ML20135C509

Comment Supporting Comments Submitted by NEI & Nuclear Utility Backfitting & Reform Group Re Proposed GL, Effectiveness of Ultrasonic Testing Sys in Inservice Insp Programs

ML20135C509
Person / Time
Site:	Calvert Cliffs
Issue date:	02/21/1997
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-61FR69120 61FR69120-00006, 61FR69120-6, NUDOCS 9703040079
Download: ML20135C509 (2)

Text

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Baltimore Gas and Electric Company Vice President Calvert Cliffs huclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway Lusby, Maryland 20657 f)_ g - 410 495-4455 February 21,1997 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Rules Review and Directives Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on Proposed Generic Letter: Effectiveness of Ultrasonic Testing Systems in Inservice Insnection Programs (61 FR 69120)

The Baltimore Gas and Electric Company is pleased to provide comments on the subject proposed Generic Letter. We have reviewed the comments submitted by the Nuclear Energy Institute and the Nuclear Utility Backfitting and Reform Group. We endorse the comments submitted by both groups.

The proposed generic letter requests all licenses to identify to what extent and on what schedule they will implement Appendix VIII to Section XI of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code. The Nuclear Regulatory Commission does not expect to complete a rulemaking to amend 10 CFR 50.5Fa requiring the use of the Appendix until around July,1998.

Therefore, we believe that the proposed generic letter is premature and should not be promulgated.

The generic letter states that "The nuclear industry recognizes Appendix VIII as an improvement over the current" inservice inspection requirements. In the 1989 Addenda to the ASME Code,Section XI, Appendi' VIII was published. In 1991, the nucle).r industry created the Performance Demonstration Initiative (PDI) to manage the implementatica of the performance demonstration criteria of Appendix VIII. Since 1991, PDI has generated over 20 exceptions to the requirements of Appendix VIII.

In addition, six ASME code cases and eight interpretations have been approved by ASME conce.rning ,

Appendix VIII as of December 31,1996. Clearly, all the exceptions and code cases indicate that it is inappropriate to state that the industry " recognizes Appendix VIII as an improvement."

We embrace improvements in the quality of non-destructive examination and fully support the PDI program. Reasonable additional costs associated with non-destructive examination improvements are recognized and acceptable provided there is a real benefit to nuclear safety.

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Rules Review and Directivrs Branch l February 21,1997  !

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The letter states that "a safety concern does not exist which would warrant immediate backfitting of Appendix VIII in advance of rulemaking." We agree with this statement; however, we are troubled by the Nuclear Regulatory Commissions determination that the proposed generic letter does not require a backfitting analysis. The letter states that a "significant improvement is gained in the effectiveness" of

, ultrasonic testirg systems qualified through Appendix VIII. We do not feel the use of the term i "significant improvement" is appropriate without some probabilistic or quantitative backfit analysis.

Further, it seems reasonable to perform a backfitting analysis ofimplementation of Appendix VIII prior i to requesting that utilities describe the extent to which their piping and reactor pressure ' vessel inservice inspection activities are being qualified consistent with the objectives of Appendix Vill.

In summary, we feel that the proposed generic letter should not be issued. To allow Baltimore Gas and

- Electric Company to implement appropriate parts of the PDI prcgram, the Nuclear Regulatory Commission should indicate that use of the new PDI program is an acceptable method of compliance with the current regulations. This could be included in their proposed amendment to 10 CFR 50.55a.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours,

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CHC/SJR/bjd cc: Document Control Desk, NRC H. J. Miller, NRC

! D. A. Brune, Esquire Resident Inspector, NRC J. E. Silberg, Esquire R.1. McLean, DNR Director, Project Directorate I-1, NRC J. H. Walter, PSC

! A. W. Dromerick, NRC i