR Part 50 [10 CFR 50.55a(a)(3)] states that alternatives uirements of subparagraph (g) may be used, when authorized by the NRC, if (1) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
Although the existing augmented examination requirements in 10 CFR 50.55a(g)(6)(ii)(A) also allows the use of alternatives, pursuant to 10 CFR 50.55a(g)(6)(11)(A) 5, the language in 10 CFR 50.55a(g)(6)(ii)(A)(5) clearly states that the us(e)of these alternatives would only be allowed when licensees are unable to completely satisfy the requirements for the augmented reactor vessel shell weld examination (e.g., as 1
a result of physical interference or obstruction).
The NRC staff has previously authorized, for many plants, less than essentially 100% weld coverage when licensees were una>le to examine portions of the reactor vessel i
shell welds due to physical interferences or obstructions. The NRC staff i
agreed to seek a legal opinion from the Office of the General Counsel (OGC) as 4
to the acceptability of using the approach in BWRVIP-05 as an alternative to the augmented vessel examination requirements.
j Clarification of License Renewal Rule e
l On October 28, 1996, members of the Materials and Chemical Engineering Branch (EMCB) and the License Renewal Project Directorate (PDLR) met with representatives of the BWRVIP and the BWR Owner's Group Renewal Committee to discuss the applicability of license (BWROG) License renewal to the efforts of the BWRVIP. Attachment 4 is a list of attendees.
2 1
1
Keith R. Wichman To date, the BWRVIP has submitted nine documents that deal with the assessment, mitigation and repair of age related degradation of the BWR vessel and its internal components. The BWRVIP requested that the NRC staff provide clarification as to how these, and future, documents could be appropriately submitted so as to be reviewed to both 10 CFR Part 50 and 10 CFR Part 54 (license renewal rule) requirements.
l The NRC staff indicated that for the BWRVIP to request review of its submittals under both Part 50 and Part 54 requirements was acceptable.
The NRC staff further informed the BWRVIP and BWROG members that the submitted l
(and future) reports will need to be modified so that they explicitly confirm l
that they are applicable to license renewal, so that individual licensees can reference these documents in their license renewal applications.
The BWRVIP I
l agreed to submit an Appendix to the existing reports that will describe how the reports meet the requirements of 10 CFR Part 54.
The NRC staff encouraged the BWRVIP to work with the NRC staff to expedite the reviews.
Further meetings will be scheduled as needed.
Attachments:
1.
October 15, 1996, List of Attendees 2.
October 15, 1996, BWRVIP Handout 3.
Rulemaking Timeline 4.
October 28, 1996, List of Attendees DISTRIBUTION: see next page Central File RAHermann MEMayfield PUBLIC CFSheng GCMillman NRR/EMCB Reading SFNewberry MBMcNeil FJMiraglia/ACThadani RKAnand DAJackson BWSheron/GClainas EMHackett DOCUMENT NAME:
G:\\BWRVIP\\ VIP-1015.MTS
- See previous concurrence To receive a copy of this document, indicate in the box:
"C" - Copy without attachment "E" - Copy with attachment "N" - No copy
~
EMCB: LPM lE EMCB:SC E
EMCB:(A)C lE DE:(A)DD lC CECarpenter A af DTerao*
KRWichman*
JRStrosnider*
12/03/96 V~
12/03/96 12/03/96 12/04/96 0Ff1CIgiRECORD; COPY, l
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l Keith R. Wichman j l
l l
To date, the BWRVIP has submitted nine documents that deal with the assessment, mitigation and repair of age related degradation of the BWR vessel and its internal components. The BWRVIP requested that the NRC staff provide clarification as to how these, and future, documents could be appropriately submitted so as to be reviewed to both 10 CFR Part 50 and 10 CFR Part 54 (license renewal rule) requirements.
The NRC staff indicated that for the BWRVIP to request review of its submittals under both Part 50 and Part 54 requirements was acceptable. The NRC staff further informed the BWRVIP and BWROG members that the submitted (and future) reports will need to be modified so that they explicitly confirm that they are applicable to license renewal, so that individual licensees can i
reference these documents in their license renewal applications.
The BWRVIP agreed to submit an Appendix to the existing reports that will describe how the reports meet the requirements of 10 CFR Part 54.
The NRC staff encouraged the BWRVIP to work with the NRC staff to expedite the red ews.
Further meetings will be scheduled as needed.
Enc 1csures: 1.
October 15, 1996, List of Attendees 2.
October 15, 1996, BWRVIP Handout 3.
Rulemaking Timeline 4.
October 28, 1996, List of Attendees DISTRIBUTION: see next page Central File RAHermann MEMayfield PUBLIC CFSheng GCMillman NRR/EMCB Reading SFNewberry MBMcNeil FJMiraglia/ACThadani RKAnand DAJackson BWSheron/GClainas EMHackett DOCUMENT NAME:
G:\\BWRVIP\\ VIP-1015.MTS To receive a copy of this document, indicate in the box:
"C" - Copy without attachment / enclosure "E" - Copy with attachment / enclosure "N" - No copy EMCB: LPM lE EMCB:SC n4-E EMCB:(A)Cn,lE DE:(A)DD C
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CECarpenter n,A DTerao C KRWichman W JRStrosnideM/
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Keith R. Wichman and its internal components. The BWRVIP requested that the NRC staff rovide clarification as to how these, and future, documents could be approp ately submitted so as to be reviewed to both 10 CFR Part 50 and 10 CFR P t 54 (license renewal-rule) requirements.
The NRC staff indicated that for the BWRVIP to request rev w of its submittals under both Part 50 and Part 54 requirements s acceptable. The NRC staff further informed the BWRVIP and BWROG memb that the submitted (and future) reports will need to be modified so t they explicitly confirm that they are applicable to license renewal, so at individual licensees can reference these documents in their license re al applications.
The BWRVIP agreed to submit an Appendix to the existin reports that will describe how the reports meet the requirements of 10 C,Part 54.
The NRC staff encouraged the BWRVIP t vork with the NRC staff to expedite the reviews.
Further meetings will be scheculed as needed.
Enclosures:
1.
October 15, 6 List of Attendees 2.
October 15 996, BWRVIP Handout 3.
Rulemaki Timeframe 4.
October 28, 1996, List of Attendees DISTRIBUTION: see ext page Central File RAHermann MEMayfield PUBLIC CFSheng GCM111 man NRR/EMCB R ding SFNewberry MBMcNeil FJMiragli /ACThadani RKAnand DAJackson BWShero GClainas EMHackett DOCU NT NAME: G:\\BWRVIP\\ VIP-1015.MTS To receive a copy of this dwment, indicate;in the box:
"C" - Copy without attachment / enclosure "E" = t,qpy with attaghment/ enclosure "N" - No copy EMCB: LPM lE EMCB:SC [ 1E EMCM ( & lE DE:(A)DD C
CECarpenter &L DTerao <P\\
K1M& madf JRStrosnider el/tt/96 il /25/96
// D T/96 '
/ /96 Off1C.1A.JECORD; COPY
cc:
John Hosmer, Executive Chairman Vaughn Wagoner, Technical Chairman BWRVIP Integration Task BWRVIP Integration Task Comonwealth Edison Carolina Power & Light Company 1400 Opus Place One Hanover Square 8C1 Downers Grove, IL 60515 P.O. Box 1551 Raleigh, NC 27612 Robert Keaten, Executive Chairman Steve Leonard, Technical Chairman BWRVIP Inspection Task BWRVIP Inspection Task GPU Nuclear Niagara Mohawk Power Company ESB1 One Upper Pond Road, Bldg F Post Office Box 63 Parsippany, NJ 07054 Lycoming, NY 13093 l
Carl Terry, Executive Chairman Robin Dyle, Technical Chairman BWRVIP Assessment Task BWRVIP Assessment Task Niagara Mohawk Power Company Southern Nuclear Operating Co.
Post Office Box 63 Post Office Box 1295 l
Lycoming, NY 13093 40 Inverness Center Parkway Birmingham, AL 35201 George Jones, Executive Chairman John Wilson, Technical Chairman BWRVIP Mitigation Task BWRVIP Mitigation Task Pennsylvania Power & Light Public Service Electric & Gas Co.
A6-1 N51 Two North Ninth Street Post Office Box 236 Allentown, PA 18101 Hancocks Bridge, NJ 08038 Bill Campbell, Executive Chairman Bruce McLeod, Technical Chairman BWRVIP Repair Task BWRVIP Repair Task Carolina Power and Light Company Southern Nuclear Operating Co.
411 Fayetteville Street Post Office Box 1295 Raleigh, NC 27602 40 Inverness Center Parkway Birmingham, AL 35201 Warren Bilanin, EPRI BWRVIP Manager Electric Power Research Institute 3412 Hillview Ave.
Palo Alto, CA 94304 i
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4 MEETING WITH BWR VESSEL & INTERNALS PROJECT TO DISCUSS PETITION FOR RULEMAKING RELATED TO BWRVIP-05 REPORT October 15, 1996 NAME TITLE ORGANIZATION TELEPHONE C. E. Carpenter Lead PM NRC/NRR/DE/EMCB 301-415-2169 0 "*
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ATTACHMENT 1 1
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i BWRVIP Petition for Rulemaking Regarding inservice inspection Requirements for BWR Reactor l
Pressure Vessel Welds i
BWRVIP i
1 ATTACHMENT 2
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Petition Format Follow outline of Regulatory Position of Draft Regulatory Guide DG-0010 " Preparation of Petitions for Rulemaking under 10CFR2.802 and Preparation and Submission of Proposals for Regulatory Guidance Documents," August 1996 t
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l BWRVIP j
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Petition Outline 1.
Proposed Regulatory Text j
2.
Consideration for the Regulation 3.
Material to Show Conformance with Legal l
Requirements l
4.
Regulatory Analysis i
4.1 Problem Statement i
4.2 Preliminary Analysis of Alternatives l
4.3 Evaluation of Values and impacts j
4.3.1 BWR Inherent Flaw Tolerance 4.4.2 Probabilistic Fracture Mechanics i
l 4.4.3 Cost / Benefit Analysis l
5.
Response to the Backfit Rule 6.
Proposals for Regulatory Guidance Documents BWRVIP 3
l iL i
i PROPOSED REGULATORY TEXT - OPTION A Revise 10CFR50.55a(g)(6)(ii)(A) as follows:
(A) Augmented examination of reactor vessel.
(1) All previously granted reliefs under $50.55a to licensees for the extent of volumetric examination of reactor vessel shell welds specified in item B1.10 of Examination Category B-A, " Pressure Retaining Welds in Reactor Vessel," in Table IWB-25001 of Subsection IWB in applicable edition and addenda of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, during the inservice inspection interval in effect on September 8, i
1992 are hereby revoked, subject to the specific modification in 950.55a(g)(6)(ii)(A)(3)(iv) for licensees that defer the augmented examination in accordance with
$50.55a(g)(6)(ii)(A)(3).
4 i
(2) Scope of examinations.
j (i) All licensees of a pressurized water-cooled nuclear power facilityM! Werer shall augment their reactor vessel examination by implementing once, as part of the inservice i
inspection interval in effect on September 8,1992, the examination requirements for reactor vessel shell welds specified in item B1.10 of Examination Category B A, j
" Pressure Retaining Welds in Reactor Vessel," in Table IWB 25001 of Subsection IWB of the 1989 Edition of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, subject to the conditions specified in 650.55a(g)(6)(ii)(A)(3) and (4). The augmented examination, when not deferred in accordance with the provisions of
$50.55a(g)(6)(ii)A(3), shall be performed in accordance with the related procedures specified in the Section XI edition and addenda applicable to the inservice inspection f
interval in effect on September 8,1992, and may be used as a substitute for the reactor
]
vessel shell weld examination scheduled for implementation during the inservice inspection interval in effect on September 8,1992. For the purpose of this augmented examination, " essentially 100% as used in Table IWB-2500-1 means more than 90 l
percent of the examination volume of each weld, where the reduction in coverage is due to j
interference by another component, or part geometry.
(ii) All licensees of a boilina water cooled nuclear power facility shall auoment their reactor j.
vessel examination by implementino once, as part of the inservice inspection interval in effect on September 8,1992, the examination requirements for reactor shell welds i
specified in Item B1.12 of Examination Gateoory B A, " Pressure Retaining Welds in Reactor vessel," in Table IWB 2500-1 of Subsection IWB of the 1989 Edition of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code, subject to the conditions i
specified in 550.55a(a)(6)1 st)LA)(3) and (4). The augmented examination, when not deferred in accordance wit 1 t1e provisions of 550.55a(Q)(6)Jii)A(3), shall be performed in accWdance with the related procedures specified in the Sec: ion XI edition and addenda applicable to the inservice inspection interval in effect on September 8,1992, and may be used as a substitute for the reactor vessel shell Weld examination scheduled for l
implementation during the inservice inspection intervalin effect on September 8,1992. For 4
the purpose of this augmented examination, " essentially 100% as used in Table IWB-2500-1 means more than 90 percent of the examination volume of each weld, where the reduction in coverage is due to interference by another component, or part oeometry.
1 (3) Licensees with fewer than 40 months remaining in the inservice inspection interval in effect on September 8,1992 may defer the augmented reactor vessel examination j
specified in 950.55a(g)(6)(ii)(A)(2) to the first period of the next inspection interval under the following conditions:
i (i) The deferred augmented examination may not be used as a substitute for the reactor vessel shell weld examination scheduled for implementation during the inservice 4
inspection interval in effect on September 8,1992.
(ii) The deferred augmented examination may be used as a substitute for the reactor vessel shell weld examination normally scheduled for the inspection interval in which the i
deferred examination is performed.
i (iii) If the deferred augmented examination is used as a substitute for the normally scheduled reactor vessel shell weld examination, subsequent reactor vessel shell weld examinations must be performed during the first period of successive inspection intervals.
i
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l (iv) Ucensees that defer the augmented examination, as permitted herein, may retain all previously granted reliefs that otherwise would be revoked by s50.55a(g)(6)(ii)(A)(1) for the inservice inspection interval in effect on September 8,1992.
(v) Licensees with fewer than 40 months remaining in the inservice inspection interval in l
effect on September 8,1992 may extend that interval in accordance with the provisions of l
Section XI (1989 Edition) IWA 2430(d) for the purpose of implementing the augmented l
examination during that interval.
(vi) The deferred augmented examination shall be performed in accordance with the l
related procedures specified in the Section XI edition and addenda applicable to the inspection interval in which the augmented examination is performed.
(4) The requirement for augmented examination of the reactor vessel may be satisfied by an examination of essentially 100 percent of the reactor vessel shell welds specified in
@50.55a(g)(6)(ii)(A)(2) that has been completed, or is scheduled for implementation with a written comm,itment, or is required by 950.55a(g)(4)(i), during the inservice inspection interval in effect on September 8,1992.
(5) Licensees that make a determination that they are unable to completely satisfy the requirements for the augmented reactor vessel shell weld examination specified in 950.55a(g)(6)(ii)(A) shall submit information to the Commission to support the determination and shall propose an altemative to the examination requirements that would provide an acceptable level of quality and safety. The licensee may use the proposed alternative when authorized by the Director of the Office of Nuclear Reactor Regulation.
l l
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l PROPOSED REGULATORY TEXT - OPTION B Add a new paragraph (6) be added to 10CFR50.55a(g)(6)(ii)(A) adding the clarification that:
(6)
For boiling water reactor nuclear power facilities, the augmented reactor vessel examination requirements in Q50.55a(g)(6)(ii)(A)(1) through
@50.55a(g)(6)(ii) A)(5) may be satisfied by examination of essentially 100% of the ion dinal shell welds identified in item B1,12 of Examination Category B-A," ressure Retaining Welds in Reactor Vessel"in Table IWB-2500-1 of subsection lWB of the 1989 Edition of section XI, Division 1, of the ASME Boiler and Pressure Vessel Code.
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1
- 2. Considerations for the i
l Regulation i
l Current ISI requirements per ASME Section XI i
and 10CFR50.55a i
s Essentially 100% of longitudinal and l
circumferential shell welds i
l Same for BWRs and PWRs But, BW.R vessels possess significantly j
greater inherent flaw tolerance i
l Lower irradiation embrittlement No pressurized thermal shock event Pressure test limiting condition l
l BWRVIP 4
lt____ _ _ _._..____,___._____._,_.___.____ _ _ _.___ _.._._... _
[
Considerations for the Regulation j
Findings of BWR vessel analysis Reduction to zero circumferential and 50% longitudinal shell weld inspections results in small but finite increase in risk of vessel failure j
i Circumferential shell welds make zero l
contribution to vessel failure probability Cost savings of $1.3M to $1.6M per plant by eliminating circumferential weld j
inspections ($46M to $58M for BWR fleet) i
. BWRVIP l
s
i Stress Intensity Factors vs. Fracture Toughness 4
Longitudinal vs. Circumferential Welds 2(N) 180 i
1 IN) 4 140 Kic-unitral Kic-irral.
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K-tong ( ASME XI)
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Crack Depth On.)
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- 3. Material to Show Conformance 1
with Legal Requirements 3.1 Environmental Impact Under NEPA j
No significant change in environmental impact compared to existing rule 3.2 Information Collection Requirements Under the Paperwork Reduction Act l
1 No measurable change in amount of paper i
provided to the Federal Government j
3.3 Economic impact on Small Entities Under the Regulatory Flexibility Act No "significant economic impact on a substantial number of small entities" (from Draft Reg. Guide DG-0010)
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- 4. Reaulatory Analysis j
Preliminary Evaluation of Alternatives Three inspection Scenarios Considered:
A. Current inspection Requirements B. Elimination of Circumferential Welds from 4
l Inspection Program l
C. Elimination of Circumferential Welds and j
50% of Longitudinal Seam Welds from j
inspection l
CASE B SELECTED FOR PETITION FOR RULEMAKING N
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i BWRVIP 7
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Comparative Analysis of Alternatives l
l CASE RISK OF VESSEL COST OF INSPECTION I
^
per Plant B W R Fleet A
5.69 x 10*
$33M
$119M 8
B 5.69 x 10
$1.85M
$67M 7
C 1.151 x 10
$1.45M
$52M l
OPTION B SELECTED FOR PETITION FOR l
RULEMAKING BECAUSE NO IMPACT ON PLANT l
SAFETY WITH SIGNIFICANT COST SAVINGS l
- BWRVIP 8
l /
Evaluation of Values and impacts
\\
1 BWR Inherent flaw tolerance l
Circumferential vs. longitudinal welds i
l Probabilistic fracture mechanics Cost / Benefit analysis I
1 i
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BWRVIP 8
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- 5. Response to Backfit Rule Proposed rule change does not impose new or additional requirements, therefore, not a backfit as defined in 10CFR50.109 and a backfit analysis is not required j
i BWRVIP i
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- 6. Proposals for Regulatory Guidance Documents i
l Not applicable to this petition I
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Meeting with BWRVIP Regarding License Extension October 28, 1996 l
NAME ORGANIZATION TITLE TELEPHONE NUMBER C.E. Carpenter NRC/NRR/DE/EMCB Lead Project Manager (301) 415-2169 k%te suc/
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s ATTACHMENT 4