ML20217K725

Correction to SE of Relief Request MC-R001 Re Qualification Requirements for non-destructive Exam Personnel Performing Containment Insp

ML20217K725
Person / Time
Site:	Duane Arnold
Issue date:	04/16/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217K673	List: ML20217K669 ML20217K725
References
NUDOCS 9805040082
Download: ML20217K725 (1)

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

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DAEC submitted its " Third 10-Year inspection interval Program Plan" for the staff review in April  !

l 1996. The program plan is based on the 1989 Edition of the ASME Section XI requirements for Class 1,2, and 3 components. The 1989 edition of the code requires the use of ASNT-TC-1 A -

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 accordance 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 l procedure for qualifying and certifying the NDE personnel, based on the provisions of SNT-l TC-1 A, provides reasonable assurance of qualified examiners for Class 1,2, and 3 l components, the use of NDE personnel qualified by the procedure for containment augmented l examination will not compromise the quality of the examination. The licensee's proposed l' alternative is to continue to use SNT-TC-1 A for certifying and qualifying the NDE personnel for the current 10-year inspection interval.

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 vision tests and illumination requirements in accordance with IWA-2321 and IWA-2322.

Considering these factors, the staff concludes that the attemative provides reasonable i assurance of qualified examiners and that the impocition of the requirement of Subarticle IWA-I 2300 (1992 Edition) for containment inspection will result in hardship without a compensating increase in the level of quality and safety.

l 4. QQNCLUSION i

Based on the review of the information provided in the relief request and the response to the staff's request for additional information, the staff finds that the attemative proposed by the licensee in lieu of the code requirement endorsed by the regulation will provide qualified j examiners and the imposition of the code requirement would result in hardship without a l compensating increase in the level of quality and safety. Accordingly, the request for relief I 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 i

Date: April 16 1998 (as corrected by letter dated April 23,1998) i 9905040082 980423 PDR ADOCK 05000331 p PDR