Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
May 30, 1997
NRC INFORMATION NOTICE 97-29: CONTAINMENT INSPECTION RULE
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice to clarify for addressees the containment inspection rule in accordance
with 10 CFR 50.55a(a), which in part endorses Subsections IWE and IWL of
Section XI of the American Society of Mechanical Engineers' Boiler and
Pressure Vessel Code (ASME Code). The rule became effective on September 9,
1996. It is expected that recipients will review the information for
applicability to their facilities and consider actions, as appropriate.
However, suggestions contained in this information notice are not NRC
requirements; therefore, no specific action or written response is required.
Description of Circumstances
In a Federal Register, dated August 8, 1996 (61 FR 41303), the NRC amended its
regulations (rule) to incorporate by reference the 1992 Edition and Addenda of
Subsections IWE and IWL of Section XI of the ASME Code. Subsections IWE and
IWL give the requirements for inservice inspection (ISI) of Class CC (concrete
containments), and Class MC (metallic containments) of light-water-cooled
power plants. The amended rule became effective on September 9, 1996; it re-
quires the licensees to incorporate the new requirements into their ISI plans
and to complete the first containment inspection within five years (i.e., no
later than September 9, 2001). Any repair or replacement (R/R) activity to be
performed on containments after the effective date of September 9, 1996, has
to be carried out in accordance with the respective requirements of
Subsections IWE and IWL.
Recognizing the potential industry concern related to the immediate
implementation of the rule for R/R activities, the Nuclear Energy Institute
(NEI) wrote a letter to NRC (Reference 1) indicating a general industry
interpretation of the rule that all containment ISI activities, including R/R
activities should be effective from September 9, 2001. The NRC responded to
the NEI letter (Reference 2) stating that all R/R activities within the scope
of Subsections IWE and IWL of the code conducted after September 9, 1996, must
be conducted in accordance with these subsections.
9705290064. IN 97-29
May 30, 1997
Page 2 of 3
Additionally, the staff stated (Reference 2) that 10 CFR 50.55a(3) permits the
Director of the Office of Nuclear Reactor Regulation at his discretion to
grant relief from the requirements of 10 CFR 50.55a to licensees who submit a
justifiable need to use an alternative that provides an acceptable level of
safety or who encounter extreme hardship or unusual difficulty without a
compensating increase in the level of quality or safety. In general, the
staff stated that with proper justification, relief requests from compliance
with the R/R requirements of Subsections IWE and IWL for a period of about one
year from September 9, 1996, would appear to be reasonable.
Although NEI sent the response from NRC to many of the addressees, the NRC
staff is issuing this information notice to inform all addressees about the
NRC staff position.
Discussion
As discussed above, addressees are required to implement the rule for all
containment-related R/R activities to be conducted after September 9, 1996.
Even though a licensee is able to demonstrate hardship or unusual difficulties
in the immediate implementation of the rule, the licensee has to demonstrate
that other procedures utilized for R/R activities will ensure adequate safety
of the containments and that proper quality assurance requirements have been
implemented.
In some of the relief requests that the staff has reviewed, licensees have
reported appropriate "hardship and unusual difficulties" reasons for
postponing the implementation of the rule, but did not describe the
effectiveness of the procedures they plan to use during the relief period.
Without such information, the staff has no way of concluding that the quality
and safety of containment R/R activities are adequate.
. IN 97-29
May 30, 1997
Page 3 of 3
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contacts listed below or the appropriate Office of Nuclear
Reactor Regulation (NRR) project manager.
signed by S.H. Weiss
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contacts: Seung Lee, NRR
301-415-2737
E-mail: sjl@nrc.gov
Hans Ashar, NRR
301-415-2851
E-mail: hga@nrc.gov
References
1. Letter from Alex Marion (NEI) to Brian Sheron (NRC), "Interpretation of
Amended 10 CFR 50.55a," dated 09/19/96 (Accession No. 9704180074).
2. Letter from Gus Lainas (NRC) to Alex Marion (NEI), "Implementation of
Containment Inspection Rule," dated 11/06/96 (Accession No. 9611130161).
