ML022130527
| ML022130527 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/24/2002 |
| From: | Nazar M Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML022130527 (4) | |
Text
NMC Mano K. Nazar Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Dr. East o Welch MN 55089 July 24, 2002 10 CFR Part 50 Section 50.55a U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Relief Requests for the 3rd 10-year Inservice Inspection Intervals for Unit I and Unit 2 Pursuant to 10 CFR 50.55a(a)(3)(i), we request NRC approval of the attached request for the Third Ten-Year Inservice Inspection Intervals for Unit 1 and Unit 2: the relief is to provide training of ultrasonic examiners per the requirements of 10 CFR 50.55a(b)(2)(xiv) in lieu of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code requirements for this training.
The details of the 10 CFR 50.55a(a)(3)(i) request are enclosed in the attached relief requests for Prairie Island Unit 1 and Unit 2 (contained in one document). Prairie Island requests approval by November 15, 2002 to support the refueling outage of Unit 1.
In this letter we have made no new Nuclear Regulatory Commission commitments.
Please contact Jack Leveille (651-388-1121, Ext. 4142) if you have any questions related to this letter.
L1L
Mano K. Nazar Site Vice President Prairie Island Nuclear Generating Plant c: (next page)
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USNRC NUCLEAR MANAGEMENT COMPANY, LLC July 24, 2002 Page 2 c: Regional Administrator-Region III, NRC Senior Resident Inspector, NRC NRR Project Manager, NRC Chief Boiler Inspector, State of MN P. Fisher, Hartford Insurance
Attachment:
(one document, 2 pages)
Prairie Island Unit 1 - RELIEF REQUEST NUMBER: 9 (Rev. 0)
Prairie Island Unit 2 - RELIEF REQUEST NUMBER: 10 (Rev. 0)
Relief request 9&10 (training) letter.DOC
Prairie Island Unit 1 and Unit 2 3rd Interval In-service Inspection Examination Plan Prairie Island Unit 1 - RELIEF REQUEST NUMBER: 9 (Rev. 0)
Prairie Island Unit 2 - RELIEF REQUEST NUMBER: 10 (Rev. 0)
Appendix VII Annual Training SYSTEM/COMPONENT(S) FOR WHICH RELIEF REQUEST WILL BE USED Code Class:
All
Reference:
ASME,Section XI 1989 Edition, Appendix VII,VII-4240 Examination Category:
All Item Number:
All
==
Description:==
All components subject to ultrasonic volumetric examination in accordance with ASME Section XI, 1989 Edition and Appendix VII, Annual Training.
Component Numbers:
All CODE REQUIREMENT ASME Section XI, 1989 Edition Appendix VII, Subsection VII-4240 requires:
"Supplemental training is required on an annual basis to impart knowledge of new developments, material failure modes, and any pertinent technical topics as determined by the Employer. The extent of this training shall be a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per year. A record of attendance and the topics covered during the training shall be maintained."
BASIS FOR RELIEF REQUEST 10 CFR 50.55a(b)(2)(xiv) was amended in September 1999 to require that: "All personnel qualified for performing ultrasonic examinations in accordance with Appendix VIII shall receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens that contain cracks. This training must be completed no earlier than 6 months prior to performing ultrasonic examinations at a licensee's facility."
Paragraph 2.4.1.1.1 in the Federal Register (Volume 64, No. 183 dated September 22, 1999) during rule making contained the following statement, regarding the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of training on an annual basis: "The NRC had determined that this requirement was inadequate for two reasons.
The first reason was that the training does not require laboratory work and examination of flawed specimens. Signals can be difficult to interpret and as detailed in the regulatory analysis for this rulemaking, experience and studies indicate that the examiner must practice on a frequent basis to maintain the capability for proper interpretation. The second reason is related to the length of training and its frequency. Studies have shown that an examiner's capability begins to diminish within approximately 6 months if skills are not maintained. Thus, the NRC had determined that 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training is not sufficient practice to maintain skills, and that an examiner must practice on a more frequent basis to maintain proper skill level."
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Prairie Island Unit 1 and Unit 2 3rd Interval In-service Inspection Examination Plan ALTERNATIVE REQUIREMENT Annual ultrasonic examination training shall be conducted in accordance with 10 CFR 50.55a(b)(2)(xiv) in lieu of ASME Section XI, 1989 Edition, Appendix VII, Subparagraph VII-4240.
All personnel qualified for performing ultrasonic examinations in accordance with Appendix VIII-- Supplements ASME Section XI, 1995 Edition, 1996 Addenda shall receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens that contain cracks. This training will be completed no earlier than 6 months prior to performing ultrasonic examinations at Prairie Island Unit 1 and Unit 2.
JUSTIFICATION FOR GRANTING RELIEF This relief improves the performance of Appendix VIII-Supplements examinations by requiring NDE examiner performing Appendix VIII Supplemental examinations to demonstrate proficiency on specimens that contain cracks prior to performing actual examinations.
IMPLEMENTATION SCHEDULE Alternative is requested for the 3rd Ten-year Interval of the In-service Inspection Program for Prairie Island Unit 1 and Unit 2.
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