0CAN089401, Requests Use of ASME Code Cases N-416-1 & N-498-1,per 10CFR50.55a(a)(3)
| ML20072F443 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 08/12/1994 |
| From: | Mims D ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 0CAN089401, CAN89401, OCAN89401, NUDOCS 9408230339 | |
| Download: ML20072F443 (4) | |
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August 12,1994 0CAN089401 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station PI-137 Washington, DC 20555
Subject:
Use of ASME Code Cases N-416-1 and N-498-1 Arkansas Nuclear One - Units I and '
Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 River Bend Station Docket No. 50 458 j
License No. NPF-47 Gentlemen:
The purpose of this submittal is to request approval, pursuant to 10CFR50.55a(a)(3), for the use of the American Society of Mechanical Engineers (ASME) Code Cases N-416-1 and N-498-1 as alternatives to the ASME Section XI Code requirements in effect at all of Entergy Operations' nuclear units, i.e., Arkansas Nuclear One, Units 1 and 2 (ANO),
Grand Gulf Nuclear Station, Waterford 3 Steam Electric Station, and River Bend Station.
Code Case N-416-1 was approved for use on February 15,1994, by the ASME Board of Nuclear Codes and Standards and is included in Supplement 8 of the Nuclear Code Case Book for the 1992 edition of the Code. Code Case N-498-1 was approved by the ASME Board of Nuclear Codes and Standards on May 11,1994, but has not yet been published.
Neither code case has yet been added to the approved list of code cases included in NRC rs.,
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U. S. NRC August 12,1994 0CAN089401 Page 2 Regulatory Guide 1.147," Inservice Inspection Code Case Acceptability - ASME Section XI Division 1."
Code Case N-4161, " Alternative Pressure Test Requirement for Welded Repairs or Installation of Replacement items by Welding," addresses the use of a system leakage test as an alternative in lieu of performing the hydrostatic pressure test required by IWA-4000 for Class 1,2, and 3 components, provided certain requirements are met.
Code Case N-498-1, " Alternative Rules for 10-Year System Hydrostatic Pressure Testing for Class I,2, and 3 Systems," utilizes leakage (Class 1) and pressure (Class 2 and 3) tests, in conjunction with other requirements, as an acceptable alternative to 10-year hydrostatic pressure tests.
The alternative pressure tests permitted by these code cases fulfill the same purpose as a hydrostatic pressure test, i.e., a check for component / system leakage. To perform a hydrostatic test, a pressure above normal operating pressure is required; therefore, the
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alTected system must be placed in a non-conventional configuration to support, isolate, or obtain this elevated pressure. Since system pressure tests are performed at operating pressure, the probability of challenging the pressure integrity of any afTected component, or causing the actuation of any system safety valve, is reduced from that of a hydrostatic test. Testing at operating pressure also eliminates the need to " gag" or remove system pressure relief valves, as is currently necessary to comply with the higher pressure requirements for hydrostatic tests. The elimination of" gagging" or valve removal reduces the possibility of damaging the afTected relief valves, thereby causing system leakage or valve inoperability. Additionally, elimination of hydrostatic tests minimizes the shutdown risk due to non-conventional system configurations. Based upon the preceding, Entergy Operations has determined that the proposed alternatives will provide an acceptable level of quality and safety as required by 10CFR50.55a(a)(3)(i).
ANO-1 is the first of Entergy Operations' nuclear units to be able to utilize these code cases, with its twelllh refueling outage (IR12) currently scheduled to begin on February 14,1995. Approval of Entergy Operations' request to use these code cases prior to IR12 will save approximately $525,000 ($14,000 for N-416-1 and $511,000 for the Class 3 hydros covered by N-498-1) at ANO-1. This amount includes the cost of one day of critical path time due to the 10-year hydrostatic tests of the service water system.
Throughout the life of the two ANO units, elimination of the hydrostatic tests covered by these two code cases are expected to save in excess of $3,495,000. Similar cost savings, reduced for single unit operation, are expected at Entergy Operations' other nuclear units.
Due to the significant cost savings to be achieved by the use of these code cases, as well as the marginal increase in safety caused by implementation, Entergy Operations requests that this submittal be considered a cost beneficial licensing action (CBLA).
Should you have any questions regarding this submittal, please contact me.
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U.S.NRC August 12,1994 OCAN089401 Page 3 Very truly yours, keyNC.W/J Dwight C. Mims Director, Licensing DCM/jjd cc:
Mr. Leonard J. Callan Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Stewart D. Ebneter Regional Administrator
-l U. S. Nuclear Regulatory Commission Region 11 101 Marietta St., N. W., Suite 2900 Atlanta, GA 30323 NRC Senior Resident Inspector Aikansas Nuclear One 1448 S. R. 333 Russellville, AR 72801 NRC Resident Inspector's 00 ice Waterford 3 Steam Electric Station Trailer 426 Post 00 ice Box B Killona, LA 70066 NRC Resident Inspector's 00 ice River Bend Station Post ORice Box 1051 St. Francisville, LA 70775
U. S. NRC August 12,1994 OCAN089401 Page 4 4
Mr. George Kalman NRR Project Manager Region IV/ANO-l & 2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3
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One White Flint North l1555 Rockville Pike Rockville, MD 20852 Mr. P. W. O'Connor NRR Project Manager Grand Gulf U. S. Nuclear Regulatory Commission 00 ice of Nuclear Reactor Regulation NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. David Wiggington NRR Project Manager, Region IV/W3 U. S. Nuclear Regulatory Commission 00 ice of Nuclear Reactor Regulation NRR Mail Stop 13-H-3 One White Flint LNonh 11555 Rockville Pike Rockville, MD 20852 Mr. Ramon Azua NRR Project Manager, Region IV/R13 U. S. Nuclear Regulatory Commission 00 ice of Nuclear Reactor Regulation NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Eugene Imbro Cl3LA Task Force U. S. Nuclear Regulatory Commission l
00 ice of Nuclear Reactor Regulation j
NRR Mail Stop 9-A-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852