ML20246B601

Forwards Fr Notice Proposing Amend to Update 10CFR50.55a, Incorporating Natl Codes & Stds for Design,Fabrication, Const,Testing & Insp of Reactor Components & Sys for Signature

ML20246B601
Person / Time
Issue date:	02/09/1987
From:	Beckjord E NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:	Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20245A520	List: ML20245B265 ML20245C202 ML20246B595 ML20246B601 NUREG-1032, Draft Reg Guide,Task SI 501-4, Station Blackout. Draft NUREG-1109 & NUREG-1032 Re Regulatory/Backfit Analysis for Resolution of USI A-44 & Evaluation of Station Blackout Accidents at Nuclear Power Plants,Respectively,Encl NUREG-1109, Recommends That Final Station Blackout Rule,As Contained in Encl Fr Notice & Reg Guide,Providing Method Acceptable to Comply W/Rule,Be Issued in Order to Implement Final Resolution of USI A-44
References
NUDOCS 8905090115
Download: ML20246B601 (34)

Text

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1. o UNsTED STATES

[' g NUCLEAR REGULATORY COMMISSION g' j WASHINGTON, D. C 20555 l

,o FEB 9. ;ggy j i

MEMORANDUM FOR: Victor Stello, Jr. l Executive Director for Operations FROM: Eric S. Beckjord, Director Office of Nuclear Regulatory Research  !

J

SUBJECT:

PROPOSED AMENDMENT TO 10 CFR 650.55a - CODES AND  !

STANDARDS j l

Enclosed for your signature is a Federal Register Notice proposing an  !

amendment to update 650.55a of 10 CFR Part 50 which incorporates by ,

reference national codes and standards for the design, fabrication, I construction, testing and inspection of reactor components and systems. j i

It has been a continuing policy of the Commission to update this section of the regulations to keep the references current. The preamble to the August 24, 1972, final rule amending 650.55a (37 FR 17021) states: "As new or amended editions of applicable codes, code cases, or addenda are issued, the Commission will review them and amend the provisions of

$50.55a . . . as appropriate."

This section of the regulations incorporates by reference Division 1 i rules of Section III, " Rules for the Construction of Nuclear Power Plant i Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) and Division 1 rules of Section XI,

" Rules for Inservice Inspection of Nuclear Power Plant Components" of the l ASME Code. The present reference endorses the 1983 Edition and Addenda through the Summer 1984 Addenda for Section III, Division 1, and the 1983 Edition and Addenda through the Summer 1983 Addenda for Section XI, Divi-sion 1.

ASME procedures provide that editions of the ASME Code be revised every three years and that addenda to the editions be issued on a semiannual basis. The 1986 Edition, which was issued July 1986, updates the 1983 Edition by incorporating all addenda from the Summer 1983 through the

. Winter 1985 Addenda. Addenda subsequent to the Winter 1985 Addenda modify the 1986 Edition.

This amendment incorporates by reference the Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section III, Division 1, and the Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section XI, Division 1, of the ASME Code. The edition and addenda have l been reviewed by the staff and, with one exception, found to be accept-able and not inconsistent with regulatory criteria. The exception l relates to the acceptance criteria for flawed austenitic piping. A limitation is placed on the use of the acceptance criteria for flawed austenitic piping that are contained in the Winter 1983 Addenda and l s90so90115 870623  !

PDR REVGP NRCCRGR MEETING 115 PDC  !

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Victor Stello, Jr. 2 FEB s 1987 Winter 1984 Addenda to Section XI, Division 1. The limitation requires that 'for certain types of welds, the acceptance criteria be used as improved by the Winter 1985 Addenda. No changes are proposed to previous supplementary requirements included in the regulation.

The enclosed notice provides a period of 60 days after publication in the Federal Register for submitting coments on the proposed amendment.

A note regarding issuance of the proposed amendment will be included in the next Weekly Information Report to the Commission. The Subcommittee i on Energy and the Environment of the House Interior and Insular Affairs Comittee, the Subcommittee on Energy Conservation and Power of the House 4 Comittee on Energy and Commerce, and the Subcommittee on Nuclear Regula-tion of the Senate Committee on Environment and Public Works will be in-formed of this action. No public announcement will be issued.

Coordination: The Offices of Nuclear Reactor Regulation, Inspection and Enforcement, Administration, and Public Affairs concur in the proposed amendment to 10 CFR 550.55a. The Office of the General Counsel has no legal objection to the proposed amendment.

. OV Eric S. Beckjord,IDi rector Office of NucleaP Regulatory Research

Enclosures:

1. Federal Register Notice

2. Regulatory Analysis ,

3. Draft Transmittal letter to '

I Congressional Committees

4. Weekly Information Report l

) j

Victor Stello, Jr. 3 APPROVED FOR PUBLICATION j The Commission has delegated to the ED0'(10 CFR 1.40(c) and (d), published on March 18, 1982, at 47 FR 11816 and 0ctober 18, 1985, at 50 FR 42145) the authority to develop and promulgate rules as defined in the APA (5 U.S.C.

551(4)) subject to the limitations in NRC Manual Chapter 0103, Organization and Functions, Office of the Executive Director for Operations, paragraphs 0213, 038, 039, and 0310.

The enclosed proposed rule entitled " Codes and Standards" amends 10 CFR 50.55a to incorporate by reference the Winter 1984 Addenda, Sunner 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section III, Division 1, and the Winter 1983 Addenda, Sumer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section XI, Division 1, of the ASME Code.

This proposed rule does not constitute a significant questfor of policy, nor does it amend regulations contained in 10 CFR Parts 7, 8, or 9, Subpart C.

concerning matters of policy. I therefore find that this proposed rule is within the scope of my rulemaking authority and am proceeding to issue it.

l Date Victor J. Stello, Jr. ,

Executive Director for Operations b

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Enclosure 1 Federal Register Notice NUCLEAR REGULATORY COMMISSION 10 CFR Part 50 Codes and Standards for Nuclear Power Plants AGENCY: Nuclear Regulatory Commission.

ACTION: Proposed rule.

SUMMARY

The Commission proposes to amend its regulations to incorporate by reference the Winter 1984 Addenda, Summer 1985 Addenda. Winter 1985 Addenda, and 1986 Edition of Section III, Division 1, of.the American So-ciety of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),

and the Winter.1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, .and 1986 Edition of Section XI, q Division 1, of the ASME Code. A limitation is.placed on the use of paragraph IWB-3640 as contained in the Winter 1983 Addenda and Winter 1984 Addenda of Section XI, Division 1. This limitation requires that for i certain types of welds, IWP-3640 be used as modified by the Winter 1985 Addenda. The sections of the ASME Code being incorporated provide rules for the construction of light-water-cooled nuclear power plant components

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l and specify requirements for inservice inspection of those components. l Adoption of these amendments would permit the use of improved methods for construction and inservice inspection of nuclear power plants.

• l DATES: Comment period expires . i Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to l comments received on or before this date. ,

1 ADDRESSES: Send comments to: Secretary, U.S. Nuclear Regulatory- 2 Commission, Washington, DC 20555. ATTN: Docketing and Service Branch.

Hand deliver comments to: Room 1121, 1717 H Street, NW., between 8:15 a.m.

and 5:00 p.m. Monday through Friday. Examine comments received at the NRC Public Document Room, 1717 H Street, NW., Washington, DC.

FOR FURTHER INFORMATION CONTACT: Mr. G. C. Millman, Division of Engineer-ing Safety, Office of Nuclear Regulatory Research, U.S. Nuclear Regu-latory Commmission, Washington, D.C. 20555, Telephone: (301)443-7713.

SUPPLEMENTARY INFORMATION: On September 26, 1985, the Nuclear Regulatory Commission published in the Federal Register (50 FR 38970) amendments to its regulation, 10 CFR Part 50, " Domestic Licensing of Production and Uti-lization Facilities," which incorporated by reference a new edition and l

! new addenda to the American Society of Pechanical Engineers Boiler and ,

1 1

• A date will be inserted allowing 60 days from date of publication for public comment.

L l I i 2 j

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l f7590-011, l

Pressure Vessel Code (ASME Code). This amendment revised 550.55a to in-l corporate by reference all editions through the 1983 Edition and all ad- l i

denda through the Summer 1984 Addenda that modify Division 1 rules of Section III, " Rules for the Construction of Nuclear Plant Components," )

i and all editions through the 1983 Edition and all addenda through the i Summer 1983 Addenda that modify Division 1 rules of Sections XI, " Rules for the Inservice Inspection of Nuclear Power Plant Components," of the ASME Code. The Commission proposes to amend 650.55a to incorporate by reference the Winter 1984 Addenda, Summer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Division 1 rules of Section III, and the Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda Winter 1985 Addenda, and 1986 Edition for Division 1 rules of Section XI of the ASME Code. The 1986 Edition is equivalent to the 1983 Edition, as modified by the Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and Winter 1985 Addenda. The Summer 1984 Addenda and Summer 1985 Addenda for Section XI do not include technical requirements related to Division 1, but are included in the reference to prevent the confusion that might occur with a lack of continuity in the addenda references.

Paragraph IWB-3640 was incorporated into the Winter 1983 Addenda of Sec-tion XI, Division 1, to provide procedures and acceptance criteria for determining the acceptability for continued service of austenitic stain-less steel piping with flaws in excess of the allowable indications spec-ified in IWB-3514.3. Concern was expressed by the NRC staff and others that IWB-3640, as presented initially in the Winter 1983 Addenda, did not provide an acceptable level of margin against failure for materials with 3

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low toughness, such as might occur in fluxed welds (i.e., submerged arc welds ('SAW) or shielded metal arc welds (SMAW)). One concern with low ]

toughness materials was that such materials might fail at load levels below limit load. Additionally, there was concern that secondary stresses, which were not included in the stress analysis procedures  ;

required by IWB-3640, might contribute to the failure of low toughness ir.aterial s . ,

The ASME established a special task group to address the concerns associ-ated with paragraph IWB-3640 as contained in the Winter 1983 Addenda. In the interim, the NRC staff required that licensees utilizing the proce-dures and acceptance criteria of IWB-3640, as contained in the Winter 1983 Addenda, apply additional safety factors in their analyses to be submitted to the staff to account for the above concerns. NRC staff acceptance criteria were provided in Generic Letter 84-11, " Inspections of BWR Stain-less Steel Piping."*

In the opinion of the NRC staff, the concerns associated with material i

toughness have been adequately addressed by the ASME Code with the modification to paragraph IWB-3640 in the Winter 1985 Addenda. This I addenda provides specific acceptance criteria for SAW and SMAW type welds,

and these criteria address the concerns associated with limit load and the need to incorporate secondary stresses in the evaluation.

This proposed amendment to 550.55a incorporates a limitation in paragraph L

50.55a(b)(2)(i) that allows for the use of paragraph IWB-3640, as A copy of Generic Letter 84-11 is available for inspection or copying l

for a fee at the NRC Public Document Room 1717 H Street NW., Washington, DC.

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I contained in the Winter 1983 Addenda and Winter 1984 Addenda, for all applications permitted in that paragraph except those associated with SAW and SMAW type welds. For these welds, the proposed amendment specifies that paragraph IWB-3640, as modified by the Winter 1985 Addenda, must used.

Footnote 6 of $50.55a provides reference to the NRC Regulatory Guides I that denote which ASME Code Cases have been determined to be acceptable to the NRC staff for implementation. At present, this footnote provides reference to only Regulatory Guides 1.84 and 1.85, which denote ac-ceptability of Section III, Division 1, Code Cases on design and fabri-cation, and on materials, respectively. This proposed amendment revises Footnote 6 to incorporate a reference to Regulatory Guide 1.147, "in-service Inspection Code Case Acceptability -- ASME Section XI Divisicn 1," which identifies the Code Cases acceptable to the NRC staff for implementation in the inservice inspection (ISI) program of light-water-cooled nuclear power plants. At present, the Implementation section of Regulatory Guide 1.147 specifies that applicants should make a specific request to the NRC to use Code Cases endorsed in the regulatory guide.

The next revision of Regulatory Guide 1.147 (i.e., Revision 6) will reflect the proposed change in Footnote 6 of the regulation. It will permit the use of Code Cases endorsed in the regulatory guide without a specific request to the NRC for approval. In the interim, it is the intent of the NRC that Code Cases listed in Regulatory Guide 1.147 may be used without specific application to the NRC.

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Subsection IWE, " Requirements for Class MC Components of Light-Water Cooled Power Plants", was added to Section XI, Division 1, in the Winter 1981 Addenda. However, 10 CFR 650.55a presently incorporates only those portions of Section XI that address the ISI requirements for Class 1, 2, and 3 components and their supports. The regulation does not currently address the ISI of containments. Since this proposed amendment is only intended to update current regulatory requirements to include the latest ASME Code edition and addenda, the requirements of Subsection IWE would not be imposed upon Commission licensees by this amendment. The applicability of Subsection IWE is being considered separately.

ENVIRONMENTAL IMPACT: CATEGORICAL EXCLUSION The NRC has determined that this proposed rule is the type of action described in categorical exclusion 10 CFR 51.22(c)(3). Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this proposed rule.

REGULATORY ANALYSIS The Commission has prepared a regulatory analysis for this proposed l-amendment to the regulations. The analysis examines the costs and benefits of th,e alternatives considered by the Commission. Interested persons may examine a copy of the regulatory analysis at the NRC Public 6

[7590-011 Document Room, 1717 H St. NW., Washington, D.C. Single copies of the analysis may be obtained from Mr. G. C. Millman, Division of Engineering Safety, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555, Telephone (301)443-7713.

PAPERWORK REDUCTION ACT STATEMENT This proposed rule would amend information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U. S. C. 3501 et seq.). This proposed rule has been submitted to the Office of Manage-ment and Budget for review and approval of the paperwork requirements.

REGULATORY FLEXIBILITY CERTIFICATION As required by the Pegulatory Flexibility Act of 1980, 5 U.S.C.

605(b), the Commission hereby certifies that this rule, if promulgated, will not have a significant economic impact _on a substantial number of small entities. This proposed rule affects only the licensing and operation of nuclear power plants. The companies that own these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexibility Act or the Small Pusiness Size Standards set out in regulations issued by the Small Business Administration at 13 CFR Part 121.

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, LIST OF SUBJECTS IN 10 CFR PART 50 l

Antitrust, Classified information, Fire protection, Incorporation by reference, Intergovernmental relations, Nuclear power plants and reactors, Penalty, Radiation protection, Reactor siting criteria, Reporting and '

recordkeeping requirements.

Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC proposes to adopt the following amendments to 10 CFR Part 50.

PART 50 - DOMESTIC 1.ICENSING 0F PRODUCTION AND UTILIZATION FACILITIES

1. The authority citation for Part 50 continues to read as follows:

AUTHORITY: Secs. 103, 104, 161, 182, 183, 186, 189, 68 Stat. 936, 937, 948, 953, 954, 955, 956, as amended, sec. 234, 83 Stat. 1244, as amended (42 U.S.C.

2133, 2134, 2201, 2232, 2233, 2236, 2239, 2282); secs. 201, 202, 206, 88 Stat.

1242, 1244, 1246, as amended (42 U.S.C. 5841, 5842, 5846), unless otherwise noted.

Section 50.7 also issued under Pub. L.95-601, sec.10, 92 Stat. 2951 (42 U.S.C. 5851). Sections 50.58, 50.91 and 50.92 also issued under Pub. L.97-415, 96 Stat. 2073 (42 U.S.C. 2239). Section 50.78 also issued under sec. 122, 68 Stat. 939 (42 U.S.C. 2152). Sections 50.80-50.81 also issued under sec. 184, 68 Stat. 954, as amended (42 U.S.C. 2234). Sections 50.100-50.102 also issued under sec.186, 68 Stat. 955 (42 U.S.C. 2236).

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For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C. 2273),

il50.10(a),(b),and(c), 50.44, 50.46, 50.48, 50.54, and 50.80(a) are issued under sec.161b, 68 Stat. 948, as amended (42 U.S.C. 2201(b)); $9 50.10(b) and (c) and 50.54 are issued under sec. 1611, 68 Stat. 949, as amended (42 U.S.C.

2201(i));and6550.55(e),50.59(b),50.70,50.71,50.72,50.73'and50.78are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(c)).

2. For 650.55a, paragraph (b)(1), the introductory text of paragraph (b)(2), paragraph (b)(2)(i), and Footnote 6 are revised to read as follows:

650.55a Codes and standards (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 1986 Edition and Addenda through the Winter 1985 Addenda.

(2) As used in this section, references to Section XI of the ASME 8 oiler and Pressure Vessel Code refer to Section XI, Division 1, and include editions ,

through the 1986 Edition and Addenda through the Winter 1985 Addenda, subject to the following limitations and modifications:

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(i) Limitations on specific editions and addenda. When applying the 1974 Edition, only the addenda through the Summer 1975 Addenda may be used. When applying the 1977 Edition, all of the addenda through the Sum-mer 1978 Addenda must also be used. Addenda and editions subsequent to the Summer 1978 Addenda, that are incorporated by reference in paragraph (b)(2) of this section are not affected by these limitations. When apply-

• ing the Winter 1983 Addenda and Winter 1984 Addenda, the rules of paragraph IWB-3640 may be used for all applications permitted in that paragraph,exceptthoseassociatedwithsubmergedarcwelds(SAW)or shielded metal arc welds (SMAW). For SAW or SMAW, use paragraph IWB-3640, as modified by the Winter 1985 Addenda.

l Footnotes to 550.55a:

0 ASME Code cases that are authorized for use by the Commission staff are listed in NRC Regulatory Guide 1.84, " Code Case Acceptability--ASME Section 111 Design and Fabrication," NRC Regulatory Guide 1.85, " Code Case Acceptability--ASME Section III Materials," and NPC Pegulatory Guide 1.147, " Inservice Inspection Code Case Acceptability -- ASME Section XI I

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t: Division 1." The use of other Code cases may be authorized by the Director of the Office of Nuclear Reactor Regulation upon request pursuant to 550.55a(a)(3).

Dated at this day of 1987 For the Nuclear Regulatory Comission.

Victor Stello, Jr.,.

Executive Director for Operations, 11 l

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a PDR Certified Original:

Date: l Enclosure 2 1

Draft Reculatory Analysis j l

Amendment to 10 CFR 950.55a )

Codes and Standards j Executive Summary Section 50.55a of the NRC regulations requires that nuclear power plant owners construct Class 1, 2. and 3 components in accordance with the rules pro-vided in Section III, Division 1 of the ASPE Boiler and Pressure Vessel Code (ASME Code) and that they provide for and perform an inservice inspection of those components in accordance with the rules provided in Section XI, Division i 1, of the ASME Code. NRC has been mandating this requirement since shortly '

after initial publication of Section III and Section XI of the ASME Code in 1971. The preamble to the August 24, 1972, final rule amending $50.55a (37 FR 17021) states "As new or amended editions of applicable codes, code cases, or addenda are issued, the Comission will review them and amend the prrvisions of $50.55a ... as appropriate."

The mechanism for endorsement, which has been used since the first endorsement i in 1971, has been to incorporate by reference the ASME Code into 150.55a. The regulation identifies which edition and addenda of the ASPE Code have been  !

approved by the NRC for use. At present, the NRC endorses for Section III,  !

Division 1, all addenda through the Sumer 1984 Addenda and all editions throuch the 1983 Edition, and for Section XI, Division 1, all addenda through the Sumer 1983 Addenda and all editions through the 1983 Edition. The pro-posed amendment would incorporate by reference all editions through the 1986 Edition and all addenda throuch the Winter 1985 Addenda for both Section III, 1 Division I, and Section XI, Division 1.

l The proposed amendment is of particular importance to cperating plants because 650.55a requires that licensees update their inservice examination and in-service testing programs every ten years to comply with the ree.uirements of the latest edition and addenda of Section XI, Division 1, endorsed by the NRC 12 months prior to the start of the next ten year interval. The proposed amendment is also of importance to plants preparing for their initial in-spection interval, for these plants must comply with the latest edition and addenda of Section XI, Division 1 endorsed by the NRC 12 months prior to the date of issuance of the operating license.

The ASME Code is developed through the American Natforal Standards Institute I consensus process. This ensures that the various technical interests (e.g.,

utility, manufacturing, insurance, regulatory) are represented on the standards 1

development comittees and their viewpoints are addressed fairly in the sta'ndards writing process. In general, revisions are made to improve the Code by providing more detailed rules where experience indicates greater guidance is necessary, or relaxing the rules where experience shows equivalent operational l safety can be maintained with a reduced burden on the licensees. The consensus process ensures that the cost and benefit of revisions to the ASME Code are properly considered from all sides and are reasonably balanced. Should the NRC staff feel that at any time in the process safety is being compromised, it can and has taken exception in 650.55a to the rules provided in the ASME Code.

This does not occur often, but is available to the staff when necessary.

The proposed amendment does not conflict with any existing or proposed re-gulatory action. In particular, the ASME Code rules that address the criteria for allowable cracks in austenitic stainless steel piping provide the basis for existing and proposed generic letters on the inspection of BWR stainless steel Piping.  ;

It is concluded that the proposed amendment, when implemented, would result in a net increase in the overall protection of public health and safety, because it will be the improved rules that will be used in new and subsequent inservice inspection programs. Obsolete requirements will not be promulgated  ;

from inspection interval to inspection interval. '

1. Statement of the Problem The General Design Criteria (Appendix A of 10 CFR Part 50) require that structures, systems, and components of light-water-reactors be designed, fabricated, erected, constructed, tested and inspected to cuality standards commensurate with the importance of the safety function performed. Without a set of specific rules to implement these quality standards, it would be neces-sary for e3ch applicant and licensee to develop its own program for submittal to the NPC. Each program would heve to be reviewed by the staff on a case-by-case basis. This would increase significantly the licensing review time and would make inspections by the staff more difficult because of the nonstandard nature of each program.

To provide a consistent set of rules, which the industry has participated in developing, 650.55a mandates use of Section III, Division 1, of the ASME Code for construction of Class 1, 2, 3 components, and Section XI, Division 1 of the ASME Code for inservice inspection of these components. Section III and Section XI are implemented by applicants and licensees of all light-water-cooled reactors. The WRC first endorsed the ASME Code by reference in 10 CFR 550.55a in 1971. The ASME publishes a new edition of the Code every three years. In the past, new addenda have been published for Section III, Division 1, and for Section XI, Division 1 every six months. Since 1986, new addenda have been published once a year. It has been a continuing policy of the Comission to update this section of the regulations to keep the references current. In those cases where an item in the ASME Code is inconsistent with NRC criteria, an exception may be taken to endorsing that portion of the Code or supplementary criteria may be incorporated to make tne item consistent with staff reovirements.

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Section 50.55a presently endorses all addenda thrcugh the Summer 1984 Addenda, and all editions through the 1983 Edition for Section III, Division 1, and all addenda through the Sumer 1983 Addenda, and all editions through the 1983 Edition for Section XI, Division 1. The purpose of this proposed rujemaking is to incorporate by reference into the regulations all addenda through the Winter 1985 Addenda and all editions through the 1986 Edition for both Section III, Division 1 and Section XI, Division 1.

The ASME Code is developed through the consensus process, which ensures that the various technical interests (e.g., utility, manufacturers, insurance, re-gulatory) are represented on the standards development committees and that their viewpoints are considered in the standards writing process Endorsement of the ASME Code by the NRC provides a method of incorporating rules into the regulatory process that are acceptable to the NRC and have received industry consideration in their development.

If the NRC did not taxe action to endorse the ASPE Code, the NRC position on methods for construction and inservice inspection would have to be established on a case-by-case basis. If the NPC did not take action to update the ASME Code references, improved methods for construction and inservice inspection might not be implemented.

2. Objectives The proposed rule would amend 650.55a to:

o Incorporate by reference into 10 CFR $50.55a, the Winter 1984 Ad-denda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition for Section III, Division 1, and the Winter 1983 Addenda, Sumer 1984 Addenda, Winter 1984 Addenda, Sumer 1985 Addenda, Winter 1085 Addenda, and 1986 Edition for Section XI, Division 1, of the ASME Code.

o Require that when using paragraph IWB-3640 cf Section XI, Division 1, for submerged arc welds and shielded metal arc welds the Winter 1985 Addenda be used in place of the rules contained in the Winter 1983 Addenda and Winter 1084 Addenda, o Revise footnote 6 to incorporate a reference to Regulatory Guide 1.147, " Inservice Inspection Code Case Acceptability --- ASME Sec-tion XI Division 1."

3. Alternatives One alternative to incorporating by reference into NRC's regulations the up-dated requirements of Section III, Division 1, and Section XI, Division 1, and noting the need to use the improved IW8-3640 rules contained in the Winter 1985 Addenda, and making the editorial revision to Footnote 6 would be to take i no action. This would mean that the NRC position on the methods for con-struction and inservice inspection contained in the latest edition and recent addenda of the ASME Code would have to be provided on a case-by-case basis, and there could be some question as to the applicability of Regulatory Guide 1.147.

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A second alternative to incorporating by reference these later requirements of Section III, Division 1, and Section ' XI. Division 1, is to incorporate the entire text of these sections of the ASPE Code into the NRC regulations. Re-cause of the volume of these sections, this approach is not practicable.

4 Consequences-

a. Costs and Benefits Incorporating by reference the latest edition and recent addenda of the ASME Code will establish the NRC staff position on these Code rules on a generic basis for applicants and licensees. This will minimize the need for case-by-case evaluations and will reduce the time and effort reouired for submittal preparations and license reviews.

The cost / benefit of ASME Code revisions is balanced by the manner in which these revisions are achieved through the American National Standards Ir.stitute (ANSI) consensus process. The ANSI consensus process ensures that participa-tion in ASME Code development is open to all persons and organizations that might reasonably be expected to be directly and materially affected by the activity, and ensures that such persons and organizations shall have the op-

_ portunity for fair.and equitable participation without dominance by any single interest. Consensus is established when substantial. agreement has been achieved by the interests involved. Consensus reouires that all _ views and ob-jections be considered and that a concerted effort be made toward resolution. l ASME Code proposed revisions are published for public coment in the ASME ]

F.echanical Engineering and ANSI Reporter. publications prior to being submitted i for final ASME and ANSI approval. Adverse public coments are referred to the ,

appropriate technical comittee for resolution. .)

1' The consensus process ensures a proper balance between utility, manufacturing, regulatory and other interests concerned with revisions to the ASME Code, and ensures that the cost of implementing any Code revision is consistent with its benefit.

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b. Impacts on Other Requirements (1) Effect of Proposed Amendment on Existing NRC Requirements i

Section III and Section XI have been revised, in the past, twice a year.

l These Addendarevisions and Winterhave been Addenda . p)ublished Starting in in two there 1986, addenda is only each oneyear (i.e., Summer addenda for each of these sections and it will be called the 19XX Addenda (e.g.,

j 1986 Addenda). The revisions are the result of consensus participants l meeting 4 - 5 times a year for the purpose of improving the existing

' rules. The revisions take into account the many lessons learned in a specific area since the development of a particular Code rule. The revisions generally fall into three categories; e) technical revisions that incorporate new rules in technical areas not previously addressed by the Code; b) technical revisions to existing rules; and c) editorial revisions. When a technical revision is made, it may make the existing i

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I set of rules more or less restrictive, or may simply clarify the existing rule- without changing its intent. There are numerous revisions in each addenda. Appendir. A provides a sumary of those revisions considered to be significant that are included in the addenda and edition affected by the proposed amendment.

In general, technical revisions are made to improve the ASME Code by pmviding more detailed rules where experience indicates greater guidance is necessary, or relaxing the rules where experience shows equivalent operational safety can be maintained with a reduced burden on the licensee.

Relative to implementation of Section III, Division 1, 650.55a specifies that the ASME Code edition and Addenda' to be applied to reactor coolant pres-sure boundary (i.e., Class 1), and Ouality Group B (i.e., Class 2) and Quality Group C (i.e., Class 3) components must be determined by the provisions of paragraph NCA-1140 of Subsection NCA of Section III, Division 1, of the ASME Code, but the applicable edition and adaenda must be those which are in-corporated by reference in 650.55a. NCA-1140 specifies that the owner (or his designee) shsll establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and

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addenda dates established in the Design Specifications be earlier than three years prior to the date that the nuclear power plant construction pemit is i docketed. NCA-1140 further states that later ASME Code editions and addenda i may be used by mutual consent of the Owner (or his designee) and Certificate Holder. Plants may implement the improved rules on a voluntary basis as they are incorporated by reference into 650.55a, but unless they make that choice, there is no additional burden associated with incorporating the proposed ,

Section III edition and addenda.  !

Pelative to implementation of Section XI, Division 1, 650.55a specifies that:

(a) Inservice examinations of components, inservice tests of pumps and valves, and system pressure tests conducted during the initial 120-month inspection interval shall comply with the requirements in the latest edition and addenda of the ASME Code incorporated by reference en the date 12 months prior to the date of issuance of the operating license, subject to any limitations noted (650.55a(4)(1)).

(b) Similar to (a), above, for successive 120-month inspection interval it is necessary to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference 12 months prior to the start of the 120-month inspection interval, subject to anylimitationsnoted(550.55a(4)(ii)).

(c) If a licensee determines that conformance with certain Code require-ments is impractical for his facility, the licensee shall notify the Comission and submit infernation to support his determination (50.55a(g)(5)(iii)). The Commission will evaluate licensee deter-minations that Code requirements are impractical and may grant such relief and may impose alternative requirements giving due consideration to the burden on the licensee (50.55a(g)(6)(1)).

5

4 The existing requirements in $50.55a specified in Items (a) and (b), above, ensure that all plants perform inservice inspection and inservice test pro-grams proposedin conformance with updated versions of Section XI of the ASME Code. The amendment would update the editions and addenda that are endorsed by the NRC staff, and would thereby cause these later editions and addenda to identified in be implemented Items (a) and (b),byabove.

licensees consistent with the time constraints The requirement requests in Item (c), above, provides for the submittal of relief by. licensees.

It ensures that in those cases where the generic requirements of Section XI are impractical, or are overly burdensome for a '

specific requirement,facility, that facility providad the may obtain some relief from the particular omission of the Section XI requirementlicensee demonstrates to the Coninission that believed to be impractical will not have an adverse affect on public health and safety.

As noted in Appendix A, proposed for endorsement inthere are numerous changes in the addenda being

!50.55a. Some of the changes may be considered-to reduce increasethe theburden burden.of In the licensee in implementing the Code, while others may the consensus process and, any event, all the revisions were developed as part of elements of the nuclear industry, as well as the NRCItstaff.therefore, is fair to say have b that the consensus process ensures that the value of any revision to the ASPE Code is balanced by its burden on the industry.

The proposed revistors generally improve plant safety by incorporating new rules to cover areas not previously addressed, or by revising the rules consis-tent with experience to reduce the number of areas where the Code has been found to be impractical, inadequate, or insufficiently clear.

As noted above, 950.55a presently requires that licensees update their in-service inspection programs every 10 years to the Section XI rules that were endorsed by the NRC 12 months prior to the start of the next 120-month in-spection interval.

There will be a substantial increase in safety through the 1 endorsement of the later addenda and edition, because it will be these addenda and edition that will be used in subsequent inservice inspection programs.

Obsolete inspectionrequirements interval. will not be promulgated from inspection interval to q (2) Effect of Proposed Amendment on NRC Regulatory Actions That Address the Inspection of BWR Stainless Steel Piping The proposed amendment addresses one area where an NRC regulatory action exists and where a proposed action is pending.

inspection of austenitic stainless steel piping. The actions are associated with the Cracks in austenitic stain-less steel piping have been a concern since 1973 when intergranular stress corrosion cracking (ICSCC) was first noted in some BWR feedwater lines.

Since the Winter 1975 Addenda,Section XI Division 1, has provided criteria in paragraph IWB 35H .3 for allowable indications in austenitic piping.

l Because IGSCC often exceeded these criteria, the ASPE Code developed sup-plemental rules that permitted evaluation and possible acceptance of these cracks for limited operating periods. These supplemental rules were incor-porated into paragraph IWB-3640 in the Winter 1983 Addenda of Section XI,  !

Division 1, to provide procedures and acceptance criteria for detemining the '

acceptability for continued services of austenitic stainless steel piping with flaws in excess of the allowable indications specified in IWB-3514.3.

Generic Letter 84-11, " Inspections of BWR Stainless Steel Piping", was issued to provide licensees with a sumary of actions that the staff considered an ac-ceptable response to IGSCC concerns at the time. This generic letter provided licensees with the bases for a reinspection program for piping susceptible to IGSCC. Among other things, the generic letter provides crack evaluation and repair criteria. These criteria, in part, ere based upon rules provided in the Winter 1983 Addenda of Section XI, Division 1. Because of uncertainties associated with crack sizing, the staff has adopted a criteria in Generic Letter 84-11 that pemits operation with cracked welds for the time period that the cracks are evaluated to not exceed 2/3 of the limits for depth and length provided in paragraph IWB-3640 of the Winter 1983 Addenda of Section XI, Division 1.

An additional concern expressed by the NRC staff and others was that IWB-3640, as contained in the Winter 1983 Addenda, did not provide an acceptable margin against failure for low toughness materials. The ASME established a special task group to address this concern. The result was a revision to IWB-3640 that appeared in the Winter 1985 Addenda. In the opinion of the NRC staff, this revision adequately addresses the concerns associated with the use of IWB-3640 for low toughness materials. The intent of the limitation in the proposed amendment is to prevent the use of IWB-3640 rules in the Winter 1983 l Addenda and Winter 1984 Addenda for low toughness materials, and to instead require the use of the improved rules as they are provided in the Winter 1985 Addenda.

NUREG-0313, Revision 2, " Technical Report on Material Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping", among other things, pro-vides updated guidelines for evaluating IGSCC cracks for limited further operation. This report, which incorporates public coments and is now in the NRC review and approval process, states that the problem of low toughness material has been addressed by the Code, and that the Winter 1985 Addenda provides appropriate criteria for all types of welds.

NUREG-0313, Revision 2, also addresses the original uncertainties associated ,

with the ability to adequately size cracks for evaluation by IWB-3640. The NUREG points out that this issue has been addressed by the industry, with support from NRC. Recognizing that much of the uncertainty was associated with examinations being performed by examiners with limited knowledge and experience in sizing IGSCC, the industry established a training and qualif, cation program at the EPRI NDE Center in Charlotte, North Carolina.

1 1

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The staff now believes that flaw sizes can be adequately determined when both examiners and procedures are cualified by tests provided at the EPRI NDE Center.

A Generic letter to implement the criteria in the technical basis' document, NUREG-0313, Revision 2, has been prepved and is in the review and approval process along with the subject NUREG.

IWB-3640 as presented in the Vinter 1983 Addenda provides the basis for the crack acceptance criteria specified in Generic Letter 84-11. The improve-ments to IWB-3640 for low toughness materials that are contained in the Winter 1985 Addenda provide the basis for the proposed generic letter that would implement the staff technical findings that are provided in NUREG-0313. Re-vision 2. NRR is presently using the criteria specified in the Winter 1985 Addenda on a case-by-case basis. Since the 1986 Edition of Section XI, Di-vision 1, is a composite of the 1983 Edition and all subsequent addenda through the Winter 1985 Addenda, the 1986 Edition contains the acceptable rules for base materials and low toughness materials.

(3) Application of Backfit Rule (650.109)

It is the opinion of the Office of the General Counsel that the proposed amendments should not be subjected to the backfit provisions in 10 CFR 550.109.

The rationale is that (1) the Section III, Division 1, update applies only to new construction (i.e., the edition and addenda to be used in the construction of a plant are selected based upon the date of the construction pennit and are not changed thereafter, except voluntarily by the licensee, (2) licensees are fully aware that 550.55a reouires that they update their inservice in-spection program every 10 years to the latest edition and addenda of Section XI that were incorporated by reference in 650.55a 12 months before the start of the next inspection interval, and (3) endorsing and updating references to the l ASME Code, a national consensus standard developed by participants (including the NRC) with broad and varied interests, is consistent with both the intent and spirt of the backfit rule (i.e., NRC provides for the protection of the public health and safety, and does not unilaterally impose an undue burden on applicant or licensees).

(4) Impact on Requirements of Other Government Agencies Implementation of the new ASME Code rules requires certain additional infor-mation collection requirements. The Supporting Statement for Information Col-lection Requirements in 10 CFR {50.55a is provided in Appendix B.

This amendment to $50.55a affects only the licensing and operating of nuclear power plants. The companies that own these plants do not fall within the scope of the definition of "small entities" set forth in the Regulatory Flexi-bility Act in the Small Business Administration at 13 CFR Part 121. Since 8

l these companies are dominant in their service areas, this amendment does not fall in the province of this Act. The final rule will have no significant ef- '

fect on a substantial number of small companies.

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5. Decision Rationale from the above analysis it is concluded that this proposed amendment to 10 CFR 550.55a to update the reference to incorporate the latest edition and recent addenda of the ASVE Code would result in a net increase in the overall pro-l tection of public health and safety, because the improved rules would be used 4 in new and subsequent inservice inspection programs, and would save applicants and licensees, and the NPC staff both time and effort by providing uniform detailed criteria against which the staff could review any single submission.

No significant additional cost to applicants and licensees is expected as a l

result of NPC endorsement of the new ASME Code editio:s and addenda.

6. Implementation No implementation problems are anticipated. The framework for implementation is already established in both the industry and the NRC.

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Appendix A Supportina Statement for Information Collection Requirements'in 10 CFR 650.55a

1. Justification

a. Need for.the Information Collection NRC. Regulations in 10 CFR 950.55a incorporate by reference ,

Division I rules of Section III, " Rules for Construction of Nuclear Power Plant Components," and Division 1 rules of Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). These sections of i the ASME Code set forth the requirements to which nuclear power plant components are designed, constructed, tested and inspec- 1 ted._ Inherent in these requirements are certain recordkeeping functions.  ;

Incorporation of.the Winter 1984 Addenda, Summer 1985 Addenda,

- Winter 1985 Addenda, and 1986 Edition for Section III, Division I, of the ASME Code adds the following recordkeeping requirements.

Section III i

o Winter 1984 Addenda NCA-8213(c); Attachraent of Nameplates - Nameplates attached with pressure sensitive acrylic adhesive system must meet requirements of mandatory Appendix XXI, " Adhesive Attachment of Nameplates," which states that Certificate Holders 0A manuals contain written procedures for the application of nameplates.

NB/NC/ND-7141; Installation of Pressure Relief Devices -

Technical justification for the adequacy of the installation of such devices must be provided in the Over-pressure Protection Report.

o Sumer 1985 Addenda NB-4622.11; Temper Bead Weld Repair to Dissimilar Metal Welds or Buttering - Requires preparation of welding  ;

procedure specification, o Winter 1985 Addenda NCA-8440; Data Peports, Component Sup3 orts - New provisions l require the use of NF-1 and N-5 Data )eport Forms.

NC-3812/NC-3912; Design Report - Certificate Holder must provide Design Report as part of his responsibility for achieving structural integrity of atmospheric storage tanks (NC-3812) and 0 - 15 psi storage tanks (NC-3912).

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l o' Winter' 1984 Addenda p; No additional recordkeeping.

NC/III-7750; Capacity Certification of Vacuum Relief Valves-Requirement that drawings and test results are to be suhdtted to the ASME' designee for review and acceptance.

1 o ~ 1985 Edition The Summer 1983 Addenda, Winter 1983 Addenda, Sumer 1984 Addec'a, and 1983 Edition have been incorporated by-reference into 10 CFR 550.55a by a previous amendment.

Information collection requirements for the Winter 1984' Addeda, Summer.1985 Addenda, and Winter 1985 Addenda are-7 disassed above.

Incorporation of the Winter 1983 Addenda, Summer 1984 Addenda, Winter 154 Addenda, Summer 1985 Addenda, Winter 1985 Addenda,and 1986 Edition for Section XI, Division 1, of the ASME Code adds the following recordkeeping requirements.

Section E o Vinter 1983 Addenda IWA-2420; Inspection Plans and Schedules - Requires preparation of preservice and inservice inspection plans and schedules.

IWAJ210; Storage and Handling of Welding Material -

Reqsires written procedure for storage, handling, and conwol of welding material.

IWA4210(a)/(c); Owner's Responsibility - Requires presuration of preservice inspection plans and schedules, recrds, and summary report for Class 1 and 2 pressure retining components and their supports.

IWM340(b)/(c); Inservice-Inspection Records and Reports -

Requires maintainance of preservice inspection plans, ,

schslules, and reports.

Appedix VI (Mandatory); Ultrasonic Examination of Bolts and5tuds - Requires records of the personnel performance quaWfication tests, written procedures for ultrasonic '

exadnation, documentation of the procedure qualification, ca19 ration records, and examination records.

o Sumer 1984 Addenda ne dditional recordkeeping.

I The 1986 Editism d Section III, Division 1, is equivalent to the 1983 Edition, as modifid by the Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addendt Winter 1984 Addenda, Summer 1985 Addenda, and the Winter 1985 AddendL A-2 l l

l o Summer 1985 Addenda 1

No additional recordkeeping.

1 o Winter 1985 Addenda IWA-2232(f); Ultrasonic Examination - Indications that can be identified as originating from surface configurations or variations in metallurgical structure of materials may be classified as geometric indications. The maximum amplitude, location, and extent of a geometric indication 3 shall be recorded.

.]

2 l o 1986 Edition The Summer 1983 Addenda and 1983 Edition have been incorporated by reference into 10 CFR 650.55a by a previous amendment. Information collection requirements for the Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and'Vinter 1985 Addenda are discussed above,

b. Practical Utility of the Information Collection These records are used by the licensees, National Board )

inspectors, insurance companies, and the NRC in the review of a variety of activities, many of which affect safety. The records  :

are generally historical in nature and provide data on which l future activities can be based. NRC Inspection and Enforcement 1 personnel can spot check the records required by the ASME Code  !

to determine, for example, if proper inservice examination test j methods were utilized. j 1

c. Duplication With Other Collections of Information j ASME requirements are incorporated to avoid the need for writing equivalent NRC requirements. This amendment will not duplicate the information collection requirements contained in any other generic regulatory requirement.

d. Consultations Outside the NRC i No consultations,

e. Other Supporting Information NRC applicants and licensees have been complying with the I information collection requirements of the ASME Code since 1971.

No problems with these information collection requirements have ,

been identified to the NRC by the applicants or licensees. '

2 The 1986 Edition of Section XI, Division 1, is equivalent to the 1983 Edition, as modified by the Summer 1983 Addenda, Winter 1983 Addenda, Summer 1984 Addenda, Winter 1984 Addenda, Summer 1985 Addenda, and the l Winter 1985 Addenda.

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2. Description of the Information Collection

a. Number and Type of Respondents In general, the information collection requirements incurred by

$50.55a through endorsement of the ASME Code apply to the owners of the 27 nuclear power plants under construction and to the  ;

owners of the 100 nuclear power plants in operation. The actual j number of plants that would implement the edition and addenda  ;

addressed by the proposed revision, and thereby be affected by their information collection requirements, is dependent on a variety of factors. These factors include whether the application is for Section III or Section XI, the class and type of components involved, the date of the construction permit application, the schedule of the inservice inspection program, and whether the plant voluntarily elects to implement updated editions and addenda of the ASME Code,

b. Reasonableness of the Schedule for Collecting Information 1

The information is generally not collected, but is retained by  :'

the licensee to be made available to the NRC in the event of an NRC inspection or audit.

c. Method of Collecting the Information See Item 2(b).

d. Adecuacy of the Description of the Information The ASME Code provides listings of infonnation required and specific forms to assist, where necessary, in documenting required information.

e. Record Retention Period The retention period for information is in accordance with a j schedule provided in Table NCA-4134.17-1 and paragraph IWA-6300 of the ASME Code. The record retention periods for information specified in Item 1.a above are:

Information Retention Period Procedure for attachment of nameplates. 3 yrs afjer superseded Overpressure protection report. Lifetime Welding procedure specification. Lifetime NF-1/N-5 Data Report Forms. Lifetime Design Report for storage tanks. Lifetime Test results for vacuum relief valves Lifetime Proced. for control of welding material. 3 yrs after superseded Preservice Inspection Plan. Lifetime Ultrasonic examination records. Li fetime 3

Service lifetime of the component or system.

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I Lifetime retention of the above records is necessary to ensure adequate historical information on the design and examination of components and systems to provide a basis for evaluating degra-dation of these components and systems at any time during their I service lifetime.

3. Estimate of Burden

a. Estimated Hours The information collection requirements inherent in incorporating by reference the latest edition and addenda of Section III, Division 1, and Section XI, Division 1, of the ASME Code are identified in Item 1.a above. These requirements may be categorized in terms of Section III requirements that document component design, and Section XI requirements that address ultrasonic examinations and preservice inspection programs..

The additional Section III requirements incur a one-time burden on plants under construction. Section 50.55a specifies that the Code Edition, Addenda, and optional Code Cases to be applied to reactor coolant pressure boundary, and Quality Group B and Quality Group C components must be determined by the provisions of paragraph NCA-1140 of Subsection NCA of Section III of the ASME Code. NCA-1140 specifies that the owner (or his designee) shall establish the ASME Code edition and addenda to be included in the Design Specifications, but that in no case shall the Code edition and addenda dates established in the Design Specifica-tions be earlier than three years prior to the date that the nuclear power plant construction permit is docketed. NCA-1140 further states that later ASPE Code editions and addenda may be used by mutual consent of the Doner (or his designee) and Certificate Holder. The earliest Section III addenda being addressed in the proposed rule is the Winter 1984 Addenda.

Since the last plant docketed in October 1974 (Palo Verde Units 1, P, 3), there is no plant under construction for which implementation of the Section III edition and addenda specified in the proposed rule is a requirement. Plants may implement these improved rules on a voluntary basis, but unless they make that choice, there is no additional paperwork burden associated with incorporating the proposed Section III edition and addenda.

The additional Section XI requirements incur an information collection burden associated with the documentation of procedures for the storage, handling, and control of welding material; the documentation of preservice inspection plans and schedules; and the implementation of the ultrasonic examination of bolts and studs.

Nuclear power plants are required to update their inservice l inspection programs by incorporating into their initial 120+ month inspection interval requirements of the latest edition and addenda of Section XI, Division 1, that have been incorporated by reference into %50.55a as of 12 months prior to A-5

the date of issuance of the operating license; and by incorporating into sucessive 120-month inspection intervals requirements of the latest edition and addenda of Section XI that have been incorporated by reference as of 12 months prior to the start of a 120-month inspection interval. On this basis, many plants will at one time be required to implement the l Section XI, Division 1, edition and addenda specified in the I proposed rule. The number of plants that will be implementing )

, the specified edition and addenda will grow gradually as each 4 plant updates its inservice inspection program at the 10-year interval. Therefore, conservatively, the total number of plants that may ultimately be required to implement the specified i edition and addenda is 127 (i.e., 100 operating plants and 27 plantsunderconstruction). I 1

Paragraph IWA-2420 was revised in the Winter 1983 Addenda to j require the preparation of preservice and inservice inspection J plans, to specify the content of those plans, and to require an implementation schedule for the performance of examination and {

tests. Inservice inspection plans and schedules, including those for preservice inspection are routinely submitted to the NRC as part of the regulatory process. The types of items specified for inclusion in the plan (e.g., applicable Code edition and addenda, identification of components subject to examination and test, and Code requirements for each specified component) are typically included in the plans submitted to the NRC. Therefore, there is no additional recordkeeping burden associated with the revision of IWA-2420.

I Paragraph IWA-4210 was added in the Winter 1983 Addenda to l require a written procedure for the storage, handling, and control of welding material. In general, this procedure would ,

become part of the Owner's Quality Assurance Manual. The i procedure would be prepared once per plant and would, like other '

procedures, be maintained annually thereafter. It is estimated that the time required to prepare the original procedure would be 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, end the time required to maintain the procedure would be 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / year / plant. Assuming that all plants presently operating and under construction would at some time implement this requirement, the total annual burden for all 127 plants, averaged over a ten-year inspection interval, would be 1524 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79882e-4 months <br /> / year for all plants (i.e., ((100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> / plant)/10-year interval) + 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> / year / plant) x 127 plants = 1524 hours0.0176 days <br />0.423 hours <br />0.00252 weeks <br />5.79882e-4 months <br /> / year total for all plants).

Paragraphs IWA-6210 (a) and (c), and IWA-6340 were revised in the Winter 1983 Addenda to clarify that " inservice inspection" included preservice, as well as inservice programs, and that Owners were responsible for preparing and maintaining preservice inspection plans and schedules. Preservice inspections have been a requirement of Section XI, Division 1, since its inception. Preservice inspection plans and schedules are routinely submitted to the NRC as part of the approval process for the inservice inspection program. Therefore, there is no 1 additional recordkeeping burden associated with the revision of IWA-6210 (a) and (c), and IWA-6340.  ;

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Appendix VI, " Ultrasonic Examination Of Bolts and Studs" was added to Section XI, Division 1, as a mandatory appendix in the Winter 1983 Addenda. Appendix VI provides procedures for the ultrasonic examination of Class 1 and Class 2 bolts and studs.

The recordkeeping requirements of this apperdix can be divided into those associated with documenting the examination procedures (i.e., initial examination development and updates) and those associated with personnel qualification records (i.e.,

test administration, taking tests and updating records). It is estimated that initial development of the examination procedures would require a one time effort for each plant of approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of a level III Examiner's time. Assuming 3 updates of these procedures during each 10-year inspection interval, it is estimated that an additional 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> would be expended during each interval by Level III examination personnel for updating.

The burden associated with documenting the examination procedures per plant per 10-year inspection interval would then be 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br />. Assuming the need for three qualified ultrasonic bolting examiners per plant, and four bolting configurations for each test, it is estimated that for each inspection interval, the burden associated with personnel qualification records would be a total of 304 hours0.00352 days <br />0.0844 hours <br />5.026455e-4 weeks <br />1.15672e-4 months <br /> for each inspection interval for each plant (i.e., 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of test administration,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> of updating personnel records, and 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of actual testing of Level I and II technicians). The burden associated with administering personnel qualification records per plant per 10-year inspection interval would then be 304 hours0.00352 days <br />0.0844 hours <br />5.026455e-4 weeks <br />1.15672e-4 months <br />.

Conservatively assuming that all plants presently operating and under construction would at some' time implement Appendix VI, the total annual burden of the associated recordkeeping is estimated to be 10,160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> per year for all plants (i.e. , (304 + 496 hours0.00574 days <br />0.138 hours <br />8.201058e-4 weeks <br />1.88728e-4 months <br /> / plant)/(10-year interval) x 127 plants).

Paragraph IWA-2232(f) was added in the Winter 1985 Addenda to provide the conditions by which ultrasonic indications can be classified as geometric indications. The revision specifies that the maximim amplitude, location, and extent of a geometric indication shall be recorded. Since such indications are normally recorded in this manner, there is no additional paperwork burden associated with this requirement.

b. Estimated Cost Reouired to Respond to the Collection Based upon the hours specified in Item 3.a. it is estimated that the cost of responding to the information collection required by the Section III, Division I, and Section XI, Division 1, edition and addenda specified in the proposed amendment to $50.55a is a total of $701,040/ year ((10,160 + 1524) hours. x $60/ hour) for 127 plants, or $5500/ year for each plant.

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c. Source of' Burden Data and Method for Estimating Burden Estimates of the paperwork burden associated with implementing the identified ASME Code revisions were obtained from utility staff inservice inspection specialists, an inservice inspection.

consultant to utilities, and national lab personnel engaged in inservice inspection activities.

d. Reasonableness of Burden Estimate The estimate of the burden is considered reasonable because of the reliable source of the burden data.

4. Estimate of Cost to the Federal Government NRC inspection personnel who audit plant quality assurance records would include in their audit verification that the above records are being properly prepared and maintained. The time associated with NRC inspectors verifying these records would be extremely small when the activity is performed as part of a normal quality assurance audit.

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Enclosure 3 Draft Transmittal Letter To Congressional Comittees The Honorable Morris K. Udall, Chairman Subcommittee on Energy and the Environment Committee on Interior and Insular Affairs 1 United States House of Representatives Washington, DC 20515

Dear Mr. Chairman:

Enclosed for the information of the Subcommittee are copies of a notice of proposed rulemaking to amend $50.55a of the Commission's regulations codified in 10 CFR Part 50. Section 50.55a reouires holders of construc-tion permits and licenses to conform to the requirements of certain national codes in the design, fabrication, construction, testing and inspection of specified reactor components and systems.

This section of the regulation references Division 1 rules of Section III, " Rules for the Construction of Nuclear Power Plant Components," and Division 1 rules of Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components " of the American Society of Mechanical l

Engineers Boiler and Pressure Vessel Code (ASME Code). The present I reference endorses the 1983 Edition and Addenda through the Sumer 1984 l' Addenda for Section III, Division 1, and the 1983 Edition and Addenda l through the Sumer 1983 Addenda for Section XI, Division 1.

ASME procedures provide that editions of the Boiler and Pressure Vessel Code be revised every three years and that adderda to the editions be is-sued on a semiannual basis. The 1986 Edition, which was issued July 1986, updated the 1983 Edition by incorporating all addenda from the Sumer 1983 through the Winter 1985 Addenda. Addenda subsequent to the Winter 1985 Addenda modify the 1986 Edition.

This amendment incorporates by reference the Winter 1984 Addenda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section III, Division 1, and the Winter 1983 Addenda, Sumer 1984 Addenda Winter 1984 Addenda, Sumer 1985 Addende, Winter 1985 Addenda and 1986 Edition of Section XI.

Division 1, of the ASME Code. The edition and addenda have been reviewed ,

by the staff and, with one exception, found to be acceptable and not i inconsistent with regulatory criteria. The exception relates to the acceptance criteria for flawed austenitic piping. A limitation is placed on the use of the acceptance criteria for flawed austenitic piping that are contained in the Winter 1983 Addenda and Winter 1984 Addenda to ,

Section XI, Division 1. The limitation requires that for certain types I of welds, the acceptance criteria be used as improved by the Winter 1985 Addenda. No changes are proposed to previous supplementary requirements I included in the regulation.

l

E I t- .

Morris K. Udall 2 i

i In view of the routine nature of the amendment, we do not consider that a public announcement is warranted.

Sincerely, i

Eric S. Beckjord, Director 4 Office of Nuclear Regulatory Research

Enclosures:

As stated cc: The Honorable Manuel Lujan

Enclosure 4 WEEKLY INFORMATION REPORT l l

l Proposed Rule to be Signed by EDO 1

, 1986, the Executive Director for Operations approved a On I proposed rule which revises 10 CFR 550.55a, Codes and Standards. This rule proposes to update the references incorporating the American Society of b Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) io include the Winter 1984 Addenda, Sumer 1985 Addenda. Winter 1985 Addenda, and 1986 Edition of Section III, Division 1, and the Winter 1983 Addenda, Sumer 1984 Addenda. Winter 1984 Addenda, Sumer 1985 Addenda, Winter 1985 Addenda, and 1986 Edition of Section XI, Division 1, of the ASME Code.

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