ASME Section III Component Replacements (Generic Letter 89-09)

May 8, 1989

TO:       ALL HOLDERS OF LIGHT WATER REACTOR OPERATING LICENSES

SUBJECT:  ASME SECTION III COMPONENT REPLACEMENTS (GENERIC LETTER 89-09)

BACKGROUND

The purpose of this Generic Letter is to provide guidance to Licensees who 
require component replacements, as defined in Definition 1 (see Appendix for 
definitions), for components that were constructed (see Definition 2) to 
Section III of the ASME Boiler and Pressure Vessel Code (hereafter called the 
Code), but are not currently available in full compliance with the stamping 
and documentation requirements of the Code.  The staff position in this 
Generic Letter does not apply to new construction or the addition of complete 
systems to operating power reactors.  Complete systems being added to 
operating power reactors shall continue to meet all applicable Code 
requirements, including stamping.  The position in this Generic Letter 
supersedes previously issued differing position on this subject.  This Generic 
Letter is intended to serve as interim guidance pending revision of 10 CFR 
50.55a, the Codes and Standards Rule, or development of a Regulatory Guide.

Replacements for components that were originally constructed to ASME Code 
Section III, Classes 1, 2 or 3 or other standards within the scope of the 
current edition of Section XI, Division 1, "Rules for Inservice Inspection of 
Nuclear Power Plant Components," of the Code.  Article IWA-7000 of Section XI 
specifies the general requirements for replacements.  Paragraph IWA-7210 
provides that replacements ordered as spares shall meet the requirements of the 
original construction Code used or those of a later Code edition and/or 
addenda approved in the Codes and Standards Rule 10 CFR 50.55a.

Prior to May 14, 1984, paragraph (a)(2) of the Codes and Standards Rule, 
10 CFR 50.55a, permitted an exception to Section III of the Code:  
.50.55a(a)(2) provided that the Code N-symbol need not be applied when 
constructing Class A or Class 1 nuclear reactor components to comply with the 
ASME Code.  This exception was initiated in 1971 to permit qualified foreign 
manufacturers to supply components to domestic nuclear plants.  At that time 
the ASME had no provisions for issuing Certificates of Authorization and the 
Code N-symbol stamps to firms outside of the United States and Canada.  This 
Code requirement was waived by NRC when the Code was first incorporated by 
reference in the regulation in 1971; however, the Commission always intended 
that items within the scope of the Code comply with all other Code provisions.  
As of September 11, 1972, the ASME instituted provisions for making 
Certificates of Authorization and symbol stamps available to foreign 
manufacturers, making the exemption in 10 CFR 50.55a unnecessary and 
permitting the regulation to be revised accordingly.  As of May 14, 1984, any 
components or parts required by the procurement document to meet the 
requirements of ASME Section III, Code Class 1, 2 or 3 must meet all the 
requirements of Section III, including stamping. 



8905090372
.Generic Letter 89-09                 - 2 -             May 8, 1989


Because of the decline in nuclear plant orders in the United States, a number 
of utilities are experiencing difficulties in obtaining replacements for 
components that were originally constructed in accordance with Section III of 
the Code.  This decline in nuclear power plant orders has caused certain 
manufacturing companies that previously provided nuclear-grade components in 
accordance with Section III of the Code to allow their Certificates of 
Authorization to expire.  In other cases, companies have discontinued a 
product line or sold a product line to another company that does not have a 
Certificate of Authorization and, therefore, does not manufacture 
nuclear-grade components.  Some of the companies have retained the capability 
to provide components which meet the design, fabrication, and examination 
requirements of Section III of the Code.  However, because of the limited 
demand for nuclear-grade components and part, these companies have not 
maintained their Certificates of Authorization and their related agreements 
with the Authorized Inspection Agencies.

Even though the manufacturer of an original component does not currently 
manufacture nuclear components and parts, it may sometimes be necessary to 
procure replacements from the original manufacturer in order to ensure 
adequate operation and proper fit and function.  In special cases, 
consideration may be given to procurement of replacements from the original 
manufacturer in order to avoid an adverse impact on existing components or 
systems.  However, it is also necessary to obtain objective evidence that the 
quality of the replacement is adequate.  For example, in order to avoid 
rerouting and reanalysis of system piping, consideration may be given to 
replacement of an ASME Section III, Class 3 nuclear-stamped heat exchanger 
with an ASME Section VIII stamped heat exchanger that has the same heat 
removal capacity, construction, and physical dimensions as the original 
component.  When replacements are considered as special cases, they should be 
procured in a manner consistent with the staff position provided below which 
is a means of ensuring that a replacement's level of quality is at least 
equivalent to the original Section III construction. 


NRC POSITION

In order to use the guidance in this staff position (provided below) for 
purchasing replacements, a licensee must first establish that an equivalent 
Section III stamped replacement is not available.  When replacements are 
required in accordance with Article IWA-7000 of Section XI of the Code, cost 
cannot be used as a justification for purchasing non-stamped parts.  Where 
replacements are no longer available in full compliance with the stamping and 
documentation requirements of Section III of the Code they should be procured 
under the utility's Quality Assurance Program that is in conformance with 
10 CFR Part 50, Appendix B and included in the plant operational Quality 
Assurance list.  Furthermore, these replacements should meet all other appli-
cable requirements of Section III (including third party inspection by an 
Authorized Nuclear Inspector) endorsed by NRC regulations except that the Code
N-symbol need not be applied. 
.Generic Letter 89-09                 - 3 -             May 8, 1989


Licensees that choose to use this staff position need only indicate such re-
placements in the Final Safety Analysis Report annual update and certify their 
compliance with the guidance provided herein.  Licensees should retain on file 
for the service lifetime of each replacement that information detailing the 
basis for the action and all other related documentation in order to 
demonstrate conformance with the guidance in this Generic Letter.

The staff concludes that adherence to the guidance provided in this Generic 
Letter will provide reasonable assurance that component replacements will 
perform their safety-related function.  Pursuant to 10 CFR 50.55a(3), the 
staff has determined that where component replacements are not currently 
available, full compliance with the stamping and documentation requirements of 
the Code would result in hardship or unusual difficulties without a 
compensating increase in the level of quality and safety over that provided by 
the alternatives contained in this guidance, and that the alternatives 
contained in this guidance provide an acceptable level of quality and safety.  
Accordingly, pursuant to 10 CFR 50.55a(3) relief is granted to those licensees 
that choose to use the guidance in this Generic Letter for those component 
replacements that are not currently available in full compliance with the 
stamping and documentation requirements of Section III of the ASME Boiler and 
Pressure Vessel Code.  If you have any questions about this matter, please 
contact the NRC project manager or the technical contact listed below.


                                        Sincerely,



                                        James G. Partlow
                                        Assocate Director for Projects
                                        Office of Nuclear Reacter Regulation



Enclosures:
1.  Appendix
2.  Listing of Recently Issued Generic Letters


Technical Contacts:
R. Kirkwood, RES
(301) 492-3928

S. Hou, NRR
(301) 492-0904