ML18152B540

Requests Relief from Specific Requirements of Subsection Iwl of 1992 Edition with 1992 Addenda of ASME Section Xi,Per 10CFR50.55a(a)(3)

ML18152B540
Person / Time
Site:	Surry, North Anna
Issue date:	02/11/1999
From:	Hartz L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
99-010, 99-10, NUDOCS 9902220043
Download: ML18152B540 (8)

Text

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e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 11, 1999 United States Nuclear Regulatory Commission Serial No.99-010 Attention: Document Control Desk NL&OS/ETS RO Washington, D.C. 20555 Docket Nos. 50-280 50-281 50-338 50-339 License Nos. DPR-32 DPR-37 NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATIONS UNITS 1 AND 2 NORTH ANNA POWER STATIONS UNITS 1 AND 2 ASME SECTION XI RELIEF REQUESTS North Anna Power Station Units 1 and 2 are presently in the second ten year inservice inspection interval, and examinations are conducted to the requirements of the 1983, Summer 1983 Addenda and 1986 Editions of ASME Section XI, respectively. 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 ASME Section XI. 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 10 CFR 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 five years from the effective date of the rule, which is September 9, 2001. By letter dated August 28, 1998 relief requests were previously submitted for approval for both Surry Units for their containment inservice inspection programs. An additional relief request has been identified for each unit and is now being submitted.

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Pursuant to 10 CFR 50.55a(a)(3), relief is requested from specific requirements of Subsection IWL of the 1992 Edition with the 1992 Addenda of ASME Section XI. The relief requests and the bases* for the reliefs are included in Attachments 1 and 2 for North Anna Units 1 and 2 and Surry Power Station Units 1 and 2, respectively. Relief is

requested from subsection IWL Code requirements based on proposed alternatives that would provide an acceptable level of quality and safety. These Relief Requests have been reviewed and approved by the Station Nuclear Safety and Operating Committee.

If you have any questions concerning this request, please contact us.

Very truly yours,

~~

L. N. Hartz Vice President - Nuclear Engineering and Services Attachments cc: U. S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station Mr. M. J. Morgan NRC Senior Resident Inspector North Anna Power Station Mr. R. Smith Authorized Nuclear Inspector Surry Power Station Mr. M. Grace Authorized Nuclear Inspector North Anna Power Station

I-e Attachment 1 Relief Requests IWL3 Virginia Power Electric and Power Surry Power Station Units 1 and 2

e Virginia Electric & Power Company First Containment Inspection Interval (Units 1 and 2)

Relief Request RR-IWL3 SYSTEM/COMPONENT(S) FOR WHICH RELIEF IS REQUESTED:

All concrete surfaces subject to examination in accordance with Subsection IWL of the 1992 Edition, 1992 Addenda of ASME Section XI.

CODE REQUIREMENTS:

Table IWL-2500-1, Category L-A requires a VT-3C examination method of all areas per item L1.11 and a VT-1 C examination method of suspect areas per item L1.12. The examinations are performed by personnel qualified to the requirements of IWL-2310.

CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED:

Relief is requested from the required qualification requirements for methods VT-1C and VT-3C as specified in IWL-2310.

BASIS FOR RELIEF:

The required examinations describe both the type of examinations to be performed and the qualifications of the personnel to perform them. The VT-1 C and VT-3C examinations require a certification program based upon ANSI/ASNT CP-189, 1991, to provide personnel for the examinations. This requirement will necessitate the development of a new certification program.

Additionally, the requirement of IWL-2320 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 are also found in IWL-2320. The qualification requirements do not require the Responsible Engineer to be additionally certified to VT-1 C or VT-3C, however neither do they exempt the Responsible Engineer from the requirements of IWL-2310. In fact, the requirements of IWL-2510 specify the examinations shall be performed by, or under the- direction of, the Responsible Engineer. 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, it is considered an unnecessary hardship to develop a new certification program for VT-1C and VT-3C personnel, if the examinations are performed by the

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e Responsible Engineer. The Responsible Engineer will provide equivalent quality and safety *during the examination. It should be noted that the 1998 Edition of ASME Section XI eliminates the VT-1C and VT-3C requirements and their associated CP-189 certification for the examinations required by IWL.

ALTERNATIVE REQUIREMENTS:

Only personnel determined to be Responsible Engineers will be used in lieu of VT-1C 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 92 Addenda of ASME Section XI prior to performing examinations.

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Attachment 2 Relief Requests IWL3 Virginia Power Electric and Power North Anna Power Station Units .1 and 2

e Virginia Electric & Power Company First Containment Inspection Interval (Units 1 and 2)

Relief Request RR-IWL3 SYSTEM/COMPONENT(S) FOR WHICH RELIEF IS REQUESTED:

All concrete surfaces subject to examination in accordance with Subsection IWL of the 1992 Edition, 1992 Addenda of ASME Section XI.

CODE REQUIREMENTS:

Table IWL-2500-1, Category L-A requires a VT-3C examination method of all areas per item L 1.11 and a VT-1 C examination method of suspect areas per item L 1.12. The examinations are performed by personnel qualified to the requirements of IWL-2310.

CODE REQUIREMENTS FROM WHICH RELIEF IS REQUESTED:

Relief is requested from the required qualification requirements for methods VT-1 C and VT-3C as specified in IWL-2310.

BASIS FOR RELIEF:

The required examinations describe both the type of examinations to be performed and the qualifications of the personnel to perform them. The VT-1C and VT-3C examinations require a certification program based upon ANSI/ASNT CP~189, 1991, to provide personnel for the examinations. This requirement will necessitate the development of a new certification program.

Additionally, the requirement of IWL-2320 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 are also found in IWL-2320. The qualification requirements do not require the Responsible Engineer to be additionally certified to VT-1C or VT-3C, however neither do they exempt the Responsible Engineer from the requirements of IWL-2310. In fact, the requirements of IWL-2510 specify the examinations shall be performed . by, or under the direction of, the Responsible Engineer. 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, it is considered an unnecessary hardship to develop a new certification program for VT-1C and VT-3C personnel, if the examinations are performed by the Responsible Engineer. The Responsible Engineer will provide equivalent quality and

safety during the examination. It should be noted that the 1998 Edition of ASME Section XI eliminates the VT-1C and VT-3C requirements and their associated CP-189 certification for the examinations required by IWL.

ALTERNATIVE REQUIREMENTS:

Only personnel determined to be Responsible Engineers will be used in lieu of VT-1C 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 92 Addenda of ASME Section XI prior to performing examinations.