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MONTHYEARML0811507162008-04-16016 April 2008 Request for Approval of Proposed Relief Request VR-4A to Extend 5-Year Test Interval on a One-Time Basis for One Main Steam Safety Valve RV-203-4A, Transmittal of Inservice Testing Relief Request No. RV-07, Letter No. 2.08.021 Project stage: Request ML0813004082008-05-27027 May 2008 Relief Request No. RV-07, Alternate to the ASME OM Code 5-Year Test Interval for Main Steam Safety Relief Valves - Pilgrim Nuclear Power Station Project stage: Other 2008-04-16
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Category:Code Relief or Alternative
MONTHYEARML18128A0672018-06-0808 June 2018 Arkansas, Units 1 and 2; Grand Gulf, Unit 1; Indian Point Unit Nos. 2 and 3; Palisades; Pilgrim; River Bend Station, Unit 1; and Waterford, Unit-3 Relief Request No. EN-17-RR-1, Alternative to Use ASME Code Case N-513-4 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 ML17093A8942017-05-12012 May 2017 Pilgrim Nuclear Power Station - Relief Requests PNPS-ISI-001 and PNPS-ISI-002, Relief from ASME Code Volumetric Examination Requirements for the Fourth 10-Year Inservice Inspection Interval (CAC Nos. MF8092 and MF8093) ML16257A5732016-09-15015 September 2016 Issuance of Relief Request No. PRR-52-Relief from ASME Code, Section XI Requirements for Pressure Testing of Class 1 Pressure Retaining Components as a Result of Repair/Replacement Activity and Use of Code Case N-795 ML16194A3262016-08-0404 August 2016 Issuance of Relief Request No. PRR-53 - Relief from ASME Code, Section XI Requirements for Ultrasonic Inspection Qualifications of Weld Overlays ML16096A2692016-06-0606 June 2016 Arkansas; Grand Gulf; James A. Fitzpatrick; Indian Point; Palisades; Pilgrim; River Bend; and Waterford - Relief Request RR-EN-15-2, Proposed Alternative to Use ASME Boiler and Pressure Vessel Code Case N-786-1 ML16042A2912016-03-15015 March 2016 Issuance of Proposed Alternative Relief Request PRR-51, Relief from the Requirements of the ASME Code ML16057A1772016-02-16016 February 2016 Supplement to Request for Approval of Pilgrim Relief Request (PRR)-52, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) Pressure Testing of Mechanical Joints as a Result of Performance of a Repair/Replacement Activity and Use of ML15338A3092016-01-0505 January 2016 Relief Request PRR-50, Relief from the Requirement of the ASME Code, Implementation of Code Case N-702 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 ML15103A0692015-04-21021 April 2015 Relief Request PRR-24 Regarding Nozzle-to-Vessel Welds and Nozzle Inner Radii Examination ML14198A1572014-08-0101 August 2014 Relief Requests PR-03 and PR-05 Regarding the Inservice Testing Program (Tac MF0370) ML12174A1472012-07-10010 July 2012 Safety Evaluation for Relief Request PRR-21, Rev 4, to Install a Weld Overlay on RPV-n14-1 Standby Liquid Control Safe-End Nozzle Weld at Pilgrim JAFP-11-0112, Relief Request (RR-8), Alternative Examination Requirements for Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections Using American Society of Mechanical Engineers Code Case N-702 and BWRVIP-108NP2011-10-0303 October 2011 Relief Request (RR-8), Alternative Examination Requirements for Nozzle-to-Vessel Shell Welds and Nozzle Inner Radius Sections Using American Society of Mechanical Engineers Code Case N-702 and BWRVIP-108NP ML0923705492009-09-11011 September 2009 Relief Request (PRR)19, Install a Weld Overlay on Jet Pump Instrumentation Nozzle Weld RPV-N9A-1- Pilgrim Nuclear Power Station ML0911304562009-04-30030 April 2009 Relief Request ISI-2008-1, Use of Later ASME Section XI Code Edition and Addenda for Repair and Replacement, Pressure Testing, and Destructive Testing Activities-Pilgrim Nuclear Power Station CNRO-2009-00003, Letter from Entergy Response to Request for Additional Information Regarding Request ISI-2008-1 Use of Later ASME Section Xl Code Edition and Addenda for Repair and Replacement, Pressure Testing, and Non Destructive Examination Activ2009-03-17017 March 2009 Letter from Entergy Response to Request for Additional Information Regarding Request ISI-2008-1 Use of Later ASME Section Xl Code Edition and Addenda for Repair and Replacement, Pressure Testing, and Non Destructive Examination Activities ML0813004082008-05-27027 May 2008 Relief Request No. RV-07, Alternate to the ASME OM Code 5-Year Test Interval for Main Steam Safety Relief Valves - Pilgrim Nuclear Power Station ML0805801992008-02-14014 February 2008 Request for Approval of Relief Request No. PRR-16, Implementation of BWRVIP Guidelines in Lieu of ASME Section XI Code Requirements on Reactor Vessel Internals and Components Inspection ML0724201612007-09-27027 September 2007 Relief for the Reactor Core Shroud Stabilizer Assemblies ML0618701632006-06-28028 June 2006 Request for Approval of ASME Code, Section XI, Third Ten-Year Relief Request, PRR-42, Examinations of Component Welds with Less than Essentially 100% Examination Coverage ML0606601322006-04-0505 April 2006 Relief Request No. PIL-05-R-002, ML0602400552006-03-22022 March 2006 Relief Request No. PRR-9, ML0601201272006-02-17017 February 2006 Relief Request No. PPR-05 ML0519902762005-08-29029 August 2005 Entergy Relief Request PR-03 High-Pressure Coolant Injection Pump ML0519201572005-06-29029 June 2005 Fourth Ten-Year Inservice Inspection Program Plan and the Associated Relief Requests for NRC Approval ML0429203582005-02-25025 February 2005 Request - Alternative Repair Plan for Generic Letter 88-01, Reactor Pressure Vessel Nozzle-To Cap Weld in the Control Rod Drive Return Line ML0423100082005-01-0606 January 2005 Relief Request No. PRR-29, Relief from System Hydrostatic Test Requirements for Small Bore ASME Code Class 1 Reactor Coolant Pressure Boundary Vent, Drain and Branch Lines and Connections ML0427406642004-10-14014 October 2004 Relief Request Nos. R-33, R-71, R 3-40(A) and R-41, James A. FitzPatrick Nuclear Power Plant, Indian Point Nuclear Generating Unit Nos. 2 and No. 3 and Pilgrim Nuclear Power Station ML0429505512004-10-12012 October 2004 Response to NRC Request for Additional Information and Revised Relief Request, PRR-39, Rev. 1 ML0417401842004-07-0606 July 2004 Relief Request, Nos. RR-34 and PRR for the Third 10-Year Inservice Inspection (ISI) Interval, MC1999 and MC2006 ML0410700882004-07-0606 July 2004 Relief Request to Use American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Case N-600 ML0407807052004-04-30030 April 2004 Relief Request, Fourth 10-Year Inservice Testing (IST) Program and Request for Approval of IST Relief Requests ML0408205162004-03-22022 March 2004 Relief Request Nos. RR-68, RR3-37, and PRR-34 (TAC MC1559, MC1560, & MC1561) ML0402600132004-02-26026 February 2004 Pilgrim Relief Request Review, Relief Request No. 38, Relief from ASME Code, Section XI, Appendix Viii, Supplement 11, Qualification Requirements for Full Structural Overlaid Wrought Austenitic Piping Welds. JPN-03-020, Indian Point Nuclear Generating Station, Units 2 & 3, Pilgrim Nuclear Power Station, Vermont Yankee Nuclear Power Station, Relief, Relief Request to Use ASME Code Case N-6002003-08-11011 August 2003 Indian Point Nuclear Generating Station, Units 2 & 3, Pilgrim Nuclear Power Station, Vermont Yankee Nuclear Power Station, Relief, Relief Request to Use ASME Code Case N-600 ML0312701492003-05-0808 May 2003 Relief Request, Relief from ASME Code, Section XI, Appendix Viii, Supplement 10, Performance Demonstration for Ultrasonic Examination Systems ML0306402042003-04-11011 April 2003 Relief Request, Examinations of Reactor Pressure Vessel Circumferential Shell Welds ML0224002392002-09-17017 September 2002 Relief, Code Relief Request from Section XI, the Pump and Valve Inservice Testing Program Regarding Inclusion of Additional Excess Flow Check Valves ML0216800622002-06-0505 June 2002 Code Relief, Pilgrim Relief Request (PRR)-27 Relief from 1989 ASME Code Section XI Requirements for Certification of VT-2 Visual Examination Personnel 2018-06-08
[Table view] Category:Letter
MONTHYEARL-24-002, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G2024-02-0202 February 2024 Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G ML23342A1182024-01-0909 January 2024 Independent Spent Fuel Storage Installation Security Inspection Plan L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023 Proof of Financial Protection 10 CFR 140.15 ML23334A1822023-11-30030 November 2023 Biennial Report for the Defueled Safety Analysis Report Update, Technical Specification Bases Changes, 10 CFR 50.59 Evaluation Summary, and Regulatory Commitment Change Summary November 2021 Through October 2023 L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023 Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point ML23306A0992023-11-0202 November 2023 and Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7) L-23-011, 10 CFR 72.48 Biennial Change Summary Report2023-10-27027 October 2023 10 CFR 72.48 Biennial Change Summary Report IR 05000293/20234012023-08-31031 August 2023 NRC Inspection Report No. 05000293/2023401 & 2023001 (Cover Letter Only) IR 05000293/20230022023-08-0404 August 2023 NRC Inspection Report No. 05000293/2023002 L-23-008, Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI)2023-05-23023 May 2023 Correction to Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations Holtec Decommissioning International, LLC (HDI) ML23136A7792023-05-15015 May 2023 Annual Radiological Environmental Operating Report, January 1 Through December 31, 2022 ML23135A2152023-05-15015 May 2023 Annual Radioactive Effluent Release Report, January 1 Through December 31, 2022 L-23-004, HDI Annual Occupational Radiation Exposure Data Reports - 20222023-04-24024 April 2023 HDI Annual Occupational Radiation Exposure Data Reports - 2022 L-23-003, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-31031 March 2023 Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations ML23088A0382023-03-29029 March 2023 Stations 1, 2, & 3, Palisades Nuclear Plant, and Big Rock Point - Nuclear Onsite Property Damage Insurance ML23069A2782023-03-13013 March 2023 Request for Scoping Comments Concerning the Environmental Review of Monticello Nuclear Generating Plant, Unit 1 Subsequent License Renewal Application ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities IR 05000293/20220042023-02-15015 February 2023 NRC Inspection Report No. 05000293/2022004 ML22356A0712023-01-31031 January 2023 Issuance of Exemption for Pilgrim Nuclear Power Station ISFSI Regarding Annual Radioactive Effluent Release Report - Cover Letter ML22347A2782022-12-21021 December 2022 Independent Spent Fuel Storage Installation Security Inspection Plan Dated December 21, 2022 L-22-042, Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.152022-12-14014 December 2022 Oyster, Pilgrim, Indian Point, Palisades and Big Rock Point - Proof of Financial Protection 10 CFR 140.15 L-22-041, Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension2022-12-0909 December 2022 Supplemental Information to Enhance Exemption Request Detail for Pilgrim ISFSI Annual Radioactive Effluent Release Report Due Date Extension IR 05000293/20220032022-11-18018 November 2022 NRC Inspection Report No. 05000293/2022003 L-22-036, Decommissioning Trust Fund Agreement2022-11-0808 November 2022 Decommissioning Trust Fund Agreement ML22276A1762022-10-24024 October 2022 Decommissioning International Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22266A1922022-09-23023 September 2022 and Pilgrim Nuclear Power Station - Request to Withdraw Prior Submissions from NRC Consideration ML22272A0352022-09-22022 September 2022 S. Lynch-Benttinen Letter Regarding U.S. Citizen Intent to Sue U.S. Fish and Wildlife and NOAA Fisheries Representing the Endangered Species (Na Right Whale) Which Will Be Adversely Affected by Holtec International Potential Actions ML22269A4202022-09-22022 September 2022 Citizen Lawsuit ML22241A1122022-08-29029 August 2022 Request for Exemption from 10 CFR 72.212(a)(2), (b)(2), (b)(3), (b)(4), (B)(5)(i), (b)(11), and 72.214 for Pilgrim ISFSI Annual Radioactive Effluent Release Report IR 05000293/20220022022-08-12012 August 2022 NRC Inspection Report No. 05000293/2022002 ML22215A1772022-08-0303 August 2022 Decommissioning International (HDI) Proposed Revisions to the Quality Assurance Program Approval Forms for Radioactive Material Packages ML22206A1512022-08-0101 August 2022 NRC Office of Investigations Case Nos. 1-2022-002 & 1-2022-006 ML22221A2592022-08-0101 August 2022 LTR-22-0217-1-NMSS - Town of Duxbury Letter Opposing the Irradiated Water Release from Pilgrim (Docket No. 05000293) ML22193A1662022-07-28028 July 2022 LTR-22-0154-1 - Heather Govern, VP, Clean Air and Water Program, Et Al., Letter Regarding Radioactive Wastewater Disposal from the Pilgrim Nuclear Power Station (Docket No. 05000293) ML22175A1732022-07-28028 July 2022 LTR-22-0153-1 - Response Letter to D. Turco, Cape Downwinders, from A. Roberts, NRC, Regarding Holtec-Pilgrim Plans to Dump One Million Gallons of Radioactive Waste Into Cape Cod Bay ML22154A4882022-06-0101 June 2022 Letter from Conservation Law Foundation Regarding Irradiated Water Release from Pilgrim ML22154A1622022-05-26026 May 2022 Letter and Email from Save Our Bay/Diane Turco Regarding Irradiated Water Release from Pilgrim ML22136A2602022-05-16016 May 2022 Submittal of Annual Radiological Environmental Operating Report for January 1 Through December 31, 2021 ML22136A2572022-05-16016 May 2022 Submittal of Annual Radioactive Effluent Release Report for January 1 Through December 31, 2021 ML22102A0932022-05-12012 May 2022 LTR-22-0067 Response to Matthew P. Levesque, President, Barnstable Town Council Regarding Irradiated Water Release from Pilgrim IR 05000293/20220012022-05-11011 May 2022 NRC Inspection Report No. 05000293/2022001 ML22104A0542022-04-30030 April 2022 LTR-22-0093 Response to Sheila Lynch-Benttinen, Regarding Irradiated Water Release from Pilgrim L-22-026, Occupational Radiation Exposure Data Report - 20212022-04-29029 April 2022 Occupational Radiation Exposure Data Report - 2021 ML22152A2592022-04-25025 April 2022 Zaccagnini Letter Dated 04/25/22 ML22152A2642022-04-19019 April 2022 Flynn Letter Dated 04/19/22 ML22091A1062022-04-0101 April 2022 Nuclear Onsite Property Damage Insurance (10 CFR 50.54(w)(3)) L-22-022, and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec.2022-03-25025 March 2022 and Indian Point Nuclear Generating Stations 1, 2, & 3 - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations - Holtec. ML22130A6762022-03-14014 March 2022 Decola Ltr Dtd 03/14/22 Re Potential Discharge of Radioactive Water from Pilgrim Nuclear Power Station ML22041B0762022-03-0707 March 2022 03-07-22 - Letter to the Honorable William R. Keating, Responds to Letter Regarding Proposed Release of Irradiated Water at Pilgrim Nuclear Power Station Into Cape Cod Bay ML22054A2962022-02-23023 February 2022 Annual ISFSI Radioactive Effluent Release Report for 2021 2024-02-02
[Table view] Category:Safety Evaluation
MONTHYEARML21217A1752021-08-0505 August 2021 Amendment No 255 Pilgrim Independent Spent Fuel Storage Installation (ISFSI) Only Physical Security Plan - Public Version ML20328A2972020-12-0101 December 2020 Amendment No. 253 - Non-Safeguards Version ML19276C4202020-01-0202 January 2020 Issuance of Amendment No. 252, Request to Remove Cyber Security Plan Requirements for the Permanently Defueled Condition ML19274C6742020-01-0202 January 2020 Issuance of Amendment No. 251, Revise Emergency Plan and Emergency Action Level Scheme to Address Permanently Defueled Condition ML19142A0432019-12-18018 December 2019 Letter and Safety Evaluation, Exemption to Allow Reduced Emergency Planning Requirements; Revise Radiological Emergency Response Plan Consistent with Permanently Defueled Reactor ML19235A0502019-08-27027 August 2019 Issuance of Amendment No. 249 Order Approving Direct Transfer of Renewed Facility Operating License and ISFSI General License and Conforming Amendment ML19170A2502019-08-22022 August 2019 Enclosure 3, Safety Evaluation for Direct and Indirect Transfer of Renewed Facility Operating License to Holtec Pilgrim, LLC, Owner and Holtec Decommissioning International, LLC, Operator (L-2018-LLO-0003) ML19122A1992019-06-11011 June 2019 Review of Spent Fuel Management Plan ML18284A3752018-11-30030 November 2018 Issuance of Amendment No. 248, Revise Site Emergency Plan for On-Shift and Emergency Response Organization Staffing to Address Permanently Defueled Condition ML18128A0672018-06-0808 June 2018 Arkansas, Units 1 and 2; Grand Gulf, Unit 1; Indian Point Unit Nos. 2 and 3; Palisades; Pilgrim; River Bend Station, Unit 1; and Waterford, Unit-3 Relief Request No. EN-17-RR-1, Alternative to Use ASME Code Case N-513-4 ML17066A1302017-07-10010 July 2017 Pilgrim Nuclear Power Station - Issuance of Amendment No. 246, Revise Administrative Controls Section of Technical Specifications to Change Staffing and Training Requirements for Permanently Defueled Condition (CAC No. MF9304) ML17093A8942017-05-12012 May 2017 Pilgrim Nuclear Power Station - Relief Requests PNPS-ISI-001 and PNPS-ISI-002, Relief from ASME Code Volumetric Examination Requirements for the Fourth 10-Year Inservice Inspection Interval (CAC Nos. MF8092 and MF8093) ML17058A3252017-04-12012 April 2017 Approval of Certified Fuel Handler Training and Retraining Program ML16250A2232016-10-28028 October 2016 Issuance of Amendments Proposed Changes to Emergency Plan to Revise Training for the on - Shift Chemistry Technician ML16251A6202016-09-13013 September 2016 Entergy Fleet Request for Approval of Change to the Entergy Quality Assurance Program Manual (CAC Nos. MF7086 - MF7097) ML16082A4602016-06-0606 June 2016 Issuance of Amendment Cyber Security Plan Implementation Schedule ML16096A2692016-06-0606 June 2016 Arkansas; Grand Gulf; James A. Fitzpatrick; Indian Point; Palisades; Pilgrim; River Bend; and Waterford - Relief Request RR-EN-15-2, Proposed Alternative to Use ASME Boiler and Pressure Vessel Code Case N-786-1 ML16093A0282016-05-31031 May 2016 Entergy Services, Inc., Proposed Alternative to Utilize ASME Code Case N-789-1, Relief Request RR-EN-15-1, Revision 1 ML16124B0872016-05-0303 May 2016 E-mail Review of Safety Evaluation for Proposed Alternative Relief Request No. PRR-51 ML16042A2912016-03-15015 March 2016 Issuance of Proposed Alternative Relief Request PRR-51, Relief from the Requirements of the ASME Code ML16008B0772016-03-0303 March 2016 Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051 ML15338A3092016-01-0505 January 2016 Relief Request PRR-50, Relief from the Requirement of the ASME Code, Implementation of Code Case N-702 ML15166A4012015-06-19019 June 2015 Request for Alternative PRR-26 for the Fifth 10-year Inservice Inspection Interval ML15114A0212015-05-0606 May 2015 Issuance of Amendment Regarding the Minimum Critical Power Ratio License Amendment Request ML15103A0692015-04-21021 April 2015 Relief Request PRR-24 Regarding Nozzle-to-Vessel Welds and Nozzle Inner Radii Examination ML15084A0252015-03-23023 March 2015 Non-Proprietary - Safety Evaluation - Fourth 10-Year Interval Inservice Inspection - Request for Relief PRR-24 ML14272A0702015-03-12012 March 2015 Issuance of Amendment 242 Re Revision to Technical Specification 2.1, Safety Limits to Resolve Pressure Regulator Fail-Open Transient ML14336A6612014-12-11011 December 2014 Issuance of Amendment Regarding Cyber Security Plan Implementation Schedule Milestone 8 (Tac No. MF3482) ML14295A6852014-10-31031 October 2014 Issuance of Amendment Regarding Heavy Loads to Facilitate Dry Storage Handling Operations ML14210A2662014-08-0808 August 2014 Arkansas, Units 1 & 2, Big Rock Point, James A. Fitzpatrick, Grand Gulf, Unit 1, Indian Point, Units 1, 2 & 3, Palisades, Pilgrim, River Bend, Unit 1, Vermont Yankee, Waterford, Safety Evaluation Quality Assurance Program Manual, Rev. 24 & ML14198A1572014-08-0101 August 2014 Relief Requests PR-03 and PR-05 Regarding the Inservice Testing Program (Tac MF0370) ML14083A6312014-03-27027 March 2014 Relief Request PRR-22 Regarding a Risk-Informed Inservice Inspection Program for Class 1 and 2 Piping Welds ML13149A2152013-05-29029 May 2013 Correction to Staff Assessment Letter to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident ML13127A1792013-05-21021 May 2013 Staff Assessment in Response to Recommendation 9.3 of the Near-Term Task Force Related to the Fukushima Dai-ichi Nuclear Power Plant Accident ML13025A3062013-03-14014 March 2013 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2 & 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Correction to Amendments Issued on 12/28/12, Revise QA Program Manual and Staff Qualification Technical Specifications ML12261A1302012-11-13013 November 2012 Issuance of Amendments to Renewed Facility Operating License Changes in Cyber Security Plan Implementation Milestone ML1220100482012-08-0707 August 2012 Issuance of Amendment No. 237 Revision to Condensate Storage Tank Low Level Trip Setpoint ML12174A1472012-07-10010 July 2012 Safety Evaluation for Relief Request PRR-21, Rev 4, to Install a Weld Overlay on RPV-n14-1 Standby Liquid Control Safe-End Nozzle Weld at Pilgrim ML11152A0432011-07-22022 July 2011 License Amendment, Cyber Security Plan ML1106500092011-03-28028 March 2011 Issuance of Amendment No. 235 Revised Technical Specifications for Setpoint and Setpoint Tolerance Increases for Safety Relief Valves and Spring Safety Valves ML1100502982011-01-26026 January 2011 Issuance of Amendment Regarding Revised Pressure and Temperature (P-T) Limit Curves and Relocation of P-T Curves to the PTLR ML1022901632010-08-25025 August 2010 Relief Request PRR-20, Alternative Examination Requirements for Nozzle-To-Shell and Inner Radii Welds Using ASME Code Case N-702 and BWRVIP-108 - Pilgrim Nuclear Power Station ML0936208072010-01-22022 January 2010 Cover Letter, (Non-Proprietary) Order Extending the Effectiveness of the Approval of the Indirect Transfer of Facility Operating Licenses for Big Rock Point, Fitzpatrick, Indian Point, Palisades, Pilgrim, and Vermont Yankee Nuclear Power St ML0936208952010-01-22022 January 2010 Safety Evaluation,(Non-Proprietary) Order Extending the Effectiveness of the Approval of the Indirect Transfer of Facility Operating Licenses for Big Rock Point, Fitzpatrick, Indian Point,Palisades,Pilgrim, and Vermont Yankee Nuclear Power ML0928706472009-10-29029 October 2009 Request for Threshold Determination Under 10 CFR 50.80-Big Rock Point, James A. FitzPatrick Nuclear Power Plant, Indian Point Nuclear Generating Nos. 1, 2 and 3, Palisades, Pilgrim, Vermont Yankee ML0927301372009-10-0909 October 2009 Safety Evaluation by the Office of Nuclear Reactor Regulation Corporate Restructuring Conversion of Companies and Stock Split-Off by Entergy Nuclear Operations, Inc and Subsidiaries ML0923705492009-09-11011 September 2009 Relief Request (PRR)19, Install a Weld Overlay on Jet Pump Instrumentation Nozzle Weld RPV-N9A-1- Pilgrim Nuclear Power Station ML0911304562009-04-30030 April 2009 Relief Request ISI-2008-1, Use of Later ASME Section XI Code Edition and Addenda for Repair and Replacement, Pressure Testing, and Destructive Testing Activities-Pilgrim Nuclear Power Station ML0906402242009-03-26026 March 2009 License Amendment, Revised Technical Specifications (TS) Section 2.1.2, Safety Limit Minimum Critical Power Ratio (SLMCPR) for Two-Loop and Single-Loop Operation ML0815703662008-11-20020 November 2008 License Amendment, Issuance of Amendment Adoption of TSTF-448, Revision 3, Control Room Envelope Habitability 2021-08-05
[Table view] |
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May 27, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT:
RELIEF REQUEST NO. RV-07, ALTERNATE TO THE ASME OM CODE 5-YEAR TEST INTERVAL FOR MAIN STEAM SAFETY RELIEF VALVES -
PILGRIM NUCLEAR POWER STATION (TAC NO. MD8526)
Dear Sir or Madam:
By letter dated April 16, 2008 (Agencywide Documents and Management System (ADAMS)
Accession No. ML081150716), Entergy Nuclear Operations, Inc. (the licensee) submitted Relief Request (RR) No. RV-07 for the Fourth 10-Year Interval Inservice Testing (IST) Program at Pilgrim Nuclear Power Station (PNPS). The licensee requested relief from certain IST requirements of the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code). The RR involves an extension to the ASME OM Code 5-year test interval for pressure relief devices in light water reactor power plants.
Based on the information provided in the RR, the Nuclear Regulatory Commission (NRC) staff concluded that the licensees compliance to the ASME OM Code requirements 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 (10 CFR) 50.55a(a)(3)(ii), the NRC staff authorizes the IST program alternative proposed in RR, RV-07, for the fourth 10-year IST interval for Pilgrim. The proposed alternative provides reasonable assurance that the component is operationally ready.
The requested duration of the RR is 11 months for the affected Main Steam Safety Valve (MSSV). The licensee stated that the compliance with the applicable requirements of the ASME OM Code for the one MSSV, prior to refueling outage 17 is not practical, in that the evolution would result in an unnecessary plant shutdown, unnecessary challenges to safety systems, and unnecessary cycling of equipment, all without a compensating increase in the level of quality or safety. The results of the staffs review are provided in the enclosed safety evaluation.
If you have any questions regarding this approval, please contact the Pilgrim Project Manager, James Kim, at 301-415-4125.
Sincerely,
/RA/
Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: See next page
If you have any questions regarding this approval, please contact the Pilgrim Project Manager, James Kim, at 301-415-4125.
Sincerely,
/RA/
Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: See next page Docket No. 50-293
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RPowell, RI RidsOgcMailCenter JMcHale RidsNrrDorlLpl1-1 SLittle JKim GHill (2) WPoertner RidsAcrsAcnw&mMail center Amendment No.: ML081300408 *See memo dated May 09, 2008 OFFICE LPLI-1/PM LPLI-1/LA CSGB/BC OGC LPL1-1/BC NAME JKim SLittle JMcHale
- JBielecki MKowal DATE 05/12/2008 05/12/2008 05/09/2008 5/21/08 5/27/08 OFFICIAL RECORD COPY
Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road Massachusetts Emergency King of Prussia, PA 19406-1415 Management Agency Attn: John Giarrusso, Senior Resident Inspector Nuclear Preparedness Manager U. S. Nuclear Regulatory Commission 400 Worcester Road Pilgrim Nuclear Power Station Framingham, MA 01702-5399 Post Office Box 867 Plymouth, MA 02360 Mr. William D. Meinert Nuclear Engineer Chairman, Board of Selectmen Massachusetts Municipal Wholesale 11 Lincoln Street Electric Company Plymouth, MA 02360 P.O. Box 426 Ludlow, MA 01056-0426 Chairman Nuclear Matters Committee Site Vice President Town Hall Entergy Nuclear Operations 11 Lincoln Street Pilgrim Nuclear Power Station Plymouth, MA 02360 600 Rocky Hill Road Plymouth, MA 02360-5508 Chairman, Duxbury Board of Selectmen Town Hall General Manager, Plant Operations 878 Tremont Street Entergy Nuclear Operations Duxbury, MA 02332 Pilgrim Nuclear Power Station 600 Rocky Hill Road Office of the Commissioner Plymouth, MA 02360-5508 Massachusetts Department of Environmental Protection Director, Nuclear Safety Assurance One Winter Street Entergy Nuclear Operations Boston, MA 02108 Pilgrim Nuclear Power Station 600 Rocky Hill Road Office of the Attorney General Plymouth, MA 02360-5508 One Ashburton Place 20th Floor Manager, Licensing Boston, MA 02108 Entergy Nuclear Operations Pilgrim Nuclear Power Station MA Department of Public Health 600 Rocky Hill Road Radiation Control Program Plymouth, MA 02360-5508 Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129
Pilgrim Nuclear Power Station cc:
Senior Vice President Senior Manager, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
P.O. Box 31955 P.O. Box 31955 Jackson, MS 39286-1995 Jackson, MS 39268-1995 Vice President, Oversight Assistant General Counsel Entergy Nuclear Operations, Inc. Entergy Nuclear Operations P.O. Box 31995 440 Hamilton Avenue Jackson, MS 39286-1995 White Plains, NY 10601 Senior Vice President and COO Ms. Stacey Lousteau Entergy Nuclear Operations, Inc. Treasury Department 440 Hamilton Avenue Entergy Services, Inc.
White Plains, NY 10601 639 Loyola Avenue New Orleans, LA 70113 Vice President, Operations Entergy Nuclear Operations, Inc. Mr. James Sniezek Pilgrim Nuclear Power Station 5486 Nithsdale Drive 600 Rocky Hill Road Salisbury, MD 21801-2490 Plymouth, MA 02360-5508 Mr. Michael D. Lyster Mr. Michael Kansler 5931 Barclay Lane President & CEO/CNO Naples, FL 34110-7306 Entergy Nuclear Operations, Inc.
P.O. Box 31955 Mr. Garrett D. Edwards Jackson, MS 39268-1995 814 Waverly Road Kennett Square, PA 19348 Mr. John F. McCann Director, Nuclear Safety & Licensing Mr. John Doering Entergy Nuclear Operations, Inc. P.O. Box 189 440 Hamilton Avenue Parker Ford, PA 19457 White Plains, NY 10601
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NO. RV-07 ENTERGY NUCLEAR OPERATIONS, INC.
PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
1.0 INTRODUCTION
By letter dated April 16, 2008 (Agencywide Documents and Management System (ADAMS)
Accession No. ML081150716), Entergy Nuclear Operations, Inc. (the licensee) submitted Relief Request (RR) No. RV-07 for the Fourth 10-Year Interval Inservice Testing (IST) program at Pilgrim Nuclear Power Station (PNPS). The licensee requested relief from certain IST requirements of the 1995 Edition through 1996 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code).
The Pilgrim Fourth 10-Year IST Interval commenced in December 2002. The RR involves an extension to the ASME OM Code 5-year test interval for pressure relief devices in light-water reactor power plants.
2.0 REGULATORY EVALUATION
Title 10 of the Code of Federal Regulations (10 CFR) 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 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 10-year IST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv),
Inservice tests 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 the limitations and modifications listed in paragraph (b) and NRC approval. Section 50.55a(f)(4)(iv) also provides that Portions of editions or addenda may be used provided that all related requirements of the respective editions or 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. Section 50.55a authorizes the NRC to approve alternatives and to Enclosure
grant relief from ASME OM Code requirements upon making necessary findings. NRC guidance contained in Generic Letter (GL) 89-04, Guidance 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, Guidance for Inservice Testing at Nuclear Power Plants.
The NRC staffs findings, with respect to granting or denying the IST program RR, are given below:
3.0 TECHNICAL EVALUATION
3.1 Valve Relief Request RV-07 3.1.1 Code Requirements The licensee requested relief from Appendix I, Section I-1.3.3 of ASME OM, which requires that a minimum of 20 percent of the valves from each group be tested within any 24-month interval and that the test interval for any individual valve shall not exceed 5 years. Relief was requested for Main Steam Safety Valve (MSSV) serial number BK 6302 installed in location RV-203-4A.
3.1.2 Licensees Basis for Requesting Relief (as stated by licensee) 10 CFR 50.55a(f)(4) directs licensees to meet inservice testing requirements for ASME Code Class 1 valves set forth in the ASME OM Code and addenda. The fourth 10-year IST interval for PNPS is based on the 1995 Edition through 1996 Addenda of the ASME OM Code, and specifically Appendix I of the OM Code.
The ASME OM Code, Subsection ISTC, Section ISTC 3.2, states that Inservice testing in accordance with this subsection shall commence when the valves are required to be operable to fulfill their required function(s). The ASME OM Code, Appendix I, Section I-1.3.3 states that Class 1 pressure relief valves shall be tested at least once every 5 years, starting with initial electric power generation. This section also states that the test interval for any individual valve shall not exceed 5 years.
The required test ensures that the MSSV, which is located on the A main steam line between the reactor vessel and the first isolation valve within the drywell, will open at the pressures bounded by the safety analysis.
Compliance with the applicable requirements of the ASME OM Code for MSSV
[RV-203-4A], prior to refueling outage 17 (RFO-17) is not practical, in that the evolution would result in an unnecessary plant shutdown, unnecessary challenges to safety systems, and unnecessary cycling of equipment, all without a compensating increase in the level of quality or safety.
Entergy currently replaces one (out of 2) MSSV at PNPS every refueling outage, so that all valves are removed and tested every two refueling outages. This methodology supports the ASME OM Code requirements for testing previously untested Class 1 pressure relief valves. After each valve is removed and as-found tested, the MSSVs are refurbished to a like-new condition, and reset to an as-left value of plus or minus 1%.
Entergy utilizes Wyle laboratories to perform as-found and as-left testing, and test inspection of the PNPS MSSVs. Entergy utilizes Dresser, Inc. for the valve disassembly, refurbishment, and part inspections for the Pilgrim MSSVs. Both Wyle and Dresser are qualified and approved Pilgrim vendors for the respective tasks that they perform.
Pilgrim procedures require that the safety valve with the earliest service date be removed for testing each RFO. Since there are only 2 safety valves installed, this means that the longest any safety valve can be installed in the plant without testing is 2 cycles (48 months). During the following cycle, the valve is as-found tested by Wyle, disassembled, inspected, and reassembled by Dresser, and re-certified by Wyle for installation during the next RFO. When the re-certification is completed early in the cycle (so the valve will be available as a spare), the valve test-to-test interval may exceed 60 months; but is always less than 72 months.
The valve is disassembled, inspected, and reassembled in accordance with the Dresser Repair Plan and Report for Model 3700 Series Safety Valves. The repair plan identifies the critical dimensions that are required to be measured during the inspection, and the critical components that are required to be inspected and verified as acceptable for wear and defects. If any components are found to be worn or outside the specified tolerances, they are refurbished to meet these required tolerances, or the applicable part is replaced.
The valve is then re-assembled and certified by performing a minimum of two consecutive lifts within 1% of the valves nameplate set pressure. The certified as-left set point is typically set to within 1/2% of the valves nameplate set pressure.
As part of a review of the PNPS IST program with respect to a recent ASME OM Code interpretation, Entergy identified a discrepancy relative to the 5-year test interval. The ASME OM Code interpretation (i.e., ASME Code Interpretation 01-18 from the ASMEOM code, 2004 Edition) indicated that implementation of the 5-year test interval should be based upon a test-to-test duration. The historical method used at Pilgrim with respect to MSSV test intervals has been to use an installation-to-test duration, and to ensure that all installed MSSVs would not exceed a 5-year testing frequency.
According to the licensee, both MSSVs will be replaced and tested during RFO-17, which is scheduled to begin in April 19, 2009. MSSV RV-203-4A is currently scheduled to be replaced during RFO-17. The replacement and test schedule is consistent with the historical Entergy method for implementing OM Code, Appendix I requirements (i.e., the valves will have been installed for less than or equal to two operating cycles). However, utilizing a test-to-test interpretation, the 5-year interval for MSSV RV-203-4A will have been exceeded (by approximately 11 months) prior to beginning RFO-17.
3.1.3 Licensees Basis for Use (as stated by licensee)
IST history for MSSVs at PNPS from 1987 to the present indicates that the results for all of the tests (7 total), conducted on MSSVs that have been installed for two operating cycles (i.e., 48 months) have successfully passed the ASME OM Code as-found acceptance criteria of plus or minus 3%. Furthermore, historical test data indicates that 3 of the 7 tests remained within the as-found Technical Specification (TS) tolerance of plus or minus 1%. Finally, the as-found test data for the other 4 MSSVs that lifted outside the TS 1% tolerance showed that 3 of the valves exceeded the acceptance criteria in the
negative or conservative direction. The one MSSV that exceeded the TS acceptance criterion in the positive direction was found to be above the TS specified 1% tolerance by 8 psig.
IST history, for MSSV serial number BK 6302, for which relief is being requested, from 1990 to the present all of the tests (3 total) for which this MSSV was installed for two operating cycles (i.e., 48 months) successfully passed the ASME OM Code as-found acceptance criteria of plus or minus 3%. Historical test data also indicated that 2 of the 3 tests remained within the TS tolerance of plus or minus 1%. The one test that lifted outside the 1% tolerance showed that the valve exceeded the acceptance criteria in the conservative direction; the valve lifted one pound below the 1% acceptance band.
Moreover, a fourth test of the MSSV occurred after it had been installed for 1.3 years.
Prior to this installation, the valve was stored for 1.6 years. After it was removed, it was stored for an additional 3.9 years prior to the as-found testing (a total test-to-test time of 6.8 years). The as-found test was 4 psig high (0.32%) which is within the 1% TS tolerance.
The Entergy data analysis also indicates that the test data is consistent with other industry data for this model MSSVs, including Quad Cities Nuclear Power Station, Units 1 & 2 and Dresden Nuclear Power Station, Units 1 & 2. Additionally, PNPS personnel have indicated that station experience with Dresser Model 6-3777QA MSSVs has been reliable and consistent, and recalled no failures exceeding the OM Code as-found acceptance criteria of plus or minus 3% since the early 1980s.
Entergy has reviewed the historical MSSV vendor Technical Information Program Manual to identify any operating and/or maintenance experience with Model 6-3777QA valves that could provide additional insights regarding the impact of controlled environment storage upon MSSVs. This review indicated that the Dresser 3777Q MSSVs should be stored in a controlled environment, inside specially designed metal containers prior to installation as replacement MSSVs. The vendor recommendations also specify that the controlled environment in which these MSSVs would be stored not be subject to thermal cycling or vibration (i.e., the normal operating conditions to which MSSVs are subjected).
Entergy complies with these vendor recommendations for valve storage. The test certified valves are stored with robust foreign material exclusion barriers installed on the valve inlet and outlet ports, in areas that meet Level B storage requirements at both Wyle Labs and Pilgrim Station. The tested valves are normally stored in sealed metal containers (they may be stored out of the metal container on the shop floor in a controlled area at Wyle Labs while they await shipment), in the upright position. At Pilgrim, the valves are normally stored in the Reactor Building. At both locations, the valves are maintained in environments that are well within the temperature limits specified by the vendor for extended storage.
Finally, the MSSV vendor (Dresser, Inc) has indicated to other industry users (i.e., Plants within the Exelon Generating Company) of the Model 3777Q valve that, in general, there is no degradation in an MSSV when properly stored in a controlled environment for approximately 5 years.
3.1.4 Licensees Proposed Alternative Testing MSSV serial number BK 6302 installed in location RV-203-4A will be removed and tested during RFO-17, along with the remaining other MSSV that will not have exceeded the 5-year test requirement by RFO-17.
3.1.5 Staff Evaluation of Relief Request RV-07 The NRC staff has reviewed the licensees basis and use for relief to determine if it is acceptable to extend the test interval for MSSV serial number BK 6302 installed in location RV-203-4A beyond the allowable 5-year interval specified in the ASME OM Code. Under the proposed alternative, the test interval will be extended approximately 11 months until RFO-17 on a one time basis. The alternative provides that the valve will be removed and tested along with the other remaining MSSV that will not have exceeded the 5-year interval specified by the OM Code.
Both valves will have been installed in the Unit for a maximum of 48 months, and MSSV serial number BK 6302 installed in location RV-203-4A, was in storage for 221/2 months prior to installation.
According to the licensee, the ASME Code does not require that MSSVs be routinely refurbished but refurbishment every two operating cycles provides reasonable assurance that setpoint drift will be minimized. The licensees test history for MSSV serial number BK 6302 from 1990 to the present indicates that all of the tests (3 total) for this MSSV in which it was installed for two operating cycles did not exceed the plus 1% upper acceptance criteria of the TS. One of the three tests lifted one pound below the minus 1% lower acceptance criteria of the TS, which is conservative with respect to overpressure mitigation. The licensees fourth test of MSSV serial number BK 6302 occurred after it had been installed 1.3 years. Prior to this installation, the valve had been stored for 1.6 years. After the valve was removed it was stored for an additional 3.9 years prior to as-found testing (a total test-to-test time of 6.8 years). The licensees as-found test was within the plus or minus 1% TS criteria.
According to the licensee, the testing history for all MSSVs at Pilgrim from 1987 to the present (7 total tests) indicates that 3 of the 7 tests conducted on MSSVs that have been installed for two operating cycles (i.e., 48 months) remained within the as-found TS tolerance of plus or minus 1%. The licensees as-found test data for the other 4 MSSVs that lifted outside the TS 1% tolerance showed that 3 of the valves exceeded the acceptance criteria in the negative or conservative direction. The one MSSV that exceeded the TS acceptance criteria in the positive direction was found by the licensee to be above the TS specified 1% tolerance by 8 psig. As shown in the fourth test of MSSV serial number BK 6302, the licensees test results for MSSVs stored in a controlled environment indicated that the impact of storage in a controlled environment on the opening setpoint was minimal.
The NRC staff finds that the licensee has demonstrated that the refurbishment in every two operating cycles, testing history of MSSVs from 1987 to the present, and storage conditions provide adequate assurance that the operational readiness of the valve to perform its safety function will not be impaired during the period that the proposed alternative is authorized.
Therefore, the NRC staff finds that the proposed alternative to extend the test interval for MSSV serial number BK 6302 installed in valve location RV-203-4A beyond the ASME OM Code 5-year test requirement is acceptable. Compliance with the ASME Code requirements would result in
hardship or unusual difficulty without a compensating increase in quality and safety due to unnecessary plant shutdown, unnecessary challenges to safety systems, and unnecessary cycling of equipment.
4.0 CONCLUSION
The NRC staff concludes that the proposed alternative to remove and test MSSV serial number BK 6302 installed in location RV-203-4A during RFO-17, along with the remaining other MSSV that will not have exceeded the 5-year test requirement by RFO-17, is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) on the basis that compliance with the Code requirements would result in hardship or unusual difficulty without a compensating increase in quality and safety. The additional time beyond that required by the ASME Code should not impair the valves operational readiness. The proposed alternative is authorized until the completion of RFO-17.
Principal Contributor: William K. Poertner Date: May 27, 2008