ML071630054

Comment (5) Submitted by George L. Fechter on Proposed Rules PR-50 Regarding Industry Codes and Standards; Amended Requirements

ML071630054
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	06/11/2007
From:	Fechter G Southern Nuclear Operating Co
To:	NRC/SECY
SECY RAS
References
72FR16731 00005, PR-50, RIN 3150-AH76
Download: ML071630054 (3)

Text

PR 50 DOCKETED 06/12/07 (72FR16731)

Comment No. 5 From: "Fechter, George L." <glfechte@southernco.com>

To: <SECY@nrc.gov>

Date: Mon, Jun 11, 2007 4:15 PM

Subject:

RIN 3150-AH76 Enclosed are two comments on the current revision of 10CFR50.55a which is out for public review thru 6/19/2007:

Comment (1): 10CFR50.55a(b)(2)(xx): System Leakage Tests Proposed Rulemaking:

Revision to this paragraph is being proposed which would require that after system leakage tests are performed during repair/replacement activities by welding or brazing per the 2003 Addenda through 2004 Edition of Section XI, NDE must be performed in accordance with IWA-4540 of the 2002 Addenda of Section XI.

Response

Regardless of the edition or addenda of Section XI by which repair/replacement activities are performed, NDE following welding or brazing would be performed immediately following the welding or brazing activity and prior to the system leakage test rather than following the system leakage test.

In accordance with IWA-4520 of the 2003 Addenda through 2004 Edition of Section XI, NDE following welding or brazing is required to be performed per the Construction Code noted within the repair/replacement plan in order to assure structural integrity of the respective system boundary and consequently public safety. Additional NDE requirements previously incurred in order to justify not performing a hydrostatic pressure test were alleviated when it was seen that such imposition did not provide increased verification of structural integrity. Likewise, due to the performance of a system leakage test and hydrostatic test providing the equivalent verification of leak tightness, the performance of the elevated pressure hydrostatic test was alleviated. Therefore, to reinstate the requirement to perform NDE per the 1992 Edition of Section III or later edition of Section III when the Construction Code was not Section III is not commensurate with the increased burden and resource restraints (manpower, dose, outage scheduling) such NDE will cause and provides no increased reassurance of structural integrity.

Since some plants have already updated to the 2003 Addenda of Section XI, to impose NDE per the 1992 Edition of Section III or later edition of Section III for those plants would constitute a backfit based upon adding a new requirement which does not presently exist per the 2003 Addenda. The endorsement of IWA-4520(a) and IWA-4540(a) of the 2003 Addenda without any similar limitation provides further justification with which to consider this NDE imposition as a backfit.

Comment (2): 10CFR50.55a(b)(3)(v): Subsection ISTD Current Rule:

The existing requirement is to perform a VT-3 visual examination as described in IWA-2213 for preservice or inservice snubber examinations whether using this permitted rule alternative or IWF-5000 of the 2003 Addenda through the 2004 Edition of Section XI.

Response

As IWF-5000 was deleted from the 2006 Addenda of Section XI, and with adequate verification of the training provided to personnel performing visual exams, removal, testing, and reinstallation of snubbers per applicable ISTD and site licensing and maintenance criteria, it should be justifiable to allow performance of this type of visual exam versus a VT-3 examination since the knowledge obtained from such snubber specific training and experience commonly exceeds the VT-3 criteria for snubbers. While IWA-2317 of the 2003 Addenda through 2004 Edition provide alternative VT-3 qualification requirements, the administrative burden incurred for the VT-3 certification may not be commensurate with any convenience provided by qualifying additional VT-3 personnel in this manner and, for reasons stated above, does not provide a higher quality exam. It is requested that the permissive for allowing personnel trained specifically on snubber requirements per applicable ISTD and site licensing and maintenance criteria be allowed to perform visual exams for snubbers as an alternative to performing a VT-3 exam per the method described in IWA-2213.

Sincerely, George Fechter, Senior Engineer Plant Hatch Southern Nuclear Operating Company (912) 366-2000, ext. 3632 Phone (912) 366-2008 Fax glfechte@southernco.com CC: "Graham, D. Rick" DORGRAHA@southernco.com Mail Envelope Properties (466DAD4D.37E : 0 : 21374)

Subject:

RIN 3150-AH76 Creation Date Mon, Jun 11, 2007 4:14 PM From: "Fechter, George L." <glfechte@southernco.com>

Created By: glfechte@southernco.com Recipients nrc.gov TWGWPO02.HQGWDO01 SECY (SECY)

southernco.com DORGRAHA CC (D. Rick Graham)

Post Office Route TWGWPO02.HQGWDO01 nrc.gov southernco.com Files Size Date & Time MESSAGE 4068 Monday, June 11, 2007 4:14 PM Mime.822 5577 Options Expiration Date: None Priority: Standard ReplyRequested: No Return Notification: None Concealed

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