ML23012A083
| 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 Page 1 of 11 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.
ATTACHMENT Response to NRC Request for Additional Information Page 2 of 11 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.
- 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.
ATTACHMENT Response to NRC Request for Additional Information Page 3 of 11 Table RAI-3.1 - Proposed ASME Section XI Codes1 Code Provision ASME Section XI Edition/Addenda2 Sub-Section Article 2013 Edition IWA-General Requirements IWA-1000 X3 IWA-2000 X4 IWE-Requirements for Class MC Components IWE-2300 X5 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.
ATTACHMENT Response to NRC Request for Additional Information Page 1 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Table IWA-1600-1 REFERENCED STANDARDS AND SPECIFICATIONS REFERENCED STANDARDS AND SPECIFICATIONS Table revised in its entirety.
This change has no effect IWA-2100 GENERAL GENERAL No change.
No change from 2013 to 2017 edition.
IWA-2200 EXAMINATION METHODS (c)...Nonmandatory Appendix S provides guidance that may be used for evaluating examination coverage.
EXAMINATION METHODS (c)...Nonmandatory Appendix S provides guidance that may be used for calculating examination coverage.
Subparagraph (c) revised as shown.
This change has no effect.
IWA-2210 VISUAL EXAMINATION (2013 Edition) Visual examination shall be conducted in accordance with the requirements of Section V, Article 9, except that the illumination shall be in accordance with IWA-2211 and the demonstration shall be in accordance with Table IWA-2211-1.
VISUAL EXAMINATION Visual examination shall be conducted in accordance with the requirements of Section V, Article 9, except that the angle of view requirements for direct visual only apply to VT-1, and the requirements for illumination, distance, and resolution demonstration shall be in accordance with Table IWA-2211-1.
Subarticle revised as shown.
This change is less restrictive.
IWA-2211 VT-1 Examination (e)...same portable nonbattery powered light source VT-1 Examination (e)...same portable non-battery-powered light source Subparagraph (e) corrected by errata.
This change is editorial.
IWA-2212 n/a VT-2 Examination (c) As indicated in Table IWA-2211-1, there are no illumination, distance, and resolution demonstration requirements for VT-2.
Subparagraph (c) added.
This change is less restrictive.
IWA-2213 VT-3 Examination (e)...same portable nonbattery powered light source VT-3 Examination (e)...same portable non-battery powered light source Subparagraph (e) corrected by errata.
This change is editorial.
Table IWA-2211-1 VISUAL EXAMINATIONS VISUAL EXAMINATIONS VT-2 added to table.
This change is less restrictive
ATTACHMENT Response to NRC Request for Additional Information Page 2 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Table IWA-2211-1 VISUAL EXAMINATIONS VISUAL EXAMINATIONS
"(lx)" corrected to
"(lux)" by errata in second column.
This change is editorial.
IWA-2221 Magnetic Particle Examination (c) visible light intensity required is 50 fc...
Magnetic Particle Examination (c) visible light intensity required is 50 fc (550 lux)
Subparagraph (c) corrected by errata.
This change is editorial.
IWA-2222 Liquid Penetrant Examination (b) visible light intensity required is 50 fc Liquid Penetrant Examination (b) visible light intensity required is 50 fc (550 lux)
Subparagraph (b) corrected by errata.
This change is editorial.
IWA-2232 Ultrasonic Examination Ultrasonic examination shall be conducted in accordance with Appendix I.
Ultrasonic Examination Ultrasonic examination shall be conducted in accordance with Mandatory Appendix I except for steam generator tubing examinations.
Paragraph revised as shown.
This change is less restrictive.
IWA-2234 Acoustic Emission Examination The flaws shall be sized by ultrasonic examination in accordance with Appendix I, Supplement 12, prior Acoustic Emission Examination The flaws shall be sized by ultrasonic examination in accordance with Mandatory Appendix I prior Paragraph corrected by errata as shown.
This change has no effect.
ATTACHMENT Response to NRC Request for Additional Information Page 3 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2310 GENERAL (a) Personnel performing nondestructive examinations (NDE) shall be qualified and certified using a written practice prepared in accordance with ANSI/ASNT CP 189, Standard for Qualification and Certification of Nondestructive Testing Personnel, as amended by the requirements of this Division.
Certifications based on SNT-TC-1A, ANSI N45.2.6, or earlier editions of ANSI/ASNT CP-189 are valid...
GENERAL (a) Personnel performing nondestructive examinations (NDE) shall be qualified and certified using a written practice prepared in accordance with ANSI/ASNT CP-189, Standard for Qualification and Certification of Nondestructive Testing Personnel, and ANSI/ASNT CP-105, Standard for Topical Outlines for Qualification of Nondestructive Testing Personnel, as amended by the requirements of this Division.
Certifications based on earlier editions of ANSI/ASNT CP-189 are valid...
Subparagraph (a) revised as shown.
The proposed 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-2310 GENERAL (a) responsible for the certification of Levels I, II, and III personnel GENERAL (a) responsible for the certification of Level I, II, and III personnel Subparagraph (a) corrected by errata.
This change is editorial.
IWA-2312 NDE Methods Listed in ANSI/ASNT CP-189 (c) Training, qualification, and certification of visual examination personnel shall comply with the requirements of Appendix VI.
NDE Methods Listed in ANSI/ASNT CP-189 (c) Training, qualification, and certification of visual examination personnel shall also comply with the requirements of Mandatory Appendix VI.
(d) Training, qualification, and certification of steam generator tubing examination personnel shall include the requirements of IWA-2315.
(1) Subparagraph (c) revised as shown.
(2) New subparagraph (d) added and remaining subparagraphs redesignated.
The proposed 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.
ATTACHMENT Response to NRC Request for Additional Information Page 4 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2314 Certification and Recertification (2013 Edition)
(a) Level I, II, and III personnel (d) Level I, II, and III NDE personnel...
Certification and Recertification (2015 Edition)
(a) Levels I, II, and III personnel (d) Levels I, II, and III NDE personnel...
Subparagraphs (a) and (d) revised as shown.
This change is editorial.
IWA-2314 Certification and Recertification (2015 Edition)
(a) Levels I, II, and III personnel (c) requirements for Levels I and II NDE personnel.
(d) Levels I, II, and III NDE personnel...
Certification and Recertification (a) Level I, II, and III personnel (c) requirements for Level I and II NDE personnel.
(d) Level I, II, and III NDE personnel...
Subparagraphs (a),
(c), and (d) corrected by errata.
This change is editorial.
IWA-2315 Personnel Requirements for Eddy Current Examination of Steam Generator Tubing Personnel performing analysis or evaluation of data shall be qualified by examination to perform analysis of multifrequency data and to use multiparameter signal combination techniques. The qualification shall include a practical examination that includes techniques used and the types of flaws that may be found during examination of steam generator tubing.
Personnel Requirements for Examination of Steam Generator Tubing Personnel performing analysis or NDE evaluation of the data shall be qualified. The qualification shall include a practical examination that includes techniques used and the types of flaws that may be found during examination of steam generator tubing.
Paragraph revised as shown.
This change is less restrictive.
ATTACHMENT Response to NRC Request for Additional Information Page 5 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2318 n/a Qualification for Pneumatic Pressure Test Personnel New paragraph IWA-2318 added.
The proposed 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 for CP-189 New paragraph IWA-2324 added.
The proposed 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 IWA-2324-1 n/a Practical Examination NDE Techniques New Table IWA-2324-1 added.
The proposed 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.
ATTACHMENT Response to NRC Request for Additional Information Page 6 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments IWA-2330 LEVEL I RESPONSIBILITIES
...Level I personnel shall not evaluate or accept the results of a nondestructive examination.
LEVEL I RESPONSIBILITIES
...Level I personnel shall not perform an NDE evaluation or accept the results of a nondestructive examination.
Paragraph revised as shown.
This change has no effect.
IWA-2350 LIMITED CERTIFICATION Limited certification in a method is permitted for personnel who are restricted to performing examinations of limited scope, i.e.,
limited operations or limited techniques within the method.
Topics that are not relevant to the limited certification may be deleted from the ANSI/ASNT CP-189, Appendix VI, or Appendix VII training outline and may be accompanied...
LIMITED CERTIFICATION Limited certification provisions of ANSI/ASNT CP-189 do not apply.
Limited certification in a method is permitted for personnel who are restricted to performing examinations of limited scope, i.e., limited operations or limited techniques within the method. Topics that are not relevant to the limited certification may be deleted from the applicable training outline and may be accompanied...
Paragraph revised as shown.
This change has no effect.
IWA-2360 LEVEL I AND LEVEL II TRAINING AND EXPERIENCE n/a LEVEL I AND LEVEL II TRAINING AND EXPERIENCE (c) Experience is work time in an NDE method. Classroom and laboratory training time shall not be credited as experience.
Subparagraph (c) added.
The proposed 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.
IWE-2300 Examination and Inspection Examination and Inspection No change impacting NDE requirements.
This change has no effect.
ATTACHMENT Response to NRC Request for Additional Information Page 7 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix I I-3200 PIPING (c) Dissimilar metal welds shall be examined in two axial and two circumferential directions.
Procedures and personnel qualified solely from the austenitic side of the weld may be used to perform examinations from either side of the weld. When examination from both sides is not possible, procedures 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.
PIPING (c) Dissimilar metal welds shall be examined in two axial and two circumferential directions. If examination from both sides of the weld is not possible, procedures and personnel qualified for singleside examination in accordance with Mandatory Appendix VIII, Supplement 10, shall be used Subparagraph revised as shown.
This change is less restrictive.
Appendix I Supplement 11 GEOMETRIC INDICATIONS (a) and flaw sizing in accordance with Supplement 12 and comparison...
GEOMETRIC INDICATIONS (a) and flaw sizing and comparison...
Text "in accordance with Supplement 12" removed by errata.
This change has no effect.
Appendix III III-1100 GENERAL (b) The requirements of Supplement 1 apply to examination of austenitic and dissimilar metal welds.
GENERAL (b) The requirements of Supplement 1 apply to examination of welds in wrought austenitic materials and dissimilar metal welds from the outside surface. The requirements of Supplement 2 apply to welds in centrifugally and statically cast austenitic materials examined from the outside surface.
Subparagraph (b) revised as shown.
The proposed 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.
ATTACHMENT Response to NRC Request for Additional Information Page 8 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix III Supplement 1 AUSTENITIC AND DISSIMILAR METAL WELDS.
AUSTENITIC AND DISSIMILAR METAL WELDS Supplement 1 revised in its entirety to remove cast materials.
The proposed 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.
Appendix III Supplement 2 n/a WELDS IN CAST AUSTENTIC MATERIALS Supplement 2 added to address welds in cast austenitic materials.
The proposed 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.
Appendix IV IV-2200 PROCEDURE SPECIFICATIONS (b)(3) extent or area of the component evaluated PROCEDURE SPECIFICATIONS (b)(3) extent or area of the component examined Subparagraph (b)(3) revised as shown.
This change has no effect.
Appendix IV Table IV-3110-1 Table IV-3110-1 Table IV-3110-1 Added Component Type "Piping (Inside Surface)" and Applicable Supplement "4" to the table.
The proposed 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.
ATTACHMENT Response to NRC Request for Additional Information Page 9 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix IV Supplement 2 1.0 SPECIMEN REQUIREMENTS (d)(2) The length of cracks or notches open to the surface shall not exceed the allowable length specified in IWB-3514 and IWC-3514 for inservice surface flaws for piping or Table IWB-3510-3 and Table IWC-3510-3 for vessels.
1.0 SPECIMEN REQUIREMENTS (2015 Edition)
(d)(2) The length of cracks or notches open to the surface shall be either (a) 1/16 in. (1.5 mm) or less, or (b) less than or equal to the allowable length specified in IWB-3514 and IWC-3514 for inservice surface flaws for piping or Tables IWB-3510-3 and IWC-3510-3 for vessels Subparagraph (d)(2) revised as shown.
This change is less restrictive.
Appendix IV Supplement 2 1.0 SPECIMEN REQUIREMENTS (2015 Edition)
(d)(2) The length of cracks or notches open to the surface shall be either (a) 1/16 in. (1.5 mm) or less, or (b) less than or equal to the allowable length specified in IWB-3514 and IWC-3514 for inservice surface flaws for piping or Tables IWB-3510-3 and IWC-3510-3 for vessels 1.0 SPECIMEN REQUIREMENTS (d)(2) The length of cracks or notches open to the surface shall (-a) not exceed 1/16 in. (1.5 mm) for any austenitic stainless steels, or nickel alloys UNS N06600, N06082, W86182, W86152, and N06054.
(-b) for ferritic material be less than or equal to the allowable length specified in IWB-3514 and IWC-3514 for inservice surface flaws for piping or Tables IWB-3510-3 and IWC-3510-3 for vessels.
Subparagraphs (d)(2),
(d)(2) (-a), and (d)(2)
(-b) revised as shown.
The proposed 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.
Appendix IV Supplement 3 1.0 SPECIMEN REQUIREMENTS (b) The effect of the presence of corrosion products must be evaluated if the bore hole of the bolt or stud is not thoroughly cleaned prior to examination [IV-3120(b)].
1.0 SPECIMEN REQUIREMENTS (b) The effect of the presence of corrosion products must be assessed if the bore hole of the bolt or stud is not thoroughly cleaned prior to examination [IV-3120(b)].
Subparagraph (b) revised as shown.
This change is editorial.
ATTACHMENT Response to NRC Request for Additional Information Page 10 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix IV Supplement 4 n/a QUALIFICATION REQUIREMENTS FOR COMPLEMENTARY EDDY CURRENT EXAMINATION OF INSIDE SURFACES OF PIPING New Supplement 4 added.
The proposed 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.
Appendix VI Mandatory Appendix VI Qualification of Personnel for Visual Examination Mandatory Appendix VI Qualification of Personnel for Visual Examination No change impacting NDE requirements.
This change has no effect.
Appendix VII VII-1000 INTRODUCTION AND SCOPE This Appendix specifies requirements for the training and qualification of ultrasonic nondestructive examination (NDE) personnel in preparation for Employer certification to perform NDE. Personnel shall be qualified in accordance with IWA-2300 as modified by this Appendix.
INTRODUCTION AND SCOPE This Appendix specifies requirements for the training and qualification of ultrasonic nondestructive examination (NDE) personnel in preparation for Employer certification to perform NDE. Personnel shall be qualified in accordance with IWA-2300 as modified by this Appendix. The requirements of this Appendix do not apply to personnel performing examination of steam generator tubing.
Article revised as shown.
The proposed 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.
ATTACHMENT Response to NRC Request for Additional Information Page 11 of 11 Table RAI-3.2 - Detailed Analysis of Changes Paragraph 2013 Edition 2017 Edition Description of Change Comments Appendix VII Table VII-4110-1 REQUIRED EXPERIENCE FOR INITIAL CERTIFICATION FOR ULTRASONIC EXAMINATIONS (HOURS)
General Notes:
(c) All or part of the Level I experience hours may be satisfied by laboratory practice hours beyond those required for training in accordance with VII-4220, provided those practice hours are dedicated to the Level I or Level II skill areas as described in CP-189.
REQUIRED EXPERIENCE FOR INITIAL CERTIFICATION FOR ULTRASONIC EXAMINATIONS (HOURS)
General Notes:
(c) All or part of the Level I experience hours may be satisfied by laboratory practice hours beyond those required for training in accordance with VII-4220, provided those practice hours are dedicated to the Level I and Level II skill areas as described in ANSI/ASNT CP-189.
General note (c) editorially revised.
This change is editorial.
Appendix VII VII-4323 Level I and II Practical Examinations (c)(6) evaluation in terms of the recording criteria.
Level I and II Practical Examinations (c)(6) NDE evaluation in terms of the recording criteria.
Subparagraph (c)(6) revised as shown.
This change has no effect.
Appendix VII VII-4330 LEVEL III QUALIFICATION EXAMINATIONS (a) cover Section XI UT examination, evaluation, and acceptance criteria. Necessary data such as graphs, tables, specifications, procedures, and Codes shall be furnished.
LEVEL III QUALIFICATION EXAMINATIONS (a) cover Section XI UT examination, NDE evaluation, and acceptance criteria. Necessary data such as graphs, tables, specifications, procedures, and Codes shall be furnished.
Subparagraph (a) revised as shown.
This change has no effect.
Appendix VIII Performance Demonstration For Ultrasonic Examination Systems Performance Demonstration For Ultrasonic Examination Systems No change As required by 10 CFR 50.55a, Constellation implements the latest approved Edition of Appendix VIII.