NRC-2011-0088, Comment (23) from Thomas Conboy of Prairie Island Nuclear Plant on the Proposed Rule for 10 CFR Part 50 - Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases
| ML15355A158 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/15/2015 |
| From: | Conboy T, Johnson P Xcel Energy |
| To: | Annette Vietti-Cook NRC/SECY |
| SECY/RAS | |
| References | |
| 80FR56819 00023, NRC-2011-0088 | |
| Download: ML15355A158 (5) | |
Text
PR 10 CFR Part 50 80 FR 56819 23 From: Johnson, Pamela J.
To: RulemakingComments Resource Cc: Johnson, Pamela J.
Subject:
[External_Sender] COMMENTS on Docket ID NRC 2011-0088 Date: Friday, December 18, 2015 4:53:29 PM Attachments: Xcel Rulemaking Comments 12-18-15.pdf Importance: High
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 Enclosure
§50.55a(b)(3)(iv)
Proposed Changes to Regulations (Draft Rule): (iv) OM condition: Check valves (Appendix II). Appendix II, Check Valve Condition Monitoring Program, of the OM Code, 2003 Addenda through the 2012 Edition, is acceptable for use without conditions with the clarifications that (1) the maximum test interval allowed by Appendix II for individual check valves in a group of two valves or more must be supported by periodic testing of a sample of check valves in the group during the allowed interval and (2) the periodic testing plan must be designed to test each valve of a group at approximate equal intervals not to exceed the maximum requirement interval. Licensees applying Appendix II of the OM Code, 1995 Edition with the 1996 and 1997 Addenda, shall satisfy the requirements of paragraphs (b)(3)(iv)(A) through (C) of this section.
Licensees applying Appendix II, 1998 Edition through the 2012 Edition, shall satisfy the requirements of paragraphs (b)(3)(iv)(A), (B), and (D) of this section.
Comment: The condition additions of clarifications (1) and (2) should be removed from rulemaking.
This condition should only be applicable to 1998 Edition through 2003 Addenda. This condition should not be applicable to the 2004 Edition through 2012 Edition because the requirements of (b)(3)(iv)(A), (B), and (D) have already been incorporated into these versions of the code.
§50.55a(b)(3)(xi)
Proposed Changes to Regulations (Draft Rule): (xi) OM condition: Valve Position Indication. When implementing ASME OM Code, Subsection ISTC-3700, Position Verification Testing, licensees shall develop and implement a method to 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.
Comment: The major burden here is the shall statement regarding the implementation of supplemental methods to verify obturator position and movement.
The ASME Subsection ISTC, is working to change the code to alleviate the regulatory concern associated with the determination of obturator position or movement using ONLY stem position.
The background information for the proposed rule indicates that this is only a clarification of the intent of the existing ASME OM Code. This statement is misleading
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 and incorrect. The existing code does not require supplemental indications to be performed with all position indication testing. This was confirmed through ASME OM Code Interpretation 12-01, which is consistent with how the industry approaches this testing. This NRC clarification of the code would result in a very significant new requirement for licensees. Finally, based on the NRCs Backfit Rule, this clarification appears to be a new or different regulatory position that would require a backfit analysis.
To impose this condition on every IST component with a position indication test would be overly burdensome to the licensees with little to no benefit in return.
This condition, as written, should be removed from the rulemaking. If this condition remains in the rulemaking, it should add a where practicable clause in order to reduce the potential large volume of requests for relief. In addition, the condition should provide an implementation period to allow licensees adequate time to develop the necessary test procedures. Recommend allowing licensees 2 years to implement or the next refueling outage, whichever is longer.
§50.55a(f)(4)
Proposed Changes to Regulations (Draft Rule): (4) Inservice testing standards requirement for operating plants. Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) and (3) of this section and that are incorporated by 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.
Comment: Removal of reference to ASME Code Class 1, Class 2, and Class 3 is a major change and will have significant impact to licensees and NRC. The current industry practice is to limit the IST Program scope to the Class 1, 2 and 3 pumps and valves that fit the scope of OM Code, ISTA-1100. Non-Code Class pumps and valves that perform a safety function (e.g., fit the scope of OM Code ISTA-1100) are typically included in an Augmented IST Program and tested commensurate with their function. Furthermore, removing reference to ASME Class 1, Class 2, and Class 3 would include components that are not designed to mitigate the consequences of an accident as described in the design basis accident section. Modifications may also be necessary to update to these proposed requirements.
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 This condition would require relocation of non-Code Class components to the IST Program. As a result, a significant number of plant procedures would have to be revised and any ASME OM Code requirements that cant be implemented as required would require new relief requests to be submitted to the NRC for approval. Generally, Augmented IST Programs are designed to meet the OM Code where practicable, but relief requests are not required when alternate testing is required.
Recommend leaving the restriction to Code Class 1, Class 2, and Class 3 applicable to existing plants. Then remove the restriction to Code Class pumps and valves for new reactors only.
PR 10 CFR Part 50 80 FR 56819 23 From: Johnson, Pamela J.
To: RulemakingComments Resource Cc: Johnson, Pamela J.
Subject:
[External_Sender] COMMENTS on Docket ID NRC 2011-0088 Date: Friday, December 18, 2015 4:53:29 PM Attachments: Xcel Rulemaking Comments 12-18-15.pdf Importance: High
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 Enclosure
§50.55a(b)(3)(iv)
Proposed Changes to Regulations (Draft Rule): (iv) OM condition: Check valves (Appendix II). Appendix II, Check Valve Condition Monitoring Program, of the OM Code, 2003 Addenda through the 2012 Edition, is acceptable for use without conditions with the clarifications that (1) the maximum test interval allowed by Appendix II for individual check valves in a group of two valves or more must be supported by periodic testing of a sample of check valves in the group during the allowed interval and (2) the periodic testing plan must be designed to test each valve of a group at approximate equal intervals not to exceed the maximum requirement interval. Licensees applying Appendix II of the OM Code, 1995 Edition with the 1996 and 1997 Addenda, shall satisfy the requirements of paragraphs (b)(3)(iv)(A) through (C) of this section.
Licensees applying Appendix II, 1998 Edition through the 2012 Edition, shall satisfy the requirements of paragraphs (b)(3)(iv)(A), (B), and (D) of this section.
Comment: The condition additions of clarifications (1) and (2) should be removed from rulemaking.
This condition should only be applicable to 1998 Edition through 2003 Addenda. This condition should not be applicable to the 2004 Edition through 2012 Edition because the requirements of (b)(3)(iv)(A), (B), and (D) have already been incorporated into these versions of the code.
§50.55a(b)(3)(xi)
Proposed Changes to Regulations (Draft Rule): (xi) OM condition: Valve Position Indication. When implementing ASME OM Code, Subsection ISTC-3700, Position Verification Testing, licensees shall develop and implement a method to 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.
Comment: The major burden here is the shall statement regarding the implementation of supplemental methods to verify obturator position and movement.
The ASME Subsection ISTC, is working to change the code to alleviate the regulatory concern associated with the determination of obturator position or movement using ONLY stem position.
The background information for the proposed rule indicates that this is only a clarification of the intent of the existing ASME OM Code. This statement is misleading
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 and incorrect. The existing code does not require supplemental indications to be performed with all position indication testing. This was confirmed through ASME OM Code Interpretation 12-01, which is consistent with how the industry approaches this testing. This NRC clarification of the code would result in a very significant new requirement for licensees. Finally, based on the NRCs Backfit Rule, this clarification appears to be a new or different regulatory position that would require a backfit analysis.
To impose this condition on every IST component with a position indication test would be overly burdensome to the licensees with little to no benefit in return.
This condition, as written, should be removed from the rulemaking. If this condition remains in the rulemaking, it should add a where practicable clause in order to reduce the potential large volume of requests for relief. In addition, the condition should provide an implementation period to allow licensees adequate time to develop the necessary test procedures. Recommend allowing licensees 2 years to implement or the next refueling outage, whichever is longer.
§50.55a(f)(4)
Proposed Changes to Regulations (Draft Rule): (4) Inservice testing standards requirement for operating plants. Throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) and (3) of this section and that are incorporated by 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.
Comment: Removal of reference to ASME Code Class 1, Class 2, and Class 3 is a major change and will have significant impact to licensees and NRC. The current industry practice is to limit the IST Program scope to the Class 1, 2 and 3 pumps and valves that fit the scope of OM Code, ISTA-1100. Non-Code Class pumps and valves that perform a safety function (e.g., fit the scope of OM Code ISTA-1100) are typically included in an Augmented IST Program and tested commensurate with their function. Furthermore, removing reference to ASME Class 1, Class 2, and Class 3 would include components that are not designed to mitigate the consequences of an accident as described in the design basis accident section. Modifications may also be necessary to update to these proposed requirements.
Comments on the Proposed Rules Federal Register Vol. 80, No. 181 Dated September 18, 2015 This condition would require relocation of non-Code Class components to the IST Program. As a result, a significant number of plant procedures would have to be revised and any ASME OM Code requirements that cant be implemented as required would require new relief requests to be submitted to the NRC for approval. Generally, Augmented IST Programs are designed to meet the OM Code where practicable, but relief requests are not required when alternate testing is required.
Recommend leaving the restriction to Code Class 1, Class 2, and Class 3 applicable to existing plants. Then remove the restriction to Code Class pumps and valves for new reactors only.