POLICY ISSUE 

NOTATION VOTE 

April 17, 2012 SECY-12-0060

FOR: The Commissioners 

FROM: R. W. Borchardt 

 Executive Director for Operations 

SUBJECT: PROPOSED CHANGES TO THE AMERICAN SOCIETY OF 

MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE 

ASSOCIATED WITH BURIED PIPING 

PURPOSE: 

This paper requests Commission approval as required by Staff Requirements Memorandum 

(SRM) for SECY-11-0019, “Senior Management Review of Overall Regulatory Approach to 

Groundwater Protection,” to incorporate by reference American Society of Mechanical 

Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code Section XI changes related to 

groundwater protection in the 2009 Addenda through the 2011 Addenda into Title 10 of the 

Code of Federal Regulations (10 CFR) Part 50.55a, “Codes and Standards.” This paper does 

not address any new commitments or resource implications. 

BACKGROUND: 

The Nuclear Regulatory Commission (NRC) incorporates by reference the requirements of the 

ASME B&PV Code into 10 CFR 50.55a. After the NRC incorporates an edition of the ASME 

Code into its regulations, licensees may voluntarily update their ASME Section XI inservice 

inspection code of record to the updated edition. Licensees are required to update their code 

of record at least once every 10 years. 

Until recently,1

 ASME updated its B&PV Code editions every 3 years and issued addenda 

approximately every year. The NRC periodically reviews new editions and addenda of the 

ASME B&PV Code and updates 10 CFR 50.55a to incorporate selected changes. The staff is 

CONTACT: Keith M. Hoffman, NRR/DE 

 301-415-1294 

 

1

 ASME recently revised its procedures and intends to revise the B&PV Code every 2 years in the future and no 

longer plans to issue addenda. 
The Commissioners -2- 

currently processing a rulemaking to revise 10 CFR 50.55a so as to incorporate newer editions 

and addenda of the ASME Code. 

The ongoing rulemaking action to update the edition and addenda of the ASME B&PV Code to 

the 2009 Addenda through the 2011 Addenda would incorporate some changes to inspections 

of buried piping that could be related to groundwater protection. These changes are associated 

with the performance of leakage testing of buried piping as described in the 2011 Addenda to 

ASME Section XI, Paragraph IWA-5244. The Enclosure shows the changes instituted from the 

2010 Edition to the 2011 Addenda of ASME Code Section XI. ASME adopted these changes 

through a consensus standard development process, which was fully vetted by a wide crosssection of stakeholders. 

In the SRM for SECY-11-0019, the Commission stated: 

The Commission approves the SMRG’s [Senior Management Review Group’s] 

recommendation for the staff to continue its efforts to work with consensus 

standards organizations to have certain provisions related to inspecting and 

maintaining safety related buried piping incorporated into ASME code cases and 

NACE [National Association of Corrosion Engineers] standards. 

If, based on its participation in consensus standard activities the staff determines 

that revisions to the agency’s regulations are necessary to incorporate changes 

to the ASME codes related to groundwater protection, the staff should seek 

Commission approval via a notation vote paper. 

In accordance with the SRM for SECY-11-0019, the staff is providing this notation vote paper for 

Commission consideration. 

DISCUSSION: 

ASME meets periodically to discuss and update its B&PV Code. Through the ASME Code 

committee consensus process, the nuclear industry and licensees continually revise ASME 

Code language or develop Code Cases to incorporate new technologies and processes, provide 

greater operational flexibility, enhance safety, and improve the clarity of ASME Code language. 

The new editions and addenda typically revise provisions of the ASME Codes to broaden their 

applicability, add specific elements to current provisions, delete specific provisions, and clarify 

the provisions. The revisions to the editions and addenda of the ASME Code do not 

significantly change ASME Code philosophy or approach. 

The consensus process ensures that the requirements developed in the ASME Code are fully 

vetted by a wide variety of stakeholders, including NRC staff. 

The ASME B&PV Code is a national, voluntary consensus standard. The National Technology 

Transfer and Advancement Act of 1995 (Public Law 104-113) requires government agencies to 

use voluntary consensus standards, where practicable, instead of government-unique 

standards, unless the use of such a standard is inconsistent with applicable law or is otherwise 

impractical. The NRC reviews new editions and addenda of the ASME B&PV Code and 

updates the edition and addenda incorporated by reference in 10 CFR 50.55a approximately 

every 2 years. Revisions to the agency’s regulations are always necessary to incorporate 
The Commissioners -3- 

changes to the ASME Code into regulations; revising 10 CFR 50.55a is the process used to 

endorse updated editions and addenda of the ASME Code. 

The NRC approves and mandates the use of editions and addenda of the ASME Code in 

10 CFR 50.55a through the rulemaking process of “incorporation by reference.” As such, 

each provision of the ASME Code—as incorporated by reference into, and mandated by, 

10 CFR 50.55a—constitutes a legally binding NRC requirement imposed by rule. Since the 

ASME Code is a consensus document, technical experts may disagree on what constitutes an 

acceptable level of safety. The NRC imposes conditions to enhance the provisions in the ASME 

Code in instances in which the NRC has determined that the provisions do not provide an 

acceptable level of safety. 

The 2011 Addenda to ASME Code Section XI contains changes to the leakage testing 

requirements of buried components in IWA-5244. These changes basically require that, in 

addition to the current requirements of performing either a pressure drop test or flow verification 

test, licensees shall perform a visual examination for leakage “on ground surfaces in the vicinity 

of the buried components and in areas where leakage might be channeled or accumulated.” 

The staff recognizes that these changes could be interpreted to be related to groundwater 

protection. 

The staff determined that this ASME Code change, if implemented, would not reduce safety and 

may improve the effectiveness of the leakage testing performed. Accordingly, the staff 

recommends that the changes be endorsed as-written, without the need to impose any 

restrictive conditions. If the Commission approves this recommendation, then once the rule is 

issued, licensees would be able to adopt the revised, more effective ASME Code section. All 

licensees would be required to adopt the change within 10 years. If the Commission does not 

approve the staff’s recommendation, licensees would not be required to enhance their leakage 

testing procedures for buried components. 

The SRM for SECY-11-0019 requires the staff to seek approval, through a notation vote paper, 

before revising 10 CFR 50.55a if the revision would endorse an edition of the Code that 

contained changes affecting groundwater protection. In the case of the current rulemaking, the 

ASME Code changes that could be related to groundwater protection are minor. 

RECOMMENDATIONS: 

The NRC staff recommends the Commission take the following action: 

 Approve the incorporation by reference of the buried component pressure testing 

requirements of the 2011 Addenda of ASME Section XI (Enclosure 1). 
The Commissioners -4- 

COORDINATION: 

The Office of the General Counsel has reviewed this Commission paper and has no legal 

objection to its content. 

 

 /RA/ 

 R. W. Borchardt 

 Executive Director 

 for Operations 

Enclosure: 

Proposed ASME Section XI Changes 
The Commissioners -4- 

COORDINATION: 

The Office of the General Counsel has reviewed this Commission paper and has no legal 

objection to its content. 

 

 /RA/

 R. W. Borchardt 

 Executive Director 

 for Operations 

Enclosure: 

Proposed ASME Section XI Changes 

EDATS: NRR-2012-0013 

ADAMS Accession No.: ML12082A067 

* By e-mail

OFFICE NRR/DE/EPNB NRR/DE * NRR/DE/EPNB:BC NRR/DPR/PRB:BC NRR/DPR 

NAME KHoffman RHardies TLupold SHelton TMcGinty 

(SBahadur for) 

DATE 02/16/2012 02/16/2012 02/21/2012 02/29/2012 03/6/2012 

OFFICE NRR/DE TECH:ED * OGC – NLO 

w/ comments NRR EDO 

NAME PHiland 

(MCheok for) JDougherty JBiggins ELeeds 

(DDorman for) RBorchardt 

DATE 03/20/2012 03/12/2012 04/03/2012 04/13/2012 04/17/2012 

OFFICIAL RECORD COPY 
PROPOSED ASME SECTION XI CHANGES 

Enclosure 

2011 Edition ASME Section XI IWA-5244 Buried Components

(a) For buried components surrounded by an annulus, the VT-2 visual examination shall consist 

of an examination for evidence of leakage at each end of the annulus and at low point 

drains. 

(b) For buried components without an annulus, the following examination requirements shall be 

met. 

 (1) A VT-2 visual examination shall be performed to identify evidence of leakage on ground 

surfaces in the vicinity of the buried components and in areas where leakage might be 

channeled or accumulated. The examination shall be performed after the component 

has been pressurized to system leakage test pressure for at least 24 hours. Portions of 

buried components where a VT-2 examination is impractical (e.g., component is buried 

beneath impermeable material or encased in concrete) are exempt from VT-2 

examination. 

 (2) A test that determines the rate of pressure loss, a test that determines the change in flow 

between the ends of the buried components, or a test that confirms that flow during 

operation is not impaired shall be performed. Personnel performing these tests need not 

be qualified for VT-2 visual examination. 

 (3) The Owner shall specify criteria for the examinations and tests of (b)(1) and (b)(2). 

Summary of changes in the 2011 Edition

In the Code requirement above, the major change from the current Code is the requirement to 

perform a visual examination for leakage (VT-2) on the ground surfaces in the vicinity of buried 

components and in areas where leakage might be channeled or accumulated after the 

component has been pressurized for 24 hours.