ML20155K866
| ML20155K866 | |
| Person / Time | |
|---|---|
| Issue date: | 06/04/2020 |
| From: | David Rudland NRC/NRR/DNRL |
| To: | |
| David Rudland-NRR/DNRL 301-415-1896 | |
| References | |
| Download: ML20155K866 (16) | |
Text
10CFR50.55a Condition for Pressure Testing of Mechanical Joints Category 2 Public Meeting June 4, 2020
Purpose, Outcome, Process
Purpose:
Understand the industry concern on the revision of 10 CFR 50.55a(b)(2)(xxvi)-Pressure Testing Mechanical Joints
- Outcome: Supply NRC staff sufficient information to consider next steps
- Process: See meeting agenda 06/04/2020 2
Meeting Agenda Time Topic Speaker 9:00am-9:05am Introduction NRC History/Intent of Condition 9:05am-9:20am NRC 10 CFR 50.55a(b)(2)(xxvi) 9:20am-10:00am Industry Position NEI/ASME 10:00am-10:45am Discussion of Condition NRC/NEI/ASME 10:45am-11:00am Public comment All 11:00am Adjourn NRC 06/04/2020 3
Original Condition - 2001/2003 Rule
- 10 CFR 50.55a(b)(2)(xxvi)-Pressure Testing Mechanical Joints
- Section XI condition: Pressure testing Class 1, 2 and 3 mechanical joints. The repair and replacement activity provisions in IWA-4540(c) of the 1998 Edition of Section XI for pressure testing Class 1, 2, and 3 mechanical joints must be applied when using the 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section.
06/04/2020 4
Statements of Consideration - 2001/2003 Rule
- Several comments on this proposed rule
- mechanical joint leakage is not prohibited by Section XI
- Section XI does not provide leakage acceptance criteria
- 1998 Edition and earlier editions and addenda of Section XI, testing is to monitor for leakage not verify the structural integrity of the pressure boundary
- Section III does not prohibit leakage at mechanical connections
- post maintenance test programs specify requirements for leak testing mechanical connections following reassembly 06/04/2020 5
Statements of Consideration - 2001/2003 Rule
- NRC statement:
- After consideration of public comments, the NRC finds that Code pressure testing of mechanical joints after repair and replacement activities is still warranted, and that reliance on programs which are not under Code jurisdiction is not an appropriate substitute for specifying Code repair and replacement requirements.
- Rule was published as is
- NRC position: pressure test of mechanical joints after repair/replacement activities are required. NPS-1 and smaller are excluded 06/04/2020 6
Condition Revision - 2015/2017 Rule
- During the ASME Section XI 2015-2017 rule making, the staff revised this condition due to confusion on what code edition was required for NDE qualification, etc.
- Initial condition wording
- When using the 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, licensees shall pressure test mechanical joints in Class 1, 2, and 3 piping and components greater than NPS-1 which are disassembled and reassembled during the performance of a Section XI activity (e.g., repair/replacement activity), in accordance with IWA-5211(a). The pressure test and examiners shall meet the requirements of the licensees/applicants current ISI code of record.
06/04/2020 7
Condition Public Comment - 2015/2017 Rule
- This condition is not necessary because the current practice of leakage testing and quality assurance (QA) program activities is adequate
- List repair or replacement activities for which the NRC requires a pressure test following assembly or reassembly of a mechanical joint
- This condition should not apply to installed items rotated from stock 06/04/2020 8
NRC Response - 2015/2017 Rule
- The NRCs continued position is that it should be a requirement that Class 1, 2, and 3 mechanical joints affected by repair or replacement activities be pressure tested in accordance with IWA-4540(c), as described in the 1998 Edition of ASME BPV Code,Section XI
- The NRC agrees with the comment that the condition should not apply to items rotated from stock 06/04/2020 9
Published Condition - 2015/2017 Rule
- Section XI condition: Pressure testing Class 1, 2, and 3 mechanical joints.
When using the 2001 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, licensees shall pressure test in accordance with IWA-5211(a) mechanical joints in Class 1, 2, and 3 piping and components greater than NPS-1 which are disassembled and reassembled during the performance of a Section XI repair/replacement activity requiring documentation on a Form NIS-2.
The system pressure test and NDE examiners shall meet the requirements of the licensees/applicants current ISI code of record
- NRC Position has not changed: pressure test of mechanical joints after repair/replacement activities are required. NPS-1 and smaller and parts rotated from stock are excluded 06/04/2020 10
Pressure Test Exemptions in Code
- IWA-4540(b) describes items that are exempt from all pressure tests
- In the 1995 edition with 1996, 1997 addendum that list contained 7 items 06/04/2020 11
Pressure Test Exemptions in Code
- By the 2017 edition, that list increased to 10 items
- Note (b)(4) and (b)(10) 06/04/2020 12
Pressure Test Questions
- Based on the understanding of the staffs intent, what exemptions do the industry interpret as excluded? Basis?
- Based on the original condition and revised version, what specific text revised the intent of the condition such as to result in an emergent issue for Owners? What is driving the timeliness of this issue?
- Per public comments, leak testing (are those done at operating pressure?) would be required by the QA program. If so, are there other impacts of the condition beyond VT-2 qualification?
06/04/2020 13
Path Forward
- Staff will consider input from industry
- Staff will re-examine the condition
- Public feedback is always welcome
- Staff will consider communication to clarify intent and path forward
- Staff are open to alternatives to 10CFR50.55a related to this topic 06/04/2020 14
Backup Slides 06/04/2020 15
ASME Section XI Code Language
- 1995 edition with 1996,
- 1998 edition with 2000,
- 2017 edition 1997 addendum 2001 addendum 06/04/2020 16