ML073380107
| ML073380107 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/03/2007 |
| From: | Bottemiller C Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GNRO-2007-00075, IN-98-044 | |
| Download: ML073380107 (5) | |
Text
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~*Entergy GNRO-2007-00075 December 3, 2007 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Entergy Operations, Inc.
Waterloo Road P.O. Box 756 Port Gibson, MS 39150 Tel 601 437 6299 Charles A. Bottemiller Attention:
Subject:
Document Control Desk lSI Request for Alternative GG-ISI-004 Request to Extend the Current ASME Inservice Interval in accordance with NRC Information Notice 98-44 Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
Dear Sir or Madam:
Pursuant to 10CFR50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) requests approval to extend the current Inservice Inspection (lSI) interval for piping and certain components at Grand Gulf Nuclear Station (GGNS) to the end of its sixteenth refueling outage (RF-16), currently scheduled for fall 2008. This request is enclosed as Request for Alternative GG-ISI-004. The requested extension is approximately four months beyond the one-year extension allowed by ASME Section XIIWB-2412(b).
Entergy requests that the NRC staff approve GG-ISI-004 by May 2, 2008 in order to support planning efforts for the upcoming fall 2008 refueling outage at GGNS. Should you have any questions regarding this submittal, please contact Michael Larson at (601) 437-6685.
This letter contains no commitments.
Sincerely, CAB/MJL
Enclosure:
Request for Alternative GG-ISI-004 cc:
(See Next Page)
GNRO-2007/00075 Page 2 cc:
NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. Elmo E. Collins (w/a)
Regional Administrator, Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ATTN: Mr. Bhalchandra Vaidya,NRR/DORL (w/2)
ATTN: ADDRESSEE ONLY ATTN: U.S. Postal Delivery Address Only Mail Stop OWFN/O-8G14 Washington, D.C. 20555-0001
ENCLOSURE GNRO-2007-00075 REQUEST OF ALTERNATIVE GG-ISI-004
- Page 1 REQUEST FOR ALTERNATIVE GGNS-ISI-004 Components/Numbers:
Code Classes:
References:
Examination Category:
Item Number(s):
==
Description:==
Unit /Inspection Interval Applicability:
B13-N04F-KB and B13-N05B-KB ASME Code Class 1
- 1. ASME Section XI 1992 Edition
- 2. CNRI-2007-00004, dated February 13, 2007 (TAC No. MD3167)
B-F, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles B5.10 NPS 4 or Larger Nozzle-to-Safe End Butt Welds Grand Gulf Nuclear Station (GGNS), Second (2nd) 10-year interval l.
CODE REQUlREMENT(S)
ASME Section XI Table IWB-2412-1 defines an inservice inspection (lSI) interval to be 10 years in duration. IWB-2412(b) allows extending the interval for one year to coincide with a plant outage.
ASME Section XI, Table IWB-2500-1, Examination Category B-F, Pressure Retaining Dissimilar Metal Welds in Vessel Nozzles, Items B5.1 0, requires 100% volumetric examination of the Class 1 Nozzle-to-Safe End Butt Welds.
II.
REQUESTED ALTERNATIVE Pursuant to 10CFR50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) requests authorization to extend the current lSI interval to include an additional refueling outage, which will be the sixteenth refueling outage (RF-16) currently scheduled for fall 2008 for components B13-N04F-KB and B13-N05B-KB (category B-F).
The requested extension is approximately four months beyond the one-year extension allowed by ASME Section XI IWB-2412(b). This alternative will not affect the start date of the third interval.
III.
BASIS FOR RELIEF During the fifteenth refueling outage (RF-15) Entergy attempted to examine nozzle to safe end welds B13-N04F-KB and B13-N05B-KB and determined none of the required ultrasonic examination could be performed on the subject welds due to the weld configuration/profiles. An attempt was made to perform the needed surface preparation but a large amount of grinding (flat topping) was needed. Because of the critical nature of grinding on class 1 piping welds and the high dose rates in the RPV (reactor pressure vessel) annulus region, it was determined that an engineering evaluation/structural analysis was necessary in order to safely plan and execute the preparation of the welds.
- Page 1 III.
Basis for Relief (cant.)
Due to the critical nature of the task and after communication with the NRC staff, Entergy decided to defer the examinations and prepare for this work until after RF-15. The surface preparation (grinding) along with the weld examinations will be performed during the next refueling outage (RF-16).
Entergy has already submitted and received approval of a similar request to extend the second Inservice Inspection interval per letter CNRI-2007-0004 dated February 13, 2007(TAC No. MD3167) for Category B-J, C-F-1 and C-F-2 piping welds in accordance with NRC Information Notice 98-44. However, this request did not include Category B-F piping welds, which are inspected in accordance with Generic Letter 88-01.
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."
As discussed in Section III above, the extension of the interval to the end of RF-16 would allow time for Entergy to properly develop and execute a succession plan in achieving the required ultrasonic examination on the subject piping welds. Therefore, Entergy requests authorization to perform the requested alternative to the Code requirements pursuant to 10 CFR 50.55a(a)(3) (i).