ML041070088
| ML041070088 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Pilgrim, Vermont Yankee, FitzPatrick  |
| Issue date: | 07/06/2004 |
| From: | Richard Laufer NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Vissing G, NRR/DLPM, 415-1441 | |
| References | |
| TAC MC0303, TAC MC0336, TAC MC0337, TAC MC0338, TAC MC0339 | |
| Download: ML041070088 (12) | |
Text
July 6, 2004 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT, INDIAN POINT NUCLEAR GENERATING UNITS NO. 2 AND NO. 3, PILGRIM NUCLEAR POWER STATION, AND VERMONT YANKEE NUCLEAR POWER STATION -
RELIEF REQUEST TO USE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE CASE N-600 (TAC NOS. MC0303, MC0336, MC0337, MC0338, AND MC0339)
Dear Mr. Kansler:
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 11, 2003, as supplemented by letters dated March 4, and March 18, 2004, Entergy Nuclear Operations, Inc.
(the licensee) submitted requests for relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(a)(3)(i). The licensee sought relief from the requirements of the American Society of Mechanical Engineers (ASME) Code,Section XI, 1989 Edition, Article IWA-4440(b), for the James A. FitzPatrick Nuclear Power Plant (JAF), Indian Point Nuclear Generating Units No. 2 and No. 3 (IP2 and IP3) and the Pilgrim Nuclear Power Station (PNPS). The licensee also sought relief from the requirements of ASME Code,Section XI, 1998 Edition, through the 2000 Addenda, Articles IWA-4440(c) and (d), for the Vermont Yankee Nuclear Power Station (VY). These articles require that the Owner/Repair Organization shall qualify all welders, welding operators, brazers, and brazing operators in accordance with the ASME Code specified in the Repair/Replacement Plan. The licensee proposed to use the alternative welding qualification requirements provided in ASME Code Case N-600, Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners.
The NRC staff reviewed the proposed alternative as discussed in the enclosed safety evaluation. Based on its review, the NRC staff concludes that the proposed alternative welding and brazing personnel qualification requirement of the Code Case would provide a comparable level of quality and safety as that of the ASME Code,Section XI, Article IWA-4440(b), for the JAF, IP2 & IP3, and PNPS, and Articles IWA-4440(c) and (d) for VY. Therefore, the use of ASME Code Case N-600 is authorized pursuant to 10 CFR 50.55a(a)(3)(i) at the JAF, IP2 &
IP3, and PNPS during the remainder of the third 10-year inservice inspection interval (ISI) and during the fourth 10-year ISI interval at VY. The licensee is authorized to use ASME Code Case N-600 until such time as the code case is included in a future revision of Regulatory Guide (RG) 1.147, Inservice inspection ASME Code Case Acceptability, ASME Section XI Division I. At that time, the licensee must follow all provisions and any limitations that may be described in RG 1.147 concerning the use of ASME Code Case N-600.
M. Kansler All other requirements of the ASME Code,Section III and XI, for which relief has not been specifically requested and approved remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
A copy of the related safety evaluation is enclosed.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-333, 50-247, 50-286, 50-293, and 50-271
Enclosure:
As stated cc w/encl: See next page
- Safety evaluation provided - no significant changes made OFFICE PDI-1/PM PDI-1/PM PDI-2/PM PDI-2/PM PDI-1/LA OGC EMCB*
PDI-1/SC NAME GVissing PMilano TTate REnnis SLittle GLongo SCoffin RLaufer DATE 6/18/04 6/18/04 6/16/04 6/16/04 6/15/04 6/28/04 4/6/04 7/06/04
FitzPatrick Nuclear Power Plant cc:
Mr. Gary J. Taylor Chief Executive Officer Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Theodore A. Sullivan Site Vice President Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Kevin J. Mulligan General Manager, Plant Operations Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Resident Inspector's Office James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. William Maquire Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Andrew Halliday Manager, Regulatory Compliance Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. Charles Donaldson, Esq.
Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271
FitzPatrick Nuclear Power Plant cc:
Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Ken L. Graesser BWR SRC Consultant 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. Jim Sniezek Nuclear Management Consultant 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ron Toole BWR SRC Consultant 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue Mail Stop L-ENT-15E New Orleans, LA 70113
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Mr. Gary J. Taylor Chief Executive Officer Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Fred Dacimo Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Christopher Schwarz General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 2 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Danny L. Pace Vice President Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Columb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspectors Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511-0038
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Senior Resident Inspectors Office Indian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy Electric Division New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue Mail Stop: L-ENT-15E New Orleans, LA 70113 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Dan C. Poole PWR SRC Consultant 20 Captains Cove Road Inglis, FL 34449 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Alex Matthiessen Executive Director Riverkeeper, Inc.
25 Wing & Wing Garrison, NY 10524 Mr. Paul Leventhal The Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036 Mr. Karl Coplan Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Mr. Robert D. Snook Assistant Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Mr. David Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006
Pilgrim Nuclear Power Station cc:
Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 Dr. Robert M. Hallisey, Director Radiation Control Program Commonwealth of Massachusetts Executive Offices of Health and Human Services 174 Portland Street Boston, MA 02114 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Steve Brennion Supt., Regulatory & Industry Affairs Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road, M/S 1 Plymouth, MA 02360-5508 Mr. Jack Alexander Manager, Reg. Relations and Quality Assurance Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5599 Mr. David F. Tarantino Nuclear Information Manager Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5599 Ms. Jane Perlov Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Mr. Stephen J. McGrail, Director Attn: James Muckerheide Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426
Pilgrim Nuclear Power Station cc:
Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Assessment Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Senior Resident Inspector U.S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station 600 Rocky Hill Road Mail Stop 66 Plymouth, MA 02360-5508 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Jim Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Kennety L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202
Vermont Yankee Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. David R. Lewis Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, DC 20037-1128 Ms. Christine S. Salembier, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. Michael H. Dworkin, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.
Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Deborah B. Katz Box 83 Shelburne Falls, MA 01370 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.
Framingham, MA 01702-5399 Jonathan M. Block, Esq.
Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. John F. McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213
Vermont Yankee Nuclear Power Station cc:
Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Danny L. Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Jay K. Thayer Site Vice President Entergy Nuclear Operations, Inc.
Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Kenneth L. Graesser 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801 Mr. Ronald Toole 1282 Valley of Lakes Box R-10 Hazelton, PA 18202 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR JAMES A. FITZPATRICK NUCLEAR POWER PLANT INDIAN POINT NUCLEAR GENERATING UNITS NO. 2 AND NO. 3 PILGRIM NUCLEAR POWER STATION AND VERMONT YANKEE NUCLEAR POWER STATION RELIEF REQUEST TO USE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE CASE N-600 BY ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NOS. 50-333, 50-247, 50-286, 50-293, AND 50-271
1.0 INTRODUCTION
By letter to the U.S. Nuclear Regulatory Commission (NRC) dated August 11, 2003, as supplemented by letters dated March 4, and March 18, 2004, Entergy Nuclear Operations, Inc.
(the licensee) submitted requests for relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(i). The licensee sought relief from the requirements of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),
Section XI, 1989 Edition, Article IWA-4440(b), for the James A. FitzPatrick Nuclear Power Plant (JAF), Indian Point Nuclear Generating Units No. 2 and No. 3 (IP2 & IP3), and the Pilgrim Nuclear Power Station (PNPS). The licensee also sought relief from the requirements of ASME Code,Section XI, 1998 Edition, through the 2000 Addenda, Articles IWA-4440(c) and (d), for the Vermont Yankee Nuclear Power Station (VY). These articles require that the Owner/Repair Organization shall qualify all welders, welding operators, brazers, and brazing operators in accordance with the ASME Code specified in the Repair/Replacement Plan. The licensee proposed to use the alternative welding qualification requirements provided in ASME Code Case N-600, Transfer of Welder, Welding Operator, Brazer, and Brazing Operator Qualifications Between Owners. Specifically, ASME Code Case N-600 permits welders, welding operators, brazers, and brazing operators qualified by one owner to be used by another owner provided that the owner which qualified the welding and/or brazing personnel certifies in writing that Welder/Welding Operator/Brazer/Brazing Operator Performance Qualifications (WPQ/BPQ) were conducted in accordance with a Quality Assurance Program that satisfies the requirements of ASME Code,Section XI, IWA-1400. The owner accepting the WPQ/BPQ must accept responsibility for the completed WPQ/BPQ. In addition, the owner accepting the WPQ/BPQ shall require each welder, welding operator, brazer, or brazing operator to demonstrate proficiency by completing a renewal qualification test in accordance with ASME Code,Section IX, QW 322.2(a) or QB-322(b). ASME Code Case N-600 was approved by the ASME Code in January 2001. The proposed relief is sought for the remainder of the third 10-year inservice inspection (ISI) interval for JAF, IP2 & IP3, and PNPS and the fourth 10-year ISI interval for VY.
The regulation at 10 CFR 50.55a(g) specifies that ISI of nuclear power plant components shall be performed in accordance with the requirements of the ASME Code,Section XI, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). The regulation at 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY EVALUATION
The information provided by the licensee in support of the requests has been evaluated and the bases for disposition are documented below.
James A. FitzPatrick Nuclear Power Plant Relief Request RR-32, Revision 1 Indian Point Generating Unit No. 2 Relief Request RR-64, Revision 1 Indian Point Generating Unit No. 3 Relief Request RR 3-33 (A), Revision 1 Pilgrim Nuclear Power Station Relief Request PRR-33, Revision 1 ASME Code Component(s) Affected:
Component Numbers: All Examination Category: All Item Number: All Code Edition and Addenda:
The Code of Record for the third 10-year ISI interval is ASME Code,Section XI, 1989 Edition, No Addenda.
Code Requirements:
Article IWA-4400(b) - All welders shall be qualified by the repair organization in accordance with the requirements of the codes specified in the Repair Program in accordance with IWA-4120."
Duration of Proposed Alternative:
It is proposed to use the alternative for the remainder of the third 10-year ISI interval for JAF, IP2, IP3, and PNPS.
Proposed Alternative:
The following alternative requirements will be implemented as defined by ASME 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 (as stated below):
1.
Entergy will perform a technical review of the supplying Owners 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 XI.
3.
Entergy will obtain any necessary supporting information to satisfy the requirements of ASME Section XI, QW-301.4 or QB-301.4.
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 XI, 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/WOPQ/BPQ. 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 XI, 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 XI, 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).
Vermont Yankee Nuclear Power Station Relief Request No. ISI-012, Revision 2 ASME Code Component(s) Affected: (As stated)
Component Numbers: All Examination Category: All Item Number: All Code Edition and Addenda:
The Code of Record for the fourth 10-year ISI interval is ASME Section XI Code, 1998 Edition, through the 2000 Addenda.
Code Requirements:
Articles IWA-4440(c) and (d), 1998 Edition, 2000 Addenda, require 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.
Duration of Proposed Alternative:
It is proposed to use the alternative for the remainder of the Fourth ISI for VY.
Proposed Alternative:
The following alternative requirements will be implemented as defined by ASME 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.
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/WOPQ/BPQ. 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 XI, 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 Relief ASME Code 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 ASME 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 ASME Code Case N-600 in its entirety provides an acceptable level of quality and safety, pursuant to 10 CFR 50.55a(a)(3)(i).
3.0 TECHNICAL EVALUATION
The licensee has proposed to use the provisions included in ASME Code Case N-600. ASME Code Case N-600 was approved by the ASME Code in January 2001. The specific requirements listed in ASME Code Case N-600 are:
a)
The Owner who performed the qualification test shall certify that testing was performed in accordance with ASME Code,Section IX by signing the record of Welder/Welding Operator, Brazer, Brazing Operator Performance Qualification (WPQ/BPQ).
b)
The Owner who performed the qualification test shall certify, in writing, that the qualification was conducted in accordance with a Quality Assurance Program that satisfies the requirements of ASME Code,Section XI, IWA-1400.
c)
The Owner accepting the WPQ/BPQ, shall obtain any necessary supporting information to satisfy ASME Code,Section IX, QW-301.4 (e.g., Welding Procedure Specification, type of tests).
d)
The Owner accepting the WPQ/BPQ, shall require each welder, welding operator, brazer, or brazing operator to demonstrate proficiency by completing a renewal qualification test in accordance with QW-322.2(a) or QB-322(b).
(1)
When WPQ transfer involves prior groove tests, the renewal test shall use a groove configuration.
(2)
When WPQ transfer involves fillet tests, the renewal test may be either fillet or groove configuration.
e)
The Owner accepting the WPQ/BPQ, shall accept responsibility for the Performance Qualification Test, and shall document acceptance on the WPQ/BPQ for the renewal test. This WPQ/BPQ shall reference the WPQ/BPQ supplied by the Owner that performed the qualification.
f)
The Owner accepting the WPQ/BPQ shall accept responsibility for compliance with ASME Section IX, QW-322.
g)
The Owner may accept and use a WPQ/BPQ only when it is received directly from the Owner who performed the qualification.
h)
The Owner accepting the WPQ/BPQ shall comply with the Quality Assurance requirements of IWA-4142(a).
Paragraph E-8" in relief requests, RR-32 (JAF), RR-64 (IP2), RR-3-33(A) (IP3), and PRR-33 (PNPS) states, "Entergy will comply with the Quality Assurance requirements of ASME Code Section XI, 1998 Edition, Article IWA-4142(a)." This requirement is from ASME Code Case N-600, paragraph (h). However, for JAF, IP2, IP3, and PNPS, the applicable Code of Record is ASME Code,Section XI, 1989 Edition, no Addenda. The 1989 Edition does not have a subparagraph IWA-4142(a). Instead, the applicable Quality Assurance requirements are included in Article IWA-1400 of the 1989 Edition of the ASME Code,Section XI. In this specific application only, the NRC authorizes the implementation of a later approved edition of this paragraph in the ASME Code for these repair/replacement activities, since Section XI, 1998 Edition IWA-4142(a)(1) specifies that the Quality Assurance Program shall comply with the following: IWA-1400(n) when the owner is the Repair/Replacement organization. Since the owner is the Repair/Replacement organization, then these ASME Code sections are essentially equivalent. Therefore, Entergy will implement ASME Code Case N-600 in its entirety, including the IWA-4142(a) requirements of the later edition of the ASME Code. Revision 1 of the request for relief for IP2, IP3, JAF, and PNPS reflect this code case requirement.
Based upon our review of the information provided by the licensee, the NRC staff finds that the above listed alternative requirements of ASME Code Case N-600 specify an acceptable level of control for the owner accepting a WPQ/BPQ. For example, the licensee would be required to:
(1) review and accept the responsibility of the WPQ/BPQ, and (2) demonstrate technical competence in application of the received WPQ/BPQ by completing a renewal performance qualification test in accordance with article QW-322.2(a) of ASME Code,Section IX. These actions will ensure the acceptability of the WPQ/BPQ prior to it being used at JAF, IP2, IP3, PNPS, and VY. The NRC staff also finds that qualification of a WPQ/BPQ for the purpose of welding or brazing may be performed by any Owner provided the applicable requirements for WPQ/BPQ qualification are maintained. The Owners may use WPQ/BPQ qualified by other Owners provided the conditions/requirements listed in ASME Code Case N-600 are met.
Therefore, the proposed alternative will provide an acceptable level of quality and safety.
4.0 CONCLUSION
The NRC staff has determined that the proposed alternative welding and brazing personnel qualification requirement of the code case would provide a comparable level of quality and safety as that of the ASME Code,Section XI, Article IWA-4440(b), for the JAF, IP2, IP3, PNPS, and Articles IWA-4440(c) and (d) for VY. Therefore, the use of ASME Code Case N-600 is authorized pursuant to 10 CFR 50.55a(a)(3)(i) at the JAF, IP2 & IP3, and PNPS during the remainder of the third 10-year ISI interval and during the remainder of the fourth 10-year ISI interval at VY. The licensee is authorized to use ASME Code Case N-600 until such time as the code case is included in a future revision of RG 1.147. At that time, the licensee must follow all provisions and any limitations that may be described in RG 1.147 concerning the use of ASME Code Case N-600.
All other requirements of the ASME Code,Section III and XI, for which relief has not been specifically requested and approved remain applicable, including third party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: E. Andruszkiewicz Date: July 6, 2004