ML20195G756
| ML20195G756 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1987 |
| From: | Shao L Office of Nuclear Reactor Regulation |
| To: | Bosnak R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| Shared Package | |
| ML20150E547 | List: |
| References | |
| FRN-52FR24015, RULE-PR-50 AC29-2-09, AC29-2-9, NUDOCS 8712020339 | |
| Download: ML20195G756 (4) | |
Text
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November 25, 1987 MEMORANDUM FOR: Robert J. Bosnak, Deputy Director Division of Engineering Office of Nuclear Regulatory Research FROM:
Lawrence C. Shao, Director Division of Engineering and Systems Technology Office of Nuclear Reactor Regulation
SUBJECT:
INTEROFFICE REVIEW 0F THE FINAL RULE FOR 10 CFR 50.55a TO UPDATE REFERENCES T0' EDITIONS AND ADDENDA 0F SECTION III, DIVISION 1 AND SECTION XI, DIVISION 1, OF THE ASME B0ILER AND PRESSURE VESSEL CODE In accordance with your request of October 22, 1987, the staff of DEST has a
reviewed the Final Rule for 10 CFR 50.55a and the related regulatory analysis. We recommend that RES take appropriate action to revise the Final Rule prior to publication.
Specific comments, proposed revisions and the technical basis for the recomendations are provided in the attachment.
These issues have been discussed with the RES Task Leader.
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awrence C. Shao, Director Division of Engineering and Systems Technology
Enclosure:
As stated cc:
T. Murley J. Sniezek R. Starostecki J. Richardson C. Y. Cheng L. Marsh G. Bagchi C. Serpan G. Millman W. Hazelton K. Wichman F. Hebdon M. Hum
Contact:
M. Hum, EMTB/ DEST X-27694 XS 27/2@Zf ?Is/f, A
4 INTEROFFICE REVIEW OF THE FINAL RULE FOR 10 CFR 50.55a DIVISION OF ENGINEERING AND SYSTEMS TECilN0 LOGY OFFICE OF NUCLEAR REACTOR REGULATION BACKGROUND Ar. interoffice review of the Final Rule for 10 CFR 50.55a was requested in a RES memorandum dated October 22, 1987. The objective of the rule is to incorporate into the regulations by reference later editions and addenda of the ASME Code. The 60-day public connent period of the proposed rule closed on August 25, 1987. The Final Rule addresses the public comments received from three individuals.
STAFF EVALUATION The review by the Division of Engineering and Systems Technology, NRR, determined that the Final Rule is acceptable with the following conditions.
r1.
Issue:
The Final Rule must be revised to maintain a uniform extent of inservice inspection of ASME Code Class 2 piping welds.
Final Rule: paragraph 50.55a(b)(iv)(B)
Technical _ Ba_si_s:
If the Final Rule is published as defined in the October 22, 1987 memorandum, the extent of examination of piping welds will be reduced from the existing requirements by approximately a factor of four when applying the 1986 Edition of ASME Section XI. The Commission has always intended to maintain the size of the sample.
In this edition, Table IWC-2500-1, Examination Categories C-F-1 and C-F-2, require a 1.5% sample of certain pipino welds selected from all ASME Code
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Class 2 systems during each inspection interval.
ImplementiKg~10 CFR 50.55a (b)(iv)(B), specifically ASME Section XI paragraph IWC-2411, the selection of the 7.5% sample can be frcm a sinole redundant loop, t econnendation: A restriction should be added to paragraph 50.55a(b)(iv)(B)
R limiting applic.ations to editions and addenda up to the 1983 Edition through the Summer 1983 Addenda of Section XI of the ASME Code.
- 2.
Issue; The Final Rule should be revised to express the normal citation of ASME Code editions and addenda.
Final Rule:
paragraphs 50.55a(b)(1) and (2)
Technical Basis: Althouoh a licensee familiar with the ASME Code could understand the proposed terminology, the reference in the rule is different from the normal convention.
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, -Becommendation_: The subject paragraphs should be changed to the following:
(b)
(1) As used in this section, references to Section III of the ASME Boiler and Pressure Vessel Code refer to Section III, Division 1, and 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 Vessel Code refer to Section XI, Division 1, and include editions through the 1983 Edition and Addenda through the Winter 1985 Addenda and the 1986 Edition, subject to the following limitations and modifications:
This recommendation is essentially the same as or.e of the written public comments. The "Supplementary Information" should be revised to agree with the commentor.
((3)
I_s sue _: The regulatory analysis is ambiguous in stating that 50.55a presently endorses all editions through the 1983 Edition for ASME Section XI, Division 1.
Reaulatory Analysis:
page 3, paragraph 1.
Technical Basis _: The Commission never intended to reference the Winter 1975, Summer 1976 and Winter 1976 addenda of ASME Section XI in the regulations.
?Reconnendation: The "Supplementary Information" should be revised to clarify the conmission's position on Section XI addenda that are not acceptable for use.
A(4)
_I_s s ue : The Code now contains provisions that could result in confusion when implementing the regulations.
ASME Section XI: paragraphs IWA-2411 "Preservice Inspection" and IWA-2412 "Initial Inspection Interval,' 1986 Edition.
Technical Basis: The 1986 Edition of ASME Section XI has the followino requirements:
IWA-2411 Preservice Inspection The inspection plan for preservice inspection shall comply withtheEdigionandAddendaofthisDivisionthathas been adopted by the regulatory authority 36 months prior to the docket date of the f acility's construction permit,7 or subsequent Editions and Addenda that have been adopted by the regulatory authority.
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. IWA-2412 Initial Inspection Interval The inspection plan for the initial inspection interval shall comply with ghe Edition and Addenda of this Division that has been adopted by the regulatory authority 36 months after the date of issuance of the construction permit or subsequent 2
Editions and Addenda that have been adopted by the regulatoty authority.
Refer to 10 CFR 50, Article 50.55a.
A comparison of the published Code requirements with the regulations shows that a Code edition 36 months after to the docket date of the facility's j
construction permit is much earlier than the requirements of 10 CFR 50.55a(g) for the initial inspection interval. The option provided by the Code to use i
the subsequent editions referenced in the regulations could be interpreted as j
requiring the updating of programs to Code editions later than required by 10 CFR 50.55a(g).
R_econnendationi The "Supplementary Information" should be revised to state that the most restrictive requirements of the regulations or the Code apply.
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j0NCLUSIONS:
The Final Rule and the related regulatory analysis are acceptable with the exception of the issues identified.
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