ML21267A098

Rulemaking: Final Rule: Annotated Public Comments Document: Incorporate by Reference American Society of Mechanical Engineers Boiler and Pressure Vessel Code and Operations and Maintenance Code

ML21267A098
Person / Time
Issue date:	09/30/2022
From:	Office of Nuclear Material Safety and Safeguards
To:
Huckabay, Victoria
Shared Package
ML21267A036	List: ML21267A091 ML21267A092 ML21267A094 ML21267A098
References
10 CFR Part 50, ASME 219-2020, Final Rule, NRC-2018-0290, RIN 3150-AK22
Download: ML21267A098 (96)

Text

Annotated Public C omments on Proposed R ule:

American Society of Mechanical Engineers 2019-2 020 Code Editions

September 2022

Proposed rule: 86 FR 16087 (March 26, 2021)

NRC-2 018-0 290; RIN 3150-A K22

Comment Commenter Name and Affiliation ADAMS Accession Submission ID Number 001 Jeffrey D. Stumb, Dominion Energy ML21140A358 002 Mark Gowin, Inservice Testing Owners Group ML21141A263 003 Terence Chan, Private Citizen ML21144A032 004 Thomas Basso, Nuclear Energy Institute ML21145A172 005 Thomas Vogan, American Society of Mechanical ML21146A041 Engineers 006 David P. Helker, Exelon Generation Company, LLC ML21146A042 007 Ronald Swain, Electric Power Research Institute ML21146A043 008 C.J. Riedl, Tennessee Valley Authority ML21146A150 Submission ID 001 Jeffrey D. Stumb, Dominion Energy ADAMS Accession No. ML21140A358 From: Jeffrey.D.Stumb@dominionenergy.com To: RulemakingComments Resource Cc: Wolfgang, Bob; Scarbrough, Thomas

Subject:

[External_Sender] Docket ID NRC-2018-0290 Date: Thursday, May 20, 2021 11:15:51 AM Attachments: JStumb Comments on NRC-2018-0290.pdf

NRC Staff,

I attempted to upload my comments at regulations.gov, but I received an error message upon uploading my comment file. Please reference my comments on Docket ID NRC-2018-0290 attached to this email. Feel free to reach out to me if there are any questions regarding my input.

Thank you,

Jeff Stumb Innsbrook - 3NW Cell Phone 703-928-1983

CONFIDENTIALITY NOTICE: This electronic message contains information which may be legally confidential and or privileged and does not in any case represent a firm ENERGY COMMODITY bid or offer relating thereto which binds the sender without an additional express written confirmation to that effect. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you.

M a y 20, 2021

Office of Administration U.S. Nuclear Regulatory Co mmission Washington, DC 20555-0001

S ub je c t: Public C omments on American Society of Mechanical Engineers 2019 - 20 20 Code Editions Incorporation by Reference [ R IN 31 50-AK22; Docket ID N RC-2 018-029 0]

10 CFR 50.55a(b)(3)(xi) OM Condition: Valve Position Indication

This condition is applicable when implementing the 2012 or later editions of the ASM E OM C ode. This requirem ent stipulates that licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position.

In the last r ulem a king, 1 0C FR 50. 55 a (b)(3 )(xi) was updated to increase the scope of the O M condition to include valves covered in all of the mandatory appendices within the ASM E OM Code. This change also allows other test methods and frequencies used in Subsection ISTC and the mandatory appendice s to verify obturator position on a test interval long er than every two years as prescribed by ISTC -37 00.

Establishing a requirement to verify obturator position on every valve in the IST prog ram with remote position indication can place a sig nificant burden on the licensee to develop new t est methods and procedures for valves that do not have supplemental means available, such as flow or pressure indication. In these cases, it may be necessary to purchase special equipment and deploy personnel to high radiological areas to verify obturator position on a frequency that may not add any increase in safety.

Recently, utilities have received NRC approval to use performance-based test methods, such as the 10 C FR 50 Appendix J test prog ram, to verify obturator position. Performance-based test programs allow for valves to be tested at frequencies g reater than every two years and require more frequent testing for poor performing valves. Other perfor mance-based test prog rams include OM C ode Cases OM N-23 and OM N-27, as well as the C heck V alve C ondition M onitoring program in M andatory Appendix II, the inservice (diagnostic) test on motor-operated valves in M andatory Appendix III, and the performance assessment test on air-operated valves in M andatory Appendix IV.

The NRC expectations versus what is required in this condition is confusing. I S TC -37 00 prescribes the position indication test be performed on a 24M frequency and the supplemental position verification test prescribed by this condition can be performed at a 24M frequency or other verification methods and frequencies. Is prior NRC approval required to deviate from the 24M frequency for obturator verification when using the performance -based Appendix J test program ? The condition states that other verification methods and frequencies within Subsection ISTC and its mandatory appendices can be used to verify obturator position. The 10 CFR 50 Appendix J test prog ram is prescribed in Subsection ISTC, but the NRC has also stated in a recent public meeting that prior NRC approval would be needed to credit the verification m ethod s and frequencies from the Appendix J prog ram.

If the NRC currently believes that prior NRC approval is required to use performance-based test methods and frequencies for supplemental obturator position verification then the O M condition could be modified to allow performance -based test methods to verify obturator position while still maintaining reasonable assurance of the valve condition. The NRC staff should not be concerned with the performance history on specific valves within the scope of performance -based test programs since this type of test prog ram requires more frequent testing for poor performanceand valve deg radation.

Performance-based test programs provide the reasonable assurance necessary to meet the intent of this OM condition on a frequency g reater than every two years and would g reatly reduce the burden on the licensee and the NRC staff.

It is recommended that the following wording be used to enhance the condition t o provide g reater flexibility in how licensees meet th e intent o f this O M condition:

When implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees must verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation to provide assurance of proper obturator position for valves with remote position indication within the scope of Subsection ISTC including its mandatory appendices the ASME OM Code and its performance-basedverification methods and frequencies. For valves not susceptible to stem -disk separation, the supplemental position verification testing specifie d i n paragraph ISTC-37 00this conditionm ay be performed based on guidance in Code Case OMN -28. on a 10-year interval where the licensee documents a justification, which is made available for NRC review, demonstrating that the stem -disk connection is not susceptible to separation based on the internal design and evaluation of the stem -disk connection using plant-specific and industry operating experience and vendor recommendations.

This chang e allows for the supplemental position obturator verification test to be credited by existing performance-based test m ethods and frequencies such as 10 C FR 50 Appendix J, Code C ases O MN-2 3 and OM N-27, and performance-based testing in Mandatory Appendices II, III and IV.

10 CFR 50.55a(f)(4), Inservice Te sting Standards Requirement for Operating Plants

The proposed rulemaking currently deletes the phrase... without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section. This deletion implies that th ere m ay be som e cases where non-C ode Class components will require prior NRC approval to deviate from ASME OM Code requirements. Licensees currently have justifications for non -Code Class components justifying that C ode deviations demonstrate an acceptablelevel of quality and safety, or that implementing the C ode provisions would result in a hardship or unusual difficulty without a compensating increase in the level of quality and safety. The NRC staff will need to provide exam ples of when prior NRC approval would be required and when prior NRC approval would not be required prior to implementing this chang e in order for licensees to determine if the currently implemented justifications need prior NRC approval and allow the NRC staff adequate time to reviewany needed requested alternatives.

10 CFR 50.55a(f)(7), Inservice Testing Reporting Requirements

The proposed 10 CFR 50.55a(f)(7) wording would expand the requirement of licensees to submit their IST Plans and interim IST Plan updates related to pumps and valves, and IST Plans and interim Plan updates related to snubber examination and testing tothe N RC when the final safety analysis report for the applicable nuclear power plant is updated. Submittal of interim IST Plan updates for pumps and valves and snubber examination and testing is not currently required. The new requirement to submit IST Plan updates to the NRC is considered unnecessary and overly burdensome. Currently, program plans associated with the ASM E OM C ode are submitted to the NRC for information prior to the beg inning of each 10-year interval. These prog ram plan submittals are deemed adequate for the NRC to perform their technical reviews of any associated alternative and relief requests.

The current revision of the ASM E OM C ode IST prog ram Plans are available to onsite resident inspectors, who can provide the latest revision to interested NRC technical staff and reg ional inspectors upon request. Furthermore, NRC inspectors typically request licensees to either provide, or have available upon arrival, the latest Plan documents prior to scheduled inspections. An OM C ode IST prog ram Plan is considered a living document and could g o throug h several revisions within a 10-year interval. The proposed requirement may result in licensees not updating their ASM E O M C ode prog ram plans as often due to the ex tra burden of having to send revisions to the N RC.

In summary, since the NRC Resident Inspector currently has access to the most recent revision of a licensees ASM E OM C ode program Plan and is able to distribute them to others within the NRC org anization upon request, it is recommended that the additional proposed requirement to submit interim IST Plan updates be deleted.

I hope that the NRC staff find these comments helpful and informative.

Sincerely,

Jeffr ey Stum b Submission ID 002 Mark Gowin, Inservice Testing Owners Group ADAMS Accession No. ML21141A263

From: Gowin, Mark Allen To: RulemakingComments Resource

Subject:

[External_Sender] Public comments on Proposed Rule 10 CFR 50.55a (Federal Register, Vol. 86, No. 57)

Date: Thursday, May 20, 2021 6:17:43 PM Attachments: ISTOG Comments on proposed rulemaking for 10 CFR 5055a - signed.pdf

Please see attached public comments provided by the Inservice Testing Owners Group for your consideration.

Mark Gowin Chairman - Inservice Testing Owners Group

Tennessee Valley Authority Program Manager - IST and App. J Asset Mgt Programs - OM Code Work - 423-751-3669 Cell - 423-503-5931 1101 Market St.

LP D 2S336 Chattanooga, TN 37412

ISTOG Comments on Proposed Rule for 10 CFR 50.55a

Introduction

The Inservice Testing Owners Group (ISTOG) welcomes this opportunity to provide public comments on the proposed rule for 10 CFR 50.55a (Federal Register, Vol. 86, No. 57). The following ISTOG comments were developed during a membership-wide virtual meeting where each proposed change affecting Inservice Testing (IST) was discussed. In addition, membership-wide ISTOG polls were conducted to gain more specific details where needed.

Comments

(b)(3)(iv) OM Condition: Check Valves (Appendix II)

Comment / Recommendation:

10CFR50.55a(b)(3)(iv) OM Condition: Check Valves (Appendix II) should be revised to be applicable to all addenda and editions of OM endorsed for use. In addition, the overly restrictive language At least one of the identified activities for a valve group shall be performed on each valve of the group at approximately equal intervals not to exceed the maximum interval shown in Table II-4000-1 should be revised to simply require compliance with the maximum intervals (both columns) shown in Table II-4000-1. This will provide flexibility for those CVCM plans that are not at the maximum intervals while also ensuring activities on individual valves are not deferred to the end of the group interval.

A similar comment has already been provided to chairman of the ASME OM, Subgroup - Check Valves for consideration.

Bases for Comment /

Background:

This condition was first imposed as part of final rulemaking dated July 17, 2017 and became effective on August 17, 2017 (Federal Register / Vol. 82, No. 136). This condition effectively implemented new requirements which were added to the 2017 Edition of OM, Appendix II, II-4000(b)(1)(e) that require distribution of Check Valve Condition Monitoring (CVCM) activities for each valve in a multi-valve group at approximately equal intervals across the interval for the group.

The language in the 2017 Edition of OM and this condition are essentially the same.

W hile the goal for this condition and clarification in 2017 Edition of OM is appropriate, the actual language of these two documents have lead to unintended consequences. The statement, At least one of the identified activities for a valve group shall be performed on each valve of the group at approximately equal intervals not to exceed the maximum interval shown in Table II-4000-1 has resulted in significant burden for licensees to the revise their CVCM program plans for compliance. The requirement to distribute the CVCM activities across each valve at equal intervals is more prescriptive than necessary to ensure a licensee doesnt defer activities for all valves in a group to the end of the group interval.

Before this condition and OM change, most licensees performed CVCM activities on pairs of valves in a group or staggered the activities across the valve group interval in a manner that met the goal of distributing activities of multi-valve groups. However, the method of staggering activities did not meet the prescriptive language of this condition. As a result, the only way to comply with this condition and optimize testing is to split the group into smaller groups of valves or groups of one as permitted by II-2000(a). This is a significant burden on licensees and does not necessarily ensure a better distribution of activities.

Page 1 of 5 ISTOG Comments on Proposed Rule for 10 CFR 50.55a

Example:

Assume all activities for the group have not been completed such that interval extension is not allowed at the time the condition becomes effective.

Before Condition:

1 group of 4 valves where activities on 2 valves in the group are performed every other outage

Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A, C B, D (A, B, C, D)

After Condition:

One group of four valves where activities on 1 valve in the group are performed every outage

Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A C B D (A, B, C, D)

OR

Two groups of Two valves where activities on one valve in the group are performed every other outage

Group Outage 1 Outage 2 Outage 3 Outage 4 2 valves A B (A, B) 2 valves C D (C, D)

The example above demonstrates a case where a CVCM plan that met the original intent of OM to stagger activities yet still must be revised to comply with the condition. In addition, the example shows two different ways the CVCM program may be revised to order to comply with this condition.

The last method shows how the revised CVCMP can comply with the condition without changing the schedule of activities. The end result is that compliance with this condition imposed significant burden to revise CVCM plans with no increase in the level of safety.

Page 2 of 5 ISTOG Comments on Proposed Rule for 10 CFR 50.55a

(b)(3)(XI) OM Condition: Valve Position Indication

First Comment / Recommendation:

10 CFR 50.55a(b)(3)(XI) OM Condition: Valve Position Indication should be removed.

Bases / Background

ISTOG provided comments (ML16015A352) on the rulemaking in which this condition was first proposed on Friday September 18, 2015 (Federal Register / Vol. 80, No. 181). Specifically, one of those comments stated, in part, ISTOG disagrees with proposed rulemaking and the rulemaking statement that changing the should to a shall in ISTC 3700 is not a new requirement but a clarification of the intent of the existing ASME OM Code. The proposed rulemaking goes against the recognized authority of the OM Code interpretation and change processes. See the ASME OM Interpretation 12-01... Review of the NRCs Analysis of Public Comments (ML16130A531) shows there were numerous other public commenters stating this condition represented a new requirement contrary to NRCs assertion that it was merely a clarification.

In response to public comments, the final rulemaking was modified to defer the requirement to implement this condition until licensees perform the 120 month update of their IST program to incorporate the 2012 Edition or later of OM. This relaxation of implementation dates (from 30 days to up to 120 months) makes it clear that NRC recognized this condition would be a significant burden for licensees to implement.

Some licensees have started implementation of this condition and, as a result, they have had to submit requests for alternatives to address issues with implementation. In other cases, licensees are considering changing the valve design to remove the position indication as a more effective way of complying with this condition.

None of the actions described above (multiple public comments, deferral of implementation to next interval update, new requests for alternatives, and potential design changes to remove indication) would be necessary if this condition were just a clarification. This information clearly demonstrates this condition is a new requirement and was incorrectly evaluated against the backfit rule in the original rulemaking that imposed this condition.

Second Comment / Recommendation:

If the first comment above is not accepted, then ISTOG would like to thank NRC for adding language in this condition to address those valves that are non-susceptible to stem-disc separation.

This is an important change that will benefit the industry by reducing burden of testing valves that are shown to have little to no history of stem-disc separation and providing more focus on those valves that warrant additional attention.

Recently approved ASME OM Code Case OMN-28 provides a structured approach for position indication testing of non-susceptible valves. It provides guidance for determining the scope of valves, describes testing requirements (methods and frequency), as well as necessary corrective actions upon failure of testing.

Recommend NRC endorse the use of Code Case OMN-28 in this rulemaking in lieu of the proposed new language of this condition.

Page 3 of 5 ISTOG Comments on Proposed Rule for 10 CFR 50.55a

Third Comment / Recommendation:

If the first comment above is not accepted, then ISTOG recommends this condition be revised to clarify the starting point for this condition or the time frame implementation must be completed.

Bases / Background

ISTOG members have unanimously interpreted the condition language which states, W hen implementing paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code, 2012 Edition through the latest edition to mean the implementation clock starts on the first day of the IST interval that requires compliance with the 2012 Edition or later edition of OM. Further, they believed there was two years from the start date of the interval to be in full compliance with the condition.

This interpretation is based on the principle that requirements imposed based on an interval start date could not or did not extend back into the previous interval where the 2012 Edition or later edition was not applicable. In addition, the ISTOG members also recognize that in many cases, the supplemental verification of both open and closed valve positions may not be able to be performed concurrently. Also, it also may not be possible to perform concurrent with the ISTC-3700 required local observation of stem travel. The provisions of ISTC-3700 clearly state that when using supplemental observations such as flow meters, the observations need not be concurrent.

(f)(4) Inservice testing standards requirement for operating plants

Comment / Recommendation:

The proposed rulemaking removes a portion of sentence which states, without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section...

Recommend this phrase is retained in the final rule. This language is necessary to clarify that formal submittals of requests for relief or alternatives are not required for augmented IST program related components. As an option, this language could be relocated to (f)(6)(ii) along with the subsequent sentence regarding the use of an augmented IST program.

Page 4 of 5 ISTOG Comments on Proposed Rule for 10 CFR 50.55a

(f)(7) Inservice testing reporting requirements

Comment / Recommendation:

Recommend revising (f)(7) to only require submittal of IST plans when there is a demonstrated need (e.g., planned inspection) or at the beginning of each IST interval.

Bases / Background

An ISTOG poll was conducted and of the 23 respondents: 13 stated they submitted their IST plans only at the beginning of the interval; 8 stated they submitted their IST plans after major revisions; and 2 stated they submitted their IST plans both at the start of the interval and after major revisions.

No one responded that they submitted more frequently.

Licensee processes for making formal docketed submittals to NRC are very time and labor intensive. The process requires each element of the submittal to be validated with supporting documentation. This effort would be a significant burden considering IST plans includes hundreds of components and technical requirements.

IST plans are frequently revised (sometimes multiple times per year) to address modifications or other changes in the program. Therefore, the proposed (f)(7) timing for submitting IST plans when the final safety analysis report for the applicable nuclear power plant is updated would not ensure the NRC has the latest version of a sites IST plan.

This proposed change represents a new requirement which would require changes to several licensee procedures for licensing activities and IST program activities. This new requirement would create a significant burden on licensees to submit their IST plans at least every two years without any compensating increase in quality or safety.

Conclusion

These comments are provided for your consideration. Please dont hesitate to contact Mark Gowin at the contact information below if you have any questions.

Sincerely,

Mark Gowin Gowin, Mark A. Digitally signed by Gowin, Mark A. Date: 2021.05.20 18:10:57 -04'00'

Chairman, ISTOG 423-503-5931 magowin@tva.gov

Page 5 of 5 Submission ID 003 Terence Chan, Private Citizen ADAMS Accession No. ML21144A032

From: Terence Chan, PE To: RulemakingComments Resource; Hoffman, Keith Cc: Collins, Jay

Subject:

[External_Sender] Comment to Proposed Rulemaking Docket NRC-2018-0290, ASME Code Date: Saturday, May 22, 2021 8:18:14 PM

In the proposed rulemaking 86 FR 16087 dated March 26, 2021, NRC proposes to amend 10 CFR 50.55a(b)(2)(xxvi) to require a licensee-defined leak test rather than a Code-required pressure test, to demonstrate leak tightness of ASME Class 1, 2 and 3 mechanical joints.

The NRC correctly notes that such a test would not need to meet ASME Code requirements, nor would the examiners of such a test be required to meet ASME personnel qualification requirements. Furthermore, although not specifically mentioned by the staff, such testing procedures also would not need to meet ASME requirements, any ASME documentation requirements would not need to be met, nor would any Authorized Nuclear Inservice Inspector (ANII) involvement be required. In fact, because a leak test under this amended provision is not considered a Code activity, ANII involvement could be specifically disallowed by the licensee.

While it would be good practice by an Owner to document or reference such a test to the associated repair/replacement plan of the affected component, there is no requirement to do so, either within the proposed amendment to this paragraph, or by ASME since all activities related to the leakage test permitted by this amendment is outside the jurisdiction of the ASME Code,Section XI. As a result, if the NRC feels it is important to ensure linkage between the leak test performed to the associated repair/replacement activity in order to effectively "...

continue to monitor operating experience related to mechanical joints

...", it is suggested that NRC consider adding to this amended paragraph, a requirement that states to the effect that the licensee-defined leak test shall be referenced on the relevant repair/replacement plan and/or Form OAR-1, as appropriate for the relevant repair/replacement plan.

Submission ID 004 Thomas Basso, Nuclear Energy Institute ADAMS Accession No. ML21145A172

From: BASSO, Thomas To: RulemakingComments Resource Cc: Veil, Andrea; Kock, Andrea; Taylor, Robert

Subject:

[External_Sender] NEI Comments on proposed amendment of 10 CFR 50.55a to incorporate by reference ASME 2019-2020 Code Editions (Docket ID NRC-2018-0290)

Date: Tuesday, May 25, 2021 11:14:53 AM Attachments: 05-25-21_NRC_Industry Comments on Proposed 50_55a Rule Change.pdf

THE ATTACHMENT CONTAINS THE COMPLETE CONTENTS OF THE LETTER

May 25, 2021

Office of the Secretary U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

Project Number: 696

Subject:

NEI Comments on proposed amendment of 10 CFR 50.55a to incorporate by reference ASME 2019-2020 Code Editions (Docket ID NRC-2018-0290)

Submitted via regulations.gov

Dear Rulemakings and Adjudications Staff,

The Nuclear Energy Institute (NEI), on behalf of our members, appreciates the opportunity to provide comments on the proposed amendments to 10 CFR 50.55a and respectfully requests that you review the comments in the attachment. The industry continues to review these regulations for opportunities to reduce regulatory burden to ensure that attention and resources remain focused on safe, reliable facility operation and that any changes to NRC requirements result in improved safety and efficiency.

We appreciate the NRCs effort in endorsing the latest editions of the ASME codes and standards and encourage your consideration of all stakeholder comments prior to finalizing the rule change.

We trust that you will find these comments useful and informative.

Please contact me at tbb@nei.org or (202) 739-8049 with any questions or comments about the content of this letter or the attached comments.

Sincerely,

Thomas Basso Senior Director Generation & Suppliers

Nuclear Energy Institute 1201 F St NW, Suite 1100 Washington, DC 20004 www.nei.org

P: 202.739. 8049 E: tbb@nei.org

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Sent through www.intermedia.com THOMAS BASSO Senio r Director, Engineering and Risk

1201 F Street, NW, Suite 1100 Washington, DC 200 P: 202.739.8 049 tbb@nei.org nei.org

May 25, 202 1

Office of the Secr etary U.S. Nuclear Regulatory Commission Washington, DC 20555 - 0001 ATTN: Rulemakings and Adjudications Staff

Project Number: 696

Subject:

NEI Comments on proposed amendment of 10 CFR 50.55a to incorporate by reference ASME 2019-2020 Code Editions (Docket ID NRC-2018-0290)

Submitted via regulations.gov

Dear Rulemakings and Adjudications Staff,

The Nuclear Energy Institute (NEI) 1, on behalf of our members, appreciates the opportunity to provide comments on the proposed amendments to 10 CFR 50.55a and respectfully requests that you review the comments in the attachment. The industry continues to review these regulations for opportunities to reduce regulatory burden to ensure that attention and resources remain focused on safe, reliable facility operation and that any changes to NRC requirements result in improved safety and efficiency.

We appreciate the NRCs effort in endorsing the latest editions of the ASME codes and standards and encourage your consideration of all stakeholder comments prior to finalizing the rule change. We trust that you will find these comments useful and informative.

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Rulemakings and Adjudications Staff May 25, 2021 Page 2

Please contact me at tbb@nei.org or (202) 739-8049 with any questions or comments about the content of this letter or the attached comments.

Sincerely,

Thomas Basso

Attachment

c: Andrea Veil, NRR/NRC Robert Taylor, NRR/NRC Andrea Kock, NRR/NRC Industry Comments on Proposed 10 CFR 50.55a Rule Change

Affected Section Comment Recommendation

1. 50.55a(b)(1)(xiii) (xiii)Section III Condition: Preservice Inspection of Steam Generator NEI recommends 10 CFR 50.55a(b)(1)(xiii)

Section III Tubes. Applicants or licensees applying the provisions of NB-5283 and NB -Section III Condition: Preservice Inspection of Condition 5360 in the 2019 Edition ofSection III, must apply paragraphs Steam Generator Tubes not be added to the (b)(1)(xiii)(A) through (B) of this section. rule, allowing licensees to determine and specify the requisite testing and inspection, Comments: including the appropriate and applicable criteria.

Prior to the 2017 Code edition, the Section III requirement for PSI for steam generator tubes was required by Section XI and existed to provide a baseline for Section XI exams. It was not related to any inspections or testing required to construct, stamp, or complete the NV-1 form.

Therefore, it had no relevance on the Section III construction of the Steam generator. It was just provided to support a requirement in Section XI.

Section XI deleted the requirements for PSI as a Section XI requirement in IWB-2200 via record 10-129 (incorporated in the 2017 Code Edition) and now just states that "Steam generator examinations are conducted in accordance with the program required by the plant Technical Specification."Section XI action 10-129 (incorporated in the 2017 Code Edition) changed IWB-2200(a) to remove steam generator tubing from the category of items requiring PSI prior to initial plant startup and created new Table IWB-2500-1 (B -Q) which states that s team generator examinations are conducted in accordance with the program required by the plant Technical Specification. Therefore,Section XI does not require a Section III manufacturer to provide a PSI for s team generator tubes, nor do they require a PSI for steam generator tubes to be completed prior to initial plant startup.

At the time of the Section III Construction when the manufacturer would perform the PSI, the manufacturer does not have access to the plant Technical Specifications. Therefore, the Section III manufacturer needs to Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 2 of 15

Affected Section Comment Recommendation

be provided with the inspection requireme nts and criteria. To accomplish this a requirement to conduct the PSI with the appropriate inspection criteria would need to be in the Section III Design Specification. Lacking this information any inspection done by the Section III manufacturer could be a meaningless activity at additional cost, since there is no certainty the inspection would meet the requirements of the plant Technical Specifications.

Since the only reason for the Section III requirement for a PSI of steam generator tubes was to support a Section XI requirement, and Section XI removed that requirement, this change to Section III was made to align Section III with the change that had already been incorporated in Section XI. The USNRC condition to require a specific PSI for steam generator tubes be done by the Section III manufacturer imposes additional costs on the manufacturer, is not required for Section III construction, may end up being not used, and is not consistent with Section XI requirements.

2. 50.55a(b)(2)(xxvi) (xxvi)Section XI condition: Pressure testing Class 1, 2, and 3 mechanical NEI recommends 10 CFR 50.55a(b)(2)(xxvi)

Section XI joints. Mechanical joints in Class 1, 2, and 3 piping and componentsSection XI Condition: Pressure Testing of Class Condition greater than NPS-1 which are disassembled and reassembled during the 1, 2, and 3 Mechanical Joints be completely performance of a Section XI repair/replacement activity requiring deleted from the new rule since it results in documentation on a Form NIS-2 shall be leak tested to ensure leak no additional safety benefit while increasing tightness. The owner shall establish the type of leak test, test medium, unnecessary administrative burden for test pressure, acceptance criteria that would demonstrate the joints leak licensees.

tightness, and the qualifications of the personnel who will perform the leak test.

Comments:

NEI recognizes that the NRC has revised this condition to make it somewhat more flexible for licensees. However, the condition still adds unnecessary burden by requiring licensees to make significant changes to Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 3 of 15

Affected Section Comment Recommendation

their ISI repair replacement programs to establish the type of leak test, test medium, test pressure, acceptance criteria that would demonstrate the joints leak tightness, and the qualifications of the personnel who will perform the leak test. Additionally, the condition will add administrative burden to implement these new requirements; all for no additional safety benefit. Licensees Appendix B quality and maintenance programs with the requisite site procedures to inspect and monitor for leakage at mechanical joints are and have been adequate to maintain the integrity of mechanical joints.

The NRC states on FR-2021-03-26 page 16093,. failure of a mechanical joint in the absence of a pressure test and VT-2 exam is unlikely, and the corresponding condition for Section XI pressure testing after repair/replacement activities is not needed for safety. The ASME agrees with this position and accordingly per IWA-4540(b)(1) exempts the replacement of bolts, studs, nuts, or washers from pressure testing.

The revised condition wording still does not address the conflict with the exemptions allowed per ASME IWA-4540(b)(1) without licensees having to submit a letter to obtain NRC approval for a previously approved code allowance.

3. 50.55a( b)(3)(iv) 10CFR50.55a(b)(3)(iv) OM Condition: Check Valves (Appendix II) NEI recommends 10CFR50.55a(b)(3)(iv) OM OM Condition Condition: Check Valves (Appendix II) be Comment: revised to be applicable to all addenda and editions of OM endorsed for use. In addition, Bases for Comment /

Background:

the overly restrictive language At least o ne of the identified activities for a valve group This condition was first imposed as part of final rulemaking dated July 17, shall be performed on each valve of the 2017 and became effective on August 17, 2017 (Fe deral Register / Vol. group at approximately equal intervals not to 82, No. 136). This condition effectively implemented new requirements exceed the maximum interval shown in Table which were added to the 2017 Edition of OM, Appendix II, II - II-4000-1 should be revised to simply Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 4 of 15

Affected Section Comment Recommendation

4000(b)(1)(e) that require distribution of Check Valve Condition require compliance with the maximum Monitoring (CVCM) activities for each v alve in a multi -valve group at intervals (both columns) shown in Table II-approximately equal intervals across the interval for the group. The 4000-1. This will provide flexibility for those language in the 2017 Edition of OM and this condition are essentially the CVCM plans that are not at the maximum same. intervals while also ensuring activities on individual valves are not deferred to the end While the goal for this condition and clarification in the 2017 Edition of of the group interval.

OM is appropriate, the actual language of these two documents have led to unintended consequences. The statement, At least one of the identified activities for a valve group shall be performed on each valve of the group at approximately equal intervals not to exceed the maximum interval shown in Table II-4000-1 has resulted in significant burden for licensees to the revise their CVCM program plans for compliance. The requirement to distribute the CVCM activities across each valve at equa l intervals is more prescriptive than necessary to ensure a licensee doesnt defer activities for all valves in a group to the end of the group interval.

Before this condition and OM change, most licensees performed CVCM activities on pairs of valves in a group or staggered the activities across the valve group interval in a manner that met the goal of distributing activities of multi-valve groups. However, the method of staggering activities did not meet the prescriptive language of this condition. As a result, the only way to comply with this condition and optimize testing is to split the group into smaller groups of valves or groups of one as permitted by II-2000(a). This is a significant burden on licensees and does not necessarily ensure a better distribution of activities.

Example:

Assume all activities for the group have not been completed such that interval extension is not allowed at the time the condition becomes effective.

Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 5 of 15

Affected Section Comment Recommendation

Before Condition:

1 group of 4 valves where activities on 2 valves in the group are performed every other outage

Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A, C B, D (A, B, C, D)

After Condition:

One group of four valves where activities on 1 valve in the group are performed every outage

Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A C B D (A, B, C, D)

OR

Two groups of t wo valves where activities on one valve in the group are performed every other outage

Group Outage 1 Outage 2 Outage 3 Outage 4 2 valves A B (A, B) 2 valves C D (C, D)

The example above demonstrates a case where a CVCM plan met the original intent of OM to stagger activities yet still must be revised to comply with the condition. In addition, the example shows two different Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 6 of 15

Affected Section Comment Recommendation

ways the CVCM program may be revised to order t o comply with this condition. The last method shows how the revised CVCM plan can comply with the condition without changing the schedule of activities.

The end result is that compliance with this condition imposed significant burden to revise CVCM plans w ith no increase in the level of safety.

4. 50.55a(b)(3)(xi) (xi) OM condition: Valve Position Indication. When implementing NEI recommends considering the following as OM Condition paragraph ISTC-3700, Position Verification Testing, in the ASME OM part of the revision to § 50.55a(b)(3)(xi):

Code, 2012 Edition through the latest edition of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section, licensees Licensees must verify that valve operation is must verify that valve operation is accurately indicated by supplementing accurately indicated by supplementing valve valve position indicating lights with other indications, such as flow meters position indicating lights with other or other suitable instrumentation to provide assurance of proper indications such as flow meters or other obturator position for valves with remote position indication within the suitable instrumentation during performance scope of Subsection ISTC including its mandatory appendices and their of remote position indication testing by ISTC-verification methods and frequencies. For valves not susceptible to stem-3700 to provide assurance of proper disk separation, the position verification testing specified in paragraph obturator position for valves with remote ISTC-3700 may be performed on a 10-year interval where the licensee position indication. ISTC-3700 requires documents a justification, which is made available for NRC review, remote position indication testing every 2 demonstrating that the stem-disk connection is not susceptible to years and the (b)(3)(xi) condition applies separation based on the internal design and evaluation of the stem-disk when the remote position indication test is connection using plant-specific and industry operating experience and performed (2 years from the previous remote vendor recommendations. position indication test). Supplemental position verification must be performed in Comments: conjunction with but not concurrent with remote position indication testing.

1. There were no changes made to the condition to clarify implementation of Supplemental Position Indication (SPI). Changes are Supplemental position verification for MOVs required to eliminate interpretation differences between the NRC and within the scope of Mandatory Appendix III Licensees: must be performed in conjunction with but not concurrent with III-3300(e) remote Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 7 of 15

Affected Section Comment Recommendation

a. Utilize modified wording that was presented by t he NRC during position indication testing. Supplemental public meeting: ISTC -3700 requires valve position verification position verification can be observed using testing every 2 years and the (b)(3)(xi) condition applies when performance-based verification methods and the ISTC -3700 test is performed (2 years from the previous [ISTC -frequencies within the scope of the ASME 3700] test). OM Code.

b. Clarify SPI is required to be performed in conjunction with (i.e.,

same surveillance) but not required to be concurrent with (i.e., Supplemental position verification not at the same time as) Position Verification testing following observations are not required for passive adoption of the ASME OM Code, 2012 Edition though the latest valves.

edition of the ASME OM Code.

c. Clarify SPI required surveillance due date for MOVs in Appendix Supplemental position verification III as Position Verification testing shifted from 2Y to the Appendix observations are required to start during III inservice testing frequency. For example, is the SPI test due performance of the first remote position date X years from the previous Position Verification test or X indication test following licensee years from the previous diagnostic test (where X years implementation of the ASME OM Code, 2012 represents the Appendix III inservice test interval). Edition through the latest edition of the

d. Clarify required surveillance due date when implementing ASME OM Code incorporated by reference in extended frequency testing for valves not susceptible to stem-paragraph (a)(1)(iv) of this section. If plant disc separation. For example, can SPI be performed 10Y from the conditions prohibit the initial supplemental last performance of a Position Verification test prior to position verification within the 2-year period implementing the latest edition of the Code? of the previously performed remote position

e. Confirm that MOV Position Verification testing, and therefore SPI indication test, then it shall be done at the testing, will follow the extended inservice test interval per OMN-next opportunity but prior to 24 months from 26 application. OMN-26 provides an alternate inservice test the implementation of ASME OM Code, 2012 interval based on individual valve Risk and Margin. The alternate Edition.

interval is applicable to III-3300 Inservice Test including III-3300(e) remote position indication and therefore SPI.

2. Passive Valves - Sites are performing modification where possible or removing valves from the IST program to eliminate the need to do SPI testing. The condition should be changed to eliminate SPI for passive Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 8 of 15

Affected Section Comment Recommendation

valves. If this change is not agreeable, then the condition should be changed to only perform SPI testing of passive valves in the valves normal passive position. Since these valves are not required to change position to perform their safety function, SPI verification and especially verification in both positions does not provide any benefit to safety.

a. As stated in EPRI 3002019621: The NRC monitors current industry -average nuclear power plant equipment performance on its website Industry Average Parameter Estimates. This website currently contains component reliability data through 2015, based on data from INPO. The Component Reliability Data Sheets on this website summarize failure data for various component types, including valves. The failure data is categorized by failure mode (e.g., failure to open), and the details of the failure (such as whether it was due to a stem-to-disk separation) are not included. This data is used by the NRC as input to their Standardized Plant Analysis Risk models and by nuclear plants in the Probabilistic Risk Assessment (PRA) models and provides a reference point against which the stem-to -disk failure data summarized later in this section can be compared.

This data should have identified any concerns with stem-to -disc failure, however, the NRC s SPAR modeling and industry use for PRA does not appear to identify any industry concerns of stem-to-disc failures. This would provide more documented data that passive valves and Non -susceptible stem -to -disk connections should be exempted for SPI.

3. Endorse ASME Code Case OMN-28s 12-year extended frequency for non-susceptible valves as approved or by name, versus the proposed NRC extended frequency wording of 10 years. OMN-28 provides additional guidance compared to the NRC proposed wording and will ensure there Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 9 of 15

Affected Section Comment Recommendation

are no interpretation issues that would require sites to prepare additional relief.

4. The proposed rulemaking has reduced the burden of testing valves not susceptible to stem -disc separation by allowing the test frequency to occur at a 10-year interval based on a sites justification. However, if a valve is determined to not be susceptible to stem -disc separation, then NEI recommends that SPI testing is not required at all and Position Verification testing (excluding SPI) continue once every 2 years. If a valve is non-susceptible, then the burden of adding additional testing to verify stem-to -disc integrity doesnt add value or benefit to safety.

5. Due to the detail provided in the EPRI Technical Report for evaluation of valve susceptibilit y, Susceptibility of Valve Applications to Failure of the Stem-to - disk Connection, it is recommended that it be referenced as an acceptable method for determination of valve susceptibility in support of implementing the proposed rulemaking or OMN-28.

6. The current condition states that SPI must be performed on valves with indicating lights that are within the scope of Subsection ISTC including applicable mandatory appendices. The condition also states that SPI can be performed by using other verification methods and frequencies within Subsection ISTC and applicable Mandatory Appendices that are performed at intervals greater than every two years.

The Local Leak Rate Testing (LLRT) prescribed by 10 CFR 50 Appendix J programs is also prescribed by Subsection ISTC. Based on the condition wording, licensees believe that prior NRC approval is not required for SPI testing to be performed on the LLRT frequency because it is prescribed by Subsection ISTC. However, to ensure alignment on this interpretation, and prevent additional burden, the condition should clarify that it is permitted to use NRC - approved seat leakage performance - based Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 10 of 15

Affected Section Comment Recommendation

frequencies for SPI, such as 10 CFR 50 Appendix J, approved performance-based Code Cases (OMN -23 and OMN-27), or NRC -

approved site-specific relief requests, without having to seek approval of more relief requests which would be redundant to already approved alternatives.

7. Stop check valves should be excluded from SPI.Per valve design, the disc is not connected to the stem. In this case, position indication is for the valve stem only and not the check valve disc.

5. 50.55a(f)(4) (4) Inservice testing standards requirement for operating plants. NEI recommends that the phrase without Inservice testing Throughout the service life of a boiling or pressurized water-cooled requesting relief under paragraph (f)(5) of standards nuclear power facility, pumps and valves that are within the scope of the this section or alternatives under paragraph requirement for ASME OM Code must meet the inservice test requirements (except design (z) of this section be retained in 10 CFR operating plants and access provisions) set forth in the ASME OM Code and addenda that 50.55a(f)(4) or this change be analyzed for become effective subsequent to editions and addenda specified in justification under the backfit rule per 10 CFR paragraphs (f)(2) and (3) of this section and that are incorporated by 50.109(a)(1).

reference in paragraph (a)(1)(iv) of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The inservice test requirements for pumps and valves that are within the scope of the ASME OM Code but are not classified as ASME BPV Code Class 1, Class 2, or Class 3 may be satisfied as an augmented IST program in accordance with paragraph (f)(6)(ii) of this section without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section. This use of an augmented IST program may be acceptable provided the basis for deviations from the ASME OM Code, as incorporated by reference in this section, demonstrates an acceptable level of quality and safety, or that implementing the Code provisions would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, where documented and available for NRC review.

Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 11 of 15

Affected Section Comment Recommendation

Comment:

10 CFR 50.55a(f)(4) requires that pumps and valves classified as ASME BPV Code Class 1, 2, 3, and non-Code Class be included within the scope of the IST program. Non -Code Class components are allowed to deviate from ASM E OM Code requirements without asking for prior NRC approval, provided that the basis for the deviation is justified to meet an acceptable level of quality and safety, or that implementing the Code requirements would result in hardship or unusual difficult y without a compensating increase in the level of quality and safety and the justification is documented in the Owners IST Program Plan. In the draft Rulemaking the phrase without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section" has been deleted.

The deletion of this phrase implies that there are some cases where non-Code Class components will require prior NRC approval without stating what those cases are. Owners currently maintain justifications for non-Code Class components that deviate from ASME OM Code requirements without prior NRC approval as allowed in 10 CFR 50.55a(f)(4). If the phrase is deleted these currently implemented justifications could be determined to require prior NRC approval even though the current CFR allows this. It appears that the deletion of this phrase imposes a new generic requirement causing licensees to modify procedures and therefore meeting the definition of a backfitting under 10 CFR 50.109(a)(1).

6. 50.55a(f)(7) (7) Inservice testing reporting requirements. Inservice Testing Program NEI recommends that § 50.55a(f)(7) not be Preservice and Test and Examination Plans (IST Plans) for pumps, valves, and dynamic included in the rule change to be consistent inservice testing restraints (snubbers) prepared to meet the requirements of the ASME OM with Inservice Inspection plans or as a requirements Code must be submitted to the NRC as specified in § 50.4. IST Plans must Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 12 of 15

Affected Section Comment Recommendation

be submitted within 90 days of their implementation for the applicable minimum only require submittal of IST Plans 120-month IST Program interval. IST Plan revisions must be submitted as part of interval updates.

when the final safety analysis report for the applicable nuclear power plant is updated. Electronic submission is preferred. If the NRC includes the proposed section 50.55a(f)(7) in the final rule, then the agency Comment: should provide a backfit ting analysis supporting imposition of the amended The proposed addition of § 50.55a(f)(7) will increase the frequency of the regulation, as required by section IST program plan submittals, thereby resulting in additional, unnecessary 50.109(a)(3).

regulatory burden. The new wording ties the IST Program Plan submittals to the Updated Final Safety Analysis Report (UFSAR) submittals. Section 50.71 (e)(4), requires that licensees file updated UFSARs annually or 6 months after each refueling outage provided the interval between successive updates does not exceed 24 months. Tying submittal of IST Program Plans to UFSAR updates will require the filing of IST Plans multiple times each interval. In contrast, the current editions of the ASME OM Code allows for a single submittal for the new 10-year interval and possible updates during the 10 years.If included in the final rule, this change will result in increased costs due to additional internal processing and reviews and will require changes to plant procedures (in many cases both regulatory procedures and IST program procedures).

In the proposed rule, NRC explained the need for this change stating that the agency needs these IST Plans for use in evaluating relief and alternative requests and to review deferral of quarterly testing to cold shutdowns and refueling outages. (86 Fed. Reg. 16,087, 16,096) But, as implemented in current editions of the ASME OM Code, IST Program Plans are not submitted until implemented at the beginning of each interval, i.e., after the start of the interval. Licensees typically submit relief requests prior to the start of the interval such that intervals are started with the appropriate code reliefs in place. Submitting an updated Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 13 of 15

Affected Section Comment Recommendation

IST Program Plan after the start of the interval does not aid the NRC in the review of these relief r equests.

Additionally, even an updated IST Program Plan submitted on the schedule proposed in section 50.55a(f)(7) may contain outdated information if it is used by NRC to review relief requests that are submitted after the start of the 10-year interval, but prior to the next UFSAR revision. If the NRC requires information from a licensees current IST Program Plan in order to review a relief request, the staff may request that information as part of its review of that specific relief request. This is the most efficient way for the NRC staff to ensure that it has the most up-to -date information necessary to complete its review.

Thus, there is no safety benefit associated with increasing the frequency of IST Plan submittals.

We also note that Code Case N -778, Alternative Requirements for Preparation and Submittal of Inservice Inspection Plans, Schedules, and Preservice and Inservice Inspection Summary Reports,Section XI, Division 1, as endorsed in the most recently approved Revision to Regul atory Guide 1.147, has eliminated the submittal of the Inservice Inspection Program Plans for the Inservice Inspection Program. If the proposed section 50.55a(f)(7) is included in the final rule, it will unnecessarily create inconsistencies between the IST and ISI programs, with no corresponding benefit to safety.

As discussed in the Federal Register Notice that endorsed the use of Code Case N -778 (83 FR 2331, dated January 17, 2018):

The NRC reviewed its needs with respect to the submittal of the subject plans, schedules, and reports, and determined that it is not necessary to require the submittal of plans and schedules. The NRC made this Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 14 of 15

Affected Section Comment Recommendation

determination because the latest up -to-date plans and schedules are available at the plant site and can be requested by the NRC at any time.

We see no reason why having current program plans available at plant sites and furnished by licensees upon request would be sufficient for the ISI program, b ut insufficient for the IST program.

Finally, from a backfitting perspective, section XII of the Federal Register notice states that the proposed rule would:

Add § 50.55a(f)(7) to state that IST Plans and interim IST Plan updates for pumps, valves, and dynamic restraints (snubbers) must be submitted to the NRC. This requirement was specified in the ASME OM Code up to the 2020 Edition, but the ASME removed this requirement from the 2020 Edition of the ASME OM Code as more appropriate to the regulatory authority responsibilities. Therefore, this rule change is not a backfit because the NRC is continuing the current requirement and is not imposing a new requirement.

But this description does not acknowledge that tying the submittal of IST Program Plans to submittal of the UFSAR will increase the frequency of the filings and is thus substantially different from current OM Code language. As proposed, section 50.55a(f)(7) would impose a requirement that is substantially different from the existing requirement (i.e., the pre -

2020 Edition of the ASME OM Code), as well as the 2020 Edition of the ASME OM Code that is being incorporated -by -reference in this rulemaking (which eliminates the requirement to submit IST Plans altogether).

As described in NUREG/BR -0058, Appendix D Guidance on Regulatory Analysis Related to ASME Code Changes, one of the scenarios in which Industry Comments on Proposed 10 CFR 50.55a Rule Change Page 15 of 15

Affected Section Comment Recommendation

the NRC considers adoption of a later code provision backfitting is when the NRC takes an exception to an ASME BPV or OM code provision and imposes a requirement that is substantially different from the current existing requirement as well as substantially different than the later code... This is precisely what will result if section 50.55a(f)(7) is included in the final rule - the pre-2020 OM Code re quirement allows a single submittal of the IST Plans at start of the interval, the 2020 OM Code does not require submittal at all, and the proposed section 50.55a(f)(7) would require submittal at least once every 24 months with the FSAR updates.

Further, a s state above, if this change in finalized it will require licensees to modify procedures required to implement their ASME Code programs and FSAR updates. Thus, this proposed amendment to section 50.55a meets the definition of backfitting contained in 10 C FR 50.109 and must meet the requirements of section 50.109(a)(3) prior to being imposed on licensees.

Submission ID 005 Thomas Vogan, American Society of Mechanical Engineers ADAMS Accession No. ML21146A041

From: Kathryn Hyam To: RulemakingComments Resource Cc: Nove, Carol; Mark Ferlisi; Tom Vogan; rcl@tnorthconsulting.com; PRESSBURGER, MAURY A; Oliver Martinez; Kimberly Verderber; Daniel Miro-Quesada; Adams, Timothy; Rick Swayne; skulat@inserviceeng.com; dlamond@tnorthconsulting.com; cnpendle@southernco.com; trugs@comcast.net; Allyson B. Byk; Robert Keating; MATTHEWS Dale (Framatome) (dale.matthews@framatome.com); MCINTYRE, JAMES W; sparkmand@sparkmanandassociates.com; tauniav@lanl.gov; Kathryn Hyam

Subject:

[External_Sender] ASME Comments on Draft 50.55a 2019-2020 Edition Rule - RIN 3150-AK22, Docket ID NRC-2018-0290 Date: Tuesday, May 25, 2021 3:09:51 PM Attachments: ASME Comments on Draft 50.55a 2019-2020 Edition Rule 05-24-2021.pdf Importance: High

To whom it may concern:

ASME is pleased to have the opportunity to provide comments and suggestions on Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, 10 CFR Part 50, RIN 3150- AK22, Docket ID NRC-2018-0290.

Please find attached the compiled comments from ASME for consideration during this rulemaking.

Sincerely,

Kate Hyam

Kate Hyam Director Nuclear Codes and Standards ASME 1828 L St. N.W.,

Washington, DC 20036-5104 Tel 1.212.591.8704 hyamk@asme.org

May 24, 2021

Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001

Attention: Rulemakings and Adjudications Staff

Subject:

Comments on Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, 10 CFR Part 50, RIN 3150-AK22, Docket ID NRC-2018- 0290

Reference:

1. Federal Register / Vol. 86, No. 57, pp. 16087-16114 / Friday, March 26, 2021/Proposed Rule

2. Federal Register/ Vol. 86, No. 90, pp. 25977-25978 / Wednesday, May 12, 2021, Proposed Rule; Correction

Dear Sir or Madam:

ASME is pleased to have the opportunity to provide comments and suggestions on your Nuclear Regulatory Commission (NRC), 10 CFR Part 50, RIN 3150-A K22, Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, Proposed Amended Requirements, published in Reference 1, as corrected in Reference 2.

Specifically, ASME supports the NRCs endorsement of later editions, addenda, and revisions to its Nuclear Codes, Standards, and Code Cases in the Code of Federal Regulations in 10 CFR 50.55a. It is our understanding that within this proposed rulemaking, the NRC is amending this regulation to incorporate by reference the following ASME Codes, Standards, and Code Cases:

1. The 2019 Editions of Section III, Division 1 and Section XI, Division 1 of the ASME Boiler and Pressure Vessel (BPV) Code, with conditions

2. The 2020 Edition of the ASME Operation and Maintenance (OM) Code, with conditions

3. NQA-1b-2011 Addenda, and the 2012 and 2015 Editions of ASME NQA-1, Quality Assurance Requirements for Nuclear Facility Applications The ASME comments included in Enclosures 1 and 2 are intended to support the nuclear industry while protecting the health and safety of the public, without placing unnecessary burden on licensees. Thus, Enclosures 1 and 2 are provided for the use by the NRC staff to support, reconsider, remove, or modify its proposed (and existing) conditions where comments are provided. It is hoped that upon review of these ASME comments that the NRC staff will be able to allow the necessary changes to be made or modify the conditions in the final rule to such a degree as to fully endorse the ASME Nuclear Codes and Standards contained in this proposed rulemaking.

May 24, 2021 Secretary, U.S. Nuclear Regulatory Commission Page 2

If you have any questions concerning the contents of this letter, please direct them to Ms.

Kathryn Hyam, Director, ASME Nuclear Codes & Standards by telephone (212) 591-8704 or by e-mail hyamk@asme.org.

Very Truly Yours,

Thomas J. Vogan, Chair ASME Board on Nuclear Codes and Standards Tomvogan45@gmail.com

Enclosures:

1. ASME Comments on 10 CFR 50.55a Proposed Rule

2. ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule

cc: Carol Nove, USNRC (carol.nove@nrc.gov)

Officers of the ASME Board on Nuclear Codes and Standards Officers of the ASME Standards Committee on Nuclear Inservice Inspection Officers of the ASME Standards Committee on Construction of Nuclear Facility Components Officers of the ASME Standards Committee on Operation and Maintenance of Nuclear Power Plants Officers of the ASME Standards Committee on Nuclear Quality Assurance (NQA)

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

§50.55a(b)(1) (1) Conditions on ASME BPV Code Section (1) Conditions on ASME BPV Code Section ASME has no comments on the proposed III. Each manufacturing license, standard design III. Each manufacturing license, standard design change.

approval, and design certification under 10 CFR approval, and design certification under 10 CFR part 52 is subject to the following conditions. As part 52 is subject to the following conditions. As used in this section, references to Section III used in this section, references to Section III refer to Section III of the ASME BPV Code and refer to Section III of the ASME BPV Code and include the 1963 Edition through 1973 Winter include the 1963 Edition through 1973 Winter Addenda and the 1974 Edition (Division 1) Addenda and the 1974 Edition (Division 1) through the 2017 Edition (Division 1), subject to through the latest edition and addenda the following conditions: incorporated by reference in paragraph (a)(1)(i) of this section, subject to the following conditions:

§50.55a(b)(1)(ii), Table I Table I - Prohibited Code Provisions. Table I - Prohibited Code Provisions. ASME has no comments on the proposed Editions and addenda Code provision Editions and addenda Code provision changes to §50.55a(b)(1)(ii), Table I - Prohibited Code Provisions.

1989 Addenda through Subparagraph NB-1989 Addenda through the Subparagraph NB-2013 Edition 3683.4(c)(1); latest edition and addenda 3683.4(c)(1);

Subparagraph NB-incorporated by reference Subparagraph NB-3683.4(c)(2). in paragraph (a)(1)(i) of 3683.4(c)(2).

this section.

1989 Addenda through Footnote 11 to Figure 1989 Addenda through Footnote 11 to Figure NC-2003 Addenda NC-3673.2(b)- 1; 2003 Addenda3673.2(b)-1; Note 11 to Footnote 11 to Figure Figure ND-3673.2(b)-1.

ND-3673.2(b)-1.

2004 Edition through 2010 Footnote 13 to Figure 2004 Edition through 2010 Footnote 13 to Figure NC-Edition NC-3673.2(b)- 1; Edition 3673.2(b)-1; Note 13 to Footnote 13 to Figure Figure ND-3673.2(b)-1.

ND-3673.2(b)-1.

2011 Addenda through Footnote 11 to Table 2011 Addenda through the Footnote 11 to Table NC-2017 Edition NC-3673.2(b)- 1; latest edition and addenda 3673.2(b)-1; Note 11 to Footnote 11 to Table incorporated by reference Table ND-3673.2(b)-1.

ND-3673.2(b)- 1. in paragraph (a)(1)(i) of this section.

§50.55a(b)(1)(iii) (iii)Section III condition: Seismic design of (iii)Section III condition: Seismic design of ASME has no comments on the proposed piping. Applicants or licensees may use piping. Applicants or licensees may use change.

Subarticles NB-3200, NB-3600, NC-3600, and Subarticles NB-3200, NB-3600, NC-3600, and ND-3600 for seismic design of piping, up to and ND-3600 for seismic design of piping, up to and including the 1993 Addenda, subject to the including the 1993 Addenda, subject to the condition specified in paragraph (b)(1)(ii) of this condition specified in paragraph (b)(1)(ii) of this section. Applicants or licensees may not use section. Applicants or licensees may not use

Page 1 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

these subarticles for seismic design of piping in these subarticles for seismic design of piping in the 1994 Addenda through the 2005 Addenda the 1994 Addenda through the 2005 Addenda incorporated by reference in paragraph (a)(1) of incorporated by reference in paragraph (a)(1) of this section, except that Subarticle NB -3200 in this section, except that Subarticle NB -3200 in the 2004 Edition through the 2017 Edition may the 2004 Edition through the 2017 Edition may be used by applicants and licensees, subject to be used by applicants and licensees, subject to the condition in paragraph (b)(1)(iii)(A) of this the condition in paragraph (b)(1)(iii)(A) of this section. Applicants or licensees may use section. Applicants or licensees may use Subarticles NB-3600, NC-3600, and ND-3600 Subarticles NB-3600, NC-3600, and ND-3600 for the seismic design of piping in the 2006 for the seismic design of piping in the 2006 Addenda through the 2017 Edition, subject to Addenda through the latest edition and addenda the conditions of this paragraph corresponding incorporated by reference in paragraph (a)(1)(i) to those subarticles. of this section, subject to the conditions of this paragraph (b)(1)(iii) corresponding to those subarticles.

§50.55a(b)(1)(iv) (iv)Section III condition: Quality assurance. (iv)Section III condition: Quality assurance. ASME supports the proposed revision to When applying editions and addenda later than When applying editions and addenda later than §50.55a(b)(1)(iv).

the 1989 Edition of Section III, the requirements the 1989 Edition of Section III, an applicant or of NQA-1, "Quality Assurance Requirements for licensee may use the requirements of NQA -1, Nuclear Facility Applications," 1994 Edition, Quality Assurance Requirements for Nuclear 2008 Edition, and the 2009-1a Addenda Facility Applications, that is both incorporated by specified in either NCA-4000 or NCA-7000 of reference in paragraph (a)(1)(v) of this section that edition and addenda of Section III may be and specified in either NCA -4000 or NCA-7000 used by an applicant or licensee, provided that of that Edition and Addenda of Section III, the administrative, quality, and technical provided that the administrative, quality, and provisions contained in that edition and addenda technical provisions contained in that Edition and of Section III are used in conjunction with the Addenda of Section III are used in conjunction applicant's or licensee's appendix B to this part with the applicants or licensees appendix B to quality assurance program; and that the this part quality assurance program; and that the applicant's or licensee'sSection III activities applicants or licenseesSection III activities comply with those commitments contained in the comply with those commitments contained in the applicant's or licensee's quality assurance applicants or licensees quality assurance program description. Where NQA-1 and Section program description. Where NQA -1 and Section III do not address the commitments contained in III do not address the commitments contained in the applicant's or licensee's appendix B quality the applicants or licensees appendix B quality assurance program description, those licensee assurance program description, those licensee commitments must be applied to Section III commitments must be applied to Section III activities. activities.

Page 2 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

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§50.55a(b)(1)(vii) (vii)Section III condition: Capacity (vii)Section III condition: Capacity certification ASME has no comments on the proposed certification and demonstration of function of and demonstration of function of incompressible-change.

incompressible-fluid pressure-relief valves. fluid pressure-relief valves. When applying the When applying the 2006 Addenda through all 2006 Addenda through all editions and addenda editions and addenda up to and including the up to and including the latest edition and 2017 Edition, applicants and licensees may use addenda incorporated by reference in paragraph paragraph NB-7742, except that paragraph NB- (a)(1)(i) of this section, applicants and licensees 7742(a)(2) may not be used. For a valve design may use paragraph NB -7742, except that of a single size to be certified over a range of set paragraph NB-7742(a)(2) may not be used. For pressures, the demonstration of function tests a valve design of a single size to be certified over under paragraph NB-7742 must be conducted a range of set pressures, the demonstration of as prescribed in NB-7732.2 on two valves function tests under paragraph NB -7742 must be covering the minimum set pressure for the conducted as prescribed in NB-7732.2 on two design and the maximum set pressure that can valves covering the minimum set pressure for the be accommodated at the demonstration facility design and the maximum set pressure that can selected for the test. be accommodated at the demonstration facility selected for the test.

§50.55a(b)(1)(x) (x)Section III Condition: Visual examination (x)Section III Condition: Visual examination of ASME has no comments on the proposed of bolts, studs and nuts. Applicants or licensees bolts, studs and nuts. Applicants or licensees change.

applying the provisions of NB-2582, NC-2582, applying the provisions of NB-2582, NC-2582, ND-2582, NE-2582, NF-2582, NG-2582 in the ND-2582, NE-2582, NF-2582, NG-2582 in the 2017 Edition of Section III, must apply 2017 Edition of Section III through the latest paragraphs (b)(1)(x)(A) through (B) of this edition and addenda incorporated by reference in section. paragraph (a)(1)(i) of this section, must apply (A) Visual examination of bolts, studs, and nuts: paragraphs (b)(1)(x)(A) through (B) of this First provision. When applying the provisions of section.

NB-2582, NC-2582, ND-2582, NE-2582, NF- (A) Visual examination of bolts, studs, and 2582, NG-2582 in the 2017 Edition of Section nuts: First provision. When applying the III, the visual examinations are required to be provisions of NB -2582, NC-2582, ND-2582, performed in accordance with procedures NE-2582, NF-2582, NG-2582 in the 2017 qualified to NB-5100, NC-5100, ND-5100, NE-Edition of Section III through the latest edition 5100, NF-5100, NG-5100 and performed by and addenda incorporated by reference in personnel qualified in accordance with NB-paragraph (a)(1)(i) of this section, the visual 5500, NC-5500, ND-5500, NE-5500, NF-5500, examinations are required to be performed in and NG-5500. accordance with procedures qualified to NB -

(B) Visual examination of bolts, studs, and nuts: 5100, NC-5100, ND-5100, NE-5100, NF-5100, Second provision. When applying the provisions NG-5100 and performed by personnel qualified of NB-2582, NC-2582, ND-2582, NE-2582, in accordance with NB-5500, NC-5500, ND-5500, NE-5500, NF-5500, and NG-5500.

Page 3 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

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NF-2582, and NG-2582 in the 2017 Edition of (B) Visual examination of bolts, studs, and Section III, bolts, studs, and nuts must be nuts: Second provision. When applying the visually examined for discontinuities including provisions of NB -2582, NC-2582, ND-2582, cracks, bursts, seams, folds, thread lap, voids, NE-2582, NF-2582, and NG -2582 in the 2017 and tool marks. Edition of Section III through the latest edition and addenda incorporated by reference in paragraph (a)(1)(i) of this section, bolts, studs, and nuts must be visually examined for discontinuities including cracks, bursts, seams, folds, thread lap, voids, and tool marks.

§50.55a(b)(1)(xiii) N/A (xiii)Section III Condition: Preservice Prior to the 2017 Code edition, the Section III Inspection of Steam Generator Tubes. Applicants requirement for PSI for steam generator tubes or licensees applying the provisions of NB-5283 was required by Section XI and existed to and NB-5360 in the 2019 Edition of Section III, provide a baseline for Section XI exams. It was must apply paragraphs (b)(1)(xiii)(A) through (B) not related to any inspections or testing required of this section. to construct, stamp, or completed the NV -1 form.

(A) Preservice Inspection of Steam Generator Therefore, it had no relevance on the Section III Tubes: First provision. When applying the construction of the Steam generator. It was just provisions of NB -5283 in the 2019 Edition of provided to support a requirement in Section XI.

Section III, a full-length preservice examination of Section XI deleted the requirements for PSI as a 100 percent of the steam generator tubing in Section XI requirement in IWB-2200 via record each newly installed steam generator must be 10-129 (incorporated in the 2017 Code Edition) performed prior to plant startup. and now just states that "Steam generator (B) Preservice Inspection of Steam Generator examinations are conducted in accordance with Tubes: Second provision. When applying the the program required by the plant Technical provisions of NB - 5360 in the 2019 Edition of Specification."Section XI action 10-129 Section III, flaws revealed during preservice (incorporated in the 2017 Code Edition) changed examination of steam generator tubing performed IWB-2200(a) to remove steam generator tubing in accordance with paragraph (b)(1)(xiii)(A) of from the category of items requiring PSI prior to this section must be evaluated using the criteria initial plant startup and created new Table IWB -

in the design specifications. 2500-1 (B -Q) which states that Steam generator examinations are conducted in accordance with the program required by the plant Technical Specification. Therefore,Section XI does not require a Section III manufacturer to provide a PSI for Steam Generator tubes nor do they require a PSI for steam generator tubes to be completed prior to initial plant startup.

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At the time of the Section III Construction when the manufacturer would perform the PSI, the manufacturer does not have access to the plant Technical Specifications. Therefore, the Section III manufacturer needs to be provided with the inspection requirements and criteria. To accomplish this a requirement to conduct the PSI with the appropriate inspection criteria would need to be in the Section III Design Specification.

Lacking this information any inspection done by the Section III manufacturer, could be a meaningless activity, at additional cost, since there is no certainty that the inspection would meet the requirements of the plant Technical Specifications.

Since the only reason for the requirement for the Section III requirement for a PSI of steam generator tubes was to support a Section XI requirement and Section XI removed that requirement, this change to Section III was made to align Section III with the change that had already been incorporated in Section XI. The USNRC conditions to impose a specific PSI for steam generator tubes be done by the Section III manufacturer imposes additional costs on the manufacturer, is not required for Secti on III construction, may end up being not used, and is not consistent with Section XI requirements.

Therefore, ASME strongly recommends that this condition be removed in the final rule.

§50.55a(b)(2)(viii) (viii)Section XI condition: Concrete (viii)Section XI condition: Concrete containment This condition removes references to several containment examinations. Applicants or examinations. Applicants or licensees applying older editions and addenda of Section XI that licensees applying Subsection IWL, 1992 Subsection IWL, 2001 Edition through the 2004 are no longer in use in the United States.

Edition with the 1992 Addenda, must apply Edition, up to and including the 2006 Addenda, ASME supports the proposed revision to paragraphs (b)(2)(viii)(A) through (E) of this must apply paragraphs (b)(2)(viii)(E) through (G) §50.55a(b)(2)(viii).

section. Applicants or licensees applying of this section. Applicants or licensees applying Subsection IWL, 1995 Edition with the 1996 Subsection IWL, 2007 Edition up to and including Addenda, must apply paragraphs (b)(2)(viii)(A), the 2008 Addenda must apply paragraph

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(b)(2)(viii)(D)(3), and (b)(2)(viii)(E) of this (b)(2)(viii)(E) of this section. Applicants or section. Applicants or licensees applying licensees applying Subsection IWL, 2007 Edition Subsection IWL, 1998 Edition through the 2000 with the 2009 Addenda through the latest edition Addenda, must apply paragraphs (b)(2)(viii) (E) and addenda incorporated by reference in and (F) of this section. Applicants or licensees paragraph (a)(1)(ii) of this section, must apply applying Subsection IWL, 2001 Edition through paragraphs (b)(2)(viii)(H) and (I) of this section.

the 2004 Edition, up to and including the 2006 Addenda, must apply paragraphs (b)(2)(viii)(E) through (G) of this section. Applicants or licensees applying S ubsection IWL, 2007 Edition up to and including the 2008 Addenda must apply paragraph (b)(2)(viii)(E) of this section. Applicants or licensees applying Subsection IWL, 2007 Edition with the 2009 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, must apply paragraphs (b)(2)(viii)(H) and (I) of this section.

§50.55a(b)(2)(viii)(A) (A) Concrete containment examinations: (A) >ReserYed@ ASME supports the proposed deletion of First provision. Grease caps that are accessible §50.55a(b)(2)(viii)(A).

must be visually examined to detect grease leakage or grease cap deformations. Grease caps must be removed for this examination when there is evidence of grease cap deformation that indicates deterioration of anchorage hardware.

§50.55a(b)(2)(viii)(B) (B) Concrete containment examinations: (B) [Reserved] ASME supports the proposed deletion of Second provision. When evaluation of §50.55a(b)(2)(viii)(B).

consecutive surveillances of pre-stressing forces for the same tendon or tendons in a group indicates a trend of pre-stress loss such that the tendon force(s) would be less than the minimum design pre-stress requirements before the next inspection interval, an evaluation must be performed and reported in the Engineering Evaluation Report as prescribed in IWL-3300.

§50.55a(b)(2)(viii)(C) (C) Concrete containment examinations: (C) [Reserved] ASME supports the proposed deletion of Third provision. When the elongation §50.55a(b)(2)(viii)(C).

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corresponding to a specific load (adjusted for effective wires or strands) during re-tensioning of tendons differs by more than 10 percent from that recorded during the last measurement, an evaluation must be performed to determine whether the difference is related to wire failures or slip of wires in anchorage. A difference of more than 10 percent must be identified in the ISI Summary Report required by IWA-6000.

§50.55a(b)(2)(Yiii)(D) (D) Concrete containment examinations: (D) >ReserYed@ ASME supports the proposed deletion of Fourth provision. The applicant or licensee must §50.55a(b)(2)(viii)(D).

report the following conditions, if they occur, in the ISI Summary Report required by IWA -6000:

(1) The sampled sheathing filler grease contains chemically combined water exceeding 10 percent by weight or the presence of free water; (2) The absolute difference between the amount removed and the amount replaced exceeds 10 percent of the tendon net duct volume; and (3) Grease leakage is detected during general visual examination of the containment surface.

§50.55a(b)(2)(ix) (ix)Section XI condition: Metal containment (ix)Section XI condition: Metal containment This condition removes references to several examinations. Applicants or licensees applying examinations. Applicants or licensees applying older editions and addenda of Section XI that are Subsection IWE, 1992 Edition with the 1992 Subsection IWE, 2001 Edition up to and including no longer in use in the United States.

Addenda, or the 1995 Edition with the 1996 the 2003 Addenda, must satisfy the requirements ASME supports the proposed revision to Addenda, must satisfy the requirements of of paragraphs (b)(2)(ix)(A) and (B), (F) through §50.55a(b)(2)(ix).

paragraphs (b)(2)(ix)(A) through (E) and (I), and (K) of this section. Applicants or (b)(2)(ix)(K) of this section. Applicants or licensees applying Subsection IWE, 2004 licensees applying Subsection IWE, 1998 Edition, up to and including the 2005 Addenda, Edition through the 2001 Edition with the 2003 must satisfy the requirements of paragraphs Addenda, must satisfy the requirements of (b)(2)(ix)(A) and (B), (F) through (H), and (K) of paragraphs (b)(2)(ix)(A) and (B) and (b)(2)(ix)(F) this section. Applicants or licensees applying through (I) and (b)(2)(ix)(K) of this section. Subsection IWE, 2004 Edition with the 2006 Applicants or licensees applying Subsection Addenda, must satisfy the requirements of IWE, 2004 Edition, up to and including the 2005 paragraphs (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and

Page 7 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

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Addenda, must satisfy the requirements of (K) of this section. Applicants or licensees paragraphs (b)(2)(ix)(A) and (B) and (b)(2)(ix)(F) applying Subsection IWE, 2007 Edition through through (H) and (b)(2)(ix)(K) of this section. the 2015 Edition, must satisfy the requirements Applicants or licensees applying Subsection of paragraphs (b)(2)(ix)(A)(2) and (b)(2)(ix)(B),

IWE, 2004 Edition with the 2006 Addenda, must (J), and (K) of this section. Applicants or satisfy the requirements of paragraphs licensees applying Subsection IWE, 2017 (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and (b)(2)(ix)(K) Edition, through the latest edition and addenda of this section. Applicants or licensees applying incorporated by reference in paragraph (a)(1)(ii)

Subsection IWE, 2007 Edition through the 2015 of this section must satisfy the requirements of Edition, must satisfy the requirements of paragraphs (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and paragraphs (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and (J) of this section.

(J) and (K) of this section. Applicants or licensees applying Subsection IWE, 2017 Edition, must satisfy the requirements of paragraphs (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and (J) of this section.

§50.55a(b)(2)(ix)(B) (B) Metal containment examinations: Second (B) Metal containment examinations: Second ASME supports the proposed revision to provision. When performing remotely the visual provision. When performing remotely the visual §50.55a(b)(2)(ix)(B).

examinations required by Subsection IWE, the examinations required by Subsection IWE, the maximum direct examination distance specified maximum direct examination distance specified in Table IWA-2210- 1 (1992 Edition through in Table IWA-2210- 1 (2001 Edition through 2004 Edition) or Table IWA-2211-1 (2005 2004 Edition) or Table IWA -2211-1 (2005 Addenda through the latest edition and addenda Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1) of incorporated by reference in paragraph (a)(1) of this section) may be extended and the minimum this section) may be extended and the minimum illumination requirements specified may be illumination requirements specified may be decreased provided that the conditions or decreased provided that the conditions or indications for which the visual examination is indications for which the visual examination is performed can be detected at the chosen performed can be detected at the chosen distance and illumination. distance and illumination.

§50.55a(b)(2)(ix)(C) (C) Metal containment examinations: Third (C) [Reserved] ASME supports the proposed deletion of provision. The examinations specified in §50.55a(b)(2)(ix)(C).

Examination Category E-B, Pressure Retaining Welds, and Examination Category E-F, Pressure Retaining Dissimilar Metal Welds, are optional.

§50.55a(b)(2)(ix)(D) (D) Metal containment examinations: Fourth (D) [Reserved] ASME supports the proposed deletion of provision. This paragraph (b)(2)(ix)(D) may be §50.55a(b)(2)(ix)(D).

used as an alternative to the requirements of

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IWE-2430. If the examinations reveal flaws or areas of degradation exceeding the acceptance standards of Table IWE-3410- 1, an evaluation must be performed to determine whether additional component examinations are required. For each flaw or area of degradation identified that exceeds acceptance standards, the applicant or licensee must provide the following in the ISI Summary Report required by IWA-6000:

(1) A description of each flaw or area, including the extent of degradation, and the conditions that led to the degradation; (2) The acceptability of each flaw or area and the need for additional examinations to verify that similar degradation does not exist in similar components; (3) A description of necessary corrective actions; and (4) The number and type of additional examinations to ensure detection of similar degradation in similar components.

§50.55a(b)(2)(ix)(E) (E) Metal containment examinations: Fifth (E) [Reserved] ASME supports the proposed deletion of provision. A general visual examination as §50.55a(b)(2)(ix)(E).

required by Subsection IWE must be performed once each period.

§50.55a(b)(2)(ix)(J) (J) Metal containment examinations: Tenth (J) Metal containment examinations: Tenth ASME has no comments on the proposed provision. In general, a repair/replacement provision. In general, a repair/ replacement change.

activity such as replacing a large containment activity such as replacing a large containment penetration, cutting a large construction opening penetration, cutting a large construction opening in the containment pressure boundary to replace in the containment pressure boundary to replace steam generators, reactor vessel heads, steam generators, reactor vessel heads, pressurizers, or other major equipment; or other pressurizers, or other major equipment; or other similar modification is considered a major similar modification is considered a major containment modification. When applying IWE-containment modification. When applying IWE -

5000 to Class MC pressure-retaining 5000 to Class MC pressure-retaining components, any major containment components, any major containment modification

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modification or repair/replacement must be or repair/replacement must be followed by a followed by a Type A test to provide assurance Type A test to provide assurance of both of both containment structural integrity and leak-containment structural integrity and leak -tight tight integrity prior to returning to service, in integrity prior to returning to service, in accordance with 10 CFR part 50, Appendix J, accordance with appendix J to this part, Option A Option A or Option B on which the applicant's or or Option B, on which the applicants or licensee's Containment Leak-Rate Testing licensees Containment Leak -Rate Testing Program is based. When applying IWE-5000, if Program is based. When applying IWE -5000, if a a Type A, B, or C Test is performed, the test Type A, B, or C Test is performed, the test pressure and acceptance standard for the test pressure and acceptance standard for the test must be in accordance with 10 CFR part 50, must be in accordance with appendix J to this Appendix J. part.

§50.55a(b)(2)(x) (x)Section XI condition: Quality assurance. (x)Section XI condition: Quality assurance. ASME has no comments on the proposed When applying the editions and addenda later When applying the editions and addenda later change.

than the 1989 Edition of ASME BPV Code, than the 1989 Edition of ASME BPV Code,Section XI, the edition and addenda of NQA-1,Section XI, licensees may use any edition or "Quality Assurance Requirements for Nuclear addenda of NQA-1, Quality Assurance Facility Applications," 1994 Edition, the 2008 Requirements for Nuclear Facility Applications, Edition, and the 2009-1a Addenda specified in that is both incorporated by reference in either IWA-1400 or Table IWA 1600- 1 of that paragraph (a)(1)(v) of this section and specified edition and addenda of Section XI, may be used in Table IWA 1600- 1 of that edition and addenda by a licensee provided that the licensee uses its of Section XI, provided that the licensee uses its appendix B to this part quality assurance appendix B to this part quali ty assurance program in conjunction with Section XI program in conjunction with Section XI requirements and the commitments contained in requirements and the commitments contained in the licensee's quality assurance program the licensees quality assurance program description. Where NQA-1 and Section XI do description. Where NQA -1 and Section XI do not not address the commitments contained in the address the commitments contained in the licensee's appendix B quality assurance licensees appendix B quality assurance program program description, those licensee description, those licensee commitments must be commitments must be applied to Section XI applied to Section XI activities.

activities.

§50.55a(b)(2)(xii) (xii)Section XI condition: Underwater (xii)Section XI condition: Underwater welding. ASME has no comments on the proposed welding. The provisions in IWA-4660, The provisions in IWA-4660, Underwater change.

"Underwater Welding," of Section XI, 1997 Welding, of Section XI, 2001 Edition through the Addenda through the latest edition and addenda latest edition and addenda incorporated by incorporated by reference in paragraph (a)(1)(ii) reference in paragraph (a)(1)(ii) of this section, of this section, are approved for use on are approved for use on irradiated material with irradiated material with the following conditions: the following conditions:

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(A) Underwater welding: First provision. (A) Underwater welding: First provision.

Licensees must obtain NRC approval in Licensees must obtain NRC approval in accordance with paragraph (z) of this section accordance with paragraph (z) of this section regarding the welding technique to be used prior regarding the welding technique to be used prior to performing welding on ferritic material to performing welding on ferritic material exposed exposed to fast neutron fluence greater than 1 x to fast neutron fluence greater than 1 x 10 17 1017 n/cm2 (E > 1 MeV). n/cm2 (E > 1 MeV).

(B) Underwater welding: Second provision. (B) Underwater welding: Second provision.

Licensees must obtain NRC approval in Licensees must obtain NRC approval in accordance with paragraph (z) of this section accordance with paragraph (z) of this section regarding the welding technique to be used prior regarding the welding technique to be used prior to performing welding on austenitic material to performing welding on austenitic material other other than P-No. 8 material exposed to thermal than P-No. 8 material exposed to thermal neutron neutron fluence greater than 1 x 1017 n/cm2 (E < fluence greater than 1 x 1017 n/cm2 (E < 0.5 eV).

0.5 eV). Licensees must obtain NRC approval in Licensees must obtain NRC approval in accordance with paragraph (z) regarding the accordance with paragraph (z) regarding the welding technique to be used prior to performing welding technique to be used prior to performing welding on P-No. 8 austenitic material exposed welding on P-No. 8 austenitic material exposed to thermal neutron fluence greater than 1 x 1017 to thermal neutron fluence greater than 1 x 10 17 n/cm2 (E < 0.5 eV) and measured or calculated n/ cm2 (E < 0.5 eV) and measured or calculated helium concentration of the material greater than helium concentration of the material greater than 0.1 atomic parts per million. 0.1 atomic parts per million.

§50.55a(b)(2)(xiv) (xiv)Section XI condition: Appendix VIII (xiv)Section XI condition: Appendix VIII ASME has no comments on the proposed personnel qualification. All personnel qualified personnel qualification. All personnel qualified for change.

for performing ultrasonic examinations in performing ultrasonic examinations in accordance with Appendix VIII must receive 8 accordance with Appendix VIII must receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens hours of annual hands -on training on specimens that contain cracks. Licensees applying the 1999 that contain crack s. Licensees applying the 2001 Addenda through the latest edition and addenda Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) incorporated by reference in paragraph (a)(1)(ii) of this section may use the annual practice of this section may use the annual practice requirements in VII-4240 of Appendix VII of requirements in VII -4240 of Appendix VII of Section XI in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual Section XI in place of the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training provided that the hands-on training provided that the supplemental supplemental practice is performed on material practice is performed on material or welds that or welds that contain cracks, or by analyzing contain cracks, or by analyzing prerecorded data prerecorded data from material or welds that from material or welds that contain cracks. In contain cracks. In either case, training must be either case, training must be completed no earlier completed no earlier than 6 months prior to

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performing ultrasonic examinations at a than 6 months prior to performing ultrasonic licensee's facility. examinations at a licensees facility.

§50.55a(b)(2)(xv) (xv)Section XI condition: Appendix VIII N/A ASME recommends that the condition be specimen set and qualification requirements. revised to apply only to the 2001 Edition and Licensees using Appendix VIII in the 1995 later editions and addenda. ASME notes that Edition through the 2001 Edition of the ASME the NRCs markup of the existing regulations Boiler and Pressure Vessel Code may elect to included this change, but the proposed change comply with all of the provisions in paragraphs was not included in the Federal Register Notice (b)(2)(xv)(A) through (M) of this section, except for the proposed rule.

for paragraph (b)(2)(xv)(F) of this section, which may be used at the licensee's option. Licensees using editions and addenda after 2001 Edition through the 2006 Addenda must use the 2001 Edition of Appendix VIII and may elect to comply with all of the provisions in paragraphs (b)(2)(xv)(A) through (M) of this section, except for paragraph (b)(2)(xv)(F) of this section, which may be used at the licensee's option.

§50.55a(b)(2)(xviii)(A) (A) NDE personnel certification: First (A) NDE personnel certification: First ASME has no comments on the proposed provision. Level I and II nondestructive provision. Level I and II nondestructive change.

examination personnel must be recertified on a examination personnel must be recertified on a 3-year interval in lieu of the 5-year interval 3-year interval in lieu of the 5-year interval specified in the 1997 Addenda and 1998 Edition specified in IWA-2314(a) and IWA -2314(b) of of IWA-2314, and IWA-2314(a) and IWA-the 2001 Edition through the latest edition and 2314(b) of the 1999 Addenda through the latest addenda incorporated by reference in paragraph edition and addenda incorporated by reference (a)(1)(ii) of this section.

in paragraph (a)(1)(ii) of this section.

§50.55a(b)(2)(xviii)(D) (D) NDE personnel certification: Fourth (D) NDE personnel certification: Fourth ASME supports the proposed changes to provide provision. The use of Appendix VII, Table VII-provision. The use of Appendix VII, Table VII-alternative personnel qualification provisions.

4110- 1 and Appendix VIII, Subarticle VIII-2200 4110- 1 and Appendix VIII, Subarticle VIII-2200 of of the 2011 Addenda through the latest edition the 2011 Addenda through the latest edition incorporated by reference in paragraph (a)(1)(ii) incorporated by reference in paragraph (a)(1)(ii) of of this section is prohibited. When using ASME this section is prohibited. When using ASME BPV BPV Code,Section XI editions and addenda Code,Section XI editions and addenda later than later than the 2010 Edition, licensees and the 2010 Edition, licensees and applicants must applicants must use the prerequisites for use the prerequisites for ultrasonic examination ultrasonic examination personnel certifications in personnel certifications in Appendix VII, Table Appendix VII, Table VII-4110- 1 and Appendix VII-4110- 1 and Appendix VIII, Subarticle VIII-VIII, Subarticle VIII-2200 in the 2010 Edition. 2200 in the 2010 Edition.

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(1) As an alternative to Note (c) in Table VII-4110- 1 of ASME BPV Code,Section XI, 2010 Edition, the 250 hours0.00289 days <br />0.0694 hours <br />4.133598e-4 weeks <br />9.5125e-5 months <br /> of Level I experience time may be reduced to 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, if the experience time includes a minimum of 125 hours0.00145 days <br />0.0347 hours <br />2.066799e-4 weeks <br />4.75625e-5 months <br /> of field experience and 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of laboratory practice beyond the requirements of for training in accordance with Appendix VII Subarticle 4220, provided those practice hours are dedicated to the Level I or Level II skill areas as described in ANSI/ ASNT CP-189.

(2) As an alternative to Note (d) in Table VII-4110- 1 of ASME BPV Code,Section XI, 2010 Edition, the 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of Level II experience time may be reduced to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />, if the experience time includes a minimum of 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> of field experience and a minimum of 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> of laboratory practice. The practice must be dedicated to scanning specimens containing flaws in materials representative of those in actual power plant components. Additionally, for Level II Certification, the candidate must pass a Mandatory Appendix VIII, Supplement 2 performance demonstration for detection and length sizing.

§50.55a(b)(2)(xix) (xix)Section XI condition: Substitution of (xix)Section XI condition: Substitution of ASME has no comments on the proposed alternative methods. The provisions for alternative methods. The provisions for change.

substituting alternative examination methods, a substituting alternative examination methods, a combination of methods, or newly developed combination of methods, or newly developed techniques in the 1997 Addenda of IWA-2240 techniques in the 1997 Addenda of IWA -2240 must be applied when using the 1998 Edition must be applied when using the 2001 Edition through the 2004 Edition of Section XI of the through the 2004 Edition of Section XI of the ASME BPV Code. The provisions in IWA-ASME BPV Code. The provisions in IWA-4520(c), 1997 Addenda through the 2004 4520(c), 2001 Edition through the 2004 Edition, Edition, allowing the substitution of alternative allowing the substitution of alternative methods, a methods, a combination of methods, or newly combination of methods, or newly developed developed techniques for the methods specified techniques for the methods specified in the in the Construction Code, are not approved for Construction Code, are not approved for use.

use. The provisions in IWA-4520(b)(2) and The provisions in IWA-4520(b)(2) and IWA-

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IWA-4521 of the 2008 Addenda through the 4521 of the 2008 Addenda through the latest latest edition and addenda incorporated by edition and addenda incorporated by reference in reference in paragraph (a)(1)(ii) of this section, paragraph (a)(1)(ii) of this section, allowing the allowing the substitution of ultrasonic substitution of ultrasonic examination for examination for radiographic examination radiographic examination specified in the specified in the Construction Code, are not Construction Code, are not approved for use.

approved for use.

§50.55a(b)(2)(xx)(A) (A) System leakage tests: First provision. (A) System leakage tests: First provision. ASME supports the proposed change to limit the When performing system leakage tests in When performing system leakage tests in condition to the 2001 Edition through the 2002 accordance with IWA-5213(a), 1997 through accordance with IWA-5213(a), 2001 Edition Addenda. ASME also recommends that the NRC 2002 Addenda, the licensee must maintain a 10- through 2002 Addenda, the licensee must consider removing this condition in the minute hold time after test pressure has been maintain a 10-minute hold time after test subsequent §50.55a rule to incorporate by reached for Class 2 and Class 3 components pressure has been reached for Class 2 and reference the 2021 Edition of Section XI if the that are not in use during normal operating Class 3 components that are not in use during 2001 Edition through the 2002 Addenda is no conditions. No hold time is required for the normal operating conditions. No hold time is longer incorporated by reference in §50.55a(a).

remaining Class 2 and Class 3 components required for the remaining Class 2 and Class 3 provided that the system has been in operation components provided that the system has been for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated 10 minutes for uninsulated components. components or 10 minutes for uninsulated components.

§50.55a(b)(2)(xx)(B) (B) System leakage tests: Second provision. N/A ASME continues to believe that this condition The NDE provision in IWA-4540(a)(2) of the is unnecessary for reasons documented in our 2002 Addenda of Section XI must be applied letter dated November 30, 2015 to Secretary, when performing system leakage tests after U.S. Nuclear Regulatory Commission, repair and replacement activities performed by Washington, DC 20555-0001,

Subject:

welding or brazing on a pressure retaining Comments on Incorporation by Reference of boundary using the 2003 Addenda through the American Society of Mechanical Engineers latest edition and addenda incorporated by Codes and Code Cases, 10 CFR Part 50, RIN reference in paragraph (a)(1)(ii) of this section. 3150-AI97.

§50.55a(b)(2)(xx)(C) (C) System leakage tests: Third provision. (C) System leakage tests: Third provision. The ASME continues to support the Section XI Code The use of the provisions for an alternative BWR use of the provisions for an alternative BWR requirements and original technical white paper pressure test at reduced pressure to satisfy pressure test at reduced pressure to satisfy IWA - developed to support the current IWA -

IWA-4540 requirements as described in IWA-4540 requirements as described in IWB -5210(c) 5213(b)(2). To date, ASME has not received any 5213(b)(2), IWB-5210(c) and IWB-5221(d) of of Section XI, 2017 Edition and IWA -5213(b)(2) technical analysis or evaluation supporting the Section XI, 2017 Edition may be used subject to and IWB-5221(d) of Section XI, 2017 Edition increased hold time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for non-insulated the following conditions: through the latest edition incorporated by components.

(1) The use of nuclear heat to conduct the reference in paragraph (a)(1)(ii) of this section BWR Class 1 system leakage test is prohibited may be used subject to the following conditions:

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(i.e., the reactor must be in a non-critical state), (1) The use of nuclear heat to conduct the except during refueling outages in which the BWR Class 1 system leakage test is prohibited ASME Section XI Category B-P pressure test (i.e., the reactor must be in a non-critical state),

has already been performed, or at the end of except during refueling outages in which the mid-cycle maintenance outages fourteen (14) ASME Section XI Category B-P pressure test days or less in duration. has already been performed, or at the end of (2) In lieu of the test condition holding time of mid-cycle maintenance outages fourteen (14)

IWA-5213(b)(2), after pressurization to test days or less in duration.

conditions, and before the visual examinations (2) In lieu of the test condition holding time of commence, the holding time shall be 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for IWA-5213(b)(2), after pressurization to test non-insulated components. conditions, and before the visual examinations commence, the holding time shall be 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for non-insulated components.

§50.55a(b)(2)(xxi)(B) (B) Table IWB-2500- 1 examination. Use of (B) Table IWB-2500-1 examination. Use of ASME has no comments on the proposed the provisions of IWB-2500(f) and (g) and Table the provisions of IWB-2500(f) and (g) and Table change.

IWB-2500- 1 Notes 6 and 7 of the 2017 Edition IWB-2500- 1 Notes 6 and 7 of Section XI, 2017 of ASME Section XI for examination of Edition through the latest edition incorporated by Examination Category B-D Item Numbers B3.90 reference in paragraph (a)(1)(ii) of this section, and B3.100 shall be subject to the following for examination of Examination Category B -D conditions: Item Numbers B3.90 and B3.100 shall be subject (1) A plant-specific evaluation demonstrating to the following conditions:

the criteria of IWB-2500(f) are met must be (1) A plant-specific evaluation demonstrating maintained in accordance with IWA-1400(l). the criteria of IWB-2500(f) are met must be (2) The use of the provisions of IWB-2500(f) maintained in accordance with IWA -1400(l).

and Table IWB-2500- 1 Note 6 for examination (2) The use of the provisions of IWB -2500(f) of Examination Category B-D Item Numbers and Table IWB-2500-1 Note 6 for exam ination B3.90 is prohibited for plants with renewed of Examination Category B -D Item Numbers licenses in accordance with 10 CFR part 54. B3.90 is prohibited for plants with renewed (3) The provisions of IWB-2500(g) and licenses in accordance with 10 CFR part 54.

Table IWB-2500- 1 Notes 6 and 7 for (3) The provisions of IWB -2500(g) and Table examination of Examination Category B-D Item IWB-2500- 1 Notes 6 and 7 for examination of Numbers B3.90 and B3.100 shall not be used to Examination Category B -D Item Numbers B3.90 eliminate the preservice or inservice volumetric and B3.100 shall not be used to eliminate the examination of plants with a Combined preservice or inservice volumetric examination of Operating License pursuant to 10 CFR part 52, plants with a Combined Operating License or a plant that receives its operating license after pursuant to 10 CFR part 52, or a plant that October 22, 2015.

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receives its operating license after October 22, 2015.

§50.55a(b)(2)(xxv) (xxv)Section XI condition: Mitigation of (xxv)Section XV Condition: Mitigation of ASME provides the following comments on the defects by modification. Use of the provisions of defects by modification. Use of the provisions of proposed changes to §50.55a(b)(2)(xxv):

IWA-4340 shall be subject to the following IWA-4340 must be subject to the following 1. ASME notes that there are two conditions: conditions: typographical errors in the proposed revision (A) Mitigation of defects by modification: First (A) Mitigation of defects by modification: First to this condition. In §50.55a(b)(2)(xxv),

provision. The use of the provisions for person. The use of the provisions for mitigation of Section XV Condition should be changed mitigation of defects by modification in IWA-defects by modification in IWA -4340 of Section to Section XI Condition, and in 4340 of Section XI 2001 Edition through the XI 2001 Edition through the 2010 Addenda, is 50.55a(b)(2)(xxv)(A), First person should 2010 Addenda, is prohibited. prohibited. be changed to First provision.

(B) Mitigation of defects by modification: (B) Mitigation of defects by modification: 2. ASME supports the proposed change to Second provision. The provisions for mitigation Second provision. The provisions for mitigation of §50.55a(b)(2)(xxv)(B)(2) to clarify that of defects by modification in IWA-4340 of defects by modification in IWA -4340 of Section corrosion rates may be determined at Section XI 2011 Edition through the 2017 Edition XI, 2011 Edition through the latest edition alternative locations.

may be used subject to the following conditions: incorporated by reference in paragraph (a)(1)(ii) 3. ASME recommends that the re-examination (1) The use of the provisions in IWA of this section, may be used subject to the required by §50.55a(b)(2)(xxv)(B)(3) be 4340 to mitigate crack-like defects or those following conditions: changed from once per interval to once associated with flow accelerated corrosion are (1) The use of the provisions in IWA 4340 every ten years to clarify that the re-prohibited. to mitigate crack-like defects or those associated examination need not be performed in the (2) The design of a modification that with flow accelerated corrosion are prohibited. current inspection interval if less than 10 mitigates a defect shall incorporate a loss of (2) The design of a modification that years remain in that inspection interval.

material rate either 2 times the actual measured mitigates a defect must incorporate a loss of 4. ASME suggests that corrosion rate in that pipe location (established material rate either 2 times the actual measured §50.55a(b)(2)(xxv)(B)(3)(ii) might be clearer based on wall thickness measurements corrosion rate, which must be established based if revised to read as follows:

conducted at least twice in two prior consecutive on wall thickness measurements conducted at (ii) For buried pipe locations where loss of or nonconsecutive refueling outage cycles in the least twice, in that pipe location or another material has occurred due to external 10 year period prior to installation of the location with similar corrosion conditions, similar corrosion, the modification must be modification), or 4 times the estimated maximum flow characteristics, and the same piping examined at half its expected life or 10 corrosion rate for the piping system. configuration (e.g., straight run of pipe, elbow, years, whichever is sooner. Alternatively, (3) The licensee shall perform a wall tee) as the encapsulated area, or 4 times the when the modification has been recoated thickness examination in the vicinity of the estimated maximum corrosion rate for the piping prior to return to service, the modification modification and relevant pipe base metal. system. may be examined at half its expected life or Except as provided in paragraphs (3) The licensee must perform a wall during the subsequent 10- year inspection (b)(2)(xxv)(B)(3)(i) and (ii), the examination must thickness examination in the vicinity of the interval after installation, whichever is be performed during each refueling outage cycle modification and relevant pipe base metal at half sooner.

to detect propagation of the defect into the its expected life or, if the modification has an

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material credited for structural integrity of the expected life greater than 19 years, once per item unless the examinations in the two refueling interval, and the results must be used to confirm outage cycles subsequent to the installation of corrosion rates, determine the next inspection the modification are capable of validating the date, and confirm the design inputs.

projected flaw growth. Where the projected flaw (i) For buried pipe locations where the growth has been validated, the modification loss of material has occurred due to internal must be examined at half its expected life or corrosion, the wall thickness examinations may once per interval, whichever is smaller. be conducted at a different location in the same (i) For buried pipe locations where the system as long as: Wall thickness measurements loss of material has occurred due to internal were conducted at the different location at the corrosion, the refueling outage interval wall same time as installation of the modification; the thickness examinations may be conducted at a flow rate is the same or higher at the different different location in the same system as long as: location; the piping configuration is the same Wall thickness measurements were conducted (e.g., straight run of pipe, elbow, tee); and if at the different location at the same time as pitting occurred at the modification location, but installation of the modification; the flow rate is not the different location, wall loss values must the same or higher at the different location; the be multiplied by four (instead of two) times the piping configuration is the same (e.g., straight actual measured corrosion rate. Where wall loss run of pipe, elbow, tee), and if pitting occurred at values are greater than that assumed during the the modification location, but not the different design of the modification, the structural integrity location, wall loss values must be multiplied by of the modification must be reanalyzed.

four. Where wall loss values are greater than Additionally, if the extent of degradation is that assumed during the design of the different (i.e., percent wall loss plus or minus 25 modification, the structural integrity of the percent) or the corrosion mechanism (e.g.,

modification shall be reanalyzed. Additionally, if general, pitting) is not the same at the different the extent of degradation is different (i.e., location as at the modification location, the through wall, percent wall loss plus or minus 25 modification must be examined at half its percent) or the corrosion mechanism (e.g., expected life or 10 years, whichever is sooner.

general, pitting) is not the same at the different (ii) For buried pipe locations where loss location as at the modification location, the of material has occurred due to external modification must be examined at half its corrosion, the modification must be examined at expected life or 10 years, whichever is smaller. half its expected life or 10 years, whichever is (ii) For buried pipe locations where sooner. Alternatively, when the modification has loss of material has occurred due to external been recoated prior to return to service, the corrosion, the modification must be examined at modification may be examined at half its half its expected life or 10 years, whichever is expected life or during the first full 10- year smaller. inspection interval after installation, whichever is sooner.

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§50.55a(b)(2)(xxvi) (xxvi)Section XI condition: Pressure testing (xxvi)Section XI condition: Pressure Testing of ASME supports the NRCs proposal to eliminate Class 1, 2, and 3 mechanical joints. When using Class 1, 2, and 3 Mechanical Joints. Mechanical the requirement to perform a pressure test and the 2001 Edition through the latest edition and joints in Class 1, 2, and 3 piping and components VT-2 examination in accordance with IWA-addenda incorporated by reference in paragraph greater than NPS-1 which are disassembled and 5211(a) of mechanical connections in Class 1, 2, (a)(1)(ii) of this section, licensees shall pressure reassembled during the performance of a Section and 3 piping and components greater than NPS -

test in accordance with IWA-5211(a) XI repair/ replacement activity requiring 1 which are disassembled and reassembled mechanical joints in Class 1, 2, and 3 piping and documentation on a Form NIS-2 shall be leak during the performance of a Section XI components greater than NPS-1 which are tested to ensure leak tightness. The owner shall repair/replacement activity requiring disassembled and reassembled during the establish the type of leak test, test medium, test documentation on a Form NIS -2. However, performance of a Section XI repair/replacement pressure, acceptance criter ia that would ASME continues to believe that this condition, activity requiring documentation on a Form NIS-demonstrate the joints leak tightness, and the including the proposed change, is unnecessary,

2. The system pressure test and NDE examiners qualifications of the personnel who will perform based on comments submitted during the shall meet the requirements of the the leak test. previous rulemaking to incorporate by reference licensee's/applicant's current ISI code of record. the 2017 Edition of the ASME Code,Section XI, and for reasons listed below :

1. ASME considers the disassembly and reassembly of a mechanical joint to be a maintenance activity that is not subject to Section XI repair/replacement requirements, unless the reassembly involves the installation of replacement pressure retaining parts or components in the mechanical joint, or the activity involves welding or brazing on parts or components in the mechanical joint. ASME also considers the disassembly of a mechanical joint solely to facilitate the performance of a repair/replacement activity that does not affect the mechanical joint to be a maintenance activity.

As proposed, Owners could interpret this condition to apply, even if the repair/replacement activity is not being performed on items within the mechanical joint, or if the repair/replacement activity is exempt from pressure testing in accordance with IWA-4540(b). In these cases, ASME believes that there is no technical reason to require Section XI pressure testing and VT -2 examination. Post-maintenance press ure testing performed in accordance with an Owners procedures should be sufficient to verify that the reassembled mechanical joint is leak-tight.

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2. In order to comply with the proposed condition, an Owner would be required to document the type of leak test, test medium, test pressure, acceptance criteria, and personnel qualifications for leakage tests that would demonstrate the joints leak tightness following a repair replacement activity requiring documentation on an NIS -2 form. Currently, this level of detail may not exist in the Owners procedures for post-maintenance leakage testing, and the addition of these requirements creates an unnecessary burden for the utilities with no corresponding increase in quality or safety. To comply with the proposed condition, an Owner may have to revise their post -

maintenance test procedures to include these additional requirements.

3. Owners quality assurance programs already require verification of leak tightness following maintenance activities, and ASME believes that the leak-tight integrity of mechanical connections can be assured without the proposed condition.

ASME strongly recommends that this condition be removed from the final rule.

If the NRC does not accept ASMEs recommendation to remove this condition in the final rule, ASME recommends that the NRC consider revising this condition to address the following:

1. In lieu of specifying that The owner shall establish the type of leak test, test medium, test pressure, acceptance criteria that would demonstrate the joints leak tightness, and the qualifications of the personnel who will perform the leak test, ASME recommends that this sentence be deleted, and instead specify that Leak-testing mechanical joints shall be performed in accordance with IWA-5211(a) in the

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2001 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, or in accordance with requirements of the Owners Quality Assurance Program. This would allow Owners to avoid having to revise their current procedures to implement the revised condition.

2. This condition should not apply to mechanical joints that are disassembled and reassembled during the performance of a repair/replacement activity requiring documentation on an NIS -2 Form if the pressure retaining parts or components in the mechanical joint are not affected by the repair/replacement activity.

ASME notes that a pressure test in accordance with IWA-4540 would be required if a repair/replacement activity performed by welding or brazing on pressure retaining parts or components in the mechanical joint is not exempt by IWA-4540(b).

§50.55a(b)(2)(xxix) (xxix)Section XI condition: Nonmandatory (xxix)Section XI condition: Nonmandatory ASME supports the endorsement of Appendix R. Nonmandatory Appendix R, "Risk-Appendix R. (A) Nonmandatory Appendix R, Nonmandatory Appendix R, Supplement 2 in the Informed Inspection Requirements for Piping," of Risk-Informed Inspection Requirements for 2017 Edition and appreciates the NRC proposing Section XI, 2005 Addenda through the latest Piping Supplement 1Risk -Informed Selection this change to allow use of Appendix R, edition and addenda incorporated by reference Process Method A, of Section XI, 2005 Supplement 2 without requiring prior NRC in paragraph (a)(1)(ii) of this section, may not be Addenda through the latest edition and addenda authorization in accordance with §50.55a(z).

implemented without prior NRC authorization of incorporated by reference in paragraph (a)(1)(ii) the proposed alternative in accordance with of this section, may not be implemented without paragraph (z) of this section. prior NRC authorization of the proposed alternative in accordance with paragraph (z) of this section.

(B) Nonmandatory Appendix R, Risk -

Informed Inspection Requirements for Piping, Supplement 2Risk -Inform ed Selection Process Method B of Section XI, 2005 Addenda through the 2015 Edition, may not be implemented without prior NRC authorization of the proposed alternative in accordance with paragraph (z) of this section.

Page 20 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

(C) Nonmandatory Appendix R, Risk -

Informed Inspection Requirements for Piping, Supplement 2Risk -Informed Selection Process Method B of Section XI, 2017 Edition through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, may be implemented without prior NRC authorization of the proposed alternative in accordance with paragraph (z) of this section.

§50.55a(b)(2)(xxxii) (xxxii)Section XI condition: Summary report (xxxii)Section XI condition: Summary report ASME supports the proposed change to these submittal. When using ASME BPV Code, submittal. When using ASME BPV Code, Section administrative requirements, but recommendsSection XI, 2010 Edition through the latest XI, 2010 Edition through the latest edition and that the condition not be limited to the 2010 edition and addenda incorporated by reference addenda incorporated by reference in paragraph Edition and later editions and addenda. Some in paragraph (a)(1)(ii) of this section, Summary (a)(1)(ii) of this section, Summary Reports and U.S. plants may still be using the 2007 Edition Reports and Owner's Activity Reports described Owners Activity Reports described in IWA -6230 with the 2008 Addenda, and ASME would like to in IWA-6230 must be submitted to the NRC. must be submitted to the NRC. Preservice see the use of the extended timeframe for Preservice inspection reports for examinations inspection reports for examinations prior to submitting the Owners Activity Reports prior to commercial service shall be submitted commercial service must be submitted prior to permitted for those plants, as well as those using prior to the date of placement of the unit into the date of placement of the unit into commercial the 2010 Edition and later editions and addenda.

commercial service. For preservice and service. For preservice and inservice inservice examinations performed following examinations performed following placement of placement of the unit into commercial service, the unit into commercial service, reports must be reports shall be submitted within 90 calendar submitted within 120 calendar days of the days of the completion of each refueling outage. completion of each refueling outage.

§50.55a(b)(2)(xxxvi) (xxxvi)Section XI condition: Fracture (xxxvi)Section XI condition: Fracture ASME has no comments on the proposed toughness of irradiated materials. When using toughness of irradiated materials. When using change.

the 2013 through 2017 Editions of the ASME the 2013 Edition through the latest edition BPV Code,Section XI, Appendix A paragraph incorporated by reference in paragraph (a)(1)(ii)

A-4400, the licensee shall obtain NRC approval of this section of the ASME BPV Code, Section under paragraph (z) of this section before using XI, Appendix A paragraph A -4400, the licensee irradiated T0 and the associated RTT0 in shall obtain NRC approval under paragraph (z) of establishing fracture toughness of irradiated this section before using irradiated T 0 and the materials. associated RTT0 in establishing fracture toughness of irradiated materials.

§50.55a(b)(2)(xxxix) (xxxix)Section XI condition: Defect Removal. (xxxix)Section XI condition: Defect Removal. ASME has no comments on the proposed The use of the provisions for removal of defects The use of the provisions for removal of defects change.

by welding or brazing in IWA-4421(c)(1) and by welding or brazing in IWA -4421(c)(1) and IWA-4421(c)(2) of Section XI, 2017 Edition

Page 21 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

IWA-4421(c)(2) of Section XI, 2017 Edition may through the latest edition incorporated by be used subject to the following conditions: reference in paragraph (a)(1)(i i) of this section (A) Defect removal requirements: First may be used subject to the following conditions:

provision. The provisions of subparagraph IWA- (A) Defect removal requirements: First 4421(c)(1) shall not be used to contain or isolate provision. The provisions of subparagraph IWA a defective area without removal of the defect. 4421(c)(1) shall not be used to contain or isolate (B) Defect removal requirements: Second a defective area without removal of the defect.

provision. The provisions of subparagraph IWA- (B) Defect removal requirements: Second 4421(c)(2) shall not be used for crack-like provision. The provisions of subparagraph IWA -

defects. 4421(c)(2) shall not be used for crack -like defects.

§50.55a(b)(2)(xl) (xl)Section XI condition: Prohibitions on use (xl)Section XI condition: Prohibitions and ASME provides the following comments on the of IWB-3510.4(b). The use of ASME BPV Code, Restrictions on use of IWB - 3510.4(b), IWC-proposed condition:

Section XI, 2017 Edition, Subparagraphs IWB-3510.5(b), Table A - 4200-1, and Table G-2110- 1. ASME does not support the restriction on 3510.4(b)(4) and IWB-3510.4(b)(5) is prohibited. 1. The use of Subparagraphs IWB -3510.4(b)(4) the use of IWB-3510.4(b)(5) and IWC -

and IWB-3510.4(b)(5) of ASME BPV Code, 3510.5(b)(5) for SA -508 Class 1 material,Section XI, 2017 Edition through the latest edition and recommends that this condition be incorporated by reference in paragraph (a)(1)(ii) revised in the final rule so that it does not of this section is prohibited. The use of ASME apply to SA-508 Class 1 material.

BPV Code,Section XI, 2019 Edition, Subparagraphs IWC -3510.5(b)(4) and IWC-2. The proposed condition (restriction or 3510.5(b)(5), is prohibited. For ASME BPV Code, prohibition) on SA-533 Type B Class 2 isSection XI, 2019 Edition, Table A-4200- 1 and unnecessary and ASME recommends that Table G-2110- 1, use of Figure A -4200- 1 and this condition be removed in the final rule.

Figure G-2210- 1 to describe the toughness of Information supporting the above comments and material SA-533 Type B Class 2 is prohibited recommendations is provided in Enclosure 2.

without satisfying the requirements of IWB -

3510.4(c) or IWC-3510.5(c).

§50.55a(b)(2)(xliii) N/A (xliii)Section XI condition: Section XI ASME has no comments on the proposed Condition: Regulatory Submittal Requirements. conditions.

Licensees shall submit for NRC review and approval the following analyses: (A) The analytical evaluation determining the effects of an out-of -limit condition on the structural integrity of the Reactor Coolant System, as described in IWB-3720(a);

Page 22 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

(B) Determination of T 0 and RTT0, as described in Nonmandatory Appendix A, A -

4200(c); and (C) Determination of T 0 and RTT0, as described in Nonmandatory Appendix G, G -

2110(c).

§50.55a(b)(3)(iii) (iii) OM condition: New reactors. In addition (iii) OM condition: New reactors. In addition to ASME has no comments on the proposed to complying with the provisions in the ASME complying with the provisions in the ASME OM changes to these conditio ns.

OM Code with the conditions specified in Code with the conditions specified in paragraph paragraph (b)(3) of this section, holders of (b)(3) of this section, holders of operating operating licenses for nuclear power reactors licenses for nuclear power reactors that received that received construction permits under this part construction permits under this part on or after on or after the date 12 months after August 17, August 17, 2018, and holders of combined 2017, and holders of combined licenses issued licenses issued under 10 CFR part 52, whose under 10 CFR part 52, whose initial fuel loading initial fuel loading occurs on or after August 17, occurs on or after the date 12 months after 2018, must also comply with the following August 17, 2017, shall also comply with the conditions, as applicable:

following conditions, as applicable: (A) Power-operated valves. Licensees must (A) Power-operated valves. Licensees shall periodically verify the capability of power -

periodically verify the capability of power-operated valves to perform their design -basis operated valves to perform their design-basis safety functions.

safety functions. (B) Check valves. Licensees must perform bi-(B) Check valves. Licensees must perform bi-directional testing of check valves within the IST directional testing of check valves within the IST program where practicable.

program where practicable. (C) Flow-induced vibration. Licensees must (C) Flow-induced vibration. Licensees shall monitor flow-induced vibration from monitor flow-induced vibration from hydrodynamic loads and acoustic resonance hydrodynamic loads and acoustic resonance during preservice testing or inservice testing to during preservice testing or inservice testing to identify potential adverse flow effects on identify potential adverse flow effects on components within the scope of the IST program.

components within the scope of the IST (D) High risk non-safety systems. Licensees program. must assess the operational readiness of pumps, (D) High risk non-safety systems. Licensees valves, and dynamic restraints within the scope shall assess the operational readiness of pumps, of the Regulatory Treatment of Non-Safety valves, and dynamic restraints within the scope Systems for applicable reactor designs.

of the Regulatory Treatment of Non-Safety Systems for applicable reactor designs.

Page 23 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

§50.55a(b)(3)(viii) (viii) OM condition: Subsection ISTE. (viii) OM condition: Subsection ISTE. ASME has no comments on the proposed Licensees may not implement the risk-informed Licensees may not implement the risk -informed change to this condition.

approach for inservicetesting (IST) of pumps approach for inservice testing (IST) of pumps and and valves specified in Subsection ISTE, "Risk-valves specified in Subsection ISTE, Risk -

Informed Inservice Testing of Components in Informed Inservice Testing of Components in Light-Water Reactor Nuclear Power Plants," in Light-Water Reactor Nuclear Power Plants, i n the ASME OM Code, 2009 Edition through the the ASME OM Code, 2009 Edition through the latest edition and addenda of the ASME OM 2017 Edition, without first obtaining NRC Code incorporated by reference in paragraph authorization to use Subsection ISTE as an (a)(1)(iv) of this section, without first obtaining alternative to the applicable IST requirements in NRC authorization to use Subsection ISTE as an the ASME OM Code, pursuant to paragraph (z) alternative to the applicable IST requirements in of this section.

the ASME OM Code, pursuant to paragraph (z) of this section.

§50.55a(b)(3)(ix) (ix) OM condition: Subsection ISTF. (ix) OM condition: Subsection ISTF. Licensees ASME has no comments on the proposed Licensees applying Subsection ISTF, 2012 applying Subsection ISTF, 2012 Edition must change to this condition.

Edition or 2015 Edition, shall satisfy the satisfy the requirements of Mandatory Appendix requirements of Mandatory Appendix V, "Pump V, Pump Periodic Verification Test Program, of Periodic Verification Test Program," of the the ASME OM Code in that edition.

ASME OM Code in that edition. Subsection ISTF, 2011 Addenda, is prohibited for use.

§50.55a(b)(3)(xi) (xi) OM condition: Valve Position Indication. (xi) OM condition: Valve Position Indication. ASME supports the relaxation of this condition When implementing paragraph ISTC-3700, When implementing paragraph ISTC -3700, for valves that are not susceptible to stem -disk "Position Verification Testing," in the ASME OM Position Verification Testing, in the ASME OM separation.

Code, 2012 Edition through the latest edition Code, 2012 Edition through the latest edition of and addenda of the ASME OM Code the ASME OM Code incorporated by reference in incorporated by reference in paragraph (a)(1)(iv) paragraph (a)(1)(iv) of this section, licensees of this section, licensees shall verify that valve must verify that valve operation is accurately operation is accurately indicated by indicated by supplementing valve position supplementing valve position indicating lights indicating lights with other indications, such as with other indications, such as flow meters or flow meters or other suitable instrumentation to other suitable instrumentation to provide provide assurance of proper obturator position for assurance of proper obturator position for valves valves with remote position indication within the with remote position indication within the scope scope of Subsection ISTC including its of Subsection ISTC including its mandatory mandatory appendices and their verification appendices and their verification methods and methods and frequencies. For valves not frequencies. susceptible to stem-disk separation, the position verification testing specified in paragraph ISTC -

3700 may be performed on a 10-year interval

Page 24 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

where the licensee documents a justification, which is made available for NRC review, demonstrating that the stem -disk connection is not susceptible to separation based on the internal design and evaluation of the stem -disk connection using plant-specific and industry operating experience and vendor recommendations.

§50.55a(f)(4) (4) Inservice testing standards requirement (4) Inservice testing standards requirement for ASME believes that the §50.55a(f) requirements for operating plants. Throughout the service life operating plants. Throughout the service life of a for snubbers has been confusing to Owners, so of a boiling or pressurized water-cooled nuclear boiling or pressurized water -cooled nuclear the proposed c hange may help clarify these power facility, pumps and valves that are within power facility, pumps and valves that are within requirements. ASME questions whether the the scope of the ASME OM Code must meet the the scope of the ASME OM Code must meet the conditions specified in §50.55a(b)(3)(v) are still inservice test requirements (except design and inservice test requirements (except design and needed as a result of the proposed changes to access provisions) set forth in the ASME OM access provisions) set forth in the AS ME OM §50.55a(f)(4) and §50.55a(g)(4).

Code and addenda that become effective Code and addenda that become effective ASME also suggests that the reference to subsequent to editions and addenda specified in subsequent to editions and addenda specified in (b)(3)(v) in the last sentence of this condition be paragraphs (f)(2) and (3) of this section and that paragraphs (f)(2) and (3) of this section and that changed to (b)(3)(v)(A) for clarity.

are incorporated by reference in paragraph are incorporated by reference in paragraph (a)(1)(iv) of this section, to the extent practical (a)(1)(iv) of this section, to the extent practical within the limitations of design, geometry, and within the limita tions of design, geometry, and materials of construction of the components. The materials of construction of the components. The inservice test requirements for pumps and inservice test requirements for pumps and valves valves that are within the scope of the ASME that are within the scope of the ASME OM Code OM Code but are not classified as ASME BPV but are not classified as ASME BPV Code Class Code Class 1, Class 2, or Class 3 may be 1, Class 2, or Class 3 may be satis fied as an satisfied as an augmented IST program in augmented IST program in accordance with accordance with paragraph (f)(6)(ii) of this paragraph (f)(6)(ii) of this section. This use of an section without requesting relief under augmented IST program may be acceptable paragraph (f)(5) of this section or alternatives provided the basis for deviations from the ASME under paragraph (z) of this section. This use of OM Code, as incorporated by reference in this an augmented IST program may be acceptable section, demonstrates an acceptable level of provided the basis for deviations from the ASME quality and safety, or that implementing the Code OM Code, as incorporated by reference in this provisions would result in hardship or unusual section, demonstrates an acceptable level of difficulty without a compensating increase in the quality and safety, or that implementing the level of quality and safety, where documented Code provisions would result in hardship or and available for NRC review. When using the unusual difficulty without a compensating 2006 Addenda or later of the ASME BPV Code, increase in the level of quality and safety, where Section XI, the inservice examination, testing, documented and available for NRC review. and service life monitoring requirements for

Page 25 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

§50.55a Paragraph Existing §50.55a Regulations Proposed Changes to §50.55a Regulations ASME Comments on §50.55a Regulations 

(as of 03/26/2021) ([LVWLQJ DQG 3URSRVHG &KDQJHV

dynamic restraints (snubbers) must meet the requirements set forth in the applicable ASME OM Code as specified in paragraph (b)(3)(v)(B) of this section. When using the 2005 Addenda or earlier edition or addenda of the ASME BPV Code,Section XI, the inservice examination, testing, and service life monitoring requirements for dynamic restraints (snubbers) must mee t the requirements set forth in either the applicable ASME OM Code or ASME BPV Code,Section XI as specified in paragraph (b)(3)(v) of this section.

§50.55a(f)(7) N/A (7) Inservice testing reporting requirements. ASME has no comment on the proposed Inservice Testing Program Test and Examination administrative condition.

Plans (IST Plans) for pumps, valves, and dynamic restraints (snubbers) prepared to meet the requirements of the ASME OM Code must be submitted to the NRC as specified in § 50.4. IST Plans must be submitted within 90 days of their implementation for the applicable 120- month IST Program interval. IST Plan revisions must be submitted when the final safety analysis report for the applicable nuclear power plant is updated.

Electronic submission is preferred.

§50.55a(g)(4) (4) Inservice inspection standards (4) Inservice inspection standards requirement ASME believes that the §50.55a( g) requirements requirement for operating plants. Throughout the for operating plants. Throughout the service life for snubbers has been confusing to Owners, so service life of a boiling or pressurized water-of a boiling or pressurized water -cooled nuclear the proposed change may help clarify these cooled nuclear power facility, components power facility, components (including supports) requirements.

(including supports) that are classified as ASME that are classified as ASME Code Class 1, Class Code Class 1, Class 2, and Class 3 must meet 2, and Class 3 must meet the requirements, the requirements, except design and access except design and access provisions and provisions and preservice examination preservice examination requirements, set forth in requirements, set forth in Section XI of editionsSection XI of editions and addenda of the ASME and addenda of the ASME BPV Code (or ASME BPV Code that become effective subsequent to OM Code for snubber examination and testing) editions specified in paragraphs (g)(2) and (3) of that become effective subsequent to editions this section and that are incorporated by specified in paragraphs (g)(2) and (3) of this reference in paragraph (a)(1)(ii) or (iv) of this section and that are incorporated by reference in section for snubber examination and testing of paragraph (a)(1)(ii) or (iv) for snubber this section, to the extent practical within the examination and testing of this section, to the limitations of design, geometry, and materials of extent practical within the limitations of design, construction of the components. Components

Page 26 of 27 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087-16114, Friday, March 26, 2021, RIN 3150-AK22, Docket ID NRC-2018-0290

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geometry, and materials of construction of the that are classified as Class MC pressure components. Components that are classified as retaining components and their integral Class MC pressure retaining components and attachments, and components that are classified their integral attachments, and components that as Class CC pressure retaining components and are classified as Class CC pressure retaining their integral attachments, must meet the components and their integral attachments, must requirements, except design and access meet the requirements, except design and provisions and preservice examination access provisions and preservice examination requirements, set forth in Section XI of the ASME requirements, set forth in Section XI of the BPV Code and addenda that are incorporated by ASME BPV Code and addenda that are reference in paragraph (a)(1)(ii) of this section incorporated by reference in paragraph (a)(1)(ii) subject to the condition listed in paragraph of this section and the conditions listed in (b)(2)(vi) of this section and the conditions listed paragraphs (b)(2)(viii) and (ix) of this section, to in paragraphs (b)(2)(viii) and (ix) of this section, the extent practical within the limitation of to the extent practical within the limitation of design, geometry, and materials of construction design, geometry, and materials of construction of the components. of the components. When using the 2006 Addenda or later of the ASME BPV Code,Section XI, the inservice examination, testing, and service life monitoring requirements for dynamic restraints (snubbers) must meet the requirements set forth in the applicable ASME OM Code as specified in paragraph (b)(3)(v)(B) of this section. When using the 2005 Addenda or earlier edition or addenda of the ASME BPV Code,Section XI, the inservice exam ination, testing, and service life monitoring requirements for dynamic restraints (snubbers) must meet the requirements set forth in either the applicable ASME OM Code or ASME BPV Code,Section XI as specified in paragraph (b)(3)(v) of this section.

Page 27 of 27 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

ASME Section XI Working Group on Operating Plant Criteria Comments to proposed Section XI condition: Prohibitions and Restrictions on use of IWB -3510.4(b), IWC-3510.5(b), Table A-4200- 1, and Table G-2110- 1

Proposed Condition §50.55a(b)(2)(xl):

Per the 2019-2020 Code Editions Proposed Rule, (see Federal Register/Vol. 86, No.57/Friday, March 26, 2021, https://www.federalregister.gov/documents/2021/03/26/2021- 06085/american-society-of-mechanical-engineers-2019-2020- code-editions), the above condition is placed on ASME Section XI IWB-3510.4(b), IWC-3510.5(b), Table A-4200- 1, and Table G-2110-1 in the 2017 to latest Edition of ASME Code,Section XI.

Two grades of ferritic steels are affected by the above condition:

• SA-508 Class 1, which is listed in IWB-3510.4(b)(5) of 2017 and 2019 editions, and in IWC-3510.5(b)(5) of 2019 edition.

• SA-533 Type B Class 2 (former designation SA-533 Grade B Class 2), which is listed in IWB-3510.4(b)(4) of 2017 and 2019 editions, in IWC-3510.5(b)(4) of 2019 edition, and in Table A-4200- 1 and Table G-2110- 1 of 2019 edition.

Comment on proposed condition on SA -508 Class 1 SA-508 Class 1 designation was changed to SA-508 Grade 1 during the 1990s. SA-508 Class 1 has a specified minimum yield strength (YS) at room temperature of 36 ksi as provided in ASME Section II Part A and Part D. Because its specified minimum YS does not exceed 50 ksi, SA-508 Class 1 is among the permitted materials by IWB-3510.4(a) and IWC-3510.5(a). Furthermore, SA-508 Class 1 has always been permitted by Section XI Appendix G-2110(a) to use the minimum curve in Figure G-2210- 1 since Section XI Appendix G was first adopted in 1987. Note, SA-508 Class 1 is listed as SA-508-1 in G-2110(a), and the minimum curve of Figure G-2210- 1 was changed from KIa to KIc in 1999.

As a background, IWB-3510.4(b)(5) and IWC-3510.5(b)(5) were provided in those paragraphs for information purposes only, and for ease of use to the Code users. The long-term goal of the IWB-3510.4 and IWC-3510.5 paragraphs were to identify commonly used ferritic materials in the nuclear industry when applying the Acceptance Standards in IWB-3500. It should be noted, neither ASME Section XI nor

Page 1 of 6 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

10CFR50 Appendix G requires fracture-mechanics test data of ferritic steels with specified minimum YS not higher than 50 ksi (including SA-508 Class 1).

In light of the above, the proposed condition (restriction or prohibition) on IWB-3510.4(b)(5) and IWC-3510.5(b)(5) should be removed for SA-508 Class 1.

Comment on proposed condition SA-533 Type B Class 2 Prior to the 2019 edition,Section XI G-2110(b) requires fracture-mechanics test data for materials with specified minimum YS between 50 and 90 ksi before the lower-bound minimum KIc curve in Figure G-2210- 1 can be used. The minimum KIc curve is identical in Figure A-4200- 1 and Figure G-2210- 1.

SA-533 Type B Class 2 has a specified minimum YS of 70 ksi; therefore, fracture-mechanics test data were required by Section XI Appendix G-2110(b) prior to the 2019 edition. The fracture-mechanics test data requirement of G-2110(b) is also imposed by 10CFR50 Appendix G. The 2019 edition of Section XI Appendix G -2110(b) and Code Case N-890 exempted the following four grades of ferritic steels with specified minimum YS of 65 or 70 ksi:

• SA-508 Grade 2 Class 2 (former designation SA-508 Class 2A)

• SA-508 Grade 3 Class 2 (former designation SA-508 Class 3A)

• SA-5 33 Type A Class 2 (former designation SA-533 Grade A Class 2)

• SA-533 Type B Class 2 (former designation SA-533 Grade B Class 2)

Per the Proposed Rule for Approval of ASME Code Cases, 86 FR 7820, NRC-2017- 0025, (https://www.federalregister.gov/documents/2021/02/02/2021- 00890/approval-of-american-society-of-mechanical-engineers-code-cases), the Staff stated that the condition on SA-533 Type B Class 2 material in Code Case N-890 was because:

SA-533 Type B, Class 2 materials, the NRC observed that in the technical basis document, there is no fracture toughness data associated with the weld and heat affected zone to support exclusion of the fracture toughness testing requirements for these materials The technical basis including supporting fracture-mechanics test data was presented in PVP2019-93988 Technical Basis for Expansion of ASME BPVC Section XI, KIc Curve Applicability. Of the four grades of ferritic steels, only SA-533 Type B Class 2 will be restricted or prohibited by the proposed rules, due to a lack of fracture-mechanics test data for weld and HAZ.

The following fracture-mechanics test data for SA-533 Type B Class 2 were not included in PVP2019-93988 because they were uncovered after the paper was already accepted for publication:

• J.R. Hawthorne and T.R. Mager, Relationship Between Charpy V and Fracture Mechanics KIc, Assessments of A533-B Class 2 Pressure Vessel Steel, Fracture Toughness, Proceedings of the 1971 National Symposium on Fracture Mechanics, Part II, ASTM STP 514, 1972, pp. 151-263

• K. Hayashi, et al., High Performance Steel Plates for Tanks and Pressure Vessels - High Strength Steel Plates with Excellent Weldability and Superior Toughness for Energy Industry, JFE No. 5, 2004 8 p. 56-62 [JEF Technical Report No 5, p. 56-62, August 2004]

Hawthorne, 1972 The testing was performed by Naval Research Laboratory and Westinghouse. The test material was removed from a 6-3/8-thick plate per ASTM A-533 Type B Class 2. ASTM A-533 Type B Class 2 is identical to SA-533 Type B Class 2. Table 1 lists the chemical composition and unirradiated room-temperature tensile property, which met SA-533 Type B Class 2 requirements.

Figure 1 plots the unirradiated KIc data assuming RT-NDT = 0°F. The unirradiated T-NDT was 0°F; RT-NDT was not reported because RT-NDT was first adopted by Section III, NB-2300 in 1973. Judging from the unirradiated Charpy curve, the unirradiated RT-NDT per NB-2300 definition may be higher than T-

Page 2 of 6 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

NDT. If RT-NDT were higher than 0°F, the plotted KIc test data in Figure 1 would shift toward the left, resulting in higher margin against the minimum KIc curve than shown in Figure 1. Therefore, the KIc test data exceeded the minimum KIc curve in Figure G-2210- 1 and Figure A-4200- 1.

Hayashi, 2004 The testing was performed by JEF Steel in Japan. The test material was removed from a 120- mm-thick (4.7-thick) plate of Japanese SQV2B steel, which is equivalent to ASME SA-533 Type B Class 2. Table 2 lists the chemical composition and room-temperature tensile property, which met SA-533 Type B Class 2 requirements.

Figure 2 plots the KIc and KId test data. The RT-NDT was -33°C (-27°F). Figure 2 shows that the KIc test data exceeded the minimum KIc curve in Figure G-2210- 1 and Figure A-4200- 1. The KIc test data were significantly above the KId test data, and even the KId test data met the minimum KIc curve.

Discussion The above test data for SA-533 Type B Class 2 were not included in PVP2019-93988; they provide additional support to the PVP2019-93988 conclusion that the four grades of ferritic steels can be considered as one group for the applicability of the minimum KIc curve in Section XI Appendix A and Appendix G. In light of the additional test data, the proposed condition (restriction or prohibition) on SA-533 Type B Class 2 is unnecessary.

Table 1, ASTM A-533 Type B Class 2 [Hawthorne, 1972]

Composition SA-533 Type B (Class 1 and 2) A533B Class 2, Hawthorne-1972

C 0.25 max 0.24

Mn 1.15 - 1.50 1.27

P 0.025 max 0.008

S 0.025 max 0.015

Si 0.15 - 0.40 0.19

Ni 0.40 - 0.70 0.53

Cr Not specified 0.14

Mo 0.45 - 0.60 0.48

Cu Not specified 0.09

V Not specified 0.02

Al Not specified 0.031 Room Temperature SA-533 Type B Class 2 A533B Class 2, Hawthorne-1972 Tension Yield Strength 70 ksi min 74.2 ksi 75.6 ksi Tensile Strength 90 - 115 ksi 94.2 ksi 94.5 ksi

Page 3 of 6 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

Table 2, SQV2B [Hayashi, 2004]

Composition SA-533 Type B (Class 1 and 2) SQV2B, Hayashi-2004

C 0.25 max 0.17

Mn 1.15 - 1.50 1.44

P 0.025 max 0.005

S 0.025 max 0.001

Si 0.15 - 0.40 0.25

Ni 0.40 - 0.70 0.66

Cr Not specified 0.13

Mo 0.45 - 0.60 0.55 Room Temperature SA-533 Type B Class 2 SQV2B, Hayashi-2004 Tension Yield Strength 70 ksi min 75 to 79 ksi

Tensile Strength 90 - 115 ksi 93 to 98 ksi

200 A533B Class 2 Unirradiated, KIc KIC Curve KIR Curve 150

100

50

0

-350 -300 -250 -200 -150 -100 -50 0 50 100 150 200 250 300 T - RTNDT, °F

Figure 1, KIc vs T-RTNDT for ASTM A-533 Type B Class 2 [Hawthorne, 1972]

Page 4 of 6 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

500

450

400

350

300 ASME KIC ASME KIR 250 SQV2B, KIc at 1/4-T SQV2B, KIc at 1/2-T SQV2B, KId at 1/2-T

200

150

100

50

0

-200 -150 -100 -50 0 50 100 150 200 250

T - RTNDT, °F Figure 2, KIc and KId vs T-RTNDT for SQV2B [Hayashi, 2004]

Page 5 of 6 Enclosure 2 ASME Comments on 10 CFR 50.55a(b)(2)(xl) Condition in the Proposed Rule, Federal Register, Vol. 86, No. 57, pp. 16087 -16114, Friday, March 26, 2021, RIN 3150- AK22, Docket ID NRC-2018- 0290

Code Interpretation on ASME Section III Appendix G-2110 (b) requirements The original technical basis for the ASME IWB-3510.4(b), was based on data presented in PVP2010-25214, Facture Toughness of Pressure Bo0undary Steels with Higher Yield Strength, by Gupta, Hoffman, Hamilton, DeLose, July 2010.

As discussed in PVP2010- 25214, the authors submitted an ASME Section III Inquiry in November 2008 on the amount of testing data required per G-2110(b) for similar materials with minimum specified yield strength greater than 50 ksi. The ASME Section III Committee provided the interpretation (III-1 47, File 08-1636) that the ASME Section III Appendix G-2110(b) requirements (same asSection XI G-2110(b))

apply to a group of like materials rather than to each specific grade of material. Based on this inquiry (as shown below), the fracture toughness testing data for SA-533 and SA-508 Class 2 materials can be used as a combined set to determine that the KIc curve can be used to bound similar types of base materials, including HAZ and weld metals.

Therefore, since the Staff has already approved the use of SA-508 Grade 2, Class 2, SA-508 Grade 3, Class 2, and SA-533 Type A Class 2 in ASME Section XI IWB-3510.4(b), then per the Code Interpretation III 07-47 (shown below), SA-533 Type B Class 2 is also an acceptable material for use as part of IWB-3510.4(b) and IWC-3510.5(b) ), based on the combined set of fracture toughness data for (65 ksi and 70 ksi) materials of SA-533 and SA-508, whichalso include HAZ and weld metals, as provided in PVP2010-25214.

Subject:

Section III, Division 1, Nonmandatory Appendix G, Fracture Toughness Criteria for Protection Against Failure, Para. G-2110(b)

Date Issued: 11/24/2008 Record Number: 08-1636 Interpretation Number: III 07-47 Question: Does a combined set of fracture toughness data for SA-533 plate and SA-508 forging Class 2 materials, with minimum specified yield strengths greater than 50 ksi (350 MPa) but not exceeding 90 ksi (620 MPa), satisfy the requirements of G-2110(b), when three or more heats of base metal test data are available for plates and for forgings and at least three sets of test data are available on HAZ and weld metal for each specification for one or more grades of the plate and forging materials?

Reply: Yes.

Page 6 of 6 Submission ID 006 David P. Helker, Exelon Generation Company, LLC ADAMS Accession No. ML21146A042

From: Gropp Jr, Richard W:(Exelon Nuclear)

To: RulemakingComments Resource

Subject:

[External_Sender] Proposed Rule Comments - 10 CFR 50 ASME 2019-2020 Code Editions (Docket ID NRC-2018-0290)

Date: Tuesday, May 25, 2021 3:11:23 PM Attachments: 10 CFR 50 Proposed Rule ASME Codes - Exelon Comments 05-25-21 (Docket ID NRC-2018-0290).pdf

Please find attached comments on the NRCs Proposed Rule 10 CFR 50, "American Society of Mechanical Engineers 2019-2020 Code Editions" (Docket ID NRC-2018-0290). The attached comments are submitted on behalf of Exelon Generation Company, LLC.

Thank you,

Richard Gropp Exelon Generation 200 Exelon Way Kennett Square, PA 19348

This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to which it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -

EXCIP 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com

May 25, 2021

U.S. Nuclear Regulatory Commission Washington, DC 20555- 0001

Subject:

Comments Concerning Proposed Rule 10 CFR 50, "American Society of Mechanical Engineers 2019-2020 Code Editions" (86 FR16087, dated March 26, 2021, Docket ID NRC-2018-0290)

This letter is being submitted in response to the U.S. Nuclear Regulatory Commission (NRC) request for comments concerning Proposed Rule 10 CFR 50, "American Society of Mechanical Engineers 2019-2020 Code Editions," published in the Federal Register on March 26, 2021 (i.e., 86FR16087).

The NRC is proposing to amend its regulations to incorporate by reference the 2019 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code and the 2020 Edition of the American Society of Mechanical Engineers Operation and Maintenance of Nuclear Power Plants, Division 1: OM Code: Section IST, for nuclear power plants. The NRC is also proposing to incorporate by reference the 2011 Addenda to ASME NQA 2008, Quality Assurance Requirements for Nuclear Facility Applications (ASME NQA -1b-2011), and the 2012 and 2015 Editions of ASME NQA -1, Quality Assurance Requirements for Nuclear Facility Applications. This action is in accordance with the NRCs policy to periodically update the regulations to incorporate by reference new editions and addenda of the ASME codes and is intended to maintain the safety of nuclear power plants and to make NRC activities more effective and efficient.

Exelon Generation Company, LLC (Exelon) appreciates the opportunity to comment and offers the attached comments on certain sections on this proposed rule for consideration by the NRC. In addition, Exelon fully supports the comments submitted by the Nuclear Energy Institute (NEI) on behalf of the industry related to the subject proposed rulemaking.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

Respectfully,

David P. Helker Sr. Manager, Licensing Exelon Generation Company, LLC

Attachment Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2018-0290 Page 1 of 4

Comments Concerning Proposed Rule 10 CFR 50, "American Society of Mechanical Engineers 2019-2020 Code Editions"

10 CFR 50.55a Section Proposed Change Discussion Comments on Proposed Changes

§50.55a(b)(2)(xxvi), NRC proposes to amend § § 50.55a(b)(2)(xxvi)Section XI Exelon recommends (xxvi)Section X I Section XI Condition: 50.55a(b)(2)(xxvi) to remove condition: Pressure Testing of Class condition: Pressure Testing of Class Pressure Testing of Class references to Section XI pressure 1, 2, and 3 Mechanical Joints. 1, 2, and 3 Mechanical Joints not be 1, 2, and 3 Mechanical test and VT-2 examination. The Mechanical joints in Class 1, 2, and 3 added to the R ule as cu rrently Joints NRC proposes to relax the piping and components greater than proposed, but r ather w e suggest it requirement to perform an ASME NPS-1 which are disassembled and should be deleted entirely.

Section XI pressure test in reassembled during the performance Licensee's Appendix B Q uality accordance with IWA-5211(a) and of a Section XI repair/replacement Assurance programs al ready address VT-2 examination of mechanical activity requiring documentation on a leakage inspections of mechanical joints disassembled and Form NIS-2 shall be leak tested to connections outs ide of ASME S ection reassembled during the course of ensure leak tightness. The owner XI IWA-5000 pressure testing repair/replacement activities. shall establish the type of leak test, requirements. The language of the test medium, test pressure, proposed Rule creates a new acceptance criteria that would qualification and inspection program demonstrate the joints leak tightness, for l eak c hecks by r equiring licensees and the qualifications of the personnel to establish the type of leak tes t, test who will perform the leak test. medium, test pressure, acceptance criteria that would demonstrate the joints leak ti ghtness, and the qualifications of the personnel who will perform the leak tes t. Based on the previous requirements under thi s paragraph most licensees adopted using the 2017 Edition of A SME Section XI for exemptions from the IWA-4540(b) requirements without adding any conditions for standard leak checks performed at nominal operating pressure and temperature outside of ASME Section XI required tests.

Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2018-0290 Page 2 of 4

10 CFR 50.55a Section Proposed Change Discussion Comments on Proposed Changes Section 50.55a(b)(2)(xxxii) NRC proposes to amend the § 50.55a(b)(2)( (xxxii)Section XI Exelon recommends "(xxxii) Section Section XI Condition: condition in § 50.55a(b)(2)(xxxii) to condition: XI condition: Summary report Summary Report relax the timeframe for submittal of Summary report submittal. When submittal" not be added to the Rule as Submittal Summary Reports (pre-2015 using ASME BPV Code,Section XI, proposed, and instead of requiring Edition) or Owner Activity Reports 2010 Edition through the latest edition submittal of Summary Reports and (2015 Edition and later) for and addenda incorporated by Owners Activity Reports, that these inservice examinations and repair reference in paragraph (a)(1)(ii) of this reports be made available upon replacement activities. The NRC section, Summary Reports and request to the regulatory authority has no objections to allowing Owners Activity Reports described in having jurisdiction at the plant site and licensees up to 120 days to submit IWA-6230 must be submitted to the to the enforcement authority. Based the reports. NRC. Preservice inspection reports on numerous information requests for examinations prior to commercial associated with the NRC IP 71111.08 service must be submitted prior to the Inservice Inspection Activ ities it does date of placement of the unit into not appear that NRC staff is actively commercial service. For preservice reviewing submitted Summary and inservice examinations performed Reports or Owners Activity Reports following placement of the unit into until prior to the next scheduled commercial service, reports must be refueling outage when requests for submitted within 120 calendar days of information associated with the IP the completion of each refueling 71111.08 inspection are outage. developed. Allowing licensees to prepare the Summary Reports or Owners Activity Reports without formally submitting them alleviates administrative burden while still making these documents available to NRC staff for review if requested.

Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2018-0290 Page 3 of 4

Additional Comments

§ 50.55a(b)(3)(xi) - OM Condition:

1. Exelon requests further clarification concerning Supplemental Position Indication (SPI) implementation timeline and test due dates as no changes were made to the Condition to eliminate interpretation differences between the NRC and Licensees. Additionally, there should be clarification of SPI being required to be performed in conjunction with, but not required to be concurrent with, ISTC-3700 testing following adoption of the ASME OM Code, 2012 Edition, through the latest edition of the ASME OM Code.

2. Exelon requests further clarification of the SPI required testing due date for motor operated valves ( MOVs) in Appendix III as the ISTC -3700 testing has shifted from 2 years to the Appendix III Inservice Testing (IST) frequency.

3. Exelon suggests eliminat ing the supplemental verification requirement for p assive valves or at a minimum only require it in the required valve position. Sites are performing modification where possible or removing valves from the IST program to eliminate the need to do supplemental testing.

4. Exelon is requesting further clarification regarding why supplemental verification testing needs to be performed for valves that are determined to be not-susceptible to stem -disc separation.

5. Exelon suggests that the NRC consider endors ing ASME Code Case OMN-28 (instead of the proposed NRC revision) for valves that are not susceptible to stem-disc separation " similar to what was done with OMN-20."

6. Exelon requests further clarification concerning the required testing due date when implementing the conditions for valves not susceptible to stem-disc separation or OMN-28. For example, can SPI be performed 10 years from the last performance of an ISTC-3700 test prior to implementing the latest edition of the Code?

7. Exelon suggests adding a reference to the EPRI document as acceptable method for determination of val ve stem-disc separation susceptibility.

8. Exelon suggests adding an approval to utilize NRC-approved, performance-based, frequencies for SPI such as Appendix J or other approved performance-based Code Cases or site-specific relief requests.

Suggested wording to address start of SPI testing (draft):

Licensees must verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications such as flow meters or other suitable instrumentation during performance of ISTC -3700 testing to provide assurance of proper obturator Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2018-0290 Page 4 of 4

position for valves with remote position indication. Supplemental verification must be performed in conjunction with, but not concurrent with ISTC-3700, "Position Verification Testing." Supplemental verification for MOVs within the scope of Mandatory Appendix III must be performed in conjunction with but not concurrent with III-3300(e) position verification. Supplemental testing is required to start during performance of the first Position Verification Test following licensee implementation of the ASME OM Code, 2012 Edition, through the latest edition of the ASME OM Code incorporated by reference in paragraph (a)(1)(iv) of this section.

§ 50.55a(f)(4) - Inservice Testing Standards Requirement for Operating Plants :

1. With regard to the statement: "for pumps and valves that are within the scope of the ASME OM Code but are not classified as ASME BPV Code Class 1, Class 2, or Class 3 may be satisfied as an augmented IST program in accordance with paragraph (f)( 6)(ii) of this section,"

Exelon requests clarification whether the citation should be (f)( 7)(ii) since it appears that the NRC is adding Section (7).

2. Exelon is requesting clarification concerning the removal of the statement: "without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section." Is the intent of this change to require prior NRC approval for non-Code Class components to deviate from ASME OM Code requirements? Exelon believes further clarification is needed.

§ 50.55a(f)(7) - Preservice and I nservice Testing R equirements:

1. Regarding the proposed requirement to provide IST plans on a periodic basis, Exelon believes that this will impose an undue burden with no added value and safety benefit and requests further clarification. Inservice Inspection (ISI) does not have the same requirement.

Submission ID 007 Ronald Swain, Electric Power Research Institute ADAMS Accession No. ML21146A043

From: Swain, Ronald To: RulemakingComments Resource Cc: Chengelis, Steve; Selby, Greg; Lindberg, John; Latiolais, Carl; Kull, Doug; Orihuela, Mike; Dunlap, Myles; Langevin, John; Hoffman, Keith; Nove, Carol; Cumblidge, Stephen

Subject:

[External_Sender] Comments to Proposed Rulemaking Docket ID NRC-2018-0290 Date: Tuesday, May 25, 2021 4:44:57 PM Attachments: NDE 20210525-001_Comments to Proposed Rulemaking_FINAL.pdf

Dear Sirs,

Attached are comments to Proposed Rulemaking in Docket ID NRC-2018-0290.

Regards,

Ronnie Swain Senior Technical Executive Plant Support - NDE EPRI l Electric Power Research Institute Office: 704-595-2514 Cell: 704-724-5452 Email: rswain@epri.com

• • • This email message is for the sole use of the intended recipient(s) and may contain information that is confidential, privileged or exempt from disclosure under applicable law.

Unless otherwise expressed in this message by the sender or except as may be allowed by separate written agreement between EPRI and recipient or recipients employer, any review, use, distribution or disclosure by others of this message is prohibited and this message is not intended to be an electronic signature, instrument or anything that may form a legally binding agreement with EPRI. If you are not the intended recipient, please contact the sender by reply email and permanently delete all copies of this message. Please be advised that the message and its contents may be disclosed, accessed and reviewed by the sender's email system administrator and/or provider. ***

Nondestructive Evaluation Program 20210525-001

Via Email

May 25, 2021

U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards and Office of Nuclear Reactor Regulation Washington, DC 20055-001 ATTN: Rulemakings and Adjudications Staff

Subject:

Proposed Rulemaking Comments (Docket ID NRC-2018-0290)

Dear Sir or Madam,

This letter provides comments to the subject proposed rulemaking on behalf of the Nuclear Nondestructive Examination (NDE) Program at the Electric Power Research Institute.

Our comment pertains to the proposed rulemaking posted by the Nuclear Regulatory Commission on Mar 26, 2021, and specifically to Section 50.55a(b)(2)(xviii)(D) NDE Personnel Certification: Fourth Provision. According to the subject proposed rulemaking (Docket ID NRC-2018-0290), the NRC proposes to amend the condition found in

§50.55a(b)(2)(xviii) to address the removal of ASME BPV Code,Section XI, 2011 Addenda from §50.55a(a)(1)(ii). In addition, the NRC has stated that research performed at the Pacific Northwest National Laboratory (PNNL) has shown that laboratory practice can be effective in developing the skill to find flaws, and on-the-job training is effective at developing the ability to perform examinations in a nuclear reactor environment. Based on the research described in Technical Letter Report PNNL-29761 (ADAMS Accession No. ML20079E343), the NRC is proposing that the 250 experience hours for a Level I certification can be reduced to 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br />, with 125 experience hours and 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of laboratory practice, and the experience hours for Level II certification can be reduced to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />, with 400 experience hours and 320 hours0.0037 days <br />0.0889 hours <br />5.291005e-4 weeks <br />1.2176e-4 months <br /> of laboratory practice, without significantly reducing the capabilities of the examiners to navigate in a nuclear reactor environment. The NRC is therefore proposing to add an option to

§50.55a(b)(2)(xviii) to allow these requirements as an alternative to Appendix VII, Table VII-4110-1 and Appendix VIII, Subarticle VIII-2200 in the 2010 Edition.

U.S. Nuclear Regulatory Commission May 25, 2021 Page 2

EPRI NDE Comment - EPRI agrees that laboratory practice can be effective in developing UT examiner skills. As a matter of fact, we have been studying this question as part of a project we are working on to develop a technical basis for nondestructive examination (NDE) experience requirements for ASME Section XI, Appendix VII, which is scheduled to be published by the end of July, 2021. As part of that project work, we have determined that experience gained in many aspects of ultrasonic testing (UT) in the lab can be superior to experience gained performing the same examinations in the field, in terms of providing the opportunity for learning and improvement. Some of these skills are listed below:

- Inspecting UT equipment for wear/damage/operation

- Linearity checks

- Use of common calibration standards

- Applications of common UT mathematics

- Calibration and examination using shear wave transducers

- Calibration and examination using longitudinal wave straight beam transducers

- Calibration and examination using refracted longitudinal wave angle beam transducers

- Review of UT procedures and preparation for examinations (including equipment/angle selection)

- Examination of ferritic piping welds

- Examination of austenitic piping welds

- Examination of dissimilar metal piping welds

- Examination of cast austenitic piping welds

- Examination of carbon steel vessels

- Examination of bolts and studs

- Taking thickness and contour information of a component

- Recording and plotting of UT indications

- Reporting of UT examination results

- Reporting examination coverage limitations and performing calculations of coverage

- Advanced flaw detection techniques

- Through-wall sizing of flaws U.S. Nuclear Regulatory Commission May 25, 2021 Page 3

We also recognize that there are certain skills associated with performing UT examinations in a nuclear power plant that would not easily be replicated in a lab and, therefore, are advantageous to learn and practice in the field. These include:

- Reviewing historical examination data

- Providing radiological protection for UT equipment

- Reading plant isometric and fabrication drawings

- Location and positive identification of field components

- Assessing the accessibility and condition of a component for UT examination

- Performance of UT in difficult field conditions and environments So, while it is recognized that are aspects of the performance of UT in nuclear power plants that are not conducive to learning in a lab environment, many aspects of the examination process are easily replicated and can be fully exercised in the lab environment and include the added advantage of knowing the truth information (location, type, size, and orientation of defects as well as geometric and metallurgical reflectors) about the components being examined.

Additionally, radiological hazards and other safety issues and stressful conditions are not present in the lab. These advantages enable meaningful feedback to be provided to the examiner and, if necessary, the technician can even be allowed to re-examine components to reinforce learning.

Lab Time for the Skills Development of a UT Level II Borrowing from the ASME ANDE job task analysis information for UT as well as taking inputs from numerous industry UT Level III technicians, on what the required skills are to become an eligible candidate for Level II in the nuclear industry, our project team has determined that a majority of those hours would apply to learning and practicing skills that could be gained in a laboratory environment. Certainly, considering the goal of producing Level IIs that are capable of performing consistent and reliable examinations, the idea of allowing a significant portion of their experience to be garnered in the lab should be seriously considered. During our in-depth review of the skills and knowledge required of a UT technician, and a corresponding review of the hours needed to obtain proficiency in each skill area, we have determined that at least 65% of a technicians working time is spent mastering skills that can be replicated in the lab.

U.S. Nuclear Regulatory Commission May 25, 2021 Page 4

Now, we are not recommending that all of the experience needed to master a skill should be obtained in the lab environment, even where that is demonstrably possible. We recognize that there are some situations and issues that will be experienced in the field that are unlikely to occur in the lab and that those experiences are also valuable to the overall development of a well-rounded technician. But given the advantages to learning so many of these skills in a lab setting, we would suggest that up to 45% of the overall experience hours required for a technician to be considered eligible for UT Level II should be allowed to be obtained in the laboratory.

This aligns with the current NRC proposal for 320 of the 720 experience hours for a Level II to be allowed to be conducted in the lab, since 320 is approximately 45% of 720. But we think that the percentage is more important than the actual number, because once EPRI has completed the development of its technical basis for experience hours, there is a likelihood that a code action will be forwarded that, backed by technical basis, will propose a change in the experience hours in Appendix VII. If the NRC uses the percentage, in lieu of the number, then the regulation can still be applied to the overall experience hours, regardless of the actual number that is published in Appendix VII.

Lab Time for the Skills Development of a UT Level III The subject proposed rulemaking does not currently address any reduction in experience hours for eligibility for UT Level III, nor does it provide any provision for lab time that can be substituted for these experience hours. However, as part of the afore-mentioned project and using the same methodology applied to the Level II question, we have carefully thought about the experience needed to become skillful and knowledgeable enough to be eligible for initial certification to UT Level III. Many of the skills that a UT Level II gains through experience, which goes toward their qualification to become a UT Level III, are the same skills that have been outlined in this letter as being needed for qualification to UT Level II.

By scrutinizing the entire list of skills needed for this certification level and thinking about the time needed to become proficient in those areas, we have determined that 39% of the overall experience needed could be gained in the lab.

Similar to the discussion in the previous paragraphs on the unique learning opportunities afforded by field experience, we again would only suggest that 27%

of the experience hours needed to qualify an individual to be a candidate for UT Level III be allowed to be obtained via lab practice. Based on the logic provided in the previous section of this letter, we think this would result in improved technical skills leading to more consistent and reliable examination results.

Lab Time for the Skills Development of a UT Level I At present, EPRI has not studied the specific skills and knowledge needed to be a candidate for UT Level I, nor the time required to obtain proficiency in those U.S. Nuclear Regulatory Commission May 25, 2021 Page 5

areas. Therefore, we are unable to propose modifications to that aspect of the proposed rulemaking.

Summary of Changes Requested to the Proposed Rulemaking Based on the discussion provided in this letter, which is geared toward improving the overall capabilities and reliability of nuclear industry UT examiners, we request that the NRC consider modifying the proposed rulemaking with regard to

§50.55a(b)(2)(xviii) to include allowing up to 45% of required experience hours for initial certification to UT Level II to be obtained through laboratory practice and to allow up to 27% of required experience hours for initial certification to UT Level III to be obtained through laboratory practice.

We appreciate the opportunity to provide comments to this proposed rulemaking.

Should you have any questions pertaining to the comments provided in this letter, please contact Ronnie Swain for clarification.

Sincerely,

Ronnie Swain Senior Technical Executive EPRI Nuclear Plant Support Department 704-595-2514 - office 704-724-5452 - mobile rswain@epri.com

Cc: Steve Chengelis Greg Selby John Lindberg Carl Latiolais Doug Kull Mike Orihuela Myles Dunlap John Langevin Submission ID 008 C.J. Riedl, Tennessee Valley Authority ADAMS Accession No. ML21146A150 As of: 5/26/21 10:26 AM Received: May 25, 2021 PUBLIC SUBMISSION Status: Pending_Post Tracking No. kp4-xni5-sbgo Comments Due: May 25, 2021 Submission Type: Web

Docket: NRC-2018-0290 2020 Edition of the American Society of Mechanical Engineers Operations and Maintenance Code

Comment On: NRC-2018-0290-0001 American Society of Mechanical Engineers 2019-2020 Code Editions

Document: NRC-2018-0290-DRAFT-0002 Comment on FR Doc # 2021-06085

Submitter Information

Email: cjriedl@tva.gov Government Agency Type: Federal Government Agency: TVA

General Comment

See Attachment 1 - TVA Comments NRC-2018-0290

Attachments

- TVA Comments NRC-2018-0290 Tennessee Valley Authority Comments on Proposed 10 CFR 50 Rule Incorporating American Society of Mechanical Engineers 2019-2020 Code Editions (Docket ID NRC 2018 0290)

Comment #/Section Comment Recommendation

1. 50.55a(b)(2)(xxv) On page 16111 of Reference 1, 10 CFR 50.55a(b)(2)(xxv) heading, Section On page 16111 of Reference XV Condition is incor r ect, and, as noted in 86 FR, in the proposed section 1, 10 CFR 50.55a(b)(2)(xxv)

(xxv)(A), First person should be changed to First provision. heading, change Se c t ion XV Condition to Section XI Condition, and, as noted in Reference 2, in the proposed section (xxv)(A), change First person to First provision.

2. 50.55a(b)(2)(xxvi) T VA co ncurs with the NRCs proposal to eliminate the ASME Code TVA recommends that pressure test and VT - 2 examination of mechanical connections in 10 CF R 50.55a(b)(2)(xxvi) be

§ 50.55a(b)(2)(xxvi) because the same leak test procedures that are used deleted entirely, as it for non-ASME Code repair and replacement will provide adequate increases licensee burden, but assurance of leak tightness. However, TVA recommends to accomplish this provides no quality or safety objective that 10 CF R 50.55a(b)(2)(xxvi) be deleted entirely, or, benefit.

alternatively, replaced with the following: Alternatively, Mechanical joints in Class 1, 2, and 3 piping and components greater 50.55a(b)(2)(xxvi) should be than NP S-1 which are disassembled and reassembled during the replaced with Mechanical performance of a Section XI repair/replacement activity shall be ver ified joints in Class 1, 2, and 3 to be leak tight in accordance with the licensees Appendix B program. piping and components This would eliminate requirements that may be more specific than those greater than NPS - 1 which are utilized in licensees existing non-Code leak test procedures, and for which disassembled and the technical basis for such differentiation is unclear. reassembled during the performance of a Section XI First, the proposed rule requires the owner document the type of leak test, repair/replacement activity test medium, test pressure, and acceptance criteria that would demonstrate shall be verified to be leak -

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2. 50.55a(b)(2)(xxvi) the joints leak tightness when performing a leakage test following a repair / tight in accordance with the (continued) replacement activity requiring a NIS - 2 form. Specifics with these details licensees Appendix B may not exist in the licensees non-Code leak test procedures, which are program.

developed and maintained in accordance with the licensees Appendix B Q A program, and wh i ch, a s noted in the proposed rule discussion, support the qualitative risk analysis that concluded elimination of the Section XI pressure test and VT - 2 examination resul ted In a very low risk of failure.

Therefore, TVA recommends that the proposed rule language be revised to either 1) eliminate the requirement entirely, or 2) revise the language to simply require verification of leak tightness in accordance with the sites QA program requirements.

Second, the proposed rule requires licensee to specify the qualification requirements for the person performing the leak test. T ypically, maintenanc e organization personnel qualified in accordance with the sites Appendix B program will perform the field walkdown, in accordance with site Appendix B procedures, to ensure no leakage exists following reassembly of a mechanical connection. This method of leak detection has been successfully utilized for many years in the industry. Creation of an additional personnel qualification requirement in the sites non-Code leak inspection program, even if owner - defined, creates an unnecessary burden for the utilities with no corresponding increase in quality or safety. It i s recommended that this requirement be removed from the proposed rule.

Lastly, the technical basis for these proposed additional requirements is unclear, particularly when applied only to mechanical connections assembled as part of a repair or replacement activity requiring an NIS -2 form. Hypothetically, if a 2-inch ASME Code Class 2 socket weld fails due to thermal fatigue, and the adjacent mechanical connection is disassembled

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2. 50.55a(b)(2)(xxvi) and later reassembled to support the performance of that socket weld (continued) repair/replacement activity, that mechanical connection should not necessitate any more rigorous leakage test than it would if the same connection were disassembled and reassembled for any other reason. It is appropriate for mechanical connections to be subject to a leakage test when reassembled, regardless of the reason for the disassembly and reassembly, and the standards applied to those tests should be the same. The purpose of this post - maintenance leakage test is to verify adequate maintenance practices and ensure good housekeeping. By design, leakage at mechanical connections is not a condition that affects the structural integrity of a piping system. For that reason, TVA recommends that 10 CFR 50.55a(b)(2)(xxvi) should be deleted altogether or rewritten to state simply that verification of leak tightness according to the licensees Appendix B program is required for Class 1, 2, and 3 mechanical joint s.

3. 50.55a(b)(3)(iv) This condition was first imposed as part of final rulemaking dated July 17, TVA recommends that 2017 and became effective on August 17, 2017 (Federal Register / Vol. 82, 10 CF R 50.55a(b)(3)(iv) OM No. 136). This condition effectively implemented new requirements which Condition: Check Valves were added to the 2017 Edition of OM, Appendix II, II - 4000(b)(1)(e) that (Appendix II) be revised to be require distribution of Check Valve Condition Monitoring (CVCM) activities applicable to all addenda and for each valve in a multi - valve group at approximately equal intervals across editions of OM endorsed for the interval for the group. The language in the 2017 Edition of OM and this use. In addition, the overly condition are essentially the same. restrictive language At While the goal for this condition and clarification in 2017 Edition of OM is least one of the identified appropriate, the actual language of these two documents has had activities for a valve group unintended consequences. The statement, At least one of the identified shall be performed on each activities for a valve group shall be performed on each valve of the group at valve of the group at approximately equal intervals

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3. 50.55a(b)(3)(iv) not to exceed the maximum (continued) approximately equal intervals not to exceed the maximum interval shown in Table II-4000- 1 has resulted in significant burden for licensees to the interval shown in Table II -

revise their CVCM program plans for compliance. The requirement to 4000- 1 should be revised distribute the CVCM activities across each valve at equal intervals is more to simply require compliance prescriptive than necessary to ensure a licensee doesnt defer activities for with the maximum intervals all valves in a group to the end of the group interval. (both columns) shown in Before this condition and OM change, licensees regularly performed CVCM Table II - 4000- 1. T h is will activities on pairs of valves in a group or staggered the activities across the provide flexibility for those valve group interval in a manner that met the goal of distributing activities of CVCM plans that are not at mu l t i-valve groups. However, the method of staggering activities did not the maximum intervals while meet the prescriptive language of this condition. As a result, the only way to also ensuring activities on comply with this condition and optimize testing is to split the group into individual valves are not smaller groups of valves or groups of one as permitted by II - 2000(a). T his deferred to the end of the requires new test procedures and additional scheduling for all the new group interval.

groups, and substantially increases the burden on licensees without necessarily ensur ing a better distribution of activities.

Example:

Assume all activities for the group have not been completed such that interval extension is not allowed at the time the condition becomes effective.

Before Condition:

One group of four valves where activities on t wo valves in the group are performed every other outage Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A, C B, D (A, B, C, D)

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3. 50.55a(b)(3)(iv) After Condition:

(continued) One group of four valves where activities on one valve in the group are performed every outage Group Outage 1 Outage 2 Outage 3 Outage 4 4 valves A C B D (A, B, C, D)

OR Two groups of two valves where activities on one valve in the group are performed every other outage Group Outage 1 Outage 2 Outage 3 Outage 4 2 valves A B

( A, B) 2 valves C D

( C, D)

The example above demonstrates a case where a CVCM plan that met the original intent of OM to stagger activities still must be revised to comply with the condition. In addition, the example shows two different ways the CVCM program may be revised to order to comply with this condition. The last method shows how the revised CVCMP can comply with the condition without changing the schedule of activities. The end result is that compliance with this condition imposed a significant burden to revise CVCM plans with no increase in the level of safety.

4. 50.55a(b)(3)(xi) TVA acknowledges that the proposed change to condition (b)(3)(xi) p r o vides TVA recommends that the some relief from a burdensome requirement imposed by the rule. However, proposed change to the CFR in collaboration across the industry, a detailed alternative to compliance with be replaced as follows: For

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4. 50.55a(b)(3)(xi) the conditi on was created and approved in ASME OM Code Case OMN - 28. valves not susceptible to (continued) Therefore, it is recommended that the proposed change to the CFR be stem-disk separation, ASME replaced as follows: For valves not susceptible to stem - disk separation, OM Code Case OMN-28 may ASME OM Code Case OMN-28 may be used to satisfy the valve position be used to satisfy the valve verification requirements in ASME OM Code, Subsection ISTC, paragraph position verification IS T C 3700. requirements in ASME OM Code, Subsection ISTC, paragraph ISTC 3700.

5. 50.55a(b)(3)(xi) OM Condition (b)(3)(xi) provides a requirement for plants in the proces s of TVA recommends that NRC an interval update from any edition older than the 2012 ASME OM Code. specify an initial test date of There has been confusion regarding the initial test requirement and initial no later than 2 years (ISTC -

performance date. Given the potentially significant burden imposed by this 3700 Frequency) from the new test requirement, additional guidance should be provided for th e in itia l start of the interval for which implementation timeframe to minimize confusion. the newer Code applies.

While Condition (b)(3)(xi) is based upon a test currently contained in the Code, the modification of the existing test is such that an entirely new test requir ement is being created through this condition. The NRC is proposing a r isk-based modification to the implementation with the proposed change.

Specifying an initial test date of no later than 2 years (ISTC -3700 Frequency) from the start of the interval matches the historical precedent for a new requirement.

6. 50.55a(f)(4) The proposed change to 10 CF R 50.55a(f)(4) removes valuable wording TVA recommends that the and changes implementation requirements in a manner that could result in current statement, without excessive and potentially unexpected relief requests from licensees, and requesting relief under could represent a significant administrative burden for many l icensees and paragraph (f)(5) of this section the NRC. The current wording allows licensees to document an alternative or alternatives under position for components not c l as s i fi ed as A S M E B P V Code Cl as s 1, Cl as s 2, paragraph (z) of this section or Clas s 3 without requiring regulator approval. The proposed removal of remain unchanged in the

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Comment #/Section Comment Recommendation

6. 50.55a(f)(4) this wording would indicate that the NRC expects to approve relief for CF R. If this statement is to be components within the augmented IST program. TVA recommends that the removed as proposed, T VA current statement, without requesting relief under paragraph (f)(5) of this recommends that it be section or alternatives under paragraph (z) of this section. remain within the evaluated and justified as a CFR as currently approved. This statement was included to minimize the backfit under 10 CFR 50.109.

burden on licensees for non-Code components, and should be retained unless the need for additional review requirements is demonstrated.

As an example, ther e are numerous non -Code valves that perform a safety function that may not have been designed to be explicitly tested to ASME OM Code Requirements. At present, licensees may internally document deviations from the ASME OM Code relying on technical positions within the respective augmented IST programs. The proposed CFR change above would immediately result in each of these positions requiring relief from the NRC, and may place licensees in violation of 10 CFR 50.55a(f)(4).

TVA perceives that this change would be an expansion of regulatory oversight and burden, and as such, would be a backfit that requires analysis and justification to implement.

7. 50.55a(f)(7) The proposed addition of 10 C FR 50.55a(f)(7) is a burdensome change with T VA recommends removing no commensurate benefit to public health and safety. T VA r ecommends the addition of removal of this proposed requirement. This new administrative requirement 10 CF R 50.55a(f)(7) f r o m this would require a broad revision of licensee administrat ive procedures and proposed change. If addition processes, without commensurate benefit. Even without this proposed of 50.55a(f)(7) is pursued, regulation, t he licensee must work to the latest approved program TVA recommends that it be document, and it must be available to the regulator upon request. During evaluated and justified as a any inspection or event that requires the NRC to review an IST Program for backfit under 10 CFR 50.109.

requirements, the latest copy is generally requested and duly provided by the licensee. Additional preparation, verification, and review time for the increased frequency required by the proposed change for submittal of IS T Program documents, wh i c h are typically several hundred pages, could

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7. 50.55a(f)(7) require significant additional resource burden without commensurate benefit (continued) to safety or quality. While T VA recommends removal of this proposed change, if NRC pursues implementation, th is change should be evaluated and justified as a backfit under 10 CFR 50.109.

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