ML20215H692
| ML20215H692 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/1975 |
| From: | Minogue R NRC |
| To: | |
| Shared Package | |
| ML20215H685 | List: |
| References | |
| FOIA-87-136 SECY-75-283A, NUDOCS 8705050132 | |
| Download: ML20215H692 (9) | |
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.5D(\M\[tMTfC b\\ 3 OFFHCHAL USE OF Y UNITED STATES !
August 18, 1975 NUCLEAR REGULATORY CoMMISSloN SECY-75-283A CONSENT CALENDAR ITEM.
TO: THE COMMISSIONERS l
THRU Lee V. Gossick Executive Director for Operations CORRECTION NOTICE TO SECY-75-283 - PROPOSED AMENDMENT TO 10 CFR PART 50: CODES AND STANDARDS FOR NUCLEAR POWER PLANTS AND TECHNICAL INFORMATION 1 i
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Ati Policy Session 75-41, July 24,1975, the Commission approved in principle but requested revisions,of SECY-75-283.
Specific revisions made in consequence thereof are.as follows:
- 1. Paragraphs (g) (5) 6 (6) of Enclosure "D" were revised to address the basis to be used by the Comission for
, evaluating licensee detenninaticns that confonnance with Code requirements for inservice inspection is -
impractical. .
- 2. Enclosure "F" was added,'as requested, to provide a brief discussion of the anticipated impact of implementing the proposed amendment.
Please schedule the revised SECY-75-283 for affirmation at an early Policy Session. . .
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- Robert B. Minogue, Director Office of Standards Development l Enclosures l Correction Notice with Attached -
Revision to Enclosure "D" and Enclosure "F" to SECY-75-283 SECRETARIAT NOTE: Commission comments or consents are duc e
[g,g% to the Secretariat by c.o.b. Tuesday, August 26, 1975.
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FRANTZ87-136 PDR i
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O (iii) The initial inservice tests of pumps and valves for assessing operational readiness and system pressure tests conducted during the first 20 months shall comply with those requirements in editions of the code and addenda in effect no more f.han 6 months prior to the start of facility commercial operation.
(iv) Inservice tests of pumps and valves for assessing operational readiness and system pressure tests conducted during successive 20-month periods throughout the service life of the facility shall comply with those requirements in editions of the code and addenda in effect no more than 6 months prior to the start of each 20-month period.
(v) For an operating facility whose operating license was issued prior to July 1, 1975, the provisions of paragraph (g)(4) shall become effective after January 1, 1976, at the start of the next regular 40-month period of a series of such periods beginning at the start of facility commercical operation.
(5)(1) The inservice inspection program for a facility shall be revised by the licensee, as necessary, to meet the requirements of paragraph (g)(4).
(ii) If a revised inservice inspection program for a facility conflicts with the technical specification for the facility, the licensee shall a,pply to the Commission for amendment of the technical specifications to conform the technical 14 - Enclosure "D" D gg
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l specification to the revised program. This application shall be sub-l mitted at least 6 months before the start of the period during which ;
the provisions become applicable as determined by paragraph (g) (4) .
(iii) If the licensee has determined that conformance with certain code requirements is impractical for his facility, the licensee shall notify the Commission and submit information to support his determinations.
(iv) Where an examination or test requirement by the code or addenda is determined to be impractical by the licensee and is not included in the revised inservice inspection program as permitted by paragraph (g) (4) , the basis for this determination shall be demonstrated to the satisfaction of the Commission not later than 12 months after the expiration of the initial 120-month period of operation from start of facility commercial operation and each subsequent 120-month period of operation during which the examination or test is determined to be impractical.
(6)(1) The Commission will evaluate determinations under paragraph (g)(5) that code requirements are impractical and may grant such relief as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the re-quirements were imposed on the facility.
(ii) The Commission may require the licensee to follow an augmented inservice inspection program for systems and components for which the Commission deems that added assurance of structural reliability is necessary.
15 - Enclosure "D"
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ENCLOSURE "F" EXPECTED IMPACT OF IMPLEMENTING PROPOSED AMENDMENT A. Proposal to change the basis for establishing effective dates for referenced codes and standards by relating the limits for these dates to the docket date for a facility construction permit application rather than the construction permit date This change would virtually eliminate an extremely l
difficult administrative activity imposed by the existing rule, that requires substantial effort by utilities, I
prime contractors and NRC personnel without any significant benefit to safety. By avoiding this need for repeated updating of purchase orders and design basis of a plant i
the accuracy of Safety Analysis Reports should be improved and amendments to these reports should be greatly reduced.
Such changes should result in considerable savings (estimated to be in the millions of dollars) for the licensees and the government, and would eliminate a source of unnecessary delays in licensing and plant schedules. Such changes should not degrade the safety of these plants. Section III of the ASME Boiler and Pressure Vessel Code is a very mature code and changes are not normally of major safety significance. If any ;
new requirements should be adopted by the code which were essential to safety, they could be imposed by the rule change which adopts the new addenda to the code.
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- 1- Enclosure "F" l
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B. Proposal to require periodic updatina of inservice i
inspection programs for operatina facilities The proposed amendment would require reactor licensees to update their inservice inspection programs by adding new code requirements approved by the Commission. Updating these programs is essential in view of the widely perceived need for improvements in this area witnessed by the great deal of work underway to improve inservice examination technology that is expected to be incorporated into this relatively new code.
i Updating these programs is expected to greatly increase their effectiveness and add significantly to the safety of operating reactors in the following manner:
- 1. The application of improved testing techniques will result in more definitive characterization of flaw indications; these, combined with the new analytical methods being adopted by the code, should result in i I
more quantitative and reliable assessments of the i potential consequence of these flaws. Because of the i
- greater confidence afforded, the need to repair i
components may be reduced. For example, through I
the use of new code provisions, a large flaw indication in the Pilgrim vessel was determined to be well under l the size considered unsafe and was permitted to remain.
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Enclosure "F" l
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- 2. Systematic examination and testing during routine shutdowns should detect at early stages conditions
' that, if left uncorrected, could develop into major safety problems as well as unplanned plant outages 1 and lengthy downtime for repairs and additional inspections. Such a situation existed in certain pressurized water reactors where, by using a new eddy current inspection method, steam generator tubes were found to have regions of severe wastage. The unsafe tubes were plugged and corrective action was taken to prevent additional wastage. Presently, the need to inspect steam generator tubes using eddy current methods is being incorporated into the code.
Such new inspection requirements adopted by the code ,
should apply to all operating plants.
- 3. Through the proposed change, new inspection requirements would be added in a systematic and timely manner instead of the present ad hoc practice.
! Additional code requirements will result in obvious i
l additional costs for program revisions and new inspection
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and testing operations. Although code changes and related Enclosure "F" I
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costs cannot be predicted in advance, the staff has estimated the economic impact of such changes based on past and proposed code changes. Such changes may include (1) upgrading existing test procedures, (2) requiring testing of additional components, (3) making existing general requirements more specific (analysis methods, repair methods, etc.) and (4) new inspection methods.
f The impact of such changes generally is to require additional maintenance work to prepare components for inspection, additional examinations as required by the code and possibly new equipment for performing the inspections. The costs of such changes are typically not great. For example, such a major inspection operation as (1) the eddy current testing of the tubes in a PWR steam generator or (2) the ultrasonic examination of the (approximately 50) pipe welds in the pump bypass lines of a BWR, is estimated to cost less than $20,000; for the amount of inspection that the code would normally require in a forty month period. These costs include component preparation and setup operatirns.
Since the inservice inspection code is written specifically to permit inspections during normal plant outages, special outages for inspection that would involve significant costs, i should not be necessary as a result of the adoption of new code changes.
- 4- Enclosure "F" l
On balance, expenses resulting from new code requirements j should be offset by the increased safety afforded the plant, as well as economic benefits expected to result from the implementation of these programs. For example, repair of the Pilgria vessel or replacement of a steam generator would involve millions of dollars. Further, an unscheduled shutdown for several days would cost hundreds of thousands of dollars.
The staff believes that licensees are adequately protected against undue impact on plant availability and cost since the proposed amendment will not require plant modifications i or redesign, special plant outages should not be required, i
and new code provisions will be applied only to the degree practical. Further, the statement of consideration to 1
the proposed rule has provisions that commit NRC to consider the impact of code changes on existing facilities before adopting such codes and also the proposed rule l
{ requires consideration of the burden that could result prior
- to imposing new inspection and testing provisions on a i
k facility. ;
} Enclosure "F" I
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9FFICHAL USE ONLv i
DISTRIBUTION NO. OF COPIES Secretary 5 Chairman Anders 4
Commissioner Rowc.en 2 Commissioner Mason 3 Commissioner Gilinsky 2 Commissioner Kennedy 3 Exec Dir for Operations 2 Agency Inspector 6 Auditor 2 Congressional Affairs 1 Public Affairs 2 General Counsel 3 Exec Legal Director 2 Administration 3 Policy Evaluation 2 Asst Exec Dir for Operations 1 Planning 6 Analysis 1 Nuclear Reactor Regulation 2 Reactor Licensing 3 Technical Review 1 j Standards Development 5
- Inspection 6 Enforcement 3 AS6LBP 2 AS6 LAP 2 i
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1 OFFHCHAL USE ONLY
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