CNRO-2007-00019, Notification of Deviation from BWRVIP Guidelines

Notification of Deviation from BWRVIP Guidelines

ML071070297
Person / Time
Site:	Grand Gulf, River Bend
Issue date:	04/05/2007
From:	Burford F Entergy Operations
To:	Document Control Desk, NRC/NRR/ADRO
References
CNRO-2007-00019
Download: ML071070297 (2)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2007-00019 April 5, 2007 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Notification of Deviation from BWRVIP Guidelines River Bend Station Grand Gulf Nuclear Station Docket No. 50-458 Docket No. 50-416 License No. NPF-47 License No. NPF-29

REFERENCES:

1. BWRVIP-139, "BWR Vessel and Internals Project Steam Dryer Inspection and Flaw Evaluation Guidelines," Revision 0

2. BWRVIP-94, "BWR Vessel and Internals Project Program Implementation Guide," Revision 1

3. BWRVIP-03, "Reactor Pressure Vessel and Internals Examination Guidelines, RTR-105696-R8, Final Report, December 2005,"

Revision 8

Dear Sir or Madam:

Reference 2 requires a report be sent to the Nuclear Regulatory Commission (NRC) anytime a utility does not implement any portion of an applicable "mandatory" or "needed" BWRVIP guideline that has been approved by the Executive committee and transmitted to the NRC.

This notification must be sent to the NRC within 45 days of the utility executive concurrence with the deviation disposition.

A deviation disposition was signed on March 15, 2007 for River Bend Station (RBS) and Grand Gulf Nuclear Station (GGNS). The deviation is to the requirements of Reference 1 which is designated as a "needed" guideline. The guidance requires a VT-1 inspection of the reactor vessel steam dryers. Reference 3, Section 2.5, "Generic Standards for Visual Inspection of Reactor Pressure Vessel Internal, Components and Associated Repairs,"

specifies that when a VT-1 inspection is specified in a BWRVIP document, it is intended that those inspections be performed in accordance with the utility's ASME Section Xl Code of record. The current Code of record for RBS and GGNS is the 1992 edition which requires the resolution be demonstrated by use of lower case characters that are 0.044 inches in height.

Earlier edition of ASME Section Xl allow the resolution to be demonstrated with the use of a 1/32 inch line on an 18% neutral gray card. Several plants are still working to the earlier edition of the Code. Use of the later edition adds about 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> to the inspections with out A400

CNRO-2007-00019 Page 2 of 2 measurable improvement. The deviation evaluates and justifies the use of an inspection resolution consistent with the earlier edition of Section XI and industry practices.

Entergy has determined that use of the resolution requirements of the 1989 edition of the Code does not affect the ability to detect cracking which would affect the integrity of the Steam Dryer. General Electric has proposed a revision to BWRVIP-139 to specify the 1/32 inch line resolution criteria specified in the 1989 edition. In the interim, Entergy initiated this deviation until the BWRVIP guidelines can be revised.

This notification is for information only and Entergy is not requesting action from the NRC staff.

Sincerely, cc: Mr. W. R. Brian (G-ADM-1)

Mr. W. A. Eaton (ECH)

Mr. J. E. Venable (RBS)

Dr. Bruce S. Mallett Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector River Bend Station P.O. Box 1050 St. Francisville, LA 70775 NRC Senior Resident Inspector Grand Gulf Nuclear Station Route 2, Box 399 Port Gibson, MS 39150 U.S. Nuclear Regulatory Commission Attn: Mr. B. K. Vaidya MS 0-7 D1 Washington, DC 20555-0001 U.S. Nuclear Regulatory Commission Attn: Mr. John Honcharik MS 9-84 Washington, DC 20555-0001