ULNRC-03538, Submits Comments on Proposed GL on Effectiveness of Ultrasonic Testing Systems in Inservice Insp Programs

Submits Comments on Proposed GL on Effectiveness of Ultrasonic Testing Systems in Inservice Insp Programs

ML20135C331
Person / Time
Site:	Callaway
Issue date:	02/27/1997
From:	Naslund C UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-03538, ULNRC-3538, NUDOCS 9703030501
Download: ML20135C331 (4)

Text

'"'* Cattaway hant Pcst Offsw Bu 620 fatton. Missoun CS251 Union Etucruic E February 27,1997 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 ULNRC-03538 Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY P.LANT UNIT 1 FACILITY OPERATING LICENSE NPF-30 Proposed Generic Communication; Effectiveness of Ultrasonic Testing Systems in ,

Inservice Inspection Programs, (61 Fed. Reg. 69120-December 31,1996 and 62 Fed.

Reg. 3064-January 21,1997) Notice of Opportunity for Public Commeg This letter details Union Electric's comments on the subject of th< NRC's proposed Generic Letter on the " Effectiveness of Ultrasonic Testing Syster s in Inservice Inspection Programs." Union Electric believes that the NRC has not adequatelyjustified the request for licensee actions cited in the proposed Generic Letter for the following reasons:

. The proposed Generic Letter requests licensees to implement a performance based ultrasonic test qualification program similar to Appendix VIII, even though Appendix VIII has not been incorporated into the regulations. The letter places the licensee in a f position ofjustifying not responding in the preferred manner rather than the NRC /

justifying the backfit of Appendix VIII. This implies that the proposed Generic Letter IO is not a request to comply with Appendix VIII, but a requirement to comply.

• The use of the 10 CFR 50.109(a)(4)(i) compliance exemption is inappropriate, since the proposed generic letter relies on a new regulatory position as to what constitutes compliance. Therefore, a backfit analysis per 10 CFR 50.109(a)(3) should be performed by NRC.

. The change to the performance based qualification program directe:1 by the proposed generic letter would rer".!t in licensees violating the ASME rules specified by the nu.

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, February 27,1997 l Page 2 j l

edition and addenda currently committed to as required by 10 CFR 50.55a unless a 10  !

CFR 50.55a(a)(3) alternative is approved by the NRC.  !

l Union Electric Company supports the letter submitted by David J. Modeen of the Nuclear  ;

Energy Institute (NEI) dated February 21,1997, on the subject of the NRC's proposed j Generic Letter on the "Eff'ectiveness of Ultrasonic Testing Systems in Inservice Inspection  ;

Programs", with one exception. Implementation ofPerformance Demonstration Initiative {

(PDI) methods in their entirety is impractical due to technical and programmatic >

inconsistencies that still need to be rectified.

Failure of PDI to address single-sided weld examination, cumbersome provisions for the l

addition of new technology to the essential variable list, a lack ofPDI qualified exam,mers, l and the inordinate cost of qualifying personnel and equipment to PDI, are issues that still i need to be resolved. Therefore, voluntary implementation of selected portions of PDI is the only practical approach available to utilities if the NRC requires compliance with

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Appendix VIII.

If you have any questions concerning this letter, please contact Mathew Rice, Callaway Plant Inservice Inspection Engineer at (573) 676-8539, i

a 1 Cl ules D. Nislund Manager, Nuclear Engineering CDN/kkg Enclosure l

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ULNRC-03538

, February 27,1997 Page 3 cc: U. S. Nuclear Regulatory Commission (Original and I copy)

Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 Mr. James E. Dyer Regional Administrator U.S. Nuclear Regulatory Commission RegionIV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman,MO 65077 Ms. Kristine M. Thomas (2 copies)

Licensing Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission 1 Mail Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.

Washington,DC 20037 1

f e L ULNRC-03538

, February 27,1997 Page 4 bec: D. F. Schnell (400) wo  !

G. L. Randolph w/o  ;

J. V. Laux/G. A. Hughes w/a A. C. Passwater/D. E. Shafer (470) w/o  :

M. P. Barrett (100) w/o P. L. Reynolds (470) NSRB w/a H. D. Bono w/a CDN Chrono D. S. Hollabaugh M. M. Rice '

E210.0001 A160.0761 Manager, Plant Support w/o Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839 j

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