ML031950119
| ML031950119 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba  (DPR-038, DPR-047, DPR-055, NPF-035, NPF-052) |
| Issue date: | 07/01/2003 |
| From: | Mccollum W Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML031950119 (8) | |
Text
Duke WPEnergy.
Duke Energy Corporation 526 South Church Street P.O. Box 1006 Charlotte, NC 28201-1006 July 1, 2003 U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Duke Energy Corporation Oconee Nuclear Station, Units 1, 2, & 3 Docket Nos. 50-269, 50-270, 50-287 McGuire Nuclear Station, Unit 2 Docket No. 50-370 Catawba Nuclear Station, Units 1 & 2 Docket Nos. 50-413, 50-414 Relief Request for Alternative to ASME Section XI Relief Request 03-GO-007 Pursuant to 10 CFR 50.55a (a) (3) (i), Duke Energy Corporation (Duke) requests the use of an alternative to the ASME Boiler and Pressure Vessel Code,Section XI, IWA-2300, 1989 Edition for the remainder of the third inspection interval of Oconee Units 1, 2, and 3, and the remainder of the second inspection interval of McGuire Unit 2 and Catawba Units 1 and 2.
Specifically, Duke requests relief from the requirement to qualify and certify nondestructive examination (NDE) personnel in accordance with SNT-TC-1A, 1984 Edition with the additional requirements of ASME Section XI, IWA-2300, 1989 Edition. Duke requests approval to use, as an alternate, the requirements to qualify and certify NDE personnel in accordance with Sub-article IWA-2300 of the 1995 Edition through 1996 Addenda of Section XI utilizing the CP-189 qualification and certification program.
A detailed description of the proposed alternative and justification is included as an attachment to this letter. Additionally, an attached table provides a comparison of some of the major requirements of the 1984 Edition of SNT-TC-1A as modified by IWA-2300 of the 1989 Edition of Section XI with the 1991 Edition of CP-189 as modified by IWA-2300 of the 1995 Edition and 1996 Addenda of Section XI. Duke is requesting approval of this request by March 31, 2004, to support training of personnel for implementation during the fall outages. Questions regarding this request may be directed to R. K. Nader at 704-382-0979.
Very truly yours, W. R. McCollum, Jr.
Senior Vice President, Nuclear Support p517
U. S. Nuclear Regulatory Commission July 1, 2003 Page 2 Attachment xc w/att:
L. A. Reyes, Regional Administrator U. S. Nuclear Regulatory Commission, Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303 L. N. Olshan (Addressee only)
NRC Senior Project Manager (ONS)
U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 R. E. Martin (Addressee only)
NRC Senior Project Manager (MNS and CNS)
U. S. Nuclear Regulatory Commission Mail Stop 0-8 H12 Washington, DC 20555-0001 M. E. Shannon, Senior Resident Inspector (ONS)
E. F. Guthrie, NRC Senior Resident Inspector (CNS)
J. B. Brady, NRC Senior Resident Inspector (MNS)
03-GO-007 Page 1 of 3 Duke Energy Corporation McGuire Unit 2 Catawba Units 1 & 2 Oconee Units 1, 2 & 3 10-YEAR INTERVAL REQUEST FOR RELIEF NO. 03-GO-007 Pursuant to 10 CFR 50.55a (a)
(3) (i),
Duke Energy Corporation proposes an alternative to the requirements of ASME Section XI, IWA-2300, 1989 Edition.
I.
Code Requirement The 1989 Edition of ASME Section XI,IWA-2300, requires qualification of NDE personnel in accordance with a written practice developed in accordance with SNT-TC-1A, 1984 Edi-tion as amended by IWA-2300.
10 CFR 50.55a(g)(6)(ii)(C) requires implementation of the ASME Code,Section XI, Appendix VIII and the supplements to Appendix VIII of the 1995 Edition, 1996 Addenda. By refer-ence, this includes the requirements of Appendix VII and IWA-2300 of the 1995 Edition, 1996 Addenda. The qualifica-tion and certification of ultrasonic examiners must be to a written program in accordance with ANSI/ASNT CP-189, 1991 Edition as amended by IWA-2300.
II. Code Requirement for which Relief is Requested Relief is requested from the requirement to qualify and certify nondestructive examination (NDE) personnel in ac-cordance with SNT-TC-1A, 1984 Edition with the additional requirements of ASME Section XI, IWA-2300, 1989 Edition.
III. Basis for Relief ASME Section XI, IWA-2300, 1989 Edition requires develop-ment and execution of a written practice in accordance with SNT-TC-1A, 1984 to address the qualification and certifica-tion of NDE personnel.
10 CFR 50.55a was amended in the Federal Register (67 FR 60531) to require the use of ASME Section XI, 1995 Edition with the 1996 Addenda, for ultra-sonic examination with an expedited phased execution of Ap-pendix VIII.
This requires Duke Energy Corporation to de-velop and implement a written practice in accordance with the requirements of ANSI/ASNT CP-189, 1991 Edition for the qualification and certification of NDE personnel performing
03-GO-007 Page 2 of 3 ultrasonic examinations of components under the scope of Appendix VIII.
Duke Energy Corporation operates seven nuclear units, six of which are using the 1989 Edition of ASME Section XI and one, McGuire Unit-i, is using the 1995 Edition with the 1996 Addenda.
This entails the preparation and implementa-tion and to the extent possible, consolidation of numerous certification requirements, some of which are in conflict.
Personnel certified to perform ultrasonic examinations are also certified to perform other nondestructive examinations such as magnetic particle, liquid penetrant and radiogra-phy.
A direct comparison of the implementation requirements of the 1984 Edition of SNT-TC-1A as modified by IWA-2300 of the 1989 Edition of Section XI with the 1991 Edition of CP-189 as modified by IWA-2300 of the 1995 Edition and 1996 Addenda of Section XI is considered to be too cumbersome.
Therefore, the attached table provides a comparison of some of the major requirements.
IV.
Justification for Relief Utilizing the CP-189 qualification and certification re-quirements for NDE personnel, for the additional Subsection IWA examinations, is considered equivalent to the qualifi-cations and certifications required by SNT-TC-1A. Addition-ally, CP-189 is required to be used for the Fourth 10-Year Interval of the Inservice Inspection Program for Oconee Unit-i beginning in January, 2004 and is already in effect at McGuire Unit-i. Therefore, in lieu of maintaining redun-dant, possibly conflicting programs, the proposed alterna-tive of maintaining a single program which meets the re-quirements of CP-189, for the qualification and certifica-tion of NDE personnel, will simplify record keeping, sat-isfy the need to maintain personnel qualifications and cer-tifications, eliminate redundant systems, and provide an acceptable level of quality and safety appropriate for other NDE disciplines.
V. Alternative Provision Qualification and certification of NDE personnel shall be conducted in accordance with the requirements contained in Sub-article IWA-2300 of the 1995 Edition through the 1996 Addenda of Section XI utilizing the CP-189 qualification and certification program.
03-GO-007 Page 3 of 3 VI.
Schedule for Implementation CP-189 with the additional requirements of Section XI, IWA-2300, 1995 Edition through the 1996 Addenda will be used for the remainder of the Third Inspection Interval for Oconee Units 1, 2, and 3; the Second Inspection Interval for Catawba Units 1 and 2 and the Second Inspection Inter-val for McGuire Unit 2.
Sponsored Reviewed I
_Date 6 9L)3 Dat
Duke Energy Corporation Attachment to Relief Request 03-GO-007 Page 1 of 3 Requirement SNT-TC-1A, 1984 CP-189, 1991 IWA-2300, 1989 IWA-2300,1995 w/1996 UT Training Hours Level U/II Hours Level I/II Hours Level 1111 Hours Level 1II lHS l2CL 40/80 40/40 30/40 40/40 80/80 80/80 10 hrs. annual training 10 hrs. annual training UT Experience Level I Level I Level I Hrs.
Level U Hrs-Level I Hrs.
Level II Hrs.
Levd I Hrs.
Level II months months Method l
Total Method l Total 250 800 250 800
_ ___________39200 400 600 1200 RT Training Hours Level 111 Hours Level 1/fI Hours Level M/I Hours Level 1/II GS I
HS I 2CL
_=
88/80 l 39/40 l 29/35 39/40 No additional reuirements
[
No additional requirements RT Experience Level I Level II Level I Hrs.
Level II Hrs.
No additional requirements No additional requirements Months months Method I
Total I Method Total 3 _ _9 200 400 600 1200 PT Training Hours Level M/I Hours Level 1I/
Hours Level 111 Hours Level I/II GS HS 2CL
_.____nr_
12/16 4/8 4/4 8/8 No additional reuirements No additional reauirements PT Experience Level II Level I Hrs.
Level II Hrs.
No additional requirements No additional requirements months months Method Total Method Total 35 130 135 270 Notes:
- 1. Training: GS=grammar school, HS=high school, 2CL-2 years college
- 2. SNT-TC-1A allows simultaneous credit for experience in two or more NDE disciplines when at least 25% of the person's work time is spent on each method for which certification is sought. CP-189 does not allow simultaneous credit.
I -1 I
Duke Energy Corporation Attachment to Relief Request 03-GO-007 Page 2 of 3 Requirement SNT-TC-1A, 1984 CP-189, 1991 IWA-2300, 1989 IWA-2300, 1995 w/1996 ET Training Hours Level VII Hours Level 1111 Hours Level UIl Hours Level TI/I GS lHS 2CL-48/24 8/12 8/8 12/40 j
No additional requirements
]
No additional r irements ET Experience Level I Level II Level I Hrs.
Level II Hrs.
Level I Ws.
Levd II Hrs.
Level I Hrs.
Level II I His.
rnonths months Method Total Method Total No additional requirements No additional requirements 1
9 65 130 600 1200 MT Training Hours Level I/I Hours Level T/II Hours Level III Hours Level J/II GS HS l2CL=
24/16 12/8 8/4 12/8 _
No additional requirements I
No additional requirements MT Experience Level I Level I Level I Hrs.
Level II Hrs.
No additional requirements No additional requirements Months months Method r Total Method Total 1
3 65 10 200 400
_==
-'J4
-s--- :' '7777 VT Training No rules provided.
No rules provided.
Certification to levels comparable Certification to levels to SNT-TC-lA is required by comparable to CP-189 is IWA-2300 required b IWA-2300-VT Experience No rules provided.
No rules provided.
Certification to levels comparable Certification to levels to SNT-TC-1A is required by comparable to CP-189 is
,=
b
.IWA-2300 ruired IWA-2300 PW -PS P:; t :iEfNi: -!
,f -0 4!::-- ;;%m_
I Duke Energy Corporation Attachment to Relief Request 03-GO-007 Page 3 of 3 Requirement SNT-TC-1A, 1984 CP-189, 1991 IWA-2300, 1989 IWA-2300, 1995 w/1996 Level m 4 year college, 1 year No education or experience requirements, Minimum high school graduate Minimum high school graduate Education and experience; or 2 years but ASNT Level m certificate is required.
or GED. 4 year college, 1 year or GED. 4 year college, 1 year Experience college, 2 years experience; or 2 years college, 2 experience; or 2 years college, 2 experience; or 4 years years experience; or 4 years years experience; or 4 years experience l_experience exeenc Level m Basic, Method and ASNT Basic and Method examinations are Basic, Method and Specific Basic, Method, Specific, Examinations Specific optional.
required. Employer administered Specific, examinations required. ASNT Practical and Demonstration Employer may waive Practical and Demonstration examinations.
examinations are not required.
examinations required for initial the examinations.
certification. Only Method, Specific, Practical and Demonstration examinations are required for re-certification.
The Practical and Demonstration examinations may be waived under certain conditions. ASNT examinations are not required.
Grading of 70% passing for each 70% passing for each examination. 80%
Additional requirements for the Additional requirements for the Examinations examination. 80%
composite grade with simple average ultrasonic method in Appendix ultrasonic method in Appendix composite grade with required.
VII.
VII.
weighting factor allowed