ML023010209

Relief, Third 10-Year Interval Inservice Inspection Program

ML023010209
Person / Time
Site:	Prairie Island
Issue date:	11/07/2002
From:	Raghavan L NRC/NRR/DLPM/LPD3
To:	Nazar M Nuclear Management Co
References
TAC MB5690, TAC MB5691
Download: ML023010209 (6)

Text

November 7, 2002 Mr. Mano Nazar Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 -

EVALUATION OF RELIEF REQUEST NO. 9 FOR UNIT 1 AND NO. 10 FOR UNIT 2 ASSOCIATED WITH THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM (TAC NOS. MB5690 AND MB5691)

Dear Mr. Nazar:

By letter dated July 24, 2002, the Nuclear Management Company, LLC (the licensee) submitted Relief Request Nos. 9 (Unit 1) and 10 (Unit 2) related to the Third 10-Year Interval Inservice Inspection (ISI) Program for the Prairie Island Nuclear Generating Plant, Units 1 and 2. In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the 10-hour annual training requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, 1989 edition, Appendix VII, for personnel performing ultrasonic testing.

Based on the information provided in the July 24, 2002, submittal, the Nuclear Regulatory Commission (NRC) staff concludes that the proposed alternative will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the licensees proposed alternative for the third 10-year ISI interval for Prairie Island, Units 1 and 2.

The enclosed safety evaluation provides the basis for the NRC staffs determination. If you have any questions concerning this action, please call Mr. T. J. Kim of my staff at (301) 415-1392.

Sincerely,

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-282 and 50-306

Enclosure:

Safety Evaluation cc w/encl: See next page

ML023010209 OFFICE PDIII-1/PM PDIII-1/LA EMCB/SC OGC PDIII-1/SC NAME TKim RBouling TChan BSmith LRaghavan DATE 10/31/02 10/31/02 10/31/02 11/04/02 11/07/02 Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:

J. E. Silberg, Esquire Tribal Council Shaw, Pittman, Potts and Trowbridge Prairie Island Indian Community 2300 N Street, N. W. ATTN: Environmental Department Washington, DC 20037 5636 Sturgeon Lake Road Welch, MN 55089 Site Licensing Manager Prairie Island Nuclear Generating Plant Mr. Roy A. Anderson Nuclear Management Company, LLC Executive Vice President and 1717 Wakonade Drive East Chief Nuclear Officer Welch, MN 55089 Nuclear Management Company, LLC 700 First Street Adonis A. Neblett Hudson, WI 54016 Assistant Attorney General Office of the Attorney General Nuclear Asset Manager 455 Minnesota Street Xcel Energy, Inc.

Suite 900 414 Nicollet Mall St. Paul, MN 55101-2127 Minneapolis, MN 55401 U.S. Nuclear Regulatory Commission Resident Inspectors Office 1719 Wakonade Drive East Welch, MN 55089-9642 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Administrator Goodhue County Courthouse Box 408 Red Wing, MN 55066-0408 Commissioner Minnesota Department of Commerce 121 Seventh Place East Suite 200 St. Paul, MN 55101-2145 March 2002

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION RELIEF REQUEST NO. 9 (FOR UNIT 1)

RELIEF REQUEST NO. 10 (FOR UNIT 2)

NUCLEAR MANAGEMENT COMPANY, LLC PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306

1.0 INTRODUCTION

The inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Class 1, Class 2, and Class 3 components is to be performed in accordance with Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Code and applicable edition and addenda, as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.55a(g)(6)(i). The regulation at 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI code of record for the third 10-year ISI interval for the Prairie Island Nuclear Generating Plant, Units 1 and 2, is the ASME Code,Section XI, 1989 edition.

By letter dated July 24, 2002, the Nuclear Management Company, LLC (the licensee),

requested relief from certain ultrasonic testing (UT) requirements pertaining to UT performance qualification for the third 10-year ISI interval at Prairie Island, Units 1 and 2. Specifically, the licensees request proposed conducting annual UT training in accordance with 10 CFR 50.55a(b)(2)(xiv).

2.0 RELIEF REQUEST NO. 9 FOR UNIT 1 AND NO. 10 FOR UNIT 2 2.1 Code Requirements for which Relief is Requested The licensee is requesting relief from Appendix VII to Section XI of the ASME Code, Subsection VII-4240, for all UT personnel. Subsection VII-4240 requires a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual UT training.

2.2 Licensees Proposed Alternative to Code Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed conducting annual UT training in accordance with 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsection VII-4240 of Section XI of the ASME Code, 1989 edition, Appendix VII. Annual UT training in accordance with 10 CFR 50.55a(b)(2)(xiv) would require that all personnel qualified for performing UT examinations in accordance with Section XI of the ASME Code, Appendix VIII, 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 UT examinations at a licensees facility.

2.3 Licensees Bases for Requesting Relief (as stated)

The regulation at 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 licensees facility.

As part of the NRC staffs rulemaking effort to revise 10 CFR 50.55a(b)(2), the NRC staff stated in the Federal Register notice (64 FR 51369, September 22, 1999) of the proposed rulemaking 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 examiners 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.

2.4 Evaluation Subsection VII-4240, Appendix VII, of Section XI of the Code requires 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training to impart knowledge of new developments, material failure modes, and any pertinent technical topics as determined by the licensee. No hands-on training or practice is required to be included in the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of training. This training is required of all UT personnel qualified to perform examinations of ASME Code Class 1, 2, and 3 components. Independent of the ASME Code, 10 CFR 50.55a(b)(2)(xiv) imposes the requirement for Appendix VIII qualification that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on training with flawed specimens containing cracks be performed no earlier than 6 months prior to performing examinations at a licensees facility.

As part of the NRC staffs rulemaking effort to revise 10 CFR 50.55a(b)(2), the issue of UT annual training requirements was reviewed. This review was included in the summary of comments to the rule that was published in the Federal Register (64 FR 51370). In the review, the NRC staff determined that the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training requirement specified in the ASME Code was inadequate for the two reasons quoted in the licensees basis for relief (Section 2.3 above). In resolving a public comment on the rulemaking, the NRC staff adopted a recommendation advanced by the nuclear power industry which proposed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on practice with specimens containing cracks. This practice would occur no earlier than 6 months prior to performing examinations at a licensees facility. These recommendations were accepted by NRC and are reflected in 10 CFR 50.55a(b)(2)(xiv). The NRC staff has determined that the licensees proposed alternative to use 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsection VII-4240 will maintain the skill and proficiency of UT personnel at or above the level provided in the ASME Code for annual UT training, thereby, providing an acceptable level of quality and safety.

3.0 CONCLUSION

Based on the discussion above, the NRC staff concludes that the licensees proposed alternative to use the requirements in 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsection VII-4240 for annual UT training will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the alternative proposed by Relief Request No. 9 for Unit 1 and Relief Request No. 10 for Unit 2 are authorized for the third 10-year ISI interval for Prairie Island, Units 1 and 2.

Principal Contributor: T. Kim Date: November 7, 2002