ML20211D620

SER Accepting VT-2 Examiner Qualification Request for PECO Energy Company,Peach Bottom Atomic Power Station,Units 2 & 3

ML20211D620
Person / Time
Site:	Peach Bottom
Issue date:	09/17/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20211D617	List: ML20211D612 ML20211D620
References
NUDOCS 9709290185
Download: ML20211D620 (4)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION VT-2 EXAMINER OVAllFICATION REllEF RE00ESI PECO ENERGY COMPANY PEACH BOTTOM ATOMIC POWER STATION. UNIT NOS. 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1.0 INTRODUCTION

The technical specifications for Peach Bottom Atomic Power Station (PBAPS),

Units 2 and 3, state that the inservice inspection of the American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel l

Code and applicable addenda as required by Title 10 of the Code of Federal been granted by the Commission pursu) ant to 10 CFR Paragraph 50.55a(g)(6)(i).Reaulatio 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC),

if (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 unu(su)al 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 provisions and the p)reservice examination requirements, set forth in the ASMEshall me Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of component design, geometry, and materials of construction. 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 applicable ASME Code,Section XI, for the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, second 10-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1981 addenda. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.

9709290185 970917 PDR ADOCK 05000277 P PDR

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Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a '

alternative re(g)[6)(1),

qunrementsthe Commission may grant that are determined torelief and may impose be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.

In the July 21, 1997, letter to the NRC, PECO Energy Company requested relief from the applicable ASME Code,Section XI, paragraph IWA-2300, concerning VT-2 examination personnel qualification requirements. PECO Energy Company requested approval to implement ASME Code Case N-546, " Alternative Requirements for Qualification of VT-2 Examination Personnel," in their 151 l program during the current inspection interval. The NRC staff has reviewed '

and evaluated the licensee's request for relief and the proposed alternative pursuant to 10 CFR 50.55a(a)(3)(1) for the Peach Bottom plant during the current inspection interval.

2.0 DISCUSSION

Reauest for Authorization to Imolement Alternatives to Code Reauirements C9ntained in Code Case N-546. Alternative Reavirements for Qualification of VT-2 Visual Examination Personnel M t.Reauirement: Section XI, IWA-2300, requires that personnel performing VT-2 and VT-3 visual examinations be qualified in accordance with comparable levels of competency as defined in ANSI N45.2.6. Additionally, the examination personnel shall have natural or corrected near distance vision acuity, in at least one eye, equivalent to a Snellen fraction of 20/20. For far vision, personnel shall have natural or corrected far distance visual acuity of 20/30 or equivalent.

Licensee's Code Relief Reaues1: The licensee has requested approval to implement alternatives to the Code requirements contained in Code Case N-546, Alternative Requirement for Qualification of VT-2 Examination Personnel, which is not yet approved by the NRC by reference in RG 1.147.

Licensee's Basis for Relief: (Asstated)

" Code Case N-546 allows experienced plant personnel such as licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel to perform VT-2 visual examinations without having to be certified to comparable levels of competency defined in ANSI N45.2.6. The PECO Energy Company individuals performing the visual examinations will be subject to the conditions provided in Code Case N-546.

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specifically, the examination personnel will have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant walkdciu experience, receive a minimum of four hours of training on section XI requirements and plant specific and will pass the vision procedures for VT-2 test requirements visual examinations, of IWA-2321, 1995 edit ion.

In addition to the requirements in Code Case N-546, PECO Energy Company has i l

procedures to assure that consistent VT-2 visual examinations are performed. PECO Enerfly Company will continue to document the l and visual activity of persons selected qualifications, to perform the VT-2train exam < nglnations and maintain records that verify all of- the requirements in the Code Case as specified herein, are, met. This alternative to the current code requirements alleviates the need to contract certified VT-2 personnel to perform these examinations and reduces the administrative burden of maintaining an extensive Section XI qualification and certification provam for VT-2 examination personnel.'

Licensee's Alternate Provisions: (As stated)

"PECO Energy Company will mut the requirements contained in Code Case N-546. Additionally, PECO Energy Company has formal procedures so that consistent VT-2 visual examinations are performed, and will document and maintain records to verify that persons selected as VT-2 examiners are qualified. Use of this code case will provide a comparable level of quality and safety to

-that currently in place for VT-2 visual examinations."

3.0 EVALUATION

The ASME Code,Section XI, IWA-2300, requires that VT-2 visual examination sersonnel be qualified to comparable levels of competency as daf!ned in ANSI 145.2.6. The Code also requires that the examination personnel be qualified for near and far distance vision acuity. PECO Energy company proposes to implement the alternatives provided in Code Case N-546. In addition, the licensu will implement formal procedures to ensure that consistent VT-2 visual examinations are performed. The licensee will also document and maintain records to verify that persons selected are qualified by meeting the following requirements of Code Case N-546:

1. At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant walkdown experience, such as that gained by-licensed and non-licensed _ operators, local leak rate personnel -

system engineers, and inspection and nondestructive examination personnel.

2. At least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of training on Section XI requirements and plant specific procedures for VT-2 visual examination.

3. Vision test requirements of IWA-2321, 1995 Edition.

. 4 The qualification requirements in Code Case N-546 are comparable to those qualifications required for VT-2 visual examiner certification. Furthermore, all licensed and non-licensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts. Hence, 4

the plant personnel with such background are acceptable candidates for

performing VT-2 visual examinations.

Since the licensee will implement formal procedures to obtain consistent VT-2 visual examination results even with the varied experience levels and will document the qualifications, training, and visual acuity of persons selected to perform the VT-2 visual examinations, the proposed alternative will provide an acceptable level of quality.

4.0 CONCLUSION

Based on a review of Code Case N-546, the staff has determineo that the

) alternatives to the Code qualification requirements for examination personnel, in conjunction with the licensee's added provisions, will provide an

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acceptable level of quality and safety. Therefore, the licensee's request to impler.ent alternatives provided in Code Case N-546 is authorized pursuant to

' 10CFR50.55a(a)(3)(1). Use of Code Case N-546 is authorized for the current intersal at the above mentioned plants, until such time as the Code Case is approved by reference in RG 1.147. At that time, if the licensee intends to 7

continue to implement this Code Case, the licensee is to follow all provisions in Code Case N-546 with limitations issued in RG 1.147, if any.

Principal Contributor: P. Patnaik Date: September 17. 1997 1

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