Letter Sequence Request |
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EPID:L-2018-LLR-0025, Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-030 (Open) |
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MONTHYEARW3F1-2018-0008, Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-0302018-02-20020 February 2018 Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-030 Project stage: Request ML18080A0202018-03-20020 March 2018 NRR E-mail Capture - Waterford 3 - Acceptance Review of Relief Request W3-ISI-030 Regarding Charging Pipe Visual Inspection Project stage: Acceptance Review ML18093A4872018-04-17017 April 2018 Public Teleconference Regarding Request for Alternative to the Requirements in American Society of Mechanical Engineers Boiler and Pressure Vessel Code, Section XI, IWA-5211, for the Waterford Steam Electric Station, Unit 3 Project stage: Meeting ML18120A3112018-05-10010 May 2018 Summary of April 17, 2018, Category 1 Public Meeting with Entergy Operations, Inc., Regarding Relief Request for Visual Inspection of Charging Pipes for the Waterford Steam Electric Station, Unit 3 Project stage: Meeting W3F1-2018-0030, Supplemental Information Supporting the Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-0302018-05-31031 May 2018 Supplemental Information Supporting the Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-030 Project stage: Supplement ML18282A0302018-10-18018 October 2018 Proposed Alternative to ASME Code, Section XI, Regarding Charging Pipe Visual Inspection Project stage: Other 2018-03-20
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Category:Letter type:W
MONTHYEARW3F1-2023-0056, Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242023-12-19019 December 2023 Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0052, Core Operating Limits Report (COLR) - Cycle 26, Revision O2023-11-0707 November 2023 Core Operating Limits Report (COLR) - Cycle 26, Revision O W3F1-2023-0049, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal2023-09-28028 September 2023 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal W3F1-2023-0048, Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-09-25025 September 2023 Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0035, Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program2023-07-26026 July 2023 Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program W3F1-2023-0036, Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-05-0404 May 2023 Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0032, Annual Radioactive Effluent Release Report (ARERR) 20222023-04-27027 April 2023 Annual Radioactive Effluent Release Report (ARERR) 2022 W3F1-2023-0033, Submittal of Annual Radiological Environmental Operating Report - 20222023-04-27027 April 2023 Submittal of Annual Radiological Environmental Operating Report - 2022 W3F1-2023-0025, Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.22062023-04-11011 April 2023 Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.2206 W3F1-2023-0018, Updated Final Supplemental Response to NRC Generic Letter 2004-022023-03-30030 March 2023 Updated Final Supplemental Response to NRC Generic Letter 2004-02 W3F1-2023-0022, Registration of Dry Fuel Storage Cask Use2023-03-22022 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0021, Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days2023-03-17017 March 2023 Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0016, Registration of Dry Fuel Storage Cask Use2023-03-0303 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2023-0013, Notification of Readiness for Supplemental Inspection2023-02-15015 February 2023 Notification of Readiness for Supplemental Inspection W3F1-2023-0007, Registration of Dry Fuel Storage Cask Use2023-02-0606 February 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0010, Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days2023-01-25025 January 2023 Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0002, SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days2023-01-0505 January 2023 SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days W3F1-2022-0067, Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-022022-12-20020 December 2022 Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-02 W3F1-2022-0054, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability2022-11-0101 November 2022 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability W3F1-2022-0063, Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 372022-10-27027 October 2022 Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 37 W3F1-2022-0059, Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-5052022-10-13013 October 2022 Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-505 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2022-0049, Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-5052022-08-19019 August 2022 Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-505 W3F1-2022-0037, Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242022-08-0808 August 2022 Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2022-0044, SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-07-0606 July 2022 SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0042, SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-06-27027 June 2022 SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0015, Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf.2022-05-16016 May 2022 Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf. W3F1-2022-0026, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 20222022-04-28028 April 2022 Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022 W3F1-2022-0028, Annual Radiological Environmental Operating Report - 20212022-04-26026 April 2022 Annual Radiological Environmental Operating Report - 2021 W3F1-2022-0029, Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.22062022-04-26026 April 2022 Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.2206 W3F1-2022-0009, Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2022-04-25025 April 2022 Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors W3F1-2022-0031, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-2842022-04-25025 April 2022 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-284 W3F1-2022-0020, Review of Preliminary Accident Sequence Precursor Report2022-04-11011 April 2022 Review of Preliminary Accident Sequence Precursor Report W3F1-2022-0017, Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 20212022-04-0707 April 2022 Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 2021 W3F1-2022-0019, WAT-2022-02 Post Exam Analysis2022-03-0909 March 2022 WAT-2022-02 Post Exam Analysis W3F1-2022-0011, Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-02-0808 February 2022 Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days2022-02-0101 February 2022 SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days W3F1-2021-0074, Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-022021-12-16016 December 2021 Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-02 W3F1-2021-0064, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 2842021-11-30030 November 2021 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 284 W3F1-2021-0061, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-10-14014 October 2021 Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0063, Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery2021-10-12012 October 2021 Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery W3F1-2021-0050, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt2021-10-0101 October 2021 Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt W3F1-2021-0060, Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-09-30030 September 2021 Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0039, Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years2021-08-25025 August 2021 Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years W3F1-2021-0055, Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual2021-08-20020 August 2021 Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual W3F1-2021-0057, (Waterford 3) - Emergency Plan Revision 0522021-08-18018 August 2021 (Waterford 3) - Emergency Plan Revision 052 W3F1-2021-0054, License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 20202021-07-29029 July 2021 License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 2020 W3F1-2021-0051, Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator2021-07-19019 July 2021 Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator 2023-09-28
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Text
Entergy Operations, Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6685 jjarrel@entergy.com John P. Jarrell III Manager, Regulatory Assurance Waterford 3 10 CFR 50.55a W3F1-2018-0008 February 20, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Request for NRC Alternative to ASME IWA-5211 Regarding Charging Pipe Visual Inspection, Relief Request W3-ISI-030 Waterford Steam Electric Station, Unit 3 (Waterford 3)
Docket No. 50-382 License No. NPF-38
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph (z)(1), Entergy Operations, Inc. (Entergy) hereby requests NRC approval of the attached relief request associated with the Fourth Inservice Inspection (ISI) interval of the ISI program for Waterford 3.
Entergy is requesting to use an alternative to the requirements of the American Society of Mechanical Engineers (ASME) Code requirement to perform VT-2 visual examination method. As documented in the Attachment, this request pertains to portions of two charging lines that are enclosed in a vertical pipe chase. The Attachment provides Entergys request for relief including the basis for the proposed alternative.
Entergy proposes to perform the VT-2 visual examination during an outage with no pressure or temperature requirements. Entergy believes that the proposed alternative provides reasonable assurance that any through wall leakage occurring during the operating cycle will be found. As such, Entergy believes the proposed alternative provides an acceptable level of quality and safety.
Relief from this requirement was previously granted as W3-ISI-017 during Waterfords third 120-month Inservice Inspection Interval on the basis that the proposed alternative would provide an acceptable level of quality and safety. That approval was documented in the NRC Safety Evaluation Report dated January 13, 2011 (Reference 3).
Entergy requests approval of the proposed alternative by February 20, 2019.
This letter contains no new commitments.
W3F1-2018-0008 Page 2 If you have any questions or require additional information, please contact the Regulatory Assurance Manager, John P. Jarrell, at (504) 739-6685.
Sincerely, JPJ/MMZ
Attachment:
10 CFR 50.55a Request Number W3-ISI-030, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1) cc: Mr. Kriss Kennedy, Regional Administrator U.S. NRC, Region IV RidsRgn4MailCenter@nrc.gov U.S. NRC Project Manager for Waterford 3 April.Pulvirenti@nrc.gov U.S. NRC Senior Resident Inspector for Waterford 3 Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov
Attachment to W3F1-2018-0008 Entergy Operations, Inc.
10 CFR 50.55a Request Number W3-ISI-030 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Alternative Provides Acceptable Level of Quality and Safety (4 pages)
Attachment to W3F1-2018-0008 Page 1 of 4 Entergy Operations, Inc.
10 CFR 50.55a Request Number W3-ISI-030 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(1)
Alternative Provides Acceptable Level of Quality and Safety PLANT/UNIT: Waterford Steam Electric Station, Unit 3 (WF3)
INTERVAL: 4th Interval beginning December 1, 2017, and ending November 30, 2027 COMPONENTS Line 2CH2-60 A/B and 2CH2-53 A/B in the vertical pipe chase (periodic AFFECTED: system leakage test of piping contained in a vertical pipe chase)
Code Class: 2 Examination Category: C-H Item Numbers: C7.10 CODE EDITION ASME Section XI, 2007 Edition, 2008 Addenda, Table IWC-2500-1 ASME AND ADDENDA: Section XI, 2007 Edition, IWA-5211 REQUIREMENTS: ASME Section XI, Table IWC-2500-1, Examination Category C-H, Item Nos.
C7.10 requires the subject lines to be VT-2 visually examined during a system leakage test each inspection period. IWA-5211 requires that the visual examination be performed while the item being tested is at normal operating pressure.
REASON FOR Letdown line 2CH2-60 A/B and charging line 2CH2-53 A/B are located in a REQUEST: pipe chase (the vertical L-wall pipe chase) that is part of a Controlled Ventilation Area System (CVAS) boundary. Waterford 3 utilizes the CVAS to provide high efficiency particulate filtration and iodine adsorption in the controlled ventilation area. The system must exhaust air from the controlled ventilation area at a rate required to create and maintain a negative pressure below 0.25-inch water gage relative to the surrounding areas. CVAS is composed of two independent trains, each capable of creating and maintaining the 0.25-inch water gage negative pressure. (Further discussions of CVAS operation is provided in the Waterford 3 Updated Final Safety Analysis Report Section 6.5.1.)
Attachment to W3F1-2018-0008 Page 2 of 4 REASON FOR Waterford 3 Technical Specification (TS) 3/4.7.7 provides the OPERABILITY REQUEST: requirements for CVAS. TS Section 4.7.7.d.2 requires that each CVAS train (continued) be capable of maintaining a negative pressure of 0.25-inch water gage. In the event this condition cannot be met, TS requires the associated train to be declared INOPERABLE and restored to OPERABLE status within 7 days or the plant must be placed in HOT STANDBY within the next six hours and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. With both trains INOPERABLE, entry into TS Limiting Condition for Operation (LCO) 3.0.3 is required. LCO 3.0.3 requires the appropriate LCO to be met within one hour or the plant must be in HOT STANDBY within the next six hours, HOT SHUTDOWN with the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWN with the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Temporary access to the pipe chase is provided through special block-out sections consisting of multiple layers of solid concrete blocks. Except for the temporary access block-outs, the pipe chase is totally enclosed by reinforced concrete walls. The blocks are mortared in place. The block-out sections penetrate into the CVAS boundary. The approximate length of pipe that is inaccessible is approximately 450 feet (combined total length of pipe for both pipe lines 2CH2-60A/B and 2CH2-53A/B). The pipe pressure boundary for these lines contains approximately 105 total combined welds. Removing the block wall during normal operation (Modes 1, 2, 3, or 4) violates the CVAS boundary, placing both CVAS trains in INOPERABLE status in accordance with TS. Approximately six days are required to remove and re-install the block wall.
The use of remote camera devices to perform the subject examination has been evaluated by Waterford 3. It is not considered a reasonable approach because of TS 3/4.7.7 considerations in crossing the CVAS boundary while maintaining CVAS operable and the inability to establish VT-2 examination conditions, including proper illumination, within the pipe chase without opening large access points in the wall due to the crowding of piping and long vertical run within the pipe chase. The long run of piping subject to examination (estimated at 160 ft.) would necessitate numerous access points. No access points are currently installed.
Breaching of the vertical pipe chase would result in both trains of CVAS being declared INOPERABLE as the required negative pressure in the CVAS boundary could not be maintained. Outage time for the CVAS to perform the examination is estimated to be a minimum of 6 days which significantly exceeds the one (1) hour limiting condition of operation (LCO) allowed. This estimate is based on removing the concrete blocks to access the pipe chase, performance of the examination, restoration of the pipe chase, and performance of the necessary surveillances to demonstrate operability.
Attachment to W3F1-2018-0008 Page 3 of 4 REASON FOR As this system leakage inspection of the subject piping contained in the REQUEST: vertical pipe chase has only been performed using the alternative examination (continued) method provided by relief, no dose data exists for the normal method.
Therefore, no data for hardship justification for dose is presented.
The subject piping is inaccessible during normal operation without deliberate entry into a TS action statement requiring plant shutdown. When the pipe is accessible during plant shutdown (Modes 5 and 6), the system cannot be operated to obtain the required test conditions. Therefore, Entergy proposes the alternative described below.
PROPOSED Entergy requests authorization to perform a VT-2 visual examination of the ALTERNATIVE subject lines and the surrounding areas once each period during a refueling AND BASIS: outage with no pressure/temperature requirements. This alternative will be performed in lieu of the requirements of IWA-5211 for the subject lines inside the vertical pipe chase. This examination will be performed prior to any maintenance being performed inside the pipe chase or on the subject lines.
ASME Section XI IWA-5213(a) requires that a non-insulated component be at system operating pressure for 10 minutes and a VT-2 visual examination performed while at pressure. IWA-5241(b) allows an examination of the surrounding area (including floor areas or equipment surfaces located underneath the components) for evidence of leakage for non-insulated components that are inaccessible for direct VT-2 visual examination. IWA-5245 allows the pressure to be lowered to a level corresponding to a temperature of 200 °F after the required hold time but prior to the VT-2 visual examination for systems that operate above 200 °F.
Therefore, the code allows a non-insulated, non-borated standby system to be VT-2 examined by inspecting surfaces below the piping after being at test pressure for 10 minutes. In addition, the Code allows owners to perform this VT-2 examination after the pressure has been reduced to a pressure corresponding to a temperature of 200 °F.
Entergy believes the alternative provides an acceptable level of quality and safety based on the following:
- 1) If leakage from the subject sections of charging and letdown piping were to occur, it would show up as unidentified leakage in the reactor coolant system inventory balance. Operations personnel perform this balance at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per TS Surveillance 4.4.5.2.1 in Modes 1, 2, 3, and 4. The TS limit for unidentified leakage is 1 gpm unidentified leakage.
If the 1-gpm TS limit is exceeded, TS requires a plant shutdown if leakage is not restored below the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
Attachment to W3F1-2018-0008 Page 4 of 4 PROPOSED 2) These two non-insulated sections of piping in the vertical pipe chase do ALTERNATIVE not see leakage test conditions during Modes 5 and 6. However, they do AND BASIS: experience significant operation while at normal plant conditions during (continued) plant operation.
- 3) The subject charging and letdown lines are part of the charging and volume control system. This system is borated for the purpose of controlling reactivity. The boric acid provides a chemical marker that leaves behind a white stain when very small amounts of leakage occur.
As this leakage occurs over a period of time, this boric acid residue builds, allowing discovery of very small leaks.
- 4) These lines are pressurized during normal operations and since they are borated and non-insulated, sufficient time is available for boric acid to build up on the piping or adjacent surfaces. A subsequent VT-2 visual examination, after the block wall has been removed and prior to any maintenance activities, is adequate to discover any leakage.
The subject lines are in service for long periods of time between outages.
These periods are many factors of time larger than the Code required 10 minute hold time. These long periods of time in addition to the system being borated will provide positive indication of leakage regardless of system pressure. Entergy believes that performing the proposed alternative will provide a better indication of the condition of the lines than the minimum Code requirement and provides an acceptable level of quality and safety.
DURATION: 4th ISI Interval, December 1, 2017, through November 30, 2027 PRECEDENT: Relief from this requirement was previously granted as W3-ISI-017 during Waterfords third 120-month Inservice Inspection Interval on the basis that the proposed alternative would provide an acceptable level of quality and safety.
That approval was documented in the NRC safety evaluation report dated January 13, 2011 (Reference 3).
REFERENCES:
- 1. Waterford 3 Updated Final Safety Analysis Report
- 2. Waterford 3 Technical Specifications
- 3. Letter from the NRC (Michael T. Markley) to Vice President, Operations, Entergy Operations, Inc., Waterford Steam Electric Station, Unit 3 -
Request for NRC Alternative to ASME IWA-5211 Regarding Chemical Volume Control System Pipe Visual Inspection, (TAC No. ME3419), dated January 13, 2011 (ML103570392)