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 Activ
| ML090900519 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim, Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/17/2009 |
| From: | Ford B Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNRO-2009-00003, ISI-2008-1 | |
| Download: ML090900519 (13) | |
Text
dh Entergy Nuclear operations, Inc.
1340 Echelon Parkway EntergyJackson, Mississippi 39213-8298 Tel 601-368-5758 Bryan S. Ford Senior Manager, Nuclear Safety &
Licensing CNRO-2009-00003 March 17, 2009 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001
SUBJECT:
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 Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Vermont Yankee Nuclear Power Station Docket No. 50-271 License No. DPR-28
REFERENCES:
- 1. Entergy Letter to the NRC dated December 1, 2008, Request ISI-2008-1, Use of Later ASME Section Xl Code Edition and Addenda for Repair/replacement, Pressure Testing, and Nondestructive Examination Activities
- 2. Entergy Letter to the NRC dated August 22, 2007, Request ISI-2007-Use of Later ASME Section XI Code Edition and Addenda for Repair/replacement, Pressure Testing, and Nondestructive ISI Examination Activities
Dear Sir or Madam:
In Reference 1 above and pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy Nuclear Operations, Inc. (Entergy) had requested permission to use the 2001 Edition/2003 Addenda of ASME Section Xl for the performance of ISI related activities associated with repair/replacements, pressure testing, and Non Destructive Examinations. This request, ISI-2008-1, is applicable to Pilgrim (PNPS) and Vermont Yankee (VY) Nuclear Power Stations
/
CNRO-2009-00003 Page 2 of 3 During several phone calls concerning the request, the NRC asked that Entergy respond to four questions. The responses are provided in Enclosure 1. The revised Relief Request is provided in Enclosure 2.
Should you have any questions regarding this submittal, please contact Bryan Ford at (601) 368-5516.
This letter contains no commitments.
Sincerely, BSFNVBB
Enclosure:
- 1. Response to NRC RAIs concerning ISI-2008-1
Enclosure:
- 2. Revised Relief Request ISI-2008-1 cc.
Mr. Samuel J. Collins (w/o Attachment)
Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. James S. Kim, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8C2A Washington, DC 20555 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC 320 Governor Hunt Road Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601 Mr. James Shea, Project Manager Office of Nuclear Reactor Regulation Mail Stop: 0-8B-1 U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852
CNRO-2009-00003 Page 3 of 3 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector Pilgrim Nuclear Power Station
ENCLOSURE I CNRO-2009-00003 RESPONCE TO NRC RAIs CONCERNING ISI-2008-1 to CNRO-2009-00003 Page 1 of 2
- 1. NRC Question I In Enclosure to the December 1, 2008, Submittal, Page 2, Section 3B, First Bullet, the licensee's sentence does not correspond to 10 CFR 50.55a(b)(2)(xxvi) in the Title 10 Code of Federal Regulation. Please clarify.
Response: The referenced bullet contains a typographical error. The correct paragraph reference is 10 CFR 50.55a(b)(2)(xxiv). Request ISI-2008-1 has been revised.
- 2. NRC Question 2 In Enclosure to the December 1, 2008, Submittal, Page 2, Section 3B, Third Bullet, the licensee's sentence does not correspond to 10 CFR 50.55a(b)(2)(xxiv) in the Title 10 Code of Federal Regulation. Please clarify.
Response: The referenced bullet contains a typographical error. The correct paragraph reference is 10 CFR 50.55a(b)(2)(xxvi). Request ISI-2008-1 has been revised.
- 3. NRC Question 3 In Attachment 1 to the December 1, 2008, Submittal, Page 1, Table of PROPOSED ASME SECTION Xl CODE OF RECORDS FOR PNPS AND VY, Subsection of IWA-GENERAL REQUIREMENT, Article of IWA-2000, the licensee requested to use certain subarticles of both the 1998 Edition through 2000 Addenda and 2001 Edition through 2003 Addenda to the ASME Code Section XI. Footnote (2) provides specific subarticles that will be used. Please explain why IWA-2100, 2200, and 2300 from the 2001 Edition through 2003 Addenda to the ASME Code Section Xl will be used whereas IWA-2400, 2500, and 2600 from the 1998 Edition through 2000 Addenda will be used.
Response: Entergy is in the process of standardizing the performance of Inservice Inspection (ISI) related activities such as repair/replacements, pressure testing, and NDE.
Standardized ASME Section Xl repair/replacement, pressure testing, and NDE programs will be implemented at all Entergy sites including PNPS and VY in common fleet procedures - assuming NRC approval of Request ISI-2008-1 is obtained. However, as noted in Section 3 of Request ISI-2008-1, this Request does not apply to the selection, planning, or scheduling of ISI examinations and tests at PNPS and VY. Entergy intends to continue to perform these activities in accordance with the 1998 Edition/2000 Addenda which is the present Code of Record for both sites. Updating the selection, planning, and scheduling of ISI examinations and tests to the 2001 Edition/2003 Addenda prior to the scheduled Ten-Year updates would be costly, resource intensive, and overly burdensome.
In conclusion, Entergy is requesting NRC approval to allow PNPS and VY to perform ISI related activities in accordance with the 2001 Edition/2003 Addenda of ASME Section Xl with one exception:
PNPS and VY will continue to select, plan, and schedule the performance of ISI examinations and tests in accordance with the 1998 Edition/2000 Addenda which is the current Code of Record for both sites as approved by the NRC.
ASME Section Xl articles and subartilces applicable to the selection, planning, and scheduling of ISI examinations and tests are clearly defined in Attachment 1 of the to CNRO-20Q9-00003 Page 2 of 2 Request. This methodology was also approved by the NRC in Request ISI-2007-1 for ANO-2.
- 4. NRC Question 4 The licensee states that the intent of request ISI-2008-1 is to maintain a standard program among its nuclear facilities.
Their letter for ISI-2008-1 dated December 1, 2008 references ISI-2007-1 (request for ANO-2). Attachment 2 to request ISI-2007-1 lists the proposed code edition for ANO-2 and only IWE-5000 is listed as 2001 edition/2003 addenda for Class MC components. In contrary, Attachment 1 to Request ISI-2008-1 lists both IWE-3000 and IWE-5000 as 2001 edition/2003 edition for Class MC components.
There appears to be an inconsistency here.
Response: The NRC's observation is correct regarding IWE-3000 and 5000. At present, ANO-2 is only using IWE-5000 from the 2001 Edition/2003 Addenda whereas Entergy has proposed using IWE-3000 and 5000 from the 2001 Edition/2003 Addenda for PNPS and VY in Request ISI-2008-1. The proposal in Request ISI-2008-1 is consistent with what is presently done at all Entergy sites except ANO-2. Entergy intends to align ANO-2 with the rest of the fleet during the ANO-2 Ten-Year Update which is presently scheduled for March 2010.
ENCLOSURE 2 CNRO-2009-00003 ISI-2008-1 REVISED REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv) FOR USE OF LATER ASME SECTION XI CODE EDITION AND ADDENDA FOR REPAIR/REPLACEMENT, PRESSURE TESTING, AND NONDESTRUCTIVE ISI EXAMINATION ACTIVITIES
ENTERGY NUCLEAR OPERATIONS, INC.,
10 CFR 50.55a Request ISI-2008-1 REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv) FOR USE OF LATER ASME SECTION XI CODE EDITION AND ADDENDA FOR REPAIR/REPLACEMENT, PRESSURE TESTING, AND NONDESTRUCTIVE EXAMINATION ACTIVITIES
- 1. ASME Code Components Affected Class 1, 2, 3, and MC components, component supports, and welds in the ASME Section XI pressure boundary at Pilg'rim Nuclear Power Station (PNPS) and Vermont Yankee (VY).
2. Applicable Code Edition and Addenda
Inservice Inspection (ISI) related activities such as repair/replacements, pressure testing, and nondestructive examination (NDE) at PNPS and VY are currently performed in accordance with the 1998 Edition/2000 Addenda of ASME Section Xl with various NRC approved alternatives which are specified in the PNPS and VY ISI,Programs. PNPS and VY also comply with all applicable 10 CFR 50.55a conditions and limitations.
- 3. Proposed Subsequent Code Edition and Addenda (or Portion)
A. Backgqround PNPS and VY perform ISI related activities such as repair/replacements, pressure testing, and NDE in accordance with the 1998 Edition/2000 Addenda as described in Section 2 above. However, at other Entergy nuclear stations - Arkansas Nuclear One, Units 1 and 2 (ANO-1 & 2), Grand Gulf Nuclear Station (GGNS), Indian Point Energy Center, Unit 2 (IPEC-2), James A. FitzPatrick (JAF), Palisades Nuclear Plant (PLP),
River Bend Station (RBS), and Waterford Steam Electric Station Unit 3 (WF3) - these activities are currently performed in accordance with the 2001 Edition/2003 Addenda of ASME Section XI except for alternatives (e.g. ASME Section XI Code Cases) approved by the NRC in accordance with 10 CFR 50.55a and as listed below.
Performance demonstration of ultrasonic examinations complies with the 2001 Edition/No Addenda of Appendix VIII to comply with 10 CFR 50.55a(b)(2)(xxiv).
The NDE provision in IWA-4540(a)(2) of the 2001 Edition/2002 Addenda are applied when performing system leakage tests after repair/replacement activities involving welding or brazing to comply with 10 CFR 50.55a(b)(2)(xx)(B).
" Pressure'testing of mechanical joints of Class 1, 2, and 3 items are performed in accordance with IWA-4540(c) of the 1998 Edition/No Addenda to comply with 10 CFR 50.55a(b)(2)(xxvi).
Entergy is in the process of standardizing the performance of ISI related activities across the entire nuclear fleet. While ISI Program Plans will be controlled in site-specific documents, the repair/replacement, pressure testing, and NDE programs will be controlled in common program documents that will be corporately implemented across 1 of 3
the entire nuclear fleet. To do this, the ASME Section Xl Code of Record for ISI related activities at PNPS and VY must be updated to comply with the Code of Record used at other Entergy nuclear stations as described above.
B. Proposed Subsequent Code Edition and Addenda Pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy requests permission to utilize the 2001 Edition/2003 Addenda of ASME Section Xl at PNPS and VY for the performance of repair/replacements, pressure testing, and NDE with the exceptions noted below:
Performance demonstration of ultrasonic examinations will be performed in accordance with the 2001 Edition/No Addenda of Appendix VIII to comply with 10 CFR 50.55a(b)(2)(xxiv).
The NDE provision in IWA-4540(a)(2) of the 2001 Edition/2002 Addenda will be applied when performing system leakage tests after repair/replacement activities involving welding or brazing to comply with 10 CFR 50.55a(b)(2)(xx)(B).
Pressure testing of mechanical joints of Class 1, 2, and 3 items will be performed in accordance with IWA-4540(c) of the 1998 Edition/No Addenda to comply with 10 CFR 50.55a(b)(2)(xxvi).
All NRC conditions, limitations, and restrictions in 10 CFR 50.55a that are applicable to the 2001 Edition/2003 Addenda of ASME Section Xl will be met.
It is important to note that this request does not apply to the selection, planning, or scheduling of ISI examinations and tests as defined in IWB-, IWC-, IWD-, IWE-, and IWF-2500 or NRC approved ISI alternatives. Therefore, ISI examinations and tests at PNPS and VY will continue to be selected, planned, and scheduled in accordance with its present code of record as described in Section 2, above. See Attachment 1 for specific details regarding this proposal.
- 4. Related Requirements Entergy is requesting permission to use the 2001 Edition/2003 Addenda of ASME Section Xl for the performance of repair/replacements, pressure testing, and NDE with the exceptions noted in Section 3.B, above. In making this request, Entergy will comply with all related requirements in ASME Section XI as described below:
Entergy has proposed to utilize all "Articles" (e.g. IWA-4000, IWA-5000) from every "Subsection" (e.g. IWA, IWB, etc.) of the 2001 Edition/2003 Addenda that could be used or referenced for the performance of repair/replacement, pressure testing, and NDE activities. Entergy has also stated that it will comply with all "Mandatory Appendices" of the 2001 Edition/2003 Addenda.
Entergy will use Appendix VIII from the 2001 Edition/No Addenda of ASME Section Xl in accordance with the NRC restriction in paragraph (b)(2)(xxiv) of 10 CFR 50.55a.
However, this appendix includes all pertinent requirements for performance demonstration of ultrasonic examination systems.
Entergy will comply with IWA-4540(a) of the 2001 Edition/2002 Addenda and IWA-4540(c) of the 1998 Edition/No Addenda for pressure testing to comply with paragraphs 2 of 3
(b)(2)(xx)(B) and (b)(2)(xxvi) of 10 CFR 50.55a. Because all applicable requirements are included in these two code paragraphs, no other ASME Section XI code paragraphs need be invoked.
With regard to the performance of ISI examinations and tests, Entergy will continue to select, plan, and schedule these ISI inspection activities - as specified in IWA-, IWB-,
IWC-, IWD-, IWE-, and IWF-2500 or NRC approved ISI alternatives - in accordance with the PNPS and VY current ISI Program Plan. See Attachment 1 for more details.
- 5. Duration of Proposed Request PNPS and VY are presently in their fourth 10-Year ISI intervals. The effective dates for the ISI intervals are listed below:
PNPS: July 1, 2005 thru July 30, 2015 VY:
September 1,2003 thru August 31, 2013 The duration of this request will be from implementation of this alternative following approval by the NRC until the end of the fourth ISI intervals for PNPS and VY.
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REQUEST ISI-2008-1 ATTACHMENT 1 PROPOSED ASME SECTION XI CODES OF RECORD FOR PNPS AND VY
CNRO-2009-00003 PROPOSED ASME SECTION XI CODE OF RECORD FOR PNPS AND VY ASME'Section XI
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CNRO-2009-00003 PROPOSED ASME SECTION Xl CODE OF RECORD FOR PNPS AND VY Notes:
(1) The selection, planning, and scheduling of ISI examinations/tests will comply with these ASME Section Xl articles (e.g. IWB-1000 and 2000) or applicable NRC approved alternatives that are specified in the PNPS and VY ISI Program Plans. Therefore, PNPS and VY will continueto comply with its original Code of Record when performing these ISI activities.
(2) PNPS and VY are proposing to use IWA-2100, 2200, and 2300 from the 2001 Edition/2003 Addenda for requirements applicable to authorized inspection, examination methods, and qualification of NDE personnel. However, PNPS and VY will continue to comply with its original Code of Record when using IWA-2400, 2500, 2600 for the selection, planning, and scheduling of ISI examinations and tests.
(3) As exceptions to IWA-4000 of the 2001 Edition/2003 Addenda, PNPS and VY will comply with the alternatives listed below to comply with NRC restrictions in 10 CFR.55a:
The NDE provision in IWA-4540(a)(2) of the 2001 Edition/2002 Addenda will be applied when performing system leakage tests after repair/replacement activities involving welding or brazing to comply with 10 CFR 50.55a(b)(2)(xx)(B).
Pressure testing of mechanical joints of Class 1, 2, and 3 items will be performed in accordance with IWA-4540(c) of the 1998 Edition/No Addenda to comply with 10 CFR 50.55a(b)(2)(xxvi).
(4) Entergy will also comply with all NRC conditions, limitations, and restrictions specified in 10 CFR 50.55a.
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