View source for 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 Piping

{{Adams
| number = ML20198S694
| issue date = 01/09/1998
| title = 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
| author name = Huting M
| author affiliation = IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION (ADM)
| docket = 05000331
| license number = 
| contact person = 
| case reference number = FRN-62FR53663, RTR-NUREG-0800, RTR-NUREG-800, RTR-REGGD-XX.XXX, TASK-*****, TASK-RE
| document report number = 62FR53663-00011, 62FR53663-11, NG-98-0065, NG-98-65, NUDOCS 9801260259
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 5
}}

=Text=
{{#Wiki_filter:ff         g)         Duane Amold Energy Canty 3277 DAEC Road                      j ll     g
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                                                           ,l UTILITIES-NUCLEAR GENERATION DIVISION NG-98-0065                                                                 ES IN     E ?
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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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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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        ,                                                                                              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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