ML20115H502

Forwards Revised Pilgrim Relief Request (PRR)-24 Re Third Ten-Yr ISI Program

ML20115H502
Person / Time
Site:	Pilgrim
Issue date:	07/12/1996
From:	Boulette E BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LTR-2.96-067, LTR-2.96-67, NUDOCS 9607230159
Download: ML20115H502 (5)

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Boston Edison Pilgrim Nuclear Power Station Rocky Hill Road l Plymouth, Massachusetts 02360 l

i E. T. Boulette, PhD July 12, 1996 senior vice President - Nuclear BECo Ltr. #2.96- 067 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Docket No. 50-293  !

License No. DPR-35 I Revised Pilurim Relief Reauest (PRR) - 24.

Pilgrim Third Ten-Year Inservice Inspection (ISI) Program 4

The attachment to this letter provides our revised PRR - 24 for NRC approval. .This revision includes clarifications on our implementation of ASME Section XI, Appendix Vll requirements as discussed in a telephone call on June 21,1996, with the NRC, Boston Edison Company (BECo), and the Idaho National Engineering Laboratory. This relief request relates to our Third Ten-Year ISI Program  ;

submitted to the NRC by BECo Letter # 95-091, dated September 1,1995.  !

BECo previously requested relief from implementing Appendix VII until the performance demonstration requirements of Appendix VIII are fully implemented. Since the NRC has not endorsed Appendix VIII and was planning to deny our relief request, we have decided to revise our  ;

relief request and fbily implement Appendix Vll requirements. l Our Third Ten-Year ISI interval began on July 1,1995, and the annual training for our Nondestructive Examination (NDE) personnel should have been completed by June 30,1996, to l meet the Appendix VII requirements. Since the required NDE instructor training course is not j readily available, we require relief from the annual training requirement of Appendix VII, Paragraph l VII-4230, from July 1995 to December 1996. We will be in full compliance with Appendix VII by )/

June 1997, for the subsequent annual training as explained in the attached revised relief request. [h !i If you have any questions regarding the information contained in this lette , ease ontact Walter I Lobo at (508) 830-7940. ,

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9Aa7230159 960712 PDR ADOCK 05000293 E. T. Boulette, PhD G t'OR ETB\WJL\radmisc\isiprgm

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l cc: Mr. Alan B. Wang, Project Manager Project Directorate I-l  :

Office of Nuclear Reactor Regulation l

Mail Stop: 14B2 U. S. Nuclear Regulatory Commission i

1 White Flint North 11555 Rockville Pike I Rockville, MD 20852 '

U.S. Nuclear Regulatory Commission Region I l

475 Allendale Road 1 King of Prussia, PA 19406 S

Senior Resident Inspector I Pilgrim Nuclear Power Station i

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Pilgrim Station 3rd Interval Inservice Inspection Plan RELIEF REOUEST NUMBER: PRR-24 REVISION 1

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COMPONENT IDENTIFICATION Code Classes: I and 2

References:

IWA-2311(b) and Appendix VII Examination Categories: B-A, B-D, B-F, B-G-1, B-J, B-M-1, B-O C-A, C-B, C-F-1, C-F-2 l

Item Numbers: Bl.11, Bl.12, Bl .21, Bl .22, B l.30, Bl.40, B2.90, B3.100, B5.10, B5.130, B6.20, B6.30, B6.40, B6.180, B9.11, B9.12, B9.31, B12.40, B14.10 C1.10, C1.20, C5.11, C5.51

Description:

Exemption from the schedule requirement of Appendix VII, Paragraph VII-4240, Annual Training i Component Numbers: All Class 1 and 2 components requiring ultrasonic examination CODE REOUIREMENT ,

i Sub-paragraph IWA-2311(b) specifies that the training, qualification, and certification of l l l ultrasonic examination personnel shall also comply with the requirements of Appendix VII.

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! Appendix VII provides requirements for the employer's written practice, qualification of ultrasonic examiners, qualification records, and the minimum content ofinitial training courses for the ultrasonic examination method in addition to those required in SNT-TC-1 A.

l BASIS FOR RELIEF Our Third Ten-Year Inservice Inspection interval began on July 1,1995, and the annual trammg l l for our NDE personnel should be complete by June 30,1996, to comply with Paragraph VII-4240. Since we do not have an instructor qualified to Paragraph VII-4140 and the next readily l available course is in November 1996, it was not practical to meet the annual training requirements by June 30,1996. Thus, Boston Edison requests relief from the schedule from July 1995 to December 1996, to comply with the annual training requirement of Appendix VII, "aragraph VII-4240.

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Pilgrim Station 3rd Interval  ;

Inservice Inspection Plan i RELIEF REOUEST NUMBER: PRR-24 REVISION 1 (Cont)

(Page 2 of 2)

The taining ami certification program to comply with Appendix VII will be fully implemented by ]

June 1997. The program includes course material, procedures and test specimens. We are i revising our training and certification procedure (Quality Assurance Department Procedure No. l 10.09) to meet the requirements of Appendix VII. An individual will complete NDE instmetor i training in November 1996, and we will be in compliance with the subsequent annual training j requirements beginning June 1997. l PROPOSED ALTERNATE PROVISIONS The Enclosure provides a summary of BECo qualified ultrasonic examination personnel. These personnel currently comply with ASME Section XI requirements for ultrasonic qualifications in i accordance with Subarticle IWA-2310 and code interpretation X1-1-924 which recognize the  !

continuity of existing certifications. Thus, BECo fully complies with ASME Section XI by using l the provisions of Subarticle IWA-2310.

As an alternative to meeting the annual training requirement of Paragraph VII-4240, BECo NDE personnel are scheduled in 1996 for a 40-hour ultrasonic course in ASME XI examination methods. The course does not qualify to Appendix VII provisions since the instmetors are not code defined NDE instructors pursuant to Paragraph VII-4140. This 40-hour specialized course is considered to be an equst mbstitute for the 10-hour annual training by a qualified NDE instmetor l

because the course durr, tion, n.aterials and instructor's credentials are at least equivalent to code requirements, resulting in an equal level of quality and safety in the ISI examinations.  ;

1 The 40-hour ultrasonic course and the existing certification of BECo NDE personnel provide adequate basis for conducting the on-line ISI examinations beginning October 1996. Further, the' Appendix VII requirements for Refueling Outage (RFO) #11 examinations, currently planned for Febmary 1997, will be met through the use of qualified BECo contractor personnel. The alternate provision does not impact quality or safety, since ASME Section XI requirements will be met by complying with Paragraphs IWA-2310 and VII-4240 for ISI examinations. Thus, the relief request meets the requirement of 10 CFR 50.55a(a)(3)(i) in that an acceptable level of quality and safety is maintained.

APPLICABLE TIME PERIOD I

l Reliefis requested for the Third Ten-Year interval of the Pilgrim Station Inservice Inspection l l Program beginning July 1,1995 till December 1996 for implementing annual training l requirements. I

Enclosure:

Summary ofBoston Edison Company NDE Qualified Personnel 3 l

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l ENCLOSURE TO PRR-24 Summary of Boston Edison Comoany NDE Oualified Personnel Three individuals are certified in ASME Section XI ultrasonic .xamination methods at '

Boston Edison Company. Below is a summary of their qualifications.

IndividgAal.2

• Certified from 1972 to 1982 as UT Level II while in the U.S.

Navy and Stone & Webster Engineering Corporation.

Certified as an ASNT Level III from 1982 to present (by i examination).  !

Certified as a BECo NDE Level III from 1983 to present (by I examination).

. Documented classroom training in ultrasonic examination is 209 hours0.00242 days <br />0.0581 hours <br />3.455688e-4 weeks <br />7.95245e-5 months <br />.

Individual B e Certified as a NDE Level III from 1980 to present while employed at Stone & Webster Engineering Corporation, Yankee Atomic Electric Company and Boston Edison J l Company (by examination). i

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• Certified as an ASNT Level III from 1984 to present (by  !

examination).

l e Documented classroom training in ultrasonic examination is {

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! 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br />. I

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Individual C e Certified as a Level I in 1992 at Boston Edison Company.

• Certified as a Level II in 1995 at Boston Edison Company. l l

• Documented classroom training in ultrasonic examination is i 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />.

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