RIS 2003-01, Examination of Dissimilar Metal Welds, Supplement 10 to Appendix Viii of Section XI of the ASME Code
| ML030210002 | |
| Person / Time | |
|---|---|
| Issue date: | 01/21/2003 |
| From: | Beckner W NRC/NRR/DRIP/RORP |
| To: | |
| Naujock D, DLPM/LPDIV 415-2767 | |
| References | |
| TAC M6813 RIS-03-001 | |
| Download: ML030210002 (6) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, DC 20555-0001 January 21, 2003 NRC REGULATORY ISSUE SUMMARY 2003-01 EXAMINATION OF DISSIMILAR METAL WELDS,
SUPPLEMENT 10 TO APPENDIX VIII OF
SECTION XI OF THE ASME CODE
ADDRESSEES
All holders of operating licenses for nuclear power reactors.
INTENT
The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)
to inform addressees of the NRC staffs position on the implementation of Supplement 10 to Appendix VIII, Performance Demonstration for Ultrasonic Examination Systems, of Section XI
of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME
Code), as required by Title 10, Section 50.55a(g)(6)(ii)(C), of the Code of Federal Regulations
[10 CFR 50.55a(g)(6)(ii)(C)]. Supplement 10 contains the qualification requirements for procedures, equipment, and personnel involved with examining dissimilar metal welds using ultrasonic techniques, which licensees were required to implement by November 22, 2002.
This RIS requires no written response on the part of an addressee.
BACKGROUND INFORMATION
In a final rulemaking on September 22, 1999 (64 FR 51370), the NRC imposed a requirement for expedited implementation of Appendix VIII to Section XI of the ASME Code. That appendix contains several supplements, which licensees were to implement on a phased basis over a
3-year period, with Supplement 10 scheduled to be implemented by November 22, 2002. The NRC concluded that the expedited implementation of Appendix VIII was "... necessary to bring the facilities described into compliance with [General Design Criterion] GDC 14, 10 CFR Part 50, Appendix A, or similar provisions in the licensing basis for these facilities, and Criterion II, Quality Assurance Program, and Criterion XVI, Corrective Actions, of Appendix B to
10 CFR Part 50 (64 FR 51394).
Prior to November 22, 2002, the requirements for conducting dissimilar metal weld qualifications and examinations using ultrasonic techniques were stipulated in Appendix III to Section XI of the ASME Code. Since that date, however, these requirements are stipulated in Appendix VIII to Section XI of the ASME Code. A significant difference between these appendices is that Appendix III consists of prescriptive-based criteria, while Appendix VIII
consists of performance-based criteria. This is important because the performance-based criteria substantially improve the ability of an examiner to detect and characterize flaws during ultrasonic examination of components and, thereby, provide for more reliable examination results.
On August 23, 2002, the Nuclear Energy Institute (NEI) informally made the NRC staff aware of the possibility that the industry might not be able to meet the implementation date for Supplement 10. On October 31, 2002, representatives of NEI met with the NRC staff and confirmed that the industry would not be able to meet the implementation date. In fact, the NEI
representatives indicated that licensees had not yet qualified any procedures or personnel to meet the requirements of Supplement 10. The NEI further projected that the earliest any qualification could be completed was the end of November or December 2002. The NEI further stated that related uncertainties made it impossible to project with any degree of confidence when all facilities could comply with Supplement 10. The NEI suggested several alternatives for changing the implementation date, including the issuance of generic exemptions, direct final rulemaking, or the use of enforcement discretion.
SUMMARY OF ISSUE
The NRC staff has concluded that, as of November 22, 2002, facilities that do not have a program that implements Supplement 10 to Appendix VIII of Section XI of the ASME Code are noncompliant with 10 CFR 50.55a(g)(6)(ii)(C), irrespective of when the actual examination of dissimilar metal welds must be conducted. A program that implements Supplement 10 is considered to be one that has in place qualified procedures, equipment, and personnelnot one that merely references or stipulates the use of qualified procedures, equipment, and personnel.
The significance of this noncompliance (i.e., the failure to have a program in place by November 22, 2002, that implements Supplement 10) is such that enforcement action is not warranted. However, the failure to implement Supplement 10 when such examinations must be performed, either in the course of normal inservice inspection program requirements or to fulfill unanticipated examination needs, is considered safety significant and is a performance deficiency under the Reactor Oversight Process. System operability may be affected until the regulatory noncompliance has been remedied and all regulatory requirements are met, or appropriate regulatory relief is granted. Evaluation guidance on operability issues is provided in Generic Letter 91-18, Information To Licensees Regarding Two NRC Inspection Manual Sections On Resolution of Degraded and Nonconforming Conditions and On Operability.
However, the resolution of an operability issue does not negate the non-compliance with
BACKFIT DISCUSSION
This RIS imposes no new requirements and requires no action or written response. Therefore, this RIS does not constitute a backfit under 10 CFR 50.109, and the staff did not perform a backfit analysis.
FEDERAL REGISTER NOTIFICATION
A notice of opportunity for public comment was not published in the Federal Register because this RIS is informational.
PAPERWORK REDUCTION ACT STATEMENT
This RIS does not request any information collection, and, therefore, is not subject to the Paperwork Reduction Act.
If you have any questions about this RIS, please contact the person listed below or the appropriate project manager in the NRCs Office of Nuclear Reactor Regulation.
/RA/
William D. Beckner, Program Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Technical contact: Donald Naujock, NRR
301-415-2767 E-mail: dgn@nrc.gov Attachment: List of Recently Issued NRC Regulatory Issue Summaries
DOCUMENT NAME: C:\ORPCheckout\FileNET\ML030210002.wpd
- See previous concurrence OFFICE STA:OERORP:DRIP Tech Editor EMCB:DE OE SC:EMCB:DE C:EMCB:DE
NAME JWShapaker PAGarrity * DGNaujock
- FCongel * TLChan * WHBateman *
DATE 01/16/02 12/26/02 12/23/02 01/09/03 12/23/02 12/23/02 OFFICE D:DE D:DIPM OGC SC:OES:RORP:DRIP PD:RORP:DRIP
NAME RJBarrett * BABoger * RHoefling TReis WDBeckner DATE 12/23/02 01/ 06/03 01/16/03 01/16/03 01/23/03
Attachment LIST OF RECENTLY ISSUED
NRC REGULATORY ISSUE SUMMARIES
_____________________________________________________________________________________
Regulatory Issue Date of Summary No. Subject Issuance Issued to
_____________________________________________________________________________________
2002-23 Availability of Guide for Diagnostic 11/27/2002 All medical licensees.
Nuclear Medicine
2002-22 Use of EPRI/NEI Joint Task Force 11/25/2002 All holders of operating licenses Report, Guideline on Licensing for nuclear power reactors, except Digital Upgrades: EPRI those who have permanently TR-102348, Revision 1, NEI 01-01: ceased operations and have a Revision of EPRI TR-102348 to certified that fuel has been Reflect Changes to the 10 Cfr permanently removed from the
50.59 Rule reactor vessel.
2002-21 National Guard and Other 11/08/2002 All holders of operating licenses Emergency Responders Located for nuclear power reactors, in the Licensees Controlled Area including those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel.
2002-20 Clarification of Requirements 11/07/2002 All medical licensees.
Under 10 CFR 35.432, Calibration Measurements of Brachytherapy Sources
2002-19 New Modalities to be Regulated 10/21/2002 All medical licensees authorized to Under 10 CFR 35.1000 use byproduct material for therapeutic administration.
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To subscribe send an e-mail to <listproc@nrc.gov >, no subject, and the following command in the message portion:
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______________________________________________________________________________________
OL = Operating License CP = Construction Permit