Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of PipingML20198S694 |
Person / Time |
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Site: |
Duane Arnold |
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Issue date: |
01/09/1998 |
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From: |
Huting M IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
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To: |
NRC OFFICE OF ADMINISTRATION (ADM) |
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References |
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FRN-62FR53663, RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE 62FR53663-00011, 62FR53663-11, NG-98-0065, NG-98-65, NUDOCS 9801260259 |
Download: ML20198S694 (5) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl ML20247N7531988-07-28028 July 1988 Petition for Rulemaking PRM-50-53 Requesting NRC Action to Review Undue Risk Posed by BWR Thermal Hydraulic Instability.Nrr Should Issue Order Requiring All GE BWRs to Be Placed in Cold Shutdown for Stated Reasons 1999-09-24
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARNG-99-1232, Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 7901011999-09-24024 September 1999 Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.48, Fire Protection, & App R to 10CFR50, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101 NG-99-1296, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration1999-09-20020 September 1999 Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors.Approves mark-up to Draft Revision 2 to NUREG-1022 with Description & Basis for Each Change for Review & Consideration NG-99-1263, Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide1999-09-10010 September 1999 Comment Opposing Proposed Rule 10CFR50 Re Change to 10CFR50.47, Emergency Plans & Endorsing L Hendricks Ltr Re Use of Potassium Iodide NG-99-0616, Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures1999-04-30030 April 1999 Comment Opposing Proposed Rules 10CFR170 & 171 Re Rev of Fee Structures NG-98-2045, Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments1998-12-18018 December 1998 Comment Opposing Proposed Rules 10CFR50,52 & 72 Re Changes, Tests & Experiments NG-98-2056, Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself1998-12-14014 December 1998 Comment Supporting Proposed Rulemaking to 10CFR50.65, Requirements for Monitoring Effectiveness of Maint at Npps. Author,However Have Some Concerns Re Proposed Rule Language Itself NG-98-0926, Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement1998-05-22022 May 1998 Comment Opposing Proposed Rule 10CFR50 on Codes & Standards:Ieee National Consensus Standard. Ies Utilities Believes Proposed Rule Will Impose Addl Costs & Vulnerabilities on Licensees W/No Substantial Improvement NG-98-0329, Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment1998-02-20020 February 1998 Comments on Pr 10CFR50 Re Engineering Judgment for Activities or Evaluations of Components or Sys.Change to 10CFR50.55a Should Be Defined If NRC Concerned About Specific Application of Using Engineering Judgment NG-98-0065, Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping1998-01-0909 January 1998 Comment on Draft Standard Review Plan 3.9.8, for Review of Risked-Informed Inservice Insp of Piping & Draft Reg Guide DG-1063, Approach for Plant-Specific,Risked-Informed Decisionmaking:Inservice Insp of Piping NG-97-2036, Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 19711997-11-25025 November 1997 Comment on Proposed Rule 10CFR50.55(h) Re Draft RG DG-1042, Criteria for Safety Sys. Amended Rule Not Clear Regarding Application to Plants That Received Their Const Permits Prior to 1971 NG-97-1213, Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments)1997-07-0303 July 1997 Comment on NUREG-1606, Proposed Regulatory Guidance Re Implementation of 10CFR50.59 (Changes,Test or Experiments) NG-95-2723, Comment Supporting Revised NRC SALP Program1995-09-0505 September 1995 Comment Supporting Revised NRC SALP Program NG-95-1404, Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation1995-04-11011 April 1995 Comment Supporting Nuclear Energy Inst Comments on Draft Policy Statement, Freedom of Employees in Nuclear Industry to Raise Safety Concerns W/O Fear of Retaliation NG-95-0464, Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors1995-02-0303 February 1995 Comment on Proposed Rule 10CFR50 for Shutdown & low-power Operations for Nuclear Power Reactors NG-94-4468, Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures1994-12-0808 December 1994 Comment Supporting Proposed Rule 10CFR2,51 & 54 Re NPP License Renewal.Util Encourages NRC to Give Consideration to NUMARC Recommendation That Rule Include Addl Criterion Permitting Generic Exclusion of Redundant Structures ML20056G3351993-08-27027 August 1993 Comment Opposing Proposed Rule 10CFR2 Re Review of 10CFR2.206 Process NG-93-3257, Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses1993-08-12012 August 1993 Comment Supporting Proposed Rule 10CFR55 Re Operators Licenses ML20045F8561993-06-22022 June 1993 Comment on Proposed Rule 10CFR26 Re Mods to fitness-for-duty Program Requirements.Endorses NUMARC Comments ML20086K0431991-12-0202 December 1991 Comment on Draft Reg Guide DG-8003 & NUREG-1400, Air Sampling in Workplace. Licensee Feels That Concept Could Be Useful Tool in Determining When Air Sampling Is Warranted But Feels Hazard Index Level Needs Clarification NG-91-1144, Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 19911991-05-13013 May 1991 Comment on Proposed Rules 10CFR71,170 & 171, Rev of Fee Schedules;100% Fee Recovery. Endorses NUMARC Comments.Nrc Should Revise Proposed Schedule for Collection of Increased Fee for 1991 NG-91-0222, Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept1991-01-28028 January 1991 Comment Supporting Proposed Rule on Secy 90-347 Re Regulatory Impact Survey Rept NG-90-2541, Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program1990-10-30030 October 1990 Comment Supporting Proposed Rule 10CFR26 Re fitness-for-duty Program NG-90-1446, Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements1990-07-0202 July 1990 Comment Supporting Petition for Rulemaking PRM-50-55 Re FSAR Revs,Per 10CFR50.71(e)(4) Requirements ML20195J9001988-11-29029 November 1988 Comment on Proposed Rule 10CFR26 Re Fitness for Duty Program.Detailed Comments on Rule Encl 1999-09-24
[Table view] |
Text
ff g) Duane Amold Energy Canty 3277 DAEC Road j ll g
- h ( b, / f l f h' l Palo, IA 52324 7ekphone 319 8517611
' Fat 319 8517611
,l UTILITIES-NUCLEAR GENERATION DIVISION NG-98-0065 ES IN E ?
January 9,1998 g o, E j
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Rules and Directives Branch ?. o Office of Administration SG US Nuclear Regulatory Commission Washington, D.C. 20555 Project: Duane Arnold Energy Center Docket No.: 50-331 Op. License No.: DPR-40
Subject:
Comments on Draft Standard Review Plan 3.9.8. "For The Review Of Risked-Informed inservice Inspection of Piping," and Draft Regulatory Guide DG-1063,"An Approach For Plant-Specific, Risked-informed Decisionmaking: Inservice Inspection of Piping" File: A-100, A-286a
Dear Sirs:
Attached please find IES Utilities comments on the subject documents.
Sincerely, g -
1 ark Huting Program Engineering I.l 1.1 I.lil.li lil il.lill MAH/GCP/cfs ,
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Attachment:
Comments '-
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p 9s jta g 9soto9 0800 C PDR^ An IES k&stnes Corrveny
4 BACKGROUND Draft Standard Review Plan Chapter 3.9.8 describes review proceoures and acceptance guidelines for NRC staff reviews of proposed plant specific, risk-informed changes to a licensee's inservice inspection (ISI) prcgram for piping.
The review procedures contained in this SRP are consistent with the acceptable methods for implementing a risk informed ISI program described in DG-1063.
Draft Regulatory Guide DG 1063 "An Approach for Plant-Specific, Risked-Infctmed Decision Making: Inservice inspection of Piping" describes acceptable alternative approaches to the existing Section XI requirements foi ISI Programs.
Its use by licensees is voluntary. This alternative approach provides an acceptable level of quality and safety by incorporating insights from probabilistic risk analysis calculations. Licensees proposing to epply risk informed inservice inspection programs will be required to amend their final safety analysis report accordingly.
DISCUSSION This letter is to provide comments on the above-discussed NRC draft documents. The two documents will be addressed separately; however, some comments may be applicable to both.
Draft Stcodard Review Plan Chapter 3.9.8:
- 1) Clarification of the implementation of the RI ISI Program should be made, it is my understanding that if a utility decides to use the RI ISI Program during the implementation, the current ASME XI ISI Program is still required. I did not see anywhere in the SRP where it specifies an interim process for transition.
- 2) l1.2.2.1 requires all ASME Code Class 1,2, ard 3 piping to be included in the RI ISI Program along with other balance of plant systems which would be classified as safety significance. If the PSA and Maintenance Rule at the utility has already established the systems determined to be risk significant (CDF , RRW, RAW, and LERF) why would additional work be required to address the systems not already covered by the existing PSA.
In other words, use the existing listing of systems.
- 3) II.2.3.1 states 'n: ping that are subject to ISI under ASME XI requirements but have no s.,,ments exceeding the piping segment screening criteria should be further reviewed. Each ASME Class coded system should have a minimum program of piping segnients selected and categorized as more safety-significant." If this is the case muen of the benefit for using RI ISI will be lost.
t
Attachment ta NG 98 0065 Page 2 of 4
- 4) l1.3 still requires the pressure testing and visual examination of piping structural elements (assuming this is the component supports etc.) of all Class 1,2, and 3 systems in accordance with ASME BPVC Section XI Program regardless whether the segmento contain locations that havu been classified as more or less safety-significant. The reason for using this new technology is to perform examinations on systems where the risk is more significant; but if there is still a requirement for doing the visual examinations of the structural elements of all the s/ stems regardless of safety significance, then the complex process of establishing the program seems to lose much of its value.
- 5) lll.2.1 states the reviewer will ensure that the licensee has demonstrated that the Rl-ISI has no adverse impact on the augmented inspection programs such as IGSCC or EC. If the RI-ISI Program was performed properly wouldn't it take into account the IGSCC and EC degradation meQarisms, thus already include those piping segments, wherein the augmented programs would no longer be required.
Draft Regulatory Guide DG 1063:
- 1) 1.3 SCOPE discusses that the licensee's RI ISI Program should include those ASME Code Class 1,2, and 3 and NON Code systems that have been categorized as HSS. This contradicts the SRP which specifies the inclusion of all ASME Code Class 1,2, and 3 with the non-code systems in the RI ISI Program regardless of safety significance (HSS or i SS).
- 2) 4.2 Probabilistic Risk Assessment states an acceptable RI-ISI process should not focus exclusively on areas in which reduced inspection could be justified. I agree with this; however, if the acceptable RI-ISI process does provide assurance that a Code Class 1,2, or 3 system does hot have a safety significance, then the inspection of that system should be eliminated.
- 3) 5.4.l.(1) states that the NRC need not approve the elimination of items to be examined if a reevaluation is performed using the RI-ISI process. Is this because the process itself requires NRC approval?
- 4) 5.4.J.(1) states sequence of piping examinations established during the first inspection interval using the RI ISI process shall be repeated during ench successive interval. Why is the sequence so important when RI ISI Program is based on establishing the safety significance of systems and grouping items based on the same degradation mechanisms? The sequence of examination should not be based on performing examinations on the exact same item, but on items with the same degradation mechanism within the same segment. This would allow an
. Attachment 13 NG g8-0065 Page 3 of 4 owner to still ms!ntain the safety and quality of a system L-Jt have the flexibility to meet ALARA goals.
- 5) 5.4.o states that system pressure tests should be performed in accordance with ASME Section XI IWA ,lWB , lWC , and IWD 5000.
What will be specified for those non-code claesed systems which may be part of the RI ISI Program based on safety significance?
- 6) 6.2.2.1 should be clarified because all Class 1,2, and 3 systems may have been included in the PSA process; however, some of those systems may have dro,nped out and not included in the RI ISI Program based on safety significance (i.e., a system may have been classified as LSS, therefore not required to be examined). !
- 7) 6.2.2.1 also states that all systems excluded must be justified. This needs ,
to be clarified "Does potable water need justification for not being included in the Rl ISI Program?"
- 8) 6.4 specifies tha' 'll Class 1,2, and 3 systems require pressure testing and visual exam. .,a per ASME BPVC Section XI regardless of safety significance. ,
e Are there any requirements for non-class systems and
. Why perform the visual examinations of the structural elements of a ,
piping system that would not require any weld, base metal, or heat affect zone examinations?
EVALUATION ,
There is no evaluation needed at this time because the DAEC is not pursuing the RI ISl approach to an inservice inspection program.
The DAEC is not supportive, at this time, of the Risked Informed approach to setting up an ISI Program. We feel that the ASME Section XI Code committe,es represent the appropriate veh!cle for establishing inspection scope and ,
frequency. These committees ere comprised of experts from nuclear utilities, regulatory agenr,ies, and EPRI. Under an RI ISI Program, inspection ,
requirements will be made on such a case-by-case basis that it will be nearly
- impossible for utilities or regulators to understand the expectations for an -
inspection program.
RI-ISI will also require inspection programs to include some systems which were not constructed, purchased, or inspected to Code requirements. it would be reasonabis W assume that the inspection of these compor,ents will result in the discovery of fabrication flaws or manufacturing flaws that may have been y- w- - . _ , - - -a- y-- vf-e.-r , .y.- raw-ge,%,- p ,,gr*-- e --i- -----*F-w *T-9 h""-** W-
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. .~ .
.l Att:chment is
, NG 98-0065 Page 4 of 4 acceptable originally but do not meet Section XI requirements. Evaluation of these flaws will be difficult due to limited design basis information and the potential for costly scope expansions is likely without a corresponding benefit to plant safety. Many of these systems are already being monitored in support of flow accelerated corrosion and service water inspection programs.
^
l
- The cost and manpower involved with the establishment of an RI ISI Program l would be extensive and would not result in a better inspection program. In fact it would likely result in a more fragmented difficult program. The process of t justifying the basis of your program to Anils and NRC Inspectors unfamiliar with the PSA proce" would be extremely tedious and would likely result in neither :
party clearly unumstanding the intent or expectation of the other.
Codes are written to provide uniform guidance for critical activities and allow Owners and Regulators to have a standard set of rules to operate and inspect to. .
With an RI ISI Program, the rules will be uncertain and variable depending on each utility's individual approach to evaluating their systems and components and the uniqueness of individual plant designs.
We realize that there has been significant effort into preparing these two documents in order to standardize the process for assembling an RI ISI Program and for providing criteria for an NRC review of that program. However, we do not believe that these documents would be effective in accomplishing their purpose. This is based on the fact that each plant has many unique features, different uses for the same systems and differing damage mechanisms. Thus, ;
each RI ISI Program would be significantly different causing confusion within the >
industry and not simplifying or improving the current ISI programs.
l
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