ML20217H883
| ML20217H883 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 04/01/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217H866 | List: |
| References | |
| NUDOCS 9804060103 | |
| Download: ML20217H883 (5) | |
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30886 0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE RELIEF REQUEST FOR THE THIRD INSERVICE INSPECTION INTERVAL -
EQB IES UTILITIES INC.
i 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 peormed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a(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(s)(3) states that attematives to the requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed attematives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulties 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) shall meet the requirements, except the design and access provisions and the pre-service examination 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 Arnold 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 limitations and modifications listed therein and subject to Commission approval.
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 alternative requirements that are determined to be authorized by law, will not endanger life, Enclosure
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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 a letter dated October 15,1997, IES Utilities (licensee) submitted a request for relief from the ASME Code,Section XI, paragraph IWA-2300 requirements for the qualification of VT-2 examination personnel. Specifically, the licensee requested approval to implement ASME Code Case N-546,"Altemative Requirements for Qualification of VT-2 Examination Personnel". The Civil Engineering and Geosciences Branch, Division of Engineering, has reviewed and evaluated the licensee's request for relief and the proposed attemative, pursuant to 10 CFR
' 50.55a(a)(3)(i) for the Duane Arnold Energy Center third 10-year inspection interval.
2.0 DISCUSSION.
Reauest for Authorization to Imolement Altematives to Code Reauirements Contained in Code Case N-548. " Alternative Reauirements for Qualification of VT-2 Visual Examination Personng' System /Comoonent(s)
Code Classes:
1,2, and 3
References:
IWA-2300 ASME Code Case N-546 Examination Categories:
B-E, B-P, C-B, C-H, D-A, D-B, and D-C ltem Numbers:
B4.10 through B4.13 B15.10 through B15.71 C2.33 C7.10 through C7.80 D1.10, D2.10, D3.10
==
Description:==
Alternative Requirements for Qualification of Vi 2 Examination Personnel.
Component Numbers:
All pressure retaining components within each system boundary subjected to a system hydrostatic / system pressure test.
. Code Reauirement
= lWA-2312 states " Personnel performing visual examinations or using other NDE methods not addressed in SNT-TC-1A shall be qualified and certified to comparable levels of qualification as
. defined in SNT-TC-1 A and the Employer's written practice."
Licensee's Basis for Altemate Examination: (As stated)
. ASME Code Case N 546 currently provides an attemative for the qualification requirements of VT-2 personnel. This Code Case provides the following for
. qualification of VT-2 personnel:
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(a) At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> plant wa'kdown experience, such as that gained by licensed and non-licensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.
(b) 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.
(c) Vision test requirements of IWA-2321,1995 Edition.
The abstract of SNT-TC-1 A states, "This standard applies to personnel whose specific tasks or jobs require appropriate knowledge of the technical principles underlying nondestructive testing (NDT) methods for which they have responsibilities within the scope of VT-1 and VT-3 examination methods." ' fT-2 requires no special knowledge of technical principles underlying its performance. It is simply the straight forward examination for leakage. No special skills or technical training are required in order to observe water dripping from a component or bubbles forming on a joint wetted with leak detection solution. As such, qualification in accordance with the provisions of the Code Case does not present any reduction in quality and safety.
Code Case N-546 allows those personnel most familiar with the walkdown of plant systems, such as licensed and non-licensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel to perform VT-2 examinations without formal qualification and certification. These personnel typically have a sound working knowledge of plant components and piping layouts which l
makes them acceptable candidates for performing VT-2 visual examinations.
When performing system pressure tests in accordance with ASME Section XI,
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Operations personnel walk down the systems to meet the Technical Specification requirements and VT-2 examiners walk down the systems to meet the ASME Section XI requirements. The use of Code Case N-546 will allow the qualification of Operations personnel to perform VT-2 examinatior.s. This will enable the Operators to perform walkdowns which fulfill the requirements of both ASME Section XI and the Technical Specifications. This will result in savings of manpower and exposure at the DAEC.
Approval of this request would be in accordance with 10 CFR 50.55a(a)(3)(i), as compliance with Code Case N-546 will provide an essentially equivalent attemative to the IWA 2300 requirements it would also provide relief from the administrative and financial burdens of certification, which do not provide any compensating increase in the level of quality and safety, i
Licensee's Altemate Examination: (As stated)
As an attemative to existing Section XI requirements, DAEC will adopt the provisions of Code Case N-546. In lieu of certifying VT-2 Examiners to
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comparable levels of SNT-TC-1 A, they will be qualified to the requirements
- specified in Code Case N-546.
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Training and qualification of VT-2 personnel will be documented and the records will be maintained for the life of the plant. To provide for consistent quality VT-2.
visual examinations, the examinations will be performed using standard procedures. An independent review and evaluation of the W-2 visual examination results will be performed and documented on the examination records.
3.0 EVALUATION
The ASME Code,Section XI, IWA-2300, requires that VT-2 Eisual examination personnel be
. qualified to comparable levels of competency as defined in ANSI N45.2.6. The Code also requires that the examination personnel be qualified for near and far distance vision acuity. IES
. Utilities proposes to implement the alternatives provided in Code Case N-546. In addition, DAEC 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 W-2 visual examination.
3.
Vision test requirements of IWA-2321,1995 Edition.
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, 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 and safety.
4.0 CONCLUSION
Based on a review of Code Case N-546, the staff has determined that the alternatives to the Code qualification requirements for examination personnel, in conjunction with the licensee's added provisions, will provide an acceptable level of quality and safety. Therefore, the licensee's request to implement alternatives provided in Code Case N-546 is authorized pursuant to 10 CFR 50.55a(a)(3)(i). Use of Code Case N-546 is authorized for the third 10-
- year interval of the Duane Amold Energy Center for VT-2 visual examination of Class 1,2, and 4
- - 3 components of the ASME Code Section XI, until such time as the Code Case is approved by reference in Regulatory Guide 1.147. At that time, if the licensee intends to continue to-implement this Code Case, the licensee is to follow all provisions in Code Case N-546 with any limitations issued in Regulatory Guide 1.147.
Principal Contributor: P. Patnaik Date: April 1, 1998 I
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