Text

Response to RAI on Relief Requests to Use ASME Code Case N-600
	ML040690024
Person / Time
Site:	Indian Point, Pilgrim, Vermont Yankee, FitzPatrick
Issue date:	03/04/2004
From:	Kansler M; Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	BVY 04-022, ENO 2.04.021, JPN-04-005, NL-04-021, TAC MB5403, TAC MB5404, TAC MC0303, TAC MC0336, TAC MC0337, TAC MC0338, TAC MC0339
	Download: ML040690024 (21)
	v • d • e

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Entery 440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President March 4, 2004 JPN-04-005 NL-04-021 ENO 2.04.021 BVY 04-022 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-Pl-17 Washington, DC 20555-0001

SUBJECT:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Indian Point Nuclear Generating Units No. 2 and No. 3 Docket No. 50-247, and 50-286 Pilgrim Nuclear Power Station Docket No. 50-293 Vermont Yankee Nuclear Power Station Docket No. 50-271 Response to RAI on Relief Requests to Use ASME Code Case N-600

References:

1. USNRC letter from Guy S. Vissing to Michael Kansler, regarding "Request for Additional Information Concerning Relief Request to Use American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Case N-600 (TAC NOS. MC0303, MC0336, MC0337, MC0338, and MC0339)", dated January 20, 2004.

2. Entergy letter to NRC, JPN-03-020/NL-03-130/ENO 1.2.03.091/BVY 03-63, regarding "Relief Request to Use ASME Code Case N-600", dated August 11, 2003.

3. USNRC letter from L. Raghavan to F. Cayia, dated March 21, 2003 regarding "Point Beach Nuclear Plant, Units 1 and 2 - Relief Request No.

9 Associated with the 10-Year Interval Inservice Inspection Program (TAC NOS. MB5403 and MB5404)".

Dear Sir or Madam:

Enclosed is Entergy's response to the request for additional information (RAI) letter (reference 1) from the Nuclear Regulatory Commission (NRC) regarding Entergy's requests for relief (reference 2) for James A. FitzPatrick Nuclear Power Plant (JAF), Indian Point Nuclear Generating Units No. 2 and No. 3 (IP2/lP3), Pilgrim Nuclear Power Station (PNPS), and Vermont Yankee Nuclear Power Station (VY) to use Code Case N-600 as an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI (Subsection IWA) requirements for welder qualifications.

Entergy's response to the RAI questions is attached. Enclosures 1 through 5 are the revised requests for relief to use ASME Code Case N-600 for James A. FitzPatrick Nuclear Power Plant (JAF, Enclosure 1), Indian Point Nuclear Generating Unit No. 2 (IP2, Enclosure 2), Indian Point Nuclear Generating Unit No. 3 (IP3, Enclosure 3), Pilgrim Nuclear Power Station (PNPS, Enclosure 4), and Vermont Yankee Nuclear Power Station (VY, Enclosure 5). The proposed alternative would allow the Entergy plants the flexibility to utilize welders qualified by other licensees or owners (i.e.,

non-Entergy) under similar qualification pr6grams. Pursuant to 10CFR50.55a(a)(3)(i), the proposed alternative to use Code Case N-600 will provide an acceptable level of safety and quality.

Approval is requested by March 30, 2004 to support the VY Spring 2004 outage which begins in early April 2004. Due to the similarity of these requests for relief, it is also requested that approval for JAF, IP2, IP3, and Pilgrim be granted at the same time.

A similar request for relief was approved for Point Beach Nuclear Plant, Units 1 and 2 (Reference 3).

There are no new commitments made in this letter. If you have any questions, please contact Ms.

Charlene Faison at 914-272-3378.

XIcint ir s ire/A un /hi Entergy Nuclear Operations, Inc.

Attachment:

Entergy's Response to RAI Regarding Request for Relief to Use ASME Code Case N-600.

List of

Enclosures:

1. James A. FitzPatrick Nuclear Power Plant, RR-32, revision 1.

2. Indian Point Generating Station Unit No. 2, RR-64, revision 1.

3. Indian Point Generating Station Unit No. 3, RR 3-33 (A), revision 1.

4. Pilgrim Nuclear Power Station, PRR-33, revision 1.

5. Vermont Yankee Nuclear Power Station, Relief Request No. ISI-012, revision 1.

cc:

Mr. Guy S. Vissing, Sr. Project Manager Mr. Hubert J. Miller Project Directorate I Regional Administrator, Region I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 475 Allendale Road U.S. Nuclear Regulatory Commission King of Prussia, PA 19406-1415 Mail Stop 8-C2 Washington, DC 20555-0001 2

Mr. Patrick D. Milano, Sr. Project Manager USNRC Resident Inspector Project Directorate I Vermont Yankee Nuclear Power Station Division of Licensing Project Management 320 Governor Hunt Road Office of Nuclear Reactor Regulation P.O. Box 157 U.S. Nuclear Regulatory Commission Vernon, VT 05354 Mail Stop 0-8-C2 Washington, DC 20555-0001 Mr. Paul Eddy New York State Department Mr. Travis Tate, Project Manager of Public Service Project Directorate 1-2 3 Empire State Plaza Division of Licensing Project Management Albany, NY 12223 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mr. Peter R. Smith, Acting President Mail Stop 8-B-1A New York State Energy, Research, and Washington, DC 20555-0001 Development Authority Corporate Plaza West Mr. Richard B. Ennis, Project Manager 286 Washington Avenue Extension Project Directorate I Albany, NY 12203-6399 Division of Licensing Project Management Office of Nuclear Reactor Regulation Mr. David O'Brien U.S. Nuclear Regulatory Commission Commissioner Mail Stop 08-B-1 Department of Public Service Washington, DC 20555-0001 112 State Street, Drawer 20 Montpelier, VT 05620-2601 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Senior Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511-0038 Resident Inspector's Office James A. FitzPatrick U.S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093-0136 Senior Resident Inspector Pilgrim Nuclear Power Station U.S. Nuclear Regulatory Commission 600 Rocky Hill Road Mail Stop 66 Plymouth, MA 02360 3

JPN-04-005 / NL-04-021 I ENO 2.4.021 I BVY 04-022 Attachment Page 1 of 2 ENTERGY'S RESPONSE TO RAI REGARDING REQUEST FOR RELIEF TO USE ASME CODE CASE N-600 NRC Question 1:

Please note that although this appears to be one Request forAdditional Information, the response should be specific for each plant as we intend to issue a safety evaluation specific for each plant.

Relief Request RR-32, Rev. 0, James A, Fitzpatrick Nuclear Power Station Relief Request RR-64, Indian Point Nuclear Generating Station Unit No. 2 Relief Request RR-3-33(A), Indian Point Nuclear Generating Station Unit No. 3 Relief Request PRR-33, Pilgrim Nuclear Power Station Relief Request ISI-0 12, Vermont Yankee Nuclear Power Station Each specific relief request must be a stand-alone document and must state the Code of record for the specific Plant. Please modify each relief request to provide the exact Code of record applicable for each plant.

Entergy Response:

The code of record for each plant, which was included in the original submittal cover letter, has been added to revision 1 of the individual requests for relief (originally submitted as Enclosures 1 through 5).

NRC Question 2:

Each relief request shall state the technical basis for the relief requested, i.e. how does the proposed alternative provide an acceptable level of quality and safety? The proposed relief requests do not provide enough detail to justify the conclusion concerning the acceptable level of quality and safety. Please provide a more detail basis forjustification that the proposed alternative provides an acceptable level of quality and safety for each plant.

Entergy Response:

Additional details to justify the conclusion that the proposed alternative provides an acceptable level of quality and safety for each plant have been added to revision 1 of the applicable plant's request for relief (Enclosures 1 through 5).

JPN-04-005 / NL-04-021 / ENO 2.4.021 / BVY 04-022 Attachment Page 2 of 2 ENTERGY'S RESPONSE TO RAI REGARDING REQUEST FOR RELIEF TO USE ASME CODE CASE N-600 NRC Question 3:

Paragraph E.8 in Relief Requests, RR-32, RR-64, RR-3-33(A), and PRR-33 states, "Entergy will comply with the Quality Assurance requirements of ASME Section Xl, Article IWA-1400." Justify this deviation from ASME Section Xl Code Case N-600, paragraph (h) which states, 'The Owner accepting the WPQ/BPQ shall comply with the Quality Assurance requirements of IWA-4142(a). (Relief Request ISI-012, for the Vermont Yankee Nuclear Power Station contains the reference shown in Code Case N-600).

Entergy Response:

The Code of Record for Vermont Yankee Nuclear Power Plant (VY) is ASME Section Xl, 1998 Edition through 2000 Addenda. Therefore as the owner accepting the WPQ/BPQ, Vermont Yankee will comply with the Quality Assurance requirements of IWA-41 42(a) as stated in the 1998 Edition of the Code.

For Indian Point Nuclear Generating Station Units 2 and 3 (IP2/1P3), James A. FitzPatrick Nuclear Power Plant (JAF), and Pilgrim Nuclear Power Station (Pilgrim), the applicable Code of Record is ASME Section Xl, 1989 Edition, No Addenda. The 1989 Edition does not have a subparagraph IWA-4142(a). Instead, the applicable Quality Assurance requirements are included in Article IWA-1400 of the 1989 Edition of the ASME Code,Section XI, as submitted in the original requests for relief.

The ASME Code allows licensees to implement a later approved edition of the Code for repair/replacement activities, and the 1998 Edition, through 2000 Addenda of ASME Section Xl was approved by reference in 10CFR50.55a. Therefore, Entergy will implement Code Case N-600 in its entirety, including the IWA-4142(a) requirements. Revision 1 of the requests for relief for IP2, IP3, JAF, and Pilgrim (Enclosures 1 through 4) reflect this change.

JPN-04-005 / NL-04-021 / ENO 2.04.021 / BVY 04-022 Enclosure 1 JAMES A. FITZPATRICK THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-32, Revision 1 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1. ASME Code Component(s) Affected Component Numbers: All Examination Category: All Item Number: All

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements Article IWA-4400(b) - All welders shall be qualified by the repair organization in accordance with the requirements of the codes specified in the Repair Program in accordance with IWA-4120.

4. Reason for Request ASME Code Case N-600 permits nuclear plant licensees to share welder qualifications with other licensees. This Code Case reduces welder qualification costs and provides each owner access to a larger resource pool of skilled, experienced, and qualified nuclear welders.

5. Proposed Alternative The following alternative requirements will be implemented as defined by ASME Section XI Code Case N-600, "Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners, Section Xl, Division 1", when using welders qualified by other licensees or owners (i.e., non-Entergy):

1. Entergy will perform a technical review of the supplying Owner's records of Welder Performance Qualification (WPQ), Welding Operator Performance Qualification (WOPQ), or Brazer/Brazing Operator Performance Qualification (BPQ).

2. The supplying Owner will state in writing that the WPQ, WOPQ, or BPQ was performed under an acceptable Nuclear Quality Assurance program that meets ASME Section Xl, IWA-1400, and that the tests were performed in accordance with ASME Section IX.

3. Entergy will obtain any necessary supporting information to satisfy the requirements of ASME Section IX, QW-301.4 or QB-301.4.

1

JPN-04-005 / NL-04-021 / ENO 2.04.021 / BVY 04-022 Enclosure 1

4. Entergy will require each welder, welding operator, brazer, or brazing operator to demonstrate proficiency by completing a renewal qualification test in accordance with ASME Section IX, QW-322.2(a) or QB-322(b), as applicable, with the following additional requirements.

a. When the WPQ transfer involves prior groove tests, the renewal test shall use a groove configuration.

b. When the WPQ transfer involves prior fillet tests, the renewal tests may use either a groove or a fillet configuration.

5. Entergy will accept the responsibility for the Performance Qualification Test(s), and will document this acceptance on the renewal test record(s) for the WPQ/WOPQ/BPQ. The renewal test record(s) will reference the original WPQ/WOPQ/BPQ test record(s) supplied by the Owner that provided the qualification.

6. Entergy will accept the responsibility for compliance with ASME Section IX, QW-322 or QB-322, as applicable.

7. Entergy will not accept qualifications from any Owner that was not the qualifying organization nor transfer the supplied qualifications to any other Owner.

8. Entergy will comply with the Quality Assurance requirements of ASME Section Xl, 1998 Edition, Article IWA-4142(a).

9. Entergy will document the use of this Case on the record of the WPQ/WOPQ/BPQ for the renewal qualification test(s).

Basis for Use ASME Section IX, 'Welding Qualifications", requires that each organization qualify its own welders. Welder qualification responsibility cannot be subcontracted, and welder qualifications administered by one organization cannot be transferred to another organization. The basis for this requirement has become the subject of close scrutiny as the demand for efficiency, particularly among nuclear plant owners, has increased.Section IX's requirements for welder qualification are based, in part, on the fact that organizations with minimal welding experience may use Section IX. By requiring each organization to qualify its own welders,Section IX assures that all users attain some proficiency in evaluating welder skills. Welder qualification proficiency among nuclear owners, however, is not an issue. Extensive quality assurance programs mandate and continually reassess this proficiency.

The use of Code Case N-600 improves an owner's ability to attract quality welders by eliminating the obstacle of redundant performance qualification testing. It enables Owners to rely on each other's experience in selecting welders, permitting candidate selection to be based on actual field performance rather than qualification tests. It also builds the resource pool of welders who, in addition to welding skills, understand and can comply with the extensive documentation and quality assurance requirements associated with nuclear work. These skills as well as a variety of other skills unique to nuclear power (e.g., radiation control, site security programs, NRC interface, etc.) are retained when experienced nuclear welders are transferred between sites.

Based on the above described detailed qualification and testing requirements on using welders qualified by other licensees or owners (i.e., non-Entergy), Entergy believes the proposed alternative to use Code Case N-600 in its entirety provides an acceptable level of quality and safety, pursuant to 10 CFR 50.55a(a)(3)(i).

2

JPN-04-005 / NL-04-021 / ENO 2.04.021 / BVY 04-022 Enclosure 1

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for James A. FitzPatrick Nuclear Power Plant.

7. Precedents A similar request for relief was approved for Point Beach Nuclear Plant, Units 1 and 2 (TAC NOS.

MB5403 and MB5404, dated March 21, 2003).

8. Attachment None 3

JPN-04-005 / NL-04-021 / ENO 2.04.021 I BVY 04-022 Enclosure 2 INDIAN POINT GENERATING STATION UNIT NO. 2 THIRD 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. RR-64, Revision 1 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety--

1. ASME Code Component(s) Affected Component Numbers: All Examination Category: All Item Number: All

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements Article IWA-4400(b) - All welders shall be qualified by the repair organization in accordance with the requirements of the codes specified in the Repair Program in accordance with IWA-4120.

4. Reason for Request ASME Code Case N-600 permits nuclear plant licensees to share welder qualifications with other licensees. This Code Case reduces welder qualification costs and provides each owner access to a larger resource pool of skilled, experienced, and qualified nuclear welders.

5. Proposed Alternative The following alternative requirements will be implemented as defined by ASME Section Xl Code Case N-600, "Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners, Section Xl, Division 1,", when using welders qualified by other licensees or owners (i.e., non-Entergy):

1. Entergy will perform a technical review of the supplying Owner's records of Welder Performance Qualification (WPQ), Welding Operator Performance Qualification (WOPQ), or Brazer/Brazing Operator Performance Qualification (BPQ).

2. The supplying Owner will state in writing that the WPQ, WOPQ, or BPQ was performed under an acceptable Nuclear Quality Assurance program that meets ASME Section Xl, IWA-1400, and that the tests were performed in accordance with ASME Section IX.

3. Entergy will obtain any necessary supporting information to satisfy the requirements of ASME Section IX, QW-301.4 or QB-301.4.

1

JPN-04-005 / NL-04-021 / ENO 2.04.021 / BVY 04-022 Enclosure 2