ML23159A178
| ML23159A178 | |
| Person / Time | |
|---|---|
| Issue date: | 06/15/2023 |
| From: | John Honcharik NRC/NRR/DNRL/NPHP |
| To: | |
| References | |
| Download: ML23159A178 (1) | |
Text
NRC Perspective on ASME Code Preservice Inspections John Honcharik US Nuclear Regulatory Commission June 15, 2023
Outline 2
Regulations Regulations and ASME Code Requirements Removal of PSI NRC Staff Position
Regulations 3
The National Technology Transfer and Advancement Act of 1995, Public Law 104-113 (NTTAA), - Federal agencies use voluntary consensus standards to develop regulatory requirements while taking exception to specific portions of the standard, if those provisions are deemed to be inconsistent with applicable law ASME Code - Voluntary Consensus Standard contains requirements for the design, construction, and inspection of nuclear power plant components 50.55a Rulemaking - approves or mandates the use of certain parts of editions and addenda of these ASME Codes in § 50.55a through the rulemaking process of incorporation by reference to establish regulatory requirements for the design, construction, and inspection of nuclear power plants
Regulations 4
10 CFR 50.55a(g)(3)(ii) states:
For a boiling or pressurized water-cooled nuclear power facility, whose construction permit under this part, or design certification,..
that are classified as ASME BPV Code Class 1, Class 2, and Class 3..
must meet the preservice examination requirements set forth in the editions and addenda of Section III or Section XI of the ASME BPV Code incorporated by reference in paragraph (a)(1) of this section (or the optional ASME BPV Code Cases listed in NRC Regulatory Guide 1.147, as incorporated by reference in paragraph (a)(3)(ii) of this section) applied to the construction of the particular component.
Regulation and ASME Code 5
10 CFR 50.55a(g) Requires ASME Code Class 1, 2 and 3 components must meet the preservice examination requirements in Section III (new construction) or Section XI (repair/replacement)
ASME Boiler and Pressure Vessel (BPV) Code Section III, Division 1, Rules for Construction of Nuclear Facility Components (with conditions)
NCA-3252(c) (NCA-3211.19(b)(3) in 2021 Edition) - Specifies that design specifications to include all items requiring PSI to be performed in accordance with Section XI NB-5332, etc. -Provides acceptance criteria for preservice examination including use of Section XI acceptance criteria NB-5280, etc. - provides reporting requirements NB-5281 - Preservice Examination shall be completed prior to completing N-5 data report
Regulation and ASME Code 6
10 CFR 50.55a(g) Requires ASME Code Class 1, 2 and 3 components must meet the preservice examination requirements in Section III (new construction) or Section XI (repair/replacement)
ASME BPV Code Section XI, Division 1, Rules for Inservice Inspection of Nuclear Power Plant Components (with conditions)
IWx-2200 - Provides components to be examined and inspection method IWA-4520, IWX-3112 - Provides acceptance criteria for preservice examination IWA-4530 - Preservice Examination for Items subject to repair/replacement to be completed prior to return of system to service IWA-6230 - Provides recording requirements
Proposed Removal Of PSI 7
Various ASME Code actions include:
R22-630 - Delete PSI requirements from Section XI R23-113 Limiting PSI in Section XI to specific material and degradation mechanisms.
Removing PSI acceptance criteria Since ASME Code Section III referencesSection XI for certain PSI requirements, these changes may also apply to Section III
Staff Position 8
Based on the regulations:
PSI must be performed -
When the design report requires a weld to have PSI performed, the PSI of the weld must be performed and dispositioned to satisfactorily place the weld into service.
PSI provides a baseline for the ISI while also ensuring the weld meets all applicable requirements of Section III and XI, including that no unacceptable flaws are placed into service.
Staff Position 9
Based on the regulations:
Results of PSI appropriately dispositioned -
The ASME Code does not allow unacceptable flaws to be placed into service for any ASME Code class.
Whether the flaw was detected during a PSI, ISI or other examination, the flaw shall be dispositioned.
Provisions of Section III or Section XI, IWB-3500, Acceptance Standards, to evaluate such flaws and repair as necessary to meet acceptance criteria.
If flaws cannot be determined to be acceptable using above criteria, the licensee may request an alternative under 10 CFR 50.55a(z) to utilize the provisions of Section XI, IWB-3600, Analytical Evaluation of Flaws, to evaluate and disposition the flaws.
If the flaws cannot be demonstrated to be acceptable to be placed into service using the provisions of Section XI, IWB-3600, in the alternative request they must be repaired.
Staff Position 10 Based on the regulations:
Results of PSI recorded -
Documentation of the PSI results and disposition of recordable flaws shall be included in the appropriate data reports and/or forms specified by Section III or XI Preservice Examination for new construction shall be completed prior to completing N-5 data report Preservice Examination for repair/replacement to be completed prior to return of system to service
Conclusion 11 The NRC approves or mandates the use of certain parts of editions and addenda of these ASME Codes in § 50.55a through the rulemaking process of incorporation by reference which includes associated regulatory conditions.
ASME Code and the regulations (§ 50.55a) provide requirements for PSI.
If necessary, conditions to ASME Code can be applied if PSI requirements are removed from the ASME Code.