ML13149A265

Email from R. Guzman to P. Couture - Request for Additional Information Relief Request ISI-05 (TAC No. MF1194) -Updated RAI-2 (Revision 2)

ML13149A265
Person / Time
Site:	Vermont Yankee
Issue date:	05/28/2013
From:	Richard Guzman Plant Licensing Branch 1
To:	Couture P Entergy Nuclear Vermont Yankee
Guzman R
References
TAC MF1194
Download: ML13149A265 (5)

Text

From: Guzman, Richard Sent: Tuesday, May 28, 2013 2:42 PM To: 'Couture III, Philip' Cc: 'Wanczyk, Robert J'

Subject:

RE: Vermont Yankee - Request for Additional Information Re: RELIEF REQUEST ISI-05 (TAC No. MF1194) - UPDATED RAI-2

Phil, Below is revision 2 of RAI-2, revision 2, which was updated following the additional clarification I obtained from Bob Wanczyk. This version supersedes RAI-2 (rev. 1) from my previous 5/22/13 message. I understand you are targeting June 13, 2013, to provide your formal response to these RAI questions.

Thanks, Rich Guzman Sr. Project Manager NRR/DORL US NRC 301-415-1030 Richard.Guzman@nrc.gov

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RAI-2 (Rev.2)

When two sets of ASME Code editions are available for use, the NRC is concerned that the less conservative Code requirements may be applied which may reduce the safety margin of the structures, systems and components at the plant. For example, IWB-3514 of the 2007 edition states that The acceptance standards of IWB-3514 do not apply to planar surface flaws in UNS N06600, N06082, or W86182 in BWR or PWR environment or austenitic stainless steels and associated welds in BWR environments, which are subject to stress corrosion cracking IWB-3514 of the 2001 edition through the 2003 addenda does not have this limitation.

If a flaw is detected in an austenitic stainless steel ASME Class 1 pipe, under the proposed alternative, the flaw may be able to remain in service using the acceptance standards in the 2001 edition through the 2003 addenda. However, under the 2007 edition through the 2008 addenda, the flaw will need to be analyzed which may result in a shorter inspection interval for the degraded pipe, or the flaw may not be able to remain in service because the acceptance standards of IWB-3514 cannot be used to disposition the flaw. In this case, the 2001 edition through the 2003 addenda requirement is less stringent and less conservative than the 2007 edition through the 2008 addenda requirement.

In light of limitations in the flaw acceptance standards in the 2007 edition through the 2008 addenda, discuss how a flaw in an austenitic stainless steel ASME Class 1 pipe will be dispositioned under the 2001 edition through the 2003 addenda of the ASME Code,Section XI.

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From: Guzman, Richard Sent: Wednesday, May 22, 2013 12:58 PM To: 'Couture III, Philip' Cc: Wanczyk, Robert J

Subject:

RE: Vermont Yankee - Request for Additional Information Re: RELIEF REQUEST ISI-05 (TAC No. MF1194) - UPDATED RAI-2

Phil, Below is the revised RAI-2 which was updated based on our clarification call today. This version supersedes RAI-2 in my original 4/29/13 e-mail. I understand you are targeting June 13, 2013, to provide your formal response to these RAI questions. Please let me know if you need any additional clarifications.

Thanks, Rich Guzman Sr. Project Manager NRR/DORL US NRC 301-415-1030 Richard.Guzman@nrc.gov

==============================================

RAI-2 (Rev.1)

When two sets of ASME Code editions are available for use, the NRC is concerned that the less conservative Code requirements may be applied which may reduce the safety margin of the structures, systems and components at the plant. For example, IWB-3514 of the 2007 edition states that The acceptance standards of IWB-3514 do not apply to planar surface flaws in UNS N06600, N06082, or W86182 in BWR or PWR environment or austenitic stainless steels and associated welds in BWR environments, which are subject to stress corrosion cracking IWB-3514 of the 2001 edition through the 2003 addenda does not have this limitation.

If a flaw is detected in an austenitic stainless steel ASME Class 1 pipe, under the proposed alternative, the flaw may be able to remain in service using the acceptance standards in the 2001 edition through the 2003 addenda. However, under the 2007 edition through the 2008 addenda, the flaw will need to be analyzed which may result in a shorter inspection interval for the degraded pipe, or the flaw may not be able to remain in service because the acceptance standards of IWB-3514 cannot be used to disposition the flaw. In this case, the 2001 edition

through the 2003 addenda requirement is less stringent and less conservative than the 2007 edition through the 2008 addenda requirement.

For the technical changes in the 2007 editions through the 2008 addenda that reflect the requirements of the 2001 edition through the 2003 addenda being less conservative or less stringent than the corresponding requirements in the 2007 edition through the 2008 addenda, discuss technical changes between the two sets of the ASME Code,Section XI, that may significantly affect the plant operation or safety and provide justification.

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From: Guzman, Richard Sent: Monday, April 29, 2013 10:41 AM To: 'Couture III, Philip'

Subject:

Vermont Yankee - Request for Additional Information Re: RELIEF REQUEST ISI-05 (TAC No.

MF1194)

Phil, The NRC staff has reviewed the information provided in the subject relief request letter dated March 27, 2013 (Agencywide Documents Access and Management System Accession No. ML13092A204), and has determined that additional information is needed to complete its review. Shown below is the NRC staffs request for additional information (RAI) questions. To support the timely review and licensees request date for approval of this application, we request that you provide a formal response by May 31, 2013. Please contact me if you have any questions.

Thanks, Rich Guzman Sr. Project Manager NRR/DORL/LPL1-1 US NRC 301-415-1030 REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST ISI-05 USE OF ALTERNATIVE EDITION AND ADDENDA OF THE ASME CODE VERMONT YANKEE NUCLEAR POWER STATION ENTERGY NUCLEAR OPERATIONS, INC DOCKET NO. 50-271

By letter dated March 27, 2013 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML13092A204), Entergy Nuclear Operations (the licensee) submitted the fifth ten-year inservice inspection (ISI) program for the Vermont Yankee Nuclear Power Station. Included in the submittal is Relief Request ISI-05 which is related to the proposed alternative to use the current 2001 edition through the 2003 addenda in lieu of using the 2007 edition through the 2008 addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) for certain ISI activities such as the performance of repair/replacement, pressure testing and nondestructive examination for a limited duration (from 2013 to 2017). To complete its review, the Nuclear Regulatory Commission (NRC) staff requests the following additional information.

1. Section 5 of the proposed relief request states that the duration for the proposed relief request is from September 31, 2013 through December 31, 2017 and that the licensee will request NRC approval for the Entergy fleet ISI related activities to be updated to the most current ASME Code prior to December 31, 2017. (1) September has 30 days, not 31 days.

Please revise the date in the relief request and other parts of the March 27, 2013 submittal. (2)

The March 27, 2013, submittal states that the fifth 10-year ISI interval starts on September 1, 2013. Discuss why the proposed relief request is effective from September 31 [30?], 2013 instead of September 1, 2013. (3) Discuss why December 31, 2017 was selected as the end date for the proposed relief request. (4) Discuss whether the most current ASME Code as stated above would be the 2007 edition through the 2008 addenda or the edition and addenda of the ASME Code incorporated by reference in the 10 CFR 50.55a at the time of submitting the update. (4) Identify and provide the approximate date of the refueling outages in which the ISI activities will be based on the 2001 edition through the 2003 addenda in lieu of the 2007 edition through the 2008 addenda.

2. When two sets of ASME Code editions are available for use, the NRC is concerned that the less conservative Code requirements may be applied which may reduce the safety margin of the structures, systems and components at the plant. For example, IWB-3514 of the 2007 edition states that The acceptance standards of IWB-3514 do not apply to planar surface flaws in UNS N06600, N06082, or W86182 in BWR or PWR environment or austenitic stainless steels and associated welds in BWR environments, which are subject to stress corrosion cracking IWB-3514 of the 2001 edition through the 2003 addenda does not have this limitation.

If a flaw is detected in an austenitic stainless steel ASME Class 1 pipe, under the proposed alternative, the flaw may be able to remain in service using the acceptance standards in the 2001 edition through the 2003 addenda. However, under the 2007 edition through the 2008 addenda, the flaw will need to be analyzed which may result in a shorter inspection interval for the degraded pipe, or the flaw may not be able to remain in service because the acceptance standards of IWB-3514 cannot be used to disposition the flaw. In this case, the 2001 edition through the 2003 addenda requirement is less stringent and less conservative than the 2007 edition through the 2008 addenda requirement. The NRC staff finds that the licensee may need to use the more conservative requirements of the 2007 edition through the 2008 addenda of the Code.

The licensee is required to adopt the 2007 edition through the 2008 addenda of the Code for the fifth 10-year ISI interval but choose to delay the adoption. Therefore, during the period of delay, in a new 10-year ISI interval, the licensee should be required to use the more conservative requirements of the two Code editions (and addenda).

On the other hand, if the 2007 edition through the 2008 addenda requirements for the ISI activities are less conservative and less stringent than the 2001 edition through the 2003 addenda requirements, the licensee would follow the conservative 2001 edition through the 2003 addenda and may not use the less conservative 2007 edition through the 2008 addenda.

The purpose is to ensure the safety margins of the structure, systems, and components are being maintained. to the relief request includes a table that identifies the list of subarticles in the 2001 edition through 2003 addenda and the 2007 edition through the 2008 addenda of the ASME Code,Section XI that will be used during the duration of the relief request. (1) Identify the technical changes (not the editorial changes) in the subarticles between the 2001 edition through the 2003 addenda and the 2007 edition through the 2008 addenda. (2) For the technical changes in the 2007 editions through the 2008 addenda that reflect the requirements of the 2001 edition through the 2003 addenda being less conservative or less stringent than the corresponding requirements in the 2007 edition through the 2008 addenda, discuss which Code edition and addenda will be used for the ISI activities and provide justification.

3. Discuss how the dual ASME Code edition and addenda for the ISI program is tracked and monitored in terms of the plant documents such as Technical Specifications, Updated Final Safety Analysis, administrative controls, and plant procedures.

4. Discuss which edition and addenda of the ASME Code,Section XI, will the non-mandatory appendices be used from September 1, 2013 to December 31, 2017 and provide justification.