ML23012A083

Response to Request for Additional Information for Alternative I6R-09 to Permit Continued Application of Certain ASME Section XI 2013 Edition Non-Destructive Examination Requirements

ML23012A083
Person / Time
Site:	Quad Cities
Issue date:	01/12/2023
From:	Simpson P Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
RS-23-003
Download: ML23012A083 (1)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office January 12, 2023 10 CFR 50.55a RS-23-003 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Response to Request for Additional Information for Alternative I6R-09 to Permit Continued Application of Certain ASME Section XI 2013 Edition Non-Destructive Examination Requirements

References:

1. Letter from P.R. Simpson (Constellation Energy Generation, LLC (CEG)) to U.S. NRC, "Submittal of Sixth Inservice Inspection Interval Relief Request I6R-09 to Permit Continued Application of Certain ASME Section XI 2013 Edition Non-Destructive Examination Requirements, " dated July 25, 2022 (ADAMS Accession No. ML22206A143)

2. Email from R. Kuntz (U.S. NRC) to R.L. Steinman (CEG),

Subject:

DRAFT Request for Additional Information RE: Quad Cities Alternative I6R-09 (EPID L-2022-LLR-0059), dated December 14, 2022 (ADAMS Accession No. ML22348A045)

In Reference 1, Constellation Energy Generation, LLC (CEG) submitted relief requests associated with the Sixth 10-Year Inservice Inspection (ISI) Program Interval for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. The Sixth Interval ISI Program will comply with the 2017 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code. However, alternative I6R-09 seeks short-term application of certain 2013 Edition non-destructive examination requirements to maintain QCNPS requirements consistent with the remainder of the CEG fleet.

As documented in Reference 2, the NRC found that additional information was required to support its review of Reference 1. The requested information is provided in the attachment.

There are no regulatory commitments included in this letter. CEG continues to seek approval of Reference 1 by March 31, 2023.

U.S. Nuclear Regulatory Commission January 12, 2023 Page 2 Should you have any questions concerning this letter, please contact Ms. Rebecca L. Steinman at 630-657-2831.

Respectfully, Patrick R. Simpson Sr. Manager - Licensing Constellation Energy Generation, LLC

Attachment:

Response to NRC Request for Information cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector - Quad Cities Nuclear Power Station

ATTACHMENT Response to NRC Request for Additional Information REQUEST FOR ADDITIONAL INFORMATION ALTERNATIVE REQUEST I6R-09, REVISION 0, REGARDING CONTINUED APPLICATION OF THE 2013 EDITION OF ASME CODE, SECTION XI FOR NDE ACTIVITIES CONSTELLATION ENERGY GENERATION, LLC QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NUMBERS 50-254 AND 50-265 EPID: L-2022-LLR-0059

RAI 1

Confirm that, even with alternative request I6R-09, Revision 0, the length of the Quad Cities fifth and sixth 10-year ISI intervals will not be affected, and the requirements of ASME Code,Section XI, IWA-2430, Inspection Intervals, will be complied with. Provide start and end dates of the fifth and sixth 10-year ISI intervals.

Constellation Energy Generation, LLC (CEG) Response to RAI 1 The proposed alternative, I6R-09, does not impact the duration of the 5th or 6th intervals. The Quad Cities Nuclear Power Station (QCNPS) 5th In-Service Inspection Interval began on April 13, 2013 and is currently scheduled to end on April 1, 2023. The upcoming 6th In-Service Inspection Interval is currently scheduled to begin on April 2, 2023 and end on April 1, 2033.

RAI 2

The request stated, in part, CEG will comply with all related NDE requirements of the 2013 Edition of ASME Section XI, as they interface with the General Requirements of IWA-1000 as well as certain Mandatory and Nonmandatory Appendices

a. In the submittal, neither the related NDE requirements of the 2013 Edition of ASME Code,Section XI, nor the related mandatory and nonmandatory appendices were identified and listed. Provide list of related NDE requirements of the 2013 Edition of ASME Code,Section XI, and related mandatory and nonmandatory appendices that will be complied in the first period of sixth 10-year ISI interval.

b. The 2017 Edition of ASME Code,Section XI has Appendix XI, Repair/Replacement Activities for Class 3 Polyethylene Piping, but the 2013 Edition does not. Discuss how polyethylene piping NDE activities will be affected by this alternative request in the first period of sixth 10-year ISI interval.

c. Provide list of NDE requirements in the 2017 Edition of ASME Code,Section XI, as compared to the 2013 Edition that are different, newly added, and/or more stringent.

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ATTACHMENT Response to NRC Request for Additional Information Provide justifications that not complying with any one of these NDE requirements of the 2017 Edition in the first period of the sixth 10-year ISI interval will impact structural integrity.

CEG Response to RAI 2

a. Refer to Table RAI-3.1 for a summary of the American Society of Mechanical Engineers (ASME)Section XI non-destructive examination (NDE) requirements related to Mandatory Appendices that will continue to use the requirements of the 2013 Edition of ASME Section XI. Table RAI-3.2 provides a detailed analysis of each change.

b. Appendix XI of 2017 will be available for use during the 6th In-Service Inspection Interval, refer to Note 1 under Table RAI-3.1.

c. Refer to Table RAI-3.2 for a detailed summary of NDE requirements for the 2017 Edition compared to the 2013 Edition, as well as an analysis of each.

RAI 3

Discuss whether any of the prior relief and alternative requests approved by NRC will be affected by this alternative request.

CEG Response to RAI 3 The proposed alternative does not affect any previous submitted relief request for the QCNPS 6th In-Service Inspection Interval.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.1 - Proposed ASME Section XI Codes1 Code Provision ASME Section XI Edition/Addenda2 Sub-Section Article 2013 Edition IWA-1000 X3 IWA-General Requirements IWA-2000 X4 IWE-Requirements for Class IWE-2300 X5 MC Components Mandatory Appendices I X III X IV X VI X VII X6 VIII Note 7 Notes:

1. Constellation will use the Articles and Mandatory Appendices of the 2013 Edition as shown in this table for NDE related activities. Articles, Mandatory Appendices (including Appendix XI, Repair Replacement Activities for Class 3 Polyethylene Piping),

and Nonmandatory Appendices not identified in the table will use the 2017 Edition.

2. Constellation will comply with all NRC conditions, limitations, and restrictions specified in 10 CFR 50.55a(b)(2) for the applicable Edition referenced.

3. Constellation will use the referenced standards from the 2013 Edition in IWA-1600 in relation to NDE related activities. All other paragraphs will utilize the 2017 Edition.

4. Constellation will use IWA-2100, General, IWA-2200, Qualification Methods, and IWA-2300, Qualification of Nondestructive Examination Personnel, from the 2013 Edition. However, Constellation will use IWA-2400, IWA-2500, and IWA-2600 from the 2017 Edition.

5. Constellation will use IWE-2300 from the 2013 Edition for requirements applicable to examination methods and qualification of personnel.

6. Appendix VII will be implemented from the 2013 Edition as amended by 10 CFR 50.55a(b)(2)(xviii)(D) to use Table VII-4110-1 and VIII-2200 from the 2010 Edition.

7. As required by 10 CFR 50.55a, Constellation implements the latest approved Edition of Appendix VIII.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Table REFERENCED STANDARDS AND REFERENCED STANDARDS AND Table revised in its This change has no IWA-1600-1 SPECIFICATIONS SPECIFICATIONS entirety. effect IWA-2100 GENERAL GENERAL No change. No change from 2013 to 2017 edition.

IWA-2200 EXAMINATION METHODS EXAMINATION METHODS Subparagraph (c) This change has no (c) ...Nonmandatory Appendix S (c) ...Nonmandatory Appendix S revised as shown. effect.

provides guidance that may be used provides guidance that may be used for evaluating examination for calculating examination coverage.

coverage.

IWA-2210 VISUAL EXAMINATION VISUAL EXAMINATION Subarticle revised as This change is less (2013 Edition) Visual examination Visual examination shall be shown. restrictive.

shall be conducted in accordance conducted in accordance with the with the requirements of Section V, requirements of Section V, Article 9, Article 9, except that the illumination except that the angle of view shall be in accordance with IWA- requirements for direct visual only 2211 and the demonstration shall apply to VT-1, and the requirements be in accordance with for illumination, distance, and Table IWA-2211-1. resolution demonstration shall be in accordance with Table IWA-2211-1.

IWA-2211 VT-1 Examination VT-1 Examination Subparagraph (e) This change is editorial.

(e) ...same portable nonbattery (e) ...same portable non-battery- corrected by errata.

powered light source powered light source IWA-2212 n/a VT-2 Examination Subparagraph (c) This change is less (c) As indicated in Table IWA-2211-1, added. restrictive.

there are no illumination, distance, and resolution demonstration requirements for VT-2.

IWA-2213 VT-3 Examination VT-3 Examination Subparagraph (e) This change is editorial.

(e) ...same portable nonbattery (e) ...same portable non-battery corrected by errata.

powered light source powered light source Table VISUAL EXAMINATIONS VISUAL EXAMINATIONS VT-2 added to table. This change is less IWA-2211-1 restrictive Page 1 of 11

ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Table VISUAL EXAMINATIONS VISUAL EXAMINATIONS "(lx)" corrected to This change is editorial.

IWA-2211-1 "(lux)" by errata in second column.

IWA-2221 Magnetic Particle Examination Magnetic Particle Examination Subparagraph (c) This change is editorial.

(c) visible light intensity required (c) visible light intensity required is corrected by errata.

is 50 fc... 50 fc (550 lux)

IWA-2222 Liquid Penetrant Examination Liquid Penetrant Examination Subparagraph (b) This change is editorial.

(b) visible light intensity required (b) visible light intensity required is corrected by errata.

is 50 fc 50 fc (550 lux)

IWA-2232 Ultrasonic Examination Ultrasonic Examination Paragraph revised as This change is less Ultrasonic examination shall be Ultrasonic examination shall be shown. restrictive.

conducted in accordance with conducted in accordance with Appendix I. Mandatory Appendix I except for steam generator tubing examinations.

IWA-2234 Acoustic Emission Examination Acoustic Emission Examination Paragraph corrected This change has no The flaws shall be sized by The flaws shall be sized by by errata as shown. effect.

ultrasonic examination in ultrasonic examination in accordance accordance with Appendix I, with Mandatory Appendix I prior Supplement 12, prior Page 2 of 11

ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2310 GENERAL GENERAL Subparagraph (a) The proposed (a) Personnel performing (a) Personnel performing revised as shown. alternative to continue to nondestructive examinations (NDE) nondestructive examinations (NDE) implement the 2013 shall be qualified and certified using shall be qualified and certified using a Edition, including all a written practice prepared in written practice prepared in applicable 10 CFR accordance with ANSI/ASNT accordance with ANSI/ASNT CP-189, 50.55a(b)(2) conditions, CP 189, Standard for Qualification Standard for Qualification and for the first inspection and Certification of Nondestructive Certification of Nondestructive Testing period will ensure an Testing Personnel, as amended by Personnel, and ANSI/ASNT CP-105, acceptable level of the requirements of this Division. Standard for Topical Outlines for quality and safety.

Certifications based on SNT-TC-1A, Qualification of Nondestructive ANSI N45.2.6, or earlier editions of Testing Personnel, as amended by ANSI/ASNT CP-189 are valid... the requirements of this Division.

Certifications based on earlier editions of ANSI/ASNT CP-189 are valid...

IWA-2310 GENERAL GENERAL Subparagraph (a) This change is editorial.

(a) responsible for the certification (a) responsible for the corrected by errata.

of Levels I, II, and III personnel certification of Level I, II, and III personnel IWA-2312 NDE Methods Listed in NDE Methods Listed in ANSI/ASNT (1) Subparagraph (c) The proposed ANSI/ASNT CP-189 CP-189 revised as shown. alternative to continue to (c) Training, qualification, and (c) Training, qualification, and (2) New subparagraph implement the 2013 certification of visual examination certification of visual examination (d) added and Edition, including all personnel shall comply with the personnel shall also comply with the remaining applicable 10 CFR requirements of Appendix VI. requirements of Mandatory subparagraphs 50.55a(b)(2) conditions, Appendix VI. redesignated. for the first inspection (d) Training, qualification, and period will ensure an certification of steam generator tubing acceptable level of examination personnel shall include quality and safety.

the requirements of IWA-2315.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2314 Certification and Recertification Certification and Recertification Subparagraphs (a) This change is editorial.

(2013 Edition) (2015 Edition) and (d) revised as (a) Level I, II, and III personnel (a) Levels I, II, and III personnel shown.

(d) Level I, II, and III NDE (d) Levels I, II, and III NDE personnel... personnel...

IWA-2314 Certification and Recertification Certification and Recertification Subparagraphs (a), This change is editorial.

(2015 Edition) (a) Level I, II, and III personnel (c), and (d) corrected (a) Levels I, II, and III personnel (c) requirements for Level I and II by errata.

(c) requirements for Levels I and NDE personnel.

II NDE personnel. (d) Level I, II, and III NDE personnel...

(d) Levels I, II, and III NDE personnel...

IWA-2315 Personnel Requirements for Personnel Requirements for Paragraph revised as This change is less Eddy Current Examination of Examination of Steam Generator shown. restrictive.

Steam Generator Tubing Tubing Personnel performing analysis or Personnel performing analysis or evaluation of data shall be qualified NDE evaluation of the data shall be by examination to perform analysis qualified. The qualification shall of multifrequency data and to use include a practical examination that multiparameter signal combination includes techniques used and the techniques. The qualification shall types of flaws that may be found include a practical examination that during examination of steam includes techniques used and the generator tubing.

types of flaws that may be found during examination of steam generator tubing.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2318 n/a Qualification for Pneumatic New paragraph IWA- The proposed Pressure Test Personnel 2318 added. alternative to continue to implement the 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

IWA-2324 n/a Practical Examination Techniques New paragraph IWA- The proposed for CP-189 2324 added. alternative to continue to implement the 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

Table n/a Practical Examination NDE New The proposed IWA-2324-1 Techniques Table IWA-2324-1 alternative to continue to added. implement the 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2330 LEVEL I RESPONSIBILITIES LEVEL I RESPONSIBILITIES Paragraph revised as This change has no

...Level I personnel shall not ...Level I personnel shall not perform shown. effect.

evaluate or accept the results of a an NDE evaluation or accept the nondestructive examination. results of a nondestructive examination.

IWA-2350 LIMITED CERTIFICATION LIMITED CERTIFICATION Paragraph revised as This change has no Limited certification in a method is Limited certification provisions of shown. effect.

permitted for personnel who are ANSI/ASNT CP-189 do not apply.

restricted to performing Limited certification in a method is examinations of limited scope, i.e., permitted for personnel who are limited operations or limited restricted to performing examinations techniques within the method. of limited scope, i.e., limited Topics that are not relevant to the operations or limited techniques within limited certification may be deleted the method. Topics that are not from the ANSI/ASNT CP-189, relevant to the limited certification Appendix VI, or Appendix VII may be deleted from the applicable training outline and may be training outline and may be accompanied... accompanied...

IWA-2360 LEVEL I AND LEVEL II TRAINING LEVEL I AND LEVEL II TRAINING Subparagraph (c) The proposed AND EXPERIENCE AND EXPERIENCE added. alternative to continue to n/a (c) Experience is work time in an NDE implement the 2013 method. Classroom and laboratory Edition, including all training time shall not be credited as applicable 10 CFR experience. 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

IWE-2300 Examination and Inspection Examination and Inspection No change impacting This change has no NDE requirements. effect.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix I PIPING PIPING Subparagraph revised This change is less I-3200 (c) Dissimilar metal welds shall be (c) Dissimilar metal welds shall be as shown. restrictive.

examined in two axial and two examined in two axial and two circumferential directions. circumferential directions. If Procedures and personnel qualified examination from both sides of the solely from the austenitic side of the weld is not possible, procedures and weld may be used to perform personnel qualified for singleside examinations from either side of the examination in accordance with weld. When examination from both Mandatory Appendix VIII, sides is not possible, procedures Supplement 10, shall be used and personnel qualified for singleside examination in accordance with Appendix VIII, Supplement 10, with all flaws on the opposite side of the weld, shall be used to examine the required volume.

Appendix I GEOMETRIC INDICATIONS GEOMETRIC INDICATIONS Text "in accordance This change has no Supplement (a) and flaw sizing in accordance (a) and flaw sizing and with Supplement 12" effect.

11 with Supplement 12 and comparison... removed by errata.

comparison...

Appendix III GENERAL GENERAL Subparagraph (b) The proposed III-1100 (b) The requirements of (b) The requirements of Supplement 1 revised as shown. alternative to continue to Supplement 1 apply to examination apply to examination of welds in implement the of austenitic and dissimilar metal wrought austenitic materials and 2013 Edition, including welds. dissimilar metal welds from the all applicable 10 CFR outside surface. The requirements of 50.55a(b)(2) conditions, Supplement 2 apply to welds in for the first inspection centrifugally and statically cast period will ensure an austenitic materials examined from acceptable level of the outside surface. quality and safety.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix III AUSTENITIC AND DISSIMILAR AUSTENITIC AND DISSIMILAR Supplement 1 revised The proposed Supplement 1 METAL WELDS. METAL WELDS in its entirety to alternative to continue to remove cast implement the materials. 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

Appendix III n/a WELDS IN CAST AUSTENTIC Supplement 2 added The proposed Supplement 2 MATERIALS to address welds in alternative to continue to cast austenitic implement the materials. 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

Appendix IV PROCEDURE SPECIFICATIONS PROCEDURE SPECIFICATIONS Subparagraph (b)(3) This change has no IV-2200 (b)(3) extent or area of the (b)(3) extent or area of the component revised as shown. effect.

component evaluated examined Appendix IV Table IV-3110-1 Table IV-3110-1 Added Component The proposed Table Type "Piping (Inside alternative to continue to IV-3110-1 Surface)" and implement the Applicable 2013 Edition, including Supplement "4" to the all applicable 10 CFR table. 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix IV 1.0 SPECIMEN REQUIREMENTS 1.0 SPECIMEN REQUIREMENTS Subparagraph (d)(2) This change is less Supplement 2 (d)(2) The length of cracks or (2015 Edition) revised as shown. restrictive.

notches open to the surface shall (d)(2) The length of cracks or notches not exceed the allowable length open to the surface shall be either (a) specified in IWB-3514 and 1/16 in. (1.5 mm) or less, or (b) less IWC-3514 for inservice surface than or equal to the allowable length flaws for piping or specified in IWB-3514 and IWC-3514 Table IWB-3510-3 and for inservice surface flaws for piping Table IWC-3510-3 for vessels. or Tables IWB-3510-3 and IWC-3510-3 for vessels Appendix IV 1.0 SPECIMEN REQUIREMENTS 1.0 SPECIMEN REQUIREMENTS Subparagraphs (d)(2), The proposed Supplement 2 (2015 Edition) (d)(2) The length of cracks or notches (d)(2) (-a), and (d)(2) alternative to continue to (d)(2) The length of cracks or open to the surface shall (-a) not (-b) revised as shown. implement the notches open to the surface shall be exceed 1/16 in. (1.5 mm) for any 2013 Edition, including either (a) 1/16 in. (1.5 mm) or less, austenitic stainless steels, or nickel all applicable 10 CFR or alloys UNS N06600, N06082, 50.55a(b)(2) conditions, (b) less than or equal to the W86182, W86152, and N06054. for the first inspection allowable length specified in (-b) for ferritic material be less than or period will ensure an IWB-3514 and IWC-3514 for equal to the allowable length specified acceptable level of inservice surface flaws for piping or in IWB-3514 and IWC-3514 for quality and safety.

Tables IWB-3510-3 and inservice surface flaws for piping or IWC-3510-3 for vessels Tables IWB-3510-3 and IWC-3510-3 for vessels.

Appendix IV 1.0 SPECIMEN REQUIREMENTS 1.0 SPECIMEN REQUIREMENTS Subparagraph (b) This change is editorial.

Supplement 3 (b) The effect of the presence of (b) The effect of the presence of revised as shown.

corrosion products must be corrosion products must be assessed evaluated if the bore hole of the bolt if the bore hole of the bolt or stud is or stud is not thoroughly cleaned not thoroughly cleaned prior to prior to examination [IV-3120(b)]. examination [IV-3120(b)].

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix IV n/a QUALIFICATION REQUIREMENTS New Supplement 4 The proposed Supplement 4 FOR COMPLEMENTARY EDDY added. alternative to continue to CURRENT EXAMINATION OF implement the INSIDE SURFACES OF PIPING 2013 Edition, including all applicable 10 CFR 50.55a(b)(2) conditions, for the first inspection period will ensure an acceptable level of quality and safety.

Appendix VI Mandatory Appendix VI Mandatory Appendix VI No change impacting This change has no Qualification of Personnel for Qualification of Personnel for NDE requirements. effect.

Visual Examination Visual Examination Appendix VII INTRODUCTION AND SCOPE INTRODUCTION AND SCOPE Article revised as The proposed VII-1000 This Appendix specifies This Appendix specifies requirements shown. alternative to continue to requirements for the training and for the training and qualification of implement the qualification of ultrasonic ultrasonic nondestructive examination 2013 Edition, including nondestructive examination (NDE) (NDE) personnel in preparation for all applicable 10 CFR personnel in preparation for Employer certification to perform 50.55a(b)(2) conditions, Employer certification to perform NDE. Personnel shall be qualified in for the first inspection NDE. Personnel shall be qualified in accordance with IWA-2300 as period will ensure an accordance with IWA-2300 as modified by this Appendix. The acceptable level of modified by this Appendix. requirements of this Appendix do not quality and safety.

apply to personnel performing examination of steam generator tubing.

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ATTACHMENT Response to NRC Request for Additional Information Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix VII REQUIRED EXPERIENCE FOR REQUIRED EXPERIENCE FOR General note (c) This change is editorial.

Table INITIAL CERTIFICATION FOR INITIAL CERTIFICATION FOR editorially revised.

VII-4110-1 ULTRASONIC EXAMINATIONS ULTRASONIC EXAMINATIONS (HOURS) (HOURS)

General Notes: General Notes:

(c) All or part of the Level I (c) All or part of the Level I experience experience hours may be satisfied hours may be satisfied by laboratory by laboratory practice hours beyond practice hours beyond those required those required for training in for training in accordance with accordance with VII-4220, provided VII-4220, provided those practice those practice hours are dedicated hours are dedicated to the Level I and to the Level I or Level II skill areas Level II skill areas as described in as described in CP-189. ANSI/ASNT CP-189.

Appendix VII Level I and II Practical Level I and II Practical Subparagraph (c)(6) This change has no VII-4323 Examinations Examinations revised as shown. effect.

(c)(6) evaluation in terms of the (c)(6) NDE evaluation in terms of the recording criteria. recording criteria.

Appendix VII LEVEL III QUALIFICATION LEVEL III QUALIFICATION Subparagraph (a) This change has no VII-4330 EXAMINATIONS EXAMINATIONS revised as shown. effect.

(a) cover Section XI UT (a) cover Section XI UT examination, evaluation, and examination, NDE evaluation, and acceptance criteria. Necessary acceptance criteria. Necessary data data such as graphs, tables, such as graphs, tables, specifications, specifications, procedures, and procedures, and Codes shall be Codes shall be furnished. furnished.

Appendix VIII Performance Demonstration For Performance Demonstration For No change As required by 10 CFR Ultrasonic Examination Systems Ultrasonic Examination Systems 50.55a, Constellation implements the latest approved Edition of Appendix VIII.

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