ML20212B235
| ML20212B235 | |
| Person / Time | |
|---|---|
| Issue date: | 09/07/1999 |
| From: | Collins S NRC (Affiliation Not Assigned) |
| To: | Powers D Advisory Committee on Reactor Safeguards |
| References | |
| ACRS-GENERAL, NUDOCS 9909200023 | |
| Download: ML20212B235 (6) | |
Text
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UNITED STATES
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WASHINGTON, D.C. 20066-0001
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l September 7, 1999 Dr. Dana A. Powers, Chairman Advisory Committee on Reactor Safeguards U.S. Nuclear Regulatory Commission Washington, D.C 20555
SUBJECT:
PROPOSED FINAL AMENDMENT TO 10 CFR 50.55a," CODES AND STANDARDS"
Dear Dr. Powers:
On July 15,1999, the NRC staff briefed the Advisory Committee on Reactor Safeguards (ACRS) on the proposed final amendment to 10 CFR 50.55a,
- Codes and Standards," to incorporate by reference a recent edition and addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV Code) and the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for construction, inservice inspection (ISI), and inservice testing (IST) of nuclear power plant components, in a letter dated July 21,1999, the NRC staff formally forwarded the proposed final amendment to the ACRS. In yourletter dated July 23,1999, the ACRS recommended approval of the proposed final amendment to 10 CFR 50.55a stating that the rule will provide significant improvements in the effectiveness of Isis by expediting implementation of performance demonstration requirements for inspectors, updating IST requirements, and endorsing ASME Code cases for assessment and temporary repair of Class 3 piping.
The proposed rule dated December 3,1997, would have established a backfit requirement for licensees of pressurized water reactor plants to supplement the provisions in the ASME BPV Code for surface examination of Class 1 high pressure safety injection (HPSI) system piping welds with a volumetric (ultrasonic) examination. Since issuance of the proposed rule, the industry has established a voluntary initiative to address the broad issue of thermal fatigue of nuclear power plant piping. During the briefing on July 15,1999, the NRC staff indicated that the proposed requirement for HPSI Class 1 volumetric examinations had been deferred in light of the industry initiative. However, there was not a detailed discussion of the pros and cons of deferring the volumetric examinations. We understand that the ACRS may have express ( d
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some concems about the HPSI Class 1 weld examination Issue in its July 23,1999, letter, if the issues surrounding this subject had been discussed in more detail at the briefing.
in a telephone conference on August 6,1999, the NRC staff d:scussed its plans for addressing the HPSI Class 1 weld examination issue with Dr. William Shack, Chairman of the ACRS Subcommittee on Materials and Metallurgy; John Larkins, ACRS/ACNW Executive Director; and Richard Savio, ACRS/ACNW Director for Technical Support. On August 20,1999, the NRC staff met with the Nuclear Energy Institute to discuss possible interim actions that licensees could take regarding HPSI Class 1 weld examinations during pedormance of the industry initiative on thermal fatigue. As a result of this meeting, the staff concluded that additional work was needed by the industry to qualify inspection procedures for small diameter piping and to determine the appropriate scope of inspections neccssary to effectively address the issue. Representatives of the industry's Material's Reliability Project (MRP) indicated it Th[
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would take about nine months to develop interim guidance for ultrasonic examination procedures and qualification recommendations. Industry representatives also indicated that they would pursue an ASME Code case to address HPSI piping inspections. Altemative
- inspection and monitoring methods are also being pursued as part of MRP's overall program, which is scheduled for completion in 2001. The staff encouraged the industry to consider a phased approach to implementing these options and will continue dialogue with the industry regarding implementation schedules.
The development of ultrasonic inspection guidelines, along with the longer term industry program in this area, are being pursued as part of the Commission's Direction Setting issue (DSI) 13 on "The Use of Voluntary Industry Initiatives in the Regulatory Process." Rather than delaying issuance of this rule, the NRC staff is planning to defer consideration of the HPSI Class 1 volumetric examination issue in this rulemaking, and to establish or facilitate interim action,if necessary, regarding HPSIline examinations as part of a future 10 CFR 50.55a rulemaking effort. The NRC staff does not believe that deferral of regulatory action in this rulernaking while effective inspection methods are developed will affect plant safety, because staff evaluations indicate that a minimalincrease in core damage frequency would result from potentially undiscovered flaws in HPSI Class 1 piping welds. Following completion of the
- industry initiative, the NRC staff will determine whether any changes are necessary to the interim action to provide forlong term resolution of the HPSI Class 1 piping examination issue.
In light of the limited benefit of surface examinations of HPSI Class 1 piping welds and concems regarding occupational radiation exposure in the performance of those examinations, this rule will endorse but not mandate the provision in the ASME Code for surface weld examinations of HPSI Class 1 piping.
The NRC staff will proceed with its plan for issuance of the proposed final amendment to 10 CFR 50.55a to allow the significant improvements in ISI and IST requirements provided in the rule to be implemented without further delay. The staff will continue to pursue the HPSI Class 1 weld examination issue with the industry. We regret not emphasizing issues surrounding the HPSI Class 1 weld examinations during the ACRS briefing. As a lesson leamed, we will be more vigilant in directing the Committee's attention to areas of interest or potential controversy in future ACRS briefings.
' As you are aware, the NRC staff is evaluating the current regulatory requirement for licensees to update their ISI and IST programs every 120 months to the most recent edition and addenda of the ASME Code incorporated by reference in the NRC regulations. On April 27,1999, the NRC issued a proposed mie that would eliminate the requirement to update ISI and IST programs every.120 months and would establish baseline requirements for ISI and IST programs at operating nuclear power plants. The NRC staff is reviewing the public comments received on the proposal to eliminate the ISI and IST update requirement.
l During the ACRS meeting on September 30 to October 2,1999, the NRC staff will brief the L
ACRS on the status of the HPSI Class 1 weld examination issue and the staff's recommendations regarding the ISI and IST update requirement. Please contact Gene Imbro, Chief, Mechanical and Civil Engineering Branch, Division of Engineering, Office of Nuclear L
Dr. Dana A. Powem 3
Reactor Regulation, if you would like additional details on our plans to amend 10 CFR 50.55a.
We also understand that the Committee may want to have additional discussions on DSI-13 and we will be pleased to discuss this initiative at your convenience.
Sincerely, ORIGINA!.S!G!D EY:
Samuel J. Collins, Director Office of Nuclear Reactor Regulation 1
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'3 Reactor Regulation, if you would like additional details on our plans to amend 10 CFR 50.55a.
We also understand that the Committee may want to have additional discussio6s on DSI-13
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Sincerely,
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f Samuel J. ' Collins,Oirector Office of Nuclear' Reactor Regulation
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Industry initiatives in the Regulatory Process." Rather than delaying issuance of this rule, the NRC staff is planning to defer consideration of the HPSI Class 1 volumetric examination issue in this rulemaking, and to establish or facilitate interim action, if necessary, regarding HPSI line examinations as part of the next 10 CFR 50.55a rulemaking effort. The NRC staff does not believe that deferral of regulatory action in this rulemaking while evaluating the need for interim action for HPSI Class 1 weld examinations will significantly affect plant safety, because staff evaluations indicate that a minimal increase in core damage frequency would result from potentially undiscovered flaws in HPSI Class 1 piping welds. Following completion of the industry initiative, the NRC staff will determine whether any changes are necessary to the interim action to provide for long-term resolution of the HPSI Class 1 piping examination issue.
In light of the limited benefit of surface examinations of HPSI Class 1 piping welds and concerns regarding occupational radiation exposure in the performance of those examinations, this rule will endorse but not mandate the provision in the ASME Code for surface weld examinations of HPSI Class 1 piping.
The NRC staff will proceed with its plan for issuance of the proposed final amendment to 10 CFR 50.55a to allow the significant improvements in ISI and IST requirements provided in the rule to be implemented without further delay. The staff will promptly address the HPSI Class 1 weld examination issue. We regret not emphasizing issues surrounding the HPSI 1
Class 1 weld examinations during the ACRS briefing. As a lesson learned, we will be more i
vigilant in directing the Committee's attention to areas of interest or potential controversy in future ACRS briefings.
As you are aware, the NRC staff is evaluating the current regulatory requirement for licensees to update their ISI and IST programs every 120 months to a recent edition and addenda of the ASME Code incorporated by reference in the NRC regulations. On April 27,1999, the NRC issued a proposed rule that would eliminate the requirement to update ISI and IST programs i
every 120 months and would establish baseline requirements for ISI and IST programs at operating nuclear power plants. The NRC staff is reviewing the public comments received on the proposal to eliminate the ISI and IST update requirement.
During the ACRS meeting on September 30 to October 2,1999, the NRC staff will brief the i
ACRS on the status of the HPSI Class 1 weld examination issue and the staff's recommendations regarding the ISI and IST update requirement. Please contact Gene Imbro, Chief, Mechanical and Civil Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, if you would like additional details on our plans to amend 10 CFR 50.55a.
We also understand that the Committee may want to have additional discussions on DSI 13 and we will be happy to discuss this initiative at your convenience.
Sincerely, Samuel J. Collins, Director Office of Nuclear Reac'or Regulation cc: [ listed on original]
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of the next 10 CFR 50.552 rul: making effort. Th5 NRC staff does not b:li:ve that deferral of regulatory action in this rulemaking while evaluating the need for interim action for.HPSI Class 1 weld examinations will significantly affect plant safety, because staff evaluationgndicate that a minimal increase in core damage frequency would result from potentially undiycovered flaws in HPSI Class 1 piping welds over this short time period. Following completio initiative, the NRC staff will determine whether any changes are necessa 'p of the ind to the interim action to provide for long-term resolution of the HPSI Class 1 piping examinati issue. In light of the limited benefit of surface examinations of HPSI Class 1 piping welds an concerns regarding occupational radiation exposure in the performance of those examinpfions, this rule will endorse but not mandate the provision in the ASME Code for surface weld xaminations of HPSI Class 1 piping.
The NRC staff will proceed with its plan for issuance of the proposed final amendment to 10 CFR 50.55a to allow the significant improvements in ISipnd IST requirements provided in the rule to be implemented without further delay. The staff will promptly address the HPSI Class 1 weld examination issue. We regret not emphas.izing the controversial nature of the issue surrounding the HPSI Class 1 weld examination,s'during the ACRS briefing. As a lesson learned, we will be more vigilant in directing the Committee's attention to areas of interest or potential controversy in future ACRS briefings.
As you are aware, the NRC staff is evaluating ttye current regulatory requirement for licensees to update their ISI and IST programs every 12p months to a recent edition and addenda of the ASME Code incorporated by reference in thefNRC regulations. On April 27,1999, the NRC issued a proposed rule that would eliminata4he requirement to update ISI and IST programs every 120 months and would establish baseline requirements for ISI and IST programs at i
operating nuclear power plants. The Nf3C staff is reviewing the public comments received on
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the proposal to eliminate the ISI and IST update requirement.
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During the ACRS meeting on SepteJnber 30 to October 2,1999, the NRC staff will brief the ACRS on the status of the HPSI Class 1 weld examination issue and the staff's recommendations regarding the)SI and IST update requirement. Please contact Gene Imbro, Chief, Mechanical and Civil Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, if you would like additional details on our plans to amend 10 CFR 50.55a.
/
Sincerely, i
Samuel J. Collins, Director Office of Nuclear Reactor Regulation cc:
Chairman Dicus Commissioner Diaz Commissioner McGaffigan Commissioner Merrifield SECY DISTRIBJTION: See next page DOCUMENT NAME: G:\\EMEB\\SCARBROUGH\\ACRS899L.WPD l
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