ML20136E759

Comment Supporting Proposed Generic Communication, Effectiveness of Ultrasonic Testing Systems in Inservice Inspection Programs

ML20136E759
Person / Time
Site:	Grand Gulf, Arkansas Nuclear
Issue date:	03/07/1997
From:	Hughey W ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-61FR69120 61FR69120-00016, 61FR69120-16, NUDOCS 9703130319
Download: ML20136E759 (5)

Text

. . . - . _ _ . . _ . _ - . -

a hh()f

• h0

$O h{g J h ala

"" " "N Entergy operations. inc.

PO. Box 756 gr/j ft * *** j (f ,, n U Port Gbson, MS 39150

.. Tel 601437-6470 lN.O ? 'l l (j % l 2[j W.K.Hughey l Nocear Safety & RwNat7f

^"+r5 hulEL . iira m a. c a.

March 7,1997 UStiRC 1

I l

U.S. Nuclear Regulatory Commission I Mail 5, top P1-137 l Washington, D.C. 20555-0001 Attention: Document Control Desk i

1

Subject:

Proposed Generic Communication; Generic Letter 96-XX, Effectiveness

! of Ultrasonic Testing Systems in Inservice Inspection Programs Arkansas Nuclear One - Units 1 and 2 River Bend Station Docket Nos. 50-313 and 50-368 Docket No. 50-458 I License Nos. DPR-51 and NPF-6 License No. NPF-47 Grand Gulf Nuclear Station Waterford 3 Steam Electric Station Docket No. 50-416 Docket No. 50 382 i j License No. NPF-29 License No. NPF-38 l GNRO: 97/00018 I

j Gentlemen:

l l The NRC issued the subject draft generic letter (DGL) for comment on 12/31/96.

We are disturbed by the inherent implications of this DGL and the justification l

given for the issuance of it. This letter provides Entergy Operations' comments on this preposed communication, in general, we believe that the DGL has not adequately justified the request for licensee actions cited in the DGL. In addition to Entergy Operations' comments, the Nuclear Energy Institute (NEI) provided comments on the DGL to you in a letter dated 2/21/97. We participated on the task force that developed those comments and fully endorse the NEl comments.

NEl commented on a variety of issues regarding the proposed issuance of the DGL. Entergy Operations wishes to elaborate on a couple of the points we find to l

be especially important. These include the current levels of safety, evaluation of current inservice Inspection (ISI) programs, implementation of Appendix Vill,

'O Performance Demonstration Initiative versus Appendix Vill and the upcoming 10-year updates at the Entergy Operations' sites. Each is discussed in more detail below.

^

}Qo}

9703130319 970307 OI PDR ADOCK 05000313 P"

eaaap!usmpt!i l

4-l '.

GNRO-97/00018

[ Page 2 of 6 I l

Current Levels of Safety

! The NRC recognizes that no safety concern exists that would warrant immediate l backfitting of Appendix Vill. This is based on defense-in-depth measures, Code margins in component design and leakage monitoring systems. Further; industry l experience indicates that these defense-in-depth measures provide an acceptable margin of safety to prevent catastrophic failure, it is evident that our current ISI programs provide an acceptable level of safety since no safety concern exists in the past, viable arguments have been made with statistical proof the the new j techniques allow for the better detection of flaws and more accurate sizing of those l flaws once detected; however, these improved techniques only provide added assurance of safety to an already safe situation.

Given this information, the requested action to evaluate our current ISl programs and the implied requirement to implement performance-based ultrasonic (UT) examination methods are inappropriate without furtherjustification. A backfit evaluation is the appropriate mechanism to impose new requirements although it seems unlikely that such an evaluation would be successful since no safety l concem exists and associated costs are high.

l i

l The evaluation of current ISI programs and the implementation of Appendix Vlli l are discussed in more detail below in the next two sections.

l Evaluation of Current inservice inspection (ISI) Programs l The DGL would request each addressee to perform an evaluation to determine whether its current ISI program ensures that flaws in the reactor vessel and safety-related piping are reliably detected and sized.

By this request, the NRC is essentially requesting licensees to justify the current requirements of 10CFR50.55a which endorse the Section XI ASME Code. These requirements have been mandated by the NRC; the licensee should not be required to perform an evaluation to justify their implementation. This is the NRC's l

responsibility under the rulemaking and backfit processes. The use of various codes and standards has long been accepted by the nuclear industry and the NRC as an efficient and effective way to preserve resources while maintaining an acceptable level of tafety' and the DGL presents no evidence that questions the effectiveness of the ASME Code to maintain safety.

4 The request for information is inappropriate given the justification presented in the DGL. An evaluation of the effectiveness of the ASME Code would likely result in 4

1 s ' Entergy Operations challenged this position as it related to the mandatory 10-year update

! provision by proposing a Cost Beneficial Licensing Action that would have eliminated the i

10-year update except for changes that provided a substantial safety benefit. Recently, the NRC denied the request but we are aware that the NRC is considering the use of the backfit rule in adopting later editions of the ASME Code.

. _ _ _ _ _ _ . _._ _ _ _. _ _ ._ _ _ _ _ __ _ __._ _ _ _ __ _~ _ _ _ _ _ _

GNRO-97/00018 Page 3 of 8 many manhours to prepare the response with no increased safety benefit. This request should be limited to fact-finding and not det?rmination of compliance.

l Additionally, this request appears to merely be an introduction for the main issue -

to gain a commitment from a licensee to implement performance-based methods for UT examination.

, implementation of Appendix Vill l We are aware that the NRC has been working for some time on a revision to l 10CFR50.55a which would require the implementation of performance-based l methods for UT examination. We understand that these requirements are being l evaluated under the provisions of 10CFR50.109. This is the appropriate path for implementing new requirements to ensure that the safety benefit is commensurate l with the cost to implement the new requirements.

However, the DGL implies that these requirements should be implemented in i advance of rulemaking to improve the methods in performing UT examinations.

l There is no evidence that implementation of Appendix Vill-type examinations are l necessary from a safety perspective. Since the DGL shows neither safety benefit j nor reasonable cost considerations to implement these requirements, this implication is inappropriate. Any suggestion that a licensee should implement or j justify not implementing performance-based UT methods to comply with 10CFR50.55a should be removed from the DGL. The NRC's desire to mandate performance-based UT examination methods should be evaluated against the criteria of the backfit rule.

l

! Performance Demonstration Initiative vs. Appendix Vill in the DGL, the NRC staff found that Performance Demonstration initiative (PDI) has established and is in the process of executing a well-planned and effective program to test UT technicians on selected portions of Appendix Vill. Accordingly, the NRC staff found that UT procedures qualified under the PDI program using performance demonstration methods provided an acceptable level of quality and safety.

However, PDI does not address several requirements of Appendix Villa, nor does it comply with Appendix Vill as written. PDI was formed to develop a program to perform UT examinations in accordance with Appendix Vlli but found that it could not implement Appendix Vill as writtan. Since 1994, PDI has taken over 20

. specific exceptions to Appendix Vlil and several code cases and code charps i have been processed to correct the Appendix Vill problems documented in the PDI j program. Since many Appendix Vill requirements are unreasonable and virtually

• Such as supplements 10 and 11 or the referenced Appendix ill required by Vill-3110(c) of Appendix Vlli, i

4

+ .

tr GNRO-97/00018 Page 4 of 6 Impossible to implement, PDI has become a program in the spirit of Appendix Vill.

PDI results provide inputs into the ASME Code to bring about changes to Appendix Vill; however, revision of Appendix Vill is probably several years behind the latest PDI information. Therefore, a usable Appendix Vill does not exist at this time.

While the NRC recognizes that PDI is an acceptable substitute for Appendix Vill, no approval or guidance is given for implementation of performance-based UT methods in advance of the rulemaking. Entergy Operations supports the voluntary implementation of Appendix-Vill-type methods for certain applications and believes  !

that guidance would be useful to ensure consistent implementation of these i methods. This guidance could include, as examples, reconciliation with various  !

regulatory guide commitments for certain types of examinations and the appropriate use oflWA-2240 of Section XI of the ASME Code.

Upcoming 10-year Updates at Entergy Operations' Sites By a letter dated December 12,1996, the NRC approved our request to use the 1992 Edition of ASME Section XI for our upcoming intervals. In the approval, the ,

NRC deferred review of our proposal to exclude Appendix Vill of the 1992 Edition l

of ASME Section XI and to instead follow the requirements in Appendix 1 of the  ;

1989 Code Edition which were already incorporated into 10CFR50.55a. In a letter dated January 9,1997, the NRC noted that the subject DGL had been issued for comment. Further, the NRC stated that Entergy Operations would be expected to  !

respond to the generic communication when it is issued in final and to revise our  ;

ISI programs accordingly.  !

As a rule', generic letters do not contain requirements that must be implemented by licensees. If the DGL is issued, Entergy Operations intends to evaluate our

)i options, considering cost and safety benefit. ' Depending on our evaluation, our l actions could range from proposing altematives to determining that no action is necessary, ,

i We appreciate the opportunity to comment on proposed communications and hope that you view these comments as helpful in supporting the issuance of appropriate regulatory communication. If you have any questions concoming our comments, please contact Sheri Mahoney at 601-437-6552.

Yours truly, 1

WKH/SBM cc: (See Next Page) l 3

NRC Inspection Manual Chapters 0720 and 0730 l

i .',

t I

l GNRO-97/00018 Page 5 of 6 cc: Ms. S. C. Black (NRC/NRR) l Mr. K. Cozens (NEI)

! Mr. R. B. McGehee l l Mr. N. S. Reynolds l Mr. H. L. Thomas l Mr. J. W. Yelverton l GGNS Resident inspector i

! Mr. L. J. Callan (w/2) l Regional Admin lstrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)

Office of Nuclear Reactor Regulation l

U.S. Nuclear Regulatory Commission Mail Stop 13H3  ;

Washington, D.C. 20555 I L

Chief, Rules Review and Directives Branch U. S. Nuclear Regulatory Commission

) Mail Stop T-6D-69 l Washington, D.C. 20555 l

l