ML20154B721

Safety Evaluation Approving Licensee Request to Implement Alternatives Contained in Code Case N-546 for Current Interval at Songs,Units 2 & 3 Until Code Case Approved by Ref in Reg Guide 1.147

ML20154B721
Person / Time
Site:	San Onofre
Issue date:	10/01/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20154B713	List: ML20154B710 ML20154B721
References
RTR-REGGD-01.147, RTR-REGGD-1.147 NUDOCS 9810050286
Download: ML20154B721 (4)

Text

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@ Rfc p UNITED STATES l, ;r NUCLEAR REGULATORY COMMISSION

~. WASHINGTON. D.C. 3000H001

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SAFETY EVALUATION BY PE OFFICE OF NUCLEAR REACTOR REGULATION i

RELATED TO A REQUEST TO USE AN ALTERNATNE TO ASME CODE SECTION XI i SOUTHERN CALIFORNIA EDISON COMPANY l

SAN ONOFKF NUCLEAR GENERATING STATION. UNITS 2 AND 3 i

DOCKET NOS. 50-361 AND 50-362

1.0 INTRODUCTION

i The technical specifications for the San Onofre Nuclear Generating Station (SONGS) Units 2 I and 3 state that the inservice inspection of the American Society of Mechanical Engineers 1 (ASME) Code Class 1,2, and 3 components shall be performed in accordance with Section XI

! of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission j pursuant to 10 CFR 50.55a(g)(6)(l). Section 50.55a(a)(3) states that attematives to the i j requirements of paragraph (g) may be used, when authorized by the NRC, if (i) the proposed altematives would provide an acceptable level of quality and safety, or (ii) compliance with the i specified requirements would result in hardship or unusual difficulties without a compensating l increase in the level of quality and safety.

l Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including i supports) shall meet the requirements, except the design and access provisions and the

preservice examination requirements, set ic th in the ASME Code,Section XI, " Rules for l 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 j regulations require that inservice examination of components and system pressure tests

conducted during the first 10-year interval and subsequent intervals comply with the ,

i requirements in the lateet edition and addenda of Section XI of the ASME Code incorporated by f reference in 10 CFR 50.ub(b) 12 months prior to the start of the 120-month interval, subject to the limitations end modifications listed therein. The applicable edition of Section XI of the ASME Code for SONGS Units 2 and 3 is the 1989 Edition with no addenda and the plants are in their second interval. If a licensee determines that conformance with certain code requirements is impractical for its facility, it may submit information pursuant to 10 CFR 50.55a(g)(5)(iii) to support the determination. Pursuant to 10 CFR 50.55a(g)(6)(i), the Commission will evaluate determinations ofimpracticality and may grant relief and impose alternative requirements as it determines are authorized by law and will not endanger life or property giving due consideration to the burden upon the licensee that could result if he requirements were imposed.

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9810050286 961001 PDR ADOCK 05000361 p PDR f

, The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Commission approval.

In a letter dated November 13,1996, Southern California Edison (SCE) submitted to the NRC a request for relief related to the respective 10-year interval inservice inspection to implement Code Case N-546 "Allemative Requirements for Qualification of VT-2 Examination Personnel, Section X/, Division 1," for SONGS Units 2 and 3. This request was supplemented by a letter  !

dated June 9,1998.

2.0 LICENSEE'S REQUEST FOR RELIEF Code Reauirement: Section XI, IWA-2300, requires that personnel performing VT-2 and VT-3 visual examinations be qualified in accordance with comparable levels of competency as defined in ANSI N45.2.6. Additionally, the examination personnel shall have natural or corrected near distance vision acuity, in at least one eye, equivalent to a Snellen fraction of 20/20. For far vision, personnel shall have natural or corrected far distance visual acuity of 20/30 or equivalent.

Licensee's Code Relief Reauest: The licensee has requested approval to implement alternatives to the Code requirements contained in Code Case N-546, Alternative Requirement for Qualification of VT-2 Examination Personnel, which is not yet approved by the NRC by reference in Regulatory Guide 1.147.

Licensee's Basis for Reauestina Relief (as stated):

"By code Case N-546, the ASME committee has established attemative qualifications to current industry standards (i.e., ANSO N45.2.6, ANSI SNT-TC-1 A, or ASNT CP-189) for VT-2 visual examination personnel. The proposed alternative qualifications provide an acceptable level of quality and safety. Specifically, the examination personnel will have at least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant walkdown experience, receive a minimum of four hours of training on Section XI requirements and plant specific procedures for VT-2 visual examinations, and will pass the vision test requirements of IWA-2321,1995 edition.

This attemative to the requirements allows the Station to utilize other experienced plant personnel to perform VT-2 Examinations. The Code Case is offering specific relief in the certification process. Under the provisions of this Code Case, experienced plant personnel may be qualified as VT-2 examiners and the certification program administered in a simpler, routine manner. Additionally, the code currently requires 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of training administered every three i years. The Code Case requires that experienced plant personnel be trained for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This is a. suffiecient amount of time to train experienced plant personnel in the special aspects of ASME Section XI."

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.' Licensee's Prooosed Alternative Examination (as stated):

"As specified in Code Case N-546, personnel shall be qualified in accordance with the following requirements:

(a) At least 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> of plant walkdown experience, such as that gained by licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel.

(b) At least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of training on Section XI requirements and plant specific procedures for VT-2 visual examination.

(c) Vision test requirements of IWA-2321,1995 Edition."

j 3.0 EVALUATION The Code requires that VT-2 visual examination personnel be qualified to comparable levels of competency as defined in ANSI N45.2.6. The Code also requires that the examination personnel be qualified for near and far distance vision acuity.

The qualification requirements in Code Case N-546 are comparable to those qualifications required for VT-2 visual examiner certification. Licensed and nonlicensed operators, local leak rate personnel, system engineers, and inspection and nondestructive examination personnel typically have a sound working knowledge of plant components and piping layouts. This  ;

knowledge makes them acceptable candidates for performing VT-2 visual examinations.

The licensee is implementing a program that documents the qualifications, training, and visual acuity of persons selected to perform the VT-2 visual examinations. In addition, in its June 9, 1998, submittal, the licensee stated that it would develop and implement formal procedures to ensure that consistent VT-2 examinations are performed and that evaluations of program ,

effectiveness will be conducted by persons other than those that performed the VT-2 examinations. The licensee also indicated that it would document and maintain records to verify that the persons selected.to conduct the examinations are qualified.

Based on a review of Code Case N-546, the staff believes that the attematives to the Code qualification requirements for examination personnel, will provide an acceptable level of quality and safety in that persons will possess qualifications acceptable for performing VT-2 visual examinations. Therefore, SCE's request to implement attematives contained in Code is acceptable.

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4.0 CONCLUSION

The staff has reviewed the licensee's request otoe requirements implement altematives contained in Code Case N-546, "Altemative Requirement for Qualifica Personnel." The alternatives contained in Code Case -

N-546 xamination e en acceptable level of will provid Code Case N-546 is hereby authorized .

ned in pursuant t 2N-546 is authorized for Code the current interval byat the San in ROno se of Code Case and 3, until such time as the Case is approved ra ng Station, reference Units At that time, if the licensee intends to continue to implement egulatory this Code Ca Guide 1.147.

follow all provisions in Code Case N-546 with any. se,limitations the licensee is toissued in Regu a ory Guide 1.147, if Principal Contributor: T. McLellan Date: October 1, 1998

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