CNRO-2006-00038, Request ISI-2006-1, Use of Later ASME Section XI Code Edition and Addenda for Qualification of Thermal Removal Processes in Accordance with IWA-4461.4

Request ISI-2006-1, Use of Later ASME Section XI Code Edition and Addenda for Qualification of Thermal Removal Processes in Accordance with IWA-4461.4

ML062200491
Person / Time
Site:	Arkansas Nuclear
Issue date:	08/02/2006
From:	Burford F Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNRO-2006-00038, ISI-2006-1
Download: ML062200491 (5)

Text

• .A Entergy Operations, Inc.

1340 Echelon Parkway Jackson, Mississippi 39213-8298 tergYTel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2006-00038 August 2, 2006 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Request ISI-2006-1 Use of Later ASME Section XI Code Edition and Addenda for Qualification of Thermal Removal Processes in Accordance With IWA-4461.4 Arkansas Nuclear One, Units 1 and 2 Docket No. 50-313 and 50-368 License No. DPR-51 and NPF-6

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy Operations, Inc. (Entergy) requests permission to use IWA-4461.4 of the 1995 Edition, 1997 Addenda of ASME Section XI. IWA-4461.4 provides rules for qualification of thermal removal processes as an alternative to mechanical processing of thermally cut surfaces. This request is applicable to Arkansas Nuclear One -

Units 1 (ANO-1) and 2 (ANO-2). This request (ISI-2006-1) is provided in the enclosure to this letter. The NRC has approved this edition and addenda of Section XI as documented in 10 CFR 50.55a(b)(2).

Entergy is providing this request in accordance with NRC Regulatory Issue Summary 2004-16, Use of Later Editions and Addenda to ASME Code Section Xl for Repair/ReplacementActivities.

Entergy requests approval of this request on or before April 1, 2007. Should you have any questions regarding this submittal, please contact Guy Davant at (601) 368-5756.

This letter contains no commitments.

Very truly yours, FGB/GHD/ghd

Enclosure:

Request ISI-2006-1

CNRO-2006-00038 Page 2 of 2 cc: Mr. W. A. Eaton (ECH)

Mr. J. S. Forbes (ANO)

Dr. Bruce S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 U. S. Nuclear Regulatory Commission Attn: Mr. D. G. Holland (ANO)

MS O-7D1 Washington, DC 20555-0001 NRC Senior Resident Inspector Arkansas Nuclear One P. 0. Box 310 London, AR 72847

ENCLOSURE CNRO-2006-00038 ISI-2006-1 REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv) FOR INSERVICE INSPECTION ITEMS

ENTERGY OPERATIONS, INC.

10 CFR 50.55a Request ISI-2006-1 REQUEST INACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv) FOR INSERVICE INSPECTION ITEMS

1. ASME Code Components Affected All Class 1, 2, and 3 vessels, piping, pumps, and valves in the Section Xl pressure boundary at Arkansas Nuclear One, Unitsl (ANO-1) and 2 (ANO-2).

2. Applicable Code Edition and Addenda

Repair/replacement activities at ANO-1 and ANO-2 are currently performed in accordance with the 1992 Edition of ASME Section XI with portions of the 1993 Addenda for pressure testing.

The start date of the next 120-month inservice inspection interval for ANO-1 and ANO-2 is June 1, 2007 and March 26, 2010, respectively.

3. Proposed Subsequent Code Edition and Addenda (or Portion)

A. Background As stated in Section 2.0, above, Entergy currently performs repair/replacement activities in accordance with the 1992 Edition of ASME Section XI with portions of the 1993 Addenda for pressure testing. However, IWA-4000 in the 1992 Edition does not contain rules for qualifying thermal removal processes, such as electrodischarge machining (EDM), that can be used without mechanical processing of thermally cut surfaces.

The 1997 Addenda of the 1995 Edition of Section XI revised the rules applicable to thermal removal processes for all repair/replacement activities. The 1997 Addenda also added new rules that exempted mechanical processing of thermally cut surfaces provided the thermal removal process was qualified in accordance with IWA-4461.4.

B. Proposed Subsequent Code Edition and Addenda Pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy requests permission to use IWA-4461.4 in the 1995 Edition, 1997 Addenda of ASME Section XI. This section of the Code provides rules for qualifying thermal removal processes as an alternative to mechanical processing of thermally cut surfaces of P-Nos. 3, 4, 5, 6, 7, 8, 9, 10, 11 A, and 43 materials.

The NRC approved the use of the 1995 Edition, 1997 Addenda as documented in 10 CFR 50.55a(b)(2) with no limitations, conditions, or modifications on IWA-4461.4.

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4. Related Requirements IWA-4461.4 of the 1995 Edition, 1997 Addenda specifies rules for qualification of a thermal removal process as an alternative to mechanical processing of thermally cut surfaces.

When applying IWA-4461.4, the following related requirement also applies:

IWA-4461.4 states: "Mechanical processing of thermally cut surfaces for materials identified in IWA-4461.2 and IWA-4461.3 is not required when using a thermal removal process qualified as follows..." Because IWA-4461.4 is an alternative to mechanical processing of thermally cut surfaces for the materials identified in IWA-4461.2 and IWA-4461.3, it is only applicable to P-Number 3, 4, 5, 6, 7, 8, 9, 10, 11A, and 43 materials; it cannot be applied to P-Number 1 materials of IWA-4461.1.

Therefore, when invoking IWA-4461.4 in the 1995 Edition 1997 Addenda, Entergy will also apply this related requirement.

The NRC prohibition on "evaluation of thermally cut surfaces" in paragraph (xxiii) of 10 CFR50.55a(b)(2) does not apply to the qualification alternative of IWA-4461.4. Rather, this NRC prohibition applies to IWA-4461.4.2, Evaluation of Thermally Cut Surfaces, which was not included into ASME Section XI until the 2001 Edition.

5. Duration of Proposed Request The duration of this request will be from approval by the NRC staff until the beginning of the next interval for each facility, as identified in Section 2, above.

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