ML20163A609
| ML20163A609 | |
| Person / Time | |
|---|---|
| Issue date: | 07/07/2020 |
| From: | David Rudland NRC/NRR/DNRL |
| To: | Anna Bradford NRC/NRR/DNRL |
| Cranston G | |
| References | |
| Download: ML20163A609 (6) | |
Text
June 07, 2020 MEMORANDUM TO: Anna H. Bradford, Director Division of New and Renewed Licenses Office of Nuclear Reactor Regulation FROM: David L. Rudland, Senior Level Advisor /RA/
Division of New and Renewed Licenses Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF THE JUNE 4, 2020, PUBLIC MEETING WITH THE NUCLEAR INDUSTRY TO DISCUSS TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, SECTION 50.55a(b)(2)(xxvi) CONDITION ON PRESSURE TESTING OF CLASS 1,2, AND 3 MECHANICAL JOINTS On June 4, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held a public teleconference with representatives from the nuclear industry, including the Nuclear Energy Institute (NEI), Electric Power Research Institute (EPRI), American Society of Mechanical Engineers (ASME) and Entergy. The purpose of the meeting was to discuss the recent modification of regulatory condition Title 10 of the Code of Federal Regulations (10 CFR)
Section 50.55a(b)(2)(xxvi), pertaining to the pressure testing of Class 1, 2 and 3 mechanical joints.
The public meeting notice can be found in the Agencywide Documents Access and Management Systems (ADAMS) under Accession No. ML20153A454. The Meeting Agenda and List of Attendees can be found in Enclosures 1 and 2, respectively.
At the start of the meeting, Greg Cranston, Senior Project Manager in the Division of New and Renewed Licenses, Office of Nuclear Reactor Regulation, kicked off the meeting by welcoming all to the Category 2 public meeting and explaining the ground rules of the meeting. He reinforced that the meeting was an information gathering dialogue only and as always for NRC public meetings, no regulatory decisions will be made. Luis Betancourt, Technical Assistant in the Office of Nuclear Reactor Regulations, provided instructions for using WebEx during the meeting.
CONTACT: David L. Rudland, Ph.D.
Senior Technical Advisor for Materials NRR/DNRL
D. Rudland After the introductions, David Rudland, Senior Technical Advisor for Materials in the Division of New and Renewed Licenses, Office of Nuclear Reactor Regulation, presented the history of the condition evolution and the NRC staffs intent for both the original and revised condition of 10 CFR 50.55a(b)(2)(xxvi). The slides for this presentation can be found in ADAMS under accession number ML20155K866. The conclusions included:
- The NRC staffs position is that pressure testing of mechanical joints after a repair/replacement activities, is required. That position has not changed.
- The NRC staffs intent in the 2015/2017 change to the condition was to clarify what code edition was required for pressure tests items such as VT-2 qualification, etc.
- Some of the items in IWA-4540(b) may not be consistent with the NRC staffs intent.
Tom Basso, NEI, began a presentation from the industry. The slides for this presentation can be found in ADAMS under accession number ML20155K866. Mr. Basso provided opening remarks that focused on the impacts that this condition change has had on plants currently in outages and those planning future outages. He stated that several people from the industry would give examples of technical, timeliness and burden impacts from this condition change.
Joe Weicks, Entergy, provided details regarding the problem statement. A copy of the problem statement can be found in ADAMS under accession number ML20155K877. Mr. Weicks began his portion of the meeting by going over the condition wording and described the words in the revised condition that were causing the confusion over the exemptions of IWA-4540(b).
Mr. Weicks stated that the words, disassembled and reassembled during the performance of a Section XI repair/replacement activity requiring documentation on a Form NIS-2, gave the impression that the exemptions in IWA-4540(b) were no longer in effect. Mr. Weicks also gave several examples where ASME had made interpretations on exempt items prior to removing the IWA-4540(c) requirement. For instance, Mr. Weicks used the example of replacement bolting, which in 1996 was determined by ASME interpretation, not to require a pressure test. He stated that ASME had determined that a pressure test would not challenge the integrity of the bolts and was therefore not needed. Mr. Weicks also stated that since ASME Section III does not require pressure testing of bolts,Section XI should not either.
Rick Swayne, ASME Section XI Chair, confirmed Mr. Weicks assertion. The NRC staff asked why bolting was not included in the code language of IWA-4540(b) in earlier editions of the code if that was ASMEs interpretation. Mr. Weicks and Mr. Swayne confirmed that since Section III did not require it, it was assumed it was not needed in Section XI. Mr. Weicks argument was if the NRC did not take a direct position on pressure tests after replacing bolts at the time this condition was placed, the industry assumed they agreed with the ASME interpretation.
There was much discussion about the disassembly and reassembly of the bolted connection and the need to pressure test. Mr. Weicks and Mr. Swayne gave many examples of times when bolted joints were opened for either inspection or internal repair activities where pressure tests were not conducted. Some of these examples include: inner diameter cladding repair, valve disc replacement, seal welds, ID corrosion repair, etc. As part of this discussion, Bill Holston, Emc2 - NRC contractor, sought clarification of the use of the term made in IWA-4540(c),
Mechanical joints made in the installation of pressure retaining items. Mr. Weicks commented the term made in the context of the ASME Code Committee interpretation was
D. Rudland when the repair/replacement was performed on the joint itself, i.e., a flange was replaced.
Mr. Swayne confirmed that this was the correct interpretation and cited a Code Inquiry, XI-1-95-48 as confirmation. Mr. Swayne stated that if the flange was replaced, a pressure test was required. Otherwise, it was not required.
Marc Hall, Dominion, presented several examples from his plants of components that would need pressure testing due to this change. He stated that he has two plants in outage now and 12 items from those outages that would need pressure tests. In addition, 50 additional items would need pressure testing in the fall outages. Items he listed included: bolting replacements, non-through-wall ID repairs, bolted manways, cladding repairs, valve body and bonnet seal welds, and flange surfaces.
Heather Malikowski, Exelon, stated that for the Exelon fleet there were 21 units that would require 600 additional work orders to be developed due to this condition change. Mr. Basso states that in total the cost to the industry could be on the order of $20-$25 million/year from this change.
Gary Park, Iddeal Solutions, gave an example of a relief request granted to a licensee in the 2000-2002 timeframe that implied they only needed to perform the pressure test for those mechanical connections that were disassembled and reassembled during the course of a Repair/Replacement Activity that included a replacement of one of the mating flanges. The NRC staff requested that the reference for this safety evaluation be sent to the NRC staff.
Mr. Basso asked if it was the NRC staffs intent to add requirements by modifying this condition.
The NRC staff stated that the intent of the revision was to clarify what code edition was needed for items such as VT-2 qualification. It was not the NRC staffs intent to change their position on pressure testing of mechanical joints. Mr. Basso asked what process could be used to clarify the condition and suggested a Regulatory Issue Summary (RIS). The NRC staff stated that the staff needed to take the information from todays meeting, and revisit with the Office of General Council, the staffs intent for the original condition, and determine the best communication method for the path forward. The NRC staff are always open to consider alternatives via 10 CFR 50.55a(z)(2) as long as the hardship is aligned with the safety significance of the inspection.
Rob Taylor, Deputy Office Director, Office of Nuclear Reactor Regulations, commented that the NRC understands the burden that this revised condition placed on the industry, and following our principles of good regulation, we would commit to developing a path forward within two weeks and communicating that through an efficient process. He did explain that if the path forward involved a RIS, our process may take a while to complete. He also stated that the NRC staff would be creative and consider all legal avenues for this communication, e.g., alternatives, enforcement discretion, etc.
During the public comment period, Mark Pyne, Duke Energy, and Leo Seaman, First Energy, provided additional hardship and hidden costs related to this revised comment. Mr. Pyne also commented that meetings like this should be held more often to make sure both the industry and the NRC are aligned on meaning of conditions and how public comments are addressed.
After the public comment period, the NRC staff and NEI made closing statements thanking everyone for the information presented at the meeting. The meeting was adjourned at 11:00 am Eastern Standard Time.
- via e-mail NRR-106 OFFICE NRR/DNLR NRR/DNRL/NRLB: LA NRR/DNRL/EPNB NAME DRudland CSmith* MMitchell*
DATE 06/11/2020 07/07/2020 07/07/2020 OFFICE NRR/DNRL/EPNB NRR/DNRL/NRLB NAME KHoffman* GCranston*
DATE 07/07/2020 07/07/2020 U.S. NUCLEAR REGULATORY COMMISSION JUNE 4, 2020 CATEGORY 2 PUBLIC TELECONFERENCE WITH NUCLEAR INDUSTRY TO DISCUSS 10 CFR 50.55a(b)(2)(xxvi), CONDITION ON PRESSURE TESTING OF CLASS 1,2, AND 3 MECHANICAL JOINTS Meeting Agenda June 4, 2020 09:00 a.m. - 11:00 a.m.
Time Topic Organization 9:00 a.m. - 9:05 a.m. Introductions U.S. Nuclear Regulatory Commission (NRC) 9:05 a.m. - 9:20 a.m. History/Intent of Condition NRC 9:20 a.m. - 10:00 a.m. Industry Position NRC/NEI/ASME 10:00 a.m. - 10:45 a.m. Discussion of Condition NRC/NEI/ASME 10:45 a.m. - 11:00 a.m. Public Comments All 11:00 a.m. Adjourn All Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION JUNE 4, 2020 CATEGORY 2 PUBLIC TELECONFERENCE WITH NUCLEAR INDUSTRY TO DISCUSS 10 CFR 50.55a(b)(2)(xxvi), CONDITION ON PRESSURE TESTING OF CLASS 1,2, AND 3 MECHANICAL JOINTS List of Attendees June 4, 2020 NAME AFFILIATION Dave Rudland U.S. Nuclear Regulatory Commission (NRC)
Rob Taylor NRC Keith Hoffman NRC Greg Cranston NRC Luis Betancourt NRC Bill Holston Emc2 Tom Basso Nuclear Energy Inc.
Rick Swayne Reedy Engineering, Inc.
Joe Weicks Entergy Marc Hall Dominion Heather Malikowski Exelon Gary Park Iddeal Solutions Mark Pyne Duke Energy Leo Seaman First Energy Enclosure 2