NL-12-069, Unit Number 2, Relief Request IP2-1SI-RR-15 - Proposed Alternative to the Use of a Weld Reference System
| ML12165A262 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/23/2012 |
| From: | Robert Walpole Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| IP2-ISI-RR-15, NL-12-069 | |
| Download: ML12165A262 (5) | |
Text
SEn tergW Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Robert Walpole Licensing Manager Tel (914) 254-6710 May 23, 2012 NL-12-069 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Relief Request IP2-1SI-RR Proposed Alternative to the Use of a Weld Reference System Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26
Dear Sir or Madam:
Entergy Nuclear Operations, Inc. (Entergy) is submitting Relief Request No. 15 (IP2-1SI-RR-
- 15) (Enclosure 1) for Indian Point Unit No. 2 (IP2). This relief request is for the Fourth 10-year Inservice Inspection (ISI) Interval. The purpose is to request relief from Subarticle IWA-2600 requirements to establish a weld reference system for all welds and areas subject to surface or volumetric examination. This request is made in accordance with 10 CFR 50.55a(a)(3)(i), an alternative which provides an acceptable level of quality and safety.
Entergy requests approval of the relief request within 12 months of docketing. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Licensing Manager at 914-254-6710.
Sincerely, N-
Enclosure:
cc:
- 1. Relief Request No IP2-1SI-RR Proposed Alternative to the Use of a Weld Reference System Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office Indian Point Ms. Bridget Frymire, New York State Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA (D (4-7 TO NL-12-069 RELIEF REQUEST NO: IP2-ISI-RR-15 PROPOSED ALTERNATIVE TO THE USE OF A WELD REFERENCE SYSTEM ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247
Relief Request IP2-1SI-RR-15 Page 1 of 3 Indian Point Unit 2 Fourth 10-year ISI Interval Relief Request No: IP2-1SI-RR-15 Proposed Alternative to the Use of a Weld Reference System Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
-Alternative Provides Acceptable Level of Quality and Safety-
- 1. ASME Code Component(s) Affected Code Class:
1 and 2
References:
IWA-2600 Examination Category:
Not Applicable Item Number:
Not Applicable
==
Description:==
Weld Reference System
2. Applicable Code Edition and Addenda
The code of record for the Indian Point Unit 2 Inservice Inspection Fourth Interval is the ASME Section Xl Code, 2001 Edition including the 2003 Addenda.
3. Applicable Code Requirement
Subarticle IWA-2600 requires the establishment of a weld reference system for all welds and areas subject to surface or volumetric examination. Each such weld area shall be located and identified by a system of reference points.
Appendix Ill, Subarticle 111-4300 - requires the identification of examination areas. Weld identification and location shall be shown on a weld identification plan. Welds shall be marked once before or during the preservice examination to establish a reference point.
4. Reason for Request
IP2 requests relief from the requirements of the weld reference system as specified in IWA-2600 and 111-4300. Pursuant to 10 CFR 50.55a(a)(3)(i) relief is requested on the basis that the proposed alternative would provide an acceptable level of quality and safety.
5. Proposed Alternative and Basis for Use
The weld reference system described below shall be used for locating welds on existing piping and components and new installations.
Datum reference markings will be established in the event that recordable indications are to be reported. Such datum points shall either be marked on the component or have their locations adequately described in the inspection documentation so that subsequent relocation can be achieved.
The method proposed for the identification of indication locations is identical to the one
Relief Request IP2-ISI-RR-15 Page 2 of 3 employed at IP2 during the first, second, and third inspection intervals.
Basis for Use The current code requirements include the establishment of a weld reference system which includes the initial marking of weld joints. At the time of construction of IP2, the application of a reference system which included the marking of welds before or during the preservice examination was not required by the code and, accordingly welds were not marked.
A reference system for controlling the selection and documentation of datum points has been in effect since preservice inspections were performed in the early 1970's. The datum and conventions established at that time have been retained to promote consistency in the recording of data. The general conventions used at IP2 for establishing weld reference datum points include:
Reference system for pipe:
- The datum point for a circumferential weld on a horizontal pipe is the intersection of the top centerline of the pipe and the weld centerline. Dimensions are taken in a clockwise direction when viewing along the direction of system flow, which is marked on the line isometric drawing.
- The datum point for a circumferential weld on a vertical pipe is the intersection of the weld centerline and the centerline through the outside (extrados) of the elbow or bend that is in the direction of the lower weld number.
- The datum for a longitudinal weld is the weld centerline and the intersecting circumferential weld.
Reference system for vessels:
- The datum for circumferential welds is the intersection of the weld centerline and the centerline of the adjacent longitudinal weld. Dimensions are taken in a clockwise direction when viewed from the top.
- Where there is no intersecting weld, the datum point is drawn from an existing structural point (i.e., the centerline of hot leg manway). This is identified on the data sheet for the weld examination.
- The datum for longitudinal welds is the intersection of the weld centerline and the centerline of the intersecting upper circumferential weld.
The weld reference system currently in use at IP2 has been performing satisfactorily for the first, second, and third 10-Year Intervals. The locations of indications have been positively identified using the conventions identified above. Therefore, the marking of weld joints is not necessary.
Relief Request IP2-ISI-RR-15 Page 3 of 3
6. Duration of Proposed Alternative
Relief is requested for the Fourth Ten Year Interval (effective from March 2007 thru May 2016).
- 7.
Precedents This request is similar to the previous IP2 Third 10-Year Inspection Interval Relief No. 3 which was approved October 29, 1996 (see TAC No. M88559) and the IP3 Fourth 10 -Year Inspection Interval Relief IP3-ISI-RR-02 which was approved on June 7, 2010 (see TAC No. ME1 576).
- 8.
References None