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 ID Commenter Name Affiliation ADAMS Accession Number 1 Jarno Makkonen Private Citizen ML18318A356 2 Ron Clow Private Citizen ML18344A191 3 J. E. O'Sullivan Private Citizen ML18355A760 4 Carl Latiolais Electric Power Research Institute ML19022A074 5 Glen Palmer Private Citizen ML19022A277 6 Richard Porco American Society of Mechanical Engineers ML19022A278 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

PUBLIC SUBMISSION As of: 11/14/18 8:23 AM Received:

November 13, 2018 Status: Pending_Post Tracking No.

1k2-96jg-7bxj Comments Due:

January 23, 2019

Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 CommentMy comments are in the attached PDF as they are too long for this input field.

AttachmentsComments to NRCPage 1 of 111/14/2018https://www.fdms.gov/fd ms/getcontent?objectId=09000064838d4550&format=xml&showorig=false

Submission ID 2 Ron Clow, Private Citizen ML18344A191

PUBLIC SUBMISSION As of: 12/10/18 7:56 AM Received:

December 07, 2018 Status: Pending_Post Tracking No.

1k2-96z7-8cox Comments Due:

January 23, 2019 Submission Type:

API Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 CF R Part 50, Proposed Rule

Subject:

Comment in differenc e 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 pressure test be performed fo llowing 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 ha ve determined that there is no need to perform a pressure test following a repair/replacement activity where the mechanical connection was Page 1 of 212/10/2018https://www.fdms.gov/fd ms/getcontent?object Id=090000648395c2f5&format=xml&showorig=false disassembled and reassembled as gaskets, bolts, studs, nuts, and washers are specifically exempted from Repair/Replacem ent and pressure testing.

For installation into a Code Clas s (1, 2, 3) system, pl ants use components th at are procured as Quality Related in accordance with a QA program and requ ire the items meet material standards, codes, etc. and are subject to additional NDE and tes ting before being utilized. This gives reasonable assurance th at the materials are free of defects and will perform their function during operation.

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

designed and fabricated to a code or design sp ecification provided by the owner, pressure testing is already requ ired of these items. Whenever maintenance is performe d that requires an item to be disassembled, re gardless if it includes an ASME XI repair/rep lacement activity, a leakage chec k 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 unn ecessarily with no ad ded safety benefit as the mechanical connection is already bein g inspected by an oper ator whose training involves the ability know how the equipment operates and to identify leakage or other abnormal conditions during their normal wo rk duties. Additionall y, the mechanical connection is disassembled and reassembled by personnel traine d to perform the activity, including use of industry standard bolt torquei ng guidance to assure pr oper integrity of the joint.

While RCS leakage is always a concern and each utility has requirements to address this leakage, this commenter is una ware of any precedence where a mechanical connection has catastrophically failed wh ich 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 conn ections 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 consideratio n for removal of the condition, plants implementing 10 CFR 50.69 would be implementing an inspection and repair program th at is in lieu of ASME XI and 10 CFR 50.55(a). Implementation of 50.69, would requ ire 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 a nd subsequent pressure testing.Page 2 of 212/10/2018https://www.fdms.gov/fd ms/getcontent?object Id=090000648395c2f5&format=xml&showorig=false

Submission ID 3 J. E. O'Sullivan, Private Citizen ML18355A760

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 addresse d 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 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 (ML 15337A414). 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 XXVI4340 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 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 t he Welding Institute in the UK, the NRC lacks conclusive evidence that either of the two tests proposed in XXVI4342(d) and XXVI4342(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 verificationtesting, the testing performed by The Welding Institute of UK indicated that the HSTI test may not detect jointsfused 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 incontact with heaters must be protected and kept free of fine particulates, as well as other deleterious material.

Also,EPRI Report Testing Methods toEvaluate the Integrity of HDPE Butt

-Fusion Joints

, was developed to assist the NRC with evaluation of mechanicaltesting methods. This report provides the results of limited studies on the comparison of the high speed tensileimpact test to the guided side b end and waisted tensile test methods.

This report identifies that situations can occurwith 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, th is 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 pipeline s 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 coupon s as well as for each installed fusi on joints. This is the approach that was approved by the USNRC as recently as two years ago for the Plant Hatch HDPE Project (ML 15337A414). In addition, all installed nuclear fusi on 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 o n the following explanations

a.) Although ASTM F2620 lacks complete requirements for how to perform the reverse bend test including temperature range, Appendix XXVI

-4342 invokesSection IX QF

-143.1 which does provide explicit directions, including require d 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 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 o f the paragraph (see Summary, below) involving performance qualification testing and reference to XXVI4340 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 XXVI2332(a) and XXVI2332(b) be performed as part of performance qualification tests, instea d 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 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 receiv es 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 electrofusio n 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 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, 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 XXVI4330 and XXVI4340 the following essential variables shall be used for the performance qualification tests of butt fusion joints:

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 with XXVI-2300 and XXVI4330 the following essential variables shall be used for the testing of butt fusion joints:

(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 XXVI4342, 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-433 0, specimen break s away from the fusion zone shall require retesting. 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 thickness es 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 XXVI4330 and XXVI4340, 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 XXVI2300 and XXVI

-4330, the following essential variables shall be used for the testing of electrofusion joints:

(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 XXVI2332(a) and XXVI2332(b) and electrofusion bend tests in accordance with 2017 BPV Code Section III XXVI2332(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.

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.

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

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) O'Sullivan, PE

Procon1 , LLC (314) 221-1800

Submission ID 4 Carl Latiolais, Electric Power Research Institute ML19022A074

"American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference"

(i)Applicable ISI Code: Initial 120-month interval. In-service examination of componentsand 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.

NRC Office of the SecretaryPage 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.

NRC Office of the SecretaryPage 3 (11) Cast stainless steel. Examination of ASME BPV Code Class 1 piping and vessel nozzle butt welds involving cast stainless steel materials, will be performed with Appendix VIII, Supplement 9 qualifications, or qualifications similar to Appendix VIII, Supplement 2 or

10 using cast stainless steel mockups no later than the next scheduled weld examination after January 1, 2022, in accordance with the requirements of Paragraph -2500(a) or, as an alternative, using inspections that meet the requirements of ASME Code Case N-

824 as conditioned in Regulatory Guide 1.147.

NRC Office of the SecretaryPage 4 (L) Specimen set and qualification: Twelfth provision. As a condition to the requirements of Supplement 8, Subparagraph 1.1(c), to Appendix VIII, notches may be located within one

diameter of each end of the bolt or stud.

(2) Where examination from both sides is not possible, full coverage credit may be claimed from a single side for ferritic welds. Where examination from both sides is not possible NRC Office of the SecretaryPage 5 on austenitic welds or dissimilar metal welds, full coverage credit from a single side may be claimed only after completing a successful single-sided Appendix VIII demonstration

using flaws on the opposite side of the weld. Dissimilar metal weld qualifications must be demonstrated from the austenitic side of the weld, and the qualification may be expanded

for austenitic welds with no austenitic sides using a separate add-on performance

demonstration. Dissimilar metal welds may be examined from either side of the weld.

NRC Office of the Secretary Page 6

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

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

Subject:

[External_Sender] EPRI Comments on the Am erican Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Re ference, 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 recipient's 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 reci pient, please contact the sender by reply email and permanen tly 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. ***

Submission ID 5 Glen Palmer, Private Citizen ML19022A277

PUBLIC SUBMISSION As of: 1/22/19 11:38 AM Received:

January 18, 2019 Status: Pending_Post Tracking No.

1k3-97r7-tuqf Comments Due:

January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 CommentComments to proposed rulemaking incor porating 2015-2017 OM Code Editions (See Attached)Attachments Palmer_Rulemaking comments_011819Page 1 of 101/22/2019https://www.fdms.gov/

fdms/getcontent?object Id=09000064839fa90f&forma t=xml&showorig=false Rulemakingcommentsto2015 2017EditionNRC 2016 0082GlenPalmerCommentsJanuary18,2019IthasbeenobservedthatthewordingintheproposedRulemakingdoesnotclearlyidentifyrequirementsforexaminationandtestingofdynamicrestraints,(snubbers)tobeapartofIST,50.55a(f)(4)Inservicetestingvs.ISI,50.55a(g)Preserviceandinserviceinspectionrequirementsandwillrequiresomechangesforclarity.BelowaretheproposedchangesthathavebeendiscussedatindustrymeetingsandarenowsenttotheNRCforconsideration.

Background:

TheNRChasalreadyidentifiedaclearpathforsnubberstobeconsideredapartofISTalongwithpumpsandvalvesinRG1.192.In1990,theASMEpublishedtheinitialeditionoftheOMCodethatprovidesrulesforISTandinserviceexaminationofpumps,valves,anddynamicrestraints(snubbers).TheOMCodewasdevelopedandismaintainedbytheASMECommitteeonOperationandMaintenanceofNuclearPowerPlants.TheOMCodewasdevelopedinresponsetotheASMEBoardonNuclearCodesandStandardsdirectivethattransferredresponsibilityfordevelopmentandmaintenanceofrulesfortheISTandinserviceexaminationofpumps,valves,anddynamicrestraints(snubbers)fromtheASMESectionXISubcommitteeonNuclearInserviceInspectiontotheASMEOMCommittee.TheASMEintendedtheOMCodetoreplaceSectionXIrulesforISTandinserviceexaminationofpumps,valves,anddynamicrestraints(snubbers),andtheSectionXIrulesforISTandinserviceexaminationofthesecomponentsthathadbeenincorporatedbyreferenceintoNRCregulationshavebeendeletedfromSectionXI.TheNRCendorsedtheOMCodeforthefirsttimeinanamendmentto10CFR50.55apublishedonSeptember22,1999(64FR51370).TheNRCendorsedOMCodeCasesthroughthisguideforthefirsttimeinJune2003.ItshouldbenotedthatthetitleoftheOMCodewaschange dbeginningwiththe2009Editionto"OperationandMaintenanceofNuclearPowerPlants."Lookingat50.55a(g),thecurrentpointerto50.55a(f)isonlyforpumpsandvalves.RequirementsforinservicetestingofClass1,Class2,andClass3pumpsandvalvesarelocatedin§50.55a(f)Itdoesnotidentifydynamicrestraints(snubbers).Althoughthewordingisunclear,thepathfromtheISICode,SectionXIClass1,2and3,totheASMEOMCode,SectionISTisidentifiedthroughparagraph50.55a(g)(4),whichdoespointtotheASMEOMCode:(4)Inserviceinspectionstandardsrequirementforoperatingplants.Throughouttheservicelife ofaboilingorpressurizedwater coolednuclearpowerfacility,components(includingsupports)thatareclassifiedasASMECodeClass1,Class2,andClass3mustmeettherequirements,exceptdesignandaccessprovisionsandpreserviceexaminationrequirements,setforthin SectionXIofeditionsandaddendaoftheASMEBPVCode(orASMEOMforsnubber examinationandtesting)thatbecomeeffectivesubsequenttoeditionsspecifiedinparagraphs (g)(2)and(3)ofthissectionandthatareincorporatedbyreferenceinparagraph(a)(1)(ii)or(iv)forsnubberexaminationandtestingofthissection,totheextentpracticalwithinthelimitationsofdesign,geometry,andmaterialsofconstructionofthecomponents.ThisclearlyidentifiestheASMEOMCodefordynamicrestraints(snubbers),whichincludesISTA 1100andthescopingofnonClass1,2and3supports.Thecurrentpointerfrom50.55a(g)(4)toASMEOMCodeidentifiessnubberstobeundertheASMEOMCode.ISTA 1100ScopeSectionISTestablishestherequirementsforpreserviceandinservicetestingandexaminationofcertaincomponentstoassesstheiroperationalreadinessinlight waterreactornuclearpowerplants.Itidentifiesthecomponentssubjecttotestorexamination,responsibilities,methods,intervals,parameterstobemeasuredandevaluated,criteriaforevaluatingtheresults,correctiveaction,personnelqualification,andrecordkeeping.Theserequirementsapplyto(a)pumpsandvalvesthatarerequiredtoperformaspecificfunctioninshuttingdownareactor tothesafeshutdowncondition,inmaintainingthesafeshutdowncondition,orinmitigatingtheconsequencesofanaccident (b)pressurereliefdevicesthatprotectsystemsorportionsofsystemsthatperformoneormore ofthethreefunctionsidentifiedinsubpara.ISTA1100(a)(c)dynamicrestraints(snubbers)usedinsystemsthatperformoneormoreofthethree functionsidentifiedinsubpara.ISTA 1100(a),ortoensuretheintegrityofthereactorcoolant pressureboundary WhentheNRCpublishesthenewRulemaking,dynamicrestraints(snubbers)shouldbeidentifiedalongwithpumpsandvalvesunder50.55a(f),foraddedclarity.BelowisasuggestedmarkuptotheproposedRulemakingtoaccomplishthischange.50.55a(f)(4)Inservicetestingstandardsrequirementforoperatingplants.Throughouttheservicelifeofaboilingorpressurizedwater coolednuclearpowerfacility,pumps,valvesanddynamicrestraints(snubbers)thatarewithinthescopeoftheASMEOMCodemustmeettheinservicetestrequirements(exceptdesignandaccessprovisions)setforthintheASMEOMCodeandaddendathatbecomeeffectivesubsequenttoeditionsandaddendaspecifiedinparagraphs(f)(2)and(3)ofthissectionandthatareincorporatedbyreferenceinparagraph(a)(1)(iv)ofthissection,totheextentpracti calwithinthelimitationsofdesign,geometry,andmaterialsofconstructionofthecomponents.Theinservicetestrequirementsforpumps,valvesanddynamicrestraints(snubbers)thatarewithinthescopeoftheASMEOMCodebutarenotclassifiedasASMEBPVCodeClass1,Class2,orClass3maybesatisfiedasanaugmentedISTprograminaccordancewithparagraph(f)(6)(ii)ofthissectionwithoutrequestingreliefunderparagraph(f)(5)ofthissectionoralternativesunderparagraph(z)ofthissection.ThisuseofanaugmentedISTprogrammaybeacceptableprovidedthebasisfordeviationsfromtheASMEOMCode,asincorporatedbyreferenceinthissection,demons tratesanacceptablelevelofqualityandsafety,orthatimplementingtheCodeprovisionswouldresultinhardshiporunusualdifficultywithoutacompensatingincreaseinthelevelofqualityandsafety,wheredocumentedandavailableforNRCreview.

50.55a(g)Preserviceandinserviceinspectionrequirements.Systemsandcomponentsofboilingandpressurizedwater coolednuclearpowerreactorsmustmeettherequirementsoftheASMEBPVCodeasspecifiedinthisparagraph.Eachoperatinglicenseforaboilingorpressurizedwater coolednuclearfacilityissubjecttothefollowingconditions.Eachcombinedlicenseforaboilingorpressurizedwater coolednuclearfacilityissubjecttothefollowingconditions,buttheconditionsinparagraphs(g)(4)through(6)ofthissectionmustbemetonlyaftertheCommissionmakesthefindingunder§52.103(g)ofthischapter.Requirementsforinservicetestingofpumps,valvesanddynamicrestraints(snubbers)arelocatedinparagraph(f)ofthissection.50.55a(g)(4)Inserviceinspectionstandardsrequirementforoperatingplants.Throughouttheservicelifeofaboilingorpressurizedwater coolednuclearpowerfacility,components(includingsupports)thatareclassifiedasASMECodeClass1,Class2,andClass3mustmeettherequirements,exceptdesignandaccessprovisionsandpreserviceexaminationrequirements,setforthinSectionXIofeditionsandaddendaoftheASMEBPVCode(orASMEOMCodefordynamicrestraint(snubber)examination

,andtestingandservicelifemonitoring)thatbecomeeffectivesubsequenttoeditionsspecifiedinparagraphs(g)(2)and(3)ofthissectionandthatareincorporatedbyreferenceinparagraph(a)(1)(ii)or(iv)forsnubberexaminationandtestingofthissection,totheextentpracticalwithinthelimitationsofdesign,geometry,andmaterialsofconstructionofthecomponents.ComponentsthatareclassifiedasClassMCpressureretainingcomponentsandtheirintegralattachments,andcomponentsthatareclassifiedasClassCCpressureretainingcomponentsandtheirintegralattachments,mustmeettherequirements,exceptdesignandaccessprovisionsandpreserviceexaminationrequirements,setforthinSectionXIoftheASMEBPVCodeandaddendathatareincorporatedbyreferenceinparagraph(a)(1)(ii)ofthissection,subjecttotheconditionlistedinparagraph(b)(2)(vi)ofthissectionandtheconditionslistedinparagraphs(b)(2)(viii)and(ix)ofthissection,totheextentpracticalwithinthelimitationofdesign,geometry,andmaterialsofconstructionofthecomponen ts.

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

PUBLIC SUBMISSION As of: 1/22/19 11:49 AM Received:

January 22, 2019 Status: Pending_Post Tracking No.

1k3-97ts-epep Comments Due:

January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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: ASMETwo Park Avenue New York, NY, 10016 Email: sannac@asme.org General CommentASME is pleased to have th e opportunity to provide comm ents and suggestions on your Nuclear Regulatory Commission (N RC), 10 CFR Part 50, RIN 3150-AJ74, Incorporation by Reference of American Society of Mechanical Engineers Codes and Code Cases, Proposed Amended Requirements, pub lished in Reference 1.

A complete cover letter statement and comments are contai ned in the attached file.Page 1 of 201/22/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a00478&format=xml&showorig=false Attachment s ASME Comments 10CFR50RulePage 2 of 201/22/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a00478&format=xml&showorig=false Tw<J Park Av .. nut <'W York, NY SETTING rHE STANDARD l o o 1 f, -', 'l <J o If . <;

• A

• January 21 , 2019 Secretary, U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attention:

Rulemakings and Adjudications Staff tel 1.212.r;qJ.8'.>00 f ax 1.2 1 2.','ll.8S01 www.asm t.org

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 th i s 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) condit i ons 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 i n 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 (m ichael.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 P roposed Rule , Federa l Reg i ster , Vo l. 83 , No. 218, pp. 56156-56196, Fri d ay, No v ember 9, 2018, Doc k et ID NRC-2016-0 0 82 §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) N I A Visual examination of bolts, studs, and nuts: First ASME be li eves that it i s unnecessary to requ i re personnel perform i ng these provision.

When applying the provisions of NB-exam i nations to be qual i fied i n accordance w i th Section Ill (SNT-TC-1A

). S i milarly , 2582, NC-2582, ND-2582tNE-2582, NF-2582, NG-ASME believes that it i s unnecessary to requ i re visual exam i nat i on procedures to 2582 in the 2017 Edition of Section Ill, the visual be qualified to Sect i on V , Article 9. Ind i cations detected by v i sual exam i nat i on examinations are required to be performed In personnel du r ing these exam i nations would be directly ident i fied and measured; accordance with procedures qualified to NB-5100, un li ke other NOE methods where an evaluation of the ind i cation is performed to NC-5100, ND-5100, NE-5100 , NF-5100, NG-5100 determ i ne acceptab ili ty. 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) N I A Visual examination of bolts, studs, and nuts: The acceptance cr i teria in NB-2582, NC-2582 , ND-2582 , NE-2582 , NF-2582 , Second provision. When applying the provisions NG-2582 i n the 2015 Edi ti on of Sect i on Ill are less prescriptive than those in the ofNB-2582,NC-2582,ND-2582,NE-2582,NF-2017 Ed i tion. For example , NB-2582 (2015 Ed i tion) a ll ows cracks that wou l d not be 2582, NG-2582 In the 2017 Edition of Section Ill, detrimental to the intended serv i ce to be acceptab l e , but i t is not c l ear how a the acceptance criteria from NB-2582, NC-2582, Mater i al Organ i zation wou l d know how to apply th i s criter i on without know i ng the ND-2582, NE-2582, NF-2582, NG-2582 in the intended serv i ce for the items. 2015 Edition of Section fl/ shall be used. ASTM F788 "establishes a ll owable l imits for the various types of s u rface d i scontinuities that may occur dur i ng the manufacture and process of bolts , screws and studs ... " and i s much more prescriptive than the requirements of NX-2582 (2015 Ed i t i on). The same is true regard i ng ASTM F812. ASME believes that the proposed cond i tion is i nappropriate and should be removed. Alternatively , the cond i tion could be rev i sed lo requ i re that the prov i s i ons of NB-2582 , NC-2582 , ND-2582 , NE-2582, NF-2582 , NG-2582 i n 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 Ed i t i on of Section Ill. §50.55a(b)(1 )(xi)(A) NIA 1 Mandatory Appendix XXVI: First provision.

When The NRC proposes to add a new cond i t i on , (b)(1)(x i)(A), which spec i fies the performing fusing procedure qualification tests and essential variables to be used in qua li fying fus i ng procedures for butt fusion jo i nts in operator performance qualification tests in polyethylene p i p i ng. Th i s includes four (4) variables i n addit i on to those stated in accordance with XXV/-4330 and XXV/-4340 the Section IX that are pert i nent to the fus i ng verification testing of XXVl-2300.

These . following essential variables shall be used for the are d i ameter, cross-sectional area, amb i ent temperature

[range specified in XXVI-performance qualification tests of butt fusion 4412(b)], and fus i ng mach i ne carriage model. joints: Previ o us d i scuss i ons w i th the Regu l ator involv i ng deve l opment and incorporation of (1) Joint Type: A change in the type of joint from Tab l es identify i ng all procedure variables appl i cab l e to testing requ i red by Sect i on that qualified, except that a square butt joint IX and Append ix XXVI addressed on l y fus i ng procedure qual ifi cation and testing -qualifies as a mitered Joint. not fus i ng operator performance qua li fication testing. However , the proposed (2) Pipe Surface Alignment:

A change In the pipe amendment (x i)(A) under " PART 50-DOMESTIC LICENSING OF PRODUCTION outside diameter (0.D.) $Urface misalignment of AND UTILIZATION FACILITIES" i nc ludes apply i ng these same essential variab l es more than 10 percent of the wall thickness of the to operator performance qua li fica ti on. thinner member to be fused. Fusing operator performance qua li fi c ation testing i s performed in accordance with (3) PE Material:

Each lot of polyethylene source XXVl-4341 and XXVl-4342 us i ng fus i ng p r ocedures tested in accordance with mater/a/ to be used in production (XXVl-2310(c)).

XXVl-2300. Such fus i ng procedures define the fusing ma c hine make and model (s) to be used i n producti o n of each jo i nt , so the fus i ng operator is required to qua li fy (4) Wall Thickness:

Each thickness to be fused in on the same mach i nes and mode l s. H o we v er, fus i na ocerators are aua lifi ed to u se Pa g e 1 of 13 Enclosure 1 ASME Comm ents on 1 0 C FR 50.55a Pro po sed Rule, Federa l Register, Vol. 83, No. 218, pp. 56156-56 196 , Friday, Novembe r 9, 2018, Docket I D NRC-2016-0 0 82 §50.SSa Paragraph Existing §50.SSa Regulations Proposed Changes to §50.SSa Regulations ASME Comments on §50.SSa Regulations

-Existing and P ro pose d C h anges (as of 11/09/2018) (Changes denoted by Bold Italics) production (XXVl-2310(c)).

those mach i n es over ranges o f d i am e t e r s and thicknesses , no t o n e a c h d i ameter to (5) Diameter: Each diameter to be fused In be f u sed. Th i s is the approach that was app r oved by t he USN RC as r ecentl y as two production (XXVJ-2310(c)J-years ago fo r t he P l ant H atch HDPE P r o j e ct (ML 1 5337A4 1 4). To requi re ea c h f u s i ng operator to perf or m qua li f i ca tio n tes t ing on e ach d i a m ete r, t h i c k nes s and l ot (6) Cross-sectional Area: Each combination of of mat erial would en t a i l s i gni fican t ad ded expense a nd hards hi p witho ut a thickness and diameter (XXVl-2310(c)).

com m e n su rate i m pro ve men t i n q u a li ty o r safety. (7) Position:

Maximum machine carriage slope ASME recommen ds that the first paragraph of §50.55a(b}(1}(x i)(A) be re v i sed to when greater than 20 degrees from horizontal read as fo ll o w s: (XXVl-4321(c)). " Mandatory Appendix XXVI: First provis i on. When perform i ng fus i ng proc edure (8) Heater Surface Temperature

A change In the qual i f ic at ion test i ng in accordance with XX V l-2300 and XXVl-4330 the fo ll ow i ng heater surface temperature to a value beyond the essential var i ab l e s shall be used for the testin g of butt fus i on jo i nt s:" range tested (XXVl-2321). ASME notes that th es e requ ir eme nt s for fusing procedure te s tin g w ill be addressed (9) Ambient Temperature:

A change In ambient further with the publication of procedure testi ng changes in the 2 019 Edition of temperature to Jess than 50 °F (10 °C) or greater ASME Sec tion Ill, Appendi x 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 s iz e from that qualified. (12) Increase in Heater Removal Time: An increase In heater* plate removal time from that qual ifie d. (13) Decrease I n 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

)(x i)(B) N/A / Mandatory Appendix XXVI: Second provision.

The NRC p r opose s to add a new parag r a ph (b)(1)(xi)(B), wh i ch w ill requ ir e bot h When performing qualification tests of butt fusion bend tests and hig h speed te n s i l e i mpac t testing (HSTIT) to q u a l i fy f u s i ng Joints in accordance with XXVl-4342 , both t he bend p ro cedures a nd to qua li fy fusing operato r s , fo r f us i n g jo i nt s in po l ye t h yl ene test and the high speed tensile impact test shall be pip in g .... Th e explanat i on of t he proposed r u li ng states: " T h e NRC h as perfor m ed successfully completed.

lim i t ed co nfir ma t ory research on t he a b ili ty o f short-term mec ha nic a l t ests to pred i ct t h e i n-serv i ce behav i or of HDPE b u tt f u s i on j oints. Based o n th i s research as well as research resu l ts from t he Weld ing Inst i t u te i n t h e UK, t he NRC l ac k s conclusive evidence th a t e i t h er of t he two t es t s proposed i n XXVl-4342(d) a n d XXVl-4342(e) is always a re l i a ble pred ic t or of j o in t qua li ty. As a result, the NRC has determ i ned that the com b i natio n of both t es t resu l ts provi des i ncreased a n d s u ffi c i ent ind i cation of butt f usion joint quality .... ' Co mm ents: 1. F us i ng Procedure Testing: Rela tiv e to jo i nt tes ting for p r ocedu r e qu a lification or XXVl-2300 f u sing verification test i ng, the test i ng pe rformed b y The Welding Ins titute of UK i ndica t ed that t h e HSTI test mav not detect io i nts f u sed w i t h fi ne Page 2 of 13 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Ru l e, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-2016-0082

§50.SSa Paragraph Existing §50.SSa Regulat ions 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 t alcum powder sized particles placed with i n the jo i nt. As a result of that testing , Paragraph XXVl-4412(a)(1) and XXVl-4412(a)(2) of Appendix XXVI , specifically require that joint surfaces com i ng 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-Fus ion Jo i nts," was developed to assist the NRC with evaluation of mechanical testing methods. Th i s report provides the resu l ts of lim i ted studies on the comparison of the high speed tensile impact test to the guided side bend and waisted tensile test methods. Th i s report identifies that situations can occur with t he HSTI test where the spec i men ruptures outside of the fus i on zone wh i le us i ng the HSTI test method. If this occurs, a recommendation is provided for nuc l ear applications that the cause be evaluated by assessing the amount of increased fusion interface resulting from t he fusion beads, and/or presence of ou t*of-roundness of the jo i ned parts. (If there is indication of m i nimal or no increased fusion interface , or that m i smatch exists between the parts be i ng jo i ned, the test should be re-performed with beads and m i smatch removed.)

Therefore, this prov i sion should be revised to instead requ i re retests for any HSTI ruptures occurring away from the fusion zone. 2. B. Fusing Operator Testing: Reverse bend testing has been used extensive l y and successfully for decades for the qua li fication of fus i ng operators in the U.S. for jo i ning polyethylene water and gas p i ping. Bend testing is endorsed by DOT for performance qual i fication for the fus i ng of interstate gas transmission p i pelines as well as for local gas d i stribution pipel i nes (Ref. 49 CFR 192.285). Government acceptance for use of only visual inspection of the test joint plus bend test i ng for performance qua li ficat i on on vo l atile gas pipelines certainly supports its use for nu clear applications

-where, in addition to the visua l inspection and bend testing, the joint parameters are also requ i red to be I recorded and ver i fied dur i ng preparat i on of the qualification test coupons as well as for each insta ll ed fus i on joints. Th i s is the approach that was approved by the USN RC as recently as two years ago for the Plant Hatch HOPE Project (ML 15337A414).

In add i t i on, all installed nuclear fusion joints receive vo l umetric examination (ult rasonic or microwave) plus a hydrostat i c test at 1.5 times maximum des i gn pressure, va li dating the integr i ty of each join t fused by each operator. The additional requ i rement to perform HST! test in addition to bend testing during performance qua l ificat i on imposes additional hardship and increased cost without commensurate improvement in qua li ty or safety. Paragraph 7.4 of EPRI Report 3002005434 provides reasons why the reverse bend test m i ght be cons i dered unacceptable for nuclear applications.

Th e stated reasons are i naccurate 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-4 342 invokesSection IX QF-143.1 wh i ch does provide explicit d i rections , i nc l ud i ng required temperature range. b) Although ASTM F2620 may lack clarity on how to perform the test,Section IX , QF-143.1 wh i ch is invoked bv Aaaendix XXVI does provide specific Page 3of 13 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Ru l e , Federal Reg is ter, Vol. 83 , No. 218 , pp. 56156-56196, Friday , November 9, 2018 , Docket I D NRC-2016-0 0 82 §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 rad i i or coupon th i ckness , ,Section IX, QF-143.1.3 and QF-463 provide exp li cit direction on how to cut the specimens and perform the test. The spec i men th ick ness , t, is the thickness of the jo i nt per QF-463 , and the bend rad i us i s defined by the 151 d i mens i on e i ther s i de of the join t with the requ i rement to bend back until both 151 ends touch. Th i s defines the ratio of thickness to bending length, which is a d i rect proportion regard l ess of what th i ckness i s bent, and a l ways results in a def i ned bend i ng radius or arc at the apex of the tested joint of approx i mately 31. A 31 arc at the apex of the bend results in at l east a 15% strain , which exceeds the 10-12% yield stra i n of HDPE materia l. d) One test report iden tified by EPRI stated that Reverse Bend testing of 1.33 in. thick 12 NPS PE p i pe did not identify defects that were detected by HSTI testing and Guided S ide Bend test i ng. With the advent of the GSB test, most fus i ng organizations are now us i ng gu i ded side bend tests i n lieu of reverse bend tests for qua li fying 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 us i ng reverse bend tests for thick sect i ons as indicated in our revised wording, below. Note: HSTI testing machines are qu ite scarce and expensive.

For fusing procedure ver i ficat i on testing (XXVl-2300) t he test spec imens are typically sent to a laboratory or shop to have the HSTI testing performed.

To requ ire th is be done fo r performance qua li fi c at i on purposes would add extra non-product i ve days for fusing operators, p l us it would require send i ng qua l i ty con trol personne l for witness i ng the off-s it e testing. S i nce t he only technical issue seems to be an anomaly w i th one test performed on 1.33 i n. th i ck material, a ' reasonab l e reso l ut i on would be to reword the prov i s i on to mandate use of side bend tests (i.e., prohibit use of re verse bend tests) for performance qualification on all p i ping th i cknesses over 1.25 in. e) Based on the above i naccu rac ies, the EPRI report suggested that other tests be used in place of or in add i tion to the Re verse Bend Test. Cons i dering the scarcity and expense of using HSTI test mach i nes, impos i ng the cond i t i on to requ i re HSTI test in add iti on to Reverse Bend or Guided Side Bend tes ting for all performance qua li fication imposes excessive cost and add i tional hardsh i p without a commensurate im provemen t in qua li ty or safety. ASME recommends that the proposed cond i tion {§50.55a(b)(1}(xi)(B)]

be re vised to read as follows: " Mandatory Appendi x XXV I: Second P rovision.

When performing procedure qualificat i on HSTT te s ting of butt fus io n joints in ac c ordance with XXVl-2300 or XXVl-4330 , spec i men breaks away from the fusion zone shall require ret esting. When perform i ng fusing operator qua li fication bend tests of butt fusion jo i nts in accordance w ith XXV/-4342, guided side bend t es t i ng shall be used for all th i cknesses greater than 1. 25 inches." Page4of 13 Enclosure 1 ASME Comments on 10 CFR 50.SSa Proposed Ru l e, 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

)(x i){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 qualify i ng fus i ng procedures for electrofus i on of operator performance quslificatlon tests in fusion jo i nts in polyethylene piping that is to be insta ll ed in accordance with ASME accordance with 2017 Edition of BPV Code Section BPV Code, Section Ill, Mandatory Append i x XXVI. This inc l udes four (4) variab l es Ill XXVl-4330 and XXVI-4340, the fol/owing in addition to those stated in Section IX that are pertinent to the fusing ver i fication essential variables shall be used for the test i ng of XXVl-2300. These are: fitt i ng polyethy l ene material, pipe wall thickness, performance qualification tests of electrofuslon power supply, and processor. joints: Prev i ous d i scuss i ons with the Regulator involv i ng development and incorporation of (1) Joint Design: A change in the design of an Tab l es i dent i fying all e l ectrofusion procedure variab l es app l icable to testing electrofusion Joint. requ i red by Sect i on IX and Append i x XXVI addressed only fus i ng procedu r e (2) Flt-up Gap: An Increase In the maximum radial qua li fication and testing -not fus i ng operator performance qua li fication testing. flt-up gap qualified.

However, the proposed amendment (xi)(C) under "PART 50-DOMESTIC LICENSING OF PRODUCTION AND UTILIZATION FACILITIES" inc l udes app l ying (3) Pipe PE Material:

A change in the PE these same essential variab l es to operator performance qual i fication.

designation or cell classification of the pipe from Fusing operator performance qua li fication test i ng is performed In accordance with that tested ()(XVI-2322(a)).

XXVl-4341 and XXVi-4342 us i ng fus i ng procedures tested in accordance w i th (4) Fitting PE Material:

A change in the XXVi-2300.

Such fus i ng procedures define the electrofusion fitting materia l, p i pe manufacturing facility or production lot from that wall thickness , power supply and processor , to be used in production of each jo i nt , 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 equ i pment. Therefore , the proposed word i ng of the paragraph

{see Summary , In production (XXVl-2310(c)). be l ow) I nvolving performance qua l ification testing and reference to XXVl-4340 should be removed from that 10CFR50.55a paragraph. (6) Fitting Manufacturer:

A change in fitting ASME notes that these requ i rements for electrofus i on procedure test i ng will be manufacturer.

addressed further with the publication of procedure test i ng changes i n the 2019 (7) Pipe Diameter:

Each diameter to be fused In Edition of ASME Section Ill , Appendi x ><XVI. production (XXVl-231Q(c)).

ASME recommends that the first paragraph of §50.55a(b}(1)(xi}(C) be revised to . (8) Cool-down Time: A decrease in the cool time at read as fo ll ows: pressure from that qualified.

" Mandatory Appendix ><XVI: Third provis i on. When performing fus i ng procedure

-(9) Fusion Voltage: A change in fusion voltage. qual i fication tests in accordance with 2017 Edition of BPV Code Sect i on Ill ><XVI-* (10) Nominal Fusion Time: A change in the nominal 2300 and XXVl-4330 , the fo ll ow i ng essential variables shall be used for the testing fusion time. of electrofus i on 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 Pro posed 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 test i ng is designed for smaller fittings 8 NPS and less. Such te s ts are Performance of crush tests In accordance with i mpractical and unsafe for s izes larger than B NPS due to t he l a rge hydrau l ic 2017 BPV Code Section Ill XXVl-2332(a) and XXVI-e q uipme n t that would be requ ire d. For t h is reason, ASTM F1055 provides the 2332(b) and electrofusion bend tests in accordance e l ectrofusion be n d test (FET) as a means of verify i ng f usio n integr ity for sizes over with 2017 BPV Code Section fl{ XXVl-2332{b) are B NPS. There is no evidence that e i ther of th e se tests are inadequate for the i r required to qualify fusing procedures for in tended purpose. e/ectrofuslon Joints In polyethylene piping installed Every electrofus io n socket join t insta lled i n a nuc l ear system a l so requires In accordance with 2017 Edition of ASME BPV CodE producing and testing an i denti ca l coupon us i ng the same lot, s i ze and th ic kness of Section Ill, Mandatory Appendix XXVI. material and fitting , the same equipment , the same power supply and the same fus i ng _procedure u n der -230 0 of Appendi x X.XVI. In addition, every electro f usion j oi nt installed in a nuclear system re q ui res data record i ng to verify the operator used the correct procedure, each joi nt rece ives full visual i nspect io n, rece ives full volumetric exam in at i on of the fused jo i nt p lus hydrostatic testing at 1.5 times the des ig n pressure. Th i s proposed cond i tion imposes significant cost, hardsh i p and pe rso nnel safety is sues without any improvement i n qual i ty. ASME recommends that the orooosed cond i tion be removed i n the f i nal rule. §50.55a(b)(1 ){xi)(E) NIA Mandatory Appendix XXVI: Fifth provision. The NRC is p ropo s i ng to add a new paragraph (b)(1}(xi)(E), which proh i bits the use Electrofusion saddle fittings and electrofusion of e l e ct r of usion saddle fitt i ngs and e le ct ro fus ion saddle jo i nts. Some Department of saddle joints are not permitted for use. Only full Energy operat ional experience in dicates that fa i lures have o ccurr ed in electrofusion 360-degree seamless sleeve electrofusion jo i nts. The NRC has determined t hat the fa il u re of a saddle type electrofusion joint couplings and full 360-degree electrofusion socket cou l d res ul t in stru c t u ra l separation of t he electrofus i on sadd l e coup li ng from t h e joints are permitted.

HDPE p i pe i t is a t tached to , resu lting i n a potential Joss of flow and toss of safety fun cti on in the system. ' U nl ike the fa il ures id ent i fied by DOE , every electrofusi o n sadd l e j oi n t i nstalled i n a nuclear system re quires p roducing and testi n g an identical coupon using the same equ i pment and po we r supply under -2300 of Append ix XXVI. In addit i on , each insta ll ed saddle jo in t receives visual verification of f i t-up gaps , a lig nment and out-of-roundness , rec o rd i ng and ver i fication of the actual fusing variables , full volumetric examinat i on of the fused jo i nt , and a hydr o sta ti c pressure test at 1.5 t im es the design pressure.

Without the capability of us i ng electrofusion saddle connections, nec ess ary mod i fications to or r epai r s of e xisti ng i ns ta lla t io ns cou l d be cost prohib i t i ve, impos in g significant hard shi p without any i mpro v emen t in q ua l it y or safety. ASME recommends that the proposed condi tion be removed in the final rule. §50.55a(b)(2)(vi ii) (vi i i) Sect io n XI cond i tion: Concrete N IA Th i s condition app li es to the several olde r ed itio ns and addenda of Sect i on XI that , containment examinations. Applicants or to th e know l edge of ASME , are no longer i n u se in t he United Sta tes. licensees app l ying Subsection IWL , 1992 ASME re c o mmends that the NRG consider remov ing applicable co nd ition s that Edit i on with the 199 2 Addenda, m ust apply apply to the 1992 Editi o n wit h the 1992 Addenda , and any later code ed i t io n s and paragraphs (b)(2)(viii)(A) thro u gh (E) of th i s addenda th a t are no lonaer in use bv an v U.S. olants. P age 6 of 13 Enclo su re 1 ASME Comments on 10 CFR 50.55a Proposed Ru le, Federa l Reg iste r , Vol. 83, No. 2 1 8, 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 app l ying Subsection IWL , 1995 Ed i tion with the 1996 Addenda , must apply paragraphs (b)(2)(vi ii)(A), , (b)(2)(vi ii)(D)(3), and (b)(2)(viii)(E) of this section. Applicants or lic ensees app l ying Subsection IWL , 1998 Ed i tion through the 2000 Addenda , must app l y paragraphs (b)(2)(v iii)(E) and (F) of th i s section. Applicants or licen sees applying Subsection IWL , 2001 Ed i t i on through the 2004 Ed i tion, up to and i nc l ud in g the 2006 Addenda , must app ly paragraphs (b)(2)(viii)(E) thr ough (G) of this section. App li cants or licensees applying Subsect io n IWL , 2007 Ed i tion up to and inc l ud i ng the 2008 Addenda must app l y paragraph (b)(2)(vi i i)(E) of this section. Applicants or lice nsees applying Subsection JWL , 2007 Ed i tion with the 2009 Addenda through the l atest ed i t i on and addenda i ncorporated by reference in paragraph (a)(1)(ii) of th i s sect io n, must apply oaraaraohs

/bl/21/vi i il/Hl and m of th i s section. §50.55a(b)(2)(viii)(A) (A) Concrete containment exam i nations: F irst NIA Th i s cond i tion app li es only when us i ng the 1995 Ed i t i on with the 1996 Addenda and provision. Grease caps that are access i b l e earlier ed i tions/addenda of Section XI. must be visually e x am i ned to detect grease ASME recommends that the NRG consider removing this condition because there leaka ge or grease cap deformations. G r ease should be no U.S. plants sti ll us ing the 1995 Ed ition wi th the 1996 Addenda or caps must be removed for th is examination earlier editions/addenda of Se ction XI. when the r e i s e vide nce of grease cap deforma ti on that ind ic ates deterioration of anchoraae hardware.

' §50.55a(b)(2)(v ii i)(B) (B) Con c rete conta in ment e x am i nat i ons: N/A Th i s cond i tion app li es on l y when us i ng the 1992 Ed i t i on with the 1992 A d denda of Second provision.

When evaluation of Sect i on XI. consecutive surve ill ances of P.r e-stressing ASME recommends that the NRG cons i der remov i ng this cond iti on because there forces for the same tendon or tendons in a group in d ic ates a tr end of p re-stress loss such should be no U.S. plants st ill us i ng the 1992 Edition with the 1992 Addenda of that the tendon force(s) would be less t han the Sec tion XI. m i n i mum des i gn pre-stress requ i rements before the next insp ectio n interval, an eva l uat i on must be performed and reported in t he Eng i neer i ng Eva lua t i on Report as prescribed i n IWL-3300. §50.55a(b)(2)(vi i i)(C) (C) Concrete conta i nment e xami nat io ns: Third N/A Th i s condition appl i es on ly when us ing the 1992 Edition w i th the 1992 Addenda of provision.

When the e l ongation co rrespond ing Se c tion XI. to a specific load (adjusted for effective wires or ASME recommends that the NRG consider rem oving this condition because th e r e strands) during re-tensi oni ng of tendons d i ffers should be no U.S. p l ants still using the 1992 Ed i t i on with the 1992 Addenda of by more than 1 O percent from that recorded Sec t io n XI. d u ring t he l ast measurement , an ev alua tio n Pa ge 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, Do c ket 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 d i fference is related to wire failures or slip of wires in anchorage. A d i fference of more than , 10 percent must be identified in the ISi Summarv Reoort reau i red bv IWA-6000. §50.55a(b)(2)(vi i i)(D) (D) Concrete containment examinations:

Fourth N I A Th i s condition app li es only when us i ng the 1995 Ed i t i on with the 1996 Addenda and prov i sion. The applicant or licensee must report earlier editions/addenda of Sect i on XI. the following cond i tions , if they occur , i n the ISi ASME recommends that the NRG cons i der remov i ng this condition because there Summary Report requ i red by IWA-6000: should be no U.S. plants st ill us i ng the 1995 Edition with the 1996 Addenda or (1) The sampled sheath i ng filler grease earlier ed i tions/addenda of Section XI. conta i ns chemically comb i ned water exceed i ng 1 O percent by we i ght or the presence of free water; (2) The absolute difference between the amount removed and the amount replaced exceeds 1 o percent of the tendon net duct vo l ume; and (3) Grease leakage is detected during general v i sual examination of the containment surface. §50. 55a(b)(2){ix) (ix)Section XI cond i tion: Metal containment (ix)Section XI condition: Metal containment Th i s condition applies to the several o l der edit i ons and addenda of Section XI that , examinat i ons. App li cants or l i censees applying examinations. Appl ic ants or l i censees apply i ng to the know l edge of ASME, are no longer in use i n the United States. Subsection IWE , 1992 Ed i tion with the 1992 Subsect i on IWE , 1992 Edition with the 1992 Addenda, ASME recommends that the NRG consider removing app lic able condit i ons that Addenda, or the 1995 Ed i tion with the 1996 or the 1995 Ed i tion with the 1996 Addenda , must apply to the 1992 Edition with the 1992 Addenda, and any later code ed i tions and Addenda , must sat i sfy the requ ir ements of sat i sfy the requ i rements of paragraphs (b)(2)(ix)(A) addenda that are no longer in use by any U.S. plants. paragraphs (b)(2)(i x)(A) through (E) of th i s through (E) and (b)(2)(ix)(K) of this section. Applicants section. Applicants or licensees applying or lice nsees applying Subsection IWE , 1998 Edition Subsection IWE , 1998 Edition through the 2001 through the 2001 Ed i tion w i th the 2003 Addenda , must Edition with the 2003 Addenda , must satisfy the sat i sfy the requ i rements of paragraphs

{b)(2)(ix)(A) and r equirements of paragraphs (b)(2)(ix)(A) and (B) (B) and (F) through (I) and (b)(2)(/x)(K) of th i s sect i on. and (F) through (I) of th i s sect i on. Appl i cants or Applicants or licensees app l y i ng Subsection IWE , 2004 l icensees applying Subsect i on , IWE, 2004 Ed i tion , up to and including the 2005 Addenda, must Edit i on , 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 th i s App li cants or licensees app l ying Subsection IWE , 2004 section. App l icants or licensees applying Edition w i th the 2006 Addenda , must satisfy the Subsection IWE , 2004 Edition with the 2006 requ i rements of paragraphs

{b){2)(ix)(A)(2) and Addenda, must sat i sfy the requirements of (b)(2)(ix)(B) and (b)(2)(/x)(K) of th i s section. Applicants paragraphs (b){2)(ix)(A)(2) and (b)(2)(ix)(B) of or lic ensees applying Subsection IWE , 2007 Edit i on this section. Appl i cants or l i censees applying through the 2015 Edition must satisfy the Subsection IWE , 2007 Edition through the l atest requirements of paragraphs (b)(2)(ix)(A)(2) and edit i on and addenda i ncorpora te d by reference (b)(2J(lx)(B) and ( J) and (K) of this section. i n paragraph (a)(1 )(i i) of th i s section, must Applicants or licensees applying Subsection

/WE satisfy the requ ire ments of paragraphs 2017 Edition must satisfy the requirements of (b)(2)(ix){A)(2) and (b)(2)(ix)(B) and (J) of th i s 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 Ru le, Federal Register, Vol. 83, No. 218, pp. 56156-56196, Friday, November 9, 2018, Docket ID NRC-20 16-0 082 §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 conta i nment exam i nations: Th i rd No changes proposed.

This condition appl i es only when us i ng the 1995 Ed i tion with the 1996 Addenda and provision.

The exam ina t ion s specified in earlier editions/addenda of Sect ion XI. Exam i nation Category E-8 , Pressure Reta i n i ng , ASME recommends that the NRG consider remov ing this cond i tion because there Welds, and Exam i nation Category E-F, should be no U.S. p l ants still using the 1995 Edition with the 1996 Addenda or Pressure Reta ining Diss i milar Metal Welds, are ear lie r editions/addenda of Section XI. ootional.

§50.55a(b)(2)(ix)(D) (D) Metal conta i nment exam i nat ion s: Fourth No changes proposed.

This condition app li es only when us i ng the 199 5 Ed ition with the 1996 Addenda and provision.

This paragraph (b)(2)(ix)(D) may be earlier editions/addenda of Sect ion XI. used as an a l ternat ive to the requ i rements of ASME recommends that the NRG consider remov ing this condition because there IWE-2430. If the exam i nations reveal flaws or areas of degradation exceeding the acceptance should be no U.S. plants sti ll us in g the 1995 Ed ition with the 1996 Addenda or standards of Table IWE-3410-1, an evaluation earlier editions/addenda of Section XI. must be performed to determ i ne whether additional component exam i nations are required.

For each flaw or area of degradat i on identified that exceeds acceptance standards , the applicant or licensee must provide the fo ll owing in the ISi Summary Report required by IWA-6000: (1) A descr iptio n of each flaw or area, including the extent of degradation , and the cond i tions that led to the degradation; (2) The acceptability of each flaw or area and the need for addit i onal exam ination s to verify that s i m il ar degradation does not exist i n s i milar components; (3) A description of necessary corrective actions; and (4) The number and type of ~dditional e xami nations to ensure detection of s i m il ar dei:iradation in sim il ar components. §50.55a(b)(2)(ix)(E) (E) Metal containment exam i nations: F ifth No changes proposed.

This condition appl i es only when using the 1995 Ed ition with the 1996 Addenda and provision. A general visual examination as earlier ed i tions/a ddenda of Section XI. requ i red by Subsection IWE must be performed ASME recommends that the NRG consider remov i ng this condition because there once each period. 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 leak age tests: Second provision. (B) System leakage tests: , Second prov isio n. The ASME cont inu es to bel i eve that this cond i tion is unnecessary for reasons The NOE provision in IWA-4540(a)(2) of the nondestructive examination method and do c umented in our letter dated November 30 , 2015 to Secretary, U.S. Nuclear 2002 Addenda of Section XI mus t be app li ed acceptance criteria of the 1992 or later of Section Regulatory Commission, Washington , DC 20555-0001, Sub j ect: Comments on when perform i ng system leakage tests after Ill shall be met when performing system leakage Incorporation by Reference of American Soc i ety 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. we l d i ng or brazing on a pressure retain i ng 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 fo llowin a editorial chanaes be incoroorated:

Page 9 of13

§50.SSa Paragraph

§50.55a(b)(2)(xxv)

Enclosure 1 ASME Comment s on 10 CFR 50.SSa Proposed Ru l e, Federal Register , Vol. 83, No. 218, pp, 56156-56196 , Friday, No v ember 9, 2018, Docket ID NRC-2016-0 0 82 Existing §50.SSa Regulations (as of 11/09/2018) latest ed i tion and addenda i ncorporated by reference in paragraph (a)(1)(i i) of th i s section. (xxv) Sect i on XI cond i t i on: M i tigat i on of defects by mod i f i cat i on. The use of the provisions in IWA-4340 , "Mit i gat i on of Defects by Modification

,"Section XI , 2001 Ed i tion through the latest edi ti on and addenda incorporated by reference in paragraph (a)(1 )(i i) of th i s section are proh i bited. Proposed Changes to §50.SSa Regulations (Changes denoted by Bold Italics) pressure retaining boundary using the 2003 Addenda through the latest edition and addenda of Section XI lncorporate<j by reference in 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, (xxv) Sect i on XI condition:

M i t i gation of defects by modification. The use of the provisions i n IWA-4340 , shall be subject to the following conditions: (A) Mitigation of defects by modification:

First provision.

The use of the provisions for mitigation of defects by modification in IWA-4340 of Section XI 2001 Edition through the 2010 Addenda, Is prohibited. (B) Mitigation of defects by modification:

Second provision.

The use of the provisions for mitigation of defects by modification in IWA-4340 of Section XI 2011 Edition through the 2017 Edition may be used subject to the following conditions:

(1) The use of the provisions in IWA-4340 to mitigate crack-llke defects or those associated with flow accelerated corrosion are prohibited.

(2) The design of a modification that mitigates a defect shall incorporate a loss of material rate either 2 times the actual measured corrosion rate In that pipe location (established based on wall thickness measurements conducted at least twice in two prior consecutive or nonconsecutive refueling outage cycles In the 10 year period prior to lnstallatlon of the modification, or 4 times the estimated maximum corrosion rate for the piping system. The Owner shall perform a wall thickness examination In the vicinity of the modification and relevant pipe base metal during each refueling outage cycle to detect propagation of the flaw into the material credited for structural integrity of the 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. Pa g e 10 o f 13 ASME Comments on §50.SSa Regulations.

Existing and Proposed Changes 1. Revise " 1992 or later" to read " 1992 Ed i t i on or later editions ... " 2. In the last sentence , insert " program" after " ISi". ASME would l ike to thank the NRG for reeva l uating the changes made to IWA-4340 pub li shed i n the 2011 Addenda. ASME has no comments on the new paragraph (b)(2)(xxv)(A), wh i ch continues the proh i b i tion of IWA-4340 in Ed i t i ons and Addenda prior to 2011 Addenda. For new paragraph (b)(2)(xxv)(B), ASME has no comments on the first and second proposed cond i tions. Regarding the proposed th i rd condition in {b)(2)(xxv)

{B), ASME has no comments regarding perform i ng wall th i ckness examinat i ons every refue li ng outage for mod i ficat i ons insta ll ed in access i b l e locations. However, for mod i ficat i ons i nsta ll ed in inaccess i b l e locations (e.g. buried p i p i ng , p i p i ng encased in concrete, etc.), ASME be l ieves that requ i ring e x am i nat i ons to be performed every refuel i ng outage is onerous. The e x cavation costs and the risk of damage to the pip i ng system to perform these exam i nations far outweigh the small increase in safety as a result of exam i nat i on at the modification. Instead, corros i on rates can be va li dated at accessib l e degraded l ocations , in the same p i p i ng system, to confirm the des i gn corrosion rates for the inaccessib l e locations. Exam i nations performed to validate corrosion rates are prudent. However, ASME be l ieves those exam i nations should be conducted at one half of the remaining expected life of the modification , or every ten years from the date of i nsta ll ation , wh i chever is more frequent.

ASME recommends that this cond i tion be revised to read as follo w s: "For accessible lo c ations , the Owner shall perform w all thickness e x aminations in the vic i nity of the mod i f i cat i on and relevant p i pe base metal to detect p r opagat i on ol the flaw info the material cred i ted for structural integr i ty o f the i tem. For inaccess i b l e locations (e.g. bur i ed , encased in concrete , etc.}, the O w ner may va li date flaw growth by performing exam i nations at an access i b l e degraded location in the same system. Examinations sha l l be performed every refueling outage unless /he actual flaw growth i s val i dated by examination in t w o consecutive refue li ng outages. For inaccess i b l e locations , the Owner sha ll a l so perform w all th i ckness examinat i ons in the v i c i nity of the mod i fication and re l evant p i pe base metal to detect propagat i on of the fla w i nto the material credited for structural i ntegrity of the item. These e x am i nations shall be perf o rmed prior to e x ceed i ng one half of the expected l i fe of the repa i r, or at least once e v ery ten years , w h ic hever occurs first."

En c losure 1 ASME Comments on 10 CFR 50.55a Pro p osed Rule , Federal Register, Vol. 83, No. 218, pp. 56156-56196, Fr i day, No v ember 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 cond i tion: Pressure test i ng (xxvl)Section XI condition:

Pressure testing Class ASME cont i nues to be li eve that th i s cond i tion i s unnecessary and offers the Class 1 , 2 and 3 mechan i cal jo i nts. The repa i r 1, 2 and 3 mechanical joints. When using the 2001 fo ll owing comments regard i ng th i s condition: and replacement ac t iv i ty prov i s i ons in IWA-Edition through the latest'edition and addenda 1. The revised system leakage test requ i rements in the 1999 Addenda and later 4540(c) of the 1998 Ed i tion of Sect i on XI for incorporated by reference in paragraph (a)(1)(ii) of editions and addenda are cons i stent w i th the construction requ i rements for pressure test i ng Class 1, 2 , and 3 mechanical this section , licensees shall pressure test mechanical jo i nt leakage in Section Ill of the ASME Code. Sect i on Ill does not j o i nts must be app l i ed when us i ng the 2001 mechanical Joints In Class 1, 2, and 3 piping and proh i bit leakage at mechanica l connections , and requ i res only that mechanical Ed i t i on through the latest ed i tion and addenda components greater than NPS-1 which are connection leakage not mask other leakage. i ncorporated by refere n ce in paragraph (a)(1)(ii) disassembled and reassembled during the of this sect i on. performance of a Section XI activity (e.g., Op e rators and system eng i neers per i od i ca ll y mon i tor systems for lea k age and repair/replacement activity), in accordance with evaluate if correct i ve action i s warranted when leakage is i dentified. IWA-5211(a).

The pressure test and examiners Post-ma i ntenance test programs requ i red by operating p l ants' current lic ens i ng shall meet the requirements of the bases specify requ i rements for leak test i ng mechan i cal conne c tions fo ll ow in g licensee's/applicant's current ISi code of record. reassemb l y. Sect i on XI does not provide any acceptance cr i ter i a for mech a nical jo i nt l ea k age fo ll ow i ng reassembly, and i t has always been the responsib i l i ty of l i censees to determ i ne if correclive action i s warranted. ASME does agree with the NRC that there i s much confus i on in the i ndustry regarding th i s cond i tion , and agree that t he NRC should clar i fy , in deta i l , their posit i on on what repa i r/repl a cement activ i t i es affe c t i ng me c han i cal j oi nts requ i re pressure testing. However , ASME does not be li eve the proposed amendment to 10 CFR 50.55a(b)(2)(x xv i) w i ll accomp li sh that goa l, and may ac t ually cause additional confusion. The proposed amendment states in part " .. a ll me c han i cal jo i nts ... that are disassemb l ed and reassemb l ed during the performance of a Se c t i on XI ac t i vi ty ... sha ll be pressure tested ... " This statement can be read to apply to a flanged p i p i ng spool removed s i mply to provide access to the po rti on of a component subject to a repair/replacement activ i ty , to repla c e ga sk eti n g , or to apply to that same flanged spool p i ece r emo v ed to perform a repa i r/replacement activity on the p i p i ng between the f l anges. In the 1 998 I Ed i t i on and ear li er Ed i tions, ASME wou l d consider the flanges i n both of these scenar i os to be e x e m pt from pressure testing. It i s not c l ear what the NRC i ntends for th i s condition to accomp l ish because the NRC appea r s to take / e x cept i on to s o me ASME interpretations , and th o se exceptions are not c l ear l y identi fi ed. In the Ana l ysis of Publ i c Comments for the final rule inco r porati n g the 2013 Ed i ti o n (ML 16130A531), the NRC indicates i t d i s a grees w i th interp r etation Xl-1-10-20, w h i ch e x empts bolting rep l a c ements from press u re testing. Ot h er than some I nform al d i sc u ss i ons and corresp o ndence with the ASME , th a t is the only p l a c e where the NRC states that pos i tion. In the same document , the NRC i nd i cates that i tems rotated from stock (IWA-4 1 32) are a l so sub j ect to pressure t e sting. Th i s issue i s further confused be c ause Reg. Gu i de 1.1 47 appro v es Case N-508-4 w i th no l i m i tat i on regard i ng pressure testing (N-508-4 ta k es e x ception to all of IWA-4000, in cl ud i ng I WA-4 540 , and the r efor e 1 0 CFR 5D.55a (b)(2)(xx vi) d o esn't app l y). 2. Th i s cond i tion takes e x cept i on to ASME Sect i on i n XI in tha t i t m a ndates that a pressure test and VT-2 v is ual e x am i nati o n b e perf o rmed fo llo w i n g p erformance of a reoa i r/reo l acement acti vi tv w hen the me c h a nical connection o f an item is Pa ge llof 13 Enclosure 1 ASME Comments o n 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/rep l acement activ i ty does not involve the repair or replacement of items with i n the , mechanical joint. Moreover , as worded, this cond i t i on wou l d require a pressure test and VT-2 visual examination i f the repa i r/replacement act i vity involves on l y the replacement of a single fastener, regardless of the reason the fastener is rep l aced when the i tem is disassembled. ASME notes that mechanical joints that are disassembled and reassemb l ed for a ma i ntenance activity (e.g., gasket replacement}

would not be affected by the proposed cond i tion, provided the mechanical jo i nt is reassembled us i ng no replacement items. The ASME I Ii and XI committees have determ i ned that there is no need to perform a pressure test following a repair/replacement activity w here the mechanical connection was disassembled and reassemb l ed 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 Re l ated in accordance with a QA program and requ i re the item s meet material standards , codes , etc. and are subject to add i tional NOE and testing before be i ng util i zed. This prov i des reasonab l e assurance that the materials are free of defects and w ill perform the i r function during operation. In the case of valves , pumps, manufactured p i p i ng 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 ma intenance is performed that requires an item to be disassemb l ed, regard l ess if i t i nc l udes an ASME XI repair/replacement activ i ty, a leakage check i s performed uti l izing p l ant operators to inspect for leakage during post-ma i ntenance testing / return to service (PMT/RTS) activilies.

Verifying no leakage is just one of the many observations they perform to assure the item i s ' functioning as expected before cons i dering it operable.

Add i ng a requ ir ement to include a VT-2 examiner, and in some cases an ANII, does not increase the level of pub li c safety and i t does not support ALARA goals i n those areas of the plant where rad iation is present. The proposed cond i t i on will cause expose . addit i onal personnel to unnecessary radio l ogical dose with no added safety benefit because the mechanical connection is a l ready being inspec ted by an operator whose training involves the abil i ty to know how the equipment operates and to identify leakage or other abnormal conditions during their normal work duties. Addit io nally , the mechan i cal connection is disassembled and reassembled by personnel trained to perform the activ i ty , includ i ng use of industry standard bolt torque i ng gu i dance to assure proper integrity of the joint. Wh il e Reactor Coo l ant System lea kage is always a concern and each utility has requirements to address th i s leakage, ASME i s unaware of any precedence where a mechan ic al connection has catastrophically fa iled which would be cause for requ iri ng add i tional visual scrut i ny of the mechanical connection by a VT-2 exam i ner , inc l ud i ng the need for use of an ANII. In cases where a condit io n of leakage has been identified during PMT/RTS activities (w i th i n or outs i de the ASME Section XI program b oundaries}, the mechanical connections had no catastrophic failure and cond i tions were corrected to e li minate the Page 12 of 13 Enclosure 1 ASME Comments on 10 CFR 50.55a Proposed Rule , Federal Reg is ter, 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 u nacceptable lea kage. The leakage can be ident i fied without the need for the added burden of using a VT-2 exam i ner and an ANII. > As an additional consideration for removal of the cond i tion, plants implement i ng 10 CFR 50.69 would be implement i ng an inspection and repa i r program that is in lieu of ASME X I and 10 CFR 50.55(a). Imp lementa t ion of 50.69, would require pressure testing per construction code re quireme nts and does not require a VT-2 pressure test fo llowing a we l ded or mechanical repair/replacement activ i ty. The NRG has found th is approach to be acceptab l e when imp l ementing th i s alternat iv e regulation and should rema i n consistent w i th req uireme nts within 5D.55(a). ASME recommends that this condition be removed from the f i nal rule. If this recommendat i on is not accepted, then ASME recommends that 10 CFR 50. 55a(b) (2) (xxvi) be revised to s pecifically

/i sl the repair/repla c ement act i vities for which the NRG requ i res a pressure test following assembly or reassembl y of a mechanical joint. That is, the NRG should clarify whe ther th i s cond i tion specifically app li es when only bolting is r eplaced, an item rotated from stock is installed in a mechanical joint, and when a mechanical jo i nt is assembled or reassembled to perform a repair/rep l acement activity that does not affect pressure reta i ning parts of the mechanical jo i nt (e.g. mechanica l ly remov i ng a valve bonnet to rep l ace the valve disc), etc. §50.55a(g)(6)(i i)(D)(5) NIA (5) Peening. In lieu of inspection requirements of ASME understands that the proposed condition w ill requ i re that MRP-335-3A be Table 1, Items B4.50 and 84.60, and all other followed (w i th the exception of NRC condition 5.4) in order for a licensee to avo i d requirements in ASME BPV Code Case N-729-6 having to seek relief from the req u i rements ofTable 1 for a RPV upper head w i th pertaining to peening, In order for a RPV upper nozzles and a s soc i ated J-groo ve weld s that are m i tigated by peening. head with nozzles and associated J-groove welds, ASME recommends that the condition be clar i fied to spec i fy that the Extent and 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) N I A (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 i nsuffi cient techn ical basis to support t h e difference in inspectio n frequency with 360 excavate and weld repairs, Inspection Item between N-1 and M-2 welds. As is noted i n the Case and technical basis for the N-1 of Table 1, welds shall be examined during the EWR repa i r met hod , the N-1 repa i r is a full 360-degree repa i r with stress reversal, first or second refueling outage following EWR. which should prec l ude flaw growth. Stress rever sal does not occur for M-2 we l d Examination volumes that show no indication of EWR. ASME be li eves that this key technical d i fference should a ll ow the use of t he crack growth or new cracking shall be examined sa m p li ng s trategy as p r ovided in t he Case for N-1 EWR. once each inspection lnteNal thereafter.

For this reason. ASME bel i eves that the proposed condition is unnecessary and recommends tha t the orooosed condition be removed from the final rule. Page 13 of 13

Submission ID 7 Richard Deopere, Private Citizen ML19024A023

1 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

DearSirorMadam,

IrespectfullysubmittheattachedcommentstoproposedrulemakingrelatedtoASMECodesandStandardsfor10CFR50.55aforyourconsideration.ReferenceFederalRegister,Vol.83,No.218,pp.56156 56196,Friday,November9,2018,DocketIDNRC 2016 0082.Respectfully,RichardDeopereBrooklynPark,MN 10 CFR 50.55a paragraph NRC Proposed Change, Condition, and/or Provision Reviewer comments 50.55a(b)(2)(xxvi)

Section XI condition: Pressure testing Class 1, 2, and 3 mechanical joints.

When using the 2001 Edition through the latest edition and addenda

incorporated by reference in

paragraph (a)(1)(ii) of this section, licensees shall pressure test mechanical

joints in Class 1, 2, and 3 piping and components

greater than NPS-1 which are

disassembled and

reassembled during the

performance of a Section XI

activity (e.g.,

repair/replacement activity), in accordance with IWA-5211(a).

The pressure test and

examiners shall meet the

requirements of the licensee's/applicant's current

ISI code of record. I respectfully recommend that the NRC delete the current and proposed condition to (xxvi) as applicable to mechanical joints for the reasons stated below.

There is no practical need to impose a requirement to perform a pressure test with a VT-2 examination on a

mechanical joint to detect leakage when the equivalent outcome can be fulfilled with a leak inspection by knowledgeable personnel, such as operations, maintenance, instrument and controls, engineering staff, etc., during post-maintenance testing (PMT) and return to service (RTS) activities.

Oftentimes, these same knowledgeable personnel are

already present at the component location when the system is put into the conditions required for PMT/RTS, so adding a VT-2 examiner, as well as the likelihood of an Inspecto r from an Authorized Inspection Agency, increase s the number of personnel

to meet the existing and proposed requirement in order to achieve the same desired outcome.

Industry practice during PMT/

RTS activities requires 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 connecti ons 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 appropr iate level to perform its function as determined by th e Owner requirements.

10 CFR 50.55a paragraph NRC Proposed Change, 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 Constructi on Code to be met for a repair/replacement activity. The NRC should not

impose the additional requirements stated in this

condition for mechanical join ts, 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 wit nessing 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 provisio n unnecessarily increases the number of involved per sonnel needed to perform

"an examination." This re sults 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

PUBLIC SUBMISSION As of: 1/24/19 1:45 PM Received:

January 22, 2019 Status: Pending_Post Tracking No.

1k3-97tx-llg9 Comments Due:

January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 Pos ition Indication The NRC proposes to amend 50.

55a(b)(3)(xi) for the implemen tation of paragraph ISTC3700, Position Verification Testing, in the ASME OM Code to apply to the 2012 Edition through the latest edition and ad denda of the ASME OM Code incorp orated 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 wit hout the need to revise 50.55a(b)(3)(xi). In addition, the NRC propose s to clarify that this condition ap plies to all valves with remote position indicators within the scope of Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, in cluding MOVs within th e scope of Mandatory Page 1 of 201/24/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a0155 c&format=xml&showorig=false Appendix III, Preservice a nd Inservice Testing Active Electric Motor-Operated Valve Assemblies in Water-Cooled Reac tor Nuclear Power Plants. IS TC3700 references Mandatory Appendix III for valve position testing of MOVs. The developm ent of Mandatory Appendix III was intended to verify valve position indication as part of th e diagnostic testing performed on the intervals established by th e appendix. This clarification will ensure that verification of valve position indication is unde rstood to be important for a ll valves with remote position indication addressed in Subsection ISTC and all of its mandatory appendices.

Comment: The intent of this OM Condition is we ll 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 th an MOVs, supplemental position verification activities are performed at a two year interval as required by ISTC-3700. Most pl ants have voluntarily included MOVs in the scope of supplemental position veri fication. For some MOVs the periodic diagnostic testing (DIA G) in accordance with Appendi x III-3300 is utilized as the method for supplemental position ve rification. Such testing may be performed at intervals of up to 10 years. For other MOVs the Local Leak Rate Testing (L LRT) provides the appropriate conditions for supplemental position verification.

LLRTs may be performe d at intervals of up to 6 years. In some cas es System Operating Procedures, such as for fill and vent, provide the necessary conditions for crediti ng MOV supplemental position ve rification and are performed every 2 years or less.

The wording in the proposed condition above has been disc ussed with industry experts and there is a lack of consensus on what the condition requires in terms of allowed MOV supplemental position verificatio n 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 perf ormed at intervals up to 10 y ears. As described above, there is a variety of activitie s being performed or cr edited 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 cred ited, MOV supplemental position verification must be performed at least once every 10 years.

Attachments E Cavey Comment on Proposed 10CFR50.55aPage 2 of 201/24/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a0155 c&format=xml&showorig=false 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 ISTC3700, 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 Valves in Water-s within the scope of -Operated Valve Assemblies in Water-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 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

PUBLIC SUBMISSION As of: 1/24/19 1:51 PM Received:

January 23, 2019 Status: Pending_Post Tracking No.

1k3-97uh-4e89 Comments Due:

January 23, 2019 Submission Type: Web Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 CommentPublic Comments on Dock et 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 Case and conditions should be liste d in Reg. Guide 1.147 for cons istency, instead of in the Rule. If the intent of this co nditional paragraph is different fro m providing endo rsement of the Code Case, the intent should be clarified in the Rule.(b)(2)(ix)(K) Metal Containm ent Examinations: Eleventh provision; Table IWE 2411 1 should be Table IWE-2411-1. paragraph IW E 2430 should be paragraph IWE 2430.(b)(2)(xxxix)(A) Defect Removal: First Provision; subparagraph IWA 4421(c)(1) should read subparagraph IWA-4421(c)(1)(b)(2)(xxxix)(B) Defect Removal: Second Provision; subparagraph IWA 4421(c)(2) should Page 1 of 201/24/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a03af6&format=xml&showorig=false read subparagraph IWA-4421(c)(2)50.55a(b)(2)(xl)Section XI Condi tion: Prohibitions on Use of IWB-3510.4(b); The proposed 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) Sec tion XI Condition: Steam Generato r Nozzle-to-Component Welds and 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 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.Page 2 of 201/24/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a03af6&format=xml&showorig=false

Submission ID 10 Gary Becker, NuScale Power, LLC ML19024A527

PUBLIC SUBMISSION As of: 1/24/19 1:58 PM Received:

January 23, 2019 Status: Pending_Post Tracking No.

1k3-97um-m9n9 Comments Due:

January 23, 2019 Submission Type:

API Docket: NRC-2016-0082 American Society of Mechanical Engineer s 2015 - 2017 Code Editio ns Incorporation by ReferenceComment On:

NRC-2016-0082-0003American 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 200Corvallis, OR, 97330-4741 Email: gbecker@nuscalepower.comOrganization: NuScale Power, LLC General Comment See attached file(s)

AttachmentsLO-0119-64284 Federal Registry Comments on BRVC Code Edition SignedPage 1 of 101/24/2019https://www.fdms.gov/

fdms/getcontent?object Id=0900006483a01d2 a&format=xml&showorig=false 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.

L0-0119-64284 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 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

A Southern Nuclear JAN 2 3 2019 Secretary U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 A TIN: Rulemakings and Adjudications Staff. Regulatory Affairs 40 Inverness Cente r Parkway Post O ffi ce Box 1295 Birm i ngham , AL 35242 205 992 5000 tel 205 992 7601 fax NL-19-0071 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 quest i ons, please contact me at 205.992.5998.

Respectfully submitted, ~_.:k(~ Justin T. Wheat Nuclear Licensing Ma nager 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

1. Identifier Comment Proposed (Section, Page, Paragraph)

Resolution

1. 83 FR 56167; The industry's confusion is centered around the requirement of SNC recommends that the NRC 10 CFR 50.55a(b)(2)(xxvi) pressure testing after mechanical repair/replacement activities, specifically identify which mechanical Section XI Condition: such as the replacement of bolting in a mechanical connection repair/replacement activities would Pressure Testing Class 1 , 2 , (ASME Interpretation Xl-1-10-20). require pressure testing. and 3 Mechanical Joints Regarding Xl-1-10-20, 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 10 CFR 50.55a(b)(3)(xii)

OM the 2017 Edition of the OM Code, when implementing the 2015 recommendations in order of Condition:

Air-Operated Edition is unnecessary and inappropriate. desirability

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 Existing rules adequately address the use of subsequent between the 2012 and 2015 Edition

• to incorporate the 2017 Edition. approved Editions of the code, so it is unclear why the NRC 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 1 OCFR50 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 Ed i tion 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 10 CFR 50.55a(f)(7) lnservice burden on the Licensee and the NRG to process and review a the number of locations official Testing Reporting significant increase in the number of submittals which ultimately submittals are required to be sent to Requirements contain no new technical information. For example, 1ST program one (i.e., NRG Headquarters), and 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, 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-Revise the condition by replacing service testing would not provide a good measure of the effects

• 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 50.55a(f)(4) lnservice testing and IWV of the ASME 8PV Code, the scope was intentionally requiring testing per 10 CFR standards requirement for changed to test all pumps and valves with a safety related 50.55(a)(f)(4) shall be limited to valves operating plants function (even if not Class 1, 2 or 3). This change resulted in and rupture discs installed in piping unintended consequences for relief devices and has systems designed to ASME B&PV 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 committee has resolved the issue. relief devices protecting components 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 1 O 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 10 CFR 50.55a{b){3){xi)

OM licensees should expect to be included:

the exact wording that is intended to be Condition: Valve Position "In addition, the NRC proposes to clarify that this condition included in this amended condition.

Indication a1212lies to all valves with remote 12osition indicators within 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 10 CFR 50.55a(b)(3)(xii)

OM licensees should expect to be included in the new condition:

the exact wording that is intended to be Condition: Air-Operated "The NRC grogoses to include new§ 50.55a(b}(3}(xii) to included in this new condition.

Valves (Appendix IV) require the application of the provisions in Appendix IV of the 2017 Edition of the ASME OM Code, when implementing 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 1 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.pdfIn 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 Vesse l Code and the 2015 and 2017 Editions of the ASME Operation and Maintenance of Nuclear Power Plants, Division 1: OM: Section 1ST, res pectively, for nuclear power plants. (Docket ID NRC-2016-0082).

Justin Wheat Nuclear Licensing Manager Southern Nuclear Operating Company

Submission ID 12 Stephen Vaughn, Nuclear Energy Institute ML19028A019

From: VAUGHN, Stephen [mailto:sjv@nei.org

] 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 standardsTHE 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. In summary, since the NRC Resident Inspector currently has access to the most recent revision of a licensee's 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]TheNuclearEnergyInstitute(NEI)isresponsibleforestablishingunifiedpolicyonbehalfofitsmembersrelatingtomattersaffectingthenuclearenergyindustry,includingtheregulatoryaspectsofgenericoperationalandtechnicalissues.NEI'smembersincludeentitieslicensedtooperatecommercialnuclearpowerplantsintheUnitedStates,nuclearplantdesigners,majo rarchitectandengineeringfirms,fuelcyclefacilities,nuclearmaterialslicensees,andotherorganizationsinvolvedinthenuclearenergyindustry.

STEPHEN J. VAUGHN Senior Project Manager, Engineering and Risk 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8 163 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 Referenc e" 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 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. NEI's 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 valve's 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 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 licensee's 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 O'Driscoll, NRC/NMSS Mr. Keith Hoffman, NRC/NRR

Submission ID 13 Mark Gowin, Private Citizen ML19029B164

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gvi,kU nnPFWV 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 related to new Condition that imposes Appendix IV on the 2015 Edition. See comment below for paragraph (b)(3)(xii)

(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)(x i) Recommend clarifying this OM Condition with respect to its application to Mandatory Appendices. For example, clarify whether the ISTC

-3700 methods and frequency OR the Mandatory Appendix methods and frequency are applicable.

. (b)(3)(xi i) 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, 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-92 00 (c) IV-9 2 00 (d) As an alternative, this rulemaking could be revised to eliminate NRC endorsement of the 2015 Edition of OM Code for use by utilities..

(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" 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

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

Subject:

Comments Concerning Proposed Rule 1 O CFR 50, "American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference 11 (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 1 O CFR 50, "American Society of Mechanical Engineers 2015-2017 Code Editions Incorporation by Reference, 11 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 1 O 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" 1 O 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)

§50 .55a(b )(2)(xxvi)

§50.55a(b)(2)(xxxii)

§50.55a(g)(6)(ii)(D)(5)

§50.55a(g)(6)(ii)(F)(15) 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 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." 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 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. Exelon understands that Code changes are in progress to extend the submittal timeframe for reports like this to 120 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. 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 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. 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 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 1 O CFR 50 Proposed Rule Docket ID NRC-2016-0082 Page 2 of 2 1 O 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; 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 1 O CFR 50.55a(b)(2)(xxxii).

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