ML20035C492
| ML20035C492 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/05/1993 |
| From: | Wigginton D Office of Nuclear Reactor Regulation |
| To: | Barkhurst R ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M84584, NUDOCS 9304080033 | |
| Download: ML20035C492 (6) | |
Text
_ __.
D'ocket No. 50-382 April 5, 1993 Mr..Ross P. Barkhurst Vice President Operations Entergy Operations, Inc.
Post Office Box B Killona, Louisiana 70066
Dear Mr. Barkhurst:
REQUEST FOR ADDITIONAL INFORMATION (RAI) - WATERFORD STEAM ELECTRIC
SUBJECT:
STATION, UNIT 3, FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN, REVISION 5 (TAC NO. M84584)
The Office of Nuclear Reactor Regulation (NRR), with assistance from its contractor, Idaho National Engineering Laboratory (INEL), is reviewing and evaluating the First 10-Year Interval Inservice Inspection Program Plan and requests for relief from the requirements of Section XI of the ASME Boiler and To Pressure Vessel Code for Waterford Steam Electric Station, Unit 3.
complete its review, the staff requires additional information from Entergy Operations, Inc. To meet the review schedule, the staff requests a response within 60 days.
In addition, to expedite the review process, please send a copy of your Mr. Boyd W. Brown, EG&G Idaho, response to INEL at the following address:
Inc., INEL Research Center, 2151 North Boulevard, P.O. Box 1625, Idaho Falls, Idaho 83415-2209.
This If you have any questions on this request, please let us know.
requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under Public Law 96-511.
Sincerely, ORIGINAL SIGNED BY:
David L. Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
RAI cc w/ enclosure:
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April 5, 1993 Docket No. 50-382 Mr. Ross P. Barkhurst Vice President Operations Entergy Operations, Inc.
Post Office Sox B Killona, Louisiana 70006
Dear Mr. Barkhurst:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) - WATERFORD STEAM ELECTRIC STATION, UNIT 3, FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN, REVISION 5 (TAC N0. M84584)
The Office of Nuclear Reactor Regulation (NRR), with assistance' from its contractor, Idaho National Engineering Laboratory (INEL), is reviewing and evaluating the First 10-Year Interval Inservice Inspection Program Plan and requests for relief from the requirements of Section XI of the ASME Boiler and Pressure Vessel Code for Waterford Steam Electric U tion, Unit 3.
To complete its review, the staff requires additional information from Entergy Operations, Inc. To meet the review schedule, the staff requests a response within 60 days.
In addition, to expedite the review process, please send a copy of your response to INEL at the following address: Mr. Boyd W. Brown, EG&G Idaho, Inc., INEL Research Center, 2151 North Boulevard, P.O. Box 1625, Idaho Falls, Idaho 83415-2209.
If you have any questions on this request, please let us know. This requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under Public Law 96-511.
Sincerely, 0
~<
i i
David L. k g inton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation i
Enclosure:
RAI cc w/ enclosure:
See next page I
Mr. Ross P. Barkhurst Enterg*y Operations, Inc.
Waterford 3 i
i
.CC' Mr. Hall Bohlinger, Administrator Regional Administrator, Region IV.
Radiation Protection Division U.S. Nuclear Regulatory Commission -
t Office of Air Quality and Nuclear Energy
- 61) Ryan Plaza Drive, Suite 1000 l
Post Office Box 82135 Arlington, Texas. 76011 Baton Rouge, Louisiana 70884-2135 Resident' Inspector /Waterford NPS' I
Mr. John R. McGaha Post Office Box B22' Vice President; Operations Killona, Louisiana 70066 Support' Entergy Operations, Inc.
Parish President Council j
1 Pc 0. Box 31995 St. Charles Parish Jackson, Mississippi 39286 P. 0.- Box 302 Hahnville, Louisiana _ 70057 William A. Cross Bethesda Licensing Office Mr. Donald C.- Hintz, President -
i 3 Metro Center and' Chief Executive Officer l
Suite 610 Entergy Operations, Inc.
Bethesda, Maryland 20814 P. O. Box 31995 i
Jackson, Mississippi 39286 Mr. Robei. B. McGehee i(
Wise, Carter, Child & Caraway Chairman P.O. Box 651 Louisiana _Public Service Commission'
't Jackson, Mississippi 39205 One American P1 ace, Suite 1630_
Baton Rouge, Louisiana 70825-1697.
Mr. D. F. Packer j
General Manager Plant Operations Mr. R. F. Barski, Director i
Entergy Operations, Inc.
Nuclear Safety-
?
P. O. Box B Entergy. Operations, Inc..
Killona, Louisiana 70066 P. O. Box B 1
Killona, Louisiana 70066 i
Mr. L. W. Laughlin, Licensing Manager Entergy Operations, Inc.
P. O. Box B
- 1 Killona, Louisiana 70066 Winston & Strawn Attn:
N. S. Reynolds 1400 L Street, N.W.
Washington, DC 20005-3502 q
i Ij
Enclosure l
RE00EST FOR ADDITIONAL INFORMATION FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM WATERFORD STEAM ELECTRIC STATION. UNIT 3 1.
Scope / Status of Review Throughout the service life of a water-cooled nuclear power facility,10 CFR 50.55a(g)(4) requires that components (including supports) that are classified by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Code as Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure usts conducted during the initial 120-month inspection interval comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the issuance of the operating license, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein. The licensee, Entergy Operations, Inc., has prepared the Waterford Steam Electric Station, Unit 3 (Waterford 3), Inservice i
Inspection (ISI) Program, through Revision 5, to meet the requirements of the 1980 Edition, Winter 1981 Addenda (80W81) of Section XI of the ASME Code, except that the extent and frequency of examination for Code Class 2 piping welds in residual heat removal (RHR) systems, emergency core cooling (ECC)
~
systems, and containment heat removal (CHR) systems have been determined by the 1974 Edition through Summer 1975 Addenda (74S75).
As required by 10 CFR 50.55(g)(5), if the licensee (itermines that certain Code examination requirements are impractical and requests relief, the licensee shall submit information to the NRC to support that determination.
1 The staff has reviewed the available information provided by the licensee in the September 17, 1992, submittal of the Waterford 3 First 10-Year Interval ISI Program, throug! Revision 5, and the requests for relief from the ASME Code Section XI requirements that the licensee has determined to be impractical.
2.
Additional Information recuired Based on the above review, the staff has concluded that the following information and/or clarification is required to complete the review of the ISI Program Plan-a.
Paragraph 1.6.1 of Revision 4 of the First 10-Year ISI Program states that "any non-geometric indication that is between 20% and i
4
. 49% of the Distance Amplitude Correction (DAC) is recorded and investigated by a Level II cr Level III examiner...." This ultrasonic recording level is a requirement found in the Winter 1985 Addenda and later.
In Revision 5, the equivalent paragraph (1.5.1) has been revised and the above statement eliminated.
Please provide a discussion regarding the recording criteria being used for ultrasonic inspections during the first inspection interval.
b.
In Section 4.1 of Revision 5 of the First 10-Year ISI Program, the examination boundaries of Class 3 integral attachments and i
components were recategorized such that Subsection IWD integral attachments are included in the Subsection IWF component support boundary. Recategorizing the boundaries in this manner essentially i
eliminates Subsection IWD integral attachments. This concept was contained in Request for Relief ISI-005 (Revision 2) and evaluated in the NRC safety evaluation (SE) dated June 6, 1989, where it was determined that relief was not required since the examination method, extent of examination, or scheduling requirements for Class 3 integral attachments were not affected. However, it was also noted in the SE that any relief granted for supports under IWF would not relieve the licensee of the responsibility of examining the associated integral attachments.
It appears that Request for Relief ISI-006 is for the integral attachments that are now part of' the IWF examination boundary.
Please provide a detailed discussion regarding the extent of Code-required visual examination of Class 3 integral attachments at Waterford 3 and a detailed discussion, with drawings if necessary, describing the portion of the IWF boundary that requires relief.
c.
Reauest for Relief ISI-001:
151-001 contains approximately-200 welds in 10 Code examination categories and one non-Code examination category (N/A). There are 71 welds identified as new welds in Revision 5 and many other welds that were not evaluated in i
the SE on Revision 2.
Please clarify the welds that require relief and provide an estimate of the percentage of the Code-required examination volume / area that can be examined.
Regarding the welds listed as category N/A, please clarify the requirements from which relief is being requested.
In addition, approximately 97 welds have been eliminated without explanation since the evaluation of Revision 2.
(Is Code Case N-460, " Alternative Examination Coverage for Class 1 and 2 Welds," being applied?)
d.
Reauest for Relief 1S1-012: Relief is requested from performing the Code-required VT-2 visual examination during system pressure testing for a number of Class 2 and 3 systems that are inaccessible for direct visual examination.
Paragraph IWA-5241, Noninsulated Components, states
1 (a) The visual examination VT-2 shall be conducted by examining the accessible external exposed surfaces of pressure retaining components for evidence of leakage; and (b) For components whose external surfaces are inaccessible for direct visual examination VT-2 only the examination of surrounding area, including the floor areas or equipment surfaces located.
underneath the components, for evidence of leakage shall be required.
It appears that the Code requirements can be met as described in paragraph (b) above.
Please provide a discussion regarding this option.
The examination requirements as stated by the licensee require a VT-2 visual examination during system inservice and functional tests. Hcwever, the same ;1mitations should apply to the VT-2 performed during the system hydrostatic test.
If relief is required, is relief from the VT-2 during hydrostatic testing of Class 3 components also needed? Please provide a clarification regarding the scope of this request.
e.
A number of the relief requests in Revision 5 have been modified by shifting components to other requests, eliminating components without explanation, and/or adding components since the last NRC evaluation. To ensure that each request is evaluated properly and relief is granted for the correct component, please provide the staff with a current listing of the components requiring relief for each request that has been modified since the last evaluation.
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