ML20216J917

Safety Evaluation Accepting Relief Request MC-R001 for First 10-yr Interval of Containment Insp Program Per 10CFR50.55a (a)(3)(ii),per 971219 Request

ML20216J917
Person / Time
Site:	Duane Arnold
Issue date:	04/16/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216J902	List: ML20216J896 ML20216J917
References
NUDOCS 9804220032
Download: ML20216J917 (4)

Text

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NUCLEAR REGULATORY COMMISSION g WASHINGTON, D.C. 20066-0001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EOR RELIEF REQUEST MC-R001 FOR THE FIRST 10-YEAR INTERVAL OF THE CONTAINMENT INSPECTION PROGRAM E.QB IES UTILITIES INC.

DUANE ARNOLD ENERGY CENTER DOCKET NUMBER: 50-331

1.0 INTRODUCTION

The Technical Specifications for the Duane Amold Energy Center (DAEC) 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 'he ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR SU.65a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed attematives would provide an acceptable level l of quality and safety, or (ii) compliance with the specified requirements would result in hardship l or unusual difficulty without a compensating increase in the level of quality and safety.

Puisuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) shall meet the requirements, except the design .id access provisions and the pre-l service exar,nination requirements, set forth in the ASME Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. 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 third inspection interval of the Duane Amold Energy Center, is the 1989 Edition. 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 limitatione and modifications listed therein and subject to Commission approval.

Enclosure 9804220032 980416 PDR ADOCK 05000331 P PDR

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. l l 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(g)(6)(i), the Commission may grant relief and may impose attemative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are othenvise in the public interest, giving due consideration to the burden upon the licensee that could result if the requimments were imposed.

By letter dated December 19,1997, as supplemented on March 18,1998, IES Utilities Inc. (the licensee) submitted a request for relief from the applicable ASME Code,Section XI, requirements for the qualification and certification of non-destructive examination (NDE) personnel for containment inspections at the Duane Amold Energy Center (DAEC).

Specifically, relief is requested from the provisions of Subarticle IWA-2300, " Qualification of Nondestructive Examination Personnel," which requires NDE personnel to be qualified and certified using a written practice in accordance with CP-189, an American Society of

,fondestructive Testing (ASNT) Standard published in 1991 and endorsed in Subarticle IWA-2300.

1 2.0 DISCUSSION Component identification Code Class: MC

References:

IWE-2000 Examination Category: E-A, E-B, E-C, E-D, E-F, E-G, and E-P ltem Number: Allitem numbers

Description:

ASME Section XI Examination and Inspection Procedures for IWE l

' Components Component Numbers: All Components l Code Requirement 10 CFR 50.55a(g)(4)(v) requires that Class MC (IWE) and CC (lWL) pressure retaining components and their integral attachments meet the applicable ASME Section XI examination l and inspection requirements (1992 with the 1992 addenda). (Subsection IWL does not apply to DAEC.)

Relief is requested from the provisions of IWA-2300, " Qualification of 14ondestructive

! Examination Personnel." This requires NDE personnel to be qualified and certified using a written practice in accordance with CP-189, Standard for Quelification and Certification of Nondestructive Testing Personnel, as amended by the requirements of this Division.

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• 3-Licensee's Basis for Relief (as stated) j I

10 CFR 50.55a was amended in the Federal Register (61 FR 41303) to require the use of the 1992 Edition,1992 Addenda, of Section XI when performing containment examinations. A i

written practice based on the requirements of CP-189, as amended by the requirements of the i Subarticle IWA-2300, to implement Subsection IWE duplicates efforts already in place for all i other subsections.10 CFR 50.55a references the 1989 Edition of ASME Section XI for all other i subsections. Subarticle IWA 2300 of Me 1989 Edition requires a written practice based on i SNT-TC-1 A, as amended by the requW monts of Subarticle IWA-2300.

l Further, Subarticle IWA-2300 of the 1992 Edition,1992 Addenda, states, ' Certifications based on SNT-TC-1 A are valid until recertification is required." Visual examination is the primary

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1 nondestructive examination method required by Subsection IWE. Neither CP-189 nor SNT-TC-  ;

1 A specifically includes visual examination; thus, the Code requires qualification and l certification to comparable levels as defined in CP-189 or SNT-TC-1 A, as applicable, and the l Emple"er's written practice.

Development and administration of a second program would not enhance safety or quality and  ;

would serve as a burden, particularly in developing as a second written practice, tracking of  !

certifications, and duplication of paperwork. This duplication would also apply to NDE vendor programs. Updating to the 1992 Edition,1992 Addenda, for Subsections IWB, IWC, etc., would require a similar request for relief.

Relief is requested in accordance with 10 CFR 50.55a(a)(3)(ii). Compliance with the specified  ;

requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. )

Licensee's Pronosed Alternative Examination (as stated) i Examinations required by Subsection IWE and IWL shall be cor. ducted by personnel qualified i and certified to a written practice based on SNT-TC-1 A to the current Section XI Code of record.

Relief is requested for the first 10-year interval of the Containment inspection Program for DAEC.

3.0 EVALUATION in Federal Register Notice No.154, Volume 61, dated August 8,1996, the Nuclear Regulatory Commission amended its regulationc to incorpointe by reference the 1992 edition with 1992 addenda of Subsections lWE and IWL of Section Xi of the ASME Boiler and Pressure Vessel Code. Subsections IWF. and IWL provide the requirements for incervice inspection (ISI) of ' i Class CC (concrete containments), and Class MC (metallic containments) of the light-water cooled power plants. The effective date for the amend. ;f ;ub was September 9,1996, and it requires the licensees to incorporate the new requiren.ents into ' heir ISI plans and to complete the first containment inspection by September 0. 2001. H&cvsr, a licensee can submit a

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4 request for relief from one or more requirements of the regulation (or the endorsed code requirements) with proper justification. The provision for granting relief is incorporated in the j regulation.

DAEC submitted its " Third 10-Year Inspection Interval Program Plan" for the staff review in April 1996. The program plan is based on the 1989 Edition of the ASME Section XI requirements for Class 1,2, and 3 components. The 1980 edition of the code requires the use of ASNT-TC-1A for the qualification and certification of NDE personnel. Thus, the staff recognizes that the licensee will have to develop a second program for qualifying and certifying its NDE personnel for containment inspection in acc,ordance with Subarticle IWA-2300 and its associated documentation. Moreover, as pointed out by the licensee, most of the containment examinations required by Subsection IWE are VT-3, general visual. Volumetric examination is required during the containment surface augmented inspection. Because the licensee's current procedure for qualifying and certifying the NDE personnel, based on the provisions of SNT- i TC-1 A, provides reasonable assurance of qualified examiners for Clan 1,2, and 3 I components, the use of NDE personnei qualified by the procedure for containment augmented l examination will not compromise the quality of the examination. The licensee's proposed I altemative is to continue to use CP-189 for certifying and qualifying the NDE personnel for the l next 10-year inspection interval program plan. l As the VT-3 visual examination is the basic examination technique for containment inspection, the licensee has developed procedures for qualifying the visual examination personnel for i vision tests and illumin ation requirements in accordance with IWA-2321 and IWA-2322. j Considering thm factors, the staff concludes that the alternative provides reasonable assurance of qt.daied examiners and that the imposition ~of the requirement of Subarticle IWA-2300 (1992 Edition) for containment inspection will result in hardship without a compensating increase in the level of quality and safety.

4. CONCLUSION Based on the review of the information provided in the relief reovest and the response to the staff's request for additional information, the staff finds that the alternative proposed by the licensee in lieu of the code requirement endorsed by the regulation will provida qualified examiners and the imposition of the code requirement would result in hardship without a compensating increase in the level of quality and safety. Accordingly, the request for relief dated December 19,1997, to allow the use of licensee's existing practice for qualifying the NDE personnel for containment inspections until the end of the current inspection interval, is authorized, pursuant to 10 CFR 50.55a(a)(3)(ii).

Principal Contributor: Hans Ashar Date: IPril 16, 1998 e