ML20217N720

Comment on Proposed Rule 10CFR50 Re Proposed Changes to 10CFR50.55a,inservice Inspection & Inservice Testing of Nuclear Power Plant Components

ML20217N720
Person / Time
Site:	Palisades
Issue date:	03/31/1998
From:	Jennifer Ford CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-62FR63892, RULE-PR-50 62FR63892-00043, 62FR63892-43, GL-90-09, GL-90-9, NUDOCS 9804090178
Download: ML20217N720 (5)

Text

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Secretary, U.S. Nuclear Regulatory Commission ATTN: Rulemaking and Adjudicstions Staff Washington, DC 20555-0001 l

1 COMMENTS - PROPOSED AMENDMENT TO 10CFR50.55a CONCERNING l INSERVICE INSPECTION AND INSERVICE TESTING OF NUCLEAR POWER PLANT COMPONENTS A notice of a proposed amendment to 10CFR50.55a was published for public comment in he December 3,1997, Federal Register (62FR63892).

Consumers Energy has completed a review of the proposed amendment and is hereby forwarding our questions and comments for consideration.

J dy K. Ford Manager, Engineering Programs Attachment 9004090178 980331 I PDR PR 50 62FR63892 PDR ( g 3G(O

ATTACHMENT CONSUMERS ENERGY COMPANY PALISADES PLANT l

Comments on the Proposed Amendment

to 10CFR50.55a .

(62 FR 63892) l l

I 3 pages t

r O

ATTACHMENT Federal Register Mns 2.5.3 and 2.5.3.2 (ca. 63902) and 10CFR50.55aff)(1) (ca.

63909):

1) Regarding the adoption of the ISTC attemative for check valve condition monitoring:

Can the condition monitoring approach be adopted for check valves without updating the rest of the IST program to the latest edition of the l

ASME code?

Could the implementation of the condition monitoring approach be adopted for some groups of check valves without necessarily doing all of the check valves currently in the scope of the IST Program?

Can implementation of condition monitoring be done on one group of l valves at a time or must all groups of valves be done at the same time  !

(prior to implementing monitoring changes)? l F+hal Realeter Mn 2.3.2.3 (na 63897)and 10CFR50.55aff)(1) (naos 83909):

Does Federal Register Section 2.3.2.3 (pg 63897)and 10CFR50.55a(f)(1) (page 63909) mean the testing requirements of the ASME Code will apply for all non-code plant equipment that performs a safety function?

Does Federal Register Section 2.3.2.3 (pg 63897) and 10CFR50.55a(f)(1) (pg i

i 63909) include systems like instrument air, back-up nitrogen, or high pressure air supplies to certain safety-related air operated valves?

We are not aware of any industry trends of increased failures for safety related non-ASME components that would justify the increased testing burden. Was a .

specific study of failure data performed that supports the conclusion that more testing is needed?

F+hm! RW" Sa* is 2.3.2.2 (ca. 8380A) and 2.5.3.3 (ca. 83903) and 10CFR50.55a(b)(3)(v) (ca. 63909):

It was recently brought to our attention that snubber ISI was indeed part of previous rulemaking and invokes the requirements of the 1989 edition ASME Section XI. This edition of Section XI (lWF-5000) directly references the requirements of ASME OMa-1988 Part 4. Plants have been routinely getting relief requests approved to use the guidance of GL 90-09 in lieu of this OM code inservice inspection interval requirement. As a supporting argument, if snubber page 1 of 3

f L.

ISI was not covered by the ASME code, then there would have been no need for l

any code relief requests, l

o As discussed in the cunent Federal Register, the previously mentioned rulemaking did not address snubber inservice testing requirements and did not invoke any specific code in 50.55a. Instead, plant technical specification j

requirements were still being used for snubber IST. All of this resulted in snubber ISI falling into ASME Code space and snubber IST falling into technical specification space (no code).

The Federal Register (62FR63892) addresses the inservice testing requirements and approves OMa-1996 Subsection ISTD as an acceptable altemative to snubber IST requirements contained in technical sneenistions. Therefore, as l-the Federal Register (62FR63892) further indicates, this is not an approved attemative to any code requirement since snubber IST was not, and still is not addressed in 10CFR50.55a(f). l l

j It is our opinion that the intent of the proposed amendment, Federal Register l

(62FR63892), is to approve snubber IST and ISI requirements (as an option) in accordance with OMa-1996, Subsection ISTD. However the proposed rule does l not read that way, the proposed rulemaking specifically addresses only snubber 3 IST (repeatedly) and not snubber ISI requirements. The proposed rule implies that snubber IST can follow OMa-1996 (ISTD), while snubber ISI is still governed l l

by OMa-1988 under 10 CFR 50.55a(g). The amendment needs to specify that snubber ISI requirements per OMa-1996 are an acceptable attemative to the !ST l requirements in technical specifications and an acceptable attemative to tha ISI  ;

l requirements of OMa-1988, Part 4. If this is not addressed, facilities wi!i need to continue to seek relief to use the ISI interval provisions of OMa-1996. This would be an unnecessary waste of resources. Additionally, if this is not cleared up and a fecility misinterprets the rulemaking, assuming that it applies to both IST and ISI, i5at facility may inadvertently implement the attemative ISI l requirements of OMa-1996 without receiving prior NRC approval. This would I technically be a violation.

Since the provisions of GL 90-09 are contained in OMa-1996 and have been incorporated into most (if not all) plant technical specifications, why can not the amendment simply state that OMa-1996, Subsection ISTD, is an acceptable attemative to the ISI requirements of OMa-1988, Part 4?

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page 2 of 3 l

9 Federal Reaister Sections 2.3.2.1 (og. 63896). 2.3.2.3 (og. 63896) and 10CFR50.55aff)(1) (og. 63909)

The OM Code requires IST for all safety related valves. The proposed rule will increase the scope of IST dramatically by including many valves which were not designed and installed in a manner allowing the performance of classical IST procedures. The !!mitation proposed by the NRC will do nothing to alleviate this scope increase. In effect, the NRC is requiring a mid-interval IST update without providing any cost / benefit / safety analysis or considering backfit. This amendment would necessitate the submittal and approval of relief requests for those components which cannot be tested in conformance with the OM rules.

The fact that 10CFR50.55a(f)(4) does not require periodic update for all safety related pumps and valves is curious. Only, those which are class 1,2 and 3 are required to be updated to newer years and editions of the applicable codes.

Federal Register Section 2.6 (ca. 63903)

The NRC is correct in stating that ASME is the only authorized interpreter of the Code. However, if the NRC allows itself to accept certain interpretations with which the NRC agrees, while rejecting interpretations with which the NRC disagrees, the NRC has, in effect, become a second unauthorized interpreter.

The NRC should make use of the interpretation process when performing rulemaking and in instances where the NRC disagrees with an interpretation provided to a licensee. This is the only way to protect the authority of the ASME and the licensee / regulator relationship.

General Recommend that a series of public meetings should be held to address industry concerns with the proposed rulemaking.

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