ML20209A106

Response to ASME-EPRI Letters on Pressure Testing Mechanical Joints

ML20209A106
Person / Time
Issue date:	07/27/2020
From:	Louise Lund Office of Nuclear Regulatory Research
To:	Frederick G, Patten D, Vogan T ASME Board on Nuclear Codes and Standards, Electric Power Research Institute, Energy Harbor Nuclear Corp
R. Roche-Rivera
References
Download: ML20209A106 (3)

Text

July 27, 2020 Thomas Vogan, Chair ASME Board on Nuclear Codes and Standards Gregory Frederick, Program Manager EPRI Welding and Repair Technology Center Dan Patten, Manager Fleet Programs Engineering Energy Harbor Nuclear

SUBJECT:

PRESSURE TESTING CONDITION IN 10 CFR 50.55A(B)(2)(XXVI)

(85 FR 26540)

References:

1. ASME letter dated May 29, 2020, Final Rule Regarding 10 CFR 50.55a(b)(2)(xxvi), 10 CFR Part 50, RIN 3150-AJ74 (ML20198M552)

2. EPRI letter dated May 28, 2020, Final Rule Regarding 10 CFR 50.55a(b)(2)(xxvi), 10 CFR Part 50, RIN 3150-AJ74 (ML20204A964)

Dear Mr. Vogan,

Mr. Frederick, and Mr. Patten:

The purpose of this letter is to respond to the referenced American Society of Mechanical Engineers (ASME) and Electric Power Research Institute (EPRI) letters, related to the pressure testing condition in 10 CFR 50.55a(b)(2)(xxvi), as updated, in the final rule incorporating by reference the ASME, 2015-2017 Code Editions (85 FR 26540). In your letters, you requested clarification on whether the pressure testing condition addressed in 10 CFR 50.55a(b)(2)(xxvi),

as updated, would prohibit the use of the pressure testing exemptions in IWA-4540(b) and whether the updated condition requires pressure testing of mechanical joints when only bolting is replaced.

The updates to 10 CFR 50.55a(b)(2)(xxvi) and the issues discussed in your letters were discussed during public meetings with representatives from the nuclear industry that were held on June 4, 2020 and June 25, 2020. The meeting summaries can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession Nos. ML20163A609 and ML20189A286, respectively. In summary, the NRC staff presented the history of the 10 CFR 50.55a(b)(2)(xxvi) condition evolution and the NRC staffs intent for both the original and revised condition; clarified and confirmed that the pressure testing exemptions in IWA-4540(b),

including bolts as addressed by IWA-4540(b)(10) in the 2017 Edition of the ASME Code, continue to apply under the updated 10 CFR 50.55a(b)(2)(xxvi); and reiterated that licensees/applicants shall continue to meet the requirements of their current ISI Code of record.

For additional details, please refer to the meeting summaries.

Thank you for your inquiry. The NRC appreciates the open dialogue and welcomes future correspondence as the NRC continues to support the development, revision, and use of ASME Codes and Standards and its incorporation by reference in 10 CFR 50.55a. If you have questions or concerns, please contact me at Louise.Lund@nrc.gov or 301-415-0377, or David Rudland at David.Rudland@nrc.gov or 301-415-1896.

Sincerely,

/RA/

Louise Lund, NRC Standards Executive Office of Nuclear Regulatory Research cc:

Thomas Vogan (tomvogan45@gmail.com)

Allyson Byk (Byka@asme.org)

Gregory Frederick (gfrederi@epri.com)

Dan Patten (dpatten@firstenergycorp.com)

SUBJECT:

PRESSURE TESTING CONDITION IN 10 CFR 50.55A(B)(2)(XXVI) (85 FR 26540) DATED JULY 27, 2020 DISTRIBUTION:

L. Lund, RES A. Bradford, NRR M. Rahimi, RES D. Rudland, NRR M. Benson, RES R. Roche-Rivera, RES R. Iyengar, RES ADAMS Package Accession No.: ML20198M551, ML20209A106 (Letter) *via-email OFFICE RES/DE/RGGIB NRR/DNRL/NVIB NRR/DNRL RES/DE/RGGIB NAME *R. Roche-Rivera *M. Benson *D. Rudland *M. Rahimi DATE 07/22/2020 07/23/2020 07/23/2020 07/24/2020 OFFICE NRR/DNRL RES/DE NAME *A. Bradford *L. Lund DATE: 07/24/2020 07/27/2020 OFFICIAL RECORD COPY