ML19325E366
| ML19325E366 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/23/1989 |
| From: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8911060343 | |
| Download: ML19325E366 (4) | |
Text
-,-
t BALTIMORE OAS AND ELECTRIC li CHARLE S CENTER. P. O. DOX 1476. DALTIMORE, MARYLAND 21203 E
Gronot C. Catti 3
vice nuic.,,,
wetc. t p.,
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October 23, 1989 l
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U. S. Nuclear Regulatory Commission Washington, DC 20555 i
ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2: Docket Nos. 50-317 & 50-318 l
Renly to NRC Insnection Report Nos. 50-317/89-21* $0-318/89-21 i
REFERENCE:
(a) Letter from Mr. J. P. Durr (NRC) to Mr. G. C. Creel (DG&E),
i dated September 21, 1989, inspection Report Nos. 50-317/89 21; 50-318/89-21 i
Gentlemen:
Enclosed is our response to a Notice of Violation and a Notice of Deviation identified in Reference (a).
Should you have any further questions regarding this matter, we will be pleased to l
discuss them with you.
Very truly yours, t
8911060343 891023 ADOCK05g37 PDR
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o
.can.v for G. C. Creel i
Vice President - Nuclear Energy l
GCC/JMO/dtm I
t l
Enclosure ec:
D. A. Brune, Esquire J. E.
Silberg, Esquire R. A.Capra, NRC l
S. A.McNeil, NRC W. T. Russell, NRC D. F. Limroth/J. A. Golla, Jr.
T. Magette, DNR fsf I
I
.s n
o ENCLOSURE l
REPIN TO INSPECI10N REPORT NOs.
50-317/89-21;
$0-318/89-21 I
I.
NOTICE OF YlOLATION L
The Notice of Violation described in Appendix A of Reference (a) indicates that BG&E's Non-destructive Examination (NDE) Control Procedure (CP) 5.002 does 1
j not conform to the NDE Recertification Requirements invoked by ASME l
Section XI (i.e.,
BGAE allows a sixty day extension of the three year certification period).
The American Society for Non-destructive Testing (ASNT) has published a Recommended Practice No. SNT-TC-I A,
' Personnel Qualification and Certification in Non-destructive Testing.' The scope of the Recommended Practice, described in its first paragraph, notes:
1.4 It is recognized that these guidelines may not be appropriate for certain employers' circumstances and/or applications, in developing a written practice as required in Par. 5, the employer shall review the detailed recommendations presented, herein, and shall modify them as necessary to meet particular needs, i
in paragraph 9.7.1, the Recommended Practice notes that 'all levels of NDT l
personnel should be recertified at least once every three year) l Since April 1,1987, we have committed to the 1983 edition through Summer 1983 addenda of ASME Section XI.
Sub-article IWA-2300,
- Qualification of l
Non-destructive Examination Personnel
- states:
(a)
Personnel performing non-destructive examination operations shall be qualified with a written procedure prepared in accordance with SNT-TC-1 A 1980, except as required in (1), (2), and (3) below The first exception listed includes the statement:
i All Level 1,
11 and 111 personnel shall be recertified by examination on a j
,l' triennial basis.
I addends of ASME Section XI. Sub-article IWA-2300 of this version states:
Prior to April 1, 1987, we were committed to the 1974 edition through Summer 1975 i
(a)
Personnel performing non-destructive examination operations shall be qualified with a procedure prepared in accordano with SNT-TC-1 A for the i
applicable examination technique and met:iods.
Note that prior to April 1,1987, ASME Section XI invoked the Recommended Practice with no exceptions and we modified the certification period to allow a sixty-day extension (see paragraph I.4 above). Therefore, prit.,r to April 1, 1987, we were not in violation of ASME Code requirements as described in Appendix A of Reference (a).
6 r
b
.O g
ENCLOSURE o
REPLY TO INSPECT 10N REPORT NOs.
50-311/89-21;
$0-318/89-21 l
A.
Cmiedive *^ =
- k=* have been T; ken
=d the Results Aehleved 1.
On Au8ust 18, 1989, we deleted (by memo) the provision for a sixty-day extension of certification.
On September 29,
2.
An initial review of NDE personnel records, from April 1,1987 to the present, indicated the provision for a sixty-day extension of certification has not been exercised for ASME Section XI examinations, i
B.
Corrective Stens skat Will be Taken to Avoid Further VioltliDal The final review of NDE personnel records, from April 1,
1987 to the present, will be completed by November 10, 1989.
C.
Date When Full Comoliance Will be Achl ygd t
Full compliance was achieved on August 18, 1989. Prior so April 1,1987, we were in full compliance with the recommended practice for recertification that is described in SNT-TC-I A.
11.
NOTICE OF DEVIATION l
The Notice of Deviation described in Appendix B of Reference (a) indicates that our Calvert Cliffs Instruction (CCI)
- 613D,
- Qualification of Test and Inspection Personnel
- deviates from our commitment to ASME Code Requirements and established the visual examination program under ANSI N18.1-1971, instead of ANSI N45.2.6-1973.
t i
ASME Code Section XI 1983 with Summer 1983 Addenda paragraph IWA-2300(c)
{
states:
Personnel performing the visual examinations YT-2, VT-3, and VT-4 of IWA-2212, IWA-2213, and IWA-2214, respectively, shall be qualified by the Owner or the Owners' agent in accordance with the comparable levels of competency as defined in ANSI N45.2.6-1973.
ASME Boller and Pressure Vessel Code Case N-424 is approved for use in l
Regulatory Guide 1.147. Revision 6. The Code Case is referenced in our Program Plan for the Second Inspection Interval for Calvert Cliffs Nuclear Power Plant, 1
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1
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,o ENCLOSURE f rp._
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f
'[ REPLY TO INSPECTION REPORT NOs.
50-317/89-211 50-318/89-21 g,
as y.
e Units l' and 2. Table.6, Summary of Regulatory Guide 1.147 Code Cases. The Code Case states:
It. is the opinion of the Committee that ANSI /ASME N45.2.6-1978 may be L
used instead of ANSI N45.2.6-1973 when qualifying examination personnel to perform VT-2, VT-3, and VT-4 visual examinations (c.r Section XI, Division 1.
Additionally. in the Quality Assurance Policy (Revision 19), Table
- IB1, page 48, 'BG& E's Position on Guidance Contained in ANSI Standards,* we
' state,
{
All other BG&E personnel [other than personnel of B G & E's Quality Control organizations within QASD) who perform inspection, examination, I
and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1-1971.
The UFSAR contains the same exception in Chapter IB, Table iB-1.
CCI-613D, as written complies with both standards. It references ANSI N45.2.6-1978. However, in its introduction section, CCI-613n states, All Nuclear Energy Division (NED) personnel conducting, reviewing or l
fi, scheduhng Engineering Test Procedures, Functional or Surveillance Tests F'
or receipt inspections on spare parts must either be qualified per this lastruction SI per a
formal training program conforming to the rMuirements of ANSI N18.1-1971.
In tin 9 other cases where ANSI N18.1-1971 is referenced in CCI-613D, simila; m e.eptions are described. The exception is not intended to apply to ASME C,x.e Section XI NDE personnel.
CCI-613D is written to admirtistratively control the qualification of a wide range of test and inspection personnel, it is not written to exclusively apply to ASME Code Section XI NDE personnel. As it is currently used for l
qualification of ASME Code Section XI VT-2, VT-3 and VT-4 examiners, CCI-613D rnects ANSI N45.2.6-1978 requirements. Therefore, we have not d
deviated from a commitment to ASME Code requirements as described in Appenilix
('
B of Reference (a).
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