ML20217Q389

Comment on Proposed Rule 10CFR50 Re Industry Codes & Standards.Proposed Rulemaking Invalidates Qualifications of Piping & RPV Insp Entities That Would Support Util

ML20217Q389
Person / Time
Site:	Calvert Cliffs
Issue date:	04/03/1998
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR33892, FRN-62FR63892, RULE-PR-50 62FR63892-00056, 62FR63892-56, NUDOCS 9804100419
Download: ML20217Q389 (4)

Text

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e CurnLEs II. Cause DOCKETED naitimore oas ,nd Electric Company Vice President U3f!P.C Chen Cliffs Nuclear Power Plant 1650 Calven Cliffs Parkway Nuclear Energy Lusby Maryland 20657

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((4 FAG 38 9 3) 56 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Rulemaking and Adjudications Staff

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on NRC Prooosed Chances to 10 CFR 50.55a. Industry Codes and Standards

REFERENCES:

(a) Letter from D. J. Modeen (NEI) to Rulemaking and Adjudications Staff (NRC), dated April 3,1998, Comments on NRC Proposed Changes to 10 CFR 50.55a, (62 Federal Register 63892, dated December 3,1997, and 63 Federal Register 3673, dated January 26,1998)

(b) Letter from Mr. W. C. Holston (Member of the Public) to Rulemaking and Adjudications Staff (NRC), dated January 19,1998, Comments on NRC Proposed Changes to 10 CFR 50.55a (dated December 3, '1997)

(c) Federal Register Notice 62FR63892, dated December 3,1997, and Federal Register Notice 63FR3673, dated January 26,1998, Industry Codes and Standards; Amended Requirements The Baltimore Gas and Electric Company (BGE) welcomes the opportunity to provide comments on the subject proposed changes. Please be advised that BGE has reviewed the comments submitted by the Nuclear Energy Institute (Reference a), and Mr. W. C. Holston (Reference b), and fully endorses them.

Additionally, BGE would like to voice its concern regarding the three proposed modifications to Appendix Vill, " Performance Demonstration for Ultrasonic Examination Systems" to Section XI, Division I, and the proposed expedited implementation of Appendix VIII (Reference c). i The three proposed modifications address specimen set cracks, specimen set microstructure, and personnel qualification. Baltimore Gas and Electric Company's concern regarding these modifications is two fold: (1) BGE does not believe that the modification is technicallyjustifiable; and (2) BGE believes that the modification presents an unnecessary economic hardship without commensurate safety benefits.

Baltimore Gas and Electric Company also believes that the proposed implementation timeline is inappropriate. The details of BGE's concerns are outlined below.

9804100419 980403 i i

PDR PR 50 62FR33892 PDR <

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9 Rulemaking and Adjudications Staff 4

4: - April 3,1998 Page 2

- I. Propnaed Modification to Appendix VIII Speclanew Set Cracks l Forpiping, Appendix VIIIrequim that alloftheflaws in a specimen set be cracks. However,for vessels

.and nozzles, Appendix VIII would allow as many as 50% of theflaws to be notches. The proposed

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Section30.55a(b)(2)(xill) would require that allflaws in the specimen sets usedfor performance j ' demonstration be cracks.

BGE's Concerms:

l- A. - ne Performance Demonstration Initiative (PDI) Reactor Pressure Vessel (RPV) specimens L containing notches were designed and fabricated in accordance with Appendix Vill. The

(~ NRC participated in the consemius pmcess that developed Appendix Vill and never objected i to the utilization of notches in the specimens, as currently defined.

B. There is not a strong technical basis for eliminating notches. The NRC claim that notches are l categorically easier to detect than real cracks is not completely accurate. These are instances

!- where a multi-faceted real crack is much easier to detect than a smooth notch. In these instances, notches present a greater challenge to the examination system, l C. The requirement that all flaws be cracks creates a situation where all RPV qualifications issued to date would be invalidated. He industry would no longer be in a position to qualify examination systems on fabrication defects, which constitute the types of indications actually encountered 'm RPV inspections.

i D. In order to meet the requirement that all specimen flaws be real cracks, the industry would

! have to provide additional samples at an estimated cost of $4 million. Baltimore Gas and Electric Company's share of the cost for additional samples would be on the order of

$100/>00. His does not include our cost to support additional training and qualification for the industry. Past experience indicates our sharc for additional training and qualification would be'at least $50,000, for a total of $150,000.

E. Eliminating notches in lieu of cracks would impose e financial hardship.on BGE that is not -

cost-effective. His additional cost will not be offset by a compensating increase in safety.

' H. Erns M' ' T - lam to A7 'N VIII Sp== Set ML. a.. dure Appendix VIII does not distinguish specimensfor two-sided examinations from those usedfor single-sided exami: nation. The proposed Section 50.55a(b)(2)(xx) would require the industry to develop sets of specimens Ithat contain microstructures similar to the ypesfound in the components to be inspected and

-flaws with non-optimum characteristics, such as shew, tilt, and roughness, consistent with field

' experience thatprovide realistic challengesfor single-sidedperformance demonstration.

BGE's Concerms:

A. ne PDI-based specimens were designed and fabricated in accordance with Appendix Vill.

He NRC participated in the consensus process that developed Appendix Vill. They did not suggest including a requirement that addressed microstructure during the development of Appendix Vill.

I B. ' The proposed modification provides no guidance on how or when to determine actual microstructure. He modification seems to imply that every component / microstructure }

L combination in a plant would have to be represented by a corresponding test specimen. This a j

I l

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A f _, Rulemaking and Adjudications Staff April 3,1998 -

Page 3 requirement would invalidate the PDI test specimens that represent an investment of well

- over $10M.~ ne fabrication costs 'of_ the new plant specific specimen' sets would be

prohibitive. De training and qualification costs for inservice inspection personnel'on all

. specimen sets would also be prohibitive.

C. His modification would impose a staggering and unjustified increase in cost (> $10M) over -

current PDI expenditures without any compensating improvement in safety.

III. Pmpnaad Madifientians to Appendix VHI Pernommel Quallfleatina The NRC believes that the requirement in Appendix VII-4240for personnel to receive a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of training on an annual basis is inadequate. Proposed Section 50.55a(b)(2)(xvil) would require that all personnel quahped for performing ultrasonic examinations in accordance with Appendix Vill receive 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of annual training which includes laboratory work and exa nination of fawedspecimens.

BGE's Conceras: i i

A. The American Society of Mechanical Engineers Code consensus process determined that.

10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual retraining would adequately maintain inspection skill level. ne NRC participated in this Code consensus process.

, B.~ ne proposed NRC modification of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of annual retraining is arbitrary and not based on ,

fact. Furthermore, the NRC used recently published Code Case N-583 to clarify Code intent I for annual retraining. De resulting clarification focused on " hands-on" aspects and reduced the 10-hour requirement to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. He issue is addressed in Appendix VII.

C. De proposed modification really only addresses those that do not maintain skills 6 rough' actual performance,of inspections and does not address those that routinely perform Appendix Vill-based inspections.

D. De proposed modification would require annual retraining for the equivalent of 1600 1 examiners per year plus those that are new to the business, and those'that must add new  !

qualifications based on other proposed modifications.

E. In addition to its share ofindustry-level support of annual retraining, BGE will likely have to  !

support annual retraining of contract personnel supporting BGE at a minimum of $25,000 per )

year ($2,500/ week /peren).  ;

i F. - his proposed modification will serve as a barrier to entry and to retention of qualified perscar.cl in the industry. The impact to BGE could *oe significant. Shortage of qualified ,

inspection personnel will result in higher prices and longer outages. l G. De additional costs to BGE and the industry will not be offset by a compensating increase in safety.

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. _Rulemaking and Adjudications Staff

- April 3,1998 Page 4

' IV. The Proposed Expedited Implementation of Appendix VIH This mandatory appendix would normally be adopted us part of the routine 120-month spdate specuped

'in Section 30.55a(g)(4),'but because of the importance of the Appendix VIIIprogram, the NRC has

- determined that its requirements should be implemented after 6 monthsfom the date ofthepnal rule.

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BGE's Concerms: -

A. 'he proposed rulemaking invalidates the qualifications'of the piping and RPV inspection entities that would support BGE. His would cause BGE to initiate numerous relief requests a to address the inability of the industry to support the change in qualification requirements on six months notice.-

B. Appendix VIII cannot be implemented, as written, as has been demonstrated by the PDI, until outstanding Code Cases and PDI issues are resolved by the Code and the NRC.

C. Expedited implementation of Appendix VIII would impose additional financial hardship on

.BGE. Baltimore Gas and Electric Company would not only have to provide its share of funding to modify the industry program, but it must also bear the increased costs associated with an inadequate pool of inservice inspection personnel and the premium costs associated with their requalification. Dese costs are not offset by a compensating increase in safety.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

I Very truly yours, j

, aze l i

CHC/GT/ dim I i

cc: R. S. Fleishman, Esquire Resident Inspector,NRC J. E. Silberg, Esquire R. I. Mc'- m.DNR A. W. Dromerick, NRC J. H. Walter, t 2C Director, Project Directorate I-1, NRC D. J. Modeen (NEI)

H. J. Miller, NRC W. C. Holston i

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