ML051940490

Request for Additional Information on Relief Request No. RR-37

ML051940490
Person / Time
Site:	FitzPatrick
Issue date:	07/07/2005
From:	Ted Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Dyer J Office of Nuclear Reactor Regulation
References
JAFP-05-0104
Download: ML051940490 (4)

Text

• Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. Fitzpatrick NPP RO. Box 110 Lycoming, NY 13093 Tel 315 349 6024 Fax 315 349 6480 T.A. Sullivan Site Vice President - JAF July 7, 2005 JAFP-05-01 04 Mr. James Dyer Director, Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for Additional Information on Relief Request No. RR-37

Reference:

1. Letter, T. Sullivan to J. Dyer (JAFP-05-0102), dated July 6, 2005, Request for Approval of Relief Request No. RR-37, Alternative Test per 10 CFR 50.55a(a)(3)(i) from the 1998 Edition of ASME Section Xl as supplemented by the 1992 Edition ASME Section Xl through 1992 Addenda for Repair/Replacement Activities, IWE-5221, Tests Following Repair/Replacement Activities and Section III, NE-5200, Required Examination of Welds Dear Sir Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Nuclear Operations, Inc. (ENO) submitted a relief request to perform an alternative test to that specified by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code as required under the James A. FitzPatrick (JAF) Containment Inservice Inspection Program (Reference 1). Relief was also requested from the radiographic examination requirements of ASME Section 1I1.

During a telephone conference with members of the NRC Staff on July 7, 2005, additional information was requested by the Staff to assist them in the review of Reference 1. The requested information is included with this letter as Attachment 1. As noted in response to, Question 1, the categorization of the weld as a Category 'D' weld, results in there being no requirement for radiography on the weld repair. Therefore, JAF withdraws that portion of Relief Request No. RR-37.

There are no new commitments made in this letter. Should you have any questions or comments concerning this submittal, please contact Mr. Rick Plasse at (315) 349-6793.

Sincerely, T. A. Sullivan Site Vice President A ;

Attachments: 1. Request for Additional Information Pertaining to Relief Request No. RR-37

2. Description of The Torus Weld Cap (Sketch) cc:

Regiopal Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King df Prussia, PA 19406-1415 Office of the Resident Inspector U. S. Nuclear Regulatory Commission P. 0. box 136 LycoMing, NY 13093 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, IOth Floor Albany, New York 12223 Mr. John P. Boska, Project Manager Project Directorate I Divisicn of Licensing Project Management Office! of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop: 0-8-BI Washington, DC 20555-0001 Mr. Peter R. Smith, President NYSIRDA 17 Columbia Circle Albany, NY 12203-6399 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 to JAFP-05-0104 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Request for Additional Information Pertaining to Relief Request No. RR-37 Question 1: Please discuss the categorization of this weld Per the ASME Code.

Based on review of the code of record for the Mark 1 containment upgrades, ASME Section III, Subsection NE (1974 Edition through Summer 1977 Addenda), paragraph NE-3350 addresses the design of welded connections and categorizes weld joints into Categories 'A' through 'D'.

Paragraph NE-3351.4 defines Category 'D' weld joints to include nozzles attaching to the main shells. The repair cap weld joint is in the form of a nozzle connection and therefore, is classified as an ASME Section 1I1, Subsection NE Category 'D' weld joint. The weld joint type has been classified as a full penetration corner weld. As such per NE-5242 surface examination is required but radiography is not. Therefore, no relief from the code requirements is required and JAF is withdrawing that portion of Relief Request No. RR-37.

Question 2: Your relief request Indicates that 100% radiographic coverage of the weld Is not achievable. Please provide a sketch of how the nearby support/reinforcement members Interfere with the radiography.

Please see response to question one for discussion of categorization and requirements for category 'D' welds.

Question 3: NE-5280, "Special Exceptions for Radiography." is a Code alternative that oermits using UT and surface examinations In lieu of RT. Provide a discussion on the difficulties with performing UT examinations of the weld.

Please see response to question one for discussion of categorization and requirements for category 'D' welds.

Question 4: In previous discussions it was stated that surface examinations would be performed after each weld laver of the full penetration weld. Please provide a discussion to this effect In writina.

In Attachment 1 to Reference 1, Section E, Proposed Alternative And Basis For Use, ENO modifies its original discussion regarding weld examination as follows: "(1) perform surface examination of the root pass, each intermediate weld layer and the final weld, and (2) perform visual examination of each pass of the weld including the final weld."

Question 5: Please provide a cross-section sketch of the weld configuration.

See attached sketch.

Reference:

1. Letter, T. Sullivan to J. Dyer (JAFP-05-0102), dated July 6, 2005, Request for Approval of Relief Request No. RR-37, Alternative Test per 10 CFR 50.55a(a)(3)(i) from the 1998 Edition of ASME Section Xl as supplemented by the 1992 Edition ASME Section Xl through 1992 Addenda for Repair/Replacement Activities, IWE-5221, Tests Following Repair/Replacement Activities and section III, NE-5200, Required Examination of Welds Page 1 of I to JAFP-05-0104 Entergy Nuclear Operations, Inc. - FitzPatrick Docket No. 50-333 Request for Additional Information Pertaining to Relief Request No. RR-37 Description Of The Torus Cap Weld The weld joint is a full penetration groove weld with a fillet weld cap. The groove depth is approximately 7/8 with an approximate 7/8' fillet cap size. Details of the repair cap and weld joint are provided below.

12.9375" Diameter(Kax.)

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Full Penetration Weld Innsal1d Page 1 of 1