ML20209H669

Comment Supporting Proposed Rule 10CFR50 Re Elimination of Requirement for Licensees to Update Inservice Insp & Inservice Testing Programs Beyond Baseline Adition & Addenda of ASME BPV Code

ML20209H669
Person / Time
Site:	Susquehanna
Issue date:	07/12/1999
From:	Byram R PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR22580, RULE-PR-50 64FR22580-00029, 64FR22580-29, NUDOCS 9907210038
Download: ML20209H669 (2)

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DOCKET NUMBER 49 PROPOSED RULE EO 60 -

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Robert G. Byrarn PP&L, Inc. M _.., ""*-

Senior Vice President Generation and Chief Nuclear Omcer Two North Ninth Street Allentown. PA 18101-1179 V-l **..

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Tel 610.774.7502 Fax 610.774.5019 E-mait rgbyram@paptcom Tel 610.774 5151 q $* L*

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JUL 121999 m .

1.J Ua The Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 A'ITN: Rulemakings and Adjudications Staff SUSQUEIIANNA STEAM ELECTRIC STATION COMMENTS ON TIIE SUPPLEMENTAL PROPOSED RULE TO REVISE 10CFR50.55a Docket Nos. 50-387/NPF-14 PLA-5078 and 50-388/NPF-22 PP&L, Inc. supports the concept of the supplemental proposed rule to eliminate the requirement for licensees to update their Inservice Inspection (ISI) and Inservice Testing (IST) programs beyond the baseline edition and addenda of the ASME BPV Code provided the following clarifications / comments are incorporated in the final rule.

1. The proposed rule change that was issued in December 1997 proposed the endorsement of the ASME Section III and XI 1995 Edition with the 1996 Addenda. A significant amount of work regarding the acceptability of this Edition and Addenda has already been performed by the NRC. Therefore, we propose that this Edition and Addenda be included in the final rule for voluntary use.

2. Since the NRC is in the process of approving the use of the 1998 Edition of ASME Section XI for two utilities, we would propose that the 1998 Edition of ASME Section XI also be included in the final rule for voluntary use.

3. The baseline edition of ASME Section XI for Subsections IWE and IWL is the 1992 edition f with the 1992 addenda. Since 10CFR50.55a was revised mandating this edition and C addenda, the industry has recognized that many portions of this rule are impractical to implement. Substantial work has been completed on these Subsections since 10CFR50.55a was revised. The baseline edition for Subsections IWE and IWL should be the 1998 edition.

If this cannot be accomplished, the final rule should include the standardized relief requests developed by NEI and EPRI.

9907210038 990712 PDR PR 50 64FR22500 PDR Jh

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, The Secretary of the Commission

4. The requirement to implement entire future editions of Section XI already incorporated by reference in the Regulations, or get prior NRC approval to implement a portion of a future code is new. It is not clear how, or why, this requirement applies to repairs. The final rule should clearly state how this requirement applies to repairs. Also, the proposed rule directly conflicts with the provisions ofIWA-4120. This conflict should be eliminated in the fmal rule.

5. It is also unclear if the requirement on implementing future referenced editions would apply to replacements considering IWA-7210 (c). Again, this rule could be read to conflict with the provision to use later portions of the Construction Code or Section III.

If you have any questions, please contact Mr. C. T. Coddington at (610) 774-4019.

Sincerely, i _

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l copy: NRC Region I Mr. S. Hansell, NRC Acting Sr. Resident Inspector Mr. V. Nerses, NRC Sr. Project Manager 1

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