ML19172A085

NRR E-mail Capture - Waterford 3 - Final Request for Additional Information (Rais) Re Relief Request W3-ISI-032: Volumetric Examination Requirements

ML19172A085
Person / Time
Site:	Waterford
Issue date:	05/24/2019
From:	April Pulvirenti Plant Licensing Branch III
To:	Zamber M Entergy Nuclear Operations
References
L-2018-LLR-0194
Download: ML19172A085 (3)

Text

NRR-DRMAPEm Resource From: Pulvirenti, April Sent: Friday, May 24, 2019 10:13 AM To: Zamber, Maria

Subject:

Waterford 3 - Final Request for Additional Information (RAIs) RE Relief Request W3-ISI-032: Volumetric Examination Requirements (EPID L-2018-LLR-0194)

Maria, By letter dated November 30, 2018 (Agencywide Documents and Access Management System (ADAMS)

Accession No. ML18334A219), Entergy Operations, Inc., (the licensee) requested relief in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii) from the requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI. Relief request W3-ISI-032 pertains to examination coverage of the Class 1 piping welds at the Waterford Steam Electric Station (Waterford), Unit 3. Relief request W3-ISI-032 is for the third 10-year inservice inspection (ISI) interval that started on May 31, 2008, and ended on November 30, 2017.

To complete its review, the Nuclear Regulatory Commission (NRC) staff requests the following additional information. A response to this RAI is required within 45 days of the date of this email, that is, a response is required by July 8, 2019. This Request for Additional Information, along with the schedule, was discussed with Maria Zamber and others of your staff on May 23, 2019.

Thanks, April Dr. April L. Pulvirenti Project Manager, Waterford Unit 3 United States Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 301-415-1390 REQUEST FOR ADDITIONAL INFORMATION RELIEF REQUEST W3-ISI-032 REGARDING WELD EXAMINATION COVERAGE ENTERGY OPERATIONS, INC.

WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NO. 50-382 EPID: L-2018-LLR-0194 By letter dated November 30, 2018 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML18334A219), Entergy Operations, Inc., (the licensee) requested relief in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii) from the requirement of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI. Relief request W3-ISI-032 pertains to examination coverage of 1

the Class 1 piping welds at the Waterford Steam Electric Station (Waterford), Unit 3. Relief request W3-ISI-032 is for the third 10-year inservice inspection (ISI) interval that started on May 31, 2008, and ended on November 30, 2017.

To complete its review, the NRC staff requests the following additional information.

1. Pursuant to 10 CFR 50.55a(g)(6)(ii)(F), during the licensees third 10-year ISI interval, the NRC mandated augmented inspections for ASME Code,Section XI, Class 1 piping and nozzle dissimilar-metal (DM) butt welds in accordance with ASME Code Case N-770-1 Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities,Section XI, Division 1 subject to the conditions specified in paragraphs (g)(6)(ii)(F)(2) through (g)(6)(ii)(F)(10) of 50.55a, by the first refueling outage starting after August 22, 2011.

a. Provide the date the licensee completed the required baseline examinations of the DM welds with ID No.08-009 and 14-006 in accordance with 10 CFR 50.55a(g)(6)(ii)(F)(3).

b. Did the licensee achieve essentially 100 percent coverage of the required examination volume during the baseline examinations of the subject DM welds, as is mandated by paragraphs (g)(6)(ii)(F)(3) and (g)(6)(ii)(F)(4) of 10 CFR 50.55a? If not, explain.

c. Did the licensee have relief granted by the NRC under impracticality in accordance with 10 CFR 50.55a(g)(6)(i) from the essentially 100 percent examination coverage for the subject DM welds prior to the implementation of 10 CFR 50.55a(g)(6)(ii)(F)?

d. Please justify requesting relief for the DM welds with ID No.08-009 and 14-006, based on the responses to the above questions (i.e., 1.a., 1.b., and 1.c.) and an assessment of compliance with the 10 CFR 50.55a(g)(6)(ii)(F) requirements (e.g., baseline examination deadline, essentially 100 percent coverage, and/or else).

e. Discuss the locations (e.g., base metal, butter, weld metal) of the two indications detected in the DM weld with ID No.08-009. Were the indications surface connected? Since the flaw characterization table on page 43 of 79 is difficult to read, please provide a readable copy.

2. To which piping system (e.g., reactor coolant system, residual heat removal, safety injection) does each piping weld listed in the table in Attachment 1 to W3-ISI-032 belong?

3. Provide the operating temperature and pressure for each piping weld listed in W3-ISI-032 (i.e., Examination Category R-A).

4. Provide a summary of any additional piping welds that achieved required examination coverage, that were composed of same material and exposed to similar environment as the subject welds of this relief request, and that were examined in the third 10-year ISI interval.

5. Given the limited coverage achieved for the subject piping welds (i.e., ranging from 50 percent to 87.82 percent), provide a summary of the evaluation for accepting the proposed limited coverages required by Note 3 of Table 1 in ASME Code Case N-716 Alternative Classification and Examination Requirements,Section XI.

6. The NRC staff notes that the relief is also requested from the preservice inspection (PSI) coverage for some welds with Examination Category R-A. (a) Please identify those welds. (b) Was the repair/replacement due to degradation of the welds? Explain the reasons for repair/replacements activities associated with these welds.

2

Hearing Identifier: NRR_DRMA Email Number: 63 Mail Envelope Properties (BN7PR09MB28491E118BA6FC9F04A86FE38F020)

Subject:

Waterford 3 - Final Request for Additional Information (RAIs) RE Relief Request W3-ISI-032: Volumetric Examination Requirements (EPID L-2018-LLR-0194)

Sent Date: 5/24/2019 10:12:34 AM Received Date: 5/24/2019 10:12:00 AM From: Pulvirenti, April Created By: April.Pulvirenti@nrc.gov Recipients:

"Zamber, Maria" <mzamber@entergy.com>

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