ML050980068

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Draft Request for Additional Information
ML050980068
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 04/08/2005
From: Richard Ennis
NRC/NRR/DLPM/LPD1
To: Darrell Roberts
NRC/NRR/DLPM/LPD1
Ennis R, NRR/DLPM, 415-1420
References
TAC MC5850
Download: ML050980068 (4)


Text

April 8, 2005 MEMORANDUM TO: Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager, Section 2 /RA/

Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MC5850)

The attached draft request for information (RAI) was transmitted on April 7, 2005, to Ms. Ronda Daflucas of Entergy (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees request dated February 7, 2005. The licensee requested the Nuclear Regulatory Commissions approval to use a more recent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for the pressure testing requirements of Class 1, 2, and 3 items following repair/replacement activities performed by welding or brazing on a pressure-retaining boundary at Vermont Yankee Nuclear Power Station.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensee's request.

Docket No. 50-271

Attachment:

Draft RAI

April 8, 2005 MEMORANDUM TO: Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager, Section 2 /RA/

Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NO. MC5850)

The attached draft request for information (RAI) was transmitted on April 7, 2005, to Ms. Ronda Daflucas of Entergy (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees request dated February 7, 2005. The licensee requested the Nuclear Regulatory Commissions approval to use a more recent edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for the pressure testing requirements of Class 1, 2, and 3 items following repair/replacement activities performed by welding or brazing on a pressure-retaining boundary at Vermont Yankee Nuclear Power Station.

This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensee's request.

Docket No. 50-271

Attachment:

Draft RAI DISTRIBUTION PUBLIC DRoberts MMitchell VBucci, OIG PDI-2 Reading REnnis CSydnor ACCESSION NO.: ML050980068 OFFICE PDI-2/PM NAME REnnis DATE 04/07/05 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION REQUEST TO USE SUBSEQUENT EDITION AND ADDENDA OF ASME CODE, SECTION XI FOR PRESSURE TESTING REQUIREMENTS FOR REPAIRS/REPLACEMENTS PERFORMED BY WELDING OR BRAZING VERMONT YANKEE NUCLEAR POWER STATION DOCKET NO. 50-271 By letter dated February 7, 2005, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (Entergy or the licensee) requested the Nuclear Regulatory Commissions (NRCs or Commissions) approval to use a more recent edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) for the pressure testing requirements of Class 1, 2, and 3 items following repair/replacement activities performed by welding or brazing on a pressure-retaining boundary at Vermont Yankee Nuclear Power Station (VYNPS).

The NRC staff has reviewed the information the licensee provided that supports the proposed request and would like to discuss the following issues to clarify the submittal:

1. Title 10 of the Code of Federal Regulations (10 CFR), Section 50.55a(g)(4)(iv), states that inservice examination of components and system pressure tests may meet the requirements set forth in subsequent editions and addenda of the ASME Code,Section XI that are incorporated by reference in paragraph (b) of 10 CFR 50.55a, subject to the limitations and modifications listed therein, and subject to Commission approval. The regulation also states that portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

Pursuant to 10 CFR 50.55a(g)(4)(iv), the licensee has requested in its letter dated February 7, 2005, to use the 2001 Edition 2003 Addenda of the ASME Code,Section XI, Article IWA-4540, subparagraph (a), as applicable, for pressure testing of Class 1, 2, and 3 items following repair/replacement activities performed by welding or brazing on a pressure-retaining boundary. Specifically, the licensee has proposed to implement the requirements of the 2003 Addenda of the ASME Section XI Code, Article IWA-4540, subparagraph (a) in the VYNPS Repair/Replacement Program.

The licensees request to use the subsequent edition and addenda for the ASME Code subparagraph discussed above did not include the related requirements of the 2003 Addenda of the ASME Code,Section XI, Article IWA-4540, subparagraphs (c) and (d),

which read as follows:

(c) Replacement components and appurtenances shall be pressure tested in accordance with the Construction Code selected for use in accordance with IWA-4221.

ATTACHMENT

(d) Brazed joints and welds in replacement parts and piping subassemblies, fabricated by the Repair/Replacement Organization, or fabricated in accordance with the Construction Code without a hydrostatic pressure test, shall be tested as required by IWA-4540(a).

The licensees request also did not include the related requirements of Article IWA-4540, subparagraph (b) in the 2003 Addenda of the ASME Code,Section XI.

However, the licensees Code of Record for the Fourth Inservice Inspection Interval at VYNPS, the 1998 Edition through the 2000 Addenda of the ASME Code,Section XI contains requirements in Article IWA-4540, subparagraph (b) that are identical to those in the corresponding subparagraph in the 2003 Addenda of the ASME Code,Section XI.

Please clarify your pressure testing program for Class 1, 2, and, 3 systems and components following repair/replacement activities which specifically involve the use of replacement components and/or piping subassemblies containing welded or brazed joints that make up part of a pressure-retaining boundary. Please discuss whether you intend to use all requirements related to the 2003 Addenda of the ASME Code,Section XI, Article IWA-4540, subparagraph (a), specifically subparagraphs (c) and (d) of IWA-4540 in the 2003 Addenda.

2. Please clarify the ASME Code,Section XI Edition and Addenda that VYNPS proposes to use for the requirements of Article IWA-5000 that are referenced by Article IWA-4540, subparagraph (a).