ML19067A049

Rulemaking: Final Annotated Public Comments 2015-2017 ASME Code Editions (NRC-2016-0082; Rin 3150-AJ74)

ML19067A049
Person / Time
Issue date:	03/19/2019
From:	O'Driscoll J Office of Nuclear Material Safety and Safeguards
To:
James O'DRiscoll 301-415-1325
References
83FR56156, NRC-2016-0082, RIN 3150-AJ74
Download: ML19067A049 (83)

Text

Public Comments on Proposed Rule:

American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference 83 FR 56156 (November 9, 2018)

NRC-2016-0082; RIN 3150-AJ74 Submission ADAMS Accession Commenter Name Affiliation ID Number 1 Jarno Makkonen Private Citizen ML18318A356 2 Ron Clow Private Citizen ML18344A191 3 J. E. OSullivan Private Citizen ML18355A760 4 Carl Latiolais Electric Power Research Institute ML19022A074 5 Glen Palmer Private Citizen ML19022A277 American Society of Mechanical 6 Richard Porco ML19022A278 Engineers 7 Richard Deopere Private Citizen ML19024A023 8 Edward Cavey Private Citizen ML19024A529 9 Adam Keyser Private Citizen ML19024A526 10 Gary Becker NuScale Power, LLC ML19024A527 11 Justin Wheat Southern Nuclear Operating Company ML19024A528 12 Stephen Vaughn Nuclear Energy Institute ML19028A019 13 Mark Gowin Private Citizen ML19029B164 14 David Gudger Exelon Generation Company, LLC ML19037A437

Submission ID 1 Jarno Makkonen, Private Citizen ML18318A356

Page 1 of 1 83FR56156 1 PR-50 As of: 11/14/18 8:23 AM Received: November 13, 2018 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k2-96jg-7bxj Comments Due: January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0004 Comment on FR Doc # 2018-24076 Submitter Information Name: Jarno Makkonen General Comment My comments are in the attached PDF as they are too long for this input field.

Attachments Comments to NRC https://www.fdms.gov/fdms/getcontent?objectId=09000064838d4550&format=xml&showorig=false 11/14/2018

Comments to NRC-2016-0082 Proposed rule (reference 83 FR 56156)

The comments provided are from the perspective of a manufacturer of components compliant with ASME Boiler and Pressure Vessel Code, Section III, Division 1, for installation in nuclear power plants under the jurisdiction of the NRC. The views expressed are my own and do not necessarily reflect the views of my employer. I have comments to 3 specific provisions in the proposed rule.

1. Change to 10 CFR 50.55a(b)(1)(v)

The text of the revised rule is not actually provided in the Federal Register notice for this sub-paragraph referenced in the Discussion section of the notice. Neither the current text nor the proposed revision are consistent with the rationale given in the discussion section. The current rule prohibits the use of NCA-4134.10(a) in its entirety. That Code paragraph has three separate functions. First, it incorporates by reference all of Supplement 10S-1 of NQA-1. Second it exempts the requirement in paragraph 3.1 and finally, it also exempts the requirements for in service inspection. The rationale given in the proposed rule discussion states that only the exemption of the requirements of paragraph 3.1 is problematic. This implies that it is desired that the rest of Supplement 10S-1, except for the requirements of in service inspection, should apply. As such, the current rule needs modified to be consistent with the stated intent and below is suggested text.

(v) Section III Condition: Independence of inspection. Applicants or licensees may not apply the exception 1-1 to paragraph 3.1 of Supplement 10S-1 of NQA-1 as referenced in section NCA-4134.10(a) of Section III, 1995 Edition through 2009b Addenda of the 2007 Edition.

Additionally, it should be considered that the Quality Program requirements for holders of ASME Certificates of Authorization for work within the scope of Section III, Division 1 must continually update their Quality Programs to comply with NCA-3800 and NCA-4000 within 6 months of issue of new Code Editions per NCA-1140. As such, no current Certificate Holder would be able to use the exception to paragraph 3.1 of Supplement 10S-1 of NQA-1 being prohibited by this condition since their quality programs would currently comply with the 2017 Edition. As well, no component manufactured in accordance with the old Section III rules and, as a result, without an ASME Certification of Authorization and mandatory Authorized Inspection could be delivered and installed to a nuclear power plant under the jurisdiction of the NRC per the rules of Part 50 of Title 10 of the Code of Federal Regulations. This condition could be eliminated without creating any risk or substantial safety hazard to the operation of the US nuclear fleet.

2. Addition of 10 CFR 50.55a(b)(1)(x)(B)

In the Discussion section of the notice, the rationale given for the inclusion of this condition is that 2017 Edition paragraph NX-2582, in referencing ASTM F788 and ASTM F812 as acceptance criteria, only considers workmanship, finish, and appearance and does not consider structural integrity. The 1-2 condition then stipulates the use of the acceptance criteria given in the 2015 Edition of NX-2582 be used instead. This rationale is incorrect.

ASTM F788 and ASTM F812 provide quantitative acceptance criteria for imperfections in bolts and nuts, respectively, for cracks, bursts, seams, folds, voids and tool marks and were been developed based on industry experience. The acceptance criteria given in the 2015 Edition is only qualitative and thus leaves the determination of whether a given imperfection would be detrimental to the intended service

entirely to the person performing the examination. By eliminating the need for judgement by the person performing the examination, this strengthens, rather than weakens, detection of non-compliant material that could result in failures after installation.

This condition should not be included in the revised Regulation.

3. Addition of 10 CFR 50.55a(b)(1)(xii)

This new proposed condition to the use of the 2017 Edition is not correctly written. My interpretation of the intent is that the Engineer, who is certifying the documents required for the construction of components in accordance with the rules of Section III, Division 1, must be a Registered Professional Engineer in at least one state in the United States or at least one Province in Canada. This is a reasonable requirement. However, as written, the condition conflicts with the design document certification requirements in the 2017 Edition resulting in the inability to use the 2017 Edition. In order to comply with the 2017 Code and be able to construct components within its rules, the person 1-3 certifying the documents must be qualified as a Certifying Engineer per the rules of Appendix XXIII. The condition should stipulate that the Certifying Engineer can only be a Registered Professional Engineer qualified in accordance with paragraph XXIII-1222 which implies that the use of alternate Engineer qualifications listed in XXIII-1223 cannot be used.

In lieu of the current text, I would propose amending the text of this sub-paragraph to read as follows:

(xii) Section III Condition: Certifying Engineer. When applying the 2017 and later editions of the ASME BPV Code Section III, the NRC does not permit applicants and licensees to use a certifying engineer who is not a Registered Professional Engineer qualified in accordance with paragraph XXIII-1222 for Code-related activities that are applicable to U.S. nuclear facilities regulated by the NRC.

Finally, I would like to note that the arrangement between the NRC and ASME to provide electronic 1-4 access to relevant ASME Codes during comment period does not seem to be working as at the time of the submission of this comment.

Submission ID 2 Ron Clow, Private Citizen ML18344A191

Page 1 of 2 83FR56156 2 PR-50 As of: 12/10/18 7:56 AM Received: December 07, 2018 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k2-96z7-8cox Comments Due: January 23, 2019 Submission Type: API Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0005 Comment on FR Doc # 2018-24076 Submitter Information Name: Ron Clow Address:

1717 Wakonade Drive East Welch, MN, 55089 Email: ronald.clow@xenuclear.com General Comment Ref. NRC-2016-0082, 10 CFR Part 50, Proposed Rule

Subject:

Comment in difference to the proposed rule.

In differences to the 10 CFR 50.55a(b)(2)(xxvi) Section XI condition: Pressure testing Class 1, 2 and 3 mechanical joints, the following comment is being submitted.

This condition takes exception to ASME Section in XI in that it mandates that a VT-2 2-1 pressure test be performed following performance of a repair/replacement activity when the mechanical connection of an item is disassembled and subsequently reassembled.

Moreover, as worded, this condition would require a VT-2 pressure test, if only fasteners, even just one, regardless of the reason the fastener is replaced when the item is disassembled.

The ASME III and XI committees have determined that there is no need to perform a pressure test following a repair/replacement activity where the mechanical connection was https://www.fdms.gov/fdms/getcontent?objectId=090000648395c2f5&format=xml&showorig=false 12/10/2018

Page 2 of 2 disassembled and reassembled as gaskets, bolts, studs, nuts, and washers are specifically exempted from Repair/Replacement and pressure testing.

For installation into a Code Class (1, 2, 3) system, plants use components that are procured as Quality Related in accordance with a QA program and require the items meet material standards, codes, etc. and are subject to additional NDE and testing before being utilized. This gives reasonable assurance that the materials are free of defects and will perform their function during operation.

In the case of valves, pumps, manufactured piping assemblies (ASME III stamped), etc.

designed and fabricated to a code or design specification provided by the owner, pressure testing is already required of these items.

Whenever maintenance is performed that requires an item to be disassembled, regardless if it includes an ASME XI repair/replacement activity, a leakage check is performed utilizing plant operators to inspect for leakage during post-maintenance testing / return to service (PMT/RTS) activities. Verifying no leakage is just one of the many observations they perform to assure the item is functioning as expected before considering it operable. Adding a requirement to include a VT-2 examiner and in some cases an ANII, does not increase the level of public safety and it does not meet ALARA in those areas of the plant where radiation is present. Additional personnel are subject to dose unnecessarily with no added safety benefit as the mechanical connection is already being inspected by an operator whose training involves the ability know how the equipment operates and to identify leakage or other abnormal conditions during their normal work duties. Additionally, the mechanical connection is disassembled and reassembled by personnel trained to perform the activity, including use of industry standard bolt torqueing guidance to assure proper integrity of the joint.

While RCS leakage is always a concern and each utility has requirements to address this leakage, this commenter is unaware of any precedence where a mechanical connection has catastrophically failed which would be cause for requiring additional visual scrutiny of the mechanical connection by a VT-2 examiner, including the need for use of an ANII. In cases where a condition of leakage has been identified during PMT/RTS activities (within or outside the ASME Section XI program boundaries), the mechanical connections had no catastrophic failure, and conditions were corrected to eliminate the cause of unacceptable leakage. The leakage can be identified without the need for the added burden of using a VT-2 examiner and an ANII.

As an additional consideration for removal of the condition, plants implementing 10 CFR 50.69 would be implementing an inspection and repair program that is in lieu of ASME XI and 10 CFR 50.55(a). Implementation of 50.69, would require pressure testing per construction code requirements and does not require a VT-2 pressure test following a repair or replacement activity, welded or mechanical. The NRC has found this approach to be acceptable when implementing this alternative regulation and should remain consistent with requirements within 50.55(a).

The NRC should remove this condition and rely on the ASME XI code as written with regards to repair/replacement activities and subsequent pressure testing.

https://www.fdms.gov/fdms/getcontent?objectId=090000648395c2f5&format=xml&showorig=false 12/10/2018

Submission ID 3 J. E. OSullivan, Private Citizen ML18355A760

83FR56156 3 PR-50 Comments on Proposed 10CFR50.55a Ruling Section III, Appendix XXVI Discussion 10 CFR 50.55a(b)(1)(xi)(A) Mandatory Appendix XXVI: First Provision The NRC proposes to add a new paragraph (b)(1)(xi)(A), which specifies the essential variables to be used in qualifying fusing procedures for butt fusion joints in polyethylene piping. This includes four (4) variables in addition to those stated in Section IX that are pertinent to the fusing verification testing of XXVI-2300. These are diameter, cross-sectional area, ambient temperature [range specified in XXVI-4412(b)], and fusing machine carriage model.

This 10CFR50.55a provision will be resolved after publication of the 2019 edition of ASME Section III, Appendix XXVI.

Comment: Previous discussions with the Regulator involving development and incorporation of Tables identifying all procedure variables applicable to testing required by Section IX and Appendix XXVI addressed only fusing procedure qualification and testing - not fusing operator performance qualification testing. The provision relating to fusing procedure variables will be resolved by publication of the 2019 edition of ASME Section III, Appendix XXVI.

Fusing operator performance qualification testing is performed in accordance with XXVI-4341 and XXVI-4342 using fusing procedures tested in accordance with XXVI-2300. Such fusing procedures define the fusing machine 3-1 make and model(s) to be used in production of each joint, so the fusing operator is required to qualify on the same machines and models. However, fusing operators are qualified to use those machines over ranges of diameters and thicknesses, not on each diameter to be fused. This is the approach that was approved by the USNRC as recently as two years ago for the Plant Hatch HDPE Project (ML15337A414). To require each fusing operator to perform qualification testing on each diameter, thickness and lot of material would entail significant added expense and hardship without a commensurate improvement in quality or safety. Therefore, the proposed wording of the paragraph (see Summary, below) involving performance qualification testing and reference to XXVI-4340 should be removed from that 10CFR50.55a paragraph.

10 CFR 50.55a(b)(1)(xi)(B) Mandatory Appendix XXVI: Second Provision The NRC proposes to add a new paragraph (b)(1)(xi)(B), which will require both bend tests and high speed tensile impact testing (HSTIT) to qualify fusing procedures and to qualify fusing operators, for fusing joints in polyethylene piping. The explanation of the proposed ruling states: The NRC has performed limited confirmatory research on the ability of short-term mechanical tests to predict the in-service behavior of HDPE butt fusion joints. Based on this research as well as research results from the Welding Institute in the UK, the NRC lacks conclusive evidence that either of the two tests proposed in XXVI-4342(d) and XXVI-4342(e) is always a reliable predictor of joint quality. As a result, the NRC has determined that the combination of both test results provides increased and sufficient indication of butt fusion joint quality.

Comment:

A. Fusing Procedure Testing: Relative to joint testing for procedure qualification or XXVI-2300 fusing verification testing, the testing performed by The Welding Institute of UK indicated that the HSTI test may not detect joints fused with fine sand or talcum powder sized particles placed within the joint. As a result of that testing, Paragraph XXVI-4412(a)(1) and XXVI-4412(a)(2) of Appendix XXVI specifically require that joint surfaces coming in 3-2 contact with heaters must be protected and kept free of fine particulates, as well as other deleterious material. Also, EPRI Report 3002005434 Advanced Nuclear Technology: Literature Review of Mechanical Testing Methods to Evaluate the Integrity of HDPE Butt-Fusion Joints, was developed to assist the NRC with evaluation of mechanical testing methods. This report provides the results of limited studies on the comparison of the high speed tensile impact test to the guided side bend and waisted tensile test methods. This report identifies that situations can occur with the HSTI test where the specimen ruptures outside of the fusion zone while using the HSTI test method. If this

occurs, a recommendation is provided for nuclear applications that the cause be evaluated by assessing the amount of increased fusion interface resulting from the fusion beads, and/or presence of out-of-roundness of the joined parts.

(If there is indication of minimal or no increased fusion interface, or that mismatch exists between the parts being joined, the test should be re-performed with beads and mismatch removed.) Therefore, this provision should be revised to instead require retests for any HSTI ruptures occurring away from the fusion zone.

B. Fusing Operator Testing: Bend testing has been used extensively and successfully for decades for the qualification of fusing operators in the U.S. for joining polyethylene water and gas piping. It is endorsed by DOT for performance qualification for the fusing of interstate gas transmission pipelines as well as for local gas distribution pipelines. Government acceptance for use of only visual inspection of the test joint plus bend testing for performance qualification on volatile gas pipelines certainly supports its use for nuclear applications - where, in addition to the visual inspection and bend testing, the joint parameters are also required to be recorded and verified during preparation of the qualification test coupons as well as for each installed fusion joints. This is the approach that was approved by the USNRC as recently as two years ago for the Plant Hatch HDPE Project (ML15337A414).

In addition, all installed nuclear fusion joints receive ultrasonic volumetric examination plus a hydrostatic test at 1.5 times maximum design pressure, validating the integrity of each joint fused by each operator. The additional requirement to perform HSTI test in addition to bend testing during performance qualification imposes additional hardship and increased cost without commensurate improvement in quality or safety.

Paragraph 7.4 of EPRI Report 3002005434 provides reasons why the reverse bend test might be considered unacceptable for nuclear applications. The stated reasons are inaccurate based on the following explanations:

a.) Although ASTM F2620 lacks complete requirements for how to perform the reverse bend test including temperature range, Appendix XXVI-4342 invokes Section IX QF-143.1 which does provide explicit directions, including required temperature range.

b.) Although ASTM F2620 may lack clarity on how to perform the test, Section IX, QF-143.1 which is invoked by Appendix XXVI does provide specific instructions on how to perform the test.

c.) Although ASTM F2620 may lack clarity on test radii or coupon thickness, Section IX, QF-143.1.3 and QF-463 provide explicit direction on how to cut the specimens and perform the test. The specimen thickness, t, is the thickness of the joint per QF-463, and the bend radius is defined by the 15t dimension either side of the joint with the requirement to bend back until both 15t ends touch. This defines the ratio of thickness to bending length, which is a direct proportion regardless of what thickness is bent, and always results in a defined bending radius or arc at the apex of the tested joint of approximately 3t. A 3t arc at the apex of the bend results in at least a 15% strain, which exceeds the 10-12% yield strain of HDPE material.

d.) One test report identified by EPRI stated that Reverse Bend testing of 1.33 in. thick 12 NPS PE pipe did not identify defects that were detected by HSTI testing and Guided Side Bend testing. With the advent of the GSB test, most fusing organizations are now using guided side bend tests in lieu of reverse bend tests for qualifying fusing operators on thick sections over 1.25 in. for personnel safety reasons. We suggest that the provision be reworded to address this specific concern when using reverse bend tests for thick sections as indicated in the Summary, below.

Note: HSTI testing machines are quite scarce and expensive. For fusing procedure verification testing (XXVI-2300) the test specimens are typically sent to a laboratory or shop to have the HSTI testing performed. To require this be done for performance qualification purposes would add extra non-productive days for fusing operators, plus it would require sending quality control personnel for witnessing the off-site testing. Since the only technical issue seems to be an anomaly with one test performed on 1.33 in. thick material, a reasonable resolution would be to reword the provision to mandate use of side bend tests (i.e., prohibit use of reverse bend tests) for performance qualification on all piping thicknesses over 1.25 in.

e.) Based on the above inaccuracies, the EPRI report suggested that other tests be used in place of or in addition to the Reverse Bend Test. In actual fact, considering the scarcity and expense of using HSTI test machines, imposing the condition to require HSTI test in addition to Reverse Bend or Guided Side Bend testing for all performance qualification imposes excessive cost and additional hardship without a commensurate improvement in quality or safety.

10 CFR 50.55a(b)(1)(xi)(C) Mandatory Appendix XXVI: Third Provision The NRC is proposing to add a new paragraph (b)(1)(xi)(C), which specifies the essential variables to be used in qualifying fusing procedures for electrofusion of fusion joints in polyethylene piping that is to be installed in accordance with ASME BPV Code, Section III, Mandatory Appendix XXVI. This includes four (4) variables in addition to those stated in Section IX that are pertinent to the fusing verification testing of XXVI-2300. These are:

fitting polyethylene material, pipe wall thickness, power supply, and processor.

This 10CFR50.55a provision will be resolved for electrofusion fusing procedures after publication of the 2019 edition of ASME Section III, Appendix XXVI.

Comment: Previous discussions with the Regulator involving development and incorporation of Tables identifying all electrofusion procedure variables applicable to testing required by Section IX and Appendix XXVI addressed only fusing procedure qualification and testing - not fusing operator performance qualification testing. Fusing operator performance qualification testing is performed in accordance with XXVI-4341 and XXVI-4342 using 3-3 fusing procedures tested in accordance with XXVI-2300. Such fusing procedures define the electrofusion fitting material, pipe wall thickness, power supply and processor, to be used in production of each joint, so the fusing operator is already required to qualify using the same material and equipment. Therefore, the proposed wording of the paragraph (see Summary, below) involving performance qualification testing and reference to XXVI-4340 should be removed from that 10CFR50.55a paragraph.

10 CFR 50.55a(b)(1)(xi)(D) Mandatory Appendix XXVI: Fourth Provision The NRC is proposing to add a new paragraph (b)(1)(xi)(D), which will require both crush tests and electrofusion bend tests to qualify fusing procedures for electrofusion joints in polyethylene piping. The operating experience data on electrofusion joints is extremely limited and also indicates some failures. the NRC is also proposing to add a condition that requires that both tests (crush test and electrofusion bend test) specified in in XXVI-2332(a) and XXVI-2332(b) be performed as part of performance qualification tests, instead of only one or the other.

Comment: Crush testing is designed for smaller fittings 8 NPS and less. Such tests are impractical and unsafe for sizes larger than 8 NPS due to the large hydraulic equipment that would be required. For this reason, ASTM F1055 provides the electrofusion bend test (FET) as a means of verifying fusion integrity for sizes over 8 NPS. There is no evidence that either of these tests are inadequate for their intended purpose.

Every electrofusion socket joint installed in a nuclear system also requires producing and testing an identical coupon 3-4 using the same lot, size and thickness of material and fitting, the same equipment, the same power supply and the same fusing procedure under -2300 of Appendix XXVI. In addition, every electrofusion joint installed in a nuclear system requires data recording to verify the operator used the correct procedure, each joint receives full visual inspection, receives full volumetric examination of the fused joint plus hydrostatic testing at 1.5 times the design pressure. This proposed condition imposes significant cost, hardship and personnel safety issues without any improvement in quality.

10 CFR 50.55a(b)(1)(xi)(E) Mandatory Appendix XXVI: Fifth Provision The NRC is proposing to add a new paragraph (b)(1)(xi)(E), which prohibits the use of electrofusion saddle fittings and electrofusion saddle joints. some Department of Energy operational experience indicates that failures have occurred in electrofusion joints. The NRC has determined that the failure of a saddle type electrofusion joint could result in structural separation of the electrofusion saddle coupling from the HDPE pipe it is attached to, resulting in a potential loss of flow and loss of safety function in the system.

Comment: Unlike the failures identified by DOE - every electrofusion saddle joint installed in a nuclear system requires producing and testing an identical coupon using the same equipment and power supply under -2300 of Appendix XXVI. In addition, each installed saddle joint receives visual verification of fit-up gaps, alignment and 3-5 out-of-roundness, plus recording and verification of the actual fusing variables, plus full volumetric examination of the fused joint, plus a hydrostatic pressure test at 1.5 times the design pressure. Without the capability of using electrofusion saddle connections, necessary modifications to or repairs of existing installations could be cost prohibitive, imposing significant hardship without any improvement in quality or safety.

Summary Proposed 10CFR50.55a Provisions ASME Section III, Appendix XXVI, 2015 and 2017 Editions (xi) Section III condition: Mandatory Appendix XXVI. When applying the 2015 and 2017 Editions of Section III, Mandatory Appendix XXVI, Rules for Construction of Class 3 Buried Polyethylene Pressure Piping, applicants or licensees must meet the following conditions:

(A) Mandatory Appendix XXVI: First provision. When performing fusing procedure qualification tests and operator performance qualification tests in accordance with XXVI-4330 and XXVI-4340 the following essential variables shall be used for the performance qualification tests of butt fusion joints:

(1) Joint Type.

Requested change: Delete proposed requirement to impose this added testing for Fusing Operator performance qualification. Revise First Provision to read: When performing fusing procedure qualification testing in accordance 3-6 with XXVI-2300 and XXVI-4330 the following essential variables shall be used for the testing of butt fusion joints:

(1) Joint Type.

(This provision will be resolved for procedure testing with publication of the 2019 Edition of ASME Section III, Appendix XXVI.)

(B) Mandatory Appendix XXVI: Second provision. When performing qualification tests of butt fusion joints in accordance with XXVI-4342, both the bend test and the high speed tensile impact test shall be successfully completed.

Requested change: Second Provision. When performing procedure qualification HSTT testing of butt fusion joints in accordance with XXVI-2300 or XXVI-4330, specimen breaks away from the fusion zone shall require retesting.

3-7 When performing fusing operator qualification bend tests of butt fusion joints in accordance with XXVI-4342, guided side bend testing shall be used for all thicknesses greater than 1.25 inches.

(C) Mandatory Appendix XXVI: Third provision. When performing fusing procedure qualification tests and operator performance qualification tests in accordance with 2017 Edition of BPV Code Section III XXVI-4330 and XXVI-4340, the following essential variables shall be used for the performance qualification tests of electrofusion joints:

(1) Joint Design.

First provision will be resolved with publication of the 2019 Edition of Appendix XXVI.

Requested change: Second provision. When performing fusing procedure qualification tests in accordance with 2017 Edition of BPV Code Section III XXVI-2300 and XXVI-4330, the following essential variables shall be used for 3-8 the testing of electrofusion joints:

(1) Joint Design.

(This provision will be resolved for procedure testing with publication of the 2019 Edition of Appendix XXVI.)

(D) Mandatory Appendix XXVI: Fourth provision. Performance of crush tests in accordance with 2017 BPV Code Section III XXVI-2332(a) and XXVI-2332(b) and electrofusion bend tests in accordance with 2017 BPV Code Section III XXVI-2332(b) are required to qualify fusing procedures for electrofusion joints in polyethylene piping installed in accordance with 2017 Edition of ASME BPV Code Section III, Mandatory Appendix XXVI.

3-9 Requested change: Delete this provision.

(E) Mandatory Appendix XXVI: Fifth provision. Electrofusion saddle fittings and electrofusion saddle joints are not permitted for use. Only full 360-degree seamless sleeve electrofusion couplings and full 360-degree electrofusion socket joints are permitted.

3-10 Requested change: Delete this provision.

From: jimosul@sbcglobal.net To: RulemakingComments Resource Cc: Reichelt, Eric; Manoly, Kamal

Subject:

[External_Sender] NRC Proposed 50.55a Ruling Date: Friday, December 21, 2018 9:40:31 AM Attachments: Comments on Proposed Ruling Appendix XXVI (12-07-18).docx Attached please find a discussion, summary and suggested revisions on the proposed provisions to be imposed by the NRC on the 2015 and 2017 editions of ASME Section III, Appendix XXVI, Rules for Construction of Class III Buried Polyethylene Pressure Piping.

Contingent upon NRC agreement with these suggested revisions, the undersigned will commit to 3-11 initiating and promoting changes to incorporate them into future editions of Appendix XXVI.

Please advise if you have any questions.

Thank you very much, J. E. (Jim) OSullivan, PE Procon1, LLC (314) 221-1800

Submission ID 4 Carl Latiolais, Electric Power Research Institute ML19022A074

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(i) Applicable ISI Code: Initial 120-month interval. In-service examination of components and system pressure tests conducted during the initial 120-month inspection interval must comply with the requirements in the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section on the date 12 months before the date of issuance of the operating license under this part, or 12 months before the date scheduled for initial loading of fuel under a combined license under part 52 of this chapter (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, when using ASME BPV Code, Section XI, or NRC Regulatory Guide 1.192, when using the ASME OM Code, as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section, respectively), subject to the conditions listed in paragraph (b) of this section.

Licensees may, at any time in their 120-month ISI interval, elect to use the Appendix VIII in the latest edition and addenda of the ASME BPV Code incorporated by reference in paragraph (a) of this section, subject to any applicable conditions listed in paragraph (b) of this section. Licensees using this option must also use the same edition and addenda of Appendix I as Appendix VIII, including any applicable conditions listed in paragraph (b) of this section.



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Page 2 (ii) Applicable ISI Code: Successive 120-month intervals. In-service examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month inspection interval (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, when using ASME BPV Code, Section XI, or NRC Regulatory Guide 1.192, when using the ASME OM Code, as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose in-service inspection interval commences during the 12 through 18-month period after August 17, 2017, may delay the update of their Appendix VIII program by up to 18 months after August 17, 2017.

Alternatively, licensees may, at any time in their 120-month ISI interval, elect to use the Appendix VIII in the latest edition and addenda of the ASME BPV Code incorporated by reference in paragraph (a) of this section, subject to any applicable conditions listed in paragraph (b) of this section. Licensees using this option must also use the same Edition and Addenda of Appendix I as Appendix VIII, including any applicable conditions listed in paragraph (b) of this section.



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Digitally signed by Carl Latiolais DN: cn=Carl Latiolais, o=EPRI, ou=NDE Reliability, email=clatiola@epri.com, c=US Date: 2019.01.21 12:40:04 -05'00'

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RulemakingComments Resource From: Latiolais, Carl <clatiola@epri.com>

Sent: Monday, January 21, 2019 12:46 PM To: RulemakingComments Resource Cc: Feldman, Heather; Bouck, Robert; Kull, Doug; Cinson, Tony

Subject:

[External_Sender] EPRI Comments on the American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference, Proposed Rule, Docket ID NRC-2016-0082 Attachments: NDE20190117-001_10CFR50 Comments.pdf

Dear Sir or Madam:

The attached letter provides comments to the subject proposed rulemaking titled, American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference on behalf of the Nuclear Nondestructive Evaluation (NDE) Program at the Electric Power Research Institute (EPRI).

Regards

• • • This email message is for the sole use of the intended recipient(s) and may contain information that is confidential, privileged or exempt from disclosure under applicable law. Unless otherwise expressed in this message by the sender or except as may be allowed by separate written agreement between EPRI and recipient or recipients employer, any review, use, distribution or disclosure by others of this message is prohibited and this message is not intended to be an electronic signature, instrument or anything that may form a legally binding agreement with EPRI.

If you are not the intended recipient, please contact the sender by reply email and permanently delete all copies of this message. Please be advised that the message and its contents may be disclosed, accessed and reviewed by the sender's email system administrator and/or provider. ***

1

Submission ID 5 Glen Palmer, Private Citizen ML19022A277

Page 1 of 1 83FR56156 5 PR-50 As of: 1/22/19 11:38 AM Received: January 18, 2019 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k3-97r7-tuqf Comments Due: January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0007 Comment on FR Doc # 2018-24076 Submitter Information Name: Glen Palmer Address:

1906 Lake Peninsula Drive Hixson, TN, 37343 Email: glenpcha@aol.com General Comment Comments to proposed rulemaking incorporating 2015-2017 OM Code Editions (See Attached)

Attachments Palmer_Rulemaking comments_011819 https://www.fdms.gov/fdms/getcontent?objectId=09000064839fa90f&format=xml&showorig=false 01/22/2019

Rulemaking comments to 20152017 Edition NRC20160082 Glen Palmer Comments January 18, 2019 It has been observed that the wording in the proposed Rulemaking does not clearly identify requirements for examination and testing of dynamic restraints, (snubbers) to be a part of IST, 50.55a(f)(4) Inservice testing vs. ISI, 50.55a(g) Preservice and inservice inspection requirements and will require some changes for clarity. Below are the proposed changes that have been discussed at industry meetings and are now sent to the NRC for consideration.

Background:

The NRC has already identified a clear path for snubbers to be considered a part of IST along with pumps and valves in RG 1.192.

In 1990, the ASME published the initial edition of the OM Code that provides rules for IST and inservice examination of pumps, valves, and dynamic restraints (snubbers). The OM Code was developed and is maintained by the ASME Committee on Operation and Maintenance of Nuclear Power Plants. The OM Code was developed in response to the ASME Board on Nuclear Codes and Standards directive that transferred responsibility for development and maintenance of rules for the IST and inservice examination of pumps, valves, and dynamic restraints (snubbers) from the ASME Section XI Subcommittee on Nuclear Inservice Inspection to the ASME OM Committee. The ASME intended the OM Code to replace Section XI rules for IST and inservice examination of pumps, valves, and dynamic restraints (snubbers), and the Section XI rules for IST and inservice examination of these components that had been incorporated by reference into NRC regulations have been deleted from Section XI. The NRC endorsed the OM 5-1 Code for the first time in an amendment to 10 CFR 50.55a published on September 22, 1999 (64 FR 51370). The NRC endorsed OM Code Cases through this guide for the first time in June 2003.

It should be noted that the title of the OM Code was changed beginning with the 2009 Edition to Operation and Maintenance of Nuclear Power Plants.

Looking at 50.55a(g), the current pointer to 50.55a(f) is only for pumps and valves.

Requirements for inservice testing of Class 1, Class 2, and Class 3 pumps and valves are located in § 50.55a(f)

It does not identify dynamic restraints (snubbers).

Although the wording is unclear, the path from the ISI Code, Section XI Class 1, 2 and 3, to the ASME OM Code, Section IST is identified through paragraph 50.55a(g)(4), which does point to the ASME OM Code:

(4) Inservice inspection standards requirement for operating plants. Throughout the service life of a boiling or pressurized watercooled nuclear power facility, components (including supports) that are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions and addenda of the ASME BPV Code (or ASME OM for snubber examination and testing) that become effective subsequent to editions specified in paragraphs 1

(g)(2) and (3) of this section and that are incorporated by reference in paragraph (a)(1)(ii) or (iv) for snubber examination and testing of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components.

This clearly identifies the ASME OM Code for dynamic restraints (snubbers), which includes ISTA1100 and the scoping of non Class 1, 2 and 3 supports. The current pointer from 50.55a(g)(4) to ASME OM Code identifies snubbers to be under the ASME OM Code.

ISTA1100 Scope Section IST establishes the requirements for preservice and inservice testing and examination of certain components to assess their operational readiness in lightwater reactor nuclear power plants. It identifies the components subject to test or examination, responsibilities, methods, intervals, parameters to be measured and evaluated, criteria for evaluating the results, corrective action, personnel qualification, and record keeping. These requirements apply to (a) pumps and valves that are required to perform a specific function in shutting down a reactor to the safe shutdown condition, in maintaining the safe shutdown condition, or in mitigating the consequences of an accident (b) pressure relief devices that protect systems or portions of systems that perform one or more of the three functions identified in subpara. ISTA1100(a)

(c) dynamic restraints (snubbers) used in systems that perform one or more of the three functions identified in subpara. ISTA1100(a), or to ensure the integrity of the reactor coolant pressure boundary When the NRC publishes the new Rulemaking, dynamic restraints (snubbers) should be identified along with pumps and valves under 50.55a(f), for added clarity.

Below is a suggested markup to the proposed Rulemaking to accomplish this change.

50.55a(f)(4) Inservice testing standards requirement for operating plants. Throughout the service life of a boiling or pressurized watercooled nuclear power facility, pumps, valves and dynamic restraints (snubbers) that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs (f)(2) and (3) of this section and that are incorporated by reference in paragraph (a)(1)(iv) of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The inservice test requirements for pumps, valves and dynamic restraints (snubbers) that are within the scope of the ASME OM Code but are not classified as ASME BPV Code Class 1, Class 2, or Class 3 may be satisfied as an augmented IST program in accordance with paragraph (f)(6)(ii) of this section without requesting relief under paragraph (f)(5) of this section or alternatives under paragraph (z) of this section. This use of an augmented IST program may be acceptable provided the basis for deviations from the ASME OM Code, as incorporated by reference in this section, demonstrates an acceptable level of quality and safety, or that implementing the Code provisions would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, where documented and available for NRC review.

2

50.55a(g) Preservice and inservice inspection requirements. Systems and components of boiling and pressurized watercooled nuclear power reactors must meet the requirements of the ASME BPV Code as specified in this paragraph. Each operating license for a boiling or pressurized watercooled nuclear facility is subject to the following conditions. Each combined license for a boiling or pressurized watercooled nuclear facility is subject to the following conditions, but the conditions in paragraphs (g)(4) through (6) of this section must be met only after the Commission makes the finding under §52.103(g) of this chapter. Requirements for inservice testing of pumps, valves and dynamic restraints (snubbers) are located in paragraph (f) of this section.

50.55a(g)(4) Inservice inspection standards requirement for operating plants. Throughout the service life of a boiling or pressurized watercooled nuclear power facility, components (including supports) that are classified as ASME Code Class 1, Class 2, and Class 3 must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of editions and addenda of the ASME BPV Code (or ASME OM Code for dynamic restraint (snubber) examination, and testing and service life monitoring) that become effective subsequent to editions specified in paragraphs (g)(2) and (3) of this section and that are incorporated by reference in paragraph (a)(1)(ii) or (iv) for snubber examination and testing of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Components that are classified as Class MC pressure retaining components and their integral attachments, and components that are classified as Class CC pressure retaining components and their integral attachments, must meet the requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the ASME BPV Code and addenda that are incorporated by reference in paragraph (a)(1)(ii) of this section, subject to the condition listed in paragraph (b)(2)(vi) of this section and the conditions listed in paragraphs (b)(2)(viii) and (ix) of this section, to the extent practical within the limitation of design, geometry, and materials of construction of the components.

3

Submission ID 6 Richard Porco, American Society of Mechanical Engineers ML19022A278

Page 1 of 2 6

83FR56156 PR-50 As of: 1/22/19 11:49 AM Received: January 22, 2019 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k3-97ts-epep Comments Due: January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0008 Comment on FR Doc # 2018-24076 Submitter Information Name: Christian Sanna Address:

ASME Two Park Avenue New York, NY, 10016 Email: sannac@asme.org General Comment ASME is pleased to have the opportunity to provide comments and suggestions on your Nuclear Regulatory Commission (NRC), 10 CFR Part 50, RIN 3150-AJ74, Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, Proposed Amended Requirements, published in Reference 1.

A complete cover letter statement and comments are contained in the attached file.

https://www.fdms.gov/fdms/getcontent?objectId=0900006483a00478&format=xml&showorig=false 01/22/2019

Page 2 of 2 Attachments ASME Comments 10CFR50Rule https://www.fdms.gov/fdms/getcontent?objectId=0900006483a00478&format=xml&showorig=false 01/22/2019

Tw<J Park Av .. nut tel 1.212.r;qJ.8'.>00

<'W York, NY f ax 1. 2 1 2 . ','ll.8S01 SETTING rHE STANDARD o o 1 f, - o If . <;

• A

• l ', 'l <J www.asm t. org January 21 , 2019 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemakings and Adjudications Staff

Subject:

Comments on Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, 10 CFR Part 50, RIN 3150-AJ74

Reference:

1. Federal Register I Vol. 83, No. 218, pp. 56156-56196 / Friday, November 9, 2019 / Proposed Rule

Dear Sir or Madam:

ASME is pleased to have the opportunity to provide comments and suggestions on your Nuclear Regulatory Commission (NRG) , 10 CFR Part 50, RIN 3150-AJ74, Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, Proposed Amended Requirements, published in Reference 1.

Specifically, ASME supports the NRC's endorsement of later editions, addenda, and revisions to its Nuclear Codes, Standards, and Code Cases in the Code of Federal Regulations in 10 CFR 50.55a. It is our understanding that within this proposed rulemaking , the NRG is amending this regulation to incorporate by reference the following ASME Codes, Standards, and Code Cases:

1. The 2015 and 2017 Editions of Section Ill, Division 1 and Section XI, Division 1 of the ASME Boiler and Pressure Vessel (BPV) Code, with conditions

2. The 2015 and 2017 Editions of the ASME Operation and Maintenance (OM) Code, with conditions

3. ASME BPV Code Cases N-729-6 and N-770-5, with conditions The ASME comments included in Enclosure 1 are intended to support the nuclear industry while protecting the health and safety of the public, without placing unnecessary burden on licensees.

Thus, Enclosure-1 is provided for the use by the NRG staff to support, reconsider, remove, or modify its proposed (and existing) conditions where comments are provided . It is hoped that upon review of these ASME comments that the NRG staff will be able to allow the necessary changes to be made or modify the conditions in the final rule to such a degree as to fully endorse the ASME Nuclear Codes and Standards contained in this proposed rulemaking.

January 21 , 2019 Secretary, U.S. Nuclear Regulatory Commission Page2 If you have any questions concerning the contents of this letter, please direct them to Mr.

Christian Sanna, Director, ASME Nuclear Codes & Standards by telephone (212) 591-8513 or by e-mail SannaC@asme.org .

Very Truly Yours, Richard D. Porco, Chair ASME Board on Nuclear Codes and Standards richpor951@gmail.com

Enclosures:

1. ASME Comments on the Proposed Rule for 10 CFR 50 .55a cc: Michael Benson, USNRC (michael.benson@nrc.gov)

Officers of the ASME Board on Nuclear Codes and Standards Officers of the ASME Standards Committee on Nuclear lnservice Inspection Officers of the ASME Standards Committee on Construction of Nuclear Facility Components Officers of the ASME Standards Committee on Operation and Maintenance of Nuclear Power Plants

Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Rule, Federal Register, Vo l. 83, No. 218, pp. 56156-56196, Fri day, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (asofll/09/2018) (Chanees denoted by Boid Italics}

§50.55a(b)(1 )(x)(A) NIA Visual examination of bolts, studs, and nuts: First ASME believes that it is unnecessary to require personnel perform ing these provision. When applying the provisions of NB- examinations to be qualified in accordance with Section Ill (SNT-TC-1A). Similarly, 2582, NC-2582, ND-2582tNE-2582, NF-2582, NG- ASME believes that it is unnecessary to require visual examination procedures to 2582 in the 2017 Edition of Section Ill, the visual be qualified to Section V, Article 9. Indications detected by visual examination 6-1 examinations are required to be performed In personnel during these examinations would be directly identified and measured; accordance with procedures qualified to NB-5100, unlike other NOE methods where an evaluation of the indication is performed to NC-5100, ND-5100, NE-5100, NF-5100, NG-5100 determine acceptability.

and performed by personnel qualified In ASME believes that the proposed condition is unnecessary and should be removed.

accordance with NB-5500, NC-5500, ND-5500, NE-5500 NF-5500 and NG-5500.

§50 .55a(b)(1 )(x)(B) NIA Visual examination of bolts, studs, and nuts: The acceptance criteria in NB-2582, NC-2582, ND-2582, NE-2582, NF-2582, Second provision. When applying the provisions NG-2582 in the 2015 Edition of Section Ill are less prescriptive than those in the ofNB-2582,NC-2582,ND-2582,NE-2582,NF- 2017 Edition. For example, NB-2582 (2015 Edition) allows cracks that would not be 2582, NG-2582 In the 2017 Edition of Section Ill, detrimental to the intended service to be acceptable, but it is not clear how a the acceptance criteria from NB-2582, NC-2582, Material Organization wou ld know how to apply this criterion without knowing the ND-2582, NE-2582, NF-2582, NG-2582 in the intended service for the items.

2015 Edition of Section fl/ shall be used.

ASTM F788 "establishes allowable limits for the various types of surface 6-2 discontinuities that may occur during the manufacture and process of bolts, screws and studs ..." and is much more prescriptive than the requirements of NX-2582 (2015 Edition). The same is true regarding ASTM F812.

ASME believes that the proposed condition is inappropriate and should be removed. Alternatively, the condition could be revised lo require that the provisions of NB-2582, NC-2582, ND-2582, NE-2582, NF-2582, NG-2582 in the 2017 Edition of Section Ill be used when applying the acceptance criteria from NB-2582, NC-2582, ND-2582, NE-2582, NF-2582, NG-2582 in the 2015 Edition of Section Ill.

§50.55a(b)(1 )(xi)(A) NIA 1 Mandatory Appendix XXVI: First provision. When The NRC proposes to add a new condition, (b)(1)(xi)(A), which specifies the performing fusing procedure qualification tests and essential variables to be used in qualifying fusing procedures for butt fusion joints in operator performance qualification tests in polyethylene piping . This includes four (4) variables in addition to those stated in

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. accordance with XXV/-4330 and XXV/-4340 the following essential variables shall be used for the Section IX that are pertinent to the fusing verification testing of XXVl-2300. These are diameter, cross-sectional area, ambient temperature [range specified in XXVI-performance qualification tests of butt fusion 4412(b)], and fusing machine carriage model.

joints:

Previous discussions with the Regulator involving development and incorporation of (1) Joint Type: A change in the type ofjoint from Tables identifying all procedure variables applicable to testing required by Section 6-3 that qualified, except that a square butt joint IX and Appendix XXVI addressed only fusing procedure qualification and testing -

qualifies as a mitered Joint. not fusing operator performance qualification testing. However, the proposed amendment (xi)(A) under "PART 50-DOMESTIC LICENSING OF PRODUCTION (2) Pipe Surface Alignment: A change In the pipe AND UTILIZATION FACILITIES" includes applying these same essential variables outside diameter (0.D.) $Urface misalignment of to operator performance qualification.

more than 10 percent of the wall thickness of the thinner member to be fused. Fusing operator performance qualification testing is performed in accordance with XXVl-4341 and XXVl-4342 using fusing procedures tested in accordance with (3) PE Material: Each lot of polyethylene source mater/a/ to be used in production (XXVl-2310(c)). XXVl-2300. Such fusing procedures define the fusing machine make and model(s) to be used in production of each joint, so the fusing operator is required to qualify (4) Wall Thickness: Each thickness to be fused in on the same machines and models. However, fusina ocerators are aualified to use Page 1 of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) production (XXVl-2310(c)). those mach ines over ranges of diameters and thicknesses, not on each diameter to be fused. This is the approach that was approved by the USN RC as recently as two (5) Diameter: Each diameter to be fused In years ago for the Plant Hatch HDPE Project (ML15337A414). To require each production (XXVJ-2310(c)J-fusing operator to perform qualification testing on each diameter, thickness and lot (6) Cross-sectional Area: Each combination of of material would entail significant added expense and hardship without a thickness and diameter (XXVl-2310(c)). commensurate improvement in quality or safety.

(7) Position: Maximum machine carriage slope ASME recommends that the first paragraph of §50.55a(b}(1}(xi)(A) be revised to when greater than 20 degrees from horizontal read as follows:

(XXVl-4321(c)).

"Mandatory Appendix XXVI: First provision. When performing fusing procedure (8) Heater Surface Temperature: A change In the qualification testing in accordance with XXVl-2300 and XXVl- 4330 the following heater surface temperature to a value beyond the essential variables shall be used for the testing of butt fusion joints:"

range tested (XXVl-2321).

ASME notes that these requirements for fusing procedure testing will be addressed (9) Ambient Temperature: A change In ambient further with the publication of procedure testing changes in the 2019 Edition of temperature to Jess than 50 °F (10 °C) or greater ASME Section Ill, Appendix XXVI.

than 125 °F (52 ' CJ (XXVl-4412(b)).

(10) lnterfacial Pressure: A change In lnterfacial pressure to a value beyond the range tested (XXVI-2321).

(11) Decrease In Melt Bead Width: A decrease in melt bead size from that qualified.

(12) Increase in Heater Removal Time: An increase In heater*plate removal time from that qualified.

(13) Decrease In Cool-down Time: A decrease in the cooling time at pressure from that qualified.

(14) Fusing Machine Carriage Model: A change in I the fusing machine carriage model from that tested (XXVl-2310(d)).

§50.55a(b)(1 )(xi)(B) N/A / Mandatory Appendix XXVI: Second provision. The NRC proposes to add a new paragraph (b)(1)(xi)(B), which will require both

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When performing qualification tests of butt fusion bend tests and high speed tensile impact testing (HSTIT) to qualify fusing Joints in accordance with XXVl-4342, both t he bend procedures and to qualify fusing operators, for fusing joints in polyethylene test and the high speed tensile impact test shall be piping .... The explanation of the proposed ruling states : "The NRC has performed successfully completed. limited confirmatory research on the ability of short-term mechanical tests to predict the in-service behavior of HDPE butt fusion joints. Based on this research as well 6-4 as research results from the Welding Institute in the UK, the NRC lacks conclusive evidence that either of the two tests proposed in XXVl-4342(d) and XXVl-4342(e) is always a reliable predictor of joint quality. As a result, the NRC has determined that the combination of both test results provides increased and sufficient indication of butt fusion joint quality .. .. '

Comments:

1. Fusing Procedure Testing: Relative to joint testing for procedure qualification or XXVl-2300 fusing verification testing, the testing performed by The Welding Institute of UK indicated that the HSTI test mav not detect ioints fused with fine Page 2 of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) sand or talcum powder sized particles placed with in the joint. As a result of that testing , Paragraph XXVl-4412(a)(1) and XXVl-4412(a)(2) of Appendix XXVI

, specifically require that joint surfaces coming in contact with heaters must be protected and kept free of fine particulates, as well as other deleterious material.

Also, EPRI Report 3002005434 "Advanced Nuclear Technology: Literature Review of Mechanical Testing Methods to Evaluate the Integrity of HOPE Butt-Fusion Joints," was developed to assist the NRC with evaluation of mechanical testing methods. This report provides the results of limited studies on the comparison of the high speed tensile impact test to the guided side bend and waisted tensile test methods. This report identifies that situations can occur with the HSTI test where the specimen ruptures outside of the fusion zone while using the HSTI test method. If this occurs, a recommendation is provided for nuclear applications that the cause be evaluated by assessing the amount of increased fusion interface resulting from the fusion beads, and/or presence of out*of-roundness of the joined parts. (If there is indication of minimal or no increased fusion interface, or that mismatch exists between the parts being joined, the test should be re-performed with beads and mismatch removed.)

Therefore, this provision should be revised to instead requ ire retests for any HSTI ruptures occurring away from the fusion zone.

2. B. Fusing Operator Testing: Reverse bend testing has been used extensively and successfully for decades for the qualification of fusing operators in the U.S.

for joining polyethylene water and gas piping. Bend testing is endorsed by DOT for performance qualification for the fusing of interstate gas transmission pipelines as well as for local gas distribution pipelines (Ref. 49 CFR 192.285).

Government acceptance for use of only visual inspection of the test joint plus bend testing for performance qualification on volatile gas pipelines certainly supports its use for nuclear applications - where, in addition to the visua l inspection and bend testing, the joint parameters are also required to be I recorded and verified during preparation of the qualification test coupons as well as for each installed fusion joints. This is the approach that was approved by the USN RC as recently as two years ago for the Plant Hatch HOPE Project (ML

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15337A414). In addition, all installed nuclear fusion joints receive volumetric examination (ultrasonic or microwave) plus a hydrostatic test at 1.5 times maximum design pressure, validating the integrity of each joint fused by each operator. The additional requ irement to perform HST! test in addition to bend testing during performance qualification imposes additional hardship and increased cost without commensurate improvement in quality or safety.

Paragraph 7.4 of EPRI Report 3002005434 provides reasons why the reverse bend test might be considered unacceptable for nuclear applications. The stated reasons are inaccurate based on the following explanations:

a) Although ASTM F2620 lacks complete requirements for how to perform the reverse bend test including temperature range, Appendix XXVl-4342 invokes Section IX QF-143.1 which does provide explicit directions, including required temperature range.

b) Although ASTM F2620 may lack clarity on how to perform the test, Section IX ,

QF-143.1 which is invoked bv Aaaendix XXVI does provide specific Page 3of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Ru le, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§S0.55a Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations. Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) instructions on how to perform the test.

c) Although ASTM F2620 may lack clarity on test radii or coupon th ickness,

, Section IX, QF-143.1.3 and QF-463 provide explicit direction on how to cut the specimens and perform the test. The specimen th ickness, t, is the thickness of the joint per QF-463, and the bend radius is defined by the 151 dimension either side of the joint with the requirement to bend back until both 151 ends touch. This defines the ratio of thickness to bending length, which is a direct proportion regardless of what thickness is bent, and always results in a defined bending radius or arc at the apex of the tested joint of approximately

31. A 31 arc at the apex of the bend results in at least a 15% strain, which exceeds the 10-12% yield strain of HDPE material.

d) One test report identified by EPRI stated that Reverse Bend testing of 1.33 in.

thick 12 NPS PE pipe did not identify defects that were detected by HSTI testing and Guided Side Bend testing . With the advent of the GSB test, most fusing organizations are now using guided side bend tests in lieu of reverse bend tests for qualifying fusing operators on thick sections over 1.25 in. for personnel safety reasons. We suggest that the provision be reworded to address this specific concern when using reverse bend tests for thick sections as indicated in our revised wording, below.

Note: HSTI testing machines are quite scarce and expensive. For fusing procedure verification testing (XXVl-2300) the test specimens are typically sent to a laboratory or shop to have the HSTI testing performed. To require this be done for performance qualification purposes would add extra non-productive days for fusing operators, plus it would require sending quality control personnel for witnessing the off-site testing . Since the only technical issue seems to be an anomaly with one test performed on 1.33 in. thick material, a reasonable resolution would be to reword the provision to mandate use of side bend tests (i.e., prohibit use of reverse bend tests) for performance qualification on all piping thicknesses over 1.25 in.

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e) Based on the above inaccuracies, the EPRI report suggested that other tests be used in place of or in addition to the Reverse Bend Test. Considering the scarcity and expense of using HSTI test machines, imposing the condition to requ ire HSTI test in addition to Reverse Bend or Guided Side Bend testing for all performance qualification imposes excessive cost and additional hardship without a commensurate improvement in quality or safety.

ASME recommends that the proposed condition {§50.55a(b)(1}(xi)(B)] be re vised to read as follows:

"Mandatory Appendix XXVI: Second Provision. When performing procedure qualification HSTT testing of butt fus ion joints in accordance with XXVl-2300 or XXVl-4330, specimen breaks away from the fusion zone shall require retesting.

When performing fusing operator qualification bend tests of butt fusion joints in accordance with XXV/-4342, guided side bend testing shall be used for all thicknesses greater than 1. 25 inches."

Page4of 13

Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics)

§50.55a(b)(1 )(xi){C} N/A Mandatory Appendix XXVI: Third provision. When The NRC is proposing to add a new paragraph {b)(1 )(xi){C), which specifies the performing fusing procedure qualification tests and essential variables to be used in qualifying fusing procedures for electrofusion of operator performance quslificatlon tests in fusion joints in polyethylene piping that is to be installed in accordance with ASME accordance with 2017 Edition of BPV Code Section BPV Code, Section Ill, Mandatory Appendix XXVI. This includes four (4) variables Ill XXVl-4330 and XXVI- 4340, the fol/owing in addition to those stated in Section IX that are pertinent to the fusing verification essential variables shall be used for the testing of XXVl-2300. These are: fitting polyethylene material, pipe wall thickness, performance qualification tests of electrofuslon power supply, and processor.

joints: Previous discussions with the Regulator involving development and incorporation of (1) Joint Design: A change in the design of an Tables identifying all electrofusion procedure variables applicable to testing electrofusion Joint. required by Section IX and Appendix XXVI addressed only fusing procedure qualification and testing - not fusing operator performance qualification testing.

(2) Flt-up Gap: An Increase In the maximum radial However, the proposed amendment (xi)(C) under "PART 50-DOMESTIC flt-up gap qualified.

LICENSING OF PRODUCTION AND UTILIZATION FACILITIES" includes applying (3) Pipe PE Material: A change in the PE these same essential variables to operator performance qualification.

designation or cell classification of the pipe from Fusing operator performance qualification testing is performed In accordance with that tested ()(XVI- 2322(a)).

XXVl-4341 and XXVi-4342 using fusing procedures tested in accordance with (4) Fitting PE Material: A change in the XXVi-2300. Such fusing procedures define the electrofusion fitting material, pipe manufacturing facility or production lot from that wall thickness, power supply and processor, to be used in production of each joint, tested (XXVl-2322(b)). so the fusing operator is already required to qualify using the same material and (5) Pipe Wall Thickness: Each thickness to be fused equipment. Therefore, the proposed wording of the paragraph {see Summary, In production (XXVl-2310(c)). below) Involving performance qualification testing and reference to XXVl-4340 6-5 should be removed from that 10CFR50.55a paragraph.

(6) Fitting Manufacturer: A change in fitting ASME notes that these requirements for electrofusion procedure testing will be manufacturer.

addressed further with the publication of procedure testing changes in the 2019 (7) Pipe Diameter: Each diameter to be fused In Edition of ASME Section Ill, Appendix ><XVI.

production (XXVl-231Q(c)).

. (8) Cool-down Time: A decrease in the cool time at pressure from that qualified.

ASME recommends that the first paragraph of §50.55a(b}(1)(xi}(C) be revised to read as follows:

"Mandatory Appendix ><XVI: Third provision. When performing fusing procedure (9) Fusion Voltage: A change in fusion voltage.

- (10) Nominal Fusion Time: A change in the nominal qualification tests in accordance with 2017 Edition of BPV Code Section Ill ><XVI-2300 and XXVl-4330, the following essential variables shall be used for the testing

• fusion time. of electrofusion joints: "

(11) Material Temperature Range: A change in material fusing temperature beyond the range qualified.

(12) Power Supply: A change in the make or model of electrofuslon control box (XXVl-2310(f)).

(13) Power Cord: A change in power cord material, length, or diameter that reduces current at the coil to below the minimum qualified.

(14) Processor: A change in the manufacturer or model number of the processor. (XXVl-2310(f)).

(15} Saddle Clamp: A chanqe in the tvoe of saddle Page Sof 13

Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, Novemb er 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50,SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) clamp.

(16) Scraping Device: A change from a clean peeling scraofna tool to wny other tvoe of tool.

§50.55a(b}(1 }(xi)(D) NIA Mandatory Appendix XXVI: Fourth provision. Crush testing is designed for smaller fittings 8 NPS and less. Such tests are Performance of crush tests In accordance with impractical and unsafe for sizes larger than B NPS due to the large hydraulic 2017 BPV Code Section Ill XXVl-2332(a) and XXVI- equipment that would be requ ired. For this reason, ASTM F1055 provides the 2332(b) and electrofusion bend tests in accordance electrofusion bend test (FET) as a means of verifying fusion integrity for sizes over with 2017 BPV Code Section fl{ XXVl-2332{b) are B NPS. There is no evidence that either of these tests are inadequate for their required to qualify fusing procedures for intended purpose.

e/ectrofuslon Joints In polyethylene piping installed Every electrofusion socket joint installed in a nuclear system also requires 6-6 In accordance with 2017 Edition of ASME BPV CodE producing and testing an identical coupon using the same lot, size and thickness of Section Ill, Mandatory Appendix XXVI.

material and fitting , the same equipment, the same power supply and the same fusing _procedure under -2300 of Appendix X.XVI. In addition, every electrofusion joint installed in a nuclear system requires data recording to verify the operator used the correct procedure, each joint receives full visual inspection, receives full volumetric examination of the fused joint plus hydrostatic testing at 1.5 times the design pressure. This proposed cond ition imposes significant cost, hardship and personnel safety issues without any improvement in quality.

ASME recommends that the orooosed condition be removed in the final rule.

§50.55a(b)(1 ){xi)(E) NIA Mandatory Appendix XXVI: Fifth provision. The NRC is proposing to add a new paragraph (b)(1}(xi)(E), which prohibits the use Electrofusion saddle fittings and electrofusion of electrofusion saddle fittings and electrofusion saddle joints. Some Department of saddle joints are not permitted for use. Only full Energy operational experience indicates that failures have occurred in electrofusion 360-degree seamless sleeve electrofusion joints. The NRC has determined that the failure of a saddle type electrofusion joint couplings and full 360-degree electrofusion socket cou ld result in structural separation of the electrofusion saddle coupling from the joints are permitted. HDPE pipe it is attached to, resulting in a potential Joss of flow and toss of safety function in the system.

' Unlike the failures identified by DOE, every electrofusion saddle joint installed in a 6-7 nuclear system requires producing and testing an identical coupon using the same

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equipment and power supply under -2300 of Appendix XXVI. In addition, each

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installed saddle joint receives visual verification of fit-up gaps, alignment and out-of-roundness, recording and verification of the actual fusing variables, full volumetric examination of the fused joint, and a hydrostatic pressure test at 1.5 times the design pressure. Without the capability of using electrofusion saddle connections, necessary modifications to or repairs of existing installations cou ld be cost prohibitive, imposing significant hardship without any improvement in quality or safety.

ASME recommends that the proposed condition be removed in the final rule.

§50.55a(b)(2)(viii) (viii) Section XI condition: Concrete NIA This condition applies to the several older editions and addenda of Section XI that, containment examinations. Applicants or to the knowledge of ASME, are no longer in use in the United States.

6-8 licensees applying Subsection IWL, 1992 ASME recommends that the NRG consider removing applicable conditions that Edition with the 1992 Addenda, must apply apply to the 1992 Edition with the 1992 Addenda, and any later code editions and paragraphs (b)(2)(viii)(A) through (E) of this addenda th at are no lonaer in use bv anv U.S. olants.

Page 6 of 13

Enclosu re 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federa l Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §SO.SSa Regulations. Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) section. Applicants or licensees applying Subsection IWL, 1995 Edition with the 1996 Addenda, must apply paragraphs (b)(2)(viii)(A), ,

(b)(2)(viii)(D)(3), and (b)(2)(viii)(E) of this section. Applicants or licensees applying Subsection IWL, 1998 Edition through the 2000 Addenda, must apply paragraphs (b)(2)(viii)(E) and (F) of this section. Applicants or licensees applying Subsection IWL, 2001 Edition through the 2004 Edition, up to and includin g the 2006 Addenda, must apply paragraphs (b)(2)(viii)(E) through (G) of this section. Applicants or licensees applying Subsection IWL, 2007 Edition up to and including the 2008 Addenda must apply paragraph (b)(2)(viii)(E) of this section. Applicants or licensees applying Subsection JWL, 2007 Edition with the 2009 Addenda through the latest edition and addenda incorporated by reference in paragraph (a)(1)(ii) of this section, must apply oaraaraohs /bl/21/viiil/Hl and m of th is section.

§50.55a(b)(2)(viii)(A) (A) Concrete containment examinations: First NIA This condition applies only when using the 1995 Edition with the 1996 Addenda and provision. Grease caps that are accessible earlier editions/addenda of Section XI.

must be visually examined to detect grease ASME recommends that the NRG consider removing this condition because there leakage or grease cap deformations. Grease 6-9 caps must be removed for th is examination should be no U.S. plants still using the 1995 Edition with the 1996 Addenda or earlier editions/addenda of Section XI.

when there is evidence of grease cap deformation that indicates deterioration of anchoraae hardware.

§50.55a(b)(2)(viii)(B) (B) Concrete containment examinations: N/A This cond ition applies only when using the 1992 Edition with the 1992 Addenda of Second provision. When evaluation of Section XI.

consecutive surveillances of P.re-stressing ASME recommends that the NRG consider removing this condition because there forces for the same tendon or tendons in a should be no U.S. plants still using the 1992 Edition with the 1992 Addenda of group indicates a trend of pre-stress loss such 6-10 that the tendon force(s) would be less than the Section XI.

minimum design pre-stress requ irements before the next inspection interval, an evaluation must be performed and reported in the Engineering Evaluation Report as prescribed in IWL-3300.

§50.55a(b)(2)(viii)(C) (C) Concrete containment examinations: Third N/A This condition applies only when using the 1992 Edition with the 1992 Addenda of provision. When the elongation correspond ing Section XI.

6-11 to a specific load (adjusted for effective wires or ASME recommends that the NRG consider rem oving this condition because there strands) during re-tensioning of tendons differs should be no U.S. plants still using the 1992 Edition with the 1992 Addenda of by more than 1Opercent from that recorded Section XI.

during the last measurement, an evaluation Page 7 of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.55a Paragraph Existing §50.SSa Regulations Proposed Changes to §50 .SSa Regulations ASME Comments on §S0.5Sa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) must be performed to determine whether the difference is related to wire failures or slip of wires in anchorage. A difference of more than ,

10 percent must be identified in the ISi Summarv Reoort reauired bv IWA-6000.

§50.55a(b)(2)(viii)(D) (D) Concrete containment examinations: Fourth NIA This condition applies only when using the 1995 Edition with the 1996 Addenda and provision. The applicant or licensee must report earlier editions/addenda of Section XI.

the following conditions, if they occur, in the ISi ASME recommends that the NRG consider removing this condition because there Summary Report required by IWA-6000: should be no U.S. plants still using the 1995 Edition with the 1996 Addenda or (1) The sampled sheathing filler grease earlier editions/addenda of Section XI.

contains chemically combined water exceeding 6-12 1O percent by weight or the presence of free water; (2) The absolute difference between the amount removed and the amount replaced exceeds 1o percent of the tendon net duct volume; and (3) Grease leakage is detected during general visual examination of the containment surface.

§50. 55a(b)(2){ix) (ix) Section XI condition: Metal containment (ix) Section XI condition: Metal containment This condition applies to the several older editions and addenda of Section XI that, examinations. Applicants or licensees applying examinations. Applicants or licensees applying to the knowledge of ASME, are no longer in use in the United States.

Subsection IWE, 1992 Edition with the 1992 Subsection IWE, 1992 Edition with the 1992 Addenda, ASME recommends that the NRG consider removing applicable conditions that Addenda, or the 1995 Edition with the 1996 or the 1995 Edition with the 1996 Addenda , must apply to the 1992 Edition with the 1992 Addenda, and any later code editions and Addenda , must satisfy the requirements of satisfy the requirements of paragraphs (b)(2)(ix)(A) addenda that are no longer in use by any U.S. plants.

paragraphs (b)(2)(ix)(A) through (E) of this through (E) and (b)(2)(ix)(K) of this section. Applicants section. Applicants or licensees applying or licensees applying Subsection IWE, 1998 Edition Subsection IWE, 1998 Edition through the 2001 through the 2001 Edition with the 2003 Addenda, must Edition with the 2003 Addenda, must satisfy the satisfy the requirements of paragraphs {b)(2)(ix)(A) and requirements of paragraphs (b)(2)(ix)(A) and (B) (B) and (F) through (I) and (b)(2)(/x)(K) of this section.

and (F) through (I) of this section. Applicants or Applicants or licensees applying Subsection IWE, 2004 licensees applying Subsection,IWE, 2004 Edition , up to and including the 2005 Addenda, must 6-13 Edition, up to and including the 2005 Addenda, satisfy the requirements of paragraphs (b)(2)(ix)(A} and must satisfy the requirements of paragraphs (B) and (F) through (H) and (b)(2)(ix)(K) of this section.

(b)(2)(ix)(A) and (B) and (F) through (H) of this Applicants or licensees applying Subsection IWE, 2004 section. Applicants or licensees applying Edition with the 2006 Addenda, must satisfy the Subsection IWE, 2004 Edition with the 2006 requirements of paragraphs {b){2)(ix)(A)(2) and Addenda, must satisfy the requirements of (b)(2)(ix)(B) and (b)(2)(/x)(K) of this section. Applicants paragraphs (b){2)(ix)(A)(2) and (b)(2)(ix)(B) of or licensees applying Subsection IWE, 2007 Edition this section . Applicants or licensees applying through the 2015 Edition must satisfy the Subsection IWE, 2007 Edition through the latest requirements of paragraphs (b)(2)(ix)(A)(2) and edition and addenda incorporated by reference (b)(2J(lx)(B) and (J) and (K) of this section.

in paragraph (a)(1 )(i i) of this section, must Applicants or licensees applying Subsection /WE satisfy the requirements of paragraphs 2017 Edition must satisfy the requirements of (b)(2)(ix){A)(2) and (b)(2)(ix)(B) and (J) of this paragraph (b)(2)(ix)(A)(2) and (b)(2)(ix)(B) and ll) of section. this section.

Page 8 of 13

Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-20 16-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §S0.55a Regulations* Existing and Proposed Changes (asofll/09/2018) (Changes denoted by Bold Italics)

§50.55a(b)(2)(ix)(C) (C) Metal containment examinations: Th ird No changes proposed. This condition applies only when using the 1995 Edition with the 1996 Addenda and provision. The examinations specified in earlier editions/addenda of Section XI.

6-14 Examination Category E-8, Pressure Retaining Welds, and Examination Category E-F, ASME recommends that the NRG consider removing this condition because there should be no U.S. plants still using the 1995 Edition with the 1996 Addenda or Pressure Retaining Dissimilar Metal Welds, are earlier editions/addenda of Section XI.

ootional.

§50.55a(b)(2)(ix)(D) (D) Metal containment examinations: Fourth No changes proposed. This condition applies only when using the 1995 Edition with the 1996 Addenda and provision. This paragraph (b)(2)(ix)(D) may be earlier editions/addenda of Section XI.

used as an alternative to the requirements of ASME recommends that the NRG consider removing this condition because there IWE- 2430. If the examinations reveal flaws or should be no U.S. plants still using the 1995 Edition with the 1996 Addenda or areas of degradation exceeding the acceptance earlier editions/addenda of Section XI.

standards of Table IWE- 3410- 1, an evaluation must be performed to determine whether additional component examinations are required. For each flaw or area of degradation identified that exceeds acceptance standards, the applicant or licensee must provide the following in the ISi Summary Report required by IWA-6000:

6-15 (1) A description of each flaw or area, including the extent of degradation, and the conditions that led to the degradation; (2) The acceptability of each flaw or area and the need for additional examinations to verify that similar degradation does not exist in similar components; (3) A description of necessary corrective actions; and (4) The number and type of ~dditional examinations to ensure detection of similar dei:iradation in similar components.

§50.55a(b)(2)(ix)(E) (E) Metal containment examinations: Fifth No changes proposed. This condition applies only when using the 1995 Edition with the 1996 Addenda and provision. A general visual examination as earlier editions/addenda of Section XI.

6-16 requ ired by Subsection IWE must be performed once each period.

ASME recommends that the NRG consider removing this condition because there should be no U.S. plants still using the 1995 Edition with the 1996 Addenda or earlier editions/addenda of Section XI.

§50.55a(b)(2)(xx)(B) (B) System leakage tests: Second provision. (B) System leakage tests:,Second provision. The ASME continues to believe that this condition is unnecessary for reasons The NOE provision in IWA-4540(a)(2) of the nondestructive examination method and documented in our letter dated November 30, 2015 to Secretary, U.S. Nuclear 2002 Addenda of Section XI must be applied acceptance criteria of the 1992 or later of Section Regulatory Commission, Washington, DC 20555-0001,

Subject:

Comments on 6-17 when performing system leakage tests after Ill shall be met when performing system leakage Incorporation by Reference of American Society of Mechanical Engineers Codes repair and replacement activities performed by test (In lieu of a hydrostatic test) in accordance and Code Cases, 10 CFR Part 50, RIN 3150-Al97.

welding or brazing on a pressure retaining with IWA-4520 after repair and replacement If the NRG retains this condition in the final rule, ASME recommends that the boundary using the 2003 Addenda through the activities performed by welding or brazing on a followina editorial chanaes be incoroorated:

Page 9 of13

Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Ru le, Federal Register, Vol. 83, No. 218, pp, 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations. Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) latest edition and addenda incorporated by pressure retaining boundary using the 2003

1. Revise "1992 or later" to read "1992 Edition or later editions .. ."

reference in paragraph (a)(1)(ii) of this section. Addenda through the latest edition and addenda of Section XI lncorporate<j by reference in 2. In the last sentence, insert "program" after "ISi".

paragraph (a)(1)(il) of this section. The nondestructive examination and pressure testing may be performed using procedures and personnel meeting the requirements of the licensee's/applicant's current ISi code of record,

§50.55a(b)(2)(xxv) (xxv) Section XI condition: Mitigation of defects (xxv) Section XI condition: Mitigation of defects by ASME would like to thank the NRG for reevaluating the changes made to IWA-4340 by modification. The use of the provisions in modification. The use of the provisions in IWA-4340 , published in the 2011 Addenda .

IWA-4340, "Mitigation of Defects by shall be subject to the following conditions:

ASME has no comments on the new paragraph (b)(2)(xxv)(A), which continues the Modification," Section XI , 2001 Edition through (A) Mitigation of defects by modification: First prohibition of IWA-4340 in Editions and Addenda prior to 2011 Addenda.

the latest edition and addenda incorporated by provision. The use of the provisions for reference in paragraph (a)(1 )(ii) of this section For new paragraph (b)(2)(xxv)(B), ASME has no comments on the first and second mitigation of defects by modification in IWA-4340 are prohibited. proposed conditions.

of Section XI 2001 Edition through the 2010 Addenda, Is prohibited. Regarding the proposed third condition in {b)(2)(xxv) {B) , ASME has no comments regarding performing wall thickness examinations every refueling outage for (B) Mitigation of defects by modification:

modifications installed in accessible locations. However, for modifications installed Second provision. The use of the provisions for in inaccessible locations (e.g. buried piping , piping encased in concrete, etc.),

mitigation of defects by modification in IWA-4340 ASME believes that requ iring examinations to be performed every refueling outage of Section XI 2011 Edition through the 2017 is onerous. The excavation costs and the risk of damage to the piping system to Edition may be used subject to the following perform these examinations far outweigh the small increase in safety as a result of conditions:

examination at the modification. Instead, corrosion rates can be validated at (1) The use of the provisions in IWA-4340 to accessible degraded locations, in the same piping system, to confirm the design mitigate crack-llke defects or those associated corrosion rates for the inaccessible locations. Examinations performed to validate 6-18 with flow accelerated corrosion are prohibited. corrosion rates are prudent. However, ASME believes those examinations should be conducted at one half of the remaining expected life of the modification, or every (2) The design of a modification that mitigates a ten years from the date of installation, whichever is more frequent.

defect shall incorporate a loss of material rate either 2 times the actual measured corrosion rate ASME recommends that this condition be revised to read as follows:

In that pipe location (established based on wall "For accessible locations, the Owner shall perform wall thickness examinations in thickness measurements conducted at least twice the vicinity of the modification and relevant pipe base metal to detect propagation ol in two prior consecutive or nonconsecutive the flaw info the material credited for structural integrity of the item. For inaccessible refueling outage cycles In the 10 year period prior locations (e.g. buried, encased in concrete, etc.}, the Owner may validate flaw to lnstallatlon of the modification, or 4 times the growth by performing examinations at an accessible degraded location in the same estimated maximum corrosion rate for the piping system. Examinations shall be performed every refueling outage unless /he actual system.

flaw growth is validated by examination in two consecutive refueling outages.

The Owner shall perform a wall thickness For inaccessible locations, the Owner shall also perform wall thickness examination In the vicinity of the modification and examinations in the vicinity of the modification and relevant pipe base metal to relevant pipe base metal during each refueling detect propagation of the fla w into the material credited for structural integrity of the outage cycle to detect propagation of the flaw into item. These examinations shall be performed prior to exceeding one half of the the material credited for structural integrity of the expected life of the repair, or at least once every ten years, whichever occurs first. "

item unless the examinations In the two refueling outage cycles subsequent to the installation of the modification are capable of val/dating the Proiected flaw arowth.

Page 10 of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket 10 NRC-2016-0082

§50.SSa Paragraph Existing §S0.55a Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (asofll/09/2018) (Changes denoted by Bold Italics)

§50.55a(b)(2)(xxvi) (xxvi) Section XI condition : Pressure testing (xxvl) Section XI condition: Pressure testing Class ASME continues to believe that this condition is unnecessary and offers the Class 1, 2 and 3 mechanical joints. The repair 1, 2 and 3 mechanical joints. When using the 2001 following comments regarding this condition:

and replacement activity provisions in IWA- Edition through the latest' edition and addenda 1. The revised system leakage test requirements in the 1999 Addenda and later 4540(c) of the 1998 Edition of Section XI for incorporated by reference in paragraph (a)(1)(ii) of editions and addenda are consistent with the construction requirements for pressure testing Class 1, 2, and 3 mechanical this section, licensees shall pressure test mechanical joint leakage in Section Ill of the ASME Code. Section Ill does not joints must be applied when using the 2001 mechanicalJoints In Class 1, 2, and 3 piping and prohibit leakage at mechanical connections, and requ ires only that mechanical Edition through the latest edition and addenda components greater than NPS-1 which are connection leakage not mask other leakage.

incorporated by reference in paragraph (a)(1 )(ii) disassembled and reassembled during the of this section. performance of a Section XI activity (e.g., Operators and system engineers periodically monitor systems for leakage and repair/replacement activity), in accordance with evaluate if corrective action is warranted when leakage is identified.

IWA-5211(a). The pressure test and examiners Post-maintenance test programs required by operating plants' current licensing shall meet the requirements of the bases specify requirements for leak testing mechanical connections following licensee's/applicant's current ISi code of record. reassembly. Section XI does not provide any acceptance criteria for mechanical joint leakage following reassembly, and it has always been the responsibility of licensees to determine if correclive action is warranted.

ASME does agree with the NRC that there is much confusion in the industry regarding this condition, and agree that the NRC should clarify, in detail, their position on what repair/replacement activities affecting mechanical joi nts requ ire pressure testing. However, ASME does not believe the proposed amendment to 10 CFR 50.55a(b)(2)(xxvi) will accomplish that goal, and may actually cause 6-19 additional confusion. The proposed amendment states in part "..all mechanical joints ... that are disassembled and reassembled during the performance of a Section XI activity ... shall be pressure tested ... " This statement can be read to apply to a flanged piping spool removed simply to provide access to the portion of a component subject to a repair/replacement activity, to replace gasketing, or to apply to that same flanged spool piece removed to perform a repa ir/replacement activity on the piping between the flanges. In the 1998 I Edition and earlier Editions, ASME wou ld consider the flanges in both of these scenarios to be exempt from pressure testing. It is not clear what the NRC intends for this condition to accomplish because the NRC appears to take

/

exception to some ASME interpretations, and those exceptions are not clearly identified.

In the Analysis of Public Comments for the final rule incorporating the 2013 Edition (ML16130A531), the NRC indicates it disagrees with interpretation Xl 10-20, which exempts bolting replacements from pressure testing. Other than some Informal discussions and correspondence with the ASME , that is the only place where the NRC states that position. In the same document, the NRC indicates that items rotated from stock (IWA-4132) are also subject to pressure testing. Th is issue is further confused because Reg. Guide 1.147 approves Case N-508-4 with no limitation regard ing pressure testing (N-508-4 takes exception to all of IWA-4000, including IWA-4540, and therefore 10 CFR 5D.55a(b)(2)(xxvi) doesn't apply).

2. This condition takes exception to ASME Section in XI in that it mandates that a pressure test and VT-2 visual examination be performed following performance of a reoair/reolacement activitv when the mechanical connection of an item is Page llof 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) (Changes denoted by Bold Italics) disassembled and subsequently reassembled , even if the repair/replacement activity does not involve the repair or replacement of items within the

, mechanical joint. Moreover, as worded, this condition would require a pressure test and VT-2 visual examination if the repair/replacement activity involves only the replacement of a single fastener, regardless of the reason the fastener is replaced when the item is disassembled. ASME notes that mechanical joints that are disassembled and reassembled for a maintenance activity (e.g., gasket replacement} would not be affected by the proposed condition, provided the mechanical joint is reassembled using no replacement items.

The ASME IIi and XI committees have determined that there is no need to perform a pressure test following a repair/replacement activity where the mechanical connection was disassembled and reassembled as bolts, studs, nuts, and washers are specifically exempted from pressure testing.

For inslallation into a Code Class (1, 2, 3) system, plants use components that are procured as Quality Related in accordance with a QA program and require the items meet material standards, codes, etc. and are subject to additional NOE and testing before being utilized. This provides reasonable assurance that the materials are free of defects and will perform their function during operation.

In the case of valves, pumps, manufactured piping assemblies (ASME Ill stamped}, etc. designed and fabricated to a code or design specification provided by the owner, and pressure testing is already required of these items.

Whenever maintenance is performed that requires an item to be disassembled, regardless if it includes an ASME XI repair/replacement activity, a leakage check is performed utilizing plant operators to inspect for leakage during post-maintenance testing / return to service (PMT/RTS) activilies. Verifying no leakage is just one of the many observations they perform to assure the item is functioning as expected before considering it operable. Adding a requirement

' to include a VT-2 examiner, and in some cases an ANII, does not increase the level of public safety and it does not support ALARA goals in those areas of the

~

. plant where radiation is present. The proposed condition will cause expose additional personnel to unnecessary radiological dose with no added safety benefit because the mechanical connection is already being inspected by an operator whose training involves the ability to know how the equipment operates and to identify leakage or other abnormal conditions during their normal work duties. Additionally, the mechanical connection is disassembled and reassembled by personnel trained to perform the activity, including use of industry standard bolt torqueing guidance to assure proper integrity of the joint.

While Reactor Coolant System leakage is always a concern and each utility has requirements to address th is leakage, ASME is unaware of any precedence where a mechanical connection has catastrophically failed which would be cause for requiring additional visual scrutiny of the mechanical connection by a VT-2 examiner, including the need for use of an ANII. In cases where a condition of leakage has been identified during PMT/RTS activities (within or outside the ASME Section XI program boundaries}, the mechanical connections had no catastrophic failure and conditions were corrected to eliminate the Page 12 of 13

Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule, Federal Register, Vol. 83, No. 218, pp . 56156-56196, Friday, November 9, 2018, Docket ID NRC-20 16*0082

§50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations - Existing and Proposed Changes (as of 11/09/2018) [Changes denoted by Bold ltallcsl cause of unacceptable leakage. The leakage can be identified without the need for the added burden of using a VT-2 examiner and an ANII.

> As an additional consideration for removal of the cond ition, plants implementing 10 CFR 50.69 would be implementing an inspection and repair program that is in lieu of ASME XI and 10 CFR 50.55(a). Implementation of 50.69, would require pressure testing per construction code requirements and does not require a VT-2 pressure test following a welded or mechanical repair/replacement activity. The NRG has found th is approach to be acceptable when implementing this alternative regulation and should remain consistent with requirements within 5D.55(a).

ASME recommends that this condition be removed from the final rule. If this recommendation is not accepted, then ASME recommends that 10 CFR 50.55a(b) (2) (xxvi) be revised to specifically /isl the repair/replacement activities for which the NRG requires a pressure test following assembly or reassembly of a mechanical joint. That is, the NRG should clarify whether this condition specifically applies when only bolting is replaced, an item rotated from stock is installed in a mechanical joint, and when a mechanical joint is assembled or reassembled to perform a repair/replacement activity that does not affect pressure reta ining parts of the mechanical joint (e.g. mechanically removing a valve bonnet to replace the valve disc) , etc.

§50.55a(g)(6)(ii)(D)(5) NIA (5) Peening. In lieu of inspection requirements of ASME understands that the proposed condition will require that MRP-335-3A be Table 1, Items B4.50 and 84.60, and all other followed (with the exception of NRC condition 5.4) in order for a licensee to avoid requirements in ASME BPV Code Case N-729-6 having to seek relief from the req uirements ofTable 1 for a RPV upper head with pertaining to peening, In order for a RPV upper nozzles and associated J-groove welds that are mitigated by peening.

head with nozzles and associated J-groove welds, ASME recommends that the condition be clarified to specify that the Extent and 6-20 mitigated by peening to obtain inspection relief Frequency of Examination for Items 84.50 and 84.60 shall comply with the from the requirements of Table 1 for unmitigated requirements of Code Case N-729-6, Table 1.

1 heads, peening must meet the performance criteria qualification and inspection requirements stated In ASME also recommends that the word "inspection" in the first sentence be changed MRP-335, Revision 3-A, with the exception that a to "examination ".

- plant-specific alternative request Is not required

• and NRC condition 5.4 of MRP-335, Revision 3-A does not aoolv.

§50 .55a(g)(6)(ii)(F)( 15) NIA (15) Cracked excavate and weld repair. In lieu of In the explanation section of the proposed rule the staff indicates there is the examination requirements for cracked welds insufficient technical basis to support the difference in inspection frequency with 360 excavate and weld repairs, Inspection Item between N-1 and M-2 welds. As is noted in the Case and technical basis for the N-1 of Table 1, welds shall be examined during the EWR repair method, the N-1 repair is a full 360-degree repair with stress reversal, 6-21 first or second refueling outage following EWR.

Examination volumes that show no indication of which should preclude flaw growth. Stress reversal does not occur for M-2 weld EWR. ASME believes that this key technical difference should allow the use of the crack growth or new cracking shall be examined sampling strategy as provided in the Case for N- 1 EWR.

once each inspection lnteNal thereafter.

For this reason. ASME believes that the proposed condition is unnecessary and recommends that the orooosed condition be removed from the final rule.

Page 13 of 13

Submission ID 7 Richard Deopere, Private Citizen ML19024A023

83FR56156 7 PR-50 RulemakingComments Resource From: Deopere, Richard A. <Richard.Deopere@xenuclear.com>

Sent: Thursday, January 24, 2019 1:10 AM To: RulemakingComments Resource

Subject:

[External_Sender] Comments on Proposed Rulemaking applicable to 10 CFR 50.55a Attachments: Comments on Proposed Rulemaking - FR - Vol 83 - No 218 - 56156.docx

Dear Sir or Madam,

I respectfully submit the attached comments to proposed rulemaking related to ASME Codes and Standards for 10 CFR 50.55a for your consideration.

Reference Federal Register, Vol. 83, No. 218, pp. 5615656196, Friday, November 9, 2018, Docket ID NRC20160082.

Respectfully, Richard Deopere Brooklyn Park, MN 1

NRC Proposed Change, 10 CFR 50.55a paragraph Condition, and/or Provision Reviewer comments 50.55a(b)(2)(xxvi) Section XI condition: Pressure I respectfully recommend that the NRC delete the testing Class 1, 2, and 3 current and proposed condition to (xxvi) as applicable mechanical joints. When using to mechanical joints for the reasons stated below.

the 2001 Edition through the latest edition and addenda There is no practical need to impose a requirement to incorporated by reference in perform a pressure test with a VT-2 examination on a paragraph (a)(1)(ii) of this mechanical joint to detect leakage when the section, licensees shall equivalent outcome can be fulfilled with a leak pressure test mechanical inspection by knowledgeable personnel, such as joints in Class 1, 2, and 3 operations, maintenance, instrument and controls, piping and components engineering staff, etc., during post-maintenance greater than NPS-1 which are testing (PMT) and return to service (RTS) activities.

disassembled and Oftentimes, these same knowledgeable personnel are reassembled during the already present at the component location when the 7-1 performance of a Section XI system is put into the conditions required for activity (e.g., PMT/RTS, so adding a VT-2 examiner, as well as the repair/replacement activity), in likelihood of an Inspector from an Authorized accordance with IWA-5211(a). Inspection Agency, increases the number of personnel The pressure test and to meet the existing and proposed requirement in examiners shall meet the order to achieve the same desired outcome.

requirements of the licensees/applicants current Industry practice during PMT/RTS activities requires ISI code of record. that pressure retaining components that have been disassembled and reassembled are checked to verify that no leakage is present at operating conditions, with exception of those connections that are designed for a certain amount of leakage, such as some pump seals, valve packing leakoff connections, etc.; components with those specific exceptions are checked to verify the leakage is at the appropriate level to perform its function as determined by the Owner requirements.

NRC Proposed Change, 10 CFR 50.55a paragraph Condition, and/or Provision Reviewer comments ASME Section XI IWA-4540(c), 2002 Addenda of the 2001 Edition and later, requires pressure testing requirements of the Construction Code to be met for a repair/replacement activity. The NRC should not impose the additional requirements stated in this condition for mechanical joints, as they are in excess of the Construction Code requirements.

The stated provision to perform a pressure test and VT-2 examination on mechanical joints, which will likely require concurrent witnessing of the examination by an Inspector from an Authorized Inspection Agency, does not provide an increased level of quality or safety, and further imposes undue burden on the licensee to provide the desired outcome to identify leakage or verify no leakage.

By imposing an unnecessary requirement to perform pressure testing and VT-2 examination to detect leakage, the stated provision unnecessarily increases the number of involved personnel needed to perform an examination. This results in an increased risk potential for personnel injury, an increase in required amount of documentation, work preparation, and record keeping; an increase to personnel radiological dose (in opposition to ALARA principles); an increased potential for Code and regulatory non-conformance /

non-compliance; and increase to the financial costs associated with implementing the stated provision.

Submission ID 8 Edward Cavey, Private Citizen ML19024A529

Page 1 of 2 83FR56156 8 PR-50 As of: 1/24/19 1:45 PM Received: January 22, 2019 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k3-97tx-llg9 Comments Due: January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0009 Comment on FR Doc # 2018-24076 Submitter Information Name: Edward Cavey Address:

13311 Kettler rd Needville, TX, 77461 Email: wufflek@gmail.com General Comment Comment on Proposed 10CFR50.55a Rulemaking Section C ASME OM Code 10 CFR 50.55a(b)(3)(xi) OM Condition: Valve Position Indication The NRC proposes to amend 50.55a(b)(3)(xi) for the implementation of paragraph ISTC3700, Position Verification Testing, in the ASME OM Code to apply to the 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in 50.55a(a)

(1)(iv). This will allow future rulemakings to revise 50.55a(a)(1)(iv) to incorporate the latest edition and addenda of the ASME OM Code without the need to revise 50.55a(b)(3)(xi). In addition, the NRC proposes to clarify that this condition applies to all valves with remote position indicators within the scope of Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, including MOVs within the scope of Mandatory https://www.fdms.gov/fdms/getcontent?objectId=0900006483a0155c&format=xml&showorig=false 01/24/2019

Page 2 of 2 Appendix III, Preservice and Inservice Testing Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants. ISTC3700 references Mandatory Appendix III for valve position testing of MOVs. The development of Mandatory Appendix III was intended to verify valve position indication as part of the diagnostic testing performed on the intervals established by the appendix. This clarification will ensure that verification of valve position indication is understood to be important for all valves with remote position indication addressed in Subsection ISTC and all of its mandatory appendices.

Comment: The intent of this OM Condition is well understood by the industry and several plants have implemented the ASME OM Code 2012 Edition, including the Valve Position Indication requirements specified in the condition. At those plants, valves with remote position indication, other than MOVs, supplemental position verification activities are performed at a two year interval as required by ISTC-3700. Most plants have voluntarily included MOVs in the scope of supplemental position verification. For some MOVs the periodic diagnostic testing (DIAG) in accordance with Appendix III-3300 is utilized as the method for supplemental position verification. Such testing may be performed at intervals of up to 10 years. For other MOVs the Local Leak Rate Testing (LLRT) provides the appropriate conditions for supplemental position verification. LLRTs may be performed at intervals of up to 6 years. In some cases System Operating Procedures, such as for fill and vent, provide the necessary conditions for crediting MOV supplemental position verification and are performed 8-1 every 2 years or less.

The wording in the proposed condition above has been discussed with industry experts and there is a lack of consensus on what the condition requires in terms of allowed MOV supplemental position verification test interval. Some individuals believe MOV supplemental position verification must be performed every 2 years per ISTC-3700 requirements and other individuals believe it can be performed at intervals up to 10 years. As described above, there is a variety of activities being performed or credited to satisfy MOV supplemental position verification, and at a variety of intervals.

Recommend the wording of the proposed rulemaking be enhanced to clearly state that, whatever method or activity is being performed or credited, MOV supplemental position verification must be performed at least once every 10 years.

Attachments E Cavey Comment on Proposed 10CFR50.55a https://www.fdms.gov/fdms/getcontent?objectId=0900006483a0155c&format=xml&showorig=false 01/24/2019

Comment on Proposed 10CFR50.55a Ruling Section C ASME OM Code Discussion 10 CFR 50.55a(b)(3)(xi) OM Condition: Valve Position Indication The NRC proposes to amend § 50.55a(b)(3)(xi) for the implementation of paragraph ISTC-3700, Position Verification Testing, in the ASME OM Code to apply to the 2012 Edition through the latest edition and addenda of the ASME OM Code incorporated by reference in § 50.55a(a)(1)(iv). This will allow future rulemakings to revise § 50.55a(a)(1)(iv) to incorporate the latest edition and addenda of the ASME OM Code without the need to revise § 50.55a(b)(3)(xi). In addition, the NRC proposes to clarify that this condition applies to all valves with remote position indicators within the scope of Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, including MOVs within the scope of Mandatory Appendix III, Preservice and Inservice Testing Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants. ISTC-3700 references Mandatory Appendix III for valve position testing of MOVs. The development of Mandatory Appendix III was intended to verify valve position indication as part of the diagnostic testing performed on the intervals established by the appendix. This clarification will ensure that verification of valve position indication is understood to be important for all valves with remote position indication addressed in Subsection ISTC and all of its mandatory appendices.

Comment: The intent of this OM Condition is well understood by the industry and several plants have implemented the ASME OM Code 2012 Edition, including the Valve Position Indication requirements specified in the condition. At those plants, valves with remote position indication, other than MOVs, supplemental position verification activities are performed at a two year interval as required by ISTC-3700. Most plants have voluntarily included MOVs in the scope of supplemental position verification. For some MOVs the periodic diagnostic testing (DIAG) in accordance with Appendix III-3300 is utilized as the method for supplemental position verification. Such testing may be performed at intervals of up to 10 years. For other MOVs the Local Leak Rate Testing (LLRT) provides the appropriate conditions for supplemental position verification. LLRTs may be performed at intervals of up to 6 years. In some cases System Operating Procedures, such as for fill and vent, provide the necessary 8-2 conditions for crediting MOV supplemental position verification and are performed every 2 years or less.

The wording in the proposed condition above has been discussed with industry experts and there is a lack of consensus on what the condition requires in terms of allowed MOV supplemental position verification test interval. Some individuals believe MOV supplemental position verification must be performed every 2 years per ISTC-3700 requirements and other individuals believe it can be performed at intervals up to 10 years. As described above, there is a variety of activities being performed or credited to satisfy MOV supplemental position verification, and at a variety of intervals. Recommend the wording of the proposed rulemaking be enhanced to clearly state that, whatever method or activity is being performed or credited, MOV supplemental position verification must be performed at least once every 10 years.

Submission ID 9 Adam Keyser, Private Citizen ML19024A526

Page 1 of 2 9

83FR56156 PR-50 As of: 1/24/19 1:51 PM Received: January 23, 2019 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k3-97uh-4e89 Comments Due: January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0010 Comment on FR Doc # 2018-24076 Submitter Information Name: Adam Keyser General Comment Public Comments on Docket ID NRC-2016-0082 (b)(2)(xxxvii) Section XI condition: ASMEBPV Code Case N824; As written, this paragraph appears to simply provide NRC endorsement of a Code Case. If this is the intent, the Code 9-1 Case and conditions should be listed in Reg. Guide 1.147 for consistency, instead of in the Rule. If the intent of this conditional paragraph is different from providing endorsement of the Code Case, the intent should be clarified in the Rule.

9-2 (b)(2)(ix)(K) Metal Containment Examinations: Eleventh provision; Table IWE 2411 1 should be Table IWE-2411-1. paragraph IWE 2430 should be paragraph IWE 2430.

9-3 (b)(2)(xxxix)(A) Defect Removal: First Provision; subparagraph IWA 4421(c)(1) should read subparagraph IWA-4421(c)(1) 9-4 (b)(2)(xxxix)(B) Defect Removal: Second Provision; subparagraph IWA 4421(c)(2) should https://www.fdms.gov/fdms/getcontent?objectId=0900006483a03af6&format=xml&showorig=false 01/24/2019

Page 2 of 2 read subparagraph IWA-4421(c)(2) 50.55a(b)(2)(xl) Section XI Condition: Prohibitions on Use of IWB-3510.4(b); The proposed 9-5 Rule does not specify which Edition and Addenda of Section XI this condition applies to.

These paragraphs do not exist in some previous versions.

50.55a(b)(2)(xlii) Section XI Condition: Steam Generator Nozzle-to-Component Welds and 9-6 Reactor Vessel Nozzle-to-Component Welds; of the 2011a Addenda should read of the 2011 Addenda (b)(2)(xviii)(D), (g)(4)(i), and (g)(4)(ii); The Proposed Rule provides a description of changes 9-7 in Section III, Discussion, but there is no associated change for these sections under the Proposed Rule text. For consistency, the actual text of the proposed Rule needs to be published.

https://www.fdms.gov/fdms/getcontent?objectId=0900006483a03af6&format=xml&showorig=false 01/24/2019

Submission ID 10 Gary Becker, NuScale Power, LLC ML19024A527

Page 1 of 1 10 83FR56156 PR-50 As of: 1/24/19 1:58 PM Received: January 23, 2019 PUBLIC SUBMISSION Status: Pending_Post Tracking No. 1k3-97um-m9n9 Comments Due: January 23, 2019 Submission Type: API Docket: NRC-2016-0082 American Society of Mechanical Engineers 2015 - 2017 Code Editions Incorporation by Reference Comment On: NRC-2016-0082-0003 American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference Document: NRC-2016-0082-DRAFT-0012 Comment on FR Doc # 2018-24076 Submitter Information Name: Gary Becker Address:

1100 NE Circle Blvd, Suite 200 Corvallis, OR, 97330-4741 Email: gbecker@nuscalepower.com Organization: NuScale Power, LLC General Comment See attached file(s)

Attachments LO-0119-64284 Federal Registry Comments on BRVC Code Edition Signed https://www.fdms.gov/fdms/getcontent?objectId=0900006483a01d2a&format=xml&showorig=false 01/24/2019

L0-0119-64284 January 23 , 2019 Secretary, U.S. Nuclear Regulatory Commission Washington , DC 20555-0001 ATTN: Rulemakings and Adjudications Staff

SUBJECT:

NuScale Power, LLC Comments on the proposed rule American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference ,

Docket ID NRC-2016-0082.

The attached comments are submitted in response to Federal Register Notice 2018-24076 (83 Fed.

Reg. 56 ,156) requesting comments on the the U.S. Nuclear Regulatory Commission (NRC) proposed rule American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference (Docket ID NRC-2016-0082).

If you have any questions , please contact me at 541-360-0549 or at gbecker@nuscalepower.com.

Sincerely, Gary Becker Regulatory Affairs Counsel NuScale Power, LLC

Attachment:

NuScale Power, LLC Comments on proposed rule American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference , Docket ID NRC-2016-0082 NuScale Power, LLC 1100 NE Circle Blvd , Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

L0-0119-64284 Attachment Page 1 of 1 NuScale Power, LLC Comments on proposed rule American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference, Docket ID NRC-2016-0082 Comment:

Revise 10 CFR 50.55a(b)(1 )(iii) to allow use of Editions and Addenda after the 2008 Addenda. 10 CFR 50.55a(b)(1 )(iii) pertains to the allowed use of ASME Boiler and Pressure Vessel Code , Section Ill Subarticles NB-3600, NC-3600, and ND-3600 that are acceptable for seismic design of piping. The current rule allows the use of Subarticles NB-3600, NC-3600, and ND-3600 for the seismic design of piping in the 2006 Addenda through the 2008 Addenda ,

subject to the conditions of paragraph (b)(1 )(iii). The rule should be revised to include Editions and Addenda after the 2008 Addenda. For example , the revised rule may read: "(iii) ... Applicants or licensees may use Subarticles NB-3600 , NC-3600 , and ND-3600 for the seismic design of piping in the 2006 Addenda through the 2013 Edition, subject to the conditions of this paragraph corresponding to those subarticles."

Justification:

10 CFR 50.55a (b)(1 )(iii) does not allow the use of Subarticles NB-3600, NC-3600, and ND-3600 in the 1994 Addenda through the 2005 Addenda for seismic design of piping. It appears this exclusion relates to NRC's disagreement with certain provisions in the Subarticles during that time span. Beginning with the 2006 Addenda , two significant changes are apparent in what are 10-1 known as the "alternative rules" for analysis of reversing dynamic (seismic) loads. First, the specification of seismic analysis methods (including analysis type, spectrum peak broadening ,

and damping) in NB-3656(b)(3) and NC/ND-3655(b)(3) was removed. Second , guidance on analyzing piping systems with unbalanced distributions of plastic strain was added to NB-3656(b)(5) and NC/ND-3655(b)(5). Coincident with these changes , 10 CFR 50.55a(b)(1 )(iii) allows NB-3600, NC-3600, and ND-3600 in the 2006 Addenda to be used for piping seismic design , and this allowance extends through the 2008 Addenda.

However, it is not clear why the use of Subarticles NB-3600, NC-3600, and ND-3600 for piping seismic design later in subsequent Addenda and Editions of the Code is not allowed by 10 CFR 50.55a(b)(1)(iii). For example, NB-3656 and NC/ND-3655 of the 2013 Edition have only immaterial differences from the currently-endorsed 2008 Addenda , namely textual clarifications and updates to some referenced stress indices that are not specific to seismic analysis. It appears that exclusion of the post-2008 Addenda , up to and including the 2013 Edition , may have been inadvertent. Therefore, 10 CFR 50.55a(b)(1 )(iii) should be made consistent with the post-2008 Code Editions and Addenda otherwise allowed by 10 CFR 50.55a(a)(1 )(i), allowing those Editions and Addenda to be used for the seismic design of piping to the extent appropriate from a technical perspective.

NuScale Power, LLC 1100 NE Circle Blvd , Suite 200 Corvallis, Oregon 97330 Office 541.360-0500 Fax 541.207.3928 www.nuscalepower.com

Submission ID 11 Justin Wheat, Southern Nuclear Operating Company ML19024A528

11 83FR56156 PR-50 A Southern Nuclear Regulatory Affairs 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5000 tel 205 992 7601 fax JAN 2 3 2019 Secretary NL-19-0071 U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 A TIN: Rulemakings and Adjudications Staff.

Southern Nuclear Operating Company Comments on the NRG Proposal to Incorporate by Reference into Regulations the 2015-2017 ASME Code Editions. Docket ID NRC-2016-0082

Dear staff:

In response to Federal Register Notice 83 FR 56156 released on November 9, 2018, Southern Nuclear Operating Company (SNC) is hereby providing comments on the NRC's proposal to amend its regulations to incorporate by reference the 2015 and 2017 Editions of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and the 2015 and 2017 Editions of the ASME Operation and Maintenance of Nuclear Power Plants, Division 1: OM: Section 1ST, respectively, for nuclear power plants. (Docket ID NRC-2016-0082).

SNC comments have been consolidated and included in the attachment to this letter.

This letter contains no NRG commitments. If you have any questions, please contact me at 205.992.5998.

Respectfully submitted,

~ _ . : k (~

Justin T. Wheat Nuclear Licensing Manager JTW/kmo/sam

Attachment:

SNC Comments on Docket ID NRC-2016-0082 cc: Southern Nuclear Operating Company Mr. M. D. Meier, Vice President - Regulatory Affairs SNC Document Services - RType: CGA02.001

Southern Nuclear Operating Company Comments on the NRC Proposal to Incorporate by Reference into Regulations the 2015-2017 ASME Code Editions, Docket ID NRC-2016-0082 Attachment SNC Comments on Docket ID NRC-2016-0082

Attachment to NL-19-0071 SNC Comments on Docket ID NRC-2016-0082 SNC Comments on Docket ID NRC-2016-0082 Identifier Proposed

1. Comment (Section, Page, Paragraph) Resolution

1. 83 FR 56167; The industry's confusion is centered around the requirement of SNC recommends that the NRC pressure testing after mechanical repair/replacement activities, specifically identify which mechanical 10 CFR 50.55a(b)(2)(xxvi) such as the replacement of bolting in a mechanical connection repair/replacement activities would Section XI Condition:

(ASME Interpretation Xl-1-10-20) . require pressure testing.

Pressure Testing Class 1, 2, 11-1 and 3 Mechanical Joints Regarding Xl 10-20, SNC understands that the NRC disagrees with the ASME interpretation which exempts bolting replacements from pressure testing . However, the NRC does not clearly state their position on this matter in the draft rulemaking.

2. 83 FR 56172; The proposed change requiring application of Appendix IV of SNC proposes the following the 2017 Edition of the OM Code, when implementing the 2015 recommendations in order of 10 CFR 50.55a(b)(3)(xii) OM Edition is unnecessary and inappropriate. desirability:

Condition: Air-Operated Valves (Appendix IV) It is unnecessary because:

• Remove the proposed condition;

• Licensees establishing an initial or subsequent 120-month

• Do not approve the 2015 Edition, interval plans are required to use the most recent edition of thereby forcing Licensees that wish the OM Code, which is the 2017 Edition. to take advantage of changes made between the 2012 and 2015 Edition

• Existing rules adequately address the use of subsequent to incorporate the 2017 Edition.

approved Editions of the code, so it is unclear why the NRC 11-2 has chosen to bypass the applicability of these rules by mandating those implementing the 2015 Edition use Appendix IV of the 2017 Edition.

• Licensees are already required to demonstrate that components can perform their intended safety function per 10CFR50 Appendix A. Furthermore, plants with AOVs are required to implement and maintain an AOV test program.

Most of the industry has implemented the JOG program which is very similar to Appendix IV.

It is inappropriate because:

A-1

Attachment to NL-19-0071 SNC Comments on Docket ID NRC-2016-0082 SNC Comments on Docket ID NRC-2016-0082

• The 2015 Edition does not provide the necessary framework to properly incorporate Appendix IV.

• The NRG has not indicated to Licensees utilizing previous versions of the OM Code that they will need to expeditiously implement the provision in Appendix IV of the 2017 Edition after the final rule takes effect; therefore, it is unclear why the NRG would assert the changes in Appendix IV were significant enough to warrant Licensees implementing the 2015 Edition comply.

• The requirement to utilize Appendix IV of the 2017 Edition following the implementation of the 2015 Edition or earlier would impose a significant burden on licensees by way of a major revision to their 1ST program plan for AOVs.

3. 83 FR 56172; The proposed change as written would create an unnecessary SNC recommends that the NRG limit burden on the Licensee and the NRG to process and review a the number of locations official 10 CFR 50.55a(f)(7) lnservice significant increase in the number of submittals which ultimately submittals are required to be sent to Testing Reporting contain no new technical information. For example, 1ST program one (i.e., NRG Headquarters), and Requirements plan changes including test changes or deletions, editorial should limit the frequency of these changes (e.g., correction of typos), clarifications, reassignment submittals to 120-month Initial and of a check valve from the standard ASME OM Code Subsequent interval plans, and any requirements to the Check Valve Condition Monitoring program, update that requires a relief request, 11-3 moving components to alternate treatment under 10 CFR 50.69, proposed alternative, or adoption of a and revisions that only incorporate augmented scope new ASM E OM Code of record or Code components provide no added value to the NRG staff. Case.

Furthermore, submitting program plans to multiple NRG offices and/or personnel directly would undoubtedly create a serious version control problem for both entities. It is also unnecessary to require Licensees to officially submit revisions to the NRG resident, who already has access to the most recent versions of the program plans at the station.

A-2

Attachment to NL-19-0071 SNC Comments on Docket ID NRC-2016-0082 SNC Comments on Docket ID NRC-2016-0082

4. Not Contained in Federal 50.55a(b)(3)(iii) states that the following condition is required for SNC recommends that the NRC either, Register; New Reactors:

• Remove this condition and refer 50.55a(b)(3)(iii)(C) Flow- "Flow-induced vibration. Licensees shall monitor flow- Licensees to utilize the existing induced vibration induced vibration from hydrodynamic loads and acoustic requirements for piping and resonance during preservice testing or in-service testing to component vibration monitoring identify potential adverse flow effects on components within contained in the AP1000 design the scope of the 1ST program." control documents for New Reactors, or The monitoring of flow-induced vibration during preservice or in-11-4 service testing would not provide a good measure of the effects

• Revise the condition by replacing on these components. In many cases, including those of "preservice testing or in-service utmost concern to the industry based on operating experience testing" with "initial plant operation".

(e.g., main steam and main feedwater valves}, the flow rate during preservice or in-service testing is reduced significantly to below normal operating conditions.

Furthermore, the AP1000 design control documents already contain a requirement in 3.9.2.1 .1 for piping vibration testing and assessment. This requirement provides that Licensees assess the vibration during "initial operation".

5. Not Contained in Federal When the OM Code (Parts 1,6, and 10) was being developed to SNC recommends that the NRC add a Register; encompass the requirements from Section XI, Subsections IWP statement that Pressure relief devices and IWV of the ASME 8PV Code, the scope was intentionally requiring testing per 10 CFR 50.55a(f)(4) lnservice testing changed to test all pumps and valves with a safety related 50.55(a)(f)(4) shall be limited to valves standards requirement for function (even if not Class 1, 2 or 3). This change resulted in and rupture discs installed in piping operating plants unintended consequences for relief devices and has systems designed to ASME B&PV 11-5 subsequently been raised to the attention of the OM Code Codes or ASME B31 standards.

committee by the industry. However, it is imperative that the This type of statement would ensure NRC address the issue in 10 CFR 50.55a until the OM Code relief devices protecting components committee has resolved the issue.

with safety functions built to Section VIII In short, the problem stems from the varied interpretation of or 831 .1 or 831.7, that are not Class 1, ISTA-11 OO(b) and the inclusion of components that the OM 2 or 3, are exempt from the condition.

Code was not intended to test. Some examples include:

A-3

Attachment to NL-19-0071 SNC Comments on Docket ID NRC-2016-0082 SNC Comments on Docket ID NRC-2016-0082

• To some a strict interpretation of ISTA-1100{b) implies relief devices that were not designed for use in or installed in piping systems are required to be tested per the OM Code.

While 10 CFR 50.55a{f) does refer to "pumps and valves" throughout, the limitation of the scope of 1ST relief device components should be more explicit.

• Some have interpreted that ISTA-1100{b) requires OM Code testing of structural "blow-out panels" that are designed to limit the temperature, in the area of MOVs or AOVs with safety functions, to within their EQ qualification limits. While these "blow-out panels" to need to be maintained {i.e.,

through inspection or PMs) to ensure they will function as designed, the requirements do not exist in the OM Code.

• The absence of a limit in the applicability of the OM Code to piping systems, could result in further expansion in the interpretation for relief devices to include those in HVAC or electrical systems with safety functions. Relief devices in both HVAC and electrical systems with safety functions have other design and testing standards they are required to meet; therefore, the existing OM Code testing requirements would not properly test these components.

6. 83 FR 56171 The following statement is too vague regarding what clarity SNC recommends that the NRC include licensees should expect to be included: the exact wording that is intended to be 10 CFR 50.55a{b){3){xi) OM included in this amended condition.

Condition: Valve Position "In addition, the NRC proposes to clarify that this condition Indication a1212lies to all valves with remote 12osition indicators within 11-6 the sco12e of Subsection ISTC, "lnservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants," including MOVs within the scope of Mandatory Appendix Ill, "Preservice and lnservice Testing Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reactor Nuclear Power Plants."

A-4

Attachment to NL-19-0071 SNC Comments on Docket ID NRC-2016-0082 SNC Comments on Docket ID NRC-2016-0082

7. 83 FR 56172 The following statement is too vague regarding information SNC recommends that the NRC include licensees should expect to be included in the new condition: the exact wording that is intended to be 10 CFR 50.55a(b)(3)(xii) OM included in this new condition.

Condition: Air-Operated "The NRC grogoses to include new§ 50.55a(b}(3}(xii) to Valves (Appendix IV) require the application of the provisions in Appendix IV of the 2017 Edition of the ASME OM Code, when implementing 11-7 the ASME OM Code, 2015 Edition. The new Appendix IV in the 2017 Edition of the ASME OM Code provides improved PST and 1ST of active AOVs within the scope of the ASME OM Code. This condition would provide consistency in the implementation of these two new editions of the ASME OM Code."

A-5

RulemakingComments Resource From: Mitchell, Susan Camille <SUMITCHE@southernco.com>

Sent: Thursday, January 24, 2019 3:57 PM To: RulemakingComments Resource

Subject:

[External_Sender] NRC-2016-0082 Attachments: NL-19-0071.pdf In response to Federal Register Notice 83 FR 56156 released on November 9, 2018, Southern Nuclear Operating Company (SNC) is hereby providing comments on the NRC's proposal to amend its regulations to incorporate by reference the 2015 and 2017 Editions of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code and the 2015 and 2017 Editions of the ASME Operation and Maintenance of Nuclear Power Plants, Division 1: OM: Section 1ST, respectively, for nuclear power plants.

(Docket ID NRC-2016-0082).

Justin Wheat Nuclear Licensing Manager Southern Nuclear Operating Company 1

Submission ID 12 Stephen Vaughn, Nuclear Energy Institute ML19028A019

83FR56156 PR-50 12 From: VAUGHN, Stephen [1]

Sent: Tuesday, January 22, 2019 4:12 PM To: Ma, May <May.Ma@nrc.gov>

Cc: O'Driscoll, James <James.O'Driscoll@nrc.gov>; Hoffman, Keith <Keith.Hoffman@nrc.gov>

Subject:

[External_Sender] NEI Letter to NRC - Comments on FRN to incorporate new ASME codes and standards THE ATTACHMENT CONTAINS THE FULL CONTENTS OF THE LETTER January 22, 2019 Ms. May Ma Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Comments on American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference [RIN 3150-AJ74; Docket ID NRC-2016-0082]

Reference No: 689

Dear Ms. Ma:

The Nuclear Energy Institute[1] (NEI), on behalf of our members, appreciates the opportunity to comment on American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference issued in the Federal Register on November 9, 2018. Below are two comments for your consideration.

12-1 In summary, since the NRC Resident Inspector currently has access to the most recent revision of a licensees ASME OM Code program Plan and is able to distribute them to others within the NRC organization upon request, it is recommended that the additional proposed requirement to submit interim IST Plan updates be deleted.

If you or other NRC staff have any comments or questions please contact me at sjv@nei.org or 202-739-8163.

Sincerely, Stephen Vaughn Senior Project Manager, Risk and Technical Support Nuclear Energy Institute 1201 F St., NW, Suite 1100 Washington, DC 20024 www.nei.org P: 202.739.8163 M:202.256.5393 E: sjv@nei.org

[1]

The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

STEPHEN J. VAUGHN Senior Project Manager, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8163 sjv@nei.org nei.org January 22, 2019 Ms. May Ma Office of Administration U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Comments on American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference [RIN 3150-AJ74; Docket ID NRC-2016-0082]

Reference No: 689

Dear Ms. Ma:

The Nuclear Energy Institute 1 (NEI), on behalf of our members, appreciates the opportunity to comment on American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference issued in the Federal Register on November 9, 2018. Below are two comments for your consideration.

10 CFR 50.55a(b)(3)(xi) OM Condition: Valve Position Indication (page 56171)

Verification of valve position indication became effective 8/17/2018. The proposed change is applicable when implementing the 2012 or later editions of the ASME OM Code. It stipulates that licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters or other suitable instrumentation, to provide assurance of proper obturator position. The scope of the condition follows guidance under paragraph ISTC-3700 and applies to all valves 12-2 with remote position indication, with the exception of active MOVs under Mandatory Appendix III. The condition could imply the obturator position is to be verified using supplemental means every 24 months.

In the proposed rulemaking, 10CFR50.55a(b)(3)(xi) is being updated to increase the scope of the OM condition to include valves covered in all of the mandatory appendices within the ASME OM Code, in addition to subsection ISTC. The basis for this change seems to imply that diagnostic testing performed on MOVs under Mandatory Appendix III can be used to verify obturator position on the diagnostic test frequency (up to every 10 years), as this particular test method provides reasonable assurance of valve condition.

1 The Nuclear Energy Institute (NEI) is responsible for establishing unified policy on behalf of its members relating to matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEIs members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect and engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations involved in the nuclear energy industry.

Ms. May Ma January 22, 2019 Page 2 Establishing a requirement to verify obturator position on every valve in the IST program with remote position indication places a significant burden on the licensee to develop new test methods and procedures for valves that do not have supplemental means available, such as flow or pressure indication. In these cases, it may be necessary to purchase special equipment and deploy personnel to high radiological areas in order to verify obturator position on a frequency that may not be necessary.

The OM condition could be modified to allow other NRC-approved test methods to verify obturator position while still maintaining reasonable assurance of the valve condition. An example of such an NRC-approved test method would be the Appendix J program. The Local Leak Rate Test performed under this program provides the reasonable assurance necessary to meet the intent of this OM condition on a frequency greater than 24 months and would greatly reduce the burden on the licensee. These types of NRC approved test methods call for increased testing frequencies when the valves performance shows signs of degradation.

It is recommended that the following wording be added to the condition to provide greater flexibility in how licensees meet the intent of this OM condition: Licensees shall verify that valve operation is accurately indicated by supplementing valve position indicating lights with other indications, such as flow meters, other suitable instrumentation, or NRC approved testing programs to provide assurance of proper obturator position.

10 CFR 50.55a(f)(7), Inservice Testing Reporting Requirements As stated in the proposed rulemaking, The current ASME OM Code states in paragraph (a) of ISTA-3200, Administrative Requirements, that IST Plans shall be filed with the regulatory authorities having jurisdiction at the plant site. However, the ASME is planning to remove this provision from the ASME OM Code in a future edition because this provision is more appropriate as a regulatory requirement rather than a Code requirement. Therefore [the] proposed condition is an administrative change that would relocate the provision from the ASME OM Code to § 50.55a.

However, the proposed 10 CFR 50.55a(f)(7) would expand the existing OM Code requirement to require 12-3 licensees to submit their IST Plans and interim IST Plan updates related to pumps and valves, and IST Plans and interim Plan updates related to snubber examination and testing to NRC Headquarters, the appropriate NRC Regional Office, and the appropriate NRC Resident Inspector. Submittal of interim IST Plan updates for pumps and valves and snubber examination and testing is not currently required. The new requirement to submit IST Plan updates to the NRC is considered unnecessary and overly burdensome. Currently, program plans associated with the ASME OM Code are submitted to the NRC for information prior to the beginning of each 10 year interval. These program plan submittals are deemed adequate for the NRC to perform their technical reviews of any associated alternative and relief requests.

The current revision of the ASME OM Code IST program Plans are available to onsite resident inspectors, who can provide the latest revision to interested NRC technical staff and regional inspectors upon request.

Ms. May Ma January 22, 2019 Page 3 Furthermore, NRC inspectors typically request licensees to either provide, or have available upon arrival, the latest Plan documents prior to scheduled inspections. An OM Code IST program Plan is considered a living document and could go through several revisions within a 10 year interval. The proposed requirement may result in licensees not updating their ASME OM Code program plans as often due to the extra burden of having to send revisions to NRC headquarters, the NRC Regional Office, and the NRC Resident Inspector.

In summary, since the NRC Resident Inspector currently has access to the most recent revision of a licensees ASME OM Code program Plan and is able to distribute them to others within the NRC organization upon request, it is recommended that the additional proposed requirement to submit interim IST Plan updates be deleted.

If you or other NRC staff have any comments or questions please contact me at sjv@nei.org or 202-739-8163.

Sincerely, Stephen Vaughn c: Mr. James ODriscoll, NRC/NMSS Mr. Keith Hoffman, NRC/NRR

Submission ID 13 Mark Gowin, Private Citizen ML19029B164

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Docket NRC-2016-0082 - GOWIN Comments - 2108 Draft 10 CFR 50.55a Rulemaking:

Paragraph Comment (a)(1)(ii)(C)(54) Consider not endorsing 2015 Edition of OM Code based on complications 13-1 related to new Condition that imposes Appendix IV on the 2015 Edition.

See comment below for paragraph (b)(3)(xii) 13-2 (b)(3)(x) Recommend deleting this OM Condition. This condition is no longer required because OMN-20 is included RG 1.192, Rev 2 (b)(3)(xi) Recommend clarifying this OM Condition with respect to its application to Mandatory Appendices. For example, clarify whether the ISTC-3700 13-3 methods and frequency OR the Mandatory Appendix methods and frequency are applicable..

(b)(3)(xii) The 2015 Edition of OM Code does not have the necessary pointers and references to Appendix IV. Therefore, there could be considerable confusion for plants to implement this condition. For example, Appendix IV includes much of the same valve exercise, stroke time, and fail safe test requirements contained in Subsection ISTC, but Appendix IV has combined some of these items and renamed them. Implementers may not recognize that some of these tests are the same.

In reality, the only new test requirement in Appendix IV is the Performance Assessment Testing. It may be possible to clarify this new condition to only reference the specific Appendix IV paragraphs related to Performance Assessment Testing such as those listed below.

IV-1400(a)

IV-1400(b)

IV-1400(d)

IV-2000 definitions related to Performance Assessment Testing IV-3410 - Performance Assessment Testing IV-3520 Effect of AOV Replacement, Repair, 13-4 Modification, or Maintenance (portions related to Performance Assessment Testng)

IV-3600 - Grouping of AOVs for Performance Assessment Testing IV-3800 - Risk-Informed AOV Inservice Testing IV-5000 - PERFORMANCE ASSESSMENT TEST METHODS IV-6000 - PERFORMANCE ASSESSMENT TEST ANALYSIS AND EVALUATION IV-9100 (b)

IV-9100 (c)

IV-9100 (f)

IV-9100 (g)

IV-9100 (h)

IV-9200 (c)

IV-9200 (d)

As an alternative, this rulemaking could be revised to eliminate NRC endorsement of the 2015 Edition of OM Code for use by utilities..

13-5 (f)(7) Recommend clarifying whether this paragraph also applies to Augmented Inservice Testing Programs created to comply with (f)(4) and (f)(6)(ii). It

may be as simple as stating AIST Plan and IST Plan.

Recommend clarifying that the IST plan submittals required by this paragraph are for information only, that NRC review and approval is not required, and are not considered NRC commitments that need to be tracked separately from typical compliance with NRC regulation.

Recommend adding the 90 day time frame at the end of this paragraph for submittal of interim AIST and IST Plan updates.

(f)(7)(vi) Please clarify the intent of this this paragraph.

ASME OM Code requirements for components that are not being satisfied by the tests or examinations; and justification for alternative tests or examinations 13-6 As written, may not be clear to the implementer whether this refers to those Augmented IST program deviations from the OM code that would be Relief Requests if they were in the IST Program or something else entirely.

Submission ID 14 David Gudger, Exelon Generation Company, LLC ML19037A437

83FR56156 PR-50 14 Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com February 4, 2019 Secretary ATTN: Rulemakings and Adjudications Staff U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Comments Concerning Proposed Rule 10 CFR 50, "American Society of 11 Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference (83FR53156, dated November 9, 2018, Docket ID NRC-2016-0082)

This letter is being submitted in response to the U.S. Nuclear Regulatory Commission (NRC) request for comments concerning Proposed Rule 10 CFR 50, "American Society of 11 Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference, published in the Federal Registeron November 9, 2018 (i.e., 83FR53156).

The NRG is proposing to amend its regulations to incorporate by reference seven recent editions and addenda to the American Society of Mechanical Engineers (ASME) codes for nuclear power plants and a standard for quality assurance. The NRC is also proposing to incorporate by reference four ASME code cases. This action is in accordance with the NRC's policy to periodically update the regulations to incorporate by reference new editions and addenda of the ASME codes and is intended to maintain the safety of nuclear power plants and to make NRC activities more effective and efficient.

Exelon Generation Company, LLC (Exelon) appreciates the opportunity to comment and offers the attached comments on certain sections on this proposed rule for consideration by the NRG.

If you have any questions or require additional information, please contact Richard Gropp at (610) 765-5557.

Respectfully, J..0-,,JT LJ~

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachment

Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2016-0082 Page 1 of 2 Comments Concerning Proposed Rule 10 CFR 50, "American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference" 10 CFR 50.55a Section I Comments on Proposed Changes

§50.55a(b)(2)(xx)(8) I Exelon suggests removing this condition. The NRG proposes to amend the condition found in § 50.55a(b)(2)(xx)(8) to clarify its expectations related to the Nondestructive Examination (NOE) required when a system leakage test is performed (in lieu of a hydrostatic test). As indicated in previous rulemaking comments provided to the NRG, mandating Section Ill Construction Code NOE acceptance criteria to systems and components that were not originally designed or constructed to meet Section Ill is believed to be inappropriate. NOE alone does not ensure structural integrity.

Construction codes ensure structural integrity through a combination of many factors, including material testing, design 14-1 formulas, design factors, and qualification of personnel. Adding more NOE than required by the Construction Code

{whether ASME Section Ill or 831.1) is considered unnecessary to ensure structural integrity and could be inappropriate for certain situations (e.g., volumetric NOE required of a non-volumetric quality casting).

If the condition still stands after consideration of any comments, Exelon offers the following editorial comments:

• First sentence: Insert "Edition" after "1992 or later."

• Last sentence: Insert "program" after "ISi."

§50 .55a(b)(2)(xxvi) From the 2007 through the 2017 Edition of ASME Section XI, installed items rotated from stock meeting the requirements of IWA-4132 are considered outside of the requirements of IWA-4000 (i.e., repair/replacement activities) and exempted 14-2 from preservice examinations, including pressure testing under IWA-4540; therefore, Exelon believes that

§50.55a(b)(2)(xxvi) should not apply to installed items rotated from stock.

§50.55a(b)(2)(xxxii) Exelon understands that Code changes are in progress to extend the submittal timeframe for reports like this to 120 14-3 days. Therefore, Exelon recommends this timing be adopted in the rule as well, since it is consistent with other industry inspection results' reporting time periods.

§50.55a(g)(6)(ii)(D)(5) While it is understood that MRP-335-3A is required to be followed for peening application and inspection relief, since the NRG is allowing condition 5.4 of the topical report to not apply, could the additional clarification that the Extent and 14-4 Frequency of Examination of Item 84.60 of N-729-6 be applied and added to the rule? Exelon believes that this will help validate a user trying to understand what the condition of MRP-335 not applying means in the context of the Code Case since they will still need to comply with the non-peening related portions of the Code Case.

§50.55a(g)(6)(ii)(F)(15) Exelon suggests removing this condition. In the explanation section of the proposed rule, the NRG indicates there is insufficient technical basis to support the difference in inspection frequency between N-1 and M-2 welds. As noted in the 14-5 Code Case and technical basis for the EWR repair method, the N-1 repair is a full 360-degree EWR with stress reversal.

Therefore, while there is a flaw with an N-1 weld, stress reversal is obtained with the EWR to preclude flaw growth while the M-2 weld EWR does not achieve stress reversal. That is a key technical difference in the two repairs and why the N-1 EWR should allow the sampling strategy as provided in the Code Case.

Attachment Comments Concerning 10 CFR 50 Proposed Rule Docket ID NRC-2016-0082 Page 2 of 2 10 CFR 50.55a Section I Comments on Proposed Changes

§50.55a(f)(7) I Due to changes in ASME Section XI, snubber inspection and testing programs are no longer part of the standard site lnservice Inspection (ISi) programs and are now implemented using the ASME OM Code. The wording in the proposed rulemaking is unclear as to whether snubber programs are required to comply with the rules of site lnservice Testing (1ST) programs, which include:

• Requiring sites to submit changes to their plans to the NRC Headquarters, the appropriate NRC Regional Office, and the appropriate NRC Resident Inspector within 90 days of implementation.

• Submittal of preservice test period, initial inservice test interval, and successive inservice test intervals.

• Submittal of interim Plan updates that involve any of the following:

o Classification of components and boundaries of system classification; o Identification of components subject to tests and examination; o Identification of components exempt from testing or examination; 14-6 o ASME OM Code requirements for components and the test or examination to be performed; o ASME Code requirements for components that are not being satisfied by the tests or examinations; and justification for alternative tests or examinations; o ASME OM Code Cases planned for use and the extent of their application; or o Test or examination frequency or schedule for performance of tests and examinations as applicable.

The proposed requirements listed for 1ST (including site snubber programs) are believed to be an excessive burden without providing any additional level of quality. Requiring sites to submit subtle changes to their program documentation (e.g., program plan, classifications, schedules, etc.) within 90 days of implementation to NRC Headquarters, Regional Offices, and Resident Inspectors is considered an unnecessary burden without any accompanying increase in quality or safety. This documentation could be readily available at the sites, with specific items provided to the NRC on an as needed basis.

It should also be noted that the NRC no longer requires sites to provide updates to ISi programs, with the only required ISi submittals being the post outage Summary Report/ Owner Activity Report required under 10 CFR 50.55a(b)(2)(xxxii).

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