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Category:Letter type:CNRO
MONTHYEARCNRO-2021-00023, Entergy Operations, Inc. - Supplement to CNRO-2021-00002, Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L2021-10-0606 October 2021 Entergy Operations, Inc. - Supplement to CNRO-2021-00002, Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L CNRO-2021-00002, Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L2021-01-28028 January 2021 Entergy Operations, Inc. - Basis for Concluding the Terms of Confirmatory Order EA-17-132/EA-17-153 Are Complete, Element L CNRO-2020-00023, Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary2020-12-17017 December 2020 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2020 Summary CNRO-2020-00016, Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv)2020-08-12012 August 2020 Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv) CNRO-2019-00030, Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary2019-12-30030 December 2019 Response to Confirmatory Order EA-17-132/EA-17-153, Element K 2019 Summary CNRO-2019-00010, Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2019-03-28028 March 2019 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2019-00007, Grand Gulf Nuclear Station; and Waterford 3 Steam Electric Station - Decommissioning Funding Status Report2019-03-28028 March 2019 Grand Gulf Nuclear Station; and Waterford 3 Steam Electric Station - Decommissioning Funding Status Report CNRO-2019-00013, Entergy Response to Confirmatory Order EA-17-132/EA-17-1532019-03-21021 March 2019 Entergy Response to Confirmatory Order EA-17-132/EA-17-153 CNRO-2019-00003, Application to Revise Technical Specifications to Adopt TSTF-529 11 Clarify Use and Application Rules, 11 Revision 42019-01-31031 January 2019 Application to Revise Technical Specifications to Adopt TSTF-529 11 Clarify Use and Application Rules, 11 Revision 4 CNRO-2019-00002, Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 12019-01-31031 January 2019 Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1 CNRO-2018-00051, Grand Gulf Nuclear Station, Palisades Nuclear Plant, River Bend Station, Pilgrim Nuclear Station and Waterford 3 - Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K2018-12-28028 December 2018 Grand Gulf Nuclear Station, Palisades Nuclear Plant, River Bend Station, Pilgrim Nuclear Station and Waterford 3 - Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element K CNRO-2018-00039, Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J2018-09-27027 September 2018 Entergy Response to Confirmatory Order EA-17-132/EA-17-153, Element J CNRO-2018-00021, Response to Request for Supplemental Information Regarding Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in the Spent Fuel Pools for Indian Point Energy Center, Unit 3 and Waterford 3 Steam Electric Station2018-05-30030 May 2018 Response to Request for Supplemental Information Regarding Generic Letter 2016-01, Monitoring of Neutron Absorbing Materials in the Spent Fuel Pools for Indian Point Energy Center, Unit 3 and Waterford 3 Steam Electric Station CNRO-2018-00011, Submittal of Joint Plant Access Shared Information Table2018-03-19019 March 2018 Submittal of Joint Plant Access Shared Information Table CNRO-2017-00022, Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 12017-11-17017 November 2017 Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 1 CNRO-2017-00010, Entergy Operations, Inc. - Decommissioning Funding Status Report2017-03-31031 March 2017 Entergy Operations, Inc. - Decommissioning Funding Status Report CNRO-2017-00007, Nuclear Property Damage Insurance (10 CFR 50.54(w)(3))2017-03-30030 March 2017 Nuclear Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2016-00017, Entergy Nuclear Operations - Request for Approval of Change to the Quality Assurance Program Manual2016-07-19019 July 2016 Entergy Nuclear Operations - Request for Approval of Change to the Quality Assurance Program Manual CNRO-2016-00016, Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated)2016-06-0202 June 2016 Entergy - Response to RAI Questions and Submittal of Relief Request EN-ISI-15-1 (Updated) CNRO-2016-00008, Entergy - Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2016-03-30030 March 2016 Entergy - Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2016-00005, Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM)2016-02-25025 February 2016 Response to Request for Additional Information Pertaining to a Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2016-00004, Notice Regarding Acquisition of Title to Leased Interest2016-02-10010 February 2016 Notice Regarding Acquisition of Title to Leased Interest CNRO-2016-00002, Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Secti2016-01-29029 January 2016 Entergy - Relief Request Number RR EN-15-1, Rev. 1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Water Service, Section Xl, CNRO-2015-00002, Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 12015-12-0404 December 2015 Entergy Operations, Inc. - Response to RAI Questions and Submittal of RR EN-15-2, Rev. 1 CNRO-2015-00022, Entergy - Relief Request EN-ISI-15-1: Proposed Alternative to Maintain ISI-Related Activities to the 2001 Edition/2003 Addendum of ASME Section Xl Code2015-11-20020 November 2015 Entergy - Relief Request EN-ISI-15-1: Proposed Alternative to Maintain ISI-Related Activities to the 2001 Edition/2003 Addendum of ASME Section Xl Code CNRO-2015-00023, Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM)2015-11-0606 November 2015 Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM) CNRO-2015-00020, ISFSI and Waterford 3 Steam Electric Station and ISFSI Re Required Notification of Receipt of All Required Regulatory Approvals of the Proposed Transfer Actions and Documentary Evidence of Required Insurance2015-09-23023 September 2015 ISFSI and Waterford 3 Steam Electric Station and ISFSI Re Required Notification of Receipt of All Required Regulatory Approvals of the Proposed Transfer Actions and Documentary Evidence of Required Insurance CNRO-2015-00018, Entergy - Relief Request Number RR EN-15-2 - Proposed Alternative to Use ASME Code Case N-786-1, Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping, Section XI, Division 1.2015-08-20020 August 2015 Entergy - Relief Request Number RR EN-15-2 - Proposed Alternative to Use ASME Code Case N-786-1, Alternative Requirements for Sleeve Reinforcement of Class 2 and 3 Moderate-Energy Carbon Steel Piping, Section XI, Division 1. CNRO-2015-00017, Entergy Submits Relief Request RR EN-15-1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Waster Service, Section XI, D2015-06-0505 June 2015 Entergy Submits Relief Request RR EN-15-1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Waster Service, Section XI, Division CNRO-2015-00012, Arkansas, Units 1 & 2, Grand Gulf, River Bend, Waterford, Unit 3, Indian Point, Units 1, 2, & 3, Pilgrim, James A. FitzPatrick, Big Rock, Palisades - Submittal of Revision of Quality Assurance Program Manual2015-04-30030 April 2015 Arkansas, Units 1 & 2, Grand Gulf, River Bend, Waterford, Unit 3, Indian Point, Units 1, 2, & 3, Pilgrim, James A. FitzPatrick, Big Rock, Palisades - Submittal of Revision of Quality Assurance Program Manual CNRO-2015-00010, Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2015-03-27027 March 2015 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2015-00011, Grand Gulf Nuclear Station Unit 1 and Waterford 3 Steam Electric Station Submittal of Decommssioning Funding Status Report for 20142015-03-27027 March 2015 Grand Gulf Nuclear Station Unit 1 and Waterford 3 Steam Electric Station Submittal of Decommssioning Funding Status Report for 2014 CNRO-2015-00007, ISFSI, Waterford, Unit 3, and ISFSI, Responses to NRC Request for Additional Information Regarding Application for Order Approving Transfers of Licenses and Conforming License Amendments2015-01-30030 January 2015 ISFSI, Waterford, Unit 3, and ISFSI, Responses to NRC Request for Additional Information Regarding Application for Order Approving Transfers of Licenses and Conforming License Amendments CNRO-2014-00009, Response to Request for Additional Information for Review of the Decommissioning Funding Plans for Entergy Operations, Inc., Independent Spent Fuel Storage Installations2014-07-24024 July 2014 Response to Request for Additional Information for Review of the Decommissioning Funding Plans for Entergy Operations, Inc., Independent Spent Fuel Storage Installations CNRO-2014-00007, ISFSI, Waterford 3 and ISFSI - Application for Order Approving Transfers of Licenses and Conforming License Amendments2014-06-10010 June 2014 ISFSI, Waterford 3 and ISFSI - Application for Order Approving Transfers of Licenses and Conforming License Amendments CNRO-2014-00003, Entergy Nuclear Operations, Inc., Annual Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3) and 10 CFR 72.140(d) Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G2014-04-25025 April 2014 Entergy Nuclear Operations, Inc., Annual Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a)(3) and 10 CFR 72.140(d) Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G CNRO-2014-00004, Unit 3, Letter (CNRO-2014-00002/ENOC-14-00010) of Same Subject 03/31/20142014-04-0303 April 2014 Unit 3, Letter (CNRO-2014-00002/ENOC-14-00010) of Same Subject 03/31/2014 CNRO-2014-00001, Completion of Change to the Entergy Quality Assurance Program Manual with Regards of Confirmatory Order EA-11-0962014-02-26026 February 2014 Completion of Change to the Entergy Quality Assurance Program Manual with Regards of Confirmatory Order EA-11-096 CNRO-2013-00009, Grant Gulf, River Bend, Unit 1 and Waterford 3, Response to Request for Additional Information Regarding 2013 Decommissioning Fund Status Report - Entergy Operations, Inc2013-06-20020 June 2013 Grant Gulf, River Bend, Unit 1 and Waterford 3, Response to Request for Additional Information Regarding 2013 Decommissioning Fund Status Report - Entergy Operations, Inc CNRO-2013-00007, Annual Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a) and 10 CFR 72.140(d) Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G2013-04-26026 April 2013 Annual Report for Quality Assurance Program Manual Changes Under 10 CFR 50.54(a) and 10 CFR 72.140(d) Notification of Application of Approved Appendix B to 10 CFR 72 Subpart G CNRO-2013-00008, Arkansas, Units 1, 2 & ISFSI, Grand Gulf, ESP and ISFSI, River Bend, Unit 1 and ISFSI and Waterford 3 and ISFSI, Application for Order Approving Transfers of Licenses and Conforming License and ESP Amendments2013-04-16016 April 2013 Arkansas, Units 1, 2 & ISFSI, Grand Gulf, ESP and ISFSI, River Bend, Unit 1 and ISFSI and Waterford 3 and ISFSI, Application for Order Approving Transfers of Licenses and Conforming License and ESP Amendments CNRO-2013-00006, Decommissioning Funding Status Report - Entergy Operations, Inc2013-03-29029 March 2013 Decommissioning Funding Status Report - Entergy Operations, Inc CNRO-2013-00004, Entergy Operations, Inc. and Entergy Nuclear Operations, Inc., Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3))2013-03-25025 March 2013 Entergy Operations, Inc. and Entergy Nuclear Operations, Inc., Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) CNRO-2013-00002, Responses to NRC Request for Additional Information Regarding Application for Order Approving Transfers of Licenses and Conforming License and ESP Amendments2013-01-29029 January 2013 Responses to NRC Request for Additional Information Regarding Application for Order Approving Transfers of Licenses and Conforming License and ESP Amendments CNRO-2012-00009, Entergy Responses to Request for Additional Information Regarding Changes to the Quality Assurance Program Manual & Associated Plant Technical Specifications Re Staff Qualifications2012-11-20020 November 2012 Entergy Responses to Request for Additional Information Regarding Changes to the Quality Assurance Program Manual & Associated Plant Technical Specifications Re Staff Qualifications CNRO-2012-00007, Grand Gulf Nuclear Station & Waterford 3 Steam Electric Station Status of Decommissioning Funding - Entergy Operations, Inc2012-10-15015 October 2012 Grand Gulf Nuclear Station & Waterford 3 Steam Electric Station Status of Decommissioning Funding - Entergy Operations, Inc CNRO-2012-00006, Updated Schedule of Submittal of Future License Renewal Applications for Entergy Plants2012-10-11011 October 2012 Updated Schedule of Submittal of Future License Renewal Applications for Entergy Plants CNRO-2012-00004, Request for Additional Information Regarding Changes to the Entergy Quality Assurance Program Manual (QAPM) and Associated Plant Plant Technical Specifications Regarding Staff Qualifications2012-05-21021 May 2012 Request for Additional Information Regarding Changes to the Entergy Quality Assurance Program Manual (QAPM) and Associated Plant Plant Technical Specifications Regarding Staff Qualifications CNRO-2012-00003, Annual Report for Quality Assurance Program Manual Changes Under 10CFR50.54(a)(3) and 10CFR72.140(d) Notification of Application of Approved Appendix B to 10CFR72 Subpart G2012-04-30030 April 2012 Annual Report for Quality Assurance Program Manual Changes Under 10CFR50.54(a)(3) and 10CFR72.140(d) Notification of Application of Approved Appendix B to 10CFR72 Subpart G CNRO-2011-00006, Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM) and Associated Plant Technical Specifications Regarding Staff Qualifications2011-12-13013 December 2011 Request for Approval of Change to the Entergy Quality Assurance Program Manual (QAPM) and Associated Plant Technical Specifications Regarding Staff Qualifications 2021-10-06
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Entergy Operations, Inc.
tergy 1340 Echelon Parkway Jadcson, Mississippi 39213-8298 Tel 601-368-5755 F. G. Burford Acting Director Nuclear Safety & Ucensing CNRO-2007-00011 March 8, 2007 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Request for Alternative W3-4SI-002 Request to Extend the Current ASME Inservice Inspection Interval in accordance with NRC Informaton Notice 98-44 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
REFERENCE:
NRC letter, Grand Gulf NuclearStation, Unit 1 - Request for Alternative GG-ISI-003 RE: Extending the CurrentInservice Inspection interval In accordance with U. S. NuclearRegulatory Commission Information Notice 98-44 (TAC No. MD3167), dated February 13, 2007
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 Waterford Steam Electric Station, Unit 3 (Waterford 3) to the end of its sixteenth refueling outage (RFo16), currently scheduled for the fall 2009. This request is enclosed as Request for Alternative W3-lSI-002.
The requested extension is approximately seventeen months beyond the one-year extension allowed by ASME Section XAIWB-2412(b).
NRC approved a similar request for Grand Gulf Nuclear Station (GGNS) via the referenced letter. Request for Alternative W3-4S-002 contains Information pertaining to Waterford 3 that addresses the request for additional Information for the GGNS submittal.
A4c/
CNRO-2007-00011 Page 2 of 2 Entergy requests that the NRC approve W3-ISI-002 by April 1, 2008. Should you have any questions regarding this submittal, please contact Guy Davant at (601) 368-5756.
This letter contains no commitme'nts.
Very truly yours, FGB/GHD/ghd
Enclosure:
Request for Alternative W3-ISI-002 cc: Mr. W. A. Eaton (ECH)
Mr. J. S. Forbes (ECH)
Mr. K. T. Walsh (W3)
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. M. B. Fields MS O-7D1 Washington, DC 20555-0001 NRC Senior Resident Inspector Waterford Steam Electric Station, Unit 3 P. 0. Box 822 Killona, LA 70066
ENCLOSURE CNRO-2007-00011 REQUEST FOR ALTERNATIVE W3-ISI-002
ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION, UNIT 3 REQUEST FOR ALTERNATIVE W3-ISI-002 Components/N umbers: 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
- 3. EPRI Technical Report MRP-1 39, Materials Reliability Program: PrimarySystem Piping Butt Weld Inspection and Evaluation Guidelines (MRP-139)
Examination Category: B-J, B-F, C-F-i, and C-F-2 Item Numbers: All
==
Description:==
Piping Welds Unit / Inspection Interval Waterford Steam Electric Station, Unit 3 (Waterford 3)!
Applicability: Second (2 nd) 10-year interval
- 1. CODE REQUIREMENT(S)
The ISI code of record for Waterford 3 is ASME Section XI 1992 Edition with portions of the 1993 Addenda applicable to pressure testing [see the NRC's safety evaluation report dated December 12, 1996 (TAC No. M94488)].
ASME Section Xl 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 sixteenth refueling outage (RF-16) currently scheduled for the fall 2009 for items in Examination Categories B-F, B-J, C-F-i, and C-F-2. This alternative will not affect the third interval start date.
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III. 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 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.
Waterford 3 is currently in the third period of the second IS[ interval as defined by ASME Section XI Code for Inspection Program B. The second 10-year ISI interval began July 1997 and ends June 2007. Invoking the Code-allowed one-year extension extends the interval to June 2008.
Entergy is planning to submit to the NRC staff a request for alternative to implement a risk-informed / safety-based inservice inspection (RISB) program at Waterford 3.
Entergy plans to implement the RISB ISI program during RF-1 6 currently scheduled for the fall 2009. To accomplish this, Entergy requires approval of this request, which extends the second ISI interval to the end of RF-1 6 (approximately seventeen months beyond the Code-allowed one-year extension).
The Waterford 3 RISB process will be based upon ASME Code Case N-716, Alternative Piping Classificationand ExaminationRequirements,Section XI 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.
If the to-be-requested RI-ISI program, based on ASME Code Case N-716, is not accepted by the staff, Entergy plans to submit a different request for alternative to establish an RI-ISI program at Waterford 3 based on ASME Code Case N-578, which the staff has approved for several licensees. With such a submittal, Entergy would also seek an additional extension of the third interval, if necessary. In the unlikely event the staff does not approve a RI-ISI program based on either code case, Entergy would then perform the necessary Code-required examinations for the third interval.
Table IWB-2412-1 requires that a minimum of 50% of the ASME Section XI examinations be completed by the end of the second period of an inspection interval. By the end of the thirteenth refueling outage (RF-1 3), which was in the second period of the second interval, 62% of the piping weld examinations required by ASME Section XI had been Page 2 of 4
completed for Examination Categories B-F, B-J, C-F-1, and C-F-2.1 Therefore, Waterford 3 met the minimum requirement specified in Table IWB-2412-1. By the end of the last refueling outage (RF-14), 65% of the required piping weld examinations have been completed.
During the time period needed for NRC review and approval of the RI-ISI program request, Entergy plans to perform required augmented inspection programs as committed to the staff in various correspondence. For example, augmented inspections of piping locations in the break exclusion 'region are scheduled to be performed during RF-1 5 in accordance with Waterford 3 FSAR Section 6.6.8. Entergy will also continue to examine Alloy 600 welds as allowed by EPRI MRP-1 39 (Ref. 3) and as committed to the staff in Entergy letter CNRO-2007-00005, Inspection and Mitigation of Alloy 600/82/182 PressurizerButt Welds, dated February 21, 2007.
Entergy is planning to submit the request for the Waterford 3 RISB Program following approval of the request submitted for Grand Gulf Nuclear Station (GGNS).2 Entergy expects the Waterford 3 request to be submitted after RF-1 5. Entergy intends to start implementing the RISB Program at Waterford 3 during the plant's third period of the second inspection interval. As stated above, by the end of the previous refueling outage (RF-1 4), 65% of the piping weld examinations required by ASME Section XI have been completed in the second ISI interval for Examination Categories B-F, B-J, C-F-i, and C-F-2. To ensure that 100% of the required examinations are performed during the current ISI interval, 35% of the inspection locations selected for examination per the RISB process will be examined in the third period of the interval. The third ISI interval will implement 100% of the inspection locations selected for examination per the program approved by the staff. Examinations shall be performed such that the period percentage requirements of ASME Section XI are met.
IV. CONCLUSION 10CFR50.55a(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."
1 Entergy transmitted this information to the NRC via letter W3F1 -2004-0010, Submittal of Owners Activity Report Forms for Inservice Inspection Performedduring Refueling Outages 11 and 12, dated February 17, 2004.
2 Entergy submitted the GGNS request via letter CNRO-2006-00043, Request forAltemative GG-ISI-002 - Request to Use ASME Code Case N-716, dated September 22, 2006.
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As discussed in Section III above, the extension to the end of RF-1 6 would allow time for the NRC to review Waterford 3's 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).
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