CNRO-2006-00047, Request for Alternative RBS-ISI-005, Request to Extend the Current ASME Inservice Inspection Interval in Accordance with NRC Information Notice 98-44
| ML063120415 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 11/01/2006 |
| From: | Burford F Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNRO-2006-00047, IN-98-044, RBS-ISI-005 | |
| Download: ML063120415 (8) | |
Text
~Entergy Entergy Operations, Inc.
1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5755 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2006-00047 November 1, 2006 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Request for Alternative RBS-ISI-005 Request to Extend the Current ASME Inservice Inspection Interval in accordance with NRC Information Notice 98-44 River Bend Station Docket No. 50-458 License No. NPF-47
REFERENCE:
Entergy letter CNRO-2006-00044 to the NRC dated October 4, 2006
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) requests approval to extend the second Inservice Inspection (ISI) interval for piping at River Bend Station (RBS) to the end of its fifteen refueling outage, currently scheduled for spring 2009. This request is enclosed as Request for Alternative RBS-ISI-005. This request does not involve Examination Category B-F piping welds, which are inspected in accordance with Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. The requested extension is approximately five months beyond the one-year extension allowed by ASME Section Xl IWB-2412(b).
Entergy has submitted a similar request for Grand Gulf Nuclear Station via the referenced letter.
A 0 4-7
9 CNRO-2006-00047 Page 2 of 2 Entergy requests that the NRC approve RBS-ISI-005 by November 1, 2007. Should you have any questions regarding this submittal, please contact Guy Davant at (601) 368-5756.
This letter contains no commitments.
Very truly yours, FGB/GHD/ghd
Enclosure:
Request for Alternative RBS-ISI-005 cc:
Mr. W. A. Eaton (E-MCH-38)
Mr. P. D. Hinnenkamp (R-GSB-40)
Dr. Bruce S. Mallett U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 U. S. Nuclear Regulatory Commission Attn: Mr. B. K. Vaidya MS O-7D1A Washington, DC 20555-0001 NRC Senior Resident Inspector River Bend Station P. 0. Box 1050 St. Francisville, LA 70775
I ENCLOSURE CNRO-2006-00047 REQUEST FOR ALTERNATIVE RBS-ISI-005
ENTERGY OPERATIONS, INC.
RIVER BEND STATION REQUEST FOR ALTERNATIVE RBS-ISI-005 Components/Numbers:
Piping Welds Code Class:
1 and 2
References:
- 1.
ASME Section XI, 1992 Edition
- 2.
NRC Information Notice 98-44, Ten-Year Inservice Inspection Program Update for Licensees that Intend to Implement RI-ISI of Piping Examination Category:
B-J, C-F-i, and C-F-2 Item Numbers:
All
==
Description:==
Piping Welds Unit / Inspection Interval River Bend Station (RBS) second (2 nd) 10-year interval Applicability:
- 1.
CODE REQUIREMENT(S)
ASME Section XI Table IWB-2412-1 defines an inservice inspection (ISI) interval to be 10 years in duration. IWB-2412(b) allows extending the interval for one year to coincide with a plant outage.
I1. REQUESTED ALTERNATIVE Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) requests authorization to extend the current ISI interval to include an additional refueling outage, which will be the fifteenth refueling outage (RF-1 5) currently scheduled for spring 2009 for items in Examination Categories B-J, C-F-i, and C-F-2. This alternative will not affect the third interval start date of December 1, 2007.
Ill. BASIS FOR RELIEF NRC Information Notice (IN) 98-44, Ten-Year Inservice Inspection Program Update for Licensees that Intend to Implement RI-ISI of Piping (Reference 2), states that the probabilistic risk assessment technology in NRC regulatory activities should be increased to the extent supported by state-of-the-art methods and data and in a manner that complements the NRC's deterministic approach. Basically, this information combined with risk assessment techniques and associated data provides for developing an effective approach to the ISI program. This approach provides an acceptable level of quality and safety, as required by 10 CFR 50. 55a(a)(3)(i). IN 98-44 also states that the NRC staff will consider authorizing a delay of up to 2 years in implementing the next Page 1 of 2
10-year ISI program for piping only in order for the licensee to develop and obtain approval for the risk-informed ISI program for piping.
RBS is currently in the second ISI interval as defined by ASME Section XI Code for Inspection Program B. RBS is planning to submit to the NRC staff a request for alternative to implement a risk-informed / safety-based inservice inspection (RISB) program. Entergy plans to implement the RISB ISI program during RF-15 currently scheduled for the spring 2009. To accomplish this, Entergy requires approval of this request to extend the second ISI interval to the end of RF-15 (approximately 5 months beyond the Code-allowed one-year extension).
The RBS RISB process will be based upon ASME Code Case N-716, Alternative Piping Classification and Examination Requirements, Section Xl Division 1, which is founded in large part on the RI-ISI process as described in Electric Power Research Institute (EPRI)
Topical Report (TR) 112657 Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure. The associated request for alternative will demonstrate a reduction in risk (or maintains risk neutrality) while substantially reducing worker exposure and undue burden. Because risk-informed ISI programs focus inspections (and inspection methods) on locations potentially susceptible to degradation while considering the consequence of piping failure, a more robust targeted inspection program can be defined.
IV. CONCLUSION 1 OCFR50.55a(a)(3) states:
"Proposed alternatives to the requirements of (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate that:
(i) The proposed alternatives would provide an acceptable level of quality and safety, or (ii) Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."
As discussed in Section III above, the extension to the end of RF-15 would allow time for the NRC to review RBS' risk-informed ISI submittal while not affecting future ISI intervals.
Therefore, Entergy requests authorization to perform the requested alternative to the Code requirement pursuant to 10 CFR 50.55a(a)(3)(i).
Page 2 of 2
NRC Submittal Review Letter #: CNRO-2006-00047 Response Due: N/A Date Issued for Review:, 10/10/06 Subject" Request for Alternative RBS-ISI-005 - Request to Extend the Current ASME Inservice Inspection Interval in accordance with NRC Information Notice 98-44 Correspondence P-reparer Pho.ne #: Guy Davant I 8-433-5756 Section I Letter Concurrence and Agreement to Perform Actions CONCURRENCE (sign, interoffice memo, e-mail, or telecom)
POSITION i NAME
- ACTION, SIGNATURE:
Corporate Engineering Concur See attached response to Programs Supervisor/
Steve Lewis COMMENTS Section II Correspondence Screening Does this letter contain commitments? If "yes," identify the commitments with due dates Yes in the submittal and in Section III.
No Z
Does this letter contain any information or analyses of new safety issues performed at NRC Yes
[]
request or to satisfy a regulatory requirement? If "yes," reflect requirement to update the No
[
UFSAR in Section III Does this letter request NRC approval of a change that may/will require UFSAR, TS Bases, or Yes
[
other Licensing documents to be updated if approved? If "yes," reflect requirement to No Z
update the applicable Licensing document in Section III.
Does this letter require procedure changes, if approved? If "yes," indicate in Section III an Yes L
action for the responsible department to determine the affected procedures. (The No
[
Correspondence Preparer may indicate the specific procedures requiring revision, if known.)
Does this letter contain information certified accurate? If "yes," identify the information and Yes Dl document certification in an attachment. (Attachment 9.6 may be used.)
No Z
Section III Action Items Required Actions Due Date Responsible Note: Actions needed upon approval should be captured Dept.
in the appropriate action tracking system None
Section IV Final Document Signoff for Submittal Correspondence Preparer Guy Davant Final Peer Review (optional)
Responsible Department Jerry Burford (See signed letter.)
Head
Entergy CORRECTIVE ACTION LO-LAR-2006-00138 CA Number:
1 Group
.1 Name I
Assigned By: ECH NS&L Staff Assigned To: ECH Eng Programs Mgmt Subassigned To :
Davant,Guy H Lewis,Raymond S Originated By: Davant,Guy H 10/10/2006 14:37:32 Performed By: Lewis,Raymond S 10/16/2006 16:33:31 Subperformed By:
Approved By:
Closed By: Lewis,Raymond S 10/I 6/2006 16:33:31 Current Due Date: 10/20/2006 Initial Due Date: 10/20/2006 CA Type: CONCURRENCE REVIEW Plant Constraint: OUTAGE RAI CA
Description:
Please review and concur with letter CNRO-2006-00047, which contains Request for Alternative RBS-ISI-005. A copy of this letter is attached to the CONDITION DESCRIPTION field of this LAR.
Response
Approved.
Subresponse:
Closure Comments: