ML18152B384

Safety Evaluation Granting Relief Request from ASME Section Xa Requirements for Containment Insp

ML18152B384
Person / Time
Site:	Surry
Issue date:	08/23/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML18152B382	List: ML18152B381 ML18152B383 ML18152B384
References
NUDOCS 9908270081
Download: ML18152B384 (5)

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UNITED STATE'3 NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUEST FROM ASME SECTION XI REQUIREMENTS FOR CONTAINMENT INSPECTION VIRGINIA ELECTRIC POWER COMPANY SURRY POWER STATION, UNITS 1 AND 2 DOCKET NOS: 50-280 AND 50-281

1.0 INTRODUCTION

Surry Power Station, Units 1 and 2, are presently in the third ten-year inservice inspection interval, and examinations are conducted to the requirements of the 1989 Edition of American 6ociety of Mechanical Engineers (ASME)Section XI (Ref. 1). By Federal Register Notice 154 (Volume 61 ), dated August 8, 1996, the Nuclear Regulatory Commission amended its regulations to incorporate by reference the 1992 Edition with the 1992 Addenda of Subsections IWE and IWL, with specified modifications in Title 1 O of the Code of Federal Regulations (1 O CFR) Section 50.55a. The effective date of the amended rule was September 9, 1996.

The rule requires expedited implementation of the first period examination requirements within 5 years from the effective date of the rule, which corresponds to September 9, 2001. Pursuant to 1 O CFR 50.55a(a)(3), the licensee, Virginia Electric and Power Company (VEPCO), has requested relief from specific requirements of Subsection IWL of the 1992 Edition with the 1992 Addenda of ASME Section XI.

VEPCO states that its request for relief is based on proposed alternatives that would provide an acceptable level of quality and safety, and that the relief request has been reviewed and approved by the Station Nuclear Safety and Operating Committee (Ref. 1 ). The staff has reviewed the information provided by the licensee, and its evaluation is provided below.

2.0 EVALUATION Code Requirements:

This relief request covers ali' concrete surfaces subject to examination in accordance with Subsection IWL of the 1992 Edition, 1992 Addenda of ASME Section XI (Ref. 2). Table IWL-2500-1, Category L-A, requires a VT-3C visual examination of all areas per item L1.11 and a VT-1 C visual examination of suspect areas per item L 1-12 (Ref. 2). The examinations are performed by personnel qualified to-the requirements of IWL-2310. IWL-2310 requires that VT-3C visual examinations be conducted to determine the general structural condition of concrete surfaces of containments by identifying areas of concrete deterioration and distress (Ref. 2). VT-1C visual examinations are conducted to determine concrete deterioration and distress for suspect areas detected by VT-3C and certain other conditions described in Ref. 2.

IWL-231 O further requires that (1) the owner's written practice shall define qualification requirements for concrete examination personnel in accordance with IWA-2300, and that (2) limited certification in accordance with IWA-2350 may be used for examiners limited to concrete.

9908270081 990823 PDR ADOCK 05000280 8

PDR

• Code Requirements from which VEPCO requests relief:

e VEPCO has requested relief from the qualification requirements for methods VT-1C and VT-3C as specified in IWL-2310 (Ref. 1).

Licensee's Basis for Relief:

The required examinations (specified in IWL 2310) describe both the type of examinations to be performed and the qualifications of the personnel to perform such examinations. The VT-1C and VT-3C examinations require a certification program based upon ANSI/ASNT CP-189, 1991, to provide personnel for the examinations. The licensee proposes to use Responsible Engineers in lieu of VT-1C and VT 3-C certified personnel to perform these examinations.

In addition, IWL-2320 ("Responsible Engineer) requires that the Responsible Engineer approve, instruct, and train concrete examination personnel. The Responsible Engineer is also required to evaluate examination results. The qualification requirements of the Responsible Engineer, specified in IWL-2320, do not require the Responsible Engineer to be additionally.

certified to VT-1 C or VT-3C; neither do they exempt the Responsible Engineer from the requirements of IWL-2310. In fact, the requirements of IWL-251 O specify that the examinations shall be performed by, or under the direction of, the Responsible Engineer.

The licensee further states that, from the description of the Responsible Engineer in IWL-2320, it is apparent that the individual could adequately perform the necessary examinations, given that the appropriate visual acuity requirements are met. As such, VEPCO considers that developing a new certification program for VT-1 C and VT-3C personnel will cause unnecessary hardship. The Responsible Engineer will provide equivalent quality and safety during the examination.

Licensee's Proposed Alternative: The licensee proposes the following alternative method:

Only personnel determined to be Responsible Engineers will be used in lieu of VT-1 C and VT-3C certified personnel to perform examinations required in Category L-A of ASME Section XI. Additionally, Responsible Engineers performing examinations will have met the vision test requirements of IWA-2321 and IWA-2322 of the 1992 Addenda of ASME Section XI prior to performing examinations.

Staff Evaluation:

The staff has evaluated the licensee's basis for its request for relief, as well as its proposed alternative requirements, and finds that developing a new certification program for VT-1C and VT-3C personnel will result in an undue burden on the licensee because the Code-mandated certification program i~ to be based upon ft "ISi/ ASNT CP 189, 1991, which is intended primarily for the qualification of nondestructive testing personnel for metal components and steel structures. Therefore, requiring the development of a new certification program will not add significantly to the effectiveness of the required examinations for concrete structures, provided such examinations are performed by a Responsible Engineer whose qualifications are described in IWL-2320 as follows:

The Responsible Engineer shall be a Registered Professional Engineer experienced in evaluating the in-service condition of structural concrete. The Responsible Engineer shall have knowledge of the design and Construction Code and other criteria used in design and construction of concrete containments in nuclear power plants. In addition, the Responsible Engineer shall be responsible for (a) development of procedures for examination of concrete surfaces; (b) approval, instruction, and training of concrete examination personnel; (c) evaluation of examination results; (d) preparation of repair procedures; and (e) submittal of report to the owner documenting results of examinations and repair.

VEPCO has committed, in its letter of February 11, 1999, that it will employ only personnel determined to be Responsible Engineers in lieu of VT-1C and VT-3C certified personnel to perform examinations required in Category L-A of ASTM Section XI. VEPCO has additionally committed that Responsible Engineers will have met the vision test requirements of IWA-2321 and IWA-2322 of the 1992 Addenda of ASME Section XI prior to performing examinations. In view of these facts, the staff finds that the Responsible Engineer's qualifications are adequate for performing the required examinations and provide an acceptable level of quality and safety.

3.0 CONCLUSION

The staff has evaluated VEPCO's February 11, 1999, submittal (Ref. 1) for Surry Power Station, Units 1 and 2, and concludes that the use of personnel determined to be Responsible Engineers in lieu of VT-1C and VT-3C certified personnel to perform examinations required in Category L-A of Section XI provides an acceptable level of quality and safety. Therefore, VEPCO's request for relief is authorized pursuant to 1 O CFR 50.55a(a)(3)(i).

Principal Contributor: R. Pichumani Date:

August 23, 1999

References:

1.

Letter, February 11, 1999, L. N. Hartz, VEPCO, to USNRC, Virginia Electric and Power Company, Surry Power Station, Units 1 and 2, North Anna Power Station, Units 1 and 2, ASME Section XI Relief Requests

2.

Subsection IWL" Requirements for Class CC Concrete Components of Light-Water Cooled Plants" of the 1992 Edition, 1992 Addenda of Section XI, Division 1, of ASME Boiler and Pressure Vessel Code (ASME Code)

i.

e J.P. O'Hanlon August 23', 1999 The staff has completed its evaluation of this matter, therefore, we are closing TAC Nos.

MA4823, MA4824, MA4857 and MA4858.

Sincerely, ORIGINAL SIGNED BY:

Richard L. Emch, Jr., Chief, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-280, 50-281, 50-338, and 50-339

Enclosures:

North Anna Safety Evaluation Surry Safety Evaluation cc w/encls: See next page Distribution CDockefE1le'--.:.-J PUBLIC PDll-1 R/F J. Zwolinski/S. Black

• H. Berkow E. Dunnington G. Edison (2)

RScholl (e-mail SEs only)

OGC G. Hill (4)

ACAS M. Tschiltz, EDO.

R. Haag, RII R. Pichumani

• See previous concurrence DOCUMENT NAME:

G:\\PDl1-1\\SURRY\\ma4857,4858,4823,4824.w d OFFICE PM:PDII/S1 LA:PDl1/S1

• OGC*

SC/PDII/S1 NAME EDunnin ton CMarco DATE 8/14/99 8/16/99 COPY Yes/No Yes/No Yes/No OFFICIAL RECORD COPY