ML17345A891

Responds to NRC 880621 Ltr Re Violations Noted in Insp Repts 50-254/88-10 & 50-265/88-11.Extensive Review of Personnel Records Showed That 25% Rule Not Applied in Certification of Any NDE Examiners.Adherence to ASME Code Requirements Met

ML17345A891
Person / Time
Site:	Quad Cities
Issue date:	08/15/1988
From:	Bliss H COMMONWEALTH EDISON CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8808300195
Download: ML17345A891 (10)

See also: IR 05000254/1988010

Text

AC CFLEMTED DISTRIBUTION

DEMONSTRATION

SYPH'EM r,P REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)ESSION NBR:8808300195

DOC.DATE: 88/08/15 NOTARIZED:

NO ACIL:50-254

Quad-Cities

Station, Unit 1, Commonwealth

Edison Co.50-265 Quad-Cities

Station, Unit 2, Commonwealth

Edison Co.AUTH.NAME AUTHOR AFFILIATION

BLISS,H.E.

Commonwealth

Edison Co.RECIP.NAME

RECIPIENT AFFXLIATION

Region 3, Ofc of the Director DOCKET I'5000254 05000265 SUBJECT: Responds to NRC 880621 ltr re violations

noted in Xnsp Repts 50-254/88-10

&50-265/88-11.

DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

3 ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES I D RECIPIENT ID CODE/NAME PD3-2 PD INTERNAL: ACRS DEDRO NRR/DLPQ/PEB

11 NRR/DOEA DIR 11 NRR/DREP/RPB

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0 ERMAN, J R G FIL 02 3~ILE 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME ROSS,T AEOD NRR MORISSEAU,D

NRR/DLPQ/QAB

10 NRR/DREP/EPB

10 NRR/DRIS DIR 9A NUDOCS-ABSTRACT

OGC/HDS1 RES/DSIR DEPY-NRC PDR COPIES LTTR ENCL 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 A S A.D D.TOTAL NUMBER OF COPXES~REQUIRED: LTTR 25 ENCL 25

e Commonwealth

Edison One First National Plaza, Chicago, illinois ress ep y to: ost ice ox Chicago, illinois 60690-0767 August 15, 1988 Mr.A.Bert Davis Regional Administrator

U.ST Nuclear Regulatory

Commission

Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Subject: Quad Cities Station Units 1 and 2"Response to IE Inspection

Report Nos.50-254/88010

and 50-265/88011"-2 Reference (a): Letter from J.J.Harrison to Cordell Reed dated June 21, 1988.Dear Mr.Davis: This letter is in response to the inspection

conducted by the Nuclear Regulatory

Commission (NRC)Nondestructive

Examination (NDE)Mobile Team of NRC's Region I Office on April 18 through April 29, 1988 of activities

at Quad Cities Station Units 1 and 2.The referenced

letter indicated that no violations

of NRC requirements

were identified

in the course of the inspection.

However, the letter did require Commonwealth

Edison Company to provide a written response to Unresolved

Item No.50-265/88011-04 (use of SNT-TC-lA 25'b rule).The Inspection

Report did not establish a date by which a response was required.In a July 15, 1988 telephone conversation

between Ms.I.M.Johnson of my staff and Mr.D.Danielson of your staff, it was mutually agreed that a response would be supplied by August 15, 1988.The Commonwealth

Edison Company response to that Unresolved

Item is provided in Attachment

A.office.If you have any questions regarding this matter, please contact this H.E.liss Nuclear Licensing Manager lm Attachment

A cc: NRC Resident Inspector-Quad Cities 5015K 8808300195

880815 PDR ADOCK 05000254 0 PDC

V D A routine safety inspection

of station activities

at Quad Cities Station Unit l and 2 was conducted by the NRC NDE Mobile Team of the NRC's Region I office on April l8 through April 29, 1988.A part of the NRC inspection

activities

consisted of a selective examination

of procedures

and representative

records.The NRC inspector, during his review of the Commonwealth

Edison Company's Special Process Procedure Manual (SPPM), made an observation

that the requirements

in Commonwealth

Edison Company's SPPM are not consistent

with or do not meet the intent of the SNT-TC-lA.

As a result, Mr.J.J.Harrison, NRC Region III, requested a written response to the item (No.50-265/88011/04)

in a letter dated June 21, 1988 to Mr.C.Reed, Commonwealth

Edison Company.The NRC Inspector's

observation

pertains to the so called"25%rule" in recommended

Practice No.SNT-TC-lA, June 1980 edition, published by American Society for Non-Destructive

Testing (ASNT)and the requirements

in the procedure 1-1-0, Rev.24 of Commonwealth

Edison's SPPM.The NRC inspector stated that the Commonwealth

Edison Company procedure in the SPPM has improperly

used the SNT-TC-1A 25%rule and that a possibility

exists that Commonwealth

Edison Company NDE personnel could fulfill certification

requirements

without satisfying

the ASME requirements

for minimum experience.

The conclusion

was based on the review of the certification

of one Commonwealth

Edison Company individual

who spent most of his worktime on Quality Control (QC)related activities

not involving actual application

of NDE.The NRC Inspector believed this individual

may have been certified using the 25%rule.The individual

referenced

here is actually certified as a"Radiographic

Interpreter", a special category of NDE personnel identified

in Commonwealth

Edison Company's SPPM.Commonwealth

Edison believes that application

of the 25%rule and qualification

requirements

of"RT Interpreters" are two separate issues and will be treated as such in our response which follows: Table 6.2.1A of SNT-TC-lA contains a statement,"credit for ezperience

spend at least~~r~<of his worktime on~discipline

for which experi-ence is being claimed." This provision has been incorporated

into procedure 1-1-0, paragraph 6.1.1 of Commonwealth

Edison Company's SPPM in which it is required that"an individual

may gain field experience

in~w or maxed NDE on~NDE method for which field experience

is being claimed".This clearly shows that Commonwealth

Edison Company's requirements

in the SPPM are consistent

with those in the SNT-TC-lA.

l

A review was performed, at the NRC's request, of the qualification

and certification

of all present and past Commonwealth

Edison Company personnel where the SNT-TC-1A 25%rule was used.The results of the review of the certification

records showed that, of the seventeen NDE inspectors

within the Commonwealth

Edison system, six work in System Materials Analysis Department (SMAD)which is a group dedicated full time to performing

NDE.The remaining eleven are assigned to various generating

stations.Of those eleven, eight are qualified and experienced

individuals

who were hired into Edison from outside NDE Companies.

It is our understanding

that the question of adequancy of training and experience

pertains to neither the SMAD NDE group nor with respect to experienced

inspectors

recruited from outside testing companies.

The question was raised in regard to those Commonwealth

Edison Company qualified individuals

who are not full time NDE personnel.

Our records show only three inspectors

who fall into this category.Two are certified to perform only penetrant testing (PT)and one is certified to perform PT and MT (magnetic particle testing).If the provision in the SPPM and SNT-TC-1A for simultaneous

qualification

using the 25%rule was to be used, it would have been in the case of this one individual

who is certified in both PT and MT.The review of his certification

showed that the 25'b rule'He had logged one month work experience

as defined in the SPPM for each discipline

gypsy.before he was certified as a Level 1 inspector.

He also worked an additional

two months as a Level 1 PT inspector before becoming a Level II PT inspector, and an additional

3 months as a Level 1 MT inspector before being certified as a Level II MT inspector.

Even though Commonwealth

Edison Company's SPPM provides for use of the 25 percent rule as stated above, a review of personnel Edison Company qualified inspectors.

A special subcategory

of NDE personnel certified as"Radiographic

Interpreter" is identified

in the SPPM.This special"RT Interpreter" category was created to develop individuals

who would have sufficient

knowledge of RT method to review radiographic

work done by outside testing contractors.

As specified in Commonwealth

Edison Company's"written practice" (SPPM), an"RT Interpreter's" duties are limited to reviewing the radiographic

work performed by the others to ensure that radiographs

are of good quality and that proper codes and standards have been followed and that defects have been properly identified

and evaluated.

These RT Interpreters

are neither trained to perform actual radiography

nor are they allowed to specify techniqes or test parameters.

We believe that with these limitations, the subcategory

of RT Interpreter, is acceptable

and meets the intent of the code because:It is permissible

according to the SNT-TC-1A recommended

practice to create subcategories

of NDE personnel depending upon the employer's

special needs provided the duties, responsibilities, qualifiction

requirements, and any limitations

on their certification

are described in the employers w

b.Paragraph IWA-2300.a.3

of ASME Section XI, Winter 80 Addenda, states that,"........training

for NDE personnel who perform'f a non-destructive

examination

method that contains more than one operation, or who perform non-destructive

examination

of limited scope, may be less than that recommended

in Table 6'.1A of SNT-TC-lA We believe that reading and reviewing radiographs

is only one aspect of multiple tasks involved in radiographic

testing.Our RT Interpreters

receive extensive classroom training and they spend a minimum of three months reviewing r'ediographs

under the supervision

of an experienced

and certified RT person.Finally, they take a practical film interpretation

test to demonstrate

their ability to Commonwealth

Edison Company's Chief Level III before being certified as Level II RT Interpreter.

These Interpreters

played a valuable role in overviewing

quality of a voluminous

amount of RT work performed by the contractors

during Commonwealth

nuclear plant construction

program.Commonwealth

Edison's program for qualification

and certification

of the personnel involved in NDE related activities

was designed to provide various degrees of NDE expertise to fulfill our needs.In addition to SMAD's NDE group, all nuclear plants need some personnel in their QC, QA, ISI and Tech Staff groups to be familiar with some, if not all, aspects of NDE disciplines

in order to control the overall quality of the NDE work done at their respective

plants.Our program as defined in the SPPM provides rules for the training and certification

of those"limited" NDE personnel as well as defining the rules for qualification

of actual"Examiners

or Testers" which are, we believe, in strict accordance

with the ASME Code.The extensive review of personnel records showed that 25%rule was not applied in certification

of any of the NDE examiners.

The"RT Interpreters" subcategory

of NDE personnel is permissive

by the ASME Code and meets the intent of SNT-TC-lA recommended

practice.5015K