ML080930176

Approval of Relief Requests for 10 Year Updates to the 120 Month Inservice Testing Intervals

ML080930176
Person / Time
Site:	Waterford
Issue date:	06/10/2008
From:	Hiltz T NRC/NRR/ADRO/DORL/LPLIV
To:	Entergy Operations
References
TAC MD7728
Download: ML080930176 (6)

Text

June 10, 2008 Vice President, Operations Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3 17265 River Road Killona, LA 70057-3093

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - RELIEF REQUEST FOR 10 YEAR UPDATES TO THE 120 MONTH INSERVICE TESTING INTERVALS (TAC NO. MD7728)

Dear Sir or Madam:

By letter dated November 29, 2007, Entergy Operations, Inc., (Entergy, the licensee), submitted relief request PRR-WF3-2007-1 for the third 10-year interval inservice testing (IST) program at Waterford Steam Electric Station, Unit 3. The licensee requested relief from certain IST requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants.

The U.S. Nuclear Regulatory Commission (NRC) staff has completed its review of the relief request and, pursuant to paragraph 50.55a(a)(3)(i), of Title 10 of the Code of Federal Regulations, is authorizing relief request PRR-WF3-2007-1 on the basis that the proposed alternative would provide an acceptable level of quality and safety.

The NRC staff safety evaluation is enclosed.

Sincerely,

/RA/

Thomas G. Hiltz, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-382

Enclosure:

Safety Evaluation cc w/encl: See next page

ML080930176 *SE **NLO OFFICE NRR/LPL4/PM NRR/LPL4/LAiT NRR/DCI/CPTB* OGC NRR/LPL4/BC NAME NKalyanam GLappert JMcHale (*) MSpencer (**) THiltz DATE 06/10/08 06/05/08 3/20/08 5/19/08 06/10/08 Waterford Steam Electric Station, Unit 3 (2/25/08) cc:

Senior Vice President Mr. Timothy Pflieger Entergy Nuclear Operations Environmental Scientist - Supervisor P.O. Box 31995 REP&R-CAP-SPOC Jackson, MS 39286-1995 Louisiana Department of Environmental Quality Vice President, Oversight P.O. Box 4312 Entergy Nuclear Operations Baton Rouge, LA 70821-4312 P.O. Box 31995 Jackson, MS 39286-1995 Parish President Council St. Charles Parish Senior Manager, Nuclear Safety P.O. Box 302

& Licensing Hahnville, LA 70057 Entergy Nuclear Operations P.O. Box 31995 Chairman Jackson, MS 39286-1995 Louisiana Public Services Commission P.O. Box 91154 Senior Vice President Baton Rouge, LA 70825-1697

& Chief Operating Officer Entergy Operations, Inc. Mr. Richard Penrod, Senior Environmental P.O. Box 31995 Scientist/State Liaison Officer Jackson, MS 39286-1995 Office of Environmental Services Northwestern State University Associate General Counsel Russell Hall, Room 201 Entergy Nuclear Operations Natchitoches, LA 71497 P.O. Box 31995 Jackson, MS 39286-1995 Resident Inspector Waterford NPS Manager, Licensing P.O. Box 822 Entergy Operations, Inc. Killona, LA 70057-0751 Waterford Steam Electric Station, Unit 3 17265 River Road Regional Administrator, Region IV Killona, LA 70057-3093 U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE INSERVICE TESTING PROGRAM, THIRD 10-YEAR INTERVAL ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NUMBER 50-382

1.0 INTRODUCTION

By letter dated November 29, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070410350), Entergy Operations, Inc. (Entergy, the licensee),

submitted a relief request for the third 10-year inservice testing (IST) program interval at Waterford Steam Electric Station, Unit 3 (Waterford 3). The licensee requested relief from certain IST requirements of the 2001 Edition through 2003 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code). The Waterford 3 third 10-year IST interval commenced on December 1, 2007.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Part 50 Section 50.55a, requires that IST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (10-year)

IST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the U.S. Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month IST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), IST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b),

subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. In proposing alternatives or requesting relief, the licensee must demonstrate that: (1) the proposed alternatives provide an acceptable level of quality and safety; (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety; or (3) conformance is impractical for the facility. 10 CFR 50.55a authorizes the NRC to approve alternatives and to grant relief from ASME OM Code requirements upon making necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, AGuidance on Developing Acceptable Inservice Testing Programs,@ provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, and NUREG-1482 Revision 1, AGuidelines for Inservice Testing at Nuclear Power Plants.@

3.0 TECHNICAL EVALUATION

3.1 Pump Relief Request PRR-WF3-2007-1 3.1.1 Code Requirements The licensee requested relief from the requirements of ISTB-3510(b)(1), AData Collection, General, Range@ for charging pumps CVC-MPMP-0001A, CVC-MPMP-0001A/B, and CVC-MPMP-0001B. The pumps are positive displacement, motor driven pumps, ASME Code Class 2, and are classified as Group A pumps.

ISTB-3510(b)(1) requires that the full-scale range of each analog instrument shall be not greater than three times the reference value.

3.1.2 Licensee=s Basis for Requesting Relief The licensee states:

The charging pumps= discharge flow indicator does not comply with the requirement of ISTB-3510(b)(1). Each of the three pumps produces a flow of 44 gallons per minute (gpm). The flow gauge has a full-scale range of 150 gpm in order to accommodate three-pump flow, such as during safety injection operations. The full-scale range is approximately 3.4 times the reference value.

3.1.3 Licensee=s Proposed Alternative Testing The licensee states:

The existing installed flow indicator will be used for the Group A and comprehensive pump testing per ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda ISTB requirements.

According to Revision 1 of NUREG-1482, Section 5.5.1, when the range of a permanently installed analog instrument is greater than three times the reference value, but the accuracy of the instrument is more conservative than that required by the Code, the staff may grant approval to use an alternative when the combination of the range and accuracy yields a reading that is at least equivalent to that achieved using instruments that meet the Code requirements (i.e., up to "6.0 percent).

The accuracy of the instrument used for measuring charging pump discharge flow is "0.7 percent. This accuracy is more conservative than the "2.0 percent required by Subsection ISTB-3510 of the ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda.

The combination of range and accuracy for the charging pumps= discharge flow instrument is 2.39 percent, which is more conservative than the combined range and accuracy of instruments that meet the minimum Code requirements (i.e., up to "6 percent).

3.1.4 Evaluation Despite the fact that the flow indicator for charging pumps CVC-MPMP-0001A, CVC-MPMP-0001A/B, and CVC-MPMP-0001B does not meet the Code requirement for range, it is capable of providing an indicated accuracy at the reference value that is superior to the minimum indicated accuracy that would be required by the Code. Based on the least accurate instrument that would theoretically be allowed by the Code, the minimum required indicated accuracy is "6 percent for Group A tests and comprehensive tests (documented by NUREG-1482 Revision 1, Section 5.5.1). The indicated accuracy of the flow indicator for the charging pumps, as derived based upon the current reference value, is as follows:

Minimum reference value = 44 gpm Full scale range = 150 gpm Instrument tolerance = "1.05 gpm (0.7 percent x 150 gpm)

Therefore the indicated accuracy is: 1.05 gpm / 44 gpm x 100 percent = 2.39 percent As demonstrated, the indicated accuracy of the flow indicator for charging pumps CVC-MPMP-0001A, CVC-MPMP-0001A/B, and CVC-MPMP-0001B is better than the accuracy allowed by the Code. The reading accuracy achieved from the installed flow indicator meets the intent of the Code and yields an acceptable level of quality and safety for Group A tests and comprehensive tests.

3.1.5 Conclusion Based on the above evaluation, the NRC staff concludes that the licensee=s proposed alternative to the Code accuracy requirements for instruments during pump testing is authorized pursuant to 10 CFR 50.55a(a)(3)(i), on the basis that the alternative provides an acceptable level of quality and safety. The licensee=s proposed alternative provides reasonable assurance of the operational readiness of the pumps. The alternative is authorized for the third 10-year IST program interval.

Principle Contributor: R. Wolfgang Date: June 10, 2008