CNRO-2016-00023, Request EN-ISI-16-1: Use of Later Edition/Addenda of Amse Section XI Code for ISI Related Activities
| ML16337A368 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Arkansas Nuclear  |
| Issue date: | 12/01/2016 |
| From: | Ford B Entergy Nuclear Operations, Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNRO-2016-00023, EN-ISI-16-1 | |
| Download: ML16337A368 (11) | |
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Entergy Entergy Operations, Inc.
Entergy Nuclear Operations, Inc.
P. 0. Box 31995 Jackson, Mississippi 39286-1995 CNR0-2016-00023 December 1, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Bryan S. Ford Sr. Manager, Regulatory Assurance (601) 368-5516 bford@entergy.com
SUBJECT:
Request EN-ISI-16-1 : Use of Later Edition/Addenda of ASME Section XI Code for lSI Related Activities
Dear Sir or Madam:
Arkansas Nuclear One, Unit 2 (AN0-2)
Docket No. 50-368 License No. NPF-6 Indian Point Nuclear Generating Station, Unit 3 (IP-3)
Docket No. 50-286 License No. DPR-64 Pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy Operations, Inc. and Entergy Nuclear Operations, Inc. (hereafter referred to collectively as "Entergy") request NRC permission to use the 2007 Edition/2008 Addenda of American Society of Mechanical Engineers (ASME)
Section XI for the performance of lnservice Inspection (lSI) related activities associated with Entergy's repair/replacement (R&R), pressure testing (PT), and nondestructive examination (NDE) programs during the Fourth 10-Year lSI Intervals for AN0-2 and IP-3. The NRC has approved these later editions and addenda of the ASME Section XI Code as documented in 10 CFR 50.55a(1)(ii).
Entergy has developed standardized R&R, PT. and NDE programs that are based on a common Edition/Addenda of ASME Section XI. Entergy is seeking approval of Request EN-ISI-16-1 so that it can maintain standardized R&R, PT, and NDE programs across its nuclear fleet. This request uses the guidance provided in NRC Regulatory Issue Summary 2004-16, Use of Later Editions and Addenda to ASME Code Section XI for Repair/Replacement Activities.
Entergy requests approval of Request EN-ISI-16-1 on or before November 30, 2017. If you have any questions, please contact Mr. Anders Eng at (914) 272-3523.
This letter contains no commitments.
CNR0-2016-00023 Page 2 of 2 Very truly yours,
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BSF/ghd/aye Attachments: Request EN-ISI-16-1 cc: C. Bakken (ECH)
J. Ventosa 0NPO)
D. Jacobs (ECH)
M. Woodby (ECH)
R. Anderson (ANO)
A. Vitale (IPEC)
J. Davis (ECH)
G. H. Davant (ECH)
J.W. Weicks (ECH)
All above w/o attachments NRC Region I Administrator NRC Region IV Administrator NRC Project Manager (ANO)
NRC Project Manager (IP-3)
NRC Senior Resident Inspector (ANO)
NRC Senior Resident Inspector (IP-3)
ATIACHMENT CNR0-2016-00023 REQUEST EN-151-16-1 REQUEST IN ACCORDANCE WITH 10 CFR 50.55a(g)(4)(iv)
FOR USE OF LATER ASME SECTION XI CODE EDITION AND ADDENDA
Attachment to CNR0-2016-00023 Page 1 of 4 REQUEST EN-ISI-16-1
- 1. American Society of Mechanical Engineers (ASME) Code Component(s) Affected All Class 1, 2, 3, MC, and CC components, component supports, and welds located in the ASME Section XI boundaries at Arkansas Nuclear One, Unit 2 (AN0-2) and Indian Point, Unit 3 (IP-3).
2. Applicable Code Edition and Addenda
AN0-2 and IP-3 are in their fourth (4th) lnservice Inspection (lSI) Intervals and perform lSI activities in accordance with 2001 Edition/2003 Addenda as shown in the table below. The lSI interval end dates for both nuclear plants are also provided in the table.
Plant lSI ASME Section XI Interval Interval Interval Edition/Addenda Start End1 AN0-2 4
2001 Edition/2003 Addenda 3/26/10 3/25/20 IP-3 4
2001 Edition/2003 Addenda 7/21/09 7/20/19 Notes
- 1.
These are the presently scheduled lSI interval end dates for AN0-2 and IP-3. However, adjustments to these dates could be made as allowed by IWA-2430 of ASME Section XI.
- 3. Proposed Subsequent Code Edition and Addenda (or Portion)
A. Background All Entergy plants, including AN0-2 and IP-3, perform lSI-related activities such as repair/replacements (R&R), pressure testing (PT), and nondestructive examination (NDE) in accordance with standardized fleet programs. These standardized programs are based on a common Edition/Addenda of ASME Section XI which, at present, is the 2001 Edition/ 2003 Addenda. While lSI Program Plans are controlled in site-specific documents, the R&R, PT, and NDE programs are controlled in common corporate program procedures that are implemented across the entire nuclear fleet.
On December 1, 2017, Entergy plans to update its Code of Record for the R&R, PT, and NDE programs from the 2001 Edition/2003 Addenda to the 2007 Edition/2008 Addenda.
However, as shown in Section 2, the lSI intervals for AN0-2 and IP-3 are not presently scheduled to end until March 25, 2020 and July 20, 2019, respectively. If AN0-2 and IP-3 continue performing R&R, PT, and NDE activities in accordance with their current Codes of Record after Entergy implements its update on December 1, 2017, then Entergy will be required to maintain two separate R&R, PT, and NDE programs: one set of programs for AN0-2 and IP-3 and another set of programs for the balance of the Entergy nuclear fleet. Furthermore, ANO and IP personnel will have to implement two versions of each of these programs at their sites.
Attachment to CNR0-2016-00023 Page 2 of4 B. Proposed Subsequent Code Edition and Addenda Pursuant to 10 CFR 50.55a(g)(4)(iv), Entergy requests permission to utilize the 2007 Edition/2008 Addenda of ASME Section XI at AN0-2 and IP-3 for performing lSI-related activities such as R&R, PT, and NDE. In implementing this proposal, Entergy will also comply with all applicable NRC conditions and limitations specified in 10 CFR 50.55a(b) including those specified below. See Enclosure 1 for specific details regarding this proposal.
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).
It is important to note that this request does not apply to the selection, planning, or scheduling of lSI examinations and tests as defined in IWB-, IWC-, IWD-, IWE-, IWF-,
and IWL-2500 or NRC approved lSI alternatives. Therefore, lSI examinations and tests at AN0-2 and IP-3 will continue to be selected, planned, and scheduled in accordance with their present Code of Record as described in Section 2, above. See Enclosure 1 for specific details regarding this proposal.
C. Managing Use of Dual Code Editions and Addenda Entergy has process controls in place to track and monitor the implementation of the dual Code Editions/Addenda of ASME Section XI. These process controls are summarized below.
Site-specific lnservice Inspection Plans: These documents implement the ASME Section Xllnservice inspection programs at AN0-2 and IP-3. They ensure the selection, planning and scheduling of lSI examinations and tests are performed in accordance with 2001 Edition/2003 Addenda of ASME Section XI as delineated in.
Administrative and Program Procedures: These procedures establish requirements for implementing the ASME Section XI NDE, PT, and R&R programs.
These procedures also ensure program requirements comply with applicable requirements in the 2007 Edition/2008 Addenda of ASME Section XI as described in.
Therefore, Entergy believes its existing processes will ensure the use of dual Code Editions/Addenda at AN0-2 and IP-3 are appropriately managed, tracked, and controlled.
Attachment to CNR0-2016-00023 Page 3 of 4
- 4. Related Requirements Entergy is requesting permission to use the 2007 Edition/2008 Addenda of ASME Section XI for performing lSI-related activities such as R&R, PT, and NDE except where otherwise conditioned by the NRC in 10 CFR 50.55a. See Section 3.8, above. In making this request, Entergy will comply with all related requirements in ASME Section XI as described below and delineated in Enclosure 1:
Entergy has proposed to utilize aii"Articles" (e.g. IWA-4000, IWA-5000) from every "Subsection" (e.g. IWA, IWB, etc.) of the 2007 Edition/2008 Addenda that could be used or referenced for the performance of R&R, PT, and NDE activities.
Entergy has proposed to utilize aii"Mandatory Appendices" of the 2007 Edition/2008 Addenda. Mandatory appendices provide supplemental requirements to specific code articles (or paragraphs) in ASME Section XI. It should be noted that the reason Entergy has chosen to use the 2007 Edition/2008 Addenda for all Mandatory Appendices is that these Mandatory Appendices provide supplemental requirements to ASME Code articles and paragraphs that are also being used from the 2007 Edition/2008 Addenda.
Entergy has proposed to utilize the 2007 Edition/2008 Addenda for Nonmandatory Appendices A through Q. The methodology for using Nonmandatory Appendices from the 2007 Edition/2008 Addenda is as described above for Mandatory Appendices.
With regard to the performance of lSI examinations and tests, Entergy will continue to select, plan, and schedule these lSI inspection activities, as specified in IWA-, IWB-,
IWC-, IWD-, IWE-, and IWF-2500 or NRC approved lSI alternatives, in accordance with the AN0-2 and IP-3 current lSI Program Plans.
- 5. Duration of Proposed Request AN0-2 and IP-3 are presently in their fourth 10-Year lSI intervals as shown in Section 2.
The duration of this request will be from December 1, 2017 until the end of the fourth lSI interval of AN0-2 and IP-3.
6. Precedents
A. This request is similar to the following requests which were submitted in accordance with 10 CFR 50.55a(g)(4)(iv), approved by the NRC, and allowed Entergy nuclear plants to use a later Edition/Addenda of ASME Section XI for performing lSI related activities such as NDE, PT, R&R while the lSI Code of Record for these plants was an earlier Edition/Addenda:
"Arkansas Nuclear One, Unit 2-ISI-2007-1, Request to Use a Later Edition and Addenda of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (TAG NO. MD6603)," dated December 20, 2007 [ADAMS Accession No. ML073390442]
Attachment to CNR0-2016-00023 Page 4 of4 "Relief Request ISI-2008-1, Use of Later Edition and Addenda of ASME Code,Section XI for Repair and Replacement, Pressure Testing, and Nondestructive Testing Activities -Vermont Yankee Nuclear Power Station (TAC NO. ME0239),"
dated April30, 2009 [ADAMS Accession No. ML091170111]
"Relief Request ISI-2008-1, Use of Later Edition and Addenda of ASME Code,Section XI for Repair and Replacement, Pressure Testing, and Nondestructive Testing Activities-Pilgrim Nuclear Power Station (TAC NO. ME0238)," dated April 30, 2009 [ADAMS Accession No. ML091130456]
B. This request is similar to the following relief requests which were submitted in accordance with 10 CFR 50.55a(z}(1) [formerly 10 CFR 50.55a(a)(3)(i)], approved by the NRC, and allowed Entergy nuclear plants to use an earlier Edition/Addenda of ASME Section XI for performing lSI related activities such as NDE, PT, R&R while the lSI Code of Record for these plants was a later Edition/Addenda:
"Vermont Yankee Nuclear Power Station-Relief Request ISI-05: Fifth 10-Year lnservice Inspection (lSI) Interval-Maintaining Certain lSI Related Activities on Current 2001 Edition Through 2003 Addenda of ASME Code Section XI (TAC NO.
MF1194)," dated April 22, 2013 [ADAMS Accession No. ML13228A197]
"Pilgrim Nuclear Power Station Re: Request for Alternative (PRR)-26, Fifth 10-Year lnservice Inspection Interval (TAC NO. ME5432)," dated June 19, 2015 [ADAMS Accession No. ML15166A401]
"Palisades Nuclear Plant-Relief Request Number 5-1, Proposed Alternative, Extend the Current ASME Code of Record into the Fifth 10-Year lSI Interval for lSI Related Activities (CAC NO. MF6162}," dated November 25, 2015 [ADAMS Accession No. ML15320A244]
"Indian Point Nuclear Generating Station, Unit No. 2-Relief from the Requirements of the ASME Code (CAC NO.MF6319)," dated March 3, 2016 [ADAMS Accession No. ML16053A025]
CNR0-2016-00023 REQUEST EN-ISI-16-1 ENCLOSURE 1 PROPOSED ASME SECTION XI CODES OF RECORD FOR AN0-2 AND IP-3 to CNR0-2016-00023 Page 1 of 3 Proposed ASME Section XI Code of Record for AN0-2 and IP-3 Code Provision ASME Section XI Edition/Addenda 1 Sub-section Article 2001 Edition/2003 Addenda 2007 Edition/2008 Addenda IWA-1000 X
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(1) Entergy will comply with all NRC conditions, limitations, and restrictions specified in 10 CFR 50.55a as they apply to the specific edition and addenda referenced.
(2) Entergy is proposing to use IWA-2100, 2200, and 2300 from the 2007 Edition/2008 Addenda for requirements applicable to authorized inspection, examination methods, and qualification of NDE personnel. However, Entergy will use the 2001 Edition/2003 Addenda when using IWA-2400, 2500, and 2600 for the selection, planning and scheduling of lSI examinations and tests.
(3) As exceptions to IWA-4000 of the 2007 Edition/2008 Addenda, Entergy will utilize the Editions/Addenda specified below to comply with NRC conditions in 10 CFR.50.55a:
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) The selection, planning, and scheduling of lSI examinations and tests will comply with these ASME Section XI articles (e.g. IWB-1000 and 2000) from the 2001 Edition/2003 Addenda or applicable NRC approved alternatives specified in the Entergy lSI Program Plans.
(5) As stipulated in IWB-3514 of the 2007 Edition/2008 Addenda, Entergy will not apply the IWB-3514 acceptance standards to planar surface flaws in UNS N06600, N06082, or W86182 materials which are located in a Pressurized Water Reactor (PWR) environment and subject to stress corrosion cracking. Therefore, if a planar flaw is found in these nickel alloy materials, Entergy will either evaluate the acceptability of the flaw in accordance with IWB-3600 or correct the flawed condition by performing an approved ASME Section XI repair/
replacement activity. AN0-2 and IP-3 are both PWRs.
2 of 3 to CNR0-2016-00023 Page 3 of 3 (6) As allowed by 10 CFR 50.55a(b)(3)(v)(A), snubber preservice and inservice examination and testing will be performed in accordance with Subsection ISTD of the ASME Operation and Maintenance (OM) Code using an Edition/Addenda approved by the NRC in 1 0 CFR 50.55a(a)(1)(iv). In addition, preservice and inservice examination of snubbers will be performed using the VT-3 visual examination method described in IWA-2213.
(7) Article IWF-5000 was deleted from Subsection IWF in the 2006 Addenda. Therefore, it does not exist in the 2007 Edition/2008 Addenda.
(8) As an exception, Entergy will comply with the NRC condition in 10 CFR 50.55a(g)(6)(ii)(D)(4).
At present, this condition requires that ultrasonic examinations performed in accordance with Code Case N-729-1 comply with the 2004 Edition/No Addenda of Appendix VIII.
(9) Nonmandatory Appendices F and I do not exist in either the 2001 Edition/2003 Addenda or the 2007 Edition/2008 Addenda of ASME Section XI.
(10)Nonmandatory Appendix R was added into ASME Section XI in the 2004 Edition/2005 Addenda. Therefore, this appendix is in the 2007 Edition/2008 Addenda but does not exist in the 2001 Edition/2003 Addenda. Referenced in IWB-2500(c) and IWC-2500(c),
Nonmandatory Appendix R provides alternative risk-informed inspection requirements for piping welds located in the ASME Section XI boundary. Because Entergy intends to use the 2001 Edition/2003 Addenda of IWB-2000, IWC-2000, and IWD-2000, this nonmandatory appendix will not be used since it is not part of 2001 Edition/2003 Addenda.
(11)The system leakage tests required for Class 1 pressure retaining components in Table IWB-2500-1, Examination Category B-P, will comply with the boundary requirements of IWB-5222 of the 2007 Edition/2008 Addenda as follows:
The boundary of the system leakage test performed each refueling outage prior to plant start-up shall comply with lWB-5222(a)
The boundary of the system leakage test performed at or near the end of the inspection interval shall comply with IWB-5222(b) 3 of 3