View source for L-98-067, Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds

{{Adams
| number = ML20216B654
| issue date = 04/03/1998
| title = Comment Opposing Proposed Rule 10CFR50 Re Industry Codes & Stds
| author name = Jain S
| author affiliation = DUQUESNE LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000334, 05000412
| license number = 
| contact person = 
| case reference number = FRN-62FR63892, RULE-PR-50
| document report number = 62FR63892-00060, 62FR63892-60, L-98-067, L-98-67, NUDOCS 9804140032
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 3
}}

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OFFK. 7 FPJ GO           April 3,1998 L-98-067 Secretary, U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff

==Subject:==
Beaver Valley Power Station, Unit No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Comments on NRC Proposed Changes to 10 CFR 50.55a, Industry Codes andStandards (62 Fed. Reg. 63892 dated December 3,1997 and 63 Fed. Reg. 3673, dated January 26,1998 Enclosed are the Duquesne Light Company (DLC) Beaver Valley Power Station comments on the proposed rule changes to 10 CFR 50.55a, Industry Codes and Standards. The proposed rule changes, published in the Federal Register as referenced above, contain some requirements that may affect the ability of utilities to comply with the changes. Our formal comments include an endorsement and concurrence with the nuclear industry comments listed below:
e      Nuclear Energy Institute (NEl) comments dated April 3,1998 e      Performance Demonstration Initiative (PDI) comments, dated March 30,1998
              . Electric Power Research Instit.ste (EPRI) comments, dated March 30,1998 These submittals, prepared with input from a large cross-section of highly qualified individuals, clearly state the practical implementation difficulties of the proposed                                                                                         I rulemaking.                                                                                                                                                               l D
D E llH RIN G 0UAL11Y 9804140032 980403                                    "
ENERGYg PDR PR 50 62FR63892               PDR 95IO

1 Beaver Valley Power Station, Unit No. I and No. 2 Comments on NRC Proposed Changes to 50 CFR 50.55a Page 2 We are also panicularly concemed with the proposed rule technical changes to the      j Code. The proposed rule would impose a limitation on use of engineering judgment for        j inservice inspection (ISI) activities not specifically considered by the Code. This requirement could be interpreted to require prior NRC approval of everyday licensees' activities. This limitation would create a significant resource burden on licensees and the NRC staff.       The number of licensee requests for NRC approval of proposed alternatives in accordance with the new (50.55a(a)(3) could be staggering and reduce licensees willingness to utilize formal engineering judgment as defined by the proposed rule because of the need to obtain prior NRC approval. Engineering judgment has been an integral component of the ASME Code since its initial endorsement by the NRC.
Operating plant staffs exercise engineeringjudgment on a daily basis. The all-inclusive formalized requirement is impractical and burdensome and lacks a well-defined set of criteria. The requirement is likely to be misapplied by licensees and may subject li;ensees to inconsistent NRC staff interpretations. We strongly recommend this limitadon be removed in its entirety from the proposed rule. Instead, the NRC staff should identify those specific safety issues not directly addressed by the ASME Code and work within the consensus process to develop appropriate Code requirements.
With respect to the ultrasonic (UT) examination aspects of the proposed rulemaking, Beaver Valley Power Station has always realized the importance of using qualified examination procedures, equipment and personnel. We have funded, supported and actively participated in steering Performance Demonstration Initiative (PDI) since its formation. Our Ultrasonic Examination personnel have all been qualified through the PDI qualification process, and we have implemented PDI techniques for UT examination of both austenitic and ferritic piping welds and all bolting (>2 inch diameter). Only PDI qualified vendor NDE personnel are permitted to perform UT examinations on these components. This voluntary implementation was done to increase the quality and confidence level of these critical examinations.
In addition, the rule package proposes to modify Paragraph 50.55a(f)(1) to clarify the meaning of safety related. The new definition is: " Pumps and valves in steam, water, air and liquid radioactive-waste systems that perform a function to shut down the   !
reactor or maintain the reactor in a safe shutdown condition, mitigate the consequences of an accident, or provide overpressure protection for such systems." This definition would add air systems to the scope of our Inservice Inspection and Testing (IST)          {
Program We note that this is outside the scope of Regulatory Guide 1.26, and the ASME Code, and the scope of " systems typically included in IST" per NUREG-1482, Table 2.1. Our IST Programs do not typically include air systems except for               i containment isolation valves, the emergency diesel generator air stut system, and the     l control room supply and exhaust dampers. The definition of " air" systems is not clear,   J and should be clarified, or the word " air" should be excluded from the definition.
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  .      - Beaver Valley Pswer Station, Unit No. I and No. 2 Comments on NRC Proposed Changes to 50 CFR 50.55a Page 3                                                                                   )
We suggest that the NRC, the ASME Code and the Nuclear Industry (through PDI) reconsider the issues raised and work together in a spirit of cooperation to resolve the differences through the Code consensus process. This balanced approach is needed to ensure that proposed solutions to current NRC concems and areas of disagreement are      )
effective, technically sound and implemented in a timely manner.
Thank you for the opportunity to comment on this issue. If you have any questions on this submittal, please contact Mr. J. Arias, Director, Safety and Licensing Department, (412) 393-5203.
Sincerely, g- o -_W Sushil C. Jain c:    Mr. D. S. Brinkman, Sr. Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator Mr. K. Cozens, NEI                                                                 ;
Dr. Brian W. Sheron, NRC/NRR                                                       l Dr. Jack Strosnider, NRC/NRR Mr. Frank C. Cherny, NRC/RES Mr. Wallace E. Norris, NRC/RES Mr. Stewart Magruder, NRC/NRR NRC Public Document Room, Project 689 l
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