JAFP-11-0135, Response to Request for Additional Information for Valve Relief Request VRR-07
| ML113190078 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/14/2011 |
| From: | Joseph Pechacek Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-11-0135, TAC ME6686 | |
| Download: ML113190078 (4) | |
Text
JAFP-11-0135 November 14, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Subject:
Response to Request for Additional Information for Valve Relief Request VRR-07 (TAC NO. ME6686)
James A. FitzPatrick Nuclear Power Plant Docket Nos. 50-333 License Nos. DPR-59
References:
- 1. Entergy letter, Proposed Relief Request Nos. VRR-07 and VRR-08 for the James A. FitzPatrick Nuclear Power Plant Fourth Interval In-Service Testing Program, JAFP-11-0085, dated July 7, 2011
- 2. NRC email, FitzPatrick - ME6686-Draft RAIs from CPTB Re: Relief Requests VRR-07, dated October 12, 2011
- 3. Teleconference with NRC, dated October 19, 2011
Dear Sir or Madam:
James A. FitzPatrick Nuclear Power Plant (JAF) submitted two Valve Relief Request (VRR)
[Reference 1] for relief from the testing requirements of ASME OM Code-2001 including 2003 addenda ISTC-3630(a) Leakage Test Frequency (VRR-07) and ISTC-3700 Position Verification Testing (VRR-08).
The NRC provided a draft Request for Additional Information (RAI) [Reference 2] for VRR-07.
By teleconference the RAI question was clarified on October 19, 2011 [Reference 3]. JAFs response to the RAI question as clarified is contained in the attachment to this letter.
There are no commitments contained in this letter.
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Joseph Pechacek Licensing Manager - JAF
JAFP-11-0135 Page 2 of 2 Should you have any questions concerning this letter, or require additional information, please contact Joseph Pechacek, Licensing Manager, at 315-349-6766.
j Josep Pechacek Licens ng Manager JP/mh
Attachment:
cc:
Response to Request for Additional Information Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2A Washington, DC 20555-0001 Ms. Bridget Frymire New York State Department of Public Service 3 Empire State Plaza, 10 th Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President NYSERDA 17 Columbia Circle Albany, NY 12203-6399 Document Component(s):
001 Transmittal Letter JAFP-11-0xxx wi Attachment
Attachment JAFP-11-0135 Responses to Request for Additional Information (1 Pages)
Attachment JAFP-11-0135 Response to Request for Additional Information Page 1 of 1 The following is the response from the James A. FitzPatrick Nuclear Power Plant (JAF) to the NRC Request for Additional Information (RAI) for Valve Relief Request VRR-07 (Relief to implement Performance Based Scheduling of Pressure Isolation Valve Tests):
RAI VRR-07-1
Reference:
Letter from Eugene Dorman of Entergy Nuclear Operations, Inc to NRC, Proposed Relief Request Nos. VRR-07 and VRR-08 for the James A. FitzPatrick Nuclear Power Plant Fourth Interval In-Service Testing Program, dated July 7, 2011.
In the Reference noted above, it was stated that, Program guidance will be established such that if any of the valves fail either the CIV (containment isolation valve) test or PIV (pressure isolation valve) test, the test interval for both tests will be reduced to once every 30 months until they can be re-classified as good performers per the performance evaluation requirements of Appendix J, Option B. Please explain and provide a basis why the PIV test interval would only be reduced to once every 30 months instead of the initial interval of once every two years as required by the ASME OM Code, following a PIV test failure.
Response
As shown above, in VRR-07, it was stated Program guidance will be established such that if any of the valves fail either the CIV (containment isolation valve) test or PIV (pressure isolation valve) test, the test interval for both tests will be reduced to once every 30 months until they can be re-classified as good performers per the performance evaluation requirements of Appendix J, Option B.
The intent of this statement was to state that the NEI 94-01 guidance for determining intervals for 10 CFR 50 Appendix J, Option B would also be used to implement the intervals for the subject PIV testing. Since the subject valves are proposed to be extended to sixty months when classified as good performers per NEI 94-01, they were also proposed to be reduced to thirty months upon a failure.
The reason for this statement is to avoid deviations in frequencies between the PIV and the CIV testing for a particular valve. If JAF were to reset PIV testing to twenty-four months upon a failure, then resetting the CIV testing to thirty months per NEI 94-01 would create a discrepancy in the intervals.
Regardless of which interval is used, upon a failure, JAF will perform CIV (if applicable) or PIV testing on each poor performing valve during every refueling outage interval (twenty-four months) until good performance is established. This provides assurance that the thirty month testing interval will not be exceeded at any time.