BVY 04-027, Response to RAI on Relief Requests to Use ASME Code Case N-600, Supplement 1

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Response to RAI on Relief Requests to Use ASME Code Case N-600, Supplement 1
ML040820701
Person / Time
Site: Indian Point, Pilgrim, Vermont Yankee, FitzPatrick  Entergy icon.png
Issue date: 03/18/2004
From: Kansler M
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
BVY 04-027, TAC MC0303, TAC MC0336, TAC MC0337, TAC MC0338, TAC MC0339, TAC MC5403, TAC MC5404
Download: ML040820701 (5)
v • d • e


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 vEntergy Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President March 18, 2004 BVY 04-027 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Vermont Yankee Nuclear Power Station Docket No. 50-271 Response to RAI on Relief Requests to Use ASME Code Case N-600 -

Supplement 1

References:

1. Entergy letter to NRC, JPN-04-005/NL-04-021/ENO 2.04.021/BVY 04-022, "Response to RAI on Relief Requests to Use ASME Code Case N-600", dated March 4, 2004.
2. 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.
3. 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.
4. 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:

Entergy provided a letter (Reference 1) responding to the Nuclear Regulatory Commission's (NRC) request for additional information (RAI) (Reference 2) regarding Entergy's requests for relief (Reference 3) 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 for James A. FitzPatrick Nuclear Power Plant (JAF),

Indian Point Nuclear Generating Units No. 2 and No. 3 (IP2/1P3), Pilgrim Nuclear Power Station (PNPS), and Vermont Yankee Nuclear Power Station (VYNPS).

Enclosure 5 of Reference 1 provided the revised VY relief request no. ISI-012, which incorporated the applicable response to the RAI but inadvertently stated that the relief request was for the remainder of the third Interval. Vermont Yankee began its fourth Inservice Inspection Interval in September 2003, and therefore the revised request for relief should be for the remainder of the fourth Interval (Reference 3). Attached is a revised version of Enclosure 5 to Reference 1, which reflects the change for VYNPS. This attachment supercedes and replaces Enclosure 5 of Reference 1 in its entirety.

There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378. l Very truly yours, President Entergy Nuclear Operations, Inc.

Attachment:

Vermont Yankee Nuclear Power Station, Relief Request No. ISI-012, revision 2 (revised Enclosure 5 to BVY-022, dated March 4, 2004).

cc:

Mr. Hubert J. Miller Mr. David O'Brien Regional Administrator, Region I Commissioner U.S. Nuclear Regulatory Commission Department of Public Service 475 Allendale Road 112 State Street, Drawer 20 King of Prussia, PA 19406-1415 Montpelier, VT 05620-2601 Mr. Guy S. Vissing, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555-0001 Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-BI Washington, DC 20555-0001 USNRC Resident Inspector Vermont Yankee Nuclear Power Station 320 Governor Hunt Road P.O. Box 157 Vernon, VT 05354 2

JPN-04-005 / NL-04-021 / ENO 2.04.021 / BVY 04-022 Enclosure 5 VERMONT YANKEE NUCLEAR POWER STATION FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL RELIEF REQUEST NO. ISI-012, Revision 2 Proposed Alternative InAccordance 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 Fourth Inservice Inspection Interval is ASME Section XI Code, 1998 Edition, through the 2000 Addenda.
3. Applicable Code Requirements Articles IWA-4440(c) and (d), 1998 Edition, 2000 Addenda requires that the Owner / Repair Organization shall qualify all welders, welding operators, brazers, and brazing operators in accordance with the codes specified in the Repair/ Replacement Plan.
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 XI, 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 XI, 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 I ENO 2.04.021 / BVY 04-022 Enclosure 5

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/WOPQIBPQ. 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 5

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Fourth Inservice Inspection Interval for Vermont Yankee Station.
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
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