POLICY ISSUE

(Information)

December 12, 2003 SECY-03-0214

FOR: The Commissioners

FROM: William D. Travers

Executive Director for Operations /RA/

SUBJECT: REACTOR VESSEL HEAD INSPECTIONS

PURPOSE:

To inform the Commission of pressurized water reactor (PWR) vessel head inspection

requirements.

BACKGROUND:

During the Commission briefing on August 25, 2003, the U.S. Nuclear Regulatory Commission

(NRC) staff told the Commission about investigations of possible violations of NRC regulations

and resulting enforcement actions associated with the reactor vessel head degradation at

Davis-Besse. In a follow-up Staff Requirements Memorandum dated September 26, 2003, the

Commission asked the staff to confirm that all other plants have adequate service structure

access to perform sufficient inspections of the reactor vessel head.

DISCUSSION:

To provide reasonable assurance of structural and leakage integrity of reactor pressure vessel

(R.V.) heads and head penetrations, and to ensure that the reactor vessel head degradation

found at the Davis-Besse plant will not occur at other PWRs, the NRC issued Order EA-03-009 

on February 11, 2003. The order requires that each PWR licensee conduct a bare metal visual

examination of 100 percent of the R.V. head surface and perform nondestructive examination

of the associated R.V. head penetration nozzles at a frequency commensurate with the

susceptibility of the R.V. head to primary water stress corrosion cracking. Licensees are

required to notify the NRC of any deviation from the inspection requirements of the Order and

may request relaxation of specific examinations.

CONTACT:

T. Chan, NRR/DE/EMCB

(301) 415-2768
The Commissioners -2-

The staff reviews each relaxation request for its acceptability to ensure that an adequate

inspection can be performed. This review will identify instances in which inadequate service

structure access prevents sufficient examination of the R.V. head surface. Based on licensees’

compliance with the order, the staff is confident that the integrity of the R.V. head and

associated penetration nozzles will be maintained at each PWR plant because any degradation

of those components will be detected by the inspections required under the Order or by

augmented assessments conducted as compensatory measures associated with relaxation

requests. To date, the only plant which has been identified as having inadequate service

structure access for sufficient inspection of the R.V. head surface is ANO-2; the unique design

and construction of the cooling shroud structure impedes its removal without unusual

difficulties. However, sufficient augmented assessments have been performed to assure the

integrity of the R.V. head.

The staff’s long-term resolution of this issue is to incorporate a future edition of the American

Society of Mechanical Engineers Boiler and Pressure Vessel Code by reference into the

regulations which contains acceptable inspection requirements, or to implement new

augmented inspection requirements through changes to the NRC regulations in Title 10 of the

Code of Federal Regulations, Part 50.55a, “Codes and Standards.”

CONCLUSION:

The staff concludes that sufficient regulatory requirements are being implemented to assure the

integrity of the R.V. head. A commitment to perform inspections to the scope identified in the

Order is submitted to the NRC including notification of deviations and requests for relaxation. 

In those case where existing design precludes inspection, per EA-03-009, augmented

assessments have been performed and reviewed by the staff to assure R.V. head integrity.

COORDINATION:

The Office of the General Counsel has reviewed this paper and has no legal objection to its

content.

/RA/

William D. Travers

Executive Director

 for Operations
The Commissioners -2-

The staff reviews each relaxation request for its acceptability to ensure that an adequate

inspection can be performed. This review will identify instances in which inadequate service

structure access prevents sufficient examination of the R.V. head surface. Based on licensees’

compliance with the order, the staff is confident that the integrity of the R.V. head and

associated penetration nozzles will be maintained at each PWR plant because any degradation

of those components will be detected by the inspections required under the order or by

augmented assessments conducted as compensatory measures associated with relaxation

requests. To date, the only plant which has been identified as having inadequate service

structure access for sufficient inspection of the R.V. head surface is ANO-2; the unique design

and construction of the cooling shroud structure impedes its removal without unusual

difficulties. However, sufficient augmented assessments have been performed to assure the

integrity of the R.V. head.

The staff’s long-term resolution of this issue is to incorporate a future edition of the American

Society of Mechanical Engineers Boiler and Pressure Vessel Code by reference into the

regulations which contains acceptable inspection requirements, or to implement new

augmented inspection requirements through changes to the NRC regulations in Title 10 of the

Code of Federal Regulations, Part 50.55a, “Codes and Standards.”

CONCLUSION:

The staff concludes that sufficient regulatory requirements are being implemented to assure the

integrity of the R.V. head. A commitment to perform inspections to the scope identified in the

Order is submitted to the NRC including notification of deviations and requests for relaxation. 

In those case where existing design precludes inspection, per EA-03-009, augmented

assessments have been performed and reviewed by the staff to assure R.V. head integrity.

COORDINATION:

The Office of the General Counsel has reviewed this paper and has no legal objection to its

content.

/RA/

William D. Travers

Executive Director

 for Operations

Commission Paper ML033180504

OFFICE EMCB:DE EMCB:DE EMCB:DE DE/D * Tech Ed

NAME WHKoo* TLChan* WHBateman* CIG forRBarrett PKleene*

DATE 11 /12 /03 11 /12 /03 11 /14/03 11/18/03 11/14/03

OFFICE OGC * NRR/ADPT * NRR/D * EDO

NAME Ddambly Bsheron JDyer (B. Sheron for) WTravers

DATE 11/20/03 11 /26 /03 11/ 26 /03 12/12/03

OFFICIAL RECORD COPY