ML20135E726
| ML20135E726 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/1996 |
| From: | Hermann R NRC (Affiliation Not Assigned) |
| To: | Ling J AMERICAN SOCIETY OF MECHANICAL ENGINEERS |
| Shared Package | |
| ML20135E728 | List: |
| References | |
| NUDOCS 9612120028 | |
| Download: ML20135E726 (5) | |
Text
I December 5, 1996 l
i Ms. June Ling Associate Executive Director C&S j
ASME 345 East 47th Street i
M/S 98 New York, New York 10017-2392 Dear Ms. Ling.
j Enclosed is a draft copy of the meeting summary for our November 12, 1996 meeting. Please provide any comments as quickly as you may find convenient so that we can issue final summary.
You may forward your comments to the above address. My mail stop is OWFN 7 D4.
Thank you for your help.
i Sincerely, pf"!'L CGEO i
Robed:A.Hermann,SeniorLevelAdvisor for Materials Materials and Chemical Engineering Branch Division of Engineering
Enclosure:
As stated cc:
B. Sheron G. Millman J. Strosnider y-HV T <If3Mf 1
Distribution:
gh/W/#f PDR DOCUMENT NAME: G:\\JLing To rective a copy of this doctament, indicate in the box C= Cow w/o attachment / enclosure E= Copy with attachtaent/ enclosure N = No copy 0FFICE DE:EMCikf/
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NAME RAHermaMadl KRWichman h IS (/96
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DATE 12/5/96
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DPAFL MEMORANDUM TO:
Keith R. Wichman, Acting Chief Materials and Chemical Engineering Branch Division of Engineering FROM:
Robert A. Hermann, Senior Level Advisor Materials and Chemical Engineering Branch Division of Engineering
SUBJECT:
SUMARY OF MEETING WITH ASME EXECUTIVES Tuesday, November 12, 1996 One White Flint North 11555 Rockville Pike Rockville, Maryland The NRC and ASME staff identified in the attached attendance list met to discuss several issues regarding the requirements of 10CFR50.55a in implementing the ASME Code. The discussions during the meeting centered on the NRC Inspection Manual Part 9900 guidance on ASME Sections III and XI.
This document provides guidance on use of ASME Code Interpretations, engineering judgement and timeliness of flaw evaluations.
ISSUE: Code Interpretations ASME representatives stated that the guidance in the Inspection Manual chapter guidance is consistent with ASME's understanding of the relationship between the ASME Code and NRC regulations.
There were discussions regarding the mechanism for NRC informing ASME of code interpretations that NRC takes exception to.
It was agreed that the NRC should not establish a formal method for reviewing ASME code interpretations.
This conclusion was based primarily on the understanding that it would be tantamount to NRC becoming the interpreter of the Code.
It was agreed that any concerns NRC has regarding specific ASME code interpretations would be brought to the codes attention through the NRC staff's normal interaction with the Code.
Situations in which NRC disagrees with an ASME Code interpretation or how it is being implemented will also be identified and dealt with through the inspection process.
Finally, it was noted that, considering the large number of code cases that are issued, there have been very few cases where NRC has taken exception to ASME interpretations and that interpretations have been of great benefit. The NRC representative to Section XI will inform Section XI of the guidance in the Inspection Manual.
i CONTACT:
R.A. Hermann, NRR 415-2768 ENCLOSURE l
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'K.R.'Wichman ISSUE: Use of Engineering Judgement ASME representatives stated that the ASME code does not prohibit activities that are not explicitly addressed in the code, as long as such activities result in an equivalent level of safety. However, they also pointed out that whether explicitly addressed in the code or not, activities may be subject to t.dditional requirements by regulatory or enforcement organizations having jurisdiction at the site.
In this regard they referenced the following paragraph in the Foreword to the 1995 edition of the Code.
"The Code Committee does not rule on whether a component shall or shall not be constructed to the provisions of the Code. The Scope of each Section has been established to identify the components and parameters considered by the Committee in formulating the Code rules.
Laws or regulations issued by municipality, state, provincial, federal, or other enforcement or regulatory bodies having jurisdiction at the location of an installation establish the mandatory applicability of the Code rules, in whole or in part, within their jurisdiction. Those laws or regulations may require the use of this Code for vessels or components not considered to be within its Scope or may establish additions or deletions in that Scope. Accordingly, inquiries regarding such laws or regulations are to be directed to the issuing enforcement or regulatory body. Those laws or regulations may require the use of this Code for vessels or components not considered to be within its Scope or may establish additions or deletions in that Scope. Accordingly, inquiries regarding such laws and regulations are to be directed to the issuing enforcement or regulatory body."
The ASME representatives agreed that the NRC inspection guidance with regard to this subject was consistent with their understanding of the relationship between the ASME Code and Federal Regulations.
ISSUE: Timeliness of Flaw Evaluations The ASME representatives stated that operability determination is not an ASME Code issue and that the ASME had intentionally avoided making operability determinations a part of the code.
The Code has worked to establish rules for inspection, testing and assessment of structural integrity when the component and system is not in service.
Currently the Code is considering a change in scope to include all phases of plant operation. This is needed since many utilities are performing inspections and tests with the units operating.
It was agreed that the determination of operability is a regulatory issue.
It should be noted that 10 CFR 50.55a(g)(4) requires that Section XI be met throughout the service life of the plant.
This requirement provides the NRC's bases for use of the Code as a part of its operability determination.
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K.R.'Wichman The ASME representatives indicated they would follow up on three issues that came up during the meeting. These were:
- 1) Status of the proposed Code Case for evaluation of through wall flaws in Class 3 moderate energy systems (based on GL 90-05) j l
2)
Provide guidance to the Task Group on Operability.
Perhaps ASME should a
consider if the task group's objectives are consistent with the statement above that operability is not an ASME concern.
If the objective of the Task Group is to establish criteria for determining structural integrity components or systems, ASME may desire to modify the Task Group title to j
be more consistent with its charter.
- 3) Status of the Scope / title for Section XI.
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Attachment:
As stated i
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ASME/NRC Meeting 11/12/96 Attendance List Name Telephone G.M. Eisenberg (212) 705-8510 G.J. Pieper (815) 439-6106 R.A. Hermann (301) 415-2768 June Ling (212) 705-8570 l
Keith Wichman (301) 415-2796 Patricia Campbell (301) 415-1311 Loretta Cacilia (352) 563-4546 Marsha Gamberoni (301) 415-3024 i
Gil Milman (301) 415-5843 l
Jack Strosnider (301) 415-3294 Bob Evans (202) 739-8101 Nancy Chapman (301) 417-3771 i
Kamal Manoly (301) 415-2765 l
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