ML20150E789

Discusses CRGR Review of Final Rule to Amend 10CFR50.55 Re Codes & Stds.Comments Were Received from Three Individuals During Public Comment Period,Which Expired on 870825 & Most of Their Suggestions Were Incorporated in Final Rule.W/Encl

ML20150E789
Person / Time
Issue date:	02/22/1988
From:	Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Jordan E Committee To Review Generic Requirements
Shared Package
ML20150E547	List: ML20150E543 ML20150E699 ML20150E717 ML20150E745 ML20150E768 ML20150E789 ML20150E799 ML20150E817 ML20150E820 ML20150E825 ML20150E828 ML20151E040 ML20195G742 ML20195G756
References
FRN-52FR24015, RULE-PR-50 AC29-2-07, AC29-2-7, NUDOCS 8807150298
Download: ML20150E789 (36)

Text

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. P.Z>R FEB 2 21998 MEMORANDUM FOR: Edward L. Jordan, Chaiman ,

Committee to Review Generic Requirements .

FROM: Eric S. Beckjord, Director Office of Nuclear Regulatory Research

SUBJECT:

CRGR REVIEW OF FINAL RULE TO AMEND 10 CFR 50.55a, CODES AND STANDARDS RULE I

REFERENCES:

(1) Memorandum, J. H. Sniezek to E. S. Beckjord, on CRGR review of proposed amendment to 10 CFR 50.55a, dated February 13, 1987.

(2) Memorandum, E. L. Jordan to V. Stello, Jr., on CRGR review of proposed amendment to 10 CFR 50.55a dated June 1, 1987.

(3) Memorandum, E. S. Beckjord to J. E. Zerbe, on CRGR review of proposed amendment to 10 CFR 50.55a, dated -

April 13, 1987.

Section 50.55a incorporates by reference Division 1 rules of Section III, "Rules for Construction of Nuclear Power Plant Components" and Division 1 rules of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components" of the ASME Code. This final rule updates the references to editions and addenda of these sections of the ASME Code. The final rule and supporting regulatory analysis are provided in Enclosures 1 and 2.

Reference 1 specifies that the CRGR should review this an ndment to 10 CFR 50.55a. l The proposed rule that preceded this final rule was reviewed by the CRGR at  !

its meeting No. 115 on May 27, 1987. Reference 2 recomends, as a result of I that meeting, that the proposed amendment be issued for public coment. The proposed amendnient was pub?ished in the Federal Register on June 26, 1987.

The public comment period tvpirad August 25, 1987.

Coments were received from three individuals during the public coment period.

Two of the individuals supported the proposed rule and provided suggestions for cl6rifying the proposed amendment. Most suggestions were incorporated into the final rule. The resolution for one of these coments resulted in recognition  ;

of certain improvements made to Section XI in the area of Class 2 pipe weld '

examinations by amending the rule to limit the need to implement an existing NRC modification for Class 2 piping examinations. The third individual had a general concern with NRC's policy of endorsing national standards and preferred that NRC develop its own requirements. The response to each of the comenter's concerns is provided in the Supplementary Infonnation portion of the final rule  ;

(Enclosure 1) and in a. separate- sumary in Enclosure 3. With regard to the '

71 298 880708 50 52FR24015 PDR t

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-?. FEB 2 2 gggg last commenter's concern, it was explained that NRC's implementation of the ASME Code is consistent with OMB circular No. A-119 (Revised), which provides policy and administrative guidance to federal agencies regarding participation in the development and use of voluntary standards. None of the coments received expressed any specific concern regarding implementation of the later edition and addenda of the ASME Code.

The final rule and regulatory analysis have been approved by NRR. AEOD, OSP, ARM, and OGC. The regulatory analysis includes a discussion in Section 4(b)2 on the compatibility of the proposed amendment with the existing and proposed generic letters and technical basis document (i.e., NUREG-0313), that address the inspection of BWR stainless steel piping. In addition, the regulatory analysis in Section 4(b)3 summarizes the staff position, in which the OGC has previously concurred (Reference 3), that this amendment to 10 CFR 50.55a should ~

not be subjected to the backfit provisions in 10 CFR 50.109.

It is requested that the CRGR schedule a meeting to review the enclosed final rule for the purpose of recomending to the E00 that this final rule be approved for publication.

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Eric S. Beckjord, Director Office of Nuclear Regulatory Research

Enclosure:

As stated Distribution:

EMEB r/f E. Beckjord G. Arlotto R. Bosnak M. Vagins G. Millman J. Richardson L. Shao C. Cheng W. Hazleton A

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D/DEp a UTC: EMEB ce u N: EMEB :DD/DE :D:RES  :  :

NAME:GMillman/cb fIx:MVagins :RBosnak  : #rktto :EBeckjord:  :

DATE:2/s'l /88 F Y2//f /88 :?/A /88 i

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Enclosure 1 ,

NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Codes and Standards for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.

Final rule.

ACTION:

SUMMARY

The Comission is amending its regulations to incorporate by reference the Winter 1984 Addenda, Summer 1985 Addenda Winter 1985 Addenda, and 1985 Edition of Section III, Division 1, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), and the Winter 1983 Addenda, Sumer 1984 Addenda, Winter 1984 Addenda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section XI, Division 1, of the ASME Code. A limitation is placed on the use of paragraph IWB-3640 as contained in the Winter 1983 Addenda and Winter 1984 Addenda of Section XI, Division 1. This limitation requires that for certain types of welds, IWB-3640 when implemented shall be used as modified by the Winter 1985 Addenda. In addition, the existing irodification pertaining to the inser-vice inspection of pressure retaining welds in ASME Code Class ? piping  !

has been revised to limit its applicability up to the 1983 Edition with  !

addenda up through the Sumer 1983 Addenda. The sections of the ASME Code l

being incorporated by reference provide rules for the construction of light-water-cooled nuclear power plant components and specify requirements k

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for inservice inspection of those components. Adoption of these amendments would permit the use of improved methods for construction and inservice inspection of nuclear power plants. ,

EFFECTIVE DATE: . The incorporation by reference of certain publications listed in the regulations is approved by the Office of the Director of the Office of the Federal Register as of .

FOR FURTHER INFORMATION CONTACT: Mr. G. C. Millnen, Division of Engineer-ing, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission. Washington, DC 20555, Telephone: (301)492-3872.

SUPPLEMENTARY INFORMATION: On June 26, 1987, the Nuclear Regulatory Com-mission published in the Federal Register (52 FR 24015) a proposed amendment to its regulation,10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities," to update the reference to editions and addenda i

of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASMECode). This amendment revises 5 50.55a to incorporate by reference all editions through the 1986 Edition and all addenda through the Winter 1985 Addenda that modify Division 1 rules of Section III, "Rules for the Construction of Nuclear Plant Components," and, subject to certain limitations and modf #ications, addenda through the Winter 1985 Addenda that modify Division 1 rules of Sections XI, "Rules for the Inservice Inspection l of Nuclear Power Plant Components " of the ASME Code. Specifically, this amendment to 6 50.55a incorporates by reference the Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Division 1 2

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rules of Section III, and the Winter 1983 Addenda, Sumer 1984 Addenda, Winter 1984 Addenda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Division I rules of Section XI of the ASME Code. The 1986 Edition is equivalent to the 1983 Edition, as modified by the Sumer 1983 Addenda, Winter 1983 Addenda, Sumer 1984 Addenda, Vinter 1984 Addenda, Sumer '1985 Addenda, and Winter 1985 Addenda. The Sumer 1984 Addenda and Sumer 1985 Addenda for Section XI do not include technical requirements, but are included in the reference to prevent the confusion that might occur with a lack of continuity in the addenda references. .

Interested persons were invited to submit written coments for con-sideration in connection with the proposed amendment by August 25, 1987.

Coments were received from three individuals in response to the notice of proposed rulemaking. Two of the comenters were in favor of the pro-posed rule, and submitted suggestions for editorial clarifications. One of these comenters was concerned that the manner proposed for specifyin9 the endorsed editions and addenda in il 50.55a(b)(1) and (b)(2) was poten-tially confusing for this specific amendment because the latest addenda that is specified does not modify the latest edition that is specified (i.e., the Winter 1985 Addenda modifies the 1983 Edition). The staff agrees with the commenter and has modified paragraphs (b)(1) and (b)(2) to make it clear that the Winter 1985 Addenda applies to the 1983 Edition, and that the 1986 Edition is the latest ASME Cude update being incorporated by reference into the regulation.

The other commenter in favor of the proposed rule believes that the pro-posed additional sentence in i 50.55a(b)(2)(1) which specifies a limitation ,

I on the use of IWB-3640 for certain addenda should be provided for clarity l

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in a separate paragraph. The staff has considered and adopted this suggestion. In this final rule, the specified limitation is contained in anewparagraph(b)(2)(v). This commenter also reconcended a , revision to Footnote 6 to clarify details regarding implementation of the code cases specified in the identified regulatory guides. It is the opinion of the staff that the rule should not be cluttered with such information. There-fore, that proposed revision has not been incorporated into the final rule.

However, the staff is considering incorporating additional information directly into the regulatory guides to clarify their use. ,

Additionally, this commenter noted that the Winter 1983 Addenda to Section XI included significant improvements to the inservice inspection of Class 2 piping. This comment is correct. In particular, the rules specified in that addenda satisfy NRC staff concerns associated with the rules specified in earlier addenda for the examination of pressure retain-ing welds in ASME Code Class 2 piping, including residual heat removal systems, emergency core cooling systems, and containment heat removal -

systems. The staff previously addressed these concerns by specifying a modificationin650.55a(b)(2)(iv),whichrequiredthattheextentof examinations for pressure retaining welds in ASME Code Class 2 piping be determined based upon specific rules in the 1974 Edition and Addenda l through the Summer 1975 Addenda. Although the commenter did not make the point specifically, the proposed rule should have recognized the improve-  ;

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ments in the Winter 1983 Addenda by incorporating a revision to limit the j l

applicability of the required existing modification specified in l l

paragraph (b)(2)(iv) to ASME Code editions and addenda up to the 1983 Edition with addenda up through the Summer 1983 Addenda. This final rule 4

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• i incorporates this limitation to the use of the modification specified in paragraph (b)(2)(iv).  ;

The third comenter opposed the proposed amendment. That connenter believes that the NRC should not rely on industry standards, but rather I should develop its own standards based upon NRC experience and data. NRC practice is to utilize national standards, such as the ASME Code, whenever possible to define acceptable ways of implementing the NRC's basic safety I regulations. This is consistent with OMB Circular No. A-119 (Revised)I ,

which provides policy and administrative guidance to federal agencies regarding participation in the development and use of voluntary standards.

Consistent with this policy, the NRC staff participates actively in the development of many national standards, including the ASME Code, to ensure that NPC experience and data is part of the information base used to sup-port development of the standard. Although the NRC staff is heavily involved in the development of the ASME Code, endorsement of the ASME Code by the FPC without exception is not an automatic action as evidenced  ;

by the existing limitations and modifications specified in i 50.55a(b)(2) and the new limitation specified in paragraph (b)(2)(v) by this final rule. j l

Paragraph IWB-3640 was incorporated into the Winter 1983 Addenda of Section XI, Division 1, to provide procedures and acceptance criteria for determining the acceptability for continued service of austenitic stain-less steel piping with flaws in excess of the allowable indications spec-1 ified in IWB-3514.3. Concern was expressed by the NRC staff and others I that IWB-3640, as presented initially in the Winter 1983 Addenda, did not provide an acceptable level of margin against failure for materials with i I Single copies of OMB Circular No. A-119 may be obtained from the OMB l

Publications Office, 7?6 Jackson place, NW, Washington, DC, 20503 Telephone (202) 395-7332, 5

low toughness, such as might occur in fluxed welds (i.e., submerged arc welds (SAW) or shielded metal arc welds (SMAW)). One concern with low toughness materials was that such materials might fail at loa,d levels below limit load. Additionally, there was concern that secondary stresses, which were not included in the stress analysis procedures required by IWB-3640, might contribute to the failure of low toughness materials.

The ASME established a special task group to address the concerns associated with paragraph IWB-3640 as contained in the Winter 1983 Addenda. In the interim, the NRC staff required that licensees utilizing the procedures and acceptance criteria of IWB-3640, as contained in the Winter 1983 Addenda, apply additional safety factors in their analyses to be submitted to the staff to account for the abeve concerns. NRC staff acceptance criteria were provided in Generic Letter 84-11. "Inspections of BWR Stainless Steel Piping..?

In the opinion of the NRC staff, the concerns associated with material toughness have been adequately addressed by the ASME Code with the modi-fication to paragraph IWB-3640 in the Winter 1985 Addenda. This addenda provides specific acceptance criteria for SAW and SMAW type welds, and these criteria address the concerns associated with limit load and the need to incorporate secondary stresses in the evaluation.

This anendment to 5 50.55a incorporates a limitation in paragraph (b)(2)(v) that allows for the use of paragraph IWB-3640, as contained in the Winter 1983 Addenda and Winter 1984 Addenda, for all applications 2

A copy of Generic Letter 84-11 is available for inspection or copying for a fee at the NRC Public Document Room 1717 H Street NW., Washington, DC.

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I permitted in that paragraph except those associated with SAW and SMAW type I

welds. For these welds, this amendment' specifies that paragraph IWB-3640, as modified by the Winter 1985 Addenda, must be used. ,

Footnote 6 of i 50.55a provides reference to the NRC Regulatory Guides that denote which ASME Code Cases have been determined to be acceptable to the NRC staff for implementation. Previously, this footnote provided reference to only Regulatory Guides 1.84 and 1.85, which denote acceptability I of Section III, Division 1, Code Cases on design and fabrication, and on i

materials, respectively. This amendment revises Footnote 6 to incorporate a reference to Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability -- ASME Section XI Division 1," which identifies the Code Cases acceptable to the NRC staff for implementation in the inservice inspection (ISI)programoflight-water-coolednuclearpowerplants. At present, the Irplementation section of Regulatory Guide 1.147 specifies that applicants should make a specific request to the NRC to use Code Cases endorsed in the regulatory guide. The next revision of pegulatory Guide 1.147 (i.e., Revision 6) will reflect the proposed change in Footnote 6 of the regulation. It will pennit the use of Code Cases endorsed 1

in the regulatory guide without a specific request to the NRC for approval. i In the interim, it is the intent of the NRC that Code Csses listed in Regulatory Guide 1.147 be used without specific application to the NRC.

This amendment further revises Footnote 6 to correct the referenced titles l

'or Regulatory Guides 1.84 and 1.85.

Paragraph 50.55a(g) provides requirements for selecting the edition and addenda of Section XI to be complied with during the preservice inspection (5 50.55a(g)(3), for plants whose construction permit was issued 7

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nn or after July 1,1974); the initial 10-year inspection interval (i 50.55a(g)(4)(1)); and successive 10-year inspection intervals (9 50.55a(g)(4)(11)). Paragraph IWA-2400 of Section XI, as revised by the Winter 1983 Addenda, incorporates rules for selecting the applicable edition and addenda of Section XI during the preservice inspection (IWA-2411); the initial 10-year inspection interval (IWA-2412); and suc-cessive 10-year inspection intervals (IWA-2413).

The criteria provided in the regulations and Section XI are effec-tively the same for the preservice inspection, and the successive 10-year ,

inspection intervals, but differ for the initial 10-year inspection interval. For the initial 10-year inspection interval, the regulations specify that inservice examinations of components and inservice tests 1

shall comply with the requirements in the latest edition and addenda of the Code incorporated by reference en the date 12 months prior to the date of issuance of the operating license while Section XI provides that the inspection plan shall comply with the Edition and Addenda of Sec- )

tion XI that has been adopted by the regulatory authority 36 months after the date of issuance of the construction permit, or subsequent Editions I

and Addenda that have been adopted by the regulatory authority. In general, i use of the Comission requirements will result in the selection of a more j recent edition and addenda than will use of the Section XI rules.

Satisfying the requirements of 5 50.55a(g)(4)(1) for the initial 10-year inspection interval will, in general, also satisfy the rules of Section XI.

It is the Commission's intent that in all cases the existing require-ments in i 50.55a(g) be the basis for selecting the edition and addenda cf Section XI to be complied with during the preservice inspection, the 10-year inspection interval, and successive 10-year inspection intervals.

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Subsection IWE, "Requirements for Class MC Components of Light-Water Cooled Power Plants," was added to Section XI, Division 1, in the Winter 1981 Addenda. However, 10 CFR 6 50.55a presently incorporates only those portions of Section XI that address the ISI requirements for Class 1, 2, and 3 components and their supports. The regulation does not currently address the ISI of containments. Since this amendment is only intended to update current regulatory requirements to include the latest ASME Code edition and addenda, the requirements of Subsection IWE would not be imposed upon Comission licensees by this amendment. The applicability of Subsection IWE is being considered separately.

ENVIRONMENTAL IMPACT: CATEGORICAL EXCLUSION The NRC has determined that this final rule is the type of action described in categorical exclusion 10 CFR 51.22(c)(3). Therefore, neither an environmental impact statement nor an environmental m essment has beca prepared for this final rule.

REGULATORY ANALYSIS l

The Comission has prepared a regulatory analysis for this amendment to the regulations. The analysis examines the costs and benefits of the alternatives considered by the Comission. Interested persons may examine a copy of the regulatory analysis at the NRC Public Document Room, 1717 H St.

NW., Washington, DC. Single copies of the analysis may be obtained from i Mr. G. C. Millman, Division of Engineering, Office of Nuclear Regulatory Research, U.S. Nuclear Pegulatory Comission, Pashington, DC, 20555,  ;

Telephone (301)492-3872.

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PAPERWORK REDUCTION ACT STATEMENT This final rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980(44U.S.C.3501etseq.).

These requirements were approved by the Office of Management and Budget, approval number 3150-0011.

REGULATORY FLEXIBILITY CERTIFICATION As required by the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),

the Comission hereby certifies that this rule does not have a significant economic impact on a substantial number of small entities. This rule affects only the licensing and operation of nuclear power plants. The companies that own these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act o- the Small Business Size Standards set out in regulations issued by the Small Business Administration at 13 CFR Part 121.

LIST OF SUBJECTS IN 10 CFR PART 50 Antitrust, Classified infomation, Fire protection, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors.

Penalty, Radiation protection, Reactor siting criteria, Reporting and recordkeeping requirements.

Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is adopting the following amendments to 10 CFR Part 50.

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PART 50 - DOMESTIC LICENSINO 0F PRODUCTION AND UTILIZATION FACILITIES

1. The authority citation for Part 50 reads as follows: ,

AUTHORITY: Secs. 102, 103, 104, 105, 161, 182, 183, 186, 189, 68 Stat.

936, 937, 938, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat.

1244, as amended (42 U.S.C. 2132, 7133, 2134, 2135, 2201, ??32, 2233, 2236, 2239,.2282): secs. 201, as amended. 202, 206, 88 Stat. 1242, as amended I?44, 1246, (42 U.S.C. 5841, 5842, 5846). ,

Section 50.7 also issued under Pub. L.95-601, sec. 10, 92 Stat. 2951 (42 U.S.C. 5851). Section 50.10 aise issued under secs. 101, 185, 68 Stac. 936, 955, as amended (42 U.S.C. 2131, 2235); sec. 102, Pub. L.

• 91-190,83 Stat.853(42U.S.C.4332). Sections 50.23, 50.35, 50.55, and ,

50.56 also issued under sec. 185, 68 Stat. 955 (42 U.S.C. 2235). Sec-tions 50.33a, 50.55a and Appendix 0 also issued under sec. 102, Pub. L 91-190, P3 Stat. 853 (42 U.S.C 4332). Sections 50.34 and 50.54 also issued under sec. 204, 88 Stat. 1245 (42 U.S.C. 5844). Sections 50.58, 50.91 and 50.92 also issued under Pub. L.97-415, 96 Stat. 2073 (42 U.S.C. ?239).

Section 50.78 also issued under sec. 122, 68 Stat. 939 (4? U.S.C. 2152).

Sections 50.80-50.81 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234). Section 50.103 also issued under sec. 108, 68 Stat. 939, as amended (42 U.S.C. 2138). Appendix F also issued under sec. 187, 68 Stat. 955 (42 U.S.C. 2237).

For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.

??73),il50.10(a),(b),and(c), 50.44,50.46,50.ts,50.54,and50.80(a) are issued under sec. 161'b, 68 Stat. 948, as amended (42 U.S.C. 2201(b));

il 50.10(b) and (c), and 50.54 are issued under sec. 1611, 68 Stat. 949, 11

as amended (42 U.S.C. 2201(1)); and 99 50.9, 50.55(e), 50.59(b), 50.70, 50.71, 50.72, 50.73 and 50.78 are issued under sec. 1610, 68 Stat. 950,

/ as amended (42 U.S.C. 2201(o)). ,

2. For i 50.55a, par: graph (b)(1), the introductory text of para-graph (b)(2), paragraph (b)(2)(iv),andFootnote6arerevisedandpara-graph (b)(2)(v) is added to read as follows:

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950.55a Codes and standards ,

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• l (1) As used in this section, references to Section III of the ASME l 4

Boiler and Pressure Vessel Code refer to Section III, Division 1, and 1

include editions through the 1983 Edition and Addenda through the Winter 1985 Addenda, and the 1986 Edition.

(2) As used in this section, references to Section XI of the ASME Boiler and Pressure 'bssel Code refer to Section XI, Division 1, and I

include editions through the 1983 Edition and Addenda through the Winter 1985 Addenda, and the 1986 Edition, subject to the following limitations j and modifications:

(iv) Pressure-retaining welds in ASME Code Class 2 piping (applies to Tables IWC-2520 or IWC-2520-1, Category C-F). (A)AppropriateCode Class 2 pipe welds in Residual Heat Removal Systems, Emergency Core Cool-ing Systems and Containment Heat Removal Systems, shall be examined. When i 12 l

applying editions and addenda up to the 1983 Cdition through the Sumer 1983 Addenda of Section XI of the ASME Code, the extent of examination for these systems shall be detemined by the requirements of paragraph IWC-1220, Table IWC-25?0 Category C-F and C-G, and paragraph IWC-2411 in the 1974 Edition and Addenda through the Sumer 1975 Addenda.

(B) For a nuclear power plant whose application for a construction pemit was docketed prior to July 1,1978, when applying editions and addenda up to the 1983 Edition through the Sumer 1983 Addenda of Sec-tion XI of the ASME Code, the extent of examination for Code Class 2 pipe _

welds may be detertnined by the requirements of paragraph IWC-1220 Table IWC-2520 Category C-F and C-G and paragraph IWC-2311 in the 1974 Edition and Addenda through the Sumer 1975 Addenda of Section XI of the ASME Code er other requirements the Comission may adopt.

(v) Evaluation procedures and acceptance criteria for austenitic piping (applies to IWB-3640). Wher, applying the Winter 1983 Addenda and Winter 1984 Addenda, the rules of paragraph IWB-3640 may be used for all applica-tons permitted in that paragraph, except those associated with submerge:'

arc welds (SAW) or shielded metal arc welds (SMAW). For SAW or SMAW, use paragraph IWB-3640, as modified by the Winter 1985 Addenda.

Footnotes to i 50.55a:

6 ASME Code cases that have been determined suitable for use by the Comission staff are listed in NRC Regulatory Guide 1.84, "Design and Code Case Acceptability -- ASME Section III Division 1," NRC Regulatory Guide l 1.85, "Materials Code Case Acceptability -- ASME Section III Division 1,"

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and NRC Regulatory Guide 1.147, "Inservice Inspection Code Case  :

1 Acceptability -- ASME Section XI Division 1." The use of other Code ,

i cases may be authorized by the Director of the Office of Nuclear Reactor -l Regulation upon request pursuant to i 50.55a(a)(3). i Dated at this day of 1988.

1 For the Nuclear Regulatory Commission.

l Victor Stello, Jr.,

Executive Director for Operations.

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• Date:

Enclosure 2 Regulatory Analysis Amendment to 10 CFR 650.55a ,

Codes and Standards Executive Sumary Section 50.55a of the NRC regulations requires that nuclear power plant owners ~

construct Class 1, 2, and 3 components in accordance with the rules pro-vided in Section III, Division 1, of the ASME Boiler and Pressure Vessel Code (ASME Code) and that they provide for and perform an inservice inspection of those componens in accordance with the rule: provided in Section XI Division 1, of the ASME Code. NRC has been mandating this requirement since shortly after initial publication of Section III and Section XI of the ASME Code in 1971. The preamble to the August 24, 1972, final rule amending 650.55a (37 FR 17021) states "As new or amended editions of applicable codes, code cases, or addenda are issued, the Comission will review them and amend the provisions of 650.55a ... as appropriate."

The mechanism for endorsement, which has been used since the first endorsement in 1971, has been to incorporate by reference the ASME Code into 650.55a. The regulatier, identifies which edition and ad 'enda of the ASPE Code have been approved by the NRC for use. At present, the NRC endorses for Section III, Division 1, all addenda through the Sumer 1984 Addenda and all editions through the 1983 Edition, and for Section XI, Division 1, all addenda through the Sumer 1983 Addenda and all editions through the 1983 Edition. This amend-ment incorporates by reference all editions through the 1986 Edition and all addenda through the Winter 1985 Addend; for both Section III. Division 1, and i i

Section XI, Division 1.

This amendment is of particular imoortance to operating plants because l 650.55a requires that licensees update their inservice examination and in- I service testing programs every ten years to comply with the requirements of I the latest edition and addenda of Section XI, Division 1, endorsed by the NRC 12 months prior to the start of the next ten year interval. This amendment is also of importance to plants preparing 'or their initial inspection interval, for these plants must comply with the latest edition and addenda of Section XI, Division 1, endorsed by the NRC 12 months prior to the date of issuance of the operating license.

The ASME Code is developed through the American National Standards Institute consensus process. This ensures that the various technical interests (e.g.,

utility, manufacturing, insurance, regulatory) are represented on the standards

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development committees and their viewpoints are addressed fairly in the stan-dards writing process. In general, revisions are made to improve the Code 1 I

by providing more detailed rules where experience indicates greater guidance is necessary, or relaxing the rules where experience shows equivalent operational safety can be maintained with a reduced burden on the licensees. The consensus process ensures that the cost and benefit of revisions to the ASME Code are properly considered from all sides and are reasonably balanced. Should the NRC staff feel that at any time in the process safety is being compromised, it )

can and has taken exception in 650.55a to the rules provided in the ASME Code. l This does not occur often, but is available to the staff when necessary.

This amendment does not conflict with any existing or proposed regulatory action. In particular, the ASME Code rules that address the criteria for i allowabie cracks in austenitic stainless steel piping provide the basis for l existing and proposed generic letters on *:he inspection of BWR stainless steel piping.

It is concluded that t'>e proposed amendment, when implemented, would result in a net increase in the overall protection of public health and safety, because it will be the improved rules that will be used in new and subsequent inservice inspection programs. Obsolete requirements will not be promulgated from inspection interval to inspection interval.

1. Statement of the Problem The General Design Criteria (Appendix A of 10 CFR Part 50) require that structures, systems, and components of light-water-reactors be designed, fabricated, erected, constructed, tested and inspected to cuality standards corrnensurate with the importance of the safety function performed. Without a set of specific rules to implement these quality standards, it would be neces-

.ary for each applicant and licensee to davelop its own program for submittal to the NPC. Each program would have to be reviewed by the staff on a case-by-case basis. This would increase significantly the licensing review time and would make inspections by the staff more difficult because of the nonstandard nature of each program.

To provide a consistent set of rules, which the industry has participated in developing, 650.55a mandates use of Section III, Division 1, of the ASME Code for construction of Class 1, P, 3 cceponents, and Section XI, Division 1 of the ASME Code for inservice inspection of these components. Section III and Section XI are implemented by applicants and licensees of all light-water-cooled reactors. The NRC first endorsed the ASME Code by reference in 10 CFR 550.55a in 1971. The ASME publishes a new edition of the Code every three years. In the past, new addenda have been published for Section III, Division 1, and for Section XI, Division 1, every six months. Since 1986, new addenda ,

have been published once 6 year. It has been a continuing policy of the l Cocrnission to update this section of the regulations to keep the references I current. In those cases where an item in the ASME Code is inconsistent with NRC criteria, an exception may be taken to endorsing that portion of the Code or supplementary criteria may be incorporated to make the item consistent with staff requirements.

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Section 50.55a presently endorses all addenda through the Sumer 1984 Addenda, and all editions through the 1983 Edition for Section III, Division 1, and all addenda through the Sumer 1983 Addenda, and all editions through the 1983 Edition for Section XI, Division 1. The purpose of this proposed rulemaking is to incorporate by reference into the regulations all addenda through the Winter 1985 Addenda and all editions through the 1986 Edition for both S'ection III, Division 1 and Section XI, Division 1.

The ASME Code is developed through the consensus process, which ensures that the various technical interests (e.g., utility, manufacturers, insurance, regu-latory) are represented on the standards development comittees and that their viewpoints are considered in the standards writing process. Endorsement of the ASME Code by the NRC provides c method of incorporating rules into the regulatory process that are acceptable to the NRC and have received industry consideration in their development.

If the NRC did not take action to endorse the ASME Code, the NRC position on trethods for construction and inservice inspection would have to be established on a case-by-case basis. If the NRC did not take action to update the ASME Code references, improved methods for construction and inservice inspection night not be implemented.

2. Obfectives This final rule amends $50.55a to:

o Incorporate by reference into 10 CFR $50.55a, the Winter 1984 Ad-denda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Section E'. Division 1, and the Winter 1983 Addenda, Sumer 1984 Addenda, winter 1904 Addenda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Section XI, Division 1, of the ASME Code.

o Require that when using paragraph IWB-3640 of Section XI, Division 1, for submerged arc welds and shielded metal arc welds the Winter 1985 Addends be used in place of the rules contained in the Wintei 1983 Addenda and Winter 1984 Adderda.

o Revise footnote 6 to incorporate a reference to R(gulatory Guide 1.147, "Inservice Inspection Code Case Acceptability --- ASME Sec-tion XI Division 1."

o Limit use of modification specified in paragraph (b)(2)(iv) for pressure-retaining welds in ASME Code Class ? piping inspections, including residual heat removal systems, emergency core cooling systems, and containment heat removal systems, to ASidE Code editions and addenda up to the 1983 Edition with addenda up through the Sumer 1983 Addenda.

3. Alternatives One alternative to incorporating by reference into NRC's regulations the up-dated requirements of Section III, Division 1, and Section XI, Division 1, and 3

noting the need to use the improveo IWB-3640 rules contained in the Winter 1985 Addenda; limiting the use of the existing modificaticn for Class 2 piping inspection rules; and making the editorial revision to Footnote 6 would be to take no action. This would mean that the NRC position on the methods for con-struction and inservice inspection contained in the latest edition and recent addenda of the ASME Code would have to be provided on a case-by-case basis; the improved rules for inspection of Class 2 piping would not be implemented, and there could be some question as to the applicability of Regulatory Guide 1.147.

A second alternative to incorporating by reference these later requirements of Section III, Division 1, and Section XI, Division 1 is to incorporate the entire text of these sections of the ASHE Code into the NRC regulations. Be-cause of the volume of these sections, this approach is not practicable.

4 Consequences

a. Costs and Benefits Incorporating by reference the latest edition and recent addenda of the ASME Code will establish the NRC staff position on these Code rules on a generic basis for applicants and licensees. This will minimize the need for case-by-case evaluations and will reduce the time and effort required for submittal preparations and license rcviews.

The cost / benefit of ASME Code revisions is balanced by the manner in which these revisions are achieved through the American National Standards Institute (ANSI) consensus process. The ANSI consensus process ensures that participa-tion in ASME Code development is open to all persons and organizations that might reasonably be expected to be directly and materially affected by the activity, and ensures that such persons and organizations shall have the op-portunity for fair and equitable participation without dominance by any single interest. Consensus is established when substantial agreement has been achieved by the interests involved. Consensus requires that all views and ob-jections be considered and that a concerted effort be made toward resolution.

ASME Code proposed revisions are published for public comment in the ASME Mechanical Engineering and ANSI Reporter publications prior to being submitted for final ASME and ANSI approval. Adverse public comments are referred to the appropriate technical committee for resolution.

The consensus process ensures a proper balance between utility, ranufacturing, regulatory and other interests concerned with revisions to the ASME Code, and ensures that the cost of implementing any Code revision is consistent with its benefit,

b. Impacts on Other Requirements (1) Effect of Amendment on Existing NRC ReauirementsSection III and Section XI have been revised, in the past, twice a year.

These revisions have been published in t,m addenda each year (i.e., Sunner Addenda and Winter Addenda). Starting in i986, there is only one addenda for each of these sections and it will be called the 19XX Addenda (e.g.,

1986 Addenda). The revisions are the result of consensus participants 4

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meeting 4 - 5 times a year for the purpose of improving the existing j rules. The revisions take into account the many lessons learned in e specific area since the development of a particular Code rule. The revisions generally fall into three categories; a) technical revisions that incorporate new rules in technical areas not previously addressed by the Code; b) technical revisions to existing rules; and c-) editorial revisions. When a technical revision is made, it may make the existing set of rules more or less rer' W Se, or may simply clarify the existing rule without changine, its intei.:. There are numerous revisions in each addenda. Appendix A provides a sumary of those revisions considered to be significant that are included in the edition and addenda affected by the proposed amendment.

In general, technical revisions are made to improve the ASME Code by providing more detailed rules where experience indicates greater guidance is necessary, or relaxing the rules where experience shows equivalent operational safety can  ;

be maintaine6 with a reduced burden on the licensee. j Relative to implementation of Section III, Division 1, 550.55a specifies that the ASME Code edition and Addenda to be applied to reactor coolant pres- ,

sure boundary (i.e., Class 1), and Quality Group B (i.e., Class 2) and Quality )

Group C (i.e., Class 3) components must be determined by the provisions of l paragraph NCA-1140 of Subsection NCA of Section III, Division 1, of the ASME i Code, but the applicable edition and addenda must be those which are in-corporated by reference in 550.55a. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and addenda dates established in the Design Specifications be earlier than three years prior to the date that the nuclear power plant construction permit is docketed. NCA-1140 further states that later ASME Code editions and addenda may be used by mutual consent of the Owner (or his designee) and Certificate Holder. Plants may implement the improved rules on a voluntary basis as they are incorporated by reference into 650.55a, but unless they make that choice, there is no additional burden associated with incorporating the proposed Section III edition and addenda.

Relative to implementation of Section XI, Division 1, 550.55a specifies that:

(a) Inservice examinations of components, inservice tests of pumps and valves, and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the ASME Code incorporated by reference on the date 12 months prior to the date of issuance of the operating license, subject to any limitations noted (550.55a(4)(i)).

(b) Similar to (a), above, for successive 120-month inspection interval it is necessary to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference 12 months prior to the start of the 120-month inspection interval, subject to any limitations noted (550.55a(4)(ii)).

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(c) If a licensee determines that confomance with certain Code require-ments is impractical for his facility, the licensee shall notify the Commission and submit information to support his determination (50.55a(g)(5)(iii)). The Comission will evaluate licensee deter-minations that Code requirements are impractical and may grant such relief and may impose alternative requirements 'giving due consideration to the burden on the licensee (50.55a(g)(6)(i)).

The existing requirements in 650.55a specified in Items (a) and (b), above, ensure that all plants perform inservice inspection and inservice test pro-grams in conformance with updated versions of Section XI of the ASME Code. The proposed smendment would update the editions and addenda that are endorsed by the NRC staff, and would thereby cause these later editions and addenda to be licensees consistent with the time constraints identified in implemented Items (a) and by(b), above.

The Winter 1983 Addenda incorporates rules for selecting the applicable edition and addenda of Section XI for use during the preservice inspection, the initial 10-year inspection interval, and successive 10-year inspection intervals. The ASME Code rules for the initial 10-year inspection interval (IWA-2412) are not the same as those provided in the regulation for the initial inspection inter-vals (9 50.55a(g)(4)(i)). In general, use of the Commission requirements will result in the selection of a more recent edition and addenda for the initial 10-year inspection interval than will use of the Section XI rules. Satisfying the Commission requirements will, in general, also satisfy the rules of Sec-tion XI. To clarify the point, the Supplementary Information to the final rule states that it is the Comission intent that in all cases the existing req Ire-ments in 5 50.55a(g) shall be the basis for selecting the edition and addenda  !

of Section XI to be complied with during the preservice inspection, the initial 10-year inspection interval, and successive 10-year inspection intervals.

The requirement in Item (c), above, provides for the submittal of relief requests by licensecs. It encures that in those cases where the generic requirements of Section XI are impractical, or are overly burdensome for a specific facility, that facility may obtain some relief from the particular requirement, provided the licensee demonstrates to the Comission that omission of the Section XI requirement believed to be impractical will not have an adverse affect on public health and safety.

The regulation presently contains a modification (6 50.55af b)(2)(iv)) to Sec-tion XI that requires the use of specific rules in the 1974 Edition and addenda through the Summer 1975 Addenda of Section XI for detemining the extent of examinations for pressure retaining welds in ASME Code Class 2 piping. The Winter 1983 Addenda to Section XI includes significant improvements to the inservice inspection of Class 2 piping that resolves NRC staff concerns associated with the above modification to Section XI rules. The final rule recognizes the improvements in the Winter 1983 Addenda by incorporating a revision to limit the applicability of the existing modification specified in 6 50.55a(b)(2)(iv) to ASME Code editions and addenda up to the 1983 Edition with t.ddenda up through the Sumer 1963 Addenda.

As noted in Appendix A, there are numerous changes in the addenda being incor-porated by reference in to $50.55a. Sorre of the changes may be considered to reduce the burden of the licensee in implementing the Code, while others may 6

increase the burden. In any event, all the revisions were developed as part of the consensus process and, therefore, have been thoroughly reviewed by all elements of the nuclear industry, as well as the NRC staff. It is fair to say that the consensus process ensures that the value of any revision to the ASME Code is balanced by its burden on the industry. .

The revisions generally improve plant safety by incorporating new rules to cover areas not previously addressed, or by revising the rules consistent with experience tc reduce the number of areas where the Code has been found to be impractical, inadequate, or insufficiently clear.

As noted above. 650.55a presently requires that licensees update their in-service inspection programs every 10 years to the Section XI rules that were endorsed by the ~ NRC 12 months prior t'o the start of the next 120-month in-spection interval. There will be a substantial increase in safety through the endorsement of the later addenda and edition, because it will be these addenda and edition 'that will be used in subsequent inservice inspection programs.

Obsolete requirements will not be promulgated from inspection interval to inspection interval.

(2) Effect of Amendment on NRC Regulatory Actions That Address the inspection of BWR Stainless Steel Piping This amendment addresses one area where an NRC regulatory action exists and where a proposed action is pending. The actions are associated with the inspection of austenitic stainless steel piping. Cracks in austenitic stain-less steel piping have been a concern since 1973 when intergranular stress corrosion cracking (IGSCC) was first noted in some BWR feedwater lines.

Since the llinter 1975 Addenda,Section XI, Division 1, has provided criteria in paragraph IWB-3514.3 for allowable indications in austenitic piping.

Because IGSCC often exceeded these criteria, the ASME Code developed supple-mental rules that pennitted evaluation and possible acceptance of these cracks for limited operating periods. These supplemental rules were incorporated into paragraph IWB-3640 in the Winter 1983 Addenda of Section XI, Division 1, to provide procedures and acceptance criteric for determining the acceptability for continued services of austenitic stainless steel piping with flaws in excess of the allowable indications specified in IWB-3514.3.

Generic letter 84-11 "Inspections of BWR 5tainless Steel Piping," was issued to provide licensees with a sumary of acticns that the staff considered an ac-ceptable response to IGSCC concerns at the time. This generic letter provided licensees with the bases for a reinspection program for piping susceptible to IG5CC. Among other things, the generic letter provides crack evaluation and repair criteria. These criteria, in part, are based upon rules provided in the Winter 1983 Addenda of Section XI, Division 1. Because of uncertainties asso-ciated with crack sizing, the staff has adopted a criteria in Generic letter 84-11 that perTnits operation with cracked welds far the time period that the cracks are evaluated to not exceed 2/3 of the limits for depth and length pro-vided in paragraph IWB-3640 of the Winter 1983 Addenda of Section XI, Division 1.

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An additional concern expressed by the NRC staff and others was that IW8-3640, as contained in the Winter 1983 Addenda, did not provide an acceptable margin against failure for low toughness materials. The ASME established a special task group to addre.is this concern. The result was a revision to IWB-3640 that appeared in the Winter 1985 Addenda. In the opinion of the NRC staff, this revision adequately addresses the concerns associated with the use'of IWB-3640 for low toughness materials. The intent of the limitation in the proposed anendment is to prevent the use of IWB-3640 rules in the Winter 1983 Addenda '

and Winter 1984 Addenda for low toughness materials, and to instead require the use of the improved rules as they are provided in the Winter 1985 Addenda.

NUREG-0313, Revision 2, "Technical Report on Material Selection and Processing i Guidelines for BWR Coolant Pressure Boundary Piping," among other things, pro- i vides updated guidelines for evaluating IGSCC cracks for limited further opera- I tion. This report, which incorporates public comments and is now in the NRC l review and approval process, states that the problem of low toughness material i has baen addressed by the Code, and that the Winter 1985 Addenda provides  :

appropriate criteria for all types of welds. 1 NUREG-0313, Revision 2, also addresses the original uncertainties associated with the ability to adequately size cracks for evaluation by IWB-3640. The NUREG points out that this issue has been addressed by the industry, with sup- i port from NRC. Recognizing that much of the uncertainty was associated with i examinations being perfomed by examiners with limited knowledge and experience in sizing IGSCC, the industry established a training and qualification program at the EPRI NDE Center in Charlotte, North Carolina.

l The staff now believes that flaw sizes can be adequately determined when both examiners and procedures are qualified by' tests provided at the EPRI NDE Center.

A Generic Letter to implement the criteria in the technical basis document, NUREG-0313 Revision 2, has been prepared and is in the review and approval process along with the subject NUREG.

IW6-3640 as presented in the Winter 1983 Addenda provides the basis for the l crack acceptance criteria specified in Generic Letter 84-11. The improvements I to IWB-3640 for low toughness materials that are contained in the Winter 1985 '

Addenda provide the basis for the preposed generic letter that would implement the staff technical findings that are provided in NUREG-0313, Pevision 2. NRR is presently using the criteria specified in the Winter 1985 Addenda on a case-by-case basis. Since the 1986 Edition of Section XI, Division 1, is a compos-ite of the 1983 Edition and all subsequent addenda through the Winter 1985 Accenda, the 1986 Edition contains the acceptable rules for base materials and low toughness materials.

(3) Application of Backfit Rule (650.109)

It is the opinion of the Office of the General Counsel that this amendments should not be subjected to the backfit provisions in 10 CFR 950.109. The rationale is that (1) the Section III, Division 1, update applies only to new construction (i.e., the edition and addenda to be used in the construction of a plant are selected based upon the date of the construction pennit and are not changed thereaf ter, except voluntarily by the licensee, (2) licensees are fully ,

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aware that $50.55a requires that they update their inservice inspection program every 10 years to the latest edition and addenda of Section XI that were incor-porated by reference in 550.55a 12 months before the start of the next inspec-tion interval, and (3) endorsir.g and updating references to the ASME Code, a national consensus standard developed by participants (including the NRC) with broad and varied interests, is consistent with both the intent an'd spirit of the backfit rule (i.e., hRC provides for the protection of the public health and safet , and does not unilaterally impose an undue burden on applicants or licensees .

(4j Impact on Requirements of Other Government Agencies implementation of the new ASME Code rules requires certain additional informa-tion collection requirements. The Supporting Statement for Information Collec-tion Requirements in 10 CFR $50.55a is provided in Appendix B.

This amendment to $50.55a affects only the licensing and operating of nuclear power plants. The companies that cwn these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexi-bility Act in the Small Business Administration at 13 CFR Part 121. Since these companies are dominant in their service areas, this amendment does not fall in the province of this Act. This final rule will have no significant ef- .

fect on a substantial number of small companies.

(5) Decision Rationale trom the above analysis it is concluded that this amendment to 10 CFR !50.55a to update the reference to incorporate the latest edition and recent addenda of the ASME Code would result in a new increase in the overall protection of public health and safety, because the improved rules would be used in new and subsequent inservice inspection programs, and would save applicants and licensees, and the NRC staff both time and effort by providing uniform detailed criteria against which the staff could review any single submission. No significant additional cost to applicants and licensees is expected as a result of NRC endorsement of the new ASME Code edition and addenda.

(6) Implementation No implementation problems are anticipated. The framework for implementation l 1s already established in both the industry and the NRC. l l

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App; nan A -

Sumary of Significant Revisions to ASME Coda Affected by Proposed Arnendrnent to 10 CFR 50.55a m: de CD:,E SECT C0tt F#A 10 Plt REVIS10R El ICEDEN t !!!-r85 NCA-4110(b! ReferencetoNQA-1 Reference to MS!/A5t'E NDA-1-1979 is updated to NWi-1983. ' Increased 2 Ill+M NB-4243 CategoryCandsiellarmeldjoints Pereits increased used of socket welded joints. RMuted 3 Ill-rES NB-4622.9 Teger bead weld repair Incr2ase in permissible depth and surf ace area of repair. Reduced

lil-ri$ NN170 Overpreswe protectign Safety relief valves can now be used for steam service. Reduced 5 !!!-TM N9-7526 Capacity certification of pressure relief valves Sase sedia sust be used for test as is expected in service. Increased i 111 < 55 !$-7732.2 Deacostration of function Incorporates fullscale testing cf pressure re!!el valves. Increased 7 !!! < 3 70-3133 Cosponents under etternal pressure . Isproved design rules for etternal pressure on conial sections. Increased

.  : II!-riS IF-?l21(b) Materialspecsforcomponentsupports Material vsed for stcps is ereepted free Subsection W. Reduced i !!!-TM hT-3324.5 Size of fillet and partial penctration welds Minieue size requirements deleted for component supports. Reduced M !!!-S*E5 IO-4134.17(c) Quality assurance records Pereits repro. of radiographs by eitrofileing and other methods. Reduced

'  !! !!!-i'i5 NCA-d?tt .M1 review of test report Clarilles need for Certificate Holder to make reports available ta ANI. No charge 12 til-FE5 :r!-4123 Erasinations Defines who is permitted to perfore visual erasinations. Reduced I; !!!-FM I&4522.7tt) Ereeptions to sandatory postweld heat treatcat Ereepts fWI ci cladding on P-Nuder I base saterial. Reduced

4 111-15; r$-7511.2 Balanced safety valves Redundant back pressure balancing de ice required. Increased

Ill-S*H W -2122 Copper alloys (cr structural eeders Copper based alleys are prchibited free use. Increase (

lt, ill-S*5 W-3322.ltcl Allcwable stresses for structural steel New design formulas for austenitic stainless steel seebers. Reduced I? I!!-S'S W-47211a) Boltholes Erpands permissible use of overstred bolt holes. ' educed 2 !!!SB IF-4715 Lotting devices list of pereissible locking devices more precisely defined. No d ange li !!!454 NCA-6430 Data Report Foros fcr coopcment supports W-2 Data Report Fora deleted, provisions added to other fores. No change

0 ll!VEa IG-6213 Attacheent of naee plates. Attachment by pressure sensitive adhesive systees pereitted. Reduced 21 !!!TE4 NB-33!9 Fatigue evaluation of stresses in openings Provides analytical method for deteretning peak stresses. N, change

'2 lil-rE4 1&7141 Installation of pressure relief devices Limits distance between pressure relief device and coepnnent. Increased 23 it-rn IWS-ZOO Erasination of full penetration welds Condit!cns for deferral of vessel nort!r erans clarilled. Increased

h 1140 IWB-3640 Evaluation procedures and acceptance criteria Provides accept. criteria for cracks in SW and SMAW austenitic piping. Increased 4 25 11465 I + 4211 Therealremovalofdefects Requiresents for sechanical resoval of ther ally processed areas. Reduced h IIMM IW-l!00 IST of pre'ssurp relief devices iReferences MSl/ASIE OM-1-1921, incorp. provisions of Code Case H-415. Increased 27 II-TE Appendir Ill llltrasonicerasinationofpipingsystens New requireeects for prep. of a ili erae procedure qual. progran plan. Increased 3 Il f 64 1 4 -5242 Visual erasination Repirgents for visual eras of systees containing barated water. Increased

i 114C JN-2232 tiltrasonic erasination Mandates use of Appendir A of Section V, Article 5. Increased M Il-r8 Appendir VI (11trasonic etasination of bolts and studs < New roles for tli of bolts and studs, incrop. prov. of Code Case N-375, increased 31 II+S3 IWA-2232(e) (11trasonic erasination Requirements for use of electronic slaulators for calibration. Increased 32 11483 IW2300ta) - Dualification of NDE personnel increases time between recertificatices of Level 111 personnel. Reduced 33 11fB3 IWA-2400 Inspectionprograe EditionsandaddendaforISIand1stISItiedtodateofCP. Reduced 24 IIM63 Iw2400 Examination and inspection latervals Clarifles requireeents for erasination and inspection intervals. No change

5 II-rB3 12-4120 Code addenda for repair procedures . Sners pereitted to use later Section Il editions for repairs. Reduced

i IITB3 I W 4120 Storage and handling of welding material Welding eaterial aust be stored and handled law uritten procedures. No change

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7 Il-r5I In-6210 Records and reports Requires a FSI sussary report prior to consercial service. No change

?! II M B3 1+2430 Nditional inservice inspections New requirements for additional eraes when flaws exceed 14,3640 limit. Reduced 5 Il493 14-Z00 Erasinationofbolting Frohibits deferral cf inspections of bolting greater than 2*. Increased

- :!-ri3 1+2500 Examination of pressure retaining welds Modifies eethod for determining stress intensity f actcrs. Reduced

( ,. 11453 1 4 - % 00 Visual erasination Defines relevant conditions and new acceptance criteria. Increased

-: 1 -~. ' ~ 3 ! & 351! Acceptancecriteriaforflangesandshell New acceptance criteria for areas near structural discontinuity. Reduced

.: tl4E3 1 6 3640 Evaluation procedures and acceptance criteria / Alternative to the requirements of !WB-3514.3 for evaluation of flaws. Reduced a liri! I W C/ H 600 Feplacetent matt <ials Replacetents say reet later editions of Construction Code. Reduced C 41 4 53 I TA 220 Corconents creest free eraeination / respts E certain coeconents within F1R, ECCS, and C6S free 151. Reduced 3

- ':ci; ! O 2500 K{ accettare standards . Now acr etante stae r k for Cla n 7 cv<t m . NW

Appendix B ,

Supporting Statement _for Information Collection Requirements in 10 CFR 550 15a yu,stification

a. Need for the Information Collection NRC Regulatters in 10 CFR 650.55a incorporate by reference Division 1 rules of Section III, "Rules for Construction of Nuclear Power Plant Components," and Division 1 rules of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). These sections of the ASME Code set forth the requirements to which nuclear power plant components are designed, constructed, tested and inspected. Inherent in these requirements are certain recordkeeping functions.

Incorporation of the Winter 1984 Addenda, Summer 1985 Addenda, Winter 1)85 Addenda, and 1986 Edition for Section III, Division 1, of the ASME Code adds the following recordkeeping requirements.

Section III o Winter 1984 Addenda NCA-8213(c); Attachment of Nameplates - Nameplates attached with pressure sensitive acrylic adhesive system must meet requirements of mandatory Appendix XXI, "Adhesive Attachment of Nameplates," which stated that Certificate Holders OA manuals contain written procedures for the application of nameplates.

NR/NC/ND-7141; Installation of Pressure Relief Devices -

Technical justification for the adequacy of the installation of such devices must be provided in the Over-pressure Protection Report.

o Summer 1985 Addenda NB-4622.11; Tem 3er Bead Weld Repair to Dissimilar Metal Welds or Buttering - lequires preparation of welding procedure specification.

o Winter 1985 Addenda NCA-8440; Data Reports, Compunent Sup) orts - New provisions require the use of NF-1 and N-5 Data Report Forms.

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NC-381?/NC-3912; Design Report - Certificate Holder must pro-vide Design Report as part of his responsibility for achieving structural integrity of atmospheric storage tanks (NC-3812) and 0 - 15 psi storage tanks (NC-3912).

o Winter 1984 Addenda No additional recordkeeping.

NC/ND-7750; Capacity Certification of Vacuum Relief Valves -

Requirement that drawings and test results are to be sub-mitted to the ASME designee for review and acceptance.

I o 1986 Edition The Sumer 1983 Addenda, Winter 1983 Addenda, Sumer 1984 Addenda, and 1983 Edition have been incorporated by refer .

ence into 10 CFR 550.55a by a previous amendment. Infor-mation collection requirements for the Vinter 1984 Addenda, Summer 1985 Addenda, and Winter 1985 Addenda are discussed above.

Incorporation of the Winter 1983 Addenda, Surmer 1984 Addenda, Winter 1984 Addenda, Surmer 1985 Addenda, Winter ]985 Addenda, and 1986 Edition for Section XI, Division 1, of the ASME Code adds the following recordkeeping recuirements.

Section XI o Winter 1983 Addenda IWA-2420; Ir.spection Plans and Schedules - Requires pre-paration of preservice and inservice inspection plans and schedules.

IWA-4210; Storage and Handling of Welding Material -

Requires written procedure for storage, handling, and control of welding material.

IWA-6210(a)/(c); Owner's Responsibility - Requires Prepara-B on of preservice inspection plans and scheoules, records, and sunnary report for Class 1 and 2 pressure retaining components and their supports.

IWA-6340(b)/(c); Inservice Inspection Records and Reports -

Reqires maintenance of preservice inspection plans, schedules, and reports.

Appndix VI (Mandatory); tiltrasonic Examination of Bolts and Studs - Recuires records of the personnel performance I The 1986 Edition of Section III, Division 1, is eouivalent to the 1983 Edition, as modified by the Sumer 1983 Addenda Winter 1983 Addenda, Surrrrer 1984 Addenda, Winter 1984 Addenda, Sumer 1985 Addenda, and the Winter 1985 Addenda.

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qualification tests, written procedures for ultrasonic examination, documentation of the procedure ovalification, calibration records, and examination recc-ds, o Summer 1984 Addenda . .

No additional recordkeeping.

l o Summer 1985 Addenda No additional recordkeeping.

o Winter 1985 Addenda IWA-2232(f); Ultrasonic Examination - Indications that can be identified as originating from surface configurations or variations in metallurgical structure of materials may be classified as geometric indications. The maximum amplitude',

location, and extent of a geometric indication shall be recorded.

2 o 1986 Edition The Summer 1983 Addenda and 1983 Edition have been incor-porated by reference into 10 CFR 650.55a by a previous amendment. Information collection requirements for the Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and Winter 1985 Addenda are discussed above.

b. Practical Utility of the Information Collection These records are used by the licensees. National Board inspec-tors, insurance companies, and the NRC in the review of a vari-ety of activities, many of which affect safety. The records are generally historical in nature and provide data on which future activities can be based. NRC Inspection and Enforcement person-nel can spot check the records required by the ASME Code to determine, for example, if proper inservice examination test methods were utilized.

c. Duplication With Other Collections of Information ASME requirements are incorporated to avoid the need for writing equivalent NRC requirements. This amendment will not duplicate the information collection requirements contcined in any other generic regulatory requirement.

2 The 1986 Edition of Section XI, Division 1, is equivalent to the 1983 Edition, as modified by the Sumrier 1983 Addenda, Winter 1983 Addenda, Sunn.er 1984 Adderda, Winter 1984 Addenda, Summer 1985 Addenda, and the Winter 1985 Addenda.

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d. Consultations Outside the NRC No consultations,

e. Other Supporting Information ,

NRC applicants and licensees have been complying with the information collection requirements of the ASME Code since 1971.

No problems with these information collection requirements have been identified to the NRC by the applicants or licensees.

2. Description of the Information Collection

a. Number and Type of Respondents In general, the information collection requirements incurred by 650.55a through endorsement of the ASME Code apply to the owners of the 27 nuclear power plants under construction and to ,

the owners of the 100 nuclear power plants in operation. The actual number of plants that would implement the edition end addenda addressed by the proposed revision, and thereby be affected by their information collection requiremer.ts, is depen-dent on a variety of factors. These factors include whether the application is for Section III or Section XI, the class and type of components involved, the date of the constructicn permit application, the schedule of the inservice inspection program, and whether the plant voluntarily elects to implement updated editions and addenda of the ASPE Code.

b. Reasonableness of the Schedule for Collecting Information The information is generally not collected, but is retained by the licensee to be made available to the NRC in the event of an FRC inspection or audit.

c. Method of Collecting the Information See Item 2(b).

d. Adequacy of the Description of the Information The ASME Code provides listings of information required and specific forms to assist, where necessary, in documenting required information,

e. Record Retention Period The retention period for information is in accordance with a schedule provided in Table NCA-4134.17-1 and paragraph IWA-6300 A-4

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of the ASME Code. Tile record retention periods for information specified in Item 1.a above are:

Information Retention Period Procedure for attachment of nameplates. 3 yrs af3er superseded Overpressure protection report. ' Lifetime Welding procedure specification. Lifetime NF-1/N-5 Data Report Forms. Lifetime Design Report for storage tanks. Lifetime Test results for vacuum relief valves Lifetime Proced, for control of welding material. 3 yrs after superseded Preservice Inspection Plan. Lifetime Ultrasonic examination records. Lifetime '

Lifetime retention of the above records is necessary to ensure  !

adequate historical information on the design and examination of components and systems to provide a basis for evaluating degra-dation of these components and systems at any time during their .

service lifetime.

3. Estimate of Burden 1

a. Estimated Hours .

The information collection requirements inherent in incorpo-rating by reference the latest edition and addenda of Sec-tion III, Division 1, and Section XI, Division 1, of the ASME Code are identified in Item 1.a above. These requirements may be categorized in terms of Section III reouirements that document component design, and Section XI requirements that address ultrasonic examinations and preservice inspection programs.

The edditional Section III requirements incur a one-time burden i on plants under construction. Section 50.55a specifies that I I

the Code Edition, Addenda, and optional Code Cases to be applied tc reactor coolant pressure boundary, and Quality Group B and Quality Group C components must be detertnined by the provisions of paragraph NCA-1140 of Subsection NCA of Section III of the ASME Code. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and addenda dates established in tile Design Specifica- i tions be earlier than tnree years prior to the date that the l nuclear power plant construction permit is docketed. NCA-1140 further states that later ASME Code editions and addenda may be used by mutual consent of the Owner (or his designee) and Certi-ficate Holder. The earliest Section 111 addenda being addressed in the proposed rule is the Winter 1984 Addenda. Since the last plant docketed in October 1974 (Palo Verde Units 1, 2, 3), there is no plant under construction for which implementation of the Section III edition and addenda specified in the proposed rule is a reovirement. Plants may implement these improved rules on a voluntary basis, but unless they make that choice, there is Service lifetime of the component or system.

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no additional paperwork burden associated with incorporating the proposed Section 111 edition and addenda.

The additional Section XI requirements incur an infonnation col-lection burden associated with the documentation of procedures for the storage, handling, and control of welding material; the documentation of preservice inspection plans and schedules; and the implementation of the ultrasonic examination of bolts and studs.

Nuclear power plants are required to update their 1r. service inspection programs by incorporating into their initial 120-month inspection interval reouirements of the latest edition and addenda of Section XI, Division 1, that have been incor-porated by reference into $50.55a as of 12 months prior to the date of issuance of the operating license; and by incorporating into successive 120-month inspection intervals -

requirements of the latest edition and addenda of Section XI that have been incorporated by reference as of 12 months prior to the start of a 120-month inspection interval. On this basis, many plants will at one time be required to implement the Section XI, Division 1, edition and addenda specified in the proposed rule. The number of plants that will be implementing the specified edition and addenda will grow gradually as each plant updates its inservice inspection program at the 10-year interval. Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified edition and addenda is 127 (i.e., 100 operating plants and 27 plants under construction).

Paragraph IWA-2420 was revised in the Winter 1983 Addenda to reovire the preparation of preservice and inservice inspection plans, to specify the content of those plans, and to require an in.plementation schedule for the performance of examination and tests. Inservice inspection plans and schedules, including those for preservice inspection are routinely submitted to the NRC as part of the regulatory process. The types of items specified for inclusion in the plan (e.g., applicable Code edition and addenda, identification of components subject to examination and test, and Code requirements for each specified component) are typically included in the plans submitted to the NRC. Therefore, there is no additional recordkeeping burden associated with the revision of IWA-24?O.

Paragraph IWA-4210 was added in the Winter 1983 Addenda to require a written procedure for the storage, handling, and control of welding material. In general, this procedure would become part of the Owner's Quality Assurance Manual. The pro-cedure would be prepared once per plant and would, like other procedures, be maintained annually thereafter. It is estimated that the time required to prepare the original procedure would be 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, and the time required to maintain the procedure would be 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / year / plant. Assuming that all plants presently operating and under construction would at sone time implement A-6

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this requirement, the total annual burden for all 127 plants, averaged over a ten-year inspection interval, would be 1524 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79882e-4 months <br /> / year for all plants (i.e. , (((100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> / plant)/10-year interval) + 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / year / plant) x 127 plants = 1524 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79882e-4 months <br /> / year total for all plants).

Paragraphs IWA-6210 (a) and (c), and IWA-6340 were revised in the Winter 1983 Addenda to clarify that "inservice inspection" included preservice, as well as inservice programs, and that Owners were responsible for preparing and maintaining preserv-ice inspection plans and schedules. Preservice inspections have been a reouirement of Section XI, Division 1, since its inception. Preservice inspection plans and schedules are rou-tinely submitted to the NRC as part of the approval process for the inservice inspection program. Therefore, there is no addi-tional recordkeeping burden associated with the revision of IWA-6210 (a) and (c), and IWA-6340. ,

Appendix VI, "Ultrasonic Examination Of Bolts and Studs" was added to Section XI, Division 1, as a mandatory appendix in the Winter 1983 Addenda. Appendix VI provides procedures for the ultrasonic examination of Class 1 and Class 2 bolts and studs.

The recordkeeping requirements of this appendix can be divided into those associated with documenting the examination proce-

- dures (i.e., initial examination development and updates) and those associated with personnel qualification records (i.e.,

test administration, taking tests and updating records). It is estimated that initial development of the examination procedures would require a one time effort for each plant of approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of a level III Examiner's time. Assuring 3 updates of these procedures during each 10-year inspection interval, it is estimated that an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> would be expended during each interval by Level III examination personnel for updating.

The burden associated with documenting the examination proce-dures per plant per 10-year inspection interval would then be 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br />. Assuming the need for three qualified ultrasonic bolting examiners per plant, and four bolting configurations a for each test, it is estimated that for each inspection inter-val, the burden associated with personnel qualification records would be a total of 304 hours0.00352 days <br />0.0844 hours <br />5.026455e-4 weeks <br />1.15672e-4 months <br /> for each inspection interval for each plant (i.e., 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of test administration,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of updating personnel records, and 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of actual testing of Level I and II technicians). The burden associated with admin-istering personnel cualification records per plant per 10-year inspection interval would then be 304 hours0.00352 days <br />0.0844 hours <br />5.026455e-4 weeks <br />1.15672e-4 months <br />. Conservatively assuming that all plants presently operating and under construc-tion would at some time implement Appendix VI, the total annual burden of the associated recordkeeping is estimated to be 10,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year for all plants (i.e., (304 + 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br /> / plant)/

(10-year interval) x 127 plants).

Paragraph IWA-2232(f) was added in the Winter 1985 Addenda to provide the conditions by which ultrasonic indications can be classified as geometric indications. The revision specifies A-7 N

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that the maximum amplitude, location, and extent of a geometric indication shall be recorded. Since such indications are nor-mally recorded in this manner, there is no additional papertork burden associated with this requirement.

b. Estimated Cost Required to Respond to the Collection Based upon the hours specified in item 3.a. it is estimated that the cost of responding to the information collection required by the Sec-tion III, Division 1, and Section XI, Division 1, edition and addenda specified in the proposed amendaent to $50.55a is a total of $701,040/

year ((10,160 + 1524. hours. x $60/ hour) for 127 plants, or $5500/ year for each plant.

c. Source of Burden Data and Method for Estimatina Burden Estimates of the paperwork burden associated with implementing the identified ASME Code revisions were obtained from utility staff inservice inspection specialists, an inservice inspection consultant to utilities, and national lab personnel engaged in inservice inspection activities.

d. Reasonableness of Burden Estimate The estimate of the burden is considered reasonable because of the reliable source of the burden data.

4. Estimate of Cost to the Federal Government NRC inspection personnel who audit plant quality assurance records l would include in their audit verification that the above records are being properly prepared and maintained. The time associated with NRC inspectors verifying these records would be extremely small when the ,

activity is performed as part of a normal quality assurance audit. I l

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Enclosure 3 Resolution of Public Coments - -

Comenter Reference Comment Resolution 1 (b)(3) The manner proposed for Concern addressed.

(b)(?) specifying the endorsed Paragraphs (b)(1) and (b)(2) edition and addenda is were modified to make it confusing for this spe- clear that the Vinter 1985 cific amendment because Addenda applies to the 1983 the latest addenda that Edition, and that the 1986 is specified does not Edition is the latest ASME modify the latest edi- Code update being incorporated tion that is specified by reference into the regu-(i.e., the Winter 1985 lation.

Addenda modifies the 1983 Edition).

? (b)(2)(i) Proposed additional Pecomendation adopted.

(b)(2)(v) sentence which specifies Specified limitation is a limitation on the use contained in a new para-of IWB-3640 for certain graph.

addenda should be provided for clarity in a separate paragraph.

Footnote 6 Proposed revision should Not directly implemented.

expand details regarding It is the opinion of the l implementation of code staff that the rule should  ;

cases specified in the not be cluttered with such identified regulatory information. However, the guides. staff is considering incor-porating additional infonnation directly into l the regulatory guides to  !

clarify their use.

(b)(2)(iv) Noted that the Winter Comment is correct.

1983 Addenda included Proposed rule modified to significant improve- limit the applicability of ments to the inservice the required existing inspection of Class 2 modification for Class 2 piping. piping weld examinations to ASPE Code editions and addenda up to the lop 3 Edition with addenda up through the Sumer 1083 Addenda.

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3 General

...resectfully Not adopted. NRC's imple-suggest that the NRC mentation of the ASME Code.

eliminate all allowance is consistent with OPB Cir-for ASME or industry cular No. A-119 (Revised),

de\ eloped codes and which provides policy and standards in the rules administrative guidance to and regulations, and the federal agencies regarding NRC shall develop their participation in the devel-own codes and standards opment and use of voluntary from NRC experience and standards. Consistent data." with this policy, the NRC staff participates actively in the development of many national standards, includ-ing the ASME Code, to ensure that NPC experience and data is part of the information base used t'o support development of the standard.

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