ML20248M009
| ML20248M009 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/09/1998 |
| From: | Rainsberry J SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9806120226 | |
| Download: ML20248M009 (5) | |
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a_ LJ I J 5.1 Marager. Plant Licensing An LDISOV IN7LRA 4710A,41" Company June 9, 1998 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D. C. 20555
Subject:
Docket Nos. 50-361 and 50-362 Second Ten-Year Interval Inservice Inspection Program 1
San Onofre Nuclear Generating Station Units 2 and 3 l
Reference:
Letter from J. L. Rainsberry (SCE) to the Document Control Desk (NRC), dated November 13, 1996;
Subject:
Docket Nos. 50-361 and 50-362, Second Ten-Year Interval Inservice Inspection Program, San Onofre Nuclear Generating Station Units 2 and 3 Gentlemen:
This letter submits the enclosed revision to Relief Request (RR) A-2-02, for NRC approval. This revision is submitted to address questions from the NRC.
The original RR was submitted by the above reference.
RR A-2-02 requests relief from ASME Section XI Code Requirements as allowed by ASME Code Case N-546.
Code Case N-546 provides alternative certification requirements to ASNT I
Standard SNT-TC-1A for experienced personnel (e.g., licensed and nonlicensed 4
operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel).
The current revision of Regulatory Guide 1.147 does not include Code Case N-546. Therefore, The Southern l
California Edison Company (SCE) is submitting the relief request and requesting approval to use Code Case N-546.
This revision specifies a commitment by SCE to implement a program that documents qualifications, training, and visual acuity of persons selected to perform visual examinations.
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q San Onofre Nuclear Generating Station P. O. Ikn 128 San Clemente, CA 92674-0128 714 % 8-7420
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I Document Control Desk If you have any questions, please call me.
Sincerely,
& a.i.MWy Enclosure cc:
E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 J. W. Clifford, NRC Project Manager, San Onofre Units 2 and 3 i
l
Enclosure I
RELIEF REQUEST A-2-02, Revision 1 INSERVICE INSPECTION PROGRAM SAN ON0FRE UNITS 2 AND 3 c
4
RELIEF REQUEST A-2-02, Revision 1 l
INSERVICE INSPECTION PROGRAM SAN ON0FRE UNITS 2 AND 3 IDENTIFICATION Code Classes:
- 1, 2, and 3
References:
IWA-2300 Examination Categories: VT-2
==
Description:==
Alternate Requirements for Qualification of VT-2 Examination Personnel,Section XI, Division 1 CODE REQUIREMENTS Personnel performing nondestructive examination (NDE) shall be qualified and certified using a written practice prepared in accordance with SNT-TC-1A and the additional requirements of this Division.
BASIS FOR RELIEF By. Code Case N-546, the ASME committee has established alternative qualifications to current industry standards (i.e., ANSI N45.2.6, ASNT
,SNT-TC-1A, or ASNT CP-189) for VT-2 visual examination personnel. The l
. Southern California Edison Company (SCE) will implement a program that 1
documents qualifications, training, and visual acuity of persons selected to perform VT-2 visual examinations and will maintain ~ records that all of the requirements in the Code Case, and specified herein-are met.
This alternative to the requirements (Code Case N-546) alleviates the need to contract certified VT-2 personnel to perform these examinations and' reduces the administrative burden of maintaining a Section XI qualification and certification program of VT-2 examination personnel. The proposed alternative qualifications provide an acceptable level of quality and safety.
l Specifically, the examination personnel will have at least 40-hours of plant walkdown experience, receive a minimum of four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examinations, and l
- will. pass the vision test requirements of IWA-2321, 1995 edition.
i This. alternative to the requirements allows the Station to utilize other i
experienced plant personnel to perform VT-2 Examinations. The Code Case is offering specific relief in the certification process. 'Under the provisions of this Code Case, experienced plant personnel may be qualified as VT-2 examiners and 'the certification program administered in a simpler, routine i
,.. O manner. Ad,ditionally, the Code currently requires eight hours of training administered every three years. The Code Case requires that experienced plant personnel be trained for four hours.
This is a sufficient amount of time to L
train experienced plant personnel in the special aspects of ASME Section XI.
l SCE will meet the requirements contained in Code Case N-546 and will develop and implement formal procedures so that consistent VT-2 visual examinations are performed, and that the evaluation of leakage include an independent review and evaluation of findings by persons other than those that performed j
l the VT-2 exams.
Finally, SCE will document and maintain records to verify
~
that persons selected are qualified.
l PROPOSED ALTERNATE QUALIFICATION As specified in Code Case N-546, personnel shall be qualified in accordance-with the following requirements:
(a)
At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.
)
(b)
At least four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examination.
(c)
Vision test requirements of IWA-2321, 1995 Edition.
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