ML20248J510
| ML20248J510 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/29/1998 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR15233 63FR15233-00009, 63FR15233-9, NYN-98074, NUDOCS 9806090172 | |
| Download: ML20248J510 (3) | |
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- m N nhean wwa syneni RULES & DR. EimCH US NRO May 29,1998 Docket No. 50-443 NYN-98074 AR # 98006584 Chief, Rules and Directives Branch Division of Adrninistrative Services U.S. Nuclear Regulatory Commission Mail Stop T6-D59 Washington, DC 20555-0001 Seabrook S'ation Comments on NRC Proposed' Generic Laer: Augmented Inspection of Pressurized-Water Reactor Class 1 liigh Pressure Safety Injection Piping On March 30,1998, the NRC posted for comment (Federal Register: 63 FR 15233), a proposed Generic Letter: " Augmented Inspection of Pressurized-Water Reactor Class 1 Iligh Pressure Safety Injection Piping". North Atlantic Energy Service Corporation (North Atlantic), the operator of Seabrook Station, has reviewed the material within the proposed generic letter and is enclosing comments.
North Atlantic recommends that the generic letter should not be used to bypass the use of the ASME consensus process to resolve discrepancies. If the NRC believes a discrepancy exists in the ASME Code, the consensus process of the ASME is the preferred forum for resolution.
I provides North Atlantic's comments related to this proposed action. North Atlantic is endorsing the letter prepared by the Nuclear Energy Institute (NEI) on the NRC Proposed j
Generic Letter: " Augmented Inspection of Pressurized-Water Reactor Class I liigh Pressure Safety Injection Piping".
9806090172 980529 PDR I&E MISC PDR
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i U.S. Nuclear Regulatory Commission Division of Administrative Services -
w NYN-98074 / Page 2 If you have questions regarding our comments, please contact Mr. Anthony M. Callendrello, Licensing Manager at (603) 773-7751.
Very truly yours, NORTil ATL C ENERG ERVICE CORP.
ff Aj C. Fei$baum
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Executive Vi President an ChiefNuclear cc: Mr. Kurt Cozens
' Nuclear Energy Institute 1776 I Street, NW Suite 400 Washington, DC 20006-3708 I
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e ENCLOSURE I TO NYN-98074 Seabrook Station Comments on NRC Proposed Generic Letter: Augmented Inspection of Pressurized-Water Reactor Clace 1 111gh Pressure Safety Injection Piping
- 1. North Atlantic does not believe a discrepancy exists in the ASME Code regarding inspection requirements for Class 1 and Class 2 liPSI system piping less than NPS 4 inches. We acknowledge that Examination Category C-F-1 does require both a volumetric and surface examination for the subject Class 2 piping, whereas, Examination Category B-J only requires a surface examination for corresponding Class 1 piping. The 1983 Edition of ASME Section XI Examination Category C-F only required a surface examination of Class 2 welds on piping less than or equal to % inch nominal wall thickness. Examination Category C-F-1 was incorporated into later editions of the Code, but originated as Code Case N-408. This Code Case provided " Alternative Rules for Examination of Class 2 Piping". The provisions included more stringent examinations for small bore HPSI piping, but allowed a 7.5%
population selection. In addition, it contains very specific examination distributions, i.e.
-within a system the examinations shall be distributed among terminal ends and structural discontinuities. The proposed Generic Letter does not establish any such limitations.
- 2. A survey entitled " Evaluation ofInservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds in Piping" was conducted by the ASME Section XI Task Group on ISI Optimization and published in July 1995. The results of this extensive industry survey found that flaws have been detected in a very low percentage of Category B-J welds, and that a majority of these findings were due to IGSCC in BWRs. It was also concluded that there is no apparent relationship between flaws detected and those selected due to ASME Section XI "high stress /high fatigue" criteria. A recommendation from this report stated that by utilizing PRA, plant specific input, knowledge of degradation mechanisms and expert judgment to focus on the most critical locations, the overall integrity of B-J weld examinations could be enhanced. Based on this industry specific survey, North Atlantic feels this proposed Generic
- Letter would not enhance the integrity of Class 1 B-J welds since it lacks specific guidance in -
utilizing PRA principles.