ML021200050

Relief Request No. CR-38, Inservice Inspection Program Relief Re 10-Hour Annual Training Requirement

ML021200050
Person / Time
Site:	Quad Cities
Issue date:	05/22/2002
From:	Anthony Mendiola NRC/NRR/DLPM/LPD3
To:	Skolds J Exelon Generation Co
Lyon C, NRR/DLPM, 415-2296
References
TAC MB4768, TAC MB4769
Download: ML021200050 (9)

Text

May 22, 2002 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - RELIEF REQUEST NO. CR-38, INSERVICE INSPECTION PROGRAM RELIEF REGARDING 10-HOUR ANNUAL TRAINING REQUIREMENT (TAC NOS. MB4768 AND MB4769)

Dear Mr. Skolds:

By letter dated April 8, 2002, Exelon Generation Company, LLC (EGC or the licensee) submitted Relief Request CR-38 related to the Third 10-Year Interval Inservice Inspection (ISI)

Program for Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2. In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the 10-hour annual training requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code)Section XI, 1995 Edition with 1996 Addenda, Appendix VII, for personnel performing ultrasonic testing.

Based on the information provided in Relief Request CR-38, the Nuclear Regulatory Commission (NRC) staff concludes that the proposed alternative will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the licensees proposed alternative for the third 10-year ISI interval for Quad Cities Units 1 and 2, which is scheduled to conclude on February 17, 2003, and March 9, 2003, respectively.

The enclosed safety evaluation provides the basis for this determination. If you have any questions concerning this action, please call Mr. F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265

Enclosure:

Safety Evaluation cc w/encl: See next page

May 22, 2002 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - RELIEF REQUEST NO. CR-38, INSERVICE INSPECTION PROGRAM RELIEF REGARDING 10-HOUR ANNUAL TRAINING REQUIREMENT (TAC NOS. MB4768 AND MB4769)

Dear Mr. Skolds:

By letter dated April 8, 2002, Exelon Generation Company, LLC (EGC or the licensee) submitted Relief Request CR-38 related to the Third 10-Year Interval Inservice Inspection (ISI)

Program for Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2. In accordance with 10 CFR 50.55a(a)(3)(i), the licensee proposed an alternative to the 10-hour annual training requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (Code)Section XI, 1995 Edition with 1996 Addenda, Appendix VII, for personnel performing ultrasonic testing.

Based on the information provided in Relief Request CR-38, the Nuclear Regulatory Commission (NRC) staff concludes that the proposed alternative will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the licensees proposed alternative for the third 10-year ISI interval for Quad Cities Units 1 and 2, which is scheduled to conclude on February 17, 2003, and March 9, 2003, respectively.

The enclosed safety evaluation provides the basis for this determination. If you have any questions concerning this action, please call Mr. F. Lyon of my staff at (301) 415-2296.

Sincerely,

/RA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC OGC PDIII/2 r/f ACRS A. Mendiola M. Ring, RIII C. Rosenberg T. Chan F. Lyon G. Hill(2)

T. Bergman ADAMS ACCESS NO. ML021200050 OFFICE PDIII-2/PM PDIII-2/LA EMCB/SC OGC PDIII-2/SC NAME FLyon THarris for CRosenberg TChan RHoefling AMendiola DATE 05/ 02/02 05/02/02 05/09/02 05/16/02 05/22/02 OFFICIAL RECORD COPY

Quad Cities Nuclear Power Station Units 1 and 2 cc:

Site Vice President - Quad Cities Nuclear Power Station Exelon Generation Company, LLC 22710 206th Avenue N.

Cordova, IL 61242-9740 Quad Cities Nuclear Power Station Plant Manager Exelon Generation Company, LLC 22710 206th Avenue N.

Cordova, IL 61242-9740 Regulatory Assurance Manager - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.

Cordova, IL 61242-9740 Quad Cities Resident Inspectors Office U.S. Nuclear Regulatory Commission 22712 206th Avenue N.

Cordova, IL 61242 William D. Leech Manager - Nuclear MidAmerican Energy Company P.O. Box 657 Des Moines, IA 50303 Vice President - Law and Regulatory Affairs MidAmerican Energy Company One River Center Place 106 E. Second Street P.O. Box 4350 Davenport, IA 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.

Rock Island, IL 61201 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351 Illinois Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, IL 62704 Document Control Desk-Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President Mid-West Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director - Licensing Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

Quad Cities Nuclear Power Station Units 1 and 2 Senior Counsel, Nuclear Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Dresden and Quad Cities Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. CR-38 EXELON GENERATION COMPANY, LLC QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265

1.0 INTRODUCTION

The inservice inspection (ISI) of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) Class 1, Class 2, and Class 3 components is to be performed in accordance with Section XI of the ASME Code and applicable edition and addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of record for Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2, is the ASME Code Section XI, 1989 Edition, for both units. The third 10-year interval for Units 1 and 2 is scheduled to conclude on February 17 and March 9, 2003, respectively.

By letter dated April 8, 2002, Exelon Generation Company, LLC (the licensee), requested relief from certain ultrasonic testing (UT) requirements pertaining to UT performance qualification for the third 10-year ISI interval at Quad Cities. Specifically, the licensees request for relief CR-38 proposed conducting annual UT training in accordance with 10 CFR 50.55a(b)(2)(xiv).

2.0 RELIEF CR-38, SUBSUBARTICLE VII-4240 ANNUAL TRAINING FOR UT PERSONNEL 2.1 Code Requirements for which Relief is Requested The licensee is requesting relief from the 1995 Edition with 1996 Addenda, Appendix VII to Section XI of the Code, Subsubarticle VII-4240 for all UT personnel. Subsubarticle VII-4240 requires a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual UT training.

2.2 Licensees Proposed Alternative to Code Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee proposed conducting annual UT training in accordance with 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsubarticle VII-4240 of Section XI of ASME Code, 1995 Edition with 1996 Addenda, Appendix VII. Annual ultrasonic training in accordance with 10 CFR 50.55a(b)(2)(xiv) would require that all personnel qualified for performing ultrasonic examinations in accordance with Section XI of the ASME Code, Appendix VIII, receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens that contain cracks. This training must be completed no earlier than 6 months prior to performing ultrasonic examinations at a licensees facility.

2.3 Licensees Bases for Requesting Relief (as stated)

On September 22, 1999, the Nuclear Regulatory Commission (NRC) published a final rule in the Federal Register (64 FR 51370) to amend 10 CFR 50.55a(b)(2), to incorporate by reference the 1995 Edition and addenda through the 1996 Addenda, of Section XI of ASME Code. The change included the requirement to have a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training contained in Subsubarticle VII-4240 of Section XI of ASME Code.

Additionally, the September 22, 1999, Federal Register notice amended 10 CFR 50.55a(b)(2)(xiv). The amended 10 CFR 50.55a(b)(2)(xiv) requires that all personnel qualified to perform ultrasonic examinations in accordance with Appendix VIII of the ASME Code shall receive 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of annual hands-on training on specimens that contain cracks. This training must be taken no earlier than 6 months prior to performing examinations at a licensees facility. Paragraph 2.4.1.1.1 in the Federal Register notice contained the following statement which includes a discussion of the Electric Power Research Institute Performance Demonstration Initiative (PDI) program.

The NRC had determined that this requirement (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of training on an annual basis) was inadequate for two reasons. The first reason was that the training does not require laboratory work and examination of flawed specimens. Signals can be difficult to interpret and, as detailed in the regulatory analysis for this rulemaking, experience and studies indicate that the examiner must practice on a frequent basis to maintain the capability for proper interpretation. The second reason is related to the length of training and its frequency. Studies have shown that an examiners capability begins to diminish within approximately 6 months if skills are not maintained. Thus, NRC had determined that 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training is not sufficient practice to maintain skills, and that an examiner must practice on a more frequent basis to maintain proper skill level.... The PDI program has adopted a requirement for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of training, but it is required to be hands-on practice. In addition, the training must be taken no earlier than 6 months prior to performing examinations at a licensees facility. PDI believes that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will be acceptable relative to an examiners abilities in this highly specialized skill area because personnel can gain knowledge of new developments, material failure modes, and other pertinent technical topics through other means. Thus, the NRC has decided to adopt in the Final Rule the PDI position on this matter. These changes are reflected in 50.55a(b)(2)(xiv) of the final rule.

Implementation of the training requirements contained in Subsubarticle VII-4240 of Section XI of ASME Code, 1995 Edition with the 1996 Addenda, Appendix VII and 10 CFR 50.55a(b)(2)(xiv) will result in redundant training programs.

2.4 Evaluation Subsubarticle VII-4240, Appendix VII of Section XI of the Code requires 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training to impart knowledge of new developments, material failure modes, and any pertinent technical topics as determined by the licensee. No hands-on training or practice is required to be included in the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of training. This training is required of all UT personnel qualified to perform examinations of ASME Code Class 1, 2, and 3 components. Independent of the ASME Code, 10 CFR 50.55a(b)(2)(xiv) imposes the requirement for Appendix VIII qualification that 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on training with flawed specimens containing cracks be performed no earlier than 6 months prior to performing examinations at a licensees facility. The licensee contends that maintaining two separate UT annual training programs for Appendix VIII and non-Appendix VIII qualifications create redundancies in training programs.

As part of the staffs rulemaking effort to revise 10 CFR 50.55a(b)(2), the issue of UT annual training requirements was reviewed. This review was included in the summary of comments to the rule that was published in the Federal Register on September 22, 1999, (64 FR 51370). In the review, the staff determined that the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of annual training requirement specified in the ASME Code was inadequate for the two reasons quoted in the licensees basis for relief (Section 2.3 above). In resolving public comment to the rulemaking, the staff adopted a recommendation advanced by the nuclear power industry which proposed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of hands-on practice with specimens containing cracks. This practice would occur no earlier than 6 months prior to performing examinations at a licensees facility. These recommendations were accepted by NRC and are reflected in 10 CFR 50.55a(b)(2)(xiv). The staff has determined that the proposed alternative to use 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsubarticle VII-4240 will maintain the skill and proficiency of UT personnel at or above the level provided in the Code for annual UT training, thereby, providing an acceptable level of quality and safety.

3.0 CONCLUSION

Based on the discussion above, the staff concludes that the proposed alternative to use the requirements in 10 CFR 50.55a(b)(2)(xiv) in lieu of Subsubarticle VII-4240 for annual UT training will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the alternative proposed by Relief Request CR-38 is authorized for the third 10-year ISI interval for Quad Cities, Units 1 and 2, which is scheduled to conclude on February 17 and March 9, 2003, respectively.

Principal Contributor: F. Lyon Date: May 22, 2002