GNRO-2011/00084, Request for Relief GG-ISI-014, GG-ISI-015 and GG-ISI-016, Requests for Relief from ASME Code Section Xl Inservice Inspection Requirements for Pressure Retaining Welds in Control Rod Housings, Pressure Retaining Welds in Pumps
| ML113200448 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/15/2011 |
| From: | Perino C Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GG-ISI-014, GG-ISI-015, GG-ISI-016, GNRO-2011/00084 | |
| Download: ML113200448 (21) | |
Text
~Entergy GNRO-2011/00084 November 15, 2011 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001 Entergy Operations, Inc.
7003 Bald Hill Road P. O. Box 756 Port Gibson, MS 39150 Tel (601) 437-6299 Christina L. Perino Manager Licensing
SUBJECT:
Grand Gulf Nuclear Station - Request for Relief GG-ISI-014, GG-ISI-015 and GG-ISI-016 Requests for Relief from ASME Code Section Xllnservice Inspection Requirements for Pressure Retaining Welds in Control Rod Housings, Pressure Retaining Welds in Pumps and Valves and Supports Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29
REFERENCES:
1.
2nd 10 year lSI Inspection Interval, Request for Alternative of Limited Examinations (ADAMS Accession Number ML091490755) 2.
NRC SER for Second lSI Interval (ADAMS Accession Number ML101410002) 3.
NRC SER for First lSI Interval (TAC No. M95433)
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a, "Codes and Standards," paragraph (g)(5)(iii), Entergy requests relief from certain American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (BPV),Section XI, Sub Article IWB-2500 Inservice Inspection (lSI) requirements for Examination Category B-O, Pressure Retaining Welds in Control Rod Housings, ASME Section XI 1992 Edition, 1993 Addenda, Table IWC-2500-1 Inservice Inspection (lSI) requirements for Examination Category C-G, Pressure Retaining Welds in Pumps and Valves -
Inspection Program Band ASME Section XI 1992 Edition, 1993 Addenda, Table IWF-2500-1 Valves and Examination Category F-A, Supports - Inspection Program B. This relief is requested for the second 1O-year interval of the Inservice Inspection Program for the Grand Gulf Nuclear Station (GGNS).
Relief is requested in accordance with 10 CFR 50.55a(g)(6)(i) where full compliance with the ASME Code,Section XI requirements is not practical. The specific details of the requested relief are enclosed in Attachment 1, Attachment 2 and Attachment 3.
These requests for relief are being submitted beyond the 12 month timeframe following the second 120 month interval as specified under 10 CFR 50.55a(g)(5)(iv) due to them being inadvertently left off the relief request listed as Reference 1. This condition has been addressed in Entergy's Corrective Action Process.
The NRC previously granted the relief for examinations listed in attachment 1 and 2 in the Safety Evaluation listed as Reference 3.
GNRO-2011/00084 Page 2 of 2 This letter contains no new regulatory commitments.
If you have any questions concerning this letter, please contact Mr. Ernest Rufus at (601) 437-6582.
Sincerely, CLP/JAS Attachments:
1.
Grand Gulf Nuclear Station - Unit 1 second 10 year interval inservice inspection program relief request GG-ISI-014 2.
Grand Gulf Nuclear Station - Unit 1 second 10 year interval inservice inspection program relief request GG-ISI-015 3.
Grand Gulf Nuclear Station - Unit 1 second 10 year interval inservice inspection program relief request GG-ISI-016 cc:
Mr. Elmo Collins Jr.
Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATTN: Mr. A. B. Wang, NRR/DORL (w/2)
Mail Stop OWFN/8 B1 Washington, DC 20555-0001 to GNRO 2011/00084 Page 1 of7 ATTACHMENT 1 TO GNRO 2011/00084 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-014
Examination Category:
Item Number(s):
Unit / Inspection Interval Applicability:
Component(s) Affected:
Code Class:
References:
to GNRO 2011/00084 Page 2 of7 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-014 See Table 1 below ASME Code Class 1 ASME Section XI 1992 Edition, 1993 Addenda, Table IWB-2500-1 Inspection Program B B-O, Pressure Retaining Welds in Control Rod Housings B14.10, Welds in CRD Housing Grand Gulf Nuclear Station (GGNS), Second (2nd) 10-year Interval June 1, 1997 to May 31, 2008 (thru 10/22/2008 for Risk Informed Examinations)
I.
Applicable Code Requirement(s)
ASME Code,Section XI, 1992 Edition, 1993 Addenda, Table IWB-2500-1, Examination Category B-O, Pressure Retaining Welds in Control Rod Housings, Item B14.1 0 requires volumetric or surface examination of 10% of peripheral Control Rod Drive (CRD) housing welds.
II.
Impracticality of Compliance The Code required inspection for the Peripheral CRD Housing welds was not performed for the Second 10 Year lSI Interval. Relief is requested from performing the volumetric or surface examinations on the peripheral CRD housing welds based on the proposed alternative. The as-installed configuration of the CRD housings makes performance of the required examinations impractical for the following reasons. The housings are in close proximity to the reactor vessel support pedestal, which limits access to the welds on the outer circumference of the housings.
Next, the subject welds are below the lower reactor insulation support structure where the housings pass through a series of closely-spaced CRD housing support beams and associated hanger rods, which further limit access to the welds in the upper portion of the housings. Access to both the upper and lower welds from below is further limited by a series of CRD housing support bars, grid plates and grid clamps. Access to the lower welds from the housing 10 requires removal of the CRD mechanisms and sleeves. Refer to Table 1 for a list of all the Peripheral CRD Housing welds. Refer to Diagrams 1 and 2.
III.
Proposed Alternative and Basis for Use The circumstances and basis for the previous NRC approval have not changed.
The subject welds have received VT-2 examinations with the Reactor Coolant Pressure Boundary leakage test after each refueling outage. The Leak Detection System that is monitored continuously from the Control Room would detect a leak if one occurred while the plant was in operation. The "Shoot Out" steel and Grid support steel would prevent complete ejection of the CRD and will minimize the leak rate for the Makeup System.
For the Third 10 Year lSI Inspection Interval, Grand Gulf will access the CRD Housing weld area to inspect these welds to the extent possible during Refuel Outage 18.
to GNRO 2011/00084 Page 3 of7 IV. Duration of Requested Relief Relief is requested for the Second 10 Year lSI Interval from June 1, 1997 to May 31, 2008.
V.
Precedents Relief from the subject examinations was granted by the NRC for the first lSI Interval as documented in NRC SER (TAC No. M95433) dated October 18, 1996, Request for Relief 1-00008 Rev 3.
to GNRO 2011/00084 Page 4 of7 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF GG-ISI-014 TABLE 1 - PERIPHERAL CRD HOUSING WELDS COMPONENT NO 813D009-03/18-WELD-1 813D009-03/18-WELD-2 813D009-03/22-WELD-1 813D009-03/22-WELD-2 813D009-03/26-WELD-1 813D009-03/26-WELD-2 813D009-03/30-WELD-1 813D009-03/30-WELD-2 813D009-03/34-WELD-1 813D009-03/34-WELD-2 813D009-03/38-WELD-1 813D009-03/38-WELD-2 813D009-03/42-WELD-1 813D009-03/42-WELD-2 813D009-07/10-WELD-1 813D009-07/10-WELD-2 813D009-07/50-WELD-1 813D009-07/50-WELD-2 813D009-11/06-WELD-1 813D009-11/06-WELD-2 813D009-11/54-WELD-1 813D009-11/54-WELD-2 813D009-19/02-WELD-1 813D009-19/02-WELD-2 813D009-19/58-WELD-1 813D009-19/58-WELD-2 813D009-23/02-WELD-1 813D009-23/02-WELD-2 813D009-23/58-WELD-1 813D009-23/58-WELD-2 813D009-27/02-WELD-1 813D009-27/02-WELD-2 813D009-27/58-WELD-1 813D009-27/58-WELD-2 813D009-31/02-WELD-1 813D009-31/02-WELD-2 813D009-31/58-WELD-1 813D009-31/58-WELD-2 813D009-35/02-WELD-1 813D009-35/02-WELD-2 CATEGORY 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 ITEM NUMBER 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 DESCRIPTION Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing to GNRO 2011/00084 Page 5 of7 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM REQUEST FOR RELIEF GG-ISI-014 TABLE 1 - PERIPHERAL CRD HOUSING WELDS COMPONENT NO 813D009-35/58-WELD-1 813D009-35/58-WELD-2 813D009-39/02-WELD-1 813D009-39/02-WELD-2 813D009-39/58-WELD-1 813D009-39/58-WELD-2 813D009-43/02-WELD-1 813D009-43/02-WELD-2 813D009-43/58-WELD-1 813D009-43/58-WELD-2 813D009-51 /06-WELD-1 813D009-51/06-WELD-2 813D009-51/54-WELD-1 813D009-51/54-WELD-2 813D009-55/1 0-WELD-1 813D009-55/1 0-WELD-2 813D009-55/50-WELD-1 813D009-55/50-WELD-2 813D009-59/18-WELD-1 813D009-59/18-WELD-2 813D009-59/22-WELD-1 813D009-59/22-WELD-2 813D091-59/26-WELD-1 813D009-59/26-WELD-2 813D009-59/30-WELD-1 813D009-59/30-WELD-2 813D009-59/34-WELD-1 813D009-59/34-WELD-2 813D009-59/38-WELD-1 813D009-59/38-WELD-2 813D009-59/42-WELD-1 813D009-59/42-WELD-2 CATEGORY 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 8-0 ITEM NUMBER 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 814.10 DESCRIPTION Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing Welds in CRD Housing to GNRO 2011/00084 Page 6 of7 DIAGRAM 1 Elevation View Reactor Vessel Support Pedestal CRD Housing Support Beams to GNRO 2011/00084 Page 7 of7 DIAGRAM 2 eRD Housing Support Structures NOTE:
Many CRD Housings and the associated support structures are not shown CONTROL ROD DRIVING HOUSING SUPPORT STRUCTURES to GNRO 2011/00084 Page 1 of7 ATTACHMENT 2 TO GNRO 2011/00084 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-015 to GNRO 2011/00084 Page 2 of7 ASME Code Class 2 ASME Section XI 1992 Edition, 1993 Addenda, Table IWC-2500-1 Inspection Program B C-G, Pressure Retaining Welds in Pumps and Valves C6.10, Pump Casing Welds Grand Gulf Nuclear Station (GGNS), Second (2nd) 10-year Interval June 1, 1997 to May 31, 2008 (thru 10/22/2008 for Risk Informed Examinations)
GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-015 See Table 1 below Examination Category:
Item Number(s):
Unit 1Inspection Interval Applicability:
References:
Component(s) Affected:
Code Class:
I.
Applicable Code Requirement(s)
ASME Code,Section XI, 1992 Edition, 1993 Addenda, Table IWC-2500-1, Examination Category C-G, Pressure Retaining Welds in Pumps and Valves - Inspection Program B. Item C6.1 0 requires surface examination of 100% of welds in all components in each piping run examined under Examination Category C-F each inspection interval. For extent of examination, Note 1 applies, where in the case of multiple pumps and valves of similar design, size, function and service in a system, the examination of only one pump and one valve among each group of multiple pumps and valves is required.
II.
Impracticality of Compliance Relief is requested from performing the surface examination of the SB welds as depicted in Diagrams 1-3 for the pumps listed in Table 1 - Affected Components. There are 3 Residual Heat Removal Pumps (01 E12) with 01 E12C002B selected, 1 Low Pressure Core Spray Pump (01 E21) and 1 High Pressure Core Spray (01 E22) Pump. All remaining pressure retaining weld examinations for the subject pumps was performed.
III.
Basis for Use and Proposed Alternative Basis for Use Insufficient access exists to perform the required examination of the subject welds due to the pump casings being encased in concrete where only partial or no access is available.
Proposed Alternative The required examinations will be performed if the subject pumps are disassembled for maintenance to the point were the subject welds are accessible.
IV. Duration of Requested Relief Relief is requested for the Second 10 Year lSI Interval from June 1, 1997 to May 31, 2008.
V.
Precedents Relief from the subject examinations was granted by the NRC for the first lSI Interval as documented in NRC SER (TAC No. M95433).
10CFR50.55a(g)(6)(i) states:
to GNRO 2011/00084 Page 3 of7 The Commission will evaluate determinations under paragraph (g)(5) of this section that the code requirements are impractical. The Commission may grant such relief and may impose such alterative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
Entergy believes that it is impractical to obtain greater examination coverage on this component.
The examination performed on the subject component would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed relief be authorized pursuant to 10CFR50.55a(g)(6)(i).
to GNRO 2011/00084 Page 4 of7 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-015 TABLE 1 - AFFECTED COMPONENTS Group Category Item #
Component 10
% Coverage Description Indications RHR-B C-G C6.10 Q1 E12C002B-SB-1 0%
Pump None Casing Weld RHR-B C-G C6.10 Q1 E12C002B-SB-2 20%
Pump None Casing Weld LPCS C-G C6.10 Q1 E21 C001-SB-1 0%
Pump None Casing Weld LPCS C-G C6.10 Q1E21C001-SB-2 0%
Pump None CasinQ Weld HPCS C-G C6.10 Q1 E22C001-SB-1 0%
Pump None Casing Weld HPCS C-G C6.10 Q1E22C001-SB-2 0%
Pump None Casing Weld HPCS C-G C6.10 Q1 E22C001-SB-3 0%
Pump None Casing Weld to GNRO 2011/00084 Page 5 of7 Diagram 1 Pump Q1 E12C002B to GNRO 2011/00084 Page 6 of7 Diagram 2 Pump Q1 E21 C001
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~~f ~.~~~~~. SlF' to GNRO 2011/00084 Page 1 of5 ATTACHMENT 3 TO GNRO 2011/00084 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-016 to GNRO 2011/00084 Page 2 of5 GRAND GULF NUCLEAR STATION - UNIT 1 SECOND 10 YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST GG-ISI-016 Component(s) Affected:
Code Class:
References:
Examination Category:
Item Number(s):
Unit 1Inspection Interval Applicability:
See Table 1 below ASME Code Class 2 ASME Section XI 1992 Edition, 1993 Addenda, Table IWF-2500-1 Inspection Program B F-A, Supports F1.40, Supports other than Piping Supports Grand Gulf Nuclear Station (GGNS), Second (2nd) 1O-year Interval June 1, 1997 to May 31, 2008 (thru 10/22/2008 for Risk Informed Examinations)
I.
Applicable Code Requirement(s)
ASME Code,Section XI, 1992 Edition, 1993 Addenda, Table IWF-2500-1, Examination Category F-A, Supports - Inspection Program B. Item F1.40 requires visual examination of 100% of supports other than piping supports in each inspection interval.
II.
Impracticality of Compliance Due to limited access, being encased in concrete, certain code examination volumes, as depicted in ASME Section XI, cannot be examined to the extent of obtaining full code coverage. Pursuant to 10CFR50.55a(g)(5)(iii), Entergy Operations Inc. (GGNS) requests permission to perform a Visual Examination (VT-3) within the limitations described in Table 1 of this Request. Refer to Diagrams 1 and 2 for location of Pump Support component.
III.
Basis for Use and Proposed Alternative Basis for Use Insufficient access exists to perform the required examination of the subject support due to the pump support being encased in concrete where only partial access is available.
Proposed Alternative No alternative testing is proposed at this time. Entergy has examined this support weld to the extent available.
IV.
Duration of Requested Relief Relief is requested for the Second 10 Year lSI Interval from June 1,1997 to May 31,2008.
V.
Conclusion 10CFR50.55a(g)(6)(i) states:
The Commission will evaluate determinations under paragraph (g)(5) of this section that the code requirements are impractical. The Commission may grant such relief and may impose such alterative requirements as it determines is authorized by law and will not endanger life or property or the common defense and security and is otherwise in the public interest giving due consideration to the burden upon the licensee that could result if the requirements were imposed on the facility.
to GNRO 2011/00084 Page 3 of5 Entergy believes that it is impractical to obtain greater examination coverage on this component.
The examination performed on the subject component would detect generic degradation, if it existed, therefore demonstrating an acceptable level of integrity. Therefore, we request the proposed relief be authorized pursuant to 10CFR50.55a(g)(6)(i).
Table 1, limited F-A Examinations Item #
Component ID Description
% Coverage Reason for Indications Limitation F1.40 Q1 E12C002B-S2 Pump Support 50%
Partially None encased in concrete to GNRO 2011/00084 Page 4 of5 Diagram 1 Pump Q1 E12C002B
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& SIt....
to GNRO 2011/00084 Page 5 of5 Diagram 2 Pump Q1 E12C0028 Detail of S2 Support