RC-97-0024, Comment on Proposed Generic Communication, Effectiveness of Ultrasonic Testing Sys in Inservice Inspection Programs. GL Seems to Approach Mandating Implementation of App Viii Requirements
| ML20138P997 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 02/25/1997 |
| From: | Lavigne D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | NRC |
| References | |
| FRN-61FR69120 61FR69120-00008, 61FR69120-8, RC-97-0024, RC-97-24, NUDOCS 9703060059 | |
| Download: ML20138P997 (3) | |
Text
.
South Carolina Electric & Gas Company DevM A.W ne Vir il C. Summer Nuclear Station Jenkinsvillo. SC 29065 SCE&G EsEliE?
M MO a-,
psn on..N /9M February 25, 1997
[b RC-97-0024 Chief, Rules Review /). HgGoc11 and Directives Branch g,
U. S. Nuclear Regulatory Commission l6 e
Mail Stop T-6D-69 K
fi j
Washington, DC 20555-0001 g'; 7a W;:r w 71 7
g Gentlemen:
s rei
~~
,I SU
Subject:
VIRGIL C. SUMMER NUCLEAR STATION (VCSNS)
.h w
DOCKET NO. 50/395 i
OPERATING LICENSE NO. NPF-12 i
PROPOSED GENERC COMMUNICATION:" EFFECTIVENESS OF ULTRASONIC TESTIN 3 SYSTEMS IN INSERVICE INSPECTION PROGRAMS."
South Carolina Electric & Gas Company (SCE&G) requests that the following general i
comments to the subject Proposed Generic Letter (GL) be addressed by the Nuclear Regulatory Commission (NRC):
- 1. The proposed Generic Letter seems to approach mandating the implementation of Appendix Vill (App. Vill) requirements. These requirements will cause a significant increase in the required control of personnel, equipment, and procedures necessary to perform refueling inspections. This would have an adverse economic impact and result in increased outage duration. This would be an undue hardship without a compensating increase in quality.
- 2. It is not clear that the concerns raised by the GL are an issue at PWRs.
South Carolina Electric & Gas (SCE&G) submits the following specific comments with regard to the proposed GL:
(
- 1. The first concern is that App. Vill proposes a standard in ultrasonic testing (UT) which raises the qualification requirements of UT inspectors to a level that will potentially reduce the number of qualified UT inspectors to less than the number required by the licensees. This could result in the unavailability of qualified personnel to support outage initiatives, adversely impacting outage duration, without a compensating increase in quality.
9703060059 970225 PDR ADOCK 05000395 P
pon NUCLEAR EXCELLENCE-A SUMMER TRADITION!
0 i
f & S 6sre a llB,E55plJE,5lH,IR W
E.
l_
Chi:f, Rules & R:vi:w Dircctor Lctt:r RC-97-0024 j
MSP 970003 j
Page 2 of 3
- 2. The second concern is that, based on the " Description of Circumstances" and the " Regulatory Requirements" sections of the GL, it appears that the evidence only brings to question the adequacy of inspections at BWRs where IGSCC is a 4
i major problem.
The proposed GL attempts to apply a one-size-fits-all j
philosophy, by advocating that an App. Vill type inspection be incorporated by plants where there is little or no evidence that the current UT standards are not adequate. This conclusion seems to be supported by the GL itself. Under
" Description of Circumstances" the NRC states that "it should be noted that a safety concern does not exist which would warrant immediate backfitting of j
Appendix Vill in advance of the rulemaking that has been initiated." Based on this statement, SCE&G suggests that the GL be withdrawn.
I
- 3. If the NRC deems it necessary to issue a generic letter to emphasize the use j
Appendix Vill standards, it should be in relation to the need at the various type i
plants.
For example, BWRs that experience IGSCC problems should fully j
implement App. Vill, where as a PWR that has no unusual degradation mechanisms could conduct inspections using current standards and App. Vll.1 i
inspections at Ten-Year-Intervals. If tt e App. Vill inspection found significant deficiencies in the current standards utilized at that facility, the App. Vill i
inspection frequency could be adjusted accordingly, i
i
- 4. The proposed GL is not clear as to what the NRC is trying to accomplish via the requested responses. The discussion in the letter combined with the questions i
asked suggests that a utility which is not pursuing implementation of App. Vill type inspections is subject to possible enforcement under the 10CFR50 4
Appendix A and B Criterion mentioned in the proposed GL. This is confusing due to the fact that the NRC could have included App. Vill as part of their rule change when they endorsed the 1989 Edition of the ASME Code in
+
10CFR50.55a. This is the regulation which mandates the ASME edition to be 1
used in the utilities 10-Year-Interval inspection program. Also, if the safety i
significance supported it, the NRC could change 10CFR50.55a without waiting j
for the rulemaking to allow the use of the 1995 Code.
j i
l
.t.
4 Chi f, Rules & R: view Dir:ctor Lett:r RC-97-0024 MSP 970003 Page 3 of 3
- 5. It appears that the S'9C is rightly hesitant to mandate App. Vill, and even l
though some utili'.ts are willing to, and actually have raised their UT standards, the utilities are not likely to make long term commitments to adopt App. Vill standards and the associated cost, without sufficient justification from an increased safety point of view. Therefore, it would be helpful to the utilities if the NRC would refine their description of what level of UT standards is necessary to satisfy the NRC regulations.
i Should you have any questions, please call Mr. Jeffrey Pease at (803) 345-4124.
i Very truly yours, d
~
David A. Lavigne
)
JWP/DAL/nkk c:
J. L. Skolds W. F. Conway R. R. Mahan R. J. White L A. Reyes A. R. Johnson NRC Resident inspector General Managers J. B. Knotts, Jr.
File (810.32) l DMS (RC-97-0024) 4 4