ML070120081
| ML070120081 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 02/02/2007 |
| From: | Terao D NRC/NRR/ADRO/DORL/LPLIV |
| To: | Burford F Entergy Operations |
| Vaidya B, NRR/DORL/LP4, 415-3308 | |
| References | |
| CEP-PT-001, TAC MD1399, TAC MD1400, TAC MD1401, TAC MD1402, TAC MD1403 | |
| Download: ML070120081 (10) | |
Text
February 2, 2007 Mr. F. G. Burford Acting Director Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298
SUBJECT:
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2, GRAND GULF NUCLEAR STATION, RIVER BEND STATION, AND WATERFORD STEAM ELECTRIC STATION, UNIT 3 - REQUEST FOR ALTERNATIVE CEP-PT-001, VISUAL EXAMINATION OF VENT AND DRAIN LEAKAGE TESTS (TAC NOS. MD1399, MD1400, MD1401, MD1402, AND MD1403)
Dear Mr. Burford:
By letter dated April 24, 2006, Entergy Operations, Inc. (the licensee) submitted a request for relief (No. CEP-PT-001) related to the inservice inspection (ISI) program pertaining to system leakage tests for Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3. In the request for relief, the licensee proposed to perform a system leakage test of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1 pressure-retaining components in reactor coolant pressure boundary vent and drain connections with the inboard isolation valve closed that would isolate a small segment of Class 1 line from the system boundary for pressurization.
Based on the Nuclear Regulatory Commissions (NRC) evaluation of the request for relief, the staff concluded in the enclosed safety evaluation that the licensees proposed alternative provides reasonable assurance of structural integrity, and compliance with the ISI Code of Record would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Therefore, pursuant to Title 10 of the Code of Federal Regulations, 50.55a(a)(3)(ii), the NRC staff authorizes the ISI program alternative proposed in CEP-PT-001 for the third 10-year intervals of Arkansas Nuclear One, Units 1 and 2, and the second 10-year intervals of Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3.
F. G. Burford The NRC staff's related Safety Evaluation is enclosed.
Sincerely,
/RA/
David Terao, Chief Project Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-313, 50-368, 50-416, 50-458, and 50-382
Enclosure:
Safety Evaluation cc w/encl: See next page
- Minor editorial changes made to staff SE OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DCI/CFEB OGC-NLO NRR/LPL4/BC NAME BVaidya LFeizollahi KGruss
- PMoulding DTerao DATE 1/23/07 1/18/07 10/30/06 1/31/07 2/2/07
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF CEP-PT-001 ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 GRAND GULF NUCLEAR STATION RIVER BEND STATION WATERFORD STEAM ELECTRIC STATION, UNIT 3 ENTERGY OPERATIONS, INC.
DOCKET NOS. 50-313, 50-368, 50-416, 50-458, 50-382
1.0 INTRODUCTION
By letter dated April 24, 2006, Entergy Operations, Inc. (the licensee), submitted a request for relief (No. CEP-PT-001) related to the inservice inspection (ISI) program pertaining to system leakage tests for Arkansas Nuclear One, Units 1 and 2 (Arkansas 1 and 2), Grand Gulf Nuclear Station (GGNS), River Bend Station (RBS), and Waterford Steam Electric Station, Unit 3 (Waterford 3). In the request for relief, the licensee proposed to perform a system leakage test of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1 pressure retaining components in reactor coolant pressure boundary (RCPB) vent and drain connections with the inboard isolation valve closed that would isolate a small segment of Class 1 line from the system boundary for pressurization. The licensees request for relief is based on hardship of making multiple entries into the drywell for the valve alignment and thus, exposing personnel to high radiation and the risk of failure due to single-valve isolation. The Nuclear Regulatory Commission (NRC) staff has evaluated the licensees request for relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(a)(3)(ii) on the basis that compliance with the ASME Code requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.0 REGULATORY REQUIREMENTS Paragraph 10 CFR 50.55a(g) requires that ISI of ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Code and applicable addenda, except where specific written relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i). Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraph 50.55a(g) may be used, when authorized by the NRC, if an applicant demonstrates that the proposed alternatives would provide an acceptable level of quality and safety or if compliance with the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection (ISI) of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that ISI of components and system pressure tests conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The ISI Code of Record for the third 10-year intervals of Arkansas 1 and 2, and the second 10-year intervals of GGNS, RBS, and Waterford 3, is the 1992 Edition through the 1993 Addenda of the ASME Code,Section XI.
3.0 TECHNICAL EVALUATION
System/Component(s) for which Relief is Requested RCPB Vent and Drain Connections ASME Code Requirements The 1992 Edition through the 1993 Addenda of ASME Code,Section XI, Table IWB-2500-1, Examination Category B-P, Item Nos. B15.50 and B15.70 requires a system leakage test in accordance with paragraph IWB-5220. Paragraph IWB-5222(b) on Boundaries states [t]he pressure retaining boundary during system leakage test conducted at or near the end of each inspection interval shall extend to all Class 1 pressure retaining components within the system boundary.
Licensees Request for Relief Relief is requested from paragraph IWB-5222(b) during performance of a system leakage test of RCPB vent and drain connections with the inboard isolation valve in the normally-closed position, which would isolate a small segment of Class 1 line between the inboard and outboard valves from the system boundary for pressurization.
Licensees Basis for Requesting Relief Many of the vent and drain connections off the RCPB have double-manual isolation valves.
The requirement to extend the system leakage test boundary to the outboard valve on these vent and drain connections results in a hardship without a compensating increase in the level of quality and safety. Repositioning the inboard manual valves before and after the test will take considerable time and will result in an unnecessary increase in radiological dose to plant personnel. These off-normal configurations may also contribute to the risk of delaying normal plant start-up because of the critical path time and effort required to ensure configuration is restored.
Based on previous pressure test dose rates, Entergy estimates that complying with the current IWB-5222(b) requirement would result in an additional accumulated dose of approximately 1 man-rem (roentgen equivalent man) at Arkansas 1 and 2 and Waterford 3, and approximately 0.25 man-rem at GGNS and RBS.
The vent and drain connections are normally closed during plant operation. The outboard valves only see pressure if the inboard valve is open or leaks by the seat. Seat leakage, although undesirable, is not indicative of a flaw in the pressure boundary. Furthermore, these valves are generally located close to the main runs of pipe. The non-isolable portion of these vent and drain connections is pressurized and VT-2 examined during each refueling outage with the inboard isolation valve closed. In the event that leakage past the inboard valve is occurring, the VT-2 examination would be performed on the pipe while pressurized.
The plant technical specifications for RCPB leakage monitoring provide reasonable assurance that appropriate actions including a plant shutdown would be taken if leakage exceeded specified limits.
Licensees Proposed Alternative Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee proposes an alternative to perform VT-2 visual examination of RCPB vent and drain connections for leakage with the inboard isolation valve in the normally closed position during the system leakage test conducted at or near the end of each inspection interval required by IWB-5222(b).
4.0 STAFF EVALUATION The ASME Code,Section XI, of Record requires that all Class 1 components within the RCPB undergo a system leakage test at the end of each refueling outage and a system hydrostatic test at or near the end of each inspection interval. In Relief Request No. CEP-PT-001, the licensee proposed an alternative to the ASME Code requirement to perform a hydrostatic leakage test of the RCPB vent and drain connections. The proposed alternative would isolate a segment of piping between the inboard and outboard isolation valves from being pressurized during a hydrostatic leakage test. The pipe segments include two manually-operated valves separated by a short pipe that is connected to the reactor coolant system (RCS). The line configuration, as outlined, provides double-isolation of the RCS. Under normal plant operating conditions, the subject pipe segments would see RCS temperature and pressure only if leakage through the inboard isolation valves occurs. For the licensee to perform the ASME Code-required test, it would be necessary to manually open the inboard valves to pressurize the pipe segments. Pressurization by this method would preclude the RCS double-valve isolation and may cause safety concerns for the personnel performing the examination.
Typical line/valve configurations are in close proximity to the RCPB main runs of pipe and, thus, would require personnel entry into high-radiation areas within the containment. Manual actuation (opening and closing) of these valves is estimated to expose plant personnel to approximately 1 man-rem each at Arkansas 1 and 2 and Waterford 3, and approximately 0.25 man-rem at GGNS and RBS per test. The NRC staff agrees that this would constitute a hardship for the licensee. The licensee proposed to visually examine the isolation valves in the normally-closed position for leaks, which would indicate any evidence of past leakage during the operating cycle. Also, the RCPB vent and drain connections will be visually examined with the isolation valves in the normally-closed position during the 10-year system hydrostatic test.
Therefore, the NRC staff believes that the licensees proposed alternative will provide reasonable assurance of structural integrity for the RCPB vent and drain connections while maintaining personnel radiation exposure to as low as reasonably achievable. Therefore, the NRC staff has determined that compliance with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
5.0 CONCLUSION
Based on the NRC staffs evaluation of the request for relief, the licensees proposed alternative provides reasonable assurance of structural integrity, and compliance with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the proposed alternative in Relief Request No. CEP-PT-001 is authorized for the third 10-year intervals of Arkansas 1 and 2, and the second 10-year intervals of GGNS, RBS, and Waterford 3. All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested remain applicable, including a third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Prakash Patnaik Date: February 2, 2007
January 2007 Arkansas Nuclear One, Units 1 and 2 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 cc:
Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 General Manager Plant Operations Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Director, Nuclear Safety Assurance Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Manager, Licensing Entergy Operations, Inc.
Arkansas Nuclear One 1448 SR 333 Russellville, AR 72802 Director, Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298 Section Chief, Division of Health Radiation Control Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Section Chief, Division of Health Emergency Management Section Arkansas Department of Health and Human Services 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County 100 W. Main Street Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Mr. Jeffrey S. Forbes Site Vice President Arkansas Nuclear One Entergy Operations, Inc.
1448 SR 333 Russellville, AR 72802 Chief Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P.O. Box 10385 Jackson, MS 39289-0385 President Claiborne County Board of Supervisors P.O. Box 339 Port Gibson, MS 39150 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 399 Port Gibson, MS 39150
Arkansas Nuclear One, Units 1 and 2 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 January 2007 Attorney General Department of Justice State of Louisiana P.O. Box 94005 Baton Rouge, LA 70804-9005 State Health Officer State Board of Health P.O. Box 139 Jackson, MS 39205 Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Asst. Attorney General State of Mississippi P.O. Box 22947 Jackson, MS 39225-2947 Director Nuclear Safety Assurance Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Manager, Licensing Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Richard Penrod, Senior Environmental Scientist/State Liaison Officer Office of Environmental Services Northwestern State University Russsell Hall, Room 201 Natchitoches, LA 71497 Mr. William R. Brian Vice President of Operations Grand Gulf Nuclear Station Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150 General Plant Manager Operations Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Louisiana Department of Environmental Quality Radiological Emergency Planning and Response Division P.O. Box 4312 Baton Rouge, LA 70821-4312 Louisiana Department of Environmental Quality Office of Environmental Compliance P.O. Box 4312 Baton Rouge, LA 70821-4312 Senior Resident Inspector P.O. Box 1050 St. Francisville, LA 70775 President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, LA 70775 Ms. H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, LA 70806 General Manager Plant Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Director, Nuclear Safety Assurance Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775
Arkansas Nuclear One, Units 1 and 2 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 January 2007 Manager, Licensing Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Mr. Jim Calloway Public Utility Commission of Texas 1701 N. Congress Avenue Austin, TX 78711-3326 Attorney General State of Louisiana P.O. Box 94095 Baton Rouge, LA 70804-9095 Brian Almon Public Utility Commission William B. Travis Building P.O. Box 13326 1701 North Congress Avenue Austin, Texas 78701-3326 Mr. Joseph E. Venable Vice President of Operations Entergy Operations, Inc.
River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Director Nuclear Safety Assurance Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Manager, Licensing Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Resident Inspector/Waterford NPS P.O. Box 822 Killona, LA 70066-0751 Parish President Council St. Charles Parish P.O. Box 302 Hahnville, LA 70057 Chairman Louisiana Public Services Commission P.O. Box 91154 Baton Rouge, LA 70825-1697 Mr. Kevin T. Walsh Vice President of Operations Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093