ML20217H899
| ML20217H899 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/18/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217H897 | List: |
| References | |
| NUDOCS 9910220226 | |
| Download: ML20217H899 (27) | |
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UNITED STATES ye g
j NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 2006H001 p
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OF THE THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PLAN REQUESTS FOR RELIEF DUANE ARNOLD ENERGY CENTER IES UTILITIES. INC.
DOCKET NO. 50-331
1.0 INTRODUCTION
Inservice inspection (ISI) 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 (B&PV) 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(6)(g)(i). The regulation at 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 alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual 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) shall meet the requiremerits, 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 requiremer,ts 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 vdifications listed therein. For Duane Amold Energy Center, the applicable edition of Section XI of the ASME Code for the third 10-year ISI intervalis the 1989 Edition.
2.0 EVALUATION By letter dated October 30,1998, IES Utilities, Inc. (licensee), submitted nine requests seeking relief from the requirements of the ASME Code,Section XI, for the Duane Amold Energy Center. The licensee provided additional information in its letter dated July 21,1999. The Idaho National Engineering and Environmental Laboratory (INEEL) staff's evaluation of the subject revised request for relief is in Enclosure 2. Based on the results of the review, with the exception of relief request NDE-R034, the staff adopts the contractor's conclusions presented in the enclosed technical letter report (TLR).
9910220226 991018 ENCLOSURE 1 PDR ADOCK 05000331 P
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i The information provided by the licensee in support of the requests for relief from code requirements has been evaluated and the basis for disposition is documented below.
2.1 Reauest for Relief NDE-R001 (Part A) in accordance with 10 CFR 50.55a(g)(6)(li)(A), all licensees must implement once, as part of the ISI interval in effect on September 8,1992, an augmented volumetric examination of the reactor pressure vessel (RPV) welds specified in item B1.10 of Examination Category B-A of the 1989 Edition of the ASME Code,Section XI. Examination Category B-A, items B1.11 and I
B1.12 require volumetric examination of essentially 100% of the RPV circumferential and longitudinal shell welds, as defined by Figures IWB-2500-1 and -2, respectively. Essentially 100%, as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2), is greater than 90% of the examination volume of each weld.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to the code examination requirements for RPV weld VCB B004. The coverage obtained for all RPV welds is listed in the licensee's table in Relief Request NDE-R001.
The staff determined that the augmented coverage requirements cannot be met for shell weld VCB-B004 due to physical restrictions that limit scan coverage. Vessel stabilizers and an insulation support ring limit coverage to 86.91% of the weld metal and heat affected zone. To achieve complete coverage for the subject welds, design rnodifications would be required to increase access to the weld.
The licensee has examined nearly 90% of the subject weld and has examined greater that 90%
of all other RPV shell welds. Based on the cumulative volumetric examination coverage obtained, the staff concludes that the examinations performed provide an acceptable level of quality and safety. Therefore, the licensee's proposed alternative to the augmented RPV shell weld examination is authorized pursuant to 10 CFR 50.55a(a)(3)(i) and 10 CFR 50.55a(g)(6)(ii)(A).
2.2 Reauest for Relief NDE-R001 (Part B)
ASME Code,Section XI, Examination Category B-A, items B1.11, B1.12, B1.21, B1.22, B1.30, B1.40 and B1.51, require 100% volumetric examination of RPV welds, as defined by Figures IWB-2500-1, -2, -3, and -4. Item 01.40 requires essentially 100% surface and volumetric examination of RPV head-to-flange welds, as defined by Figures IWB-2500-1 and -2.
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Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to the Code 1
examination requirements for RPV welds VCB-B004, HMA-B002, VCB-C005 and HCC-C001.
The coverage obtained for all RPV welds is listed in the licensee's table in Relief Request NDE-R001.
The staff determined that the code-required essentially 100% volumetric examinations are Impractical due to scanning limitations associated with stabilizers brackets, the vessel support i
skirt, and weld configurations. To meet the code requirements, the RPV heads would have to be redesigned and modified and imposition of this ret,Jirement would be a significant burden on the licensee.
The licensee obtained significant coverage (>80%) on all welds except the shell-to-flange weld and head-to-flange welds, which received 42.7% and 36.8% volumetric coverage, respectively.
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., l In addition, the head-to-flange weld received a complete surface examination. The staff concludes that the limited volumetric examinations, in conjunction with the complete volumetric examination of other shell and head welds, and complete surface examination of the head to-l flange weld provides reasonable assurance of continued structuralintegrity of the subject L
i welds." Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for RPV welds VCB-B004, HMA-B002, VCB-C005 and HCC-C001c The staff has determined this relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
-2.3 Reauest for Rehef NDE-R027 ASME Code,Section XI, Examination Category B-G-1, item B6.40, requires 100% volumetric examination, as defined by Figure IWB-2500-12, for the threads in the RPV flange.
Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining the threads
. in the RPV flange to the extent required by the code.
The staff has determined that access to the 1-inch annular surface area surrounding the flange threads is limited by the raised sealing surface and the O-ring groove on the flange. The volumetric examination is impractical to perform to the extent required by the code. To increase examination covelage, the RPV flange would have to be redesigned and modified, creating a burden on the licensee.-
The staff concludes that the licensee's examination of 77.1% of the required volume provides reasonable assurance of structural integrity of the RPV flange area. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i). The staff has determined this relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
2.4' Request for Reliof NDE-R028
' ASME Code,Section XI, Examination Category B-D, item B3.90, requires 100% volumetric examination, as defined by Figure IWB-2500-7, for all RPV nozzle to-vessel welds.
Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from volumetrically examining,'to the extent required by the code, the nozzle-to-vessel welds listed in the licensee's
- table in Relief Request NDE-R028.
i The staff determined that access from the nozzle side is restricted by nozzle curvature and the
. code coverage requirement is impractical due to the nozzle design. To meet the code examination requirements, design modifications would be necessary to provide access for examination.- Imposition of the code requirements would result in a considerable burden on the licensee.
The staff concludes that the licensee's examinations of 50% of each of the subject nozzle-to-l Vessel welds, in conjunction with other nozzle-to-vessel weld examinations, provide reasonable assurance of structuralintegrity of the subject welds. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i). The staff has determined this relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public 1
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interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
2.5 Reaucst for Relief NDE-R0_29 ASME Code,Section XI, Examination Category B-J, item B9.11, requires 100% surface and volumetric examination, as defined by Figure IWB-2500-8, for Class 1 circumferential piping welds NPS 4 or larger.
Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from volumetrically examining the reactor water cleanup system Weld CUA-J010 to the extent required by the code.
The NRC staff determined that the reactor water cleanup system weld CUA-J010 has an elbow-to-valve configuration that limits the ultrasonic (UT) examination to one-sided coverage and the code-required examination is impractical to perform. The water cleanup system would have to be redesigned end modified and would be a burden on the licensee.
The weld examined resulted in approximately 60% examination coverage. In addition, the subject weld receives the code-required 100% surface examination each interval, and VT-2 visual examination in conjunction with the applicable system pressure test. The NRC staff concludes that the limited volumetric examination, the complete surface examination, and VT-2 visual examination of this valve-to-elbow weld provides reasonable assurance of structural integrity of the reactor water cleanup system. Therefore, relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for weld CUA-J010. The staff has determined this relief is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
2.6 Reauest for Relief No. NDE-R030 ASME Code,Section XI, Examination Category B-J, item B9.11, requires 100% surface and volumetric examination, as defined by Figure IWB-2500-8, for Class 1 circumferential piping welds NPS 4 or larger.
Pursuant to 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from volumetrically examining, to the extent required by the code, residual heat removal system weld RHC-J025.
The NRC staff determined that the residual heat removal system weld RHC-J025 has a valve-to-penetration configuration that limits the UT examination coverage and examination to the extent required by the code is impractical. To complete the code-required examination using UT, the system would have to be redesigned and modified. Imposition of this requirement would create a considerable burden on the licensee.
The licensee obtained approximately 68% examination coverage and the subject weld receives the code-required 100% surface examination each interval. The weld also receives a VT-2 visual examination in conjunction with the applicable system pressure test. The NRC staff concludes that the limited volumetric examination, the complete surface examination, and VT-2 visual examination of this valve-to-penetration weld provides reasonable assurance of the continued structuralintegrity of the residual heat removal system. Therefore relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for weld RHC-J025. The staff has determined this relief is
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,g 5-authorized by law and will not endanger life or property cr the common defense and security
- and is otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
2.7 Reauest for Relief No. NDE-R032
? ASME Code,Section XI, paragraph IWA-4400(E) requires that all welding shall be performed in L accordance with welding procedure specifications that have been qualified by the owner or repair organization in accordance with the requirements of the codes specified in the' repair program in accordance with IWA-4120.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee has proposed to use Code Case N-573, Transfer of Procedure Qualification Records Between Owners.
Code Case N-573 allows the use of a welding or brazing procedure qualification record (POR) qualified by one owner to be used by another owner for the development of the Welding Procedure Specifications.
The NRC staff determined that qualification of a welding or brazing procedure may be
' pedormed by any owner provioed the applicable requirements for procedure qualification art maintained. The NRC staff also determined that owners may use procedures qualified by other owners provided the conditions / requirements listed in Code Case N-573 are met. The licensee has committed to comply with requirements specified in Code Case N 573.
The NRC staff concludes that the licensee's proposed alternative to use Code Case N-573 provides an acceptable level of quality and safety. The licensee's proposed alternative to use Code Case N-573 is authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the current interval.
2.8 Reauest for Relief No. NDE-R034 ASME Code,Section XI, Examination Categories B-J and C-F-2, items 89.1 i ed C5.51 i
require 100% volumetric examination of Class 1 and 2 austenitic and ferritic presswe-retaining piping welds. lWA-2232 requires that the owner shall perform ultrasonic examinatione in accordance with Appendix 1. Appendix l states that the ultrasonic examination of all pipng welds shall be conducted in accordance with Appendix ill, as supplemented by Appendic l.
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Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the Performance i
Demonstration initiative (PDl) program for the qualification of its ultrasonic examination systems for austenitic and ferritic piping welds.
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i The NRC staff has issued a position on the use of PDI in the final rule presented in Volume 64, No.183, pages 51370 51400 of the Federa/ Registerissued September 22,1999, which states
~ that the licensee is permitted to implement either Appendix Vill, " Performance Demonstration for Ultrasonic Examinations Systems," to Section XI, Division 1,1995 Edition with the 1996 i
Addenda, or Appendix Vill as executed by PDI. Because PDI is not a consensus standards body, its program document cannot be referenced in the final rule. Thus, the PDI requirements am directly contained in the final rule in 50.55a(b)(2)(xv). Therefore, the licensee may choose o
to use Appendix Vill as referenced in the rule without requesting an altamative to the code.
Since tra subject of request for relief NDE-R034 is already addressed by the rule, this request is unnecessary.
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The NRC staff also notes that the qualification for personnel performing intenmular stress-
. corrosion cracking examinations, including requalification of examiners, is still governed by the agreement between the Electric Power Research Institute (EPRI), the Boiling Water Reactor Owners Broups (BWROG), and the NRC as stated, in part, in NRC's letter to K. P. Donovan (BWROG) dated March 1,1996.
2.9 Reauest for Relief No. NDE-R035
- ASME Code,Section XI, Table IWX-2412-1 requires that a certain percentage of examinations be performed within each inspection period.
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee requests to use Code Case N 598 as an alternative to the requirements of Table IWX-2412-1, paragraphs IWB-2412, IWC-2412, and IWD-2412 and Tables IWB-2412-1 and IWC-2412-1.
The code case and the code both require the same minimum percentage of examinations be completed each inspection period, but the code case allows a greater maximum percentage of examinations in the first and second periods. This allows more examinations to be performed
- early in the interval.
The use of this code case will establish a new sequence of component examinations. The licensee committed to repeating the newly established sequence of component examinations during successive inspection intervals.- Code Case N-598 allows the licensee to perform examinations earlier in the interval; 10 years will not be exceeded between component examinations. Therefore, the licensee's proposed attemative to use Code Case N 598 provides an acceptable fevel of quality and safety. The use of Code Case N-598 is authorized i
pursuant to 10 CFR 50.55a(a)(3)(i) for the current interval.
9 2.10 Reauest for Relief No. NDE-R036 ASME Code,Section XI, IWA-2313, Certification and Recettification requires that Level I and Level 11 personnel be recertified by qualification examination every 3 years.
I Pursuant'to 10 CFR 50.55a(a)(3)(i), IES Utilities requests authorization to use Code Case l-N-574 as an alternative to the requirements of IWA-2313. The licensee will use the L
recertification frequency delineated in Code Case N-574 in lieu of the requirements of 3
IWA 2313. Both Level I and Level ll personnel will be recertified by qualification examination -
every 5 years.
Based on the data reviewed in conjunction with the NRC staff's recent rulemaking requiring UT j
performance demonstration, the NRC staff noted that proficiency decreased over time. The NRC staff concludes that the proposed alternative, to use a 5-year recertification frequency for Level I and Level li personnel, is not supported by information avrilable to the NRC staff.
Therefore, the licensee's proposed attemative is denied.
3.0 CONCLUSION
The NRC staff concludes that for relief requests NDE-R001 (Part B), NDE-R027, NDE-R028, NDE-R029, and NDE-R030, the examinations are impractical to perform to the extent required by the code, and the licensee's proposed alternatives provide reasonable assurance of structural integrity of the subject welds. Relief is granted pursuant to 10 CFR 50.55a(g)(6)(i) for i
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-7, relief requests NDE-R001 (Part B), NDE-R027, NDE-R028, NDE-R029, and NDE-R030. These reliefs are authorized by law and will not endanger life or 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 on the facility.
l For relief request NDE-R001 (Part A), the licensee's proposed alternative to the augmented RPV shell weld examination provides an acceptable level of quality and safety and is authorized
- pursuant to 10 CFR 50.55a(a)(3)(l) and 10 CFR 50.55a(g)(6)(ii)(A).
For relisf requests MDE-R032 and NDE-R035, the licensee's proposed alternatives provide an acceptable level of quality and safety and are authorized pursuant to 10 CFR 50.55a(a)(3)(i).
Relief request NDE-R034 is unnecessary in light of a recently issued revision to 10 CFR 50.55a.
For relief request NDE-R-036, the NRC staff believes that increasing the interval between recertification is not technically supported. Therefore, the use of Code Case N-574 is denied.
Principal Contributor: T. McLellan Date:
October 18, 1999 l
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TECHNICAL LETTER REPORT ON THIRD 10-YEAR INTERVAL INSERVICE INGPECTION REQUESTS FOR RELIEF EQB IES UTILITIES. INC.
DUANE ARNOLD ENERGY CENTER DOCKET NUMBER: 50-331 1.
INTRODUCTION By letter dated October 30,1998, the licensee, IES Utilities, Inc., submitted nine (9) relief requests, seeking relief from the requirements of the ASME Code,Section XI, for the Duane Arnold Energy Center, third 10-year inservice inspection (ISI) interval. By i
letter dated July 21,1999, the licensee submitted a response to the NRC's request for additionalinformation. The Idaho National Engineering and Environmental Laboratory (INEEL) staff's evaluation of the subject requests for relief is in the following section.
2.
EVALUATION The information provided by lES Utilities, Inc. in support of the requests for relief from Code requirements has been evaluated and the bases for disposition are documented below. The Code of record for the Duane Arnold Energy Center, third 10-year ISI interval, which began November 1,1996, is the 1989 Edition of Section XI of the ASME Boiler and Pressure Vessel Code.
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2.1 Reauest for Relief NDE-R001 (Part A). Alternative to 10 CFR 50.55a(a)(6)(ii)(A).
Auamented Reactor Pressure Vessel (RPV) Examinations Reaulatorv Reauirement: In accordance with 10 CFR 50.55a(g)(6)(ii)(A), all licensees must idipigment mee, as part of the inservice inspection interval in effect on Sepboer 8,1912, an augmented volumetric examination of the RPV welds specified in item B1.10 of Examination Category B-A of the 1989 Edition of the ASME Code, 4
Section XI. Examination Category B-A, items B1.11 and B1.12 require volumetric examination of essentially 100% of the RPV circumferential and longitudinal shell welds, as defined by Figures IWB-2500-1 and -2, respectively. Essentially 100%, as defined by 10 CFR 50.55a(g)(6)(ii)(A)(2),is greater than 90% of the examination volume of each wald.
Licensee's Procosed Alternative Examination: In accordance with 10 CFR 50.55a(a)(3)(ii), the licenseo proposed an alternative to the Code examination requirements for RPV Weld VCB-B004. The coverage obtained for all RPV welds is listed in Table NDE-R001. The licensee stated:
" Pursuant to 10 CFR 50.55a(a)(3)(ii), the DAEC proposes to examine, once during the ten year interval, the applicable pressure retaining reactor vessel welds to the extent practical within the limitations of the examination technique or design of the component.... The inaccessible portions of the reactor vessel welds will continue ENCLOSURE 2
4 I to be subject to the applicable system pressure test requirements of IWA and IWB-5000 with a VT 2 visual examination."
TABLE NDE-R001 ftem No.
Weld Description Weld ID Coverage Comments i
VCB-B1 96.5 %
VCB-A2 96.7 %
B1.11 Circumferential i
VCB-B3 96.7 %
C8.' 1%
VCB-B4 9
VLA A {1 96.6 %
VLA-A002 96.7 %
VLB-A001 95.4 %
VLB-A002 95.8 %
B1.12 Longitudinal VLC-B001 93.8 %
VLC-B002 93.4 %
1 VLD B001 96.7 %
VLD-B002 96.7 %
B1.21 Circumferential HCA-B001 100 %
Bottom Head B1.22 Meridiona! Bottom HMA-B002 nn 1%
Head B1.30 Shell-to-flange VCB-C005
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One Side B1.40 Head-to-flange HCC-C001 J6.8%
One Side (VLA-A002) 96.9 %
Right Side B1.51 Repr,'53eltline) 118 R1 31"x 38" area Y=119" to 150" Licensee's Basis for Proposed Altemative (as stated):
"The DAEC plant design was completed and a license to operate was requested in 1971. The rea: tor vessel was designed and installed to ASME Section lil,1965 Edition,1967 Addenda. The parameters for accessibility for Inservice Inspection were not requirements at that time and therefore, not necessarily factored into component and system configurations, thereby creating conditions where ASME Section XI Code required examination coverage of reactor vessel welds cannot be obtained.
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-3 "During refueling outage (RFO) 14, the DAEC performed the augmented weld examination of the reactor vessel using the General Electric GERIS 2000 ultrasonic examination system.~ The extent of examination coverage is outlined in the following [above] table......
"VCB-8004 "This is the Course 3 to Course 4 circumferential weld. The vessel stabilizers and an insulabon support ring are located at the location and limit the examination to -
approximately 86.91%. The insulation support ring is located 18" from the weld.
The bottom of the stabilizer brackets would require removal. Removing the vessel stabilizers is not a feasible option."
Evaluation: To comply with the augmented reactor vessel examination requirements of 10 CFR 50.55a(g)(6)(ii)(A), licensees must volumetrically examine essentially 100% of each of the item B1.10 shell welds. In accordance with the regulations, essentially 100% is defined as greater than 90% of the exaniination volume of each weld.
At DAEC, the augmented coverage requirements cannot be met for shell WeM VCB-B004 due to physical restrictions that limit scan coverage. Vessel stabilizers and an insulation support ring limit coverage to 86.91% of the weld metal and heat affected zone. To achieve complete coverage for the subject welds, design modifications would be required to increase access to the weld.
The licensee has examined nearly 90% of the subject weld and has examined greater that 90% of all other RPV shell welds. Based on the cumulative volumetric examination coverage obtained, the INEEL staff concludes that any significant patterns of degradation, if present, would have been detected and that the examinations performed provide an acceptable level of quality and safety. Therefore, it is recommended that the licensee's proposed alternative to the augmented RPV shell weld examination be authorized pursuant to 10 CFR 50.55a(g)(6)(ii)(A).
2.2 Reauest for Relief NDE-R001 (Part B). Examination Cateaorv B-A. Items B1.11. B1.12.
312'. B1.22. B1.30. B1.40 and B1.51. Reactor Pressure Vessel (RPV) Welds Code Reauirement: Examination Category B-A, items B1.11, B1.12, B1.21, B1.22, j
B1.30, B1.40 and B1.51, require 100% volumetric examination of RPV welds, as defined by Figures IWB 2500-1, -2, -3, and,4. Item B1.40 requires 100% surface and volumetric examination of RPV head-to-flange welds, as defined by Figures IWB-2500-1 and 2.
- Licensee's Proposed Alternative Examination: In accordance with 10 CFR 50.55a(a)(3)(ii), the licensee proposed an alternative to the Code examination requirements for RPV Welds VCB-B004, HMA-B002, VCB-C005 and HCC-C001. The
- coverage obtained for all RPV welds is listed in Table NDE-R001. The licensee stated:
" Pursuant to 10 CFR 50.55a(a)(3)(ii), the DAEC proposes to examine, once during the ten year interval, the applicable pressure retaining reactor vessel welds to the extent practical within the limitations of the examination technique or design of the component.... The inaccessible portions of the reacto vessel welds will continue to be subject to the applicable system pressure test requirements of IWA and IWB-5000 with a VT-2 visual examination."
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, TABLE NDE-R001 l
item No.
Weld Description WeldID Coverage Comments VCB-B1 96.5 %
VCB-A2 96.7 %
B1.11 Circumferential VCB-B3 96.7 %
VCB-B4 86.91 %
VLA-A001 96.6 %
VLA-A002 96.7 %
VLB-A001 95.4 %
VLB-A002 95.8 %
B1.12 Longitudinal VLC-B001 93.8 %
VLC-B002 93.4 %
VLD-B001 96.7 %
VLD-B002 96.7 %
B1.21 Circumferential HCA-B001 100 %
Bottom Head B1.22 Meridional Bottom HMA-8002 80.3 %
Head B1.30 -
Shell-to-flange VCB-C005 42.7 %
One Side B1.40 Head-to-flange HCC-C001 36.8 %
One Side (VLA-A002) 96.9 %
Right Side B1.51 Repair (Beltline) 118 R1 31"x 38' area Y=119" to 150" Licensee's Basis for Proposed Alternative (as stated):
"The DAEC plant design was completed and a license to operate was requested in 1971. The reactor vessel was designed and installed to ASME Section lil,1965 Edition,1967 Addenda. The parameters for accessibility for Inservice inspection were not requirements at that time and therefore, not necessarily factored into component and system configurations, thereby creating conditions where ASME Section XI Code required examination coverage of reactor vessel v 1s cannot be obtained.
"During refueling outage (RFO) 14, the DAEC performed the augmented weld examination of the reactor vessel using the General Electric GERIS 2000 ultrasonic
- examination system. The extent of examination coverage is outlined in the i
following [above) table. The amount of coverage which will be obtainabis when the
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third ten-year interval examinations are performed is based on the percentages obtained during RFO 14. Relief is therefore requested for the third ten-year interval for the four welds for which less than 90% coverage will be obtainable - VCB B004, HMA-B002, VCB-C005 and HCC-C001.
"VCB-B004 "This is the Course 3 to Course 4 circumferential weld. The vessel stabilizers and an insulation support ring are located at the location and limit the examination to approximately 86.91% The insulation support ring is located 18" from the weld.
The bottom of the stabilizer brackets would require removal. Removing the vessel stabilizers is not a feasible option."
"HMA-8002 "This weld is located at the vessel skirt. There is a portion of the weld above and below the vessel skirt. Therefore the vessel skirt limits the examination coverage to approximately 80.3% in order to perform the additional 19.7% of the weld, the vessel skirt would require removal and then reinstallation. This is not a feasible option."
"VCB-C005 "This is the Vessel-to-Flange weld. This weld is examined from the flange surface and the vessel wall. The examination is limited to approximately 42.7% due to the configuration of the weld. There is no feasible option in order to examine the additional 57.3%
"HCC-C001 "This is the Head to flange weld. This weld is examined from the head surface.
the examination is limited to approximately 36.8% due to the configuration of the weld. There is no feasible option in order to examine the additional 63.2%"
Evaluation: The Code requires 100% volumetric examination of all RPV welds each inspection interval. The licensee i as requested relief from the Code required 100%
volumetric examination due to scanning limitations associated with stabilizers brackets, the vessel support skirt, cnd weld ccnfigurations. These restrictions make volumetric examination, to the extent required by the Code, impractical. To meet the Code requirements, the RPV heads would have to be redesigned and modified. Imposition of this requirement would result in a burden on the licensee.
The licensee examined the subject welds to the extent practical and obtained significant coverage (>80%) on all welds except the shell-to-flange weld and head-to-flange welds, which received 42.7% and 36.8% volumetric coverage, respectively. In addition, the head-to-flange weld received a complete surface examination. The limited volumetric examinations, in conjunction with the complete volumetric examination of other shell and head welds, and complete surface examination of the head-to-flange weld provide reasonable assurance of the continued structuralintegrity of the RPV. Therefore, it is
n recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i) for RPV Welds VCB-B004, HMA-B002, VCB-C005 and HCC-C001.
2.3 Reauest for Relief NDE-R027. Examination Cateaorv B-G-1. Item B6.40. Threads in Reactor Pressure Vessel (RPV) Flanae Code Reauirement: Examination Category B-G-1, item B6.40, requires 100% volumetric examination, as defined by Figure IWB 2500-12, for the threads in the RPV flange.
Licensee's Code ReIief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from examining the threads in the RPV flange to the extent required by the Code.
Licensee's Basis for Proposed Alternative (as stated):
"The 1 inch annular area required by IWB-2500-12 to be examined encompasses the flange sealing sudace area. This ligament examination is limited due to the proximity of the flange sealing surface. A total of approximately 77.1% of the examinction volume can be achieved. The sealing surface does not allow examination of a 4 inch and 4.3 inch area on both sides of the stud which interfaces with the sealing sudace. This is due to the flange configuration and the O-ring groove. In accordance with 10 CFR 50.55a(g)(6)(i), relief requests may be granted when the examination requirements are shown to be impractical."
Licensee's Proposed Alternative (as stated):
"The DAEC proposes to perform examination of 77.1% of the flange ligament once every ten year period."
s Evaluation: The Code requires that the closure head thread area of the RPV flange ligament be volumetric examined. However, access to the 1 inch annular sudace area surrounding the flange threads is limited by the raised sealing surface and the O-ring groove on the flange. The volumetric examination is, therefore, impractical to pedorm to the extent required by the Code. To increase examination coverage, the RPV flange would have to be redesigned and modified, creating a burden on the licensee.
The licensee has examined a significant portion (77.1%) of the required volume. This examination provides reasonable assurance that any patterns of degradation, if present, would be detected and the inservice structural integrity of the RPV flange area is maintained. Therefore, based on the impracticality of complying with the Code requirements and the burden on the licensee if the Code requirements were imposed, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
2.4 Reauest for Relief NDE-R028. Examination Cateaorv C-D. Item B3.90. Reactor Pressure Vessel (RPV) Nozzle-to-Vessel Welds Code Reauirement:. Examination Category B-D, Item B3.90, requires 100% volumetric examination, as defined by Figure IWB-2500-7, for all RPV nozzle-to-vessel welds.
Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from volumetrically examining, to the extent required by the Code, the nozzle-to-vessel welds listed in Table NDE-R028 below.
I
l Table NDE-R028 l.
Nozzle ID Coverage Remarks l
CRA D001 61.3 %
Control Rod Drive CSB-D001 66 %
Core Spray FWA-D001 56.5 %
Feedwater HVA-D001 -
66 %
Head Vent JPA-D001 61.1 %
Jet Pump MSA-D001 59.6 %
Main Steam RHA-D001 65.7 %
Head Spray RRD-D001 51.4 %
Recirculation inlet RRE-D001 64 %
Recirculation Inlet RRH-D001 64 %
Recirculation inlet VIE-D001 66 %
Vesse! Instrumentation l
Licensee's Basis for Proposed Alternative (as stated):
"Due to the design of these welds it is not feasible to effectively perform a volumetric examination of 100% of the volume as described in IWB-2500-7(b). The nozzle-to-vessel welds are accessible from the vessel side, but examination cannot be performed from the nozzle side because of the forging curvature. In addition to component configuration certain nozzle to vessel weld examinations are further limited by reactor pressure vessel (RPV) design obstructions (such as RPV appurtenances). In accordance with 10 CFR 50.55a(g)(6)(i) relief requests may be granted when the examination requirements are shown to be impractical."
Licensee's Prooosed Alternative (as stated):
"The DAEC proposes to perform volumetric examination from the vessel side of the nozzle-to-vessel welds identified in the " List of Nozzle-to-Vessel Welds." Beceuse of the design of these welds, there are no alternative examination techniques currently available to increase the examination volume."
Evaluation: The Code requires 100% volumetric examination of the RPV nozzle-to-vessel welds. However, access from the nozzle side is restricted by nozzle curvature (see Figure IWB-2500-7(b)). Therefore, the Code coverage requirement is impractical due to the nozzle design. To meet the Code examination requirements, design modifications would be necessary to provide access for examination. Imposition of the Code requirements would result in a considerable burden on the licensee.
The licensee can examine in excess of 50% cf each of the subject nozzle to-vessel I
welds. A partial examination of these welds, in conjunction with other nozzle to-vessel I
weld examinations, should detect any existing patterns of degradation and provide reasonable assurance of their structural integrity. Therefore, it is recommended that
)
relief be granted pursuant to 10 CFR 50.55a(g)(6)(i).
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2.5 ReLuest for Relief NDE-R029. Examination Cateaorv B-J. Item B9.11. Class 1 Reactor Water Cleanuo System Pioina Welds l
Code Reauirement: Examination Category B-J, item B9.11, requires 100% surface and I
volumetric examinat;un, as defined by Figure IWB-2500-8, for Class 1 circumferential piping welds NPS 4 or larger.
l Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the
' licensee requested relief from volumetrically examining, the reactor water cleanup system Weld CUA-J010 to the extent required by the Code.
Licensee's Basis for Proposed Alternative (as stated):
l "This weld is an elbow to valve weld configuration which limits the volumetric (UT) coverage to a one-sided exam. The weld was examined utilizing a 45" and a supplemental 70* shear wave search unit. This results in approximately 60%
coverage of the weld length, in order to perform radiography of the weld, the Reactor Water Cleanup System would be required to be drained, which would result in an increase in exposure to personnel by a factor of 1.7 (200mr/hr vs.
340mr/hr) for a total of 140mr for the additional 40% coverage. This does not include the operational time in valve line-ups and draining the system or the exposure in other areas of the plant due to the system being drained. The benefit of examining the additional 40% weld length has only a small potential of increasing plant safety margins and a very disproportionate impact on expenditures of plant manpower and radiation exposure."
Licensee's Prooosed Alternative (as stated):
"As an alternative to existing Section XI requirements, DAEC proposes to perform volumetric examination of the 60% weld length. DAEC will examine applicable pressure retaining piping welds to the maximum extent practical within the limitations of the examination technique or design of the component. Should reportable indications be found in the accessible portions of the listed weld, an engineering evaluation will be performed to determine if the inaccessible portion of the weld would be affected.
" Subsequent to examination of the affected weld, NDE data sheets will describe in detail, the extent of the limitation and any alternative examination techniques used to obtain coverage.
"The inaccessible portions of the weld will continue to be subject to the applicable system pressure test requirements of IWA and IWB-5000 with a VT-2 visual examination, as well as Code-required surface examination."
Evaluation: The Code requires 100% volumetric and surface examination of Category B-J, item B9.11 welds. Reactor water cleanup system Weld CUA-J010 has an elbow-to-valve configuration that limits the ultrasonic (UT) examination to one sided coverage.
Therefore, examination to the extent required by the Code is impractical. To examine the Code required volume using UT, the water cleanup system would have to redesigned and modified. Imposition of this requirement would create a considerable burden on the licensee.
i l
The licensee has proposed to use the volumetric examination, performed to the maxo um extent practical, as an alternative to the Code requirement. The weld was L
r examined using both 45* and supplemental 70' shear wave transducers, which resulted in approximately 60% examination coverage, in addition, the subject weld receives the Code-required 100% sudace examination each interval, and VT-2 visual examination in conjunction with the applicable system pressure test. The limited volumetric examination, the complete surface examination, and VT-2 visual examination of this valve-to-elbow weld provide reasonable assurance of the continued structural integrity of the reactor water cleanup system. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i) for Weld CUA-J010.
2.6 Reauest for Relief No. NDE-R030. Examination Cateaorv B-J. Item B9.11. Class 1 Residual Heat Removal System Wald Code Reauirement: Examination Category B-J, item B9.11, requires 100% surface and volumetric examination, as defined by Figure IWB-2500-8, for Class 1 circumferential piping welds NPS 4 or larger.
Licensee's Code Relief Reauest: In accordance with 10 CFR 50.55a(g)(5)(iii), the licensee requested relief from volumetrically examining, to the extent required by the Code, residual heat removal system Weld RHC-J025.
Licensee's Basis for Prooosed Alternative (as stated):
"This weld is a valve to penetration weld configuration which limits the volumetric (UT) coverage. The weld was examined utilizing a 45' shear wave search unit.
This results in approximately 68% coverage of the weld length, in order to perform radiography of the weld, the Residual Heat Removal System would be required to
' be drained, which would result in an increase in exposure to personnel by a factor of 1.7 (30mr/hr vs. 51mr/hr) for a total of 21mr for the additional 32% coverage.
This does not include the operational time in valve line-ups and draining the system or the exposure in other areas of the plant due to the system being drained. The benefit of examining the additional 32% weld length has only a small potential of increasing plant safety margins and a very disproportionate impact on expenditures of plant manpower and radiation exposure."
Licensee's Prooosed Alternative (as stated):
"As an attemative to existing Section XI requirements, the DAEC proposes to pedorm volumetric examination of approximately 68% of the weld length. The DAEC will examine applicable pressure retaining piping wegis to the maximum extent practical with.in the limitations of the examination technique or design of the component. Should reportable indications be found in the accessible portions of the listed weld, an engineering evaluation will be performed to determine if the inaccessible portion of the weld would be affected.
" Subsequent to examination of the affected weld, NDE data sheets will describe in detail, the extent of the limitation and any alternative examination techniques used to obtain coverage.
"The inaccessible portions of the weld will continue to be subject to the applicable system pressure test requirements of IWA and IWB-5000 with a VT 2 visual examination, as well as a Code-required surface examination."
Evaluation: The Code requires 100% volumetric and surface examination of Category B-J, item B9.11 welds. Residual heat removal system Weld RHC-J025 has~a valve-to-L:
e~ penetration configuration that limits the ultrasonic (UT) examination coverage.
Examination, to the extent required by the Code, is impractical. To complete the Code-required examination using UT, the system would have to redesigned and modified.
Imposition of this requirement would create a considerable burden on the licensee.
The licensee has proposed to use the volumetric examination, performed to the maximum extent practical, as an attemative to the Code requirement. The weld was examined using a 45' shear wave transducer, which resulted in approximately 68%
examination coverage. In addition, the subject weld receives the Code-required 100%
surface examination each interval,' and VT-2 visual examination in conjunction with the applicable system pressure test. Consequently, the limited volumetric examination, the complete surface examination, and VT-2 visual examination of this valve-to-penetration weld provide reasonable assurance of the continued structuralintegrity of the residual heat removal system. Therefore, it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i) for Weld RHC-J025.
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- 2.7 Reauest for Relief No. NDE-R032. Use of Code Case N-573. Transfer of Procedure Qualification Records Between Owners Code Reauirement: IWA-4400(a) requires that all welding shall be performed in accordance with Welding Procedure Specifications that have been qualified by the Owner or repair organization in accordance with the requirements of the codes specified in the Repair Program in accordance with IWA-4120.
Licensee's ProDosed Alternative: In accordance with 10 CFR 50.55a(a)(3)(i), the licensee has proposed to use Code Case N-573, Transfer of Procedure Qualification Records Between Owners. The licensee stated:
"The DAEC will use Code Case N-573 to allow the use of other Owner's PORs.
Steps to be taken by the DAEC to ensure the technical corrections of other Owner's PORs and to ensure the resulting Welding Procedure Specifications i
(WPSs) produce sound welds are as follows.
"The DAEC will perform a technical review of the supplying Owner's POR. The supplying Owner will state in writing that the POR was performed under an approved Nuclear Quality Assurance program that meets ASME Section XI, IWA-1400 and that it was performed in accordance with ASME,Section IX.
"The DAEC will generate a WPS using the variables established in the supplied PORs. DAEC PORs may supplement the other Owner's supplied POR's. All essential variables of the most re' cent ASME,Section XI, shall be addressed in the generated WPS.
"The generated WPS will be reviewed and approved in accordance with DAEC's Quality Assurance Program.
"The generated WPS will be demonstrated successfully by DAEC by successfully passing a performance qualification test in accordance with ASME,Section XI.
"DAEC will not transfer the supplied POR to any other Owner.
"NYPA will document the use of Code Case N-573 on the appropriate NIS 2 form."
Licensee's Basis for Prooosed Alternative (as stated):
" Pursuant to 10 CFR 50.55a(a)(3)(ii), relief is requested from the requirements for welding and brazing procedure qualifications as stated in ASME,Section XI, iWA-4000. This request also includes relief for all Procedure Qualification Records (PORs) supporting alternative repair procedures in accordance with ASME,Section XI, IWA-4500 and balance of plant welding.
"The Duane Arnold Energy Center (DAEC) requests to utilize ASME Code Case N-573 as an alternative method to qualify welding procedures. Code Case N $73 extends the logic already found in construction code USAS B31.1,1967 edition with 1969 addenda, paragraphs 127.4.1 and 127.5.
" Maintaining the original requirement presents an undue hardship, as considerable utility specific resources would be duplicated when qualified procedures from other
I' i
~
-12 NRC licensed facilities have already been demonstrated to provide an acceptable
- level of quality and safety. The requested alternative will not reduce safety or j
quality."
l Evaluation: lWA-4400(a) requires that all welding shall be performed in accordance with
)
Welding Procedure Specificatiore. (WPS) that have been qualified by the owner or repair organization in accordance with the requirements of the codes specified in the Repair Program of IWA-4120. The licensee has proposed to use Code Case N-573, Transfer of Procedure Qualification Records Between Owners. This Code Case essentially allows the use of a welding or brazing procedure qualification record (POR) qualified by one owner to be used by another owner for the development of the WPS.
The specific requirements listed in Code Case N-573 shall be met by the owner that performed the procedure qualification, and by the owner intending to use the POR.
These requirements are:
(a)
The owner that performed the procedure qualification test shall certify, by signing the POR, that testing was performed in accordance with Section IX.
j (b)
The owner that performed the procedure qualification test shall certify, in writing, that the procedure qualification was conducted in accordance with a Quality Assurance Program that satisfies the requirements of IWA-1400.
(c)
The owner accepting the completed POR shall accept responsibility for obtaining any additional supporting information needed for WPS development.
-(d)-
The owner accepting the completed POR shall document, on each resulting WPS, the parameters applicable to welding. Each WPS shall be supported by all necessary POR's (e)_
The owner accepting the completed POR shall accept responsibility for the POR. Acceptance shall be documented by the owner's approval of each WPS that references the POR.
t' (f).
The owner accepting the completed POR shall demonstrate technical competence in application of the received POR by completing a performance qualification test using the parameters of a resulting WPS.
(g)
The owner may accept and use a POR only when it is received directly
e.. o.
from the owner that certified the POR.
. (h)
Use of this Code Case shall be shown on the NIS-2 form documenting welding or brazing.
The INEEL staff believes that qualification of a welding or brazing procedure may be performed by any owner provided the applicable requirements for procedure qualification are maintained. The INEEL staff also believes that owners may use procedures qualified by other owners provided the conditions / requirements listed in Code Case N-573 are met. The licensee has committed to comply with requirements specified in Code Case N-573. Therefore, the proposed alternative provides an acceptable level of quality and safety and the use of this alternative should be authorized pursuant to 10 CFR 50.55a(a)(3)(i) for the current interval at Duane Arnold Energy Center.
2.8 Eauest for Relief No. NDE-R034. Authorization to Use Performance Demonstration Initiative (PDI) Techniaues for Austenitic and Ferritic Pioina Welds Code Reauirement: Examination Categories B-J and C-F-2, items B9.11 and C5.51 l
require 100% volumetric examination of Class 1 and 2 austenitic and ferritic pressure-l retaining piping welds. IWA-2232 requires that the Owner shall perform ultrasonic l
examinations in accordance with Appendix '. Appendix i states that the ultrasonic examination of all piping welds shall be conducted in accordance with Appendix lli, as supplemented by Appendix 1.
Licensee's Prooosed Alternative: In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed to use the PDI Program for the ultrasonic examination systems used for austenitic and ferritic piping welds.
The licensee stated:
I
' Examination procedures, equipment, and personnel qualified by performance demonstration will be utilized in accordance with the PDI Program for the examination of stainless steel and ferritic piping welds that fall under the above mentioned item numbers."
Licensee's Basis for Proposed Alternative (as stated):
"The PDI program is based on the 1992 Edition with the 1993. Addenda of the 1
ASME Section XI Code. This edition with addenda requires that ultrasonic equipment, procedure, and examiners be qualified on flawed and notched materials j
j
L
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-14 and configurations similar to those found in the actual plant. Hence, the PDI Program provides a higher degree of reliability for detection and characterization of flaws when compared to the conventional amplitude-based ultrasonic techniques required by the 1989 edition of the ASME Section XI Code.
l "The NRC lasued a letter on March 1,1996 discussing the transition from the Intergranular Stress Corro; ion Cracking (IGSCC) Qualification Program to the PDI Program. In this letter, the NRC approved the following actions while the staff proceeded with the rulemaking and the incorporation of the PDI into that rulemaking. The specific items that were approved by the Staff are as follows:
" Effective March 1,1996, IGSCC examiner qualification may be obtained by l
passing the appropriate test of either the PDI Program or the original IGSCC j
program. Examiner qualification for weld overlays will continue as it currently exists L
under the IGSCC Coordination Plan until weld overlay qualification is incorporated l
in the PDI Program. The need to include weld overlay qualification in the PDI j
l Program is considered an outstanding issue...
"BWR IGSCC examiner qualification for detecting and sizing IGSCC in piping and weld overlays is acceptable for up to 5 years from the date of the last qualification examination before March 1,1994. Examiner qualification acquired on or after March 1,1994, is acceptable for 3 years under the IGSCC Coordination Plan and 3 years under the PDI program. Using the PDI program for qualification of BWR j
IGSCC examination personnel is preferred over using the IGSCC Coordination Plan....
"When an examiner obtains IGSCC qualification from the PDI program, subsequent requalification must be performed under the PDI program. To avoid maintenance of dual BWR IGSCC qualification programs, it is intended that the PDI program will eventually replace the IGSCC Coordination Plan and that the IGSCC Coordination Plan will subsequently be dissolved.
"The registry of qualified personnel for ultrasonic examination of IGSCC that is being maintained for the IGSCC Coordination Plan should be expanded to include IGSCC qualified examiners from the PDI program.
" Pursuant to 10 CFR 50.55a(a)(3)(i) the use of the PDI Program for examination procedures, equipment, and personnel qualifications would provide an acceptable altamative to the existing ASME Section XI Code requirements."
Evaluation: Paragraph IWA 2232 of the 1989 Edition of Section XI specifies that the ultrasonic examination shall be conducted in accordance with Appendix 1. Appendix i states that all piping welds shall be conducted in accordance with Appendix Ill. The licensee is proposing to use ultrasonic examination procedures, equipment, and personnel that have been qualified by performance demonstration in accordance with the PDI Program in lieu of the Code requirements.
E
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L..
l The current regulations and the licensee's ISI Program incorporate the 1989 Edition of Section XI for ISI activities. The 1989 Edition includes mandatory Appendix Vil, Qualification of Nondestructive Examination Personnel for Ultrasonic Examination, which specifies requirements for the training and qualification of ultrasonic nondestructive examination (NDE) personnel in preparation for employer certification to perform NDE. The 1989 Addenda to Section XI added mandatory Appendix Vill, Performance Demonstration for Ultrasonic Examination Systems, containing requirements for performance demonstration of ultrasonic testing (UT) procedures, equipment, and personnel used to detect and size flaws. The U.S. nuclear industry created the PDI group to manage implementation of the performance demonstration requirements of Appendix Vill.
The NRC staff has evaluated the PDI Program and,in a letter dated August 5,1997, from J. R. Strc3 alder (NRC) to C. R. Osman (PDl), has found it to be acceptable for demonstrating the effectiveness of ultrasonic examination systems' in accordance with Appendix Vlli. It has been noted that some PDI participants have qualified single-sided weld examination techniques. However, Appendix ill of the Code requires that examinations be performed from two sides of the weid, where practicable. Licensees who are unable to perform volumetric examinations to the extent required by the Code must request for relief, as appropriate. Based on the NRC staff's assessment, it is concluded that the PDI Program, in conjunction with present Code volumetric coverage requirements, will provide an acceptable level of quality and safety and should be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
2.9 Reauest for Relief No. NDE-R035. Use of Code Case N-598. Alternative Reauirements to Reauired Percentaaes of Examinations i
Code Reauirement: ASME,Section XI, Tables IWX-2412-1 require that a certain percentage of examinations be performed within each inspection period, as follows:
L l
Ultrasonic examination systems include procedures. equipment, and personnel.
- e e <
-16,
inspection Period, Calendar Years of Minimum Maximum Service Within the Examinations Examinations inspection interval Interval Completed, %
Credited, %
All 3
16 34 7
50 67 10 100 100 Licensee's Proposed Alternative (as stated):
" Pursuant to 10 CFR 50.55a(a)(3)(i), the DAEC requests authorization to use Code Case N-598 as an alternative to the requirements of Table IW.X-2412-1. The DAEC will use the period percentages delineated in Code Case N-598 in lieu of the period percentages in Tables IWX-2412-1. The percentages in Code Case N-598 are shown below;"
inspection Period, Cale,idar Years of Minimum Maximum Seivice Within the Examinations Examinations inspection Interval Interval Completed, %
Credited, %
All 3
16 50 7
50' 75 10 100 100 11 the first period completion percentage for any examination category exceeds 34%, at least 16% of the required examinations shall be performed in the second period.
Licensee's Basis for Proposed Alternative (as stated):
" Inspection Program B as set up in Tables IWX 2412-1 is very restrictive, weighing the second and third periods more heavily than the first period. Both the second and third periods can have up to a maximum of 50% of the examinations performed, but the first can have only 34% ASME Code Case N-598 provides alternative examination percentages which allow more flexibility in scheduling of examinations to avoid unnecessary expenditure of both manpower and exposure, while ensuring the integrity of the examined components.
"In the 1991 Addenda of ASME Section XI, clarification was made on the scheduling of items when there are less than three items within one category.
IWB-2412(a) states 'If there are less than three items to be examined in an Examination Category, the items may be examined in any two periods, or in any one period if there is only one item, in lieu of the percentage requirements of Table IWB-2412-1.' Similar statements are made in paragraphs IWC 2412 and IWD-2412 of the same addenda. The use of Code Case N-598 is in keeping with these percentages. For example, in the case that there are only two items in a category, the Code Case, as well as the 1991 Addenda allows the examination of these items
17-.
in any two periods, for a 50% examination percentage per period. By the 1989 4
edition, neither item could be examined in the first period without exceeding the 34% maximum percentage.
3 "The use of the Code Case and the change to 50% maximum percentage for the first period does not deviate from that allowed by the 1989 Edition of the Code.
The alternative change in the maximum percentage to 75% for the second period also does not deviate from the Code philosophy because it allows more examinations to be performed in the second period. This is in line with the 1989 Code requirements of a minimum of 50% in the second period. This alternative does not change the Code philosophy of performing a percentage of each category each period, but allows the DAEC more flexibility in conducting the examinations in shorter outages."
Evaluation: Paragraphs IWB-2412, IWC-2412, and IWD-2412 and Tables IWB-2412-1, IWC-2412-1, and IWD 2412-1 require that approximately 1/3 of the Code examinations j
be performed each inspection period with 100% of the examinations completed by the end of the inspection interval. The licensee has proposed to use Code Case N 598, Altemative Requirements to Required Percentages of Examinations, for Class 1,2, and 3 components in lieu of the Code requirement. The Code Case and the Code both require the same minimum percentage of examinations be completed each inspection period, but the Code case allows a greater maximum percentage of examinations in the first and second periods. This allows more examinations to be performed early in the interval.
The use of this Code Case will establish a new sequence of component examinations.
In the response to the NRC's request for additional information, the licensee committed to repeating the newly established sequence of component examinations during successive inspection intervals. Because Code Case N-598 allows the licensee to perform examinations earlier in the interval,10-years will not be exceeded between component examinations. Consequently, the use of Code Case N-598 will provide an acceptable level of quality and safety. Therefore, it is recommended that the use of Code Case N-598 be authorized pursuant to 10 CFR 50.55a(a)(3)(i).
2.10 Reauest for Relief No. NDE-R036. Use of Code Case N-574. NDE Personnel Recertification Freauency Code Reauirement: ASME,Section XI, IWA-2313, Cedification and Recedification
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l
-18.
)
requires that Level I and Level ll personnel be recertified by qualification examination every 3 years.
i Licensee's Proposed Alternative (as stated):
" Pursuant to 10 CFR 50.55a(a)(3)(i), IES Utilities requests authorization to use Code Case N-574 as an alternative to the requirements of IWA-2313. The DAEC will use the recertification frequency delineated in Code Case N-574 in lieu of the requirements of IWA-2313. Both Level I and Level ll personnel will be recertified by qualification examination every 5 years."
Licensee's Basis for Proposed Alternative (as stated):
" Code Case N-574 extends the recertification period for Level I and Level ll personnel to 5 years. The time period between recertification for Level ill personnel is already 5 years, as allowed by IWA 2313 (1989 Edition). Code Case N-574 is included in the ASME Code in the 1997 addenda.
"The DAEC requires each Level I and 11 to annually perform the methods for which they are certified. If the individual does not complete the annual performance, he/she shall be recertified by examination. This is documented and approved under the direction of the Level 111.
"All nondestructive examination personnel will continue to be qualified and certified in accordance with the 1989 Edition of ASME Section XI (including the required tests for each Level) with the exception that the period between recertifications will be extended to 5 years."
Evaluation: The Code requires that Level I and Level li personnel be recertified by qualification examination every 3 years. The licensee is proposing to use Code Case N-574, NDE PersonnelRecertification Frequency, in lieu of the Code requirement. Code Case N-574 allows recertification of Level I and Level ll personnel by qualification examination every 5 years. The 1997 Code Addenda also provides the 5 year recertification frequency.
The licensee may propose to use, an alternative or to obtain relief from the Code requirements; however, the licensee must provide adequate information to support one of the following determinations, as required by 10 CFR 50:
1) 10 CFR 50.55a(a)(3)(i) - the proposed alternative would provide an acceptable level of quality and safety 2) 10 CFR 50.55a(a)(3)(ii) - compliance with the specified requirements of
r,.
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this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety 3) 10 CFR 50.55a(g)(6)(i) - the Commission will evaluate determinations under paragraph (g)(5) of this section that Code requirements are impractical.
The Commission may grant such relief and may impose such attemative
. requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licenses that could result if the requirements were imposed on the facility.
t The licensee has not adequately demonstrated that their proposed alternative should be
. authorized or that relief should be granted in accordance with 10 CFR 50.55a. The licensee should comply with the Code requirements or resubmit this request, identifying the regulatory basis (equivalency, hardship, or impracticality) as stated in 10 CFR 50.55a, and any other needed information to support an adequate review and favorable determination.
The licensee's proposed attemative, to use a 5 year recertification frequency for Level I and Level 11 personnel does not provide an equivalent level of quality and safety to the current 3 year recertification frequency. Therefore, it is recommended that this relief request not be authorized.
CONCLUSION The INEEL staff evaluated the licensee's submittal and concluded that certain inservice examinations cannot be performed to the extent required by the Code at the Duane Amold Energy Center. For Requests for Relief NDE-R001 (Part B), NDE-R027, NDE-R028, NDE-R029, and NDE-R030, the examinetions are impractical to perform to the extent required by the Code and it is recommended that relief be granted pursuant to 10 CFR 50.55a(g)(6)(i). For Request for Relief NDE-R001 (Part A), the licensee's proposed altamative to the augmented RPV shell weld examination will provide an acceptable level of quality and safety and should be authorized pursuant to 10 CFR L.
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l 50.55a(g)(6)(ii)(A). For Requests for Relief NDE-R032, NDE R034, and NDE-R035, the licensee's proposed attematives will provide an acceptable level of quality and safety and should be authorized pursuant to'10 CFR 50,55a(a)(3)(i). For Request for Relief NDE-R-036, the licensee has not described how the proposed altemative will provide an acceptable level of quality and safety; therefore, it is recommended that the use of Code Case N-574 not be authorized.
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