ML16313A012

NRR E-mail Capture - Verbal Authorization for Indian Point 3 IP3-ISI-RR-10

ML16313A012
Person / Time
Site:	Indian Point
Issue date:	11/07/2016
From:	Pickett D Plant Licensing Branch 1
To:	Prussman S Entergy Nuclear Operations
References
MF8792
Download: ML16313A012 (4)

Text

NRR-PMDAPEm Resource From: Pickett, Douglas Sent: Monday, November 07, 2016 4:25 PM To: Prussman, Stephen G (SPrussm@entergy.com)

Cc: Alley, David; Tsao, John; Cumblidge, Stephen; Dipaolo, Eugene; Haagensen, Brian; Newman, Garrett; Rich, Sarah

Subject:

Verbal Authorization for Indian Point 3 IP3-ISI-RR-10 Attachments: Indian Point Verbal Authorization IP3-ISI-RR-10.docx Mr. Prussman:

In accordance with NRR Office Instruction LIC-102, Relief Request Reviews, the NRR staff has provided verbal authorization for Indian Point Unit 3 relief request IP3-ISI-RR-10 as described in your letter to the NRC dated November 7, 2016.

The script read this afternoon that provides verbal authorization is attached. The staff intends to follow-up this verbal authorization with a written safety evaluation within approximately 150 days.

Please let me know if you have any questions. A copy of this email and attached verbal authorization will become publicly available in ADAMS.

Douglas V. Pickett, Senior Project Manager Indian Point Nuclear Generating Unit Nos. 2 & 3 Douglas.Pickett@nrc.gov 301-415-1364 1

Hearing Identifier: NRR_PMDA Email Number: 3150 Mail Envelope Properties (Douglas.Pickett@nrc.gov20161107162400)

Subject:

Verbal Authorization for Indian Point 3 IP3-ISI-RR-10 Sent Date: 11/7/2016 4:24:56 PM Received Date: 11/7/2016 4:24:00 PM From: Pickett, Douglas Created By: Douglas.Pickett@nrc.gov Recipients:

"Alley, David" <David.Alley@nrc.gov>

Tracking Status: None "Tsao, John" <John.Tsao@nrc.gov>

Tracking Status: None "Cumblidge, Stephen" <Stephen.Cumblidge@nrc.gov>

Tracking Status: None "Dipaolo, Eugene" <Eugene.DiPaolo@nrc.gov>

Tracking Status: None "Haagensen, Brian" <Brian.Haagensen@nrc.gov>

Tracking Status: None "Newman, Garrett" <Garrett.Newman@nrc.gov>

Tracking Status: None "Rich, Sarah" <Sarah.Rich@nrc.gov>

Tracking Status: None "Prussman, Stephen G (SPrussm@entergy.com)" <SPrussm@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 782 11/7/2016 4:24:00 PM Indian Point Verbal Authorization IP3-ISI-RR-10.docx 23971 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

1 VERBAL AUTHORIZATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR RELIEF REQUEST IP3-ISI-RR-10 ALTERNATE REPAIR OF SERVICE WATER SYSTEM PIPING INDIAN POINT UNIT NUMBER 3 ENTERGY NUCLEAR OPERATIONS INC DOCKET NUMBER 50-286 Technical Evaluation read by David Alley, Chief of the Component Performance, Non-Destructive Examination, and Testing Branch, Office of Nuclear Reactor Regulation By letter dated November 7, 2016, Entergy Nuclear Operations Inc. (the licensee) submitted Relief Request IP3-ISI-RR-10 for the alternate repair of a leaking 3-inch return piping of service water system associated with Number 31 fan cooling unit at Indian Point Unit Number 3. The licensee submitted this request in accordance with the requirements of 10 CFR 50.55a(z)(2) on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The licensee proposed to use American Society of Mechanical Engineers (ASME) Code Case N-513-3, meeting all the requirements of the Code Case and the Regulatory Guide 1.147 condition on the Code Case except for the requirement to inspect the full pipe circumference at the flaw location. As an alternative, the licensee proposed to inspect only the accessible locations on the pipe circumference.

The NRC staff finds that (1) the license has demonstrated, by analysis, that the existing flaw size will not likely exceed the allowable flaw size during the effective period of the proposed relief request, (2) the licensee will periodically examine the degraded area of the affected pipe in accordance with Code Case N-513-3, (3) the licensee has performed the extent of condition inspections, (4) the licensee will follow the technical specification service water system leakage limits beyond which the licensee is required to take corrective actions, and (5) the licensees hardship justification is acceptable because performing an ASME Code repair would elevate the plant risk without increasing the plant safety.

The NRC staff determined that the licensee's flaw evaluation has demonstrated the structural integrity of the subject piping and that the existing flaw will not likely grow to exceed the allowable flaw size within the effective period of the relief request.

Authorization read by Douglas Pickett, Acting Chief of the Plant Licensing Branch I-1, Office of Nuclear Reactor Regulation As Acting Chief of the Plant Licensing Branch I-1, Office of Nuclear Reactor Regulation, I concur with the Component Performance, Non-Destructive Examination, and Testing Branchs determinations.

The NRC staff concludes that the proposed alternative provides reasonable assurance of structural integrity of the subject piping and that complying with the ASME Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the

2 licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, as of November 7, 2016, the NRC staff authorizes the use of Relief Request IP3-ISI-RR-10 for the remainder of the fourth ten year interval until the 3R19 refueling outage, which is scheduled for March 2017, or the flaw size exceeds the acceptance criteria at Indian Point Unit No. 3.

All other requirements of ASME Code,Section XI, for which relief was not specifically requested and authorized by the NRC staff, remain applicable, including the third party review by the Authorized Nuclear In-service Inspector.

This verbal authorization does not preclude the NRC staff from asking additional clarification questions regarding Relief Request IP3-ISI-RR-10, while preparing the subsequent written safety evaluation.