ML20136G639

Forwards Dec 1983 ASME Board on Nuclear Code & Stds Position Statement on Use of multi-party Agreements.Util May Want to Resolve Code Nonconformances Using Written Agreement Between Owner,Certificate Holders & Regulatory Bodies

ML20136G639
Person / Time
Site:	Braidwood
Issue date:	05/29/1985
From:	Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20136G602	List: ML20136G598 ML20136G611 ML20136G619 ML20136G627 ML20136G639 ML20136G738 ML20136G745 ML20136G752 ML20136G769
References
FOIA-85-452 NUDOCS 8508190574
Download: ML20136G639 (2)

Text

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" N a f2 9 ',85 MEMORANDUM FOR: Charles E. Norelius, Director, Division of Reactor Projects FROM: W. S. Little, Director, Braidwood Project

SUBJECT:

BRAIDWOOD - RESOLUTION OF ASME CODE NONCONFORMANCES THROUGH MULTIPARTY AGREEMENTS Commonwealth Edison Company may want to resolve some of the Code nonconforniances at Braidwood through the use of multiparty agreements. This would allow non-conformances to be resolved based on a written agreement between the Owner, Certificate Holders, their respective Authorized Inspection Agencies, and appropriate jurisdictional and/or regulatory bodies. In effect, this allows resolution of Code nonconformances in ways not specifically addressed by the Code, but in a way agreed to by all parties.

The basis for the use of multiparty agreements is a position statement prepared in December 1983 by the ASME Board on Nuclear Codes and Standards which was subsequently accepted by the ASME Boiler and Pressure Vessel Committee and by the ASME.. Council. This position statement is described and discussed in the attachn;ent which was published in " Mechanical Engineering,"

September 1984. This method of resolution was extensively used at the South Texas Project Electric Generating Station (I have a copy of this agreement) and I understand has been used to a lesser degree at other nuclear construction sites.

I anticipate that Ceco may propose the use of multiparty agreements to resolve

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some of the MTV nonconformances, and-am issuing this memorandum to provide background information in the event that this occurs.

W. S. Little, Director Braidwood Project

- Attach. ment: ASME Position Statement cc w/ attachment:

James G. Keppler' A. 8. Davis J. J. Harrison

.D. H. Danielson J. Stevens, LPM L. McGregor j R. Schulz j M. J. Farber  !

P. R. Pelke l R. F. Warnick -

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G ASME (Codes & Ste\ncicrds

[: ASME Huclear Code-constructiors Turnover and Local Site issues

' . , . , Rogw F. Roefy and Wtteam H. Amner s Mentars of N ASW Boans on Ncheer Cases arus Stansanss' t

%e use of ASME Codes and Standarda permita the uu of en N.5 form to document might arise during site co has for produced pressure. anequipment.

retaining outsLanding To pro.safety record work partia!!y compteled and performed the treasferof Code

. prior to construction turnover,8 it does not or speci/sc corrective action on noncon/or.

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vide maximum benefits and safety, the provide for all turnover situations and no mances resulting from suork

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rnanufacturer must follow all the require. details are given in the Code for turning over

'is the sentiment of the floord on Nuclear

^i' snents of ASME Cafes and Standards as they pernal work .hich is not documented on Codes and Standards that,in these situa.

.,9 *' relate equipment.

to the design end construcdon of pardal data report forms. In some con.

fions, the determination of hoam to satisfy

, "M' Struenon turnovers, time did not permit Code requirements is best resolved through

. De ASME Code for Nuclear Components completion of Code partist data reports and . interection end- agreement b (Sec6an IIIof the Boder and Pressure Vesel other forms of documentation were used, porties involved, taking into account the o" Codelis used at nuclear construdion sites for the design and ennstruction of pressure re. ne foreword to the ASME Boiler and specifer condstanas of ahe situotion. SLeh Pressure Vessel Code states: agreements enuld include but not neces.

^ taining components, including piping sptems and their supports. %e proceu for dem* it should be pointed out that the state ne sarily be limited to the Du ner, applicable onstrating Code compliance of piping sys. municipalsty suhere the lloiter and Pressure Certrincate Holders, their respectsue Au.

tems is often more compikated than for items Vessel Code has been made e//retive has thonzed, Inspects 4n Agencies, and appew

' y,, definite jurisdiction over one particular Pn'ofe jurisdictional andlar regulatory manufactured design, febrication. eby nd e single urganisatinn.

installabon of piping %e insteHation. Inquiries dealinE with prob.

bodars.

systems often involve muluple certificate fems o/ locat character should be darected ro De ASME position statement reiterates holders, design organizations, authorized the proper authority of such state or mu. Ib' "'CTSSIIYI Of *0'k P'fIOf *'d EO "I inspection agenciss, and the owner. %e nicipality. Such authority moy.i/thereis Code requirements. This means that the interaction among these organisations can any question or doubt as to the proper in, equipment must meet the provisions of th become complicated. end if proper controls terpret ation, refer the riuestion to the lloller Code with regard to ma terials, design, fa bra,e .

are lacking, construcdon and insta!!aGon and Pressure Vessel Committee. cation, enemination, and impecuon. The ~

tirnes may be estended. ., At the December 1983 meetm.g of the fact that these provisions of the Code have Situations may arise et a site that were ASME Board on Nsclear Codes and Stan. been met tr.ust be verified and documented.

never envisioned at the time the Code rule, dards, thGsue of mtructaun turnovm and At the conclusion of construction, the re-

• were written. As a group, Code committees other related proble:ns of a local nature were sponsible ASMEcertificate holders and their' usually assume that des 4n and construction considered. Subsequently the Board for. authorized nuclear inspectors must sign will be straightforward and that allinvolved mutated the fo!!owing positson statement, documents sitesting that the work meets the' parties will perform their work according to which has been accepted by the ASME Boiler requirements of the Code.

the original contractual strangementa. and Pressure Vessel Committee and by the he poeidon statement cannot be used to However, at some nuclear sites it has beer. ASME Council: waive any required nondestructive etami.

nececary to tiensfer Code work from one N Board on Nuclear Codes and Standards natim inspdonsar m What th' en do contractor to another prior to comptedon. recognires that the Soiler and I'resare the words in the pas 46on statement.". . wrk While the Code con".ains specific pardal data Vessel Code, Section Ill, ancs not, prior nor tocompletion is it or specific correcuve ac-

.yi, reporta such as forms N.2 and NF.2, and intended to, address all situationa uJiich bon on nonconformances resul6ng from ucrk performed"mean? Dis phrase pertains to

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. ., . MECHANICAL. ENGINEERING / SEPTEMBER 9 84 /123

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@%V . . the details for resolving the nonconformance conformas.ces and/or transfer of ASME Cod

.9 *.v . - to.*.-assureare met. that the requirements of the Code attivities should involve the owner. ASME r

-E N'.*.',- . Nonconformance is deSned in NCA500 certa ;cate holders for theBoiler work and involved, their Pressure Vessel Code tends esisting w to specifi.

of Section 111. General Requiremenu, as a authorued nuclear inspectors, the NRC cally address nuclear power site construcuon.

• ..A, ,. * "denciency in a charseteristic, documenta. rep. -sentative,and representative of the ju. De purpose of this article is to e spand public

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• tjon, or prwedure that renders an item or rix.ictional authority in which the site is lo. awareness. It is hoped that this policy udvity ur. acceptable or indeterrninete." cated when that jurbdiction has a law regu.

lating the construction of nuclear plants that statement will be used oppropriately and as

. 976 his deGni6on of nonconforma nce can con. necessary to resolve concerns arising at nu.

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1. c" crivably encompana a wide tante of possi. requires conformance to the Code. After clear sites.

resoludon has been agreed upon by the re. .

bilities, both in variety and level of signdi.

.'s f cance to safety and adequacy of the equip.

spansible parties, the ASME certificate

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ment. %e prai6on statement simply states holden must document the resolu6on in a

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J , .j that the best approach in deoding what planunderstand to assure that all 1. De Boardincluding parties, on Nuclear Codes and Stan.

.Qi ASMEsurveyteams theimple. derds supervises the nuclear codes, stan-lj.$ i,*. ; * ', when needs to be done to venfy Code comphance a reporud deficaency makes the quality mentation. One obvious benefit of approv. dards, and related eccreditation ac6vi6cs of

,,;{,.., f of the itern ques 6onable or to correct a ing the plan in secordance mth the ASME the Scciety.

$*N . known defici<ncy,is to han the responsible pnaatson statement la that it provides the "

" yp; { parties agree on the p!an of action to ensure opportunity for all responsable pard-s to be 2. ASME Boiler and Pressure Vessel Code p.m, '. that the equipment meets the Code, involved in the resolutam at the appropriate Interpreta6ons. Volume 14, Interpretation j, T,..f. time.

%e speoGe details of rewlation of non. I!!.l.83161:

% w, .m. -- De posit;on stat, ment formulated by the

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