NRC Generic Letter 1989-09
UNITED STATESNUCLEAR REGULATORY COMMISSIONWASHINGTON, D. C. 20555May 8, 1989TO: ALL HOLDERS OF LIGHT WATER REACTOR OPERATING LICENSESSUBJECT: ASME SECTION III COMPONENT REPLACEMENTS (GENERIC LETTER 89-09)
BACKGROUND
The purpose of this Generic Letter is to provide guidance to Licensees whorequire comrponent replacements, as defined in Definition 1 (see Appendix fordefinitions), for components that were constructed (see Definition 2) toSection III of the ASME Boiler and Pressure Vessel Code (hereafter called theCode), but are not currently available in full compliance with the stampingand documentation requirements of the Code. The staff position in thisGeneric Letter does not apply to new construction or the addition of completesystems to operating power reactors. Complete systems being added tooperating power reactors shall continue to meet all applicable Coderequirements, including stamping. The position in this Generic Lettersupersedes previously issued differing position on this subject. This GenericLetter is intended to serve as interim guidance pending revision of 10 CFR50.55a, the Codes and Standards Rule, or development of a Regulatory Guide.For replacements of components that were originally constructed to ASME CodeSection III, Classes 1, 2 or 3 or other standards within the scope of thecurrent edition of Section XI, Division 1, "Rules for Inservice Inspection ofNuclear Power Plant Components," of the Code, Article IWA-7000 of Section XIspecifies the general requirements. Paragraph IWA-7210 provides that replace-ments ordered as spares shall meet the requirements of the originalconstruction Code used or those of a later Code edition and/oraddenda approved in the Codes and Standards Rule 10 CFR 50.55a.Prior to May 14, 1984, paragraph (a)(2) of the Codes and Standards Rule,10 CFR 50.55a, permitted an exception to Section III of the Code: §50.55a(a)(2)provided that the Code N-symbol need not be applied when constructing Class Aor Class 1 nuclear reactor components to comply with the ASME Code. Thisexception was initiated in 1971 to permit qualified foreign manufacturers tosupply components to domestic nuclear plants. At that time the ASME had noprovisions for issuing Certificates of Authorization and the Code N-symbolstamps to firms outside of the United States and Canada. This Code requirementwas waived by NRC when the Code was first incorporated by reference in theregulation in 1971; however, the Commission always intended that items withinthe scope of the Code comply with all other Code provisions. As ofSeptember 11, 1972, the ASME-instituted provisions for making Certificates ofAuthorization and symbol stamps available to foreign manufacturers, makingthe exemption in 10 CFR 50.55a unnecessary and permitting the regulation to berevised accordingly. As of May 14, 1964, any components or parts required bythe procurement document to meet the requirements of ASME Section III, CodeClass 1, 2 or 3 must meet all the requirements of Section IlI, including890007 4
'4Generic Letter 89-09 -2 -May 8, 1989Because of the decline in nuclear plant orders in the United States, a numberof utilities are experiencing difficulties in obtaining replacements forcomponents that were originally constructed in accordance with Section III ofthe Code. This decline in nuclear power plant orders has caused certainmanufacturing companies that previously provided nuclear-grade components inaccordance with Section III of the Code to allow their Certificates ofAuthorization to expire. In other cases, companies have discontinued aproduct line or sold a product line to another company that does not have aCertificate of Authorization and, therefore, does not manufacturenuclear-grade components. Some of the companies have retained the capabilityto provide components which meet the design, fabrication, and examinationrequirements of Section III of the Code. However, because of the limiteddemand for nuclear-grade components and part, these companies have notmaintained their Certificates of Authorization and their related agreementswith the Authorized Inspection Agencies.Even though the manufacturer of an original component does not currentlymanufacture nuclear components and parts, it may sometimes be necessary toprocure replacements from the original manufacturer in order to ensure adequateoperation and proper fit and function. In special cases, consideration may begiven to procurement of replacements from the original manufacturer in order toavoid an adverse impact on existing components or systems. However, it isalso necessary to obtain objective evidence that the quality of the replacementis adequate. For example, in order to avoid rerouting and reanalysis ofsystem piping, consideration may be given to replacement of an ASME SectionIII, Class 3 nuclear-stamped heat exchanger with an ASME Section VIII stampedheat exchanger that has the same heat removal capacity, construction, andphysical dimensions as the original component. When replacements areconsidered as special cases, they should be procured in a manner consistentwith the staff position provided below which is a means of ensuring that areplacement's level of quality is at least equivalent to the original SectionIII construction.NRC POSITIONIn order to use the guidance in this staff position (provided below) forpurchasing replacements, a licensee must first establish that an equivalentSection III stamped replacement is not available. When replacements arerequired in accordance with Article IWA-7000 of Section XI of the Code, costcannot be used as a justification for purchasing non-stamped parts. Wherereplacements are no longer available in full compliance with the stamping anddocumentation requirements of Section III of the Code they should be procuredunder the utility's Quality Assurance Program that is in conformance with10 CFR Part 50, Appendix B and included in the plant operational QualityAssurance list. Furthermore, these replacements should meet all other appli-cable requirements of Section III (including third party inspection by anAuthorized Nuclear Inspector) endorsed by NRC regulations except that the CodeN-symbol need not be applied.
Generic Letter 89-09-3-May 8, 1989Licensees that choose to use this staff position need only indicate such re-placements in the Final Safety Analysis Report annual update and certify theircompliance with the guidance provided herein. Licensees should retain on filefor the service lifetime of each replacement that information detailing thebasis for the action and all other related documentation in order todemonstrate conformance with the guidance in this Generic Letter.The staff concludes that adherence to the guidance provided in this GenericLetter will provide reasonable assurance that component replacements willperform their safety-related function. Pursuant to 10 CFR 50.55a(3), thestaff has determined that where component replacements are not currentlyavailable, full compliance with the stamping and documentation requirements ofthe Code would result in hardship or unusual difficulties without acompensating increase in the level of quality and safety over that provided bythe alternatives contained in this guidance, and that the alternativescontained in this guidance provide an acceptable level of quality and safety.Accordingly, pursuant to 10 CFR 50.55a(3) relief is granted to those licenseesthat choose to use the guidance in this Generic Letter for those componentreplacements that are not currently available in full compliance with thestamping and documentation requirements of Section III of the ASME Boiler andPressure Vessel Code. If you have any questions about this matter, pleasecontact the NRC project manager or the technical contact listed below.Sincerely,Jamrs G. PartlowAs sbcate Director for ProjectsOffice of Nuclear Reacter RegulationEnclosures:1. Appendix2. Listing of Recently Issued Generic LettersTechnical Contacts:R. Kirkwood, RES(301) 492-3928S. Hou, NRR(301) 492-0904
4APPENDIXDEFINITIUNS ANWFOOTNOTESDefinition 1Replacements are defined in Pdragraph IWA-7110 of Article IWA-7000, Section XIof the Code as follows:"Replacements are defined as spare and renewal components, appurtenances,and subassemblies or parts of a component or system. Replacement alsoincludes the addition of components, such as vales, and system changes,such as rerouting of piping, within the scope of this Division.* ThisArticle does not provide rules for the addition of complete systems."Definition 2Constructed, as used herein, is an all-inclusive term comprising materials,design, fabrication, examination, testing, inspection, and certificationrequired in the manufacture and installation of items.Footnote 1Included within the scope of Section XI of the Code are pressure vesselsconstructed to the 1963, 1965, and 1968 Editions of Section III, Classes A, B,and C. Also included within the scope of Section XI are componentsconstructed to other Codes and Standards, such as USAS B31.7 for nuclear powerpiping, ASME Section VIII for pressure vessels, USAS B31.1 for piping andvalves, and AISC Structural Steel Standard for supports, provided thesecomponents are in systems classified as Quality Groups A, B. and C as definedin Regulatory Guide 1.26, "Quality Group Classifications and Standards forWater-Steam-, and Radioactive-Waste-Containing Components of Nuclear PowerPlants or in the applicable Section of Standard Review Plan NUREG-0800.Replacements for components constructed to Codes and Standards not originallyrequiring stamping, such as USAS B31.1, may continue to be procured in thesame manner.*Preventive maintenance or inspection may reveal the need for replacements;reasons for such replacements may include:(a) Discrepancies detected during inservice inspection(b) Regulatory requirements change(c) Design changes to improve equipment serviced) Changes to improve reliability(e) Damage(f) Failure during service) Personnel exposureh Economicsi End of Service life ENCLOSURE 2LIST OF RECENTLY ISSUED GENERIC LETTERSGenericLetter No.Date ofSubject IssuanceIssued To89-09ASME SECTION III COMPONENTREPLACEMENTSISSUANCE OF GENERIC LETTER89-08: EROSION/CORROSION -INDUCED PIPE WALL THINNING -10 CFR §50.54(f)5/8/895/2/8989-08ALL HOLDERS OF LIGHTWATER REACTOROPERATING LICENSESLICENSEES TO ALLPOWER REACTORS,BWRS, PWRS, ANDVENDORS IN ADDITIONTO GENERAL CODESAPPLICABLE TOGENERIC LETTERSLICENSEES TO ALLBWRS, PWRS, ANDVENDORS IN ADDITIONTO GENERAL CODESAPPLICABLE TOGENERIC LETTERS89-07GENERIC LETTER 89-07, POWER 4/28/89REACTOR SAFEGUARDS CONTINGENCYPLANNING FOR SURFACE VEHICLEBOMBS89-06TASK ACTION PLAN ITEM I.D.2SAFETY PARAMETER DISPLAYSYSTEM -10 CFR §50.54(f)-4/12/89LICENSEES OF ALLPOWER REACTORS,BWRS, PWRS, HTGR,AND NSSS VENDORSIN ADDITION TOGENERAL CODESAPPLICABLE TOGENERIC LETTERS89-05PILOT TESTING OF THEFUNDAMENTALS EXAMINATIONGUIDANCE ON DEVELOPINGACCEPTABLE INSERVICETESTING PROGRAMSOPERATOR LICENSING NATIONALEXAMINATION SCHEDULE4/4/894/3/893/24/8989-04LICENSSES OF ALLPOWER REACTORS ANDAPPLICANTS FOR AREACTOR OPERATOR'SLICENSE UNDER10 CFR PART 55ALL HOLDERS OF LIGHTWATER REACTOR OPERATINGLICENSES AND CONSTRUCTIONPERMITSALL POWER REACTORLICENSEES ANDAPPLICANTS FOR ANOPERATING LICENSE89-03