ML090630469
| ML090630469 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear  |
| Issue date: | 03/30/2009 |
| From: | Markley M Plant Licensing Branch IV |
| To: | Ford B Entergy Operations |
| Kalyanam N, NRR/DORL/LPL4, 415-1480 | |
| References | |
| TAC MD8817, TAC MD8818 | |
| Download: ML090630469 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 30, 2009 Mr. Bryan S. Ford Senior Manager, Nuclear Safety & Licensing Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213-8298
SUBJECT:
ARKANSAS NUCLEAR ONE, UNIT 1, AND GRAND GULF NUCLEAR STATION - REQUEST FOR ALTERNATIVE CEP-CISI-001, USE ALTERNATIVE REQUIREMENTS IN ASME CODE CASE N-739-1 (TAC NOS. 1\\1108817 AND 1\\1108818)
Dear Mr. Ford:
By letter dated May 20, 2008, as supplemented by letter dated January 23, 2009, Entergy Operations, Inc. (Entergy, the licensee), submitted request CEP-CISI-001 for Arkansas Nuclear One, Unit 1 (ANO-1), and Grand Gulf Nuclear Station (GGNS), proposing an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition with the 2003 Addenda, IWA-2300, "Qualifications of Nondestructive Examination Personnel." The licensee's proposed alternative is applicable to the fourth 10-year inservice inspection (lSI) program interval for ANO-1, which began May 31, 2008, and ends on May 31,2018, and the third 10-year lSI interval for GGNS, which began on June 1, 2008, and ends on June 1, 2017.
The U.S. Nuclear Regulatory Commission (NRC) approval of relief request CEP-CISI-001 would authorize Entergy to utilize the alternative requirements in ASME Code Case N-739-1, "Alternative Qualification Requirements for Personnel Performing Class CC Concrete and Post-tensioning System Visual Examinations," in lieu of the requirements of IWA-2300, for personnel performing visual examinations of Class CC concrete surfaces and unbonded post tensioning system items. Article IWA-2300 provides requirements for qualification and certification of personnel performing non-destructive examinations.
The NRC staff has reviewed the licensee's submittal and determined that the proposed alternative provides an acceptable level of quality and safety. Therefore, pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR), the NRC staff authorizes the use of the proposed alternative for the Inspection Intervals for the fourth 10-year lSI interval for AI\\JO-1 and the third 10-year lSI interval for GGNS, or until Code Case N-739-1 is approved for general use by reference in Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1." After that time, if the licensee wishes to continue to use Code Case N-739, the licensee must follow all conditions and limitations placed on the use of the Code Case, jf any, that are specified in Regulatory Guide 1.147.
B. Ford
- 2 All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
The NRC staffs safety evaluation is enclosed.
Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-416
Enclosure:
Safety Evaluation cc w/encl.: Distribution via ListServ
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR ALTERNATIVE CEP-CISI-001 EI\\JTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 1 GRAND GULF NUCLEAR STATION DOCKET NOS. 50-313 AND 50-416
1.0 INTRODUCTION
By letter dated May 20, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML081620369), as supplemented by letter dated January 23, 2009 (ADAMS Accession No. ML090540059), Entergy Operations, Inc. (Entergy, the licensee),
submitted a request for alternative, CEP-CISI-001, for Arkansas Nuclear One, Unit 1 (ANO-1),
and Grand Gulf l\\Juclear Station (GGI\\JS). Entergy requested to utilize the alternative qualification requirements of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Code Case N-739-1, "Alternative Qualification Requirements for Personnel Performing Class CC Concrete and Post-tensioning System Visual Examinations,"
in lieu of the requirements of ASME Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," 2001 Edition, 2003 Addenda, IWA-2300, "Qualifications of Nondestructive Examination Personnel," for personnel performing visual examinations of Class CC concrete surfaces and unbonded post-tensioning system items. The licensee's proposed alternative is applicable to the fourth 10-year inservice inspection (lSI) program interval for ANO-1 and the third 10-year lSI interval for GGNS.
2.0 REGULATORY EVALUATION
The lSI of the ASME Code Class 1, 2, and 3 components must meet the requirements of the Section XI of editions of the ASME Code Addenda as required by Section 50.55a(g) of Title 10 of the Code of Federal Regulations (10 CFR). Section 10 CFR 50.55a(g)(4) states that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, components classified as ASME Boiler and Pressure Vessel Code Class 1, 2, and 3, including supports, must meet the requirements, except design and access provisions and preservice examination requirements, specified in Section XI of editions of the ASME Code and Addenda, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Pursuant 10 CFR 50.55a(g)(4)(ii), inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b), 12 months before the start of the 120-month inspection interval, subject to the limitations and modifications listed therein. In accordance Enclosure
- 2 the limitations and modifications listed therein. In accordance with this requirement, the Section XI, ASME Code of record for the fourth lSI interval at ANO-1, and the third lSI interval at GGNS, is the 2001 Edition with the 2003 Addenda.
10 CFR 50.55a(a)(3) states that proposed alternatives to the requirements of paragraphs (c),
(d), (e), (f), (g) and (h) of 10 CFR 50.55a, "Code and standards," or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation, provided the applicant demonstrates that: (i) the proposed alternatives would provide an acceptable level of quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Pursuant to 10 CFR 50.55a(3)(i), the licensee has submitted Relief Request CEP CISI-001, as a proposed alternative to the regulatory requirement in 10 CFR 50.55a(b)(2)(viii)(F) to the provision in IWL-2310(d) of the ASME Code,Section XI.
- 3.
TECHNICAL EVALUATION 3.1 Relief Request CEP-CISI-001 Pursuant to 10 CFR 50.55a (a)(3)(i), Entergy requested relief to utilize the alternative qualification requirements of ASME Code Case N-739-1, in lieu of the requirements in IWA 2300, specifically for personnel performing visual examinations of Class CC concrete surfaces and post-tensioning system items for ANO-1 and GGNS for the fourth and third 10-year lSI intervals, respectively.
3.1.1 ASME Code Components Affected Code Class: CC Code
Reference:
ASME Code,Section XI, Article IWA-2300 and Subarticle IWL-2310(d)
Examination Category: L-A "Concrete" and L-B "Unbonded Post-tensioning System" under Subsection IWL Item Number: L1.11, L1.12, and, L2.30 under Subsection IWL, Table IWL-2500-1, "Examination Categories"
==
Description:==
Qualification requirements for personnel performing examinations of concrete and tendon anchorage hardware, wires, or strands of Class CC components Component Number: Concrete surfaces and tendon anchorage hardware, of Class CC containments 3.1.2
Applicable Code Edition and Addenda
ASME Code,Section XI, 2001 Edition, 2003 Addenda, Subsections IWA and IWL.
- 3 3.1.3 Applicable Code Requirement from which Relief is Requested Paragraph IWL-231 O(d) states:
The Owner shall define qualification requirements for personnel performing examinations of concrete and tendon anchorage hardware, wires, or strands.
The regulatory modification requirement in 10 CFR 50.55a(b)(2)(viii)(F) states:
Personnel that examine containment concrete surfaces and tendon hardware, wires, or strands must meet the qualification provisions in IWA-2300. The "owner-defined" personnel qualification provisions in IWL-2310(d) are not approved for use.
Article IWA-2300 provides requirements for qualification and certification of personnel performing non-destructive examinations.
3.1.4 Proposed Alternative The licensee has requested to utilize the alternative requirements in ASME Code,Section XI, Division 1, Code Case 1\\1-739-1, "Alternate Qualification Requirements for Personnel Performing Class CC Concrete and Post-tensioning System Visual Examinations," in lieu of the requirements of IWA-2300 for qualification of personnel that examine containment concrete surfaces and post-tensioning system components. The licensee has requested this relief pursuant to 10 CFR 50.55a(a)(3)(i), on the basis that the proposed alternative would provide an acceptable level of quality and safety.
3.1.5 Licensee's Basis for Proposed Alternative (as stated)
The licensee stated that ASME has developed an alternative set of qualification requirements in Code Case N-739-1 which provide detailed criteria to qualify personnel who examine containment concrete surfaces and tendon hardware, wires or strands. The licensee stated that similar to the requirements in IWA-2300, Code Case N-739-1 includes plant and Section XI Subsection IWL experience requirements, as well as detailed training proficiency requirements for personnel performing Class CC concrete and post-tensioning system visual examinations.
The licensee stated that the alternative requirements in Code Case N-739-1 detail specific guidance for personnel qualification for containment concrete and post-tensioning system inspections that provide an acceptable level of quality and safety similar to the requirements in IWA-2300 and, therefore, addresses the intent of the requirements in 10 CFR 50.55a(b)(2)(viii)( F).
3.1.6 Duration of Proposed Alternative The proposed alternative is requested for the fourth 10-year lSI program interval for ANO-1, which began on May 31, 2008, and ends on May 31, 2018, and for the third 10-year lSI program interval for GGNS, which began on June 1, 2008, and ends on June 1, 2017.
- 4 3.1.7
NRC Staff Evaluation
The regulations in 10 CFR 50.55a(b)(2)(viii)(F) state that "Personnel that examine containment concrete surfaces and tendon hardware, wires, or strands must meet the qualification provisions in IWA-2300. The "owner-defined" personnel qualification provisions in IWL-231 O( d) are not approved for use." IWA-2300 provides qualification provisions for personnel performing nondestructive examination, including VT-1, VT-2, and VT-3 visual examinations.
Paragraph IWA-2312(c) requires training, qualification, and certification of visual examination personnel to comply with the requirements of Appendix VI of the Code, which makes reference to American National Standards Institute/American Society for Nondestructive Testing (ANSI/ASNT) CP-189, and allows for limited certification (for personnel who are restricted to performing examinations of limited or specific scope; Le., limited operations or limited techniques) pursuant to IWA-2350.
Code Case N-739-1 lists specific experience, classroom training, written and practical examination, and vision test requirements for qualification of personnel approved for performing general (VT-3) and detailed (VT-1) visual examinations of structural concrete and reinforcing steel and post-tensioning system items (e.g., wires, strands, anchorage hardware, corrosion protection medium and free water) of Class CC containments under the direction of the Responsible Engineer. The qualification requirements adequately cover relevant plant experience; instructional topics for classroom training in IWL requirements and plant-specific IWL visual examination procedures; written and practical examination requirements and frequency of administration to demonstrate training proficiency; vision test requirements; and documentation of qualification requirements in the Employer's written practice.
The NRC staff concludes that the Code Case meets the intent of the qualification provisions in IWA-2300 with specific scope for qualification of personnel that examine concrete surfaces and post-tensioning systems items (tendon hardware, wires or strands) of Class CC containments and is, therefore, acceptable as an alternative to the provisions of IWA-2300 for that scope of examinations. Therefore, the NRC staff concludes that the relief request meets the intent of 10 CFR 50.55a(b)(2)(viii)(F) and provides an acceptable level of quality and safety. Therefore, the requested relief is authorized pursuant to 10 CFR 50.55a(a)(3)(i).
4.0 CONCLUSION
Based on the above, the NRC staff concludes that the licensee's proposed alternative to use ASME Code Case N-739-1 in lieu of ASME Code,Section XI, IWA-2300 will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the use of the proposed alternative for qualification of personnel performing visual examinations of Class CC concrete surfaces and post-tensioning system items is authorized for the fourth 10-year lSI program interval for ANO-1 and the third 10-year lSI program interval for GGNS, or until Code Case N-739-1 is approved for general use by reference in Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1."
After that time, if the licensee wishes to continue to use Code Case N-739, the licensee must follow all conditions and limitations placed on the use of the Code Case, if any, that are specified in Regulatory Guide 1.147.
- 5 All other applicable requirements of the ASME Code,Section XI, for which relief have not been specifically requested remain applicable, including a third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors:
J. Uribe G. Thomas Date:
March 30, 2009
B. Ford
- 2 All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in this relief request remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
The NRC staff's safety evaluation is enclosed.
Sincerely, IRA!
Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-416
Enclosure:
Safety Evaluation cc w/encl.: Distribution via ListServ DISTRI BUTION:
PUBLIC LPLIV r/f RidsAcrsAcnw_MailCTR Resource RidsNrrDeEmcb Resource RidsNrrDorlLpl4 Resource RidsNrrDorlDpr Resource RidsNrrLA~IBurkhardt Resource RidsNrrPMAI\\JO Resource RidsNrrPMGrandGulf Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JUribe, NRRIDE/EMCB GThomas, NRRIDE/EMCB SWiliiams, EDO, RIV OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DCI/CPNB*
NAME NKalyanam JBurkhardt MKhanna*
DATE 3/16/09 3/13/09 2/27/09 ADAMS Accession No. ML090630469