ML081090536
| ML081090536 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/29/2005 |
| From: | Bethay S Entergy Nuclear Operations |
| To: | Document Control Desk, NRC/SECY |
| SECY RAS | |
| References | |
| 50-293-LR, ASLBP 06-848-02-LR, Pilgrim-Staff-55, RAS J-85 | |
| Download: ML081090536 (9) | |
Text
- 7! DOCKETED I I5PKIPCl.
Aoril 15. 2008 (10:00am)
Entergy Nuclear Operations, Inc.
Pilgrim Station
~Entergy OFFICE OF SECRETARY 600 Rocky Hill Road Pi ii rwAik-(rlIM AImA - Plymouth, MA 02360 Stephen J. Bethay Dreclor, NuClar Assessmcnt (IS.NUCLEA FEGUIAAlRY COMISO=
June 29, 2005 Dodd N. Sqz2..3 Offica atW t No.
OFFID by: Applicttfliense Intivea____
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 AcdoinTaken: ILIECT MTWIMD
SUBJECT:
Entergy Nuclear Operations, Inc.
Ramimlt _T h Il L.b Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Pilgrim Fourth Ten-Year Inservice Inspection Program Plan, and ther Associated Relief Requests for NRC Approval LETTER NO:, 2.05.045
Dear Sir or Madam:
By this letter Entergy submits the attached Pilgrim Nuclear Power Station (PNPS) Fourth Ten-Year Inservice Inspection (ISI) Program Plan (PNPS-RPT-05-001, Rev. 0) pursuant to 10 CFR 50.55a(a)(g)(4)(ii) and requests NRC approval of associated relief requests pursuant to 10 CFR 50.55a(a)(3).
PNPS Fourth Ten-Year ISI Interval will commence on July 1,2005 and ends on June 30, 2015.
This ISI Program Plan is developed in accordance with the 1998 Edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section Xl with the 2000 Addenda. The ISl Program Plan is divided into five major sections:
1.0 Introduction and Plan Description 2.0 ISI System / Component Exemptions & Examination Development 3.0 Code Compliance Inservice Inspection Program Summary 4.0 Inservice Inspection Components & Schedule 5.0 Appendices The ISI Program Plan contains the Second Ten-Year IWE Containment Inspection program and Second Ten-Year Risk Informed ISI program. Both programs have been aligned with the regular ISI program interval schedule.
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Entergy Nuclear Operations, Inc. Letter Number: 2.05.045 Pilgrim Nuclear Power Station Page 2 The Code of Record for the Fourth Ten-Year ISI Interval, the Second IWE Containment Inspection interval, and the Second RI-ISI interval will be the ASME Section XI Code, 1998 Edition with 2000 Addenda. Accordingly, this letter requests NRC acceptance for these programs to be based upon the aforementioned EditiornAddenda.
Fourth Ten-Year ISI Relief Requests for NRC Approval:
The relief requests associated with the Fourth Ten-Year ISI Program Plan and any precedent are contained in Section 5, Appendix B of the Program Plan. There are thirteen (13) relief requests. Two (2) relief requests PRR-28 (MB6074) and PRR-39 (MC2496) were previously approved for use during the 4 th Interval are included for information. In addition, three (3) requests related to the use of subsequent editions and addenda of Section XI of the ASME Code are Included in Appendix D.
Entergy requests NRC review and approval of the ISI Relief Requests as soon as possible, preferably by July 1, 2006.
This submittal represents ISI Program Plan and does not contain any regulatory commitments.
If you have any questions on this transmittal, please contact Mr. Bryan Ford, Licensing Manager at 508-830-W403.
Sincerely, 7-Stephen J.Bethay 6 SJB/wgI
Attachment:
- 1. PNPS Fourth Ten-Year ISI Program Plan, including IWE Containment Inspection Program (PNPS-RPT-05-001, Rev. 0) cc: Regional Administrator, Region 1 w/o U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. James Shea, Project Manager Project Directorate I Mail Stop: 0-8B-1 Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Senior Resident Inspector Pilgrim Nuclear Power Station
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---Entergy Nuclear Northeast Entergy Nuclear Generation Company PILGRIM NUCLEAR POWER STATION (PNPS)-
Plymouth, Massachusetts ASME B&PV CODE SECTION XI FOURTH TEN-YEAR INSPECTIONINTER VAL INSER VICE INSPECTION (ISi)PR0 GRAM PLA N July 1, 2005 to June 30, 2015 Commercial Service Date: June 8, 1972 NRC Docket Number: 50-293 Facility Operating License: DPR-35 Document Number: PNPS-RPT-05-001 Revision Number: 0 Document Date: July 1, 2005 Prepared by:
Entergy Nuclear Northeast 440 Hamilton A venue White Plains,New York 10601
EntergyPNSRT5-0 Nuclear Northeast Pilgrim Nuclear Powcr Station ASME SECTION XI FOURTH TEN-YEAR INTERVAL INSERVICE INSPECTION PNPS-RPT-eS-v. 1 (
PROGRAM PLAN One of the tasks required to complete the Third Interval ISI Program Update at the Pilgrim Nuclear Power Station was to perform a review of the classification boundaries for inservice inspections.
This was documented under Vectra Report 0025-00241-001. Vectra documented the information and decisions in developing recommended and required revisions to the IS1 boundaries for clarification purposes.
1.3.1 Code of Federal Renulations (IOCFR50)
Sections 50.55a(c), (d) and (e), reference I 0CFR5O.2, and Regulatory Guide 1.26 for the classification ofQuality Group A, and Quality Groups B and C components, respectively.
Footnote 9 of IOCFR50.55a specifically invokes Regulatory Guide 1.26. IOCFR50.2 provides criteria for the classification of Quality Group A components.
In accordance with IOCFRF50.55a(c), the Class I boundaries are described in I0CFRS0.2 which defines the reactor coolant boundary as follows:
"All those pressure-containing components of boiling and pressurized water-cooled nuclear power reactors such as pressure vessels, piping, pumps, and valves, which are:
(1) Part of the reactor coolant system, or (2) Connected to the reactor coolant system, up to and including any and all of the following:
(i) The outermost containment isolation valve in system piping which penetrates (
primary reactor containment, (ii) The second of two valves normally closed during normal reactor operation in system piping which does not penetrate primary reactor containment, (iii) The reactor coolant system safety and relief valves.
For nuclear power reactors of the direct cycle boiling water type, the reactor coolant system extends to and includes the outermost containment isolation valve inthe main steam and feedwater piping."
This is the definition which is used for Class I systems at Pilgrim Station.
1.3.2 Regulatory Guilde 1.26 IOCFRSO.55a does not specifically defime the boundaries for Class 2 and 3 piping systems, but in Footnote 9 itrefers to RegulatoryGuide 1.26 and NUREG-0OSQ, Section 3.2.2 forguidance. For Pilgrim Station, guidance is taken from Regulatory Guide 1.26 which provides general boundary definitions for systems containing water, steam or radioactive waste. It should be noted that Regulatory Guide 1.26 specifically states that it does not address other systems such as
"...instrument and service air, diesel engine and its generators and auxiliary support systems, diesel fuel, emergency and normal ventilation, fuel handling, and radioactive waste management systems".
1-3.3 ASME Section X1 In accordance with I0CFR50.55a, the inservice inspection of Class 1, 2 and 3 piping and components will be governed by ASME Section XM. When applying the criteria of ASME Section 1-11
Pilgrim Nuclear Power Station T EfltPV ASME SECTION XI FOURTIH TEN-YEAR PNPS-RPTr-05-001 Rev. 0 Nuclear Northeast INTERVAL INSERVICE INSPECTION PROGRAM PLAN XI, one of the main considerations is the exemption criteria presented in Paragraphs IWB-1220, IWC-1220 and IWD-1220 for Class 1,2 and 3 systems respectively. These paragraphs state specific criteria for the exemption of components due to various factors including line size, system function and operating conditions. One exemption which requires particular attention is the exemption of Class I components due to make-up flow capacity as presented in IWB- 1220(a). As addressed in BECo Boundary Study Document NED 90-300, attached NUTECH Letter No. BOS.-06-01 1, and its associated make-up capacity calculation, Class I piping in water systems with an inside diameter of 1.10" or less, and piping in steam systems with an inside diameter of 2.20" or less qualify for the make-up capacity exemption of IWB 1220(a).
ASME Section XI Examination Categories B-F and B-J currently contain the requirements for the nondestructive examination (NDE) of Class 1 piping components. The alternative RI-ISI program for piping is described Section 1.5.2.1 of this ISI Program Plan.
The RI-ISI Program will be substituted for the Section XI program for Class I piping in accordance with IOCFR50.55a(aX3)(i) by alternatively providing an acceptable level of quality and safety. Other non-related portions of the ASME Section XI Code will be unaffected. For example, existing pressure testing requirements and Class 2 piping inspection requirements remained unchanged. EPRI TR-1 12657 provides the methodology for defining the relationship between the RI-ISI program and the remaining unaffected portions of ASME Section XI.
1.3.4 Updated Final Safety Analysis Report (FSAR) .. .
In general, the PNPS Updated Final Safety Analysis Report (FSAR) provides limited references to inservice inspection requirements. There axe numerous references to inservice inspections interspersed throughout the FSAR, but most are inconsequential discussions on accessibility or testing requirements, FSAR Appendix K addresses the general requirements ofPilgrim's 1SI Program, but it only covers the First Interval ISI Program. The PNPS FSAR does not establish any additional commitments which must be incorporated into the IS! Program.
1.3.5 NRC Commitments In general, Pilgrim Station was designed and constructed prior to many of the Code and Regulatory documents becoming mandatory. The augmented examination requirements which have been issued since the start of plant operation are currently being performed at Pilgrim Station under PNPS Procedure No. NEI5.08, "ControlofAugmented Examinations". Although the documents listed in this procedure provide augmented examination requirements, they do not affect the inservice inspection boundaries.
1.3.6 IS! Ciassification & Flow Diagrams The Inservice Inspection classification process described above resulted in system classifications indicating ASME Class 1, 2, 3, and MC components. Class boundaries were developed and are shown on the ISI flow diagrams (151 P&IDs) listed in Appendix E Table E. I.
For ASME Class I components, the requirements of Subsection I\VB apply;, for ASME Class 2 components, the requirements of Subsection I\VC apply, for ASME Class 3 components, the rules of Subsection IWV'D apply; and for ASME Class MC components, the requirements of Subsection IWE apply. The rules of Subsection IWF for component supports apply to ASME Classes 1, 2, 3, and MC.
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E n te w*}*. Pilgrim Nuclear Power Station PNPS-RPT-05-001 ASME SECTION XI FOURTH TEN-YEAR Rev. 0
- Nuclear Northeast INTERVAL INSERVICE INSPECTION PROGRAM PLAN 1.4.4 The ASME Section XI Repair/.Replacement Program will be implemented and maintained in accordance with separate plant site procedures. Repair and replacement requirements for Class MC components (Code Subsection IWE) are included within the site'sSection XI Repair / Replacement Program.
1.5 Auemented and Alternative Tnservice Inspection Requirements 1.5.1 Auumented Inservice Inspection Requirements Augmented inservice inspection requirements are those examinations that are specified by documents other than the ASME Section XI Code. Augmented examinations will be performed as required by IOCFR50.55a, the NRC, Response to RAts, or as deemed necessary by the ISI Program. The augmented inservice inspections performed at the Pilgrim Nuclear Power Station are documented in controlled PNPS Procedure No.
NE 15.08, "ControlofA ugmented Examinations", latest revision. Current augmented examination programs include:
1.5.1.1 Piping Flow-Acceler*ied Corrosion (FAC) Monitoring Flow accelerated corrosion (FAC) examinations are performed in accordance within the separate and independent PNPS FAC Program under SpecificationM577. The PNPS FAC Program satisfiesNRC'd.L. 89-08 using the guidelines developed by NUMARC and EPRI. Credit is taken for 8 of the 71 RI.ISI components under the FAC Program. Coordination between the FAC Program and the RI-ISI Program is described in the PNPS RI-ISI Template and in Inservice Engineering Report No. (
PNPS-02Q.402. The FAC Program is relied upon to manage the flow accelerated corrosion damage mechanism in Class I piping, but is not otherwise affected or changed by the RI-IS! program.
-.The following table summarizes the relationship between the FAC and RI-ISI examinations. Note that some of the welds in this table are in carbon steel piping segments that are evaluated for FAC, but the welds are not selected for examination per the FAC Program. In these instances, welds selected for examination per the RI-ISI Program will require volumetric examination like any other weld.
FAC vs. RI-ISI EXAMINATIONS RISK ISEGMENT WVELD NO. EXAMINATION(S) REQUIRED CAT. RI-ISI UT FAC 2(1) FV-003 6-N4A-12 X X 2(I) FV-002 6-N4A-13 X X 2(l) FW-005 6-N4B-I I X X 2(l) RPV-003 6-N4A-1 X 2(l) RPV-004 6-N4B-1 X 2(1) RPV-005 6-N4C-1 X 2(l) RPV-006 6-N4D-I X 2(l) FW-005 6-N4B-8 X 2(l) FW-011 6-N4D-2 X 1-14 1-14 /
En e...y Pilgrim Nuclear Power Station ASME SECTION XI FOURTH TEN-YEAR PNPS-RPT-05-00i Rev. 0 Nuclear Northeast INTERVAL INSERVICE INSPECTION PROGRAM PLAN FAC vs. RI.ISI EXAMINATIONS RISK SEGMENT WELD NO. EXAAINATION(S) REQUIRED CAT. RI-ISI UT FAC' 2() FW-013 6-N4C-2 X 2(l) FW-016 6-A-10 X 2(l) FWV-016 6-A-12 X .....
4(1) MS-001 I-A-1l X*
4(l) MS-O01 l-A-12 X#
4(l) FV-009 6-N4D-14 X*
4(1) FNV-009 6-N4D-15 X0 4(1) FW-009 6-N4D-16 X*
4(1) FWV-012 6-N4C-1 I _X*
4(l) RWCU-001 12-I-4 X*
4(I) RWCU-001 12-1-5 X0 4(l) RPV-010 l-D-l X 4(l), MS-001 I-A-7 . X 4(l) MS-001 I-A-8 X 4(l) MS-015 l-A-15 X 4(l) MS-016 I-B-iS X 4(l) MS-017 I-C-15 X 4(l) MS-018 l-D-15 X
- The FAC Program examination is credited for these 8 RI-ISI components.
1.5.1.2 Salt Service Water (SSW) System Inspections Routine inspection, maintenance, and test requirements for the PNPS Salt Service Water (SSW) System piping and heat exchanger inspections, along with the associated acceptance criteria, are included in Specification M591 for compliance with NRC G.L 89-13. These inspections are separate from, but supplement, the Section XI Class 3 ISI component inspections listed in Table 4.1-18. Implementation of SSW System inspections is via PNPS Nuclear Organization Procedure NOP02EI "Service Water Inspections, Maintenance, and Testing in Response to Generic Letter 89-13".
1.5.1.3 Class I Pressure Boundary Only (PBO) Pining & Components Augmented Inspection 1.5.1.3.1 Background & Purpose During 1998 it was identified that there was not an adequate basis for the IS! boundary change from Class 3 to Class 0 at the Normally-Open RBCCW Non-Essential loop isolation K> valves. The RBCCW Non-Essential heat transfer components perform no active safety function but are categorized as PNPS Class I "Pressure Boundary Only" (PBO) and the non-essential piping, pipe supports, and components am "MQCI" per the PNPS Q-tist. The 1-15
Pilgrim Nuclear Power Station Ent r ASME SECTION X1FOURTH TEN-YEAR PNPS-RPT-05--001 Rev. 0 Nuclear Northeast INTERVAL INSERVICE INSPECTION K) PROGRAM PLAN
.1.11.1.2 Class MC (IWA-4550)
Pressure testing following repair/replacement activities performed on Class MC items will be in accordance with IWE-5000..
1.11.2 Periodic System Pressure Testine 1.11.2.1 General Periodic system pressure tests are performed by plant procedures in accordance with the requirements of Article IWA-5000 for the following components:
0 Class I Pressure Retaining Components (Examination Category B-P) 0 Class 2 Pressure Retaining Components (Examination Category C-H) 0 Class 3 Pressure Retaining Components (Examination Category D-B)
The requirements of IWA-5000 are not applicable to Class MC components, except for repair/replacement activities. Article IWA-5000 System Pressure Tests are also not applicable to Subsection IWF component supports.
Test boundaries will be determined in accordance with IWA-5220.
The required visual examinations (VT-2) will be performed by personnel qualified (
and certified in accordance with Subarticle IWA-2300. Guidance for the PNPS IS[
Inspectors When performing VT-2 visual inspections for leakage during the Class 1, Class 2, and 3 system pressure tests is provided by PNPS Procedure No. 2.1.8.3, "Visual Examinationfor Leakage During System PressureTesting".
Tests will be documented by plant procedures and made available to an ANII inspector and a Plant N-DE Level II1 inspector for review.
1.11.2.2 System Leakage Testing In accordance with 10CFR50.55a(b)(2)(xx) "System Leakage Tests". when performing system leakage tests per IWA-5213(a), 2000 Addenda, a I 0-minute hold time after attaining test pressure is required for Class 2 and Class 3 components that are not in use during normal operating conditions, and no hold time is required for the remaining Class 2 and Class 3 components provided that the system has been in operation for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for insulated components or 10 minutes for uninsulated components.
Class I System Leakage Testing shall be performed oiler every reactor refueling outage has been completed prior to plant startup.
Class 2 and Class. 3 System Leakage Testing shall be performed once each Inspection Period.
K) The leakage observations shall be made by qualified VT-2 examiners. VT.2 Visual Examination Reports shall be generated and reviewed by site personnel in 1-35
E n tergy.Pilgrim Nuclear Power Station PNPS-RPT-05-001 ASME SECTION XI FOURTH TEN-YEAR Rev. 0 Nuclear Northeast INTERVAL INSERVICE INSPECTION PROGRAM PLAN accordance with site procedures, Such reports are available for review by regulatory personnel.
1.11.2.3 Hydrostatic Testing Class I (IWB) and Class 2 (IWC) components do not require hydrostatic testing under Examination Categories B-P and C-H, respectively.
Class 3 (IWD) components under the 1998 Code, 2000 Addenda, require 10 Yr.
System Hydrostatic Tests (Exam. Cat. D-B, Item No. D2.20) to be conducted at or near the end of the Inspection Interval or during the same Inspection Period as the Third Interval. These System Hydrostatic Tests may be conducted while the plant is cither in operation or shutdown. However, per I0CFRS0.S5a Request Number PIL-05-R-003 included within Appendix D, the 2001 Edition, through the 2003 Addenda will be used in place of the 1998 Edition, 2000 Addenda. Class 3 system hydrostatic test requirements have been deleted in their entirety from the 2001 Edition, 2003 Addenda.
1.12 Calibration Blocks 1, 12.1 Calibration blocks shall meet the material, surface finish and calibration reflector configuration requirements in effect it the time of the calibration block fabrication. Where this diffeis from -
the current edition of ASME Section XI, the differences shall be noted in'the UT examination procedure.
1.12.2 Calibration blocks shall be used to establish a reference sensitivity level from which subsequent examinations may be compared. The calibration block design may be the Basic Calibration Block described in Section XI Appendix III (i.e., 111-3400) or the design may be the Alternative Calibration Block described in ENN NDE procedures. During Section XI Appendix VIII performance demonstration for ultrasonic examinations, alternate calibration blocks may be used.
1.12.3 A detailed list of all ISI calibration blocks to be employed during the Fourth Interval is provided in Appendix C of this Program Plan. Per PDI procedures, calibration blocks fabricated to an edition of Section XI earlier than the 1998 Edition with 2000 Addenda may be used in the 4 d, Interval without reconciliation.
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