ML20205C255

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Forwards Prioritization Evaluation of Generic Issue 119, Piping Review Committee Recommendations & Gimcs Info Sheet Indicating Info Needed to Monitor Resolution of Issue
ML20205C255
Person / Time
Issue date: 09/10/1985
From: Harold Denton
Office of Nuclear Reactor Regulation
To: Minogue R
NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
Shared Package
ML20205C260 List:
References
FOIA-88-464, REF-GTECI-119, REF-GTECI-NI, TASK-119, TASK-OR NUDOCS 8509200213
Download: ML20205C255 (18)


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M MEMORANDUM FOR: Robert fl. Plinogue, Director P Of fice of Nuclear Regulatory Research t ',

9 FF0F: Harold R. Denton, Director

j Of fice of Nuclear Peactor Regulation W

y St'P. LECT : SCHEDULE FOR RESOLVING AND COMPLETING GEbfRIC 7,p 1 ISSUE NO.119 - P! PING PTVIEW C0mlTTif 7 RECOMMENDATIONS y,

di The resolution for Generic issue No.119, "Piping Feview Cerriittec

$ Recomendations" is a regulatory frpact issue f or which technical resolutions 9.n have been identified es discussed in the evaluation provided in Enclosurn 1.

A Since you are taking the actions necessary to resolve this issue ir, accordance 7 with your rvriorandum to W. Dircks, dated July 30, 1985, we have not r.rioritized this issue, p(

3a However, in your July 30, 1985 memorandnr. you agreed that the resolution of this issue would be rwnitered by the Generic Issue Managerent Control System Z (GlMCS). The infomation needed for this system is indicated on the enclosed c; G!PCS infomation sheet (Enclosure 2). Norma l ly , t he i n f o rr.a t ic a needed t should be provided within six weeks. *

.Y The enclosed evaluation will br incorporated into NUPEG-0933, "A Prioritiretion glj of Generic Safety Issues," and is being sent to the regions and other offlees, e, the ACRS, and the POR for coments on the technical accuracy ard cocpleteness j of the prioritization evaluation. Any changes as a result of coments will be coordinated with you. However, the schedule for the oj

, resolution of this i! sue should not be delayed to wait for these coments.

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$ The infomatier. reouested should be sent to the Safety Prograri Evaluatinn

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. Branch, OST. Should you have any ourstions pertaining to the contents of this rsemorardum, please contact Louis Piani (74563).

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Enclosures:

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[ ENCLOSURE 1

't PRIORIT!ZATION EVALUATION M[,) GENERIC ISSUE ISSUE NO. 119 4

C "PIP!NG REVIEW CO M11 TEE RECOMMENDATION 5" l \.(A i .

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.-,_r ISSUE 119: PIPING REVIEW COMITTEE RECOMENDATIONS Historical Background in Reference 1, the Executive Director for Operation (E00) requested a comprehensive review of NRC requirements in the area of nuclear power plant piping. In respense to this request, the NRC Piping Review Committee (PRC) was formed to review and evaluate current regulatory requirements to provide recommendations on where and how the NRC should modify current requirements, and to identify areas requiring further action. The scope of the PRC review covered those pipes that are in the safety-related systems and those high energy lines important to safety in new and operating nuclear power plants. With respect to postulated pipe break, the scope covered all high energy lines.

An NRC steering committee consisting of members from the Offices of RES, NRR, IE, and ELD was formed to review and develop a plan for implementing the changes recommended in the PRC report (Reference 2). The steering committee agreed to focus their attention on the recomeended research and regulatory changes designa'.ed in the PRC report (Reference 2) as Category A (high priority) reco.mendations. The PRC recommended research and regulatory I changes were restructured by the steering Committee (combining of research i

and regulatory recommendations) to form nine tasks to be addressed by the NRC implementation plan (Ref. 3).

This issue deals with five of the nine tasks contained in the NRC imple-mentation plan. These five tasks primarily consist of NRR regulatory actions and some closely related research efforts. The remaining four tasks of the NRC implementation plan relate only to research activities and are therefore not part of this issue.

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I to 119.1 Piping Rupture Requirements and Decoupling of Seismic and LOCA Loads 2.'/ )

Description I

l c y,) This task ccebines two PRC Category A regulatory recommendations with one PRC h Category A research recommendation. The designations of the three PRC

'f recommendationv are: 1) leak-before-break (A 1), 2) decoupling of seismic and

{';< LOCA loads ( A 5), and 3) completing research on decoupling ( A 4). The

'i resolution of this task will effect all LWRs. .

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One part of the task involves rulemaking changes to the General Design ti Criterion 4 (GDC-4) in Appendia A of the 10CFR50 to redefine the need to

'j){ consider the dynamic effects of pipe breaks. A proposed rule to modify GDC 4 was published in the Federal Register un July 1, 1985. This role A

{p change codifies leak before break technology but is limited to only the

, 6 .1 primary loop piping of PWRs. A broad scope rule cealing with all high 3

l C energy piping in all LWR 5 is to be published in the Federal Register in i

.k November 1985. Revisiens to SRP 3.6.1 and SRP 3.6.2 are needed to eliminate

), the postulation of arbittary intermediate breaks. The second part of this

[ task would relax the requirement to consider LOCA and seismic loads i

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pipe rupture loads in the eechanical design of cc ponents and their supports.

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l l 1 Safety Significance l

b ly ' The current CDC 4 requirement and Section 3.6.2 of the SRP pertaining to 2

postulated double ended guillotine break (OEGB) of the largest pipes and 1 postulated arbitri:ry intercediate pipe breaks need to be changed to include h more realistic criteria and to allow consideration and acceptance of f validated analysis methods. The requirements of the current CDC 4 have led

}' to a situation where protective devices have been added to fortitall events

( that are extrem.ely unlikely. These protective devices that have been

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designed for the extremely unlikely events could, however, reduce safety and increase worker radiation exposures from normal L,vrations and more likely design basis considerations.

Section 3.9.3 of the SRP currently requires that piping systems and associated components be designed for the combined effects of an 55[ and a LOCA. Ihtre has never been a well developed rational basis for this requi rernent. The evolution of seismic design requirements and the calculations of pipe rupture loads have significantly increased the resultant Inads obtained by combining these effects. However, field evaluations of piping at conventional power plants and petrochemical facilities have indicated that ruptures in piping of the ty; e f ound in nuclear power plants do not occur during severe earthquakes. Therefore, relaxation of these requirements should not affect plant or public safety.

The resolution of this task will effect all LWRs.

119.2 P,_iping Damping Valyn Description This task combines PRC regulatory recon endation A 2 (modify seismic damping values used in seismic designs), and PRC research recom endation B 3 (complete research on damping tests).

This task ccnstitutes a two-level approach; namely, a short term, and a long-term plan. The resolutions cculd effect all LWR plants. The short term astion will rely on revision of Regulatory Guide 1.84 as the vehicle for NRC l endorsement of ASHE Code Case N 411. lhe long term action will result in the revision of Regulatory Guide 1.61 and SRP 3.9.2 to incorporate not only ASME

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.g Code Case N 411, but also new positions on pipe damping for high-frequency 2id loads and for time-history analyses.

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yh. The short-term endorsement of the ASME Code Case N All would be reu sted to q

seismic response analysis, but not time history analysis. The lony ;erm g action will result in extensive changes to SRP 3.9.2 and to Reg.h o ry Guide p 1.61 to provide more comprehensivt- 3uidance on pipe damping fee wth seisr.ic

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-) and BWR hydrodynamic loadings. Criteria for other non seismic Jjnamic loads 3$d could also be addressed in the SRP 3.9.2 revision.

5.V iY sbi Safety Significance y

y o r In general, dynamic piping responst would be more accurately predicted if

{b higher pipir.g damping values were used thn those identified in the current

$ regulatory guide. The use of higher damping values will result in nuclear i$

plant piping systems having significantly less snubbe ; and st.pports and an

(+:; overall better balance of design considering all piping loads. A significant Nj ' decrease in the numoers of snubbers and supports will allow better inspection

.h y of equip 9ent and compenents at significantly reduced occupaticaal radiolcgical b exposures.

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119.3 Decoupling the Operating Basis Earthquake (OBE) fre the Safe

[ Shutdc.n Earthquake (SSE)

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Deseription

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The task corresponds to PRC regulatory reco-eendation A 3 (decouple OBE from ff' SSE). 10CFR100, Appendix A, Section V(a)(2), stipulates: "The naximum P@ vibratory ground accelerati.n of the OBE shall be at least one half the

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maximum vib Ntary ground acceleration of the SSE." Therefore, the current

)) requirement implies the coupling of the two earthnvake design levels, the SSE f.h and OBE. In development of the current regulations, it was assu ed that the M SSE would control the design in nearly all aspects, and that the OBE would MI vd 4

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serve as a se;arate check of those systems where continued operation wa*

desired at a lower level of ground motion. However, in practice, tb* assumed ,

Icad factors, damping, stress levels and service limits. have caused the OBE, rather than the SSE, to cent ol the design for many 5,ystems including concrete and steel structures and ne tar piping. In addition, seismic design for OBE ac ounts for certain sr 'v-related factors such as fatigue and seismic anchor movement that are not Jnsidered in the design for the SSE.

Decoupling of the OBE from the SSE or modification e,f the associated load factors, etc., would impact the design of new plants, extending well beyond piping considerations. The action required to resolve this task includes:

(1) rulemaking to amend and revise Appendix A to 10CFR Piet 100 to permit decoupling of the OBE and SSE, and iricorpor .e the use of probabilistic methodology in earthquake design, (2) revising and developing Regulatory Guides, (3) uppsting pertinent sections of the Standard Review Plan, and (4) advisit _ various code comittees to revise appropriate codes and guides to reflect changes in the regulations.

l A complete listing of the Regulatory Guides and SRPs that may be af fected by this task will be identified during the review ph35e of this task and the related tasks contained in the broader scope NRC implementation plant defined in Reference 3.

Safety Significance Thare is no technical basis for coupling the OBE with the SSE. Desig *.g the piping systems to the SSE is the primary ceans of ensuring safety, Additional I margin is provided by specifying the OEE and thus the level at which ,

inscettions will be required before continued operation would be permitted.

The more realistic approach of using specific probabilities (return periods) for OBEs and the decoupling of the OBE levels and frequencies from those of the SSE will allow assurance of public safety to be ple o a a core rational basis.

5

119.4 BWR Piping Materials Description This task corresponds to the PRC reco mendation A-4 to replace regular grade 31655 and 30455 materials in BWR recirculation piping with an alloy resistant to ints granular stress corrosion cracking (lGSCC). The NRR staff action related to this task involves preparation of Revision 2 to NUREG-0313, "Technical Report on Material Selection and Precessing Guidelines for BWR Coolant Pressure Boundary Piping," and evaluating each licensees actions to comply with Revision 2.

Safety Significance

} IG5CC in BWR piping has occurred in a range of pipe over the last 25 years l resultinginmajorreactorowtages. The risk studies reported in Reference 2 indicate that pipe . lures, even assuming the higher rates due to IGSCC, j would r.ot be a major contributor to core melt and public risks. However, i use of materials m:re recistant t0 !CSCC ch0uld significantly reduce levels of in-service inspections and reactor outage times. Therefore, plant outages i and recurring occupational radiation exposures could be significantly reduced by resolution of this task.

i 119.5 teak Detection Requirements Description This task corresponds to PRC regulat"y .ccommendation A-6 (leak detect ;n requirements). To accomplish this task, additional data are necessary a further validate and improve existing leak-rate prediction analyses. Of particular interest would be investigation and improvement of local tr3k detection systems such as acoustic emission monitors or moisture ser ve

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tapes. These latter techniques may be irportant for establishing the validity of leak-before break at specific locations in certain piping systems.

The task requires a combination of two approaches. One, the surveying of operating plants to determine the sedequacy of e isting leak detection systems, and the other involves completion of the researc' recommended n by the PRC and applying the results of the research to regulatory requirements.

Subsequent to the completion of key elements of the research effort, the regulatory actions may include the following:

Identify tequired changes to tech specs, e.g., (a) unidentified leakage limits for BWRs and PWRs in the context of locating and detecting leakage from cracks with margin, (b) adequacy of surveillance require-ments and calibration of systems, (c) alarms, (d) consistency of tech sprcs, (e) new systems or different detection system combinations, and (f) forward and backfit considerations.

Revise SRP 5.2.5 and R.G. 1.45.

Resolution of this task may, to various degrees, affect all light water reactors (LWRs).

Safety Significance No dire:t safety significance can be attributed to this task. However, knowledge of the leak rates associated with various postulated throt.gh wall

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crack lengths and confidence in the ability to detect leakage in a timely

. manner is an important element of '.hc leak-before break concept that eliminates the postulated double ended guillotine break.

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Conclusions This issue primarily involves changes to Regulatory Rules, and revisions to Regulatory Guides and Standard Review Plans. No 5 nificant change in public safety will result from resolution of this issue. riowever, resolutions to the various tasks are expected to result in less complex and more realistic approaches to piping design and operation in nuclear power plants. The ,

results shnuld yield more efficient regulatory practices, improve plant l piping systems designs, increase plant reliabilities, and decrease occupational radiation exposures associated with inspections and repairs. The NRC steering comnittee has agreed that, based on th; information provided in Reference 2 ,

(huREG-1061), this work should continue on a schedule consistent with high- [

priority issues. Therefore, this issue is a Regulatory lepact issue for '

which possible resolutter.3 have been identified. RES will take the lead for l

resolution of this issue, with assistance from other NRC Offices, as defined in Reference 3.

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References:

1. Memorandum from W. Dircks (E00) to H. Denton (NRR) and R. Minogue (RES),

August 1, 1983.

2. NUREG-1061, "Report of the U.S. Nuclear Regulatory Commission Piping Review Committee," April 1985.
3. Memorandum from R. Minogue (RES) to W. Dircks (E00), July 30,1985.

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ENCLOSURE 2

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GENERIC ISSUE MAN 4GEMENT CONTROL SYSTEM ,

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g The Generic !ssues Management Control Systcm (GlHCS) provides appropriate e, infomation necessary to manage safety related and environmental generic j issues through technical resolution and completion. For the purpose of this management control system technically resolved i'. defined as the point where A

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the staff's technical resolution has been issued. Generally, speaking, this 1g.; oc:urs when the technical resolution has been incorporated into one or more of bu., the following:

a Comission policy statement / orders

@4J b NRC Regulations y c Standard Review Plan tM d Regulatory Guide y,; e Generic letter a-Q .-

GlHCS is part of an integraded system of reports and orocedures that would manage generic safety issues. THI-related issues, and proposed new generic

},c% issues through the stages of prioritization, technical resolution, development o of new criteria, review and approva!, public coments, and incorporation into the Standard Review Plan (SRP), as appropriate. NUREG-0933 provides an tv, evaluation for a recomended priority listing based on the potential safety fis significance and cost of implementation for each issue; NRR Office Letter w Number 40 provided procedures and criteria for adding new generic issues to the

  1. system; and GIMCS provides proposed scheduling for resolving and completing

.ti , issues on the prioritized listing. GIMCS will provide infomation to manage

}. and control issues that are ranked High priority generic issues, Medium-priority

? generic issues, issues for which possible resolution has been identified for

! C evaluation, issues for which a technical resolution is available (as documented g by remorandum, analysis NUREG, etc.), and issues designated by the Director of NRR as issues for which resources have been made available for resolution and I, completion. Issues ranked as either "Low" or "Dropped" are not allocated

-f. resources, therefore, there is no resolution to be tracked by GIMCS.

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1" Some new generic issues prioritized and processed in accordance with hRR Office Letter No. 40 eay not have resources allocated for resolution and completion.

', These issues will be listed in GIMCS as inactive issues. These will generally i be Medium priority issues that have no safety deficiency deranding high-priority

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. attention, but ther? is a potential for safety improvements or reduction in l

';p uncertainty of analysis that may be substantial and worthi.hile. Efforts for y resolution of these issues will be planned, over the next several years, i s but on a basis that will not interfere with the resolution of High-priority M generic issue work or other high priority work. Thus, some (Medium) generic i

l h issues will be inactive until such tine as resources become available to

! J resolve the various issues. As resource allocations are directed at issue l

C resolution, they will become active. The detailed schedule for resolving y and completing the generic issue will be developed and monitored by the management M control system.

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Iala*g'eNI^Edko'ntrolIn'dieato'r005'e'((nG[MC5 are defined as follows:

1. Item No. - Generic l'ssue Number. (
2. Issue Type - Safety Environmental or Regulatory Impact High, Note 1 or Note 2 (from NUREG-0933),

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3. Action level - Degree of management attention need to process generic issues in accordance with established
  • scheduies L1 - No management action is necessary L2 - Olvision Director action is necessary L3 - Director NRR action is necessary 4 Of fice/Olv/Br - 1st listed has lead responsibility for re-solving issue, others listed have input to resolution.
5. Test Manager - Name of assigned individual responsible for schedule updating.
6. Tac Number - Each issue should be assigned a TAC f.
7. Title - . Generic Issue Title.

Work Authoritation - Who or what authort;ed work to be done on 8.

generic issue.

9. Contract Tit h - Provide Contract Title (if contract issued).

Identify Contractor Name and FIN Nurber (as

10. Contractor Nan / Jppropriate). If Contract is rot yet issued, FIN No. -

l indicate whether the contract is included in i

the flN plan.

II. Work Scope - Describes briefly the work necessary to tech-nically resolve and complete the generic issue. ,

12. Affected Documents - Identifies documents that the technical resolution will be incorporated intc to identify new criteria.
13. Status - Describes current status of work.
14. Problem / Resolution -

Identifies potential problem areas and cescribes what actions are necessary to resolve them.

15. Technical Resolution - Identifies detailed schedule of milestone date', that are required for completing the issue through the issuance of the SRP revi. inn or other change that documents requirements.

Selected significant milestones. The "original" Milestones - Changes in schedule schedule remains unchanged.

Actual co pletion are listed under "Current".

are listed under Actual *'.

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' TYP! cat.HilfSTONES Other Divirion involve' ment Original Current Actual o Date infonation requested i from Olvision o Date received from 01 vision , ,

Contractor Inforsation o Proposal Solicited o Proposal Evaluated and Accepted o Contract Schedule, if applicable o Testing Sc'hedule, if applicable o Draft HUREC/CR report from contractor /consu1* tant  ;

l Staff review of draft HUREG/CR ,

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Value Ir. pact Statement prepared ,

(coordinated with SPEB and RRAB l as appilcab11) i 9

final report prepared by Olvision 4 . (include SPEB preliminary coments and SRP revision)

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CRCR Package to NRR Director for  !

Review [

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.......... 1 ,o Federal Register Notice of Issuance of SRP for Pubile Comment

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.......... 2 wks Conments incorporated and transultted to 051 for .

processing

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Review Package to CRGR

.......... 1 ,o CRGR review and ED0 approval completed

.......... 1 en Federal Register Notice of Issuance of SRP L

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Vork Auther!!ation - - Memorandum to from H. R. Denton cated Contract Title - ----- To Be Provided.

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Status --- ------ --

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Technical Resolution

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m: soav os ee mi nar.w n.: OFFICI AL R Er.OR D COPY so.. .. n.