ML20206K792
| ML20206K792 | |
| Person / Time | |
|---|---|
| Issue date: | 05/10/1999 |
| From: | Travers W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Powers D Advisory Committee on Reactor Safeguards |
| References | |
| SECY-99-017-C, SECY-99-17-C, NUDOCS 9905140003 | |
| Download: ML20206K792 (9) | |
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UNITED STATES 4 s* -
NUCLEAR REGULATORY COMMIS810N
\. g WASHINGTON. D.C. enmaa many May 10, 1999 Dr. Dana A. Powers, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
SECY-99-017, " PROPOSED AMENDMENT TO 10 CFR 50.55a"
Dear Dr. Powers:
In your letter dated April 19,1999, the Advisory Committee on Reactor Safeguards (ACRS) provided the results of the review of SECY-99-017," Proposed Amendment to 10 CFR 50.55a."
In SECY 99-017, the NRC staff describes a proposal to establish an applicable baseline edition of the American Society of Mechanical Engineers (ASME) Boller and Pressure Vessel Code and the ASME Code for the Operation and Maintenance of Nuclear Power Plants for inservice inspection (ISI) and inservice testing (IST) requirements at currently operating nuclear power plants. With the establishment of a baseline edition of the ASME Code, the NRC staff proposes to eliminate the requirement in 10 CFR 50.55a that nuclear power plant licensees update their ISI and IST programs every 120 months. The NRC staff briefed the ACRS and its Materials and Metallurgy Subcommittee on the proposal described in SECY-99-017 on April 7 and i March 25,1999, respectively, in the April 19 letter, the ACRS recommends against eliminating the 120-month update requirement for ISI and IST programs. The ACRS provides its view that inspection technology is not so static and mature that updating of ISI and IST programs every 120 months is unnecessary. Further, the ACRS considers the review of operational experience and
- technology changes through the ASME Code consensus process to be Important and l worthwhile such that the 120-month update provides a good baseline for inspection
- requirements. The ACRS views the projected costs of each 120-month update (up to $1 million per plant) not to be excessive considering the high costs of actualinspections and suggests that _ updating would provide more cost effective inspections and lower exposures. If the 120-month update requirement is eliminated, the ACRS proposes that all provisions of later ;
ASME Code editions or addenda be implemented where voluntarily adopted by a licensee.
{I 1
We appreciate the review of SECY-99-017 by the ACRS and the comments provided in your )
April 19 letter. As we discussed during the ACRS briefing, the reason for eliminating the 120- ,. l month update requirement is that asSection XI of the ASME Code (as well as the nuclear !
-industry) matures, the safety benefits associated with a mandatory requirement to update ISI Q_ g .
and IST programs to the latest approved edition of the ASME Code are decreasing. In fact, I many of the changes to later editions of the Code are more administrative or of only minor safety benefit. Requiring utilities to update to a later edition of the Code, without being able to clearly describe or quantify the safety benefit of such a requirement compared to the costs incurred toregulatory licensees to perform the update, is inconsistent with our goal of reduci unnecessary burden.
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Dr. Powers ~2 1
What we propose is to consider any substantial safety enhancements that may be included in newer editions of the Code. We would require only those provisions of later Code editions that pass the cost / benefit and substantial-increase-in-safety criteria contained in 10 CFR 50.109 such as Appendix Vill to Section XI.
- While we do not intend to require ISI and IST programs be updated to newer editions of the Code that are approved by the NRC, licensees will be allowed to update their programs to newer, approved editions of the Code on a voluntary basis. We believe that for some licensees, voluntary updating will prove coct/ beneficial, while for others, it might not. We further believe this approach will encourage the ASME Code committees to specifically address the safety benefits of changes proposed to the Code which they believe should be required.
As stated during the ACRS briefing, the NRC staff is collecting information on the potential I benefits and impact of the proposal to eliminate the 120-month ISI and IST update requirement {
and to establish a baseline ASME Code edition. For example, the NRC published for public comment in the Federal Register (64 FR 22580) on April 27,1999, a supplement to a previously proposed amendment to 10 CFR 50.55a that describes this proposal. In addition, the NRC staff will host a public workshop on May 27,1999, in the Two White Flint North Auditorium at the NRC headquarters office to discuss the proposed elimination of the 120-month ISI and IST update requirement and an appropriate baseline for ISI and IST requirements. The ACRS members and their staff are invited to review the specific proposal in the Federa/ Register notice and also to participate at the public workshop. The NRC staff will consider the ACRS comments in detail as part of the preparation of a final rule on the proposed amendment to 10 CFR 50.55a. I If considered helpful, we could provide more information regarding the proposed elimination of the ISI and IST update requirement at the next ACRS meeting. Further, the NRC staff will brief the ACRS on the draft final rule on the proposed amendment to 10 CFR 50.55a later in 1999.
Sincerely,
{W -
William D. Travers Executive Director for Operations cc: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield SECY
Dr. Pow 2rs 2 I
, What we propose is to consider substantial safety enhancements that may be included in newer editions of the Code. We would require only those provisions of later Code editions that pass the cost / benefit and substantial-increase-in-safety criteria contained in 10 CFR 50.109 such cs AppendixNill to Section XI.
While we do not intend to require ISI and IST programs be updated to newer editions of the Code that are approved by the NRC, licensees will be allowed to update their programs to l
I newer, approved editions of the Code on a voluntary basis. We believe that for some !
licensees, voluntary updating will prove cost / beneficial, while for others, it might not. We further )
believe this approach will encourage the ASME Code committees to specifically address the safety benefits of changes proposed to the Code which they believe should be required.
As stated during the ACRS briefing, the NRC staff is collecting information on the potential benefits and impact of the proposal to eliminate the 120-month ISI and IST update requirement and to establish a baseline ASME Code edition. For example, the NRC published for public comment in the FederalRegister(64 FR 22580) on April 27,1999, a supplement to a previously proposed amendment to 10 CFR 50.55a that describes this proposal. In addition, the NRC staff will host a public workshop on May 27,1999, in the Two White Flint North Auditorium at the NRC headquarters office to discuss the proposed elimination of the 120-month ISI and IST update requirement and an appropriate baseline for ISI and IST requirements. The ACRS members and their staff are invited to review the specific proposal in the Federal Register notice and also to participate at the public workshop. The NRC staff will consider the ACRS comments in detail as part of the preparation of a final rule on the proposed amendment to 10 ,
CFR 50.55a. I If considered helpful, we could provide more information regarding the proposed elimination of the ISI and IST update requirement at the next ACRS meeting, Further, the NRC staff will brief the ACRS on the draft final rule on the proposed amendment to 10 CFR 50.55a later in 1999, Sinceregy, .2d
. by m:am vacm William D. Travers Executive Director for Operations cc: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield SECY DISTRIBUTION: See next page DOCUMENT NAME: G:\SCARBROU%CRS499LWPD
- = SEE PREVIOUS CONCURRENCE To reewe a copy of this document. indicate in the box C= Copy w/o attachmmt/ enclosure E= Copy with attachment / enclosure N = No copy OFFICE DE:EMEB C DE:EMEB C EMEB:BC C DE:DD C DE:D C NAME TScarbrough* DTerao* Elmbro* RWessman* JStrosnider*
DATE 4/2 9/ 49 4/29/99 4/29/99 . 04/30 /99 05/03/99 OFFICE ADT NRR:D n& EDU NAME BWS on / ollins WDTra erd DATE /h/99 I/[/99 J . "h 9 j' f '); OFFICUlyRECORD COPY sIV M _
p DISTRIBUTION: Letter to Chairman Powers PUBLIC EMEB R/F EDO G19990206 EDO R/F
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- BSheron WKane JStrosnider RWessman Elmbro DTerao J TScarbrough f JSilber ACRS !
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Dr. Powers 2 l What we propose is not to' nore any substantial safety enhancements that may be included in newer editions of the Code, ther, we propose to require only those provisions of later Code editions that pass the cost /be t and substantial-increase in-safety criteria contained in 10 CFR 50.109 such as Appendix VM to Section XI.
While we do not Intend to require ISI nd IST programs be updated to newer editions of the Code that are approved by the NRC, li'oensees wili be allowed to update their programs to newer, approved editions of the Code onsa voluntary basis. We believe that for some licensees, voluntary updating will prove cost / beneficial, while for others, it might not. We further believe this approach will encourage the ASME Code committees to specifically address the safety benefits of changes proposed to the Code which they believe should be required.
\
As' stated during the ACRS briefing, the NRC staff is collecting information on the potential benefits and irnpact of the proposal to eliminate the 120-month ISI and IST update requirement
- and to establish a baseline ASME Code edition. For example, the NRC published for public comment in the Federal Register (64 FR 22580) on%pril 27,1999, a supplement to a previously proposed amendment to 10 CFR 50.55a that describe,s this proposal. In addition, the NRC staff will host a public workshop on May 27,1999, in the Two White Flint North Auditorium at the NRC headquarters office to discuss the proposed elimination of the 120-month ISI and IST update requirement and an appropriate baseline for ISI agd IST requirements. The ACRS members and their staff are invited to review the specific proposal in the Federal Register notice and also to participate at the public workshop. The NRC staff will consider the ACRS comments in detail as part of the preparation of a final rule ' the proposed amendment to 10 CFR 50.55a.
If considered helpful, we could provide more information regarding the proposed elimination of the ISI and IST update requirement at the next ACRS meeting. Further, the NRC staff will brief s the ACRS on the draft final rule on the proposed amendment to 10 CFR 50.55a later in 1999.
Sincerely, x
\
William D. Travers 1 Executive Director i for Operations cc: Chairman Jackson Commissioner Dieus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield ,
SECY DISTRIBUTION: See next page DOCUMENT NAME: G:\SCARBROU\ACRS499L.WPD
- = SEE PREVIOUS CONCURRENCE . .
To receive a copy of tNs document. Indicate in the box C= Copy w/o attachment /enclosu.e E= Copy with attachment / enclosure N = No copy OFFICE DE:EMEB C DE:EMEB ' C EMEB:BC C DE:DD C DE:D C NAME TScarbrough* DTerso* Elmbro*- RWessman* JStrosnider*
DATE 4/29/99 4/29/99 04/ 30 /99 05/03/99 m m-m . o- m m -
m OFFICE ADT NRR:D EDO NAME BWSh SJCollins WDTravers DATE /$/99', / /99 / /99 l j jg OFFICIAL RECORD COPY
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) Y I Cha!rman Powers '2 As stated during the ACRS briefing, the NRC staff is collecting informati e potential
' benefits and impact of the proposal to eliminate the 120-month ISI a T update requirement and to establish a baseline ASME Code edition. For example, th RC published for public comment in the Federa/ Reg / ster on April 27,1999, a supple t to a previously proposed amendment to 10 CFR 50.55a that describes this proposa n addition, the NRC staff will host a public workshop on May 27,1999, in the Two White F ' t North Auditorium at the NRC .
headquarters office to discuss the proposed elimina n of the 120-month ISI and IST update requirement and an appropriate baseline for ISI d IST requirements. The ACRS members
' and their staff are invited to review the specifi roposal in the Federa/ Register notice and also to participate at the public workshop. The C staff will consider the ACRS comments in detail as part of the preparation of a final rule the proposed amendment to 10 CFR 50.55a. j l
If considered helpful, we could pro ' e more information regarding the proposed elimination of I the ISI and IST update requirem t at the next ACRS meeting. Further, the NRC staff will brief l the ACRS on the draft final rul on the proposed amendment to 10 CFR 50.55a later in 1999.
Sincerely, l William D. Travers l Executive Director for Operations 1
i cc: Chairman Jackson Commissioner Dicus Commissioner Diaz Commissioner McGaffigan l Commissioner Merrifield l
SECY l
l DISTRIBUTION: See next page DOCUMENT NAME: G:\SCARBROLMCAS499LWPD
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OFFICE DE:EMEB C DE:EMEB C EMEB:BC C DE:DD % DE:D
! NAME TScarbrough* DTerao* Elmbro' RW n JStrosnjber DATE- 4/29/99 4/29/99 4/29/99 4 M/99 [/ 3/99 m -
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Chairman Powers 2 As stated during the ACRS briefing, the NRC staff is collecti.1g inf mation on the potential benefits and impact of the proposal to eliminate the 120-month I and IST update requirement and to establish a baseline ASME Code edition. For exampi e NRC published for pobr .
comment in the Federa/ Register on April 27,1999, a suppl ent to a previously proposed amendment to 10 CFR 50.55a that describes this propos in addition, the NRC staff will host
.a public workshop on May 27,1999, in the Two White F ' t North Auditorium at the NRC headauarters office to discuss the proposed eliminati of the 120-month ISI and IST update requirement and an appropriate baseline for ISI an IST requirements. The ACRS members and their etaff are invited to review the specific pr osal in the Federal Register notice and also to participate at the public workshop. The NRC taff will consider the ACRS comments in detail as part of the preparation of a final rule on the roposed amendment to 10 CFR 50.55a.
If considered helpful, we could provide m e information regarding the proposed elimination of the ISI and IST update requirement at t next ACRS meeting. Further, the NRC staff will brief the ACRS on the draft final rule on the reposed amendment to 10 CFR 50.55a later in 1999.
Sincerely, K. William D. Travers Executive Directo@perat x -
i cer Chairman Jac son Commissioner Dieus j Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield SSE--
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DOCUMENTNAME: G:\SCARBROU\ACRS499L.WPD To receiv3 a copy of this document, indicate in the bor C= Copy w/o attachment /enetesure E= Copy with attachment /enclosu a N = No copy OFFICE DEip b DE:EMEBm ]_ -
C EMEB:BQi] C DE:DD DE:D j hNAME TS a gh DTerao Elmbro [ RWessman JStrosnider DATE M /99 / /99 / /99 l mammans namm- mass maammmmmmmmmmmmmmmmm --
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,,,, ACTION f jll EDO Principal Correspondence Control FROMs' DUE: _05/14/99 EDO CONTROL: G19990206 DOC DT: 04/19/99 D:n2 A. Powers, ACRS' FINAL REPLY:
TO:.
Travers, EDO 70R SIGNATURE OF : ** GRN **
CRC NO:
Travers, EDO
@ ESC 8 ROUTING:
SECY-99-017, "PRPOSED AMENDMENT TO 10 CFR 50.55a" Travers Knapp Miraglia Norry Blaha
@ ATE: 04/22/99 Burns Thadani, RES 2SSIGNED TO: Mitchell, OEDO CONTACT:
ACRS File Q _Co11 4 sPECIAL INSTRUC"JIONS OR REMARKS:
Pr: pare response to ACRS for EDO signature. Add Commisisioners and SECY as cc's. ~~
USE SUBJECT LINE IN' RESPONSE.
NRR ACTION:..% CE." 1 2 r T)El.MicSdidef NRR RECEIVED: April 23,1999 o
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, KEgy\ UNITED STATES 8 g NUCLEAR REGULATORY COMMISSION
,, '$ p ADVISORY COMMITTEE oN REACTOR SAFEGUARDS O WASHINGTON, D. C. 20665 April 19,1999 Dr. William D. Travers Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Dr. Travers:
SUBJECT:
SECY-99-017, " PROPOSED AMENDMENT TO 10 CFR 50.55a" During the 461" meeting of the Advisory Committee on Reactor Safeguards, April 7-10, 1999, we reviewed SECY-94-017. Also, our Materials and Metallurgy Subcommittee met on March 24-25,1999, te - sw this matter. During these reviews, we had the benefit of discussinns with represe' ses of the NRC staff and the Nuclear Energy Institute (NEl),
and of the documents re,drenced.
Recommendation
- We recommend against eliminating the 120-month update requirement for inservice inspection (ISI) and inservice testing (IST) programs from the proposed amendment to 10 l CFR 50.55a.
Discussion in May 1995, we decided not to review the proposed amendment to 10 CFR 50.55a until after the staff reconciled public comments. Since then, the proposed amendment has
^
undergone nun srous changes. The staff has reviewed the public comments and is preparing the proposed final amendment to 10 CFR 50.55a. Based on internal staff discussions and the pubiic comments, the staff is consideit;;; eliminating the regulatory requirement that licensees update their ISI and IST progr?ms to the latest American -
Society of Mechanical Engineers (A.SME) Boiler and Pressure Vessel Code every 120 months. Before proceeding with the final amendment to 10 CFR 50.55a, the staff plans to request public comments specifically on the proposed elimination of the 120-month ;
update requirement.
The staff originally endorsed the ASME Code in 1971. Recognizing that the ASME Code would be updated as experience was gained with its application, the staff also required licensees to update their ISI and IST programs every 120 months. !
1 y ~ O 3.Y .
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. g 2 1 The primary justifications for the proposed elimination of the update requirement are the maturation of the currently applicable ASME Code and the reduction of the burden on licensees caused by the updating of ISI and IST programs.
We are perplexed by the argument that experience suggests that the current ASME Code requirements have reached such a level of maturity that further updating will provide little benefit. We have recently reviewed a staff safety evaluation report (SER) on a Westinghouse topical report conceming risk-informed inspections. The topical report demonstrated that current ASME Code inspections were not an effective use of resources, and that significant %provements in inspection efficiency could be achieved through the use of risk insigMs and operational experience. In addition, pilot efforts on risk-informed IST seem to promise similar beneTits.
During the past decade, experience has shown that performance demonstrations are superior to prescriptive requirements for qualifying inspectors and inspection techniques.
The experience of the past decade has also demonstrated that new modes of degradation can occur and may require changes in inspection procedures. Erosion / corrosion, boiling water reactor (BWR) vessel internals cracking, and circumferential stress corrosion cracking of steam generator tubes were not recognized as important degradation modes a decade ago and inspection procedures had to be updated to deal with such degradation modes. Inspection technologies have also matured. Indeed, in technologies that are J heavily dependent on electronics and computer analysis of signals, a decade may represent four or five generations of technology.
This experience suggests that inspection technology is not so static and mature that 120-month updates are unnecessary. Rather, changes in technology and inspection requirements frequently require prompter action than can easily be accommodated by modifications of the ASME Code. The review of operational experience and technology changes through the ASME Code consensus process is important and worthwhile. The 120-month update provides a good baseline for inspection requirements.
In SECY-99-017, the staff recommends the elimination of the 120-month update requirement. Anecdotal information in SECY-99-017 suggests that a typical update may cost a licensee $200,000 to S300,000 every 10 years. An NEl representative cited an anecdotal number of $1 million. Even if this higher estimate is more realistic, the resultant burden does not seem excessive since the actual costs ofinspections are far higher than the update costs. Updating would be expected to provide more cost-effective inspections and lower exposures, in SECY-99-017 the staff states tnat if the 120-month update requirement is eliminated, licensees who voluntarily choose to update to a later ASME Code edition or addenda i
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. 3 will be required to implement all provisions of that edition or addenda. We concur with this staff position on implementing all the provisions of an edition or addenda.
Sincerely, r ~
Q, o&"M Dana A. Powers Chairman
References:
- 1. SECY-99-017, memorandum dated January 13,1999, from William D. Travers, Executive Director for Operations, NRC, for the Commissioners,
Subject:
Proposed l Amendment to 10 CFR 50.55a. l
- 2. U. S. Nuclear Regulatory Commission, Safety Evaluation Report Related to
" Westinghouse Owners Group Application of Risk-Informed Methods to Piping inservice inspection" (Topical Report WCAP-14572, Revision 1), October 1998 (Predecisional).
- 3. Westinghouse Energy Systems, WCAP-14572, Revision 1, " Westinghouse Owners Group Application of Risk-informed Methods to Piping Inservice Inspection Topical Report," October 1997.
- 4. Westingbouse Energy System 2, WCAP-14572, Revision 1, Supplement 1,
' Westinghouse Structural Reliability and Risk Assessment (SRRA) Model for Piping R!sk-informed Inservice Inspections," October 1997.
- 5. Letter dated August 14,1998, from John N. Hannon, Office of Nuclear Reactor Regulation, NRC, to C. Lance Terry, TU Electric,
Subject:
Approval of Risk-Informed Inservice Testing (RI-IST) Program for Comanche Peak Steam Electric Station, Units 1 and 2.
l
! 9' OFFICE OF THE SECRETARY 7 . .._ . . . . . , . _ _ . _ _ _ . - - - - - CORRESPONDENCE -CONTROL TICKET - --- , - - - - - - - - - -
PAPER NUMBER: CRC-99-0369 LOGGING.DATE: Apr 23 99 i
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k; ACTION OFFICE: EDO .
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{ AUTHOR: DANA POWERS AFFILIATION: ADVISORY COMMITTEE ON~ REACTOR SAFEGUARDS
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b ADDRESSEE: WILLIAM TRAVERS
! LETTER DATE: Apr 19 99 FILE CODE: OM 7 ACRS C
SUBJECT:
SECY 99-017, PROPOSED AMENDMENT TO 10 CFR 50.55a i .
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