NG-98-1853, Forwards Relief Requests NDE-R001,NDE-R027,NDE-R028.NDE-R029 NDE-R030,for Evaluation of Third ten-year ISI Interval.Util Requests Authorization for Use of PDI Techniques in ISI Program (NDE-R034)
| ML20155H728 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 10/30/1998 |
| From: | Peveler K IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | NRC (Affiliation Not Assigned), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NG-98-1853, NUDOCS 9811100260 | |
| Download: ML20155H728 (20) | |
Text
. _ - . . ..
g VTILITIESA L I. I A N T ir.s tuiiun inc.
IES Utilities 3$",idE"EN[**
Palo IA 52324 9785 Y.If5i$EE5E" October 30,1998 """""""8"""'
NG-98-1853 l
Office of Nuclear Reactor Regulation l U. S. Nuclear Regulatory Commission Attn: Document Control Desk l Mail Station Pl-37 Washington, DC 20555-0001
Subject:
Duane Arnold Energy Center Docket No: 50-331 Op. License No: DPR-49 Inservice Inspection Relief Requests NDE-R001, NDE-R027, NDE-R028, NDE-R029, NDE-R030, NDE-R032, NDE-R034, NDE-R035 and NDE-R036
Reference:
Letter from R. Savio (NRC) to L. Liu (IES) dated March 23,1998, Evaluation of Third Ten-Year Inservice Inspection Interval Requests for Relief File: A-100, A-286 The referenced letter transmitted the NRC's evaluation of the Duane Arnold Energy Center (DAEC) inservice inspection (ISI) requests for relief for the third ten year interval. Since that time, the DAEC has identified the need for additional relief. Relief requests NDE-R001, NDE-R027, NDE-R028, NDE-R029 and NDE-R030 are provided in the attachment. IES Utilities also requests authorization for the use of Performance Demonstration Initiative k
(PDl) techniques in the ISI program (NDE-R034), t 0
_, nn p .3 7.
9811100260 991030 5 PDR ADOCK 05000331):..
a PDR g L
{ '. . .
l' October 30,1998 NG-98-1853
- . Page'2 l
In addition,IES Utilities requests authorization to use the alternative requirements described i l in Code Cases 573,598 and 574. These requests are contained in relief requests NDE-R032, i NDE-R035 end NDE-R036, respectively. As stated in footnote 6 to 10CFR50.55a, the use of Code Cases may be authorized by the Director of the Office of Nuclear Reactor Regulation, i
pursuant to 10CFR50.55a(a)(3). ' According to 10CFR50.55a(a)(3), the proposed alternatives !
l must provide an " acceptable level of quality and safety." Use of the aforementioned Code Cases does so, as discussed in the attachment. '
l .
l l
IES Utilities requests approval of these requests prior to Refueling Outage (RFO) 16, currently scheduled to begin in October 8,1999.
-Sincerely, 6 %
K'enneth E. Peveler l Manager, Regulatory Performance Attachment cc: C. Rushworth (w/a) i
'E. Protsch (w/o) l J. Franz (w/o)
D. Wilson (w/o) !
R. Laufer(NRC-NRR)(w/a)
J. Caldwell(ReFi on Ill)(w/a)
NRC Resident Office (w/a)
Docu (w/a) l u
Attachment to NG-98-1853 Page1of18 RELIEF REQUEST NUMBER: NDE-R001 COMPONENT IDENTIFICATION Code Class: 1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-A Item Number: Bl .11, B l.22, B l.30, Bl.40
Description:
Circumferential Weld (Vessel) '
Meridional Weld (Bottom Head)
Shell to Flange Weld Head to Flange Weld Component Numbers: VCB-B004, IIMA-B002, VCB-C005, HCC-C001 CODE REOUIREMENT Section XI (1989 Edition), Table IWB-25001 Category B-A, Items Bl.11, Bl.22, Bl.30 and Bl.40, require a volumetric examination of applicable Class 1 pressure retaining welds, which includes essentially 100% of weld length, once during the ten-year interval.
Code Case N-460 and 10CFR50.55 pennit a reduction in examination coverage of Class I reactor vessel welds provided the coverage reduction is less than 10%. The Duane Arnold Energy Center (DAEC) has adopted Code Case N-460 in the Inservice Inspection (ISI) Program Plan, as permitted by USNRC Regulatory Guide 1.147, Revision 11.
Reliefis requested from performing essentially 100% of the weld length for reactor vessel welds VCB-B004, HMA-B002, VCB-C005 and HCC-C001.
BASIS FOR RELIEF 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 III,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 can not be obtained.
\ .
Attachment to NG-98-1853 Page 2 of I8 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 table. The amoun'. of coverage which will be obtainable when the third ten-year interval examinations are perfonned is based on the percentages obtained during RFO 14. Reliefis therefore requested for the third ten-year interval for the four welds for which less than 90% coverage will be obtainable - VCB-B004, HMA- j B002, VCB-C005 and IICC-C001, i
i REACTOR VESSEL WELD LIMITED EXAMINATION TABI E ASME Item Weld Description Weld ID Accessible Comments No. Exam l Coverage B 1.11 Circumferential weld VCB-B1 96.5 % l B l .11 Circumferential weld VCB-A2 96.7 % l B 1.11 Circumferential weld VCB-B3 96.7 %
B l.11 Circumferential weld VCB-B4 86.91 %
Bl.12 Longitudinal Welds VLA-A001 96.6 %
B l .12 Longitudinal Welds VLA-A002 96.7 %
Bl.12 Longitudinal Welds VLB-A001 95.4 % !
Bl.12 Longitudinal Welds VLB.A002 95.8 %
Bl.12 Longitudinal Welds VLC-B001 93.8 %
Bl.12 Longitudinal Welds VLC-B002 93.4 %
Bl.12 Longitudinal Welds VLD-B001 96.7 %
Bl.12 Longitudinal Welds VLD-8002 96.7 %
B l .21 Cire Weld (Bott lid) IICA-B001 100 %
B l.22 Meridional Welds IIMA-B002 80.3 %
(Bottom llead)
B l.30 Shell to Flange Welds VCB-C005 42.7 % (one side)
B l .40 liead to Flange Welds 11CC-C001 36.8 % (one side)
Bl.51 Repair Welds (VLA-A002) 96.9 % Right side of weld, (Beltline Region) 118 R1 31" X 38" area, Y=119" to 150" l
l 1
Attachment to NG-98-1853 1 Page 3 of 18 VC'B-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 are located on the weld. In order to perform the additional 13.09% of the weld, the stabilizers would require removal. Removing the vessel stabilizers is not a feasible option.
HMA-B002 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 i 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. l There is no feasible option in o Jer to examine the additional 57.3%.
)
IICC-C001 This is the IIcad 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%.
ALTERNATE EXAMINATION Pursuant to 10CFR50.55a(a)(3)(ii), the DAEC proposes to examine, once during the ten year interval, the applicable pressure retaining reactor vessel welds to the maximum extent practical within the limitations of the examination technique or design of the component. The welds and approximate coverage are:
VCB-B004 86.91 %
HMA-B002 80.3 %
VCB-C005 42.7 %
HCC-C001 36.8%
The inaccessible portions of the reactor vessel welds will continue to be subject to the applicable system pressure test requirements ofIWA and IWB-5000 with a VT-2 visual examination.
APPI,1 CABLE TIME PERIOD Reliefis requested for the third ten year interval of the Inservice Inspection Program for DAEC.
Attachment to NG-98-1853 Page 4 of I8 l
l SNETCH l Reacter Vcssel Mcca:
T& BEAD DiLAR PLAf& H;C41
.g J f FLAME
[.....-- y 8 T T@ lead mou.un j
gj,qyjig ,,,,,,, _-. ..., ,,,s,1,1-FLANE 11 ,, ,,. ., -,,1-gg g g I l O #Eli FLANE j
! s i twiR
[ # ELL 1
s : n I Q
. -,.... .. -1,---- --,
fEPAsR 4 ELD
- ~
4@ (ppgg l
c
- *O fEFAIR YELD k, INTEMIEDATE
- I .L d hd
$g ItM)
/
i l l
,,a sai '
l enas marit> ;
\! vt&A2
=-
!s g
==
1l l
/_. _
GRTN VELD PEPM YELO
( e le ! @@D (116Rt)
N LarER # ELL
== l W
- e
,.. ...s, , . .
. - - g,/ .&a1 --
ma i
SMRr % ELD harf<3 64AD
- s- / N gg , ,u...s x.x , .s ssssss.s f L Pt t
-c 1 ,
acuanDC & TM RPV SiOMMO ARRANMhEMT WESELPLATES AMO M1DS
Attachment to NG-98-1853 Page 5 of 18 RELIEF REQUEST NUMBER: NDE-R027 COMPONENT IDENTIFICATION Code Class: 1 i
References:
IWB-2500 '
Table IWB-2500-1 1 Examination Category: B-G-1 Item Number: B6.40
Description:
Threads in Flange Component Numbers: Closure Head Threads in Vessel Flange (CLSR IID LGMNTS,(1-60))
CODE REOUIREMENT Section XI (1989 Edition), Table IWB-2500-1 Category B-G-1, Item B6.40, requires a volumetric examination, which includes 1 inch around the vessel bushing (when installed) as I referenced in Figure IWB-2500-12, once during the ten-year interval,
, Code Case N-460 permits a reduction in examination coverage of Class I welds provided the coverage reduction is less than 10%. The Duane Amold Energy Center (D AEC) has adopted l Code Case N-460 in the Inservice Inspection (ISI) Program Plan, as permitted by USNRC l Regulatory Guide 1.147, Revision 11.
HASIS FOR RELIEF The 1 inch annular area required by IWB-2500-12 to be examined encompasses the llange sealing surface area. This ligament examination is limited due to the proximity of the ihmge sealing surface. A total of approximately 77.1% of the examination 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 surface. This is due to the flange configuration and the O-ring groove. In accordance with 10CFR 50.55a(6)(i), relief requests may be granted when the examination requirements are shown to be impractical.
ALTERNATE EXAMINATION The DAEC proposes to perform examination of 77.1% of the flange ligament once every ten year period.
APPLICABLE TIME PERIOD Reliefis requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
. .-- - . . - - . . _ . _ - - . - ~ . . - _ -_ - - - . .-
Attachment to NG-98-1853 !
page 6 of 18
, RELIEF REQUEST NUMBER: NDE-R028 COMPONENT IDENTIFICATION Code Class: 1
References:
IWB-2500 Table IWB-2500-1 Examination Category: B-D ltem Number: B3.90 .
Description:
Nozzle-to-Vessel Welds Component Numbers: See " List of Nozzle-to-Vessel Welds" for Component l Identification CODE REOUIREMENT '
4
.Section XI (1989 Edition), Table IWB-2500-1 Category B-D, Item B3.90, requires a volumetric examination, which includes essentially 100% of the weld, once during the ten-year interval. l The examination volume is defined in Figure IWB 2500-7(b). ,
Code Case N-460 permits a reduction in examination coverage of Class I welds provided the coverage reduction is less than 10%. The Duane Arnold Energy Center (DAEC) has adopted .
Code Case N-460 in the Inservice Inspection (ISI) Program Plan, as permitted by USNRC l Regulatory Guide 1.147, Revision 11.
Reliefis requested from performing essentially 100% of the weld length for those welds identified in the " List of Nozzle-to-Vessel Welds."
BASIS FOR RELIEF 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 10CFR 50.55a(6)(i) relief requests may be granted when the examination requirements are shown to be impractical, i
Attachment to NG-98-1853 Page 7 of I8 AIlfERNATE EXAMINATION 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." Because of the design of these welds, there are no alternative examination techniques currently available to increase the examination volume.
List of Nozzle to-Vessel Welds !
l Nozzle ID Code Coverage
- Remarks CRA-D001 61.3 %
)
Control Rod Drive CSB-D001 66% Core Spray l FWA-D001 56.5 % Feedwater ilVA-D001 66.0 % liead Vent i JPA-D001 61.1 % Jet Pump l MSA-D001 59.6 % Main Steam I RHA-D001 65.7 % licad Spray
- RRD-D001 51.4 % Recirculation Inlet RRE-D001 64 % Recirculation Inlet RRH-D001 64 % Recirculation Inlet VIE-D001 66 % VesselInstrumentation
- Due to the nozzle design, it is not feasible to effectively exam 100% of the required code l
volume as defined in Figure IWB-2500-7(b). I APPLICABLE TIME PERIOD Reliefis requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
l l
l
Attachment to I NG-98-1853 Page 8 of 18
- RELIEF REQUEST NUMBER: NDE-R029 l
COMPONENT IDENTIFICATION Code Classes: 1
References:
IWB-2500, Table IWB-2500-1 Examination Categories: BJ Item Numbers: B9.11
Description:
All pressure retaining Component Numbers: Reactor Water Cleanup System Weld CUA-J010 CODE REOUIREMENT Section XI (1989 Edition), Table IWB-2500-1 Category B-J, item B9.11 requires a volumetric and surface examination of applicable Class 1 pressure retaining welds, which includes
)'
essentially 100% of weld length, once during the ten-year interval.
Code Case N-460 pemiits a reduction in examination coverage of Class I welds provided the ,
coverage reduction is less than 10%. The Duane Arnold Energy Center (DAEC) has adopted
]
Code Case N-460 in the Inservice Inspection (ISI) Program Plan, as permitted by USNRC l Regulatory Guide 1.147, Revision 11.
Pursuant to 10CFR50.55a(a)(3)(ii), reliefis requested from performing volumetric examination of essentially 100% of the weld length for Reactor Water Cleanup System Weld CUA-J010.
BASIS FOR RELIEF 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 i 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 ofincreasing plant safety margins and a very disproportionate impact on expenditures of plant manpower and radiation exposure.
l l
i l
Attachment to NG-98-1853
' Page 9 of 18
. ALTERNATE EXAMINATION 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. ,
1 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. .
l The inaccessible portions of the weld will continue to be subject to the applicable system
- pressure test requirements ofIWA and IWB-5000 with a VT-2 visual examination, as well as Code-required surface examination.
l APPLICABLE TIME PERIOD l
Reliefis requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
]
l i
l l
l l
l i-I l>
l l
l l .
!. i e'
l 1
1 1
4 r,-< . . . ., ~ ,.--v., , , -. - - .,,s
Attachment to NG-98-1853 Page 10 of18
, RELIEF REQUEST NUMBER: NDE-R030 COMPONENT IDENTIFICATION Code Classes: 1
References:
IWB-2500, l Table IWB-2500-1 Examination Categories: B-J Item Numbers: B9.11
Description:
All pressure retaining Component Numbers: Residual lieat Removal System Weld RIIC-J025 CODE REOUIREMENT Section XI (1989 Edition), Table IWB-2500-1 Category B-J, Item B9.11 requires a volumetric and surface examination of applicable Class 1 pressure retaining welds, which includes essentially 100% of weld length, once during the ten-year interval.
Code Case N-460 permits a reduction in examination coverage of Class I welds provided the coverage reduction is less than 10%. The Duane Arnold Energy Center (DAEC) has adopted Code Case N-460 in the Inservice Inspection (ISI) Program Plan, as permitted by USNRC Regulatory Guide 1.147, Revision 11.
Pursuant to 10CFR50.55a(a)(3)(ii), reliefis requested from performing volumetric examination ofessentially 100% of the weld length for Residual Heat Removal System Weld RIIC-J025.
HASIS FOR RELIEF 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 lleat 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. Simr/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 ofincreasing plant safety margins and a very disproportionate impact on expenditures of plant manpower and radiation exposure.
l t
i l
l
f Attachment to NG-98-1853 Page11of18 ALTERNATE EXAMINATION As an alternative to existing Section XI requirements, the DAEC proposes to perform volumetric examination of approximately 68% of the weld length. The 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 w;!! continue to be subject to the applicable system pressure test requirements ofIWA and IWB-5000 with a VT-2 visual examination, as well as a Code-required surface examination.
APPLICABLE TIME PERIOD Reliefis requested for the third ten-year interval of the Inservice inspection Program for DAEC.
l Attachment to NG-98-1853 Page 12 of18
- ALTERNATIVE EXAMINATION NUMBER: NDE-R032 SYSTEM / COMPONENT (S) FOR WHICII ALTERNATE EXAMINATION WILL BE USED Code Classes: 1,2, and 3
References:
ASME,Section XI, IWA-4400(a) (1989 Edition)
ASME Code Case N-573 Examination Category: All item Number: All
Description:
Use of Code Case N-573 Component Numbers: All CODE REOUIREMENT ASME,Section XI, IWA-4400(a),1989 edition with 1989 addenda (NDE-R015) requires that the Owner must qualify all welding procedures.
BASIS FOR ALTERNATE EXAMINATION Pursuant to 10CFR50.55a(a)(3)(ii), reliefis 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 (PQRs) supporting altctnative 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 weiding procedures. Code Case N-573 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 NRC licensed facilities have already been demonstrated to piovide an acceptable level of quality and safet". The requested alternative will not reduce safety or quality.
Attachment to NG-98-1853 Page 13 of 18 ALTERNATE EXAMINATION The DAEC will use Code Case N-573 to allow the use of other Owner's PQRs. Steps to be taken by the DAEC to ensure the technical correctness of other Owner's PQRs and to ensure the resulting Welding Procedure Specifications (WPSs) produce sound welds are as follows.
The DAEC wili ,.2rform a technical review of the supplying Owner's PQR. The supplying Owner will state in writing that the PQR 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 PQRs.
DAEC PQRs may supplement the other Owner's supplied PQRs. All essential variables of the most recent.ASME,Section IX, 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 by DAEC by successfully passing a performance qualification test in accordance with ASME,Section IX.
e The DAEC will not transfer a supplied PQR to any other Owner.
e The DAEC will de ument the use of Code Case N-573 on the appropriate NIS-2 form.
APPLICABLE TIME PERIOD Alternative is requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
t i
Attachment to NG-98-1853 Page 14 of 18 ALTERNA'IIVE EXAMINATION NUMBER: NDE-R034 SYSTEM / COMPONENT (tu FOR WIIICH ALTERNATE EXAMINATION WILL HE USED Code Classes: I and 2
References:
ASME,Section XI, IWA-2232 (1989 Edition)
Examination Category: B-J and C-F-2 Item Number: B9.11, and C5.51
Description:
Use of the Performance Demonstration Initiative (PDI) Techniques Component Numbers: All CODE REOUIREMENT ASME,Section XI,1989 edition, Tables IWB-2500 and IWC-2500 requires a volumetric examination of the above item numbers. IWA-2232 requires that the Owner shall perform ultrasonic examination in accordance with Appendix I. Appendix I states that examinations shall
- be conducted in accordance with Appendix III.
HASIS FOR ALTERNATE EXAMINATION The PDI program is based on the 1992 Edition with the 1993 Addenda of the ASME Section XI Code. This edition with addenda requires that ultrasonic equipment, procedure, and examiners be qualified on flawed and notched materials and configurations similar to those found in the actual plant. Hence, the PD1 Program provides a higher degree of reliability for detection and characterization of any flaws when compared to the conventional amplitude-based ultrasonic techniques required by the 1989 edition of the ASME Section XI Code.
The NRC issued a letter on March 1,1996 discussing the transition from the Intergranular Stress
, Corrosion Cracking (IGSCC) Qualification Program to the PDI Program. In this letter, the NRC l approved the following actions while the staff proceeded with the rulemaking and the l incorporation of the PDI into that rulemaking. The specific items that were approved by the l Staff are as follows:
! * " Effective March 1,1996, IGSCC examiner qualification may be obtained by passing the
! appropriate test of either the PD1 program or the original IGSCC program. Examiner qualification for weld overlays will continue as it currently exists under the IGSCC
- Coordination Plan until weld overlay qualification is incorporated in the PDI program. The l need to include weld overlay qualification in the PDI program is considered an outstanding issue... ."
Attachment to NG-98-1853 Page 15 of 18 e
"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 IGSCC examination personnel is preferred over using the IGSCC Coordination Plan. ..."
e "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."
- e "The registry of qualified personnel for ultrasonic examination ofIGSCC that is being maintained for the IGSCC Coordination Plan should be expanded to include IGSCC qualified examiners from the PDI program."
Pursuant to 10CFR 50.55a(a)(3)(i) the use of the PDI Program for examination procedures, equipment, and personnel qualifications would provide an acceptable altemative to the existing ASME Section XI Code requirements.
ALTERNATE EXAMINATION l Examination procedures, equipment, and personnel qualified by performance demonstration will l 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.
l l APPLICABLE TIME PERIOR ;
i I l Alternative is requested for the third ten-year interval of the Inservice Inspection Program for l- DAEC.
A Attachment to
' NG-98-1853 Page 16 of 18 ALTERNATIVE EXAMINATION NUMBER: NDE-R035 SYSTEM / COMPONENT (S) FOR WHICH ALTERNATE EXAMINATION WILL HE l USED Code Classes: All
References:
ASME,Section XI, Tables IWB-2412-1, IWC-2412-1, IWD-2412-1,(1989 Edition)
Examination Category: All Item Number: All
Description:
Alternative Requirements to Required Percentages of Examinations Component Numbers: All CODE REOUIREMENT Tables IWX-2412-1 (as shown below) requires that a certain percentage of examinations be performed within each inspection period.
1 Inspection Period, Calendar Years of Minimum Maximum inspection Plant Service Examinations Examinations Interval Within the Interval Completed, % Credited, %
All 3 16 34 7 50 67 10 100 100 HASIS FOR ALTERNATE EXAMINATION l 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 l up to a maximum of 50% of the examinations performed, but the first can have only 34%.
l ASME Code Case N-598 provides altemative examination percentages which allow more l ' flexibility in scheduling examinations The use of this Code Case allows the scheduling of examinations to avoid unnecessary expenditure of both manpower and exposure, while ensuring the integrity of the examined cemponents.
In the 1991 Addenda of ASME Section XI, clarification was made on the scheduling ofitems 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
Attachment to NG-98-1853 Page 17 of 18 i 1991 Addenda allows the examination of these items in any two periods, for a 50% examination l
3 percentage per period. By the 1989 edition, neither item could be examined in the first period !
without exceeding the 34% maximum percentage.
The use of th Code Case and the change to 50% maximum percentage for the first period does not deviate from the philosophy of the Code. In fact, this supports performing examinations earlier than 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 examinatiens 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 4
outages.
ALTERNATE EXAMINATION Pursuant to 10CFR 50.55a(a)(3)(i), the DAEC requests authorization to use Code Case N-598 as i
an alternative to the requirements of Table IWX-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, Calendar Years of Minimum Maximum Inspection Plant Service Examinations Examinations Interval Within the Interval Completed, % Credited, %
All 3 16 50 7 50' 75
, 10 100 100 m If 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.
APPLICABLE flME PERIOD Alternative is requested for the third ten-year interval of the Inservice Inspection Program for DAEC.
Attachment to NG-98-1853 Page 18 of 18 ALTERNATIVE EXAMINATION NUMBER: NDE-R036 SYSTEM / COMPONENT (S) FOR WHICII ALTERNATE EXAMINATION WILL BE USED Code Classes: All
References:
ASME,Section XI, IWA-2313, (1989 Edition)
Examination Category; All Item Number: All u acription: Alternative Requirements for NDE Personnel Recertification ,
Frequency Component Numbers: All CODE REOUIREMENT IWA-2313 " Certification and Recertification" requires that Level I and Level 11 personnel shall be recertified by qualification examinations every 3 years.
BASIS FOR ALTERNATE EXAMINATION Code Case N-574 extends the recertification period for Level I and Level 11 personnel to 5 years.
The time period between recertification for Level III 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. l 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. ,
l All nondestructive examination personnel will continue to be qualified and certified in l accordance with the 1989 Edition of ASME Section XI (including the required tests for each j Level) with the exception that the period between recertifications will be extended to 5 years.
s ALTERNATE EXAMINATION Pursuant to 10CFR 50.55a(a)(3)(i), IES Utilities requests authorization to use Code Case N-574 as an alternative to the requirements ofIWA-2313. The DAEC will use the recertification frequency delineated in Code Case N-574 in lieu of the requirements ofIWA-2313. Both Level I and Level 11 personnel will be recertified by qualification examinations every 5 years.
APPLICAHLE TIME PERIOD Alternative is requested for the third ten-year interval of the Inservice Inspection Program fbr DAEC.