ML021220431
| ML021220431 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  (DPR-064) |
| Issue date: | 04/10/2002 |
| From: | Barrett R Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IPN-02-026 | |
| Download: ML021220431 (4) | |
Text
--Entergy-Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
Indian Point Energy Center PO. Box 308 Buchanan, NY 10511 Tel 914 736 8001 Fax 914 736 8012 Robert J. Barrett Vice President, Operations Indian Point 3 IPN-02-026 April 10, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001
Subject:
Indian Point 3 Nuclear Power Plant Docket No. 50-286 License No. DPR-64 Relief Request RR3-29(S) For Inservice Inspection Program
Dear Sir:
The purpose of this letter is to submit a request for relief for the Inservice Inspection Program, pursuant to 10 CFR 50.55a. Relief request RR3-29(S) is to allow visual examination of snubbers in accordance with IWF-2510. The relief request demonstrates that the proposed alternative would provide an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i).
There are no new commitments made by this letter. If you have any questions, please contact Mr. Kevin Kingsley at (914) 734-6034.
Vice/(
R-sdn Operations India Point 3 Nuclear Power Plant cc: next page
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Docket No. 50-286 IPN-02-026 Page 2 of 2 Attachment as stated cc:
Regional Administrator U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission 295 Broadway, Suite 3 P.O. Box 337 Buchanan, NY 10511-0308 Mr. Patrick Milano, Project Manager Project Directorate I Division of Reactor Projects 1/11 U.S. Nuclear Regulatory Commission Mail Stop 0-8C2 Washington, DC 20555 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza Albany, NY 12223 Docket No. 50-286 IPN-02-026 Page 1 of 2 Indian Point 3 Third Inservice Inspection Interval Relief Request No. 3-29 (S)
A.
ARTICLE IDENTIFICATION IWF-1000 Class: 1, 2, and 3 System: All B.
EXAMINATION REQUIREMENTS ASME Section Xl 1989 Edition, Paragraph IWF-1220:
The Inservice Inspection requirements for snubbers shall be in accordance with the requirements of IWF-5000.
C.
RELIEF REQUESTED Indian Point 3 requests relief from inspecting ISI snubbers in accordance with IWF-5000.
Specifically, it is requested that the provisions of IWF-2510 be applied to snubbers.
Pursuant to 10CFR50.55a(a)(3)(i) relief is requested on the basis that the proposed alternatives discussed in this request for relief would provide an acceptable level of quality and safety.
D.
BASIS FOR RELIEF The exemptions allowed by IWF-251 0 should apply to component standard supports, including snubbers. IWF-1220 refers to IWF-5000 for snubber requirements. IWF 5000 refers to ASME/ANSI OM-1 987, Part 4, which does not contain any exemptions.
This limits the ability of licensees to utilize the exemptions of IWF-2510. There is no safety reason for this limitation.
E.
ALTERNATIVE EXAMINATIONS OR TESTS All snubbers exempted from the VT-3 exam by IWF-2510, will be visually examined in accordance with requirements in the Indian Point 3 (IP3) Technical Requirements Manual. These requirements were originally added to the Technical Specifications in response to Generic Letter 84-13 but were subsequently relocated with the adoption of Improved Technical Specifications.
Docket No. 50-286 IPN-02-026 Page 2 of 2 Indian Point 3 Third Inservice Inspection Interval Relief Request No. 3-29 (S)
F.
JUSTIFICATION FOR REQUESTING RELIEF IWF-2510 states that component supports selected for examination shall be the supports of those components that are required to be examined under IWB, IWC, IWD, and IWE during the first inspection interval. Paragraph IWC-1222(a) exempts vessels, piping, pumps, valves, and other components NPS 4 and smaller from volumetric and surface examinations. This allows 3" IS[ Class 2 component supports to be exempt from the requirement to perform a VT-3 inspection.
IWF-1220 requires snubber inspections to be performed in accordance with IWF-5000.
IWF-5000 requires VT-3 inspections and does not contain any paragraph regarding exemptions. Therefore, a snubber on a 3" ISI Class 2 line would require a VT-3 inspection while a component support such as a U-bolt can would not.
This difference in inspection requirements for supports is inconsistent. It would be possible for a snubber to be located adjacent to a U-bolt type support, both supporting the same line, and the U-bolt would not require a VT-3 but the snubber would require a VT-3. This relief request would allow the same exemptions applied to the VT-3 examination of component supports to be applied to the VT-3 examination of snubbers.
If this relief request is approved, snubbers exempted by paragraph IWF-251 0 will still be visually inspected in accordance with the Technical Requirement Manual and functionally tested in accordance with ASMEIANSI OM-4.
G.
IMPLEMENTATION SCHEDULE The requirements as specified in this relief request will be incorporated into the IP3 Inservice Inspection Program during the 3 rd Ten-Year Interval.
H.
ATTACHMENTS TO THE RELIEF None.