ML20045A425
| ML20045A425 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/04/1993 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-93-0150, W3F1-93-150, NUDOCS 9306100238 | |
| Download: ML20045A425 (8) | |
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W3F1-93-0150 A4.05-PR June 4, 1993 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Donket No. 50-382 License No. NPF-38 Request for Additional Information (RAI) - Waterford Steam Electric Station, Unit 3, First 10-Year Interval Inservice Inspection Program Plan, Revision 5
.I Gentlemen:
Entergy Operations, Inc. hereby submits the attached response to your written request for additional information (RAI), dated April 5,1993, concerning Revision 5 of the Waterford 3 First 10-Year Interval Inservice Inspection Program.
In an effort to clarify the scope of the RAI and j
achieve effective disposition of the individua. requests, we met with a
'j member of your staff on May 5, 1993.
If there are any questions concerning this submittal, please contact B.R. Loetzerich at (504) 739-6636.
j Very truly yours, Su R.F. Burski i
Director Nuclear Safety RFB/BRL/ssf cc:
J.L. Milhoan (NRC Region IV), D.L. Wigginton (NRC-NRR),
R.B. McGehee, N.S. Reynolds, NRC Resident Inspectors Office, B.W. Brown (EG & G Idaho, Inc.)
9306100238 930604 PDR ADOCK 05000392 G
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a Attachment to W3F1-93-0150 The following five items (a thru e) represent the staff's specific requests for additional information based upon their initial review of Revision 5 to the Waterford 3 Inservice Inspection (ISI) Program.
In an effort to clarify our response, we have reiterated the individual requests for additional information from the staff's correspondence.
Reauest 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 49% of the Distance Amplitude Correction (DAC) is recorded and investigated by a Level II or 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 l
above statement eliminated.
Please provide a discussion regarding the recording criteria being used for ultrasonic inspections during the first inspection interval.
Response a:
The statement in Paragraph 1.6.1 of Revision 4 to the W3 ISI Program described the ultrasonic recording criteria.
The equivalent paragraph (1.5.1) contained in Revision 5 was simplified to reflect our compliance with the recording criteria of IWA-2230, as contained in the 1980 Edition of Section XI thru Winter 1981 Addenda, to which W3 is committed. The ultrasonic examination portion (IWA-2232) of IWA-2230 provides specific requirements for ultrasonic recording criteria thereby negating the need to fully discuss the criteria in Paragraph 1.5.1.
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Reauest b:
In Section 4.1 of Revision 5 of the First 10-Year ISI Program, the examination boundaries of Class 3 integral attachments and componer,t's were recategorized such that Subsection IWD integral attachments are included in the Subsection IWF component support boundary.
Recategorizing the boundaries in this manner essentially 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 i
licensee of the responsibility of examining the associated integral attachrents.
It appears that Request for Relief 151-006 is for the integral attachments that are now part of the IWF examination l
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.
Response b:
As stated above, Relief Request 1S1-005 which allowed for the combination of IWD and IWF boundaries was evaluated by the NRC, as documented in a SE dated June 6, 1989.
Paragraph 4.1 of the W3 ISI Program states that the boundaries were combined in an effort to i
simplify the categorization and scheduling process, and does not affect the number of supports selected, the examination method, nor the extent of examination. The NRC's 1989 SE concludes that.this approach is acceptable and that no relief is required.
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In Relief Request 15I-006, W3 requested relief from total or partial visual examinations of component supports during inservice inspections which are not practical due to permanent, non-removable.
insulation.
The relief request does not differentiate between integral and nonintegral supports. This relief request was originally granted in the NRC's 1989 SE, and represents the type of administrative benefit achieved by combining the IWD and IWF boundaries. The SE granted the relief with conditions concerning sample size and the examination of similar. additional supports. The SE does not limit the relief granted for supports under IWF and the responsibility for examining associated integral attachments, as stated in the request for additional information.
The overall concept of this relief request has not been revised since the issuance of the NRC's 1989 SE.
In Revision 4 of the W3 ISI Program, Relief Request 15I-006 was revised to incorporate-the examination of all nonexempt component supports within the Chilled Water System.
In addition to the basis for relief contained in the ISI program document, this revision is described in a summary of major changes submitted by attachment to Entergy Operations letter number W3P90-ll62, dated August 16, 1990.
Reauest c:
Relief Request 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 the SE in Revision 2.
Please clarify the welds that requiie 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?)
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Response c:
Relief Request ISI-001 contains the individual welds in the W3 ISI Program for which 100% of the Code-required examination volume / area cannot be achieved.
During development of the ISI program, the extent of coverage from preservice inspection (PSI) data was considered during the weld selection process and this information was recorded in Relief Request ISI-001.
During the past 5 refueling outages, inservice inspection data has been obtained which indicates that original PSI data was conservative for determining the extent of coverage for weld examinations.
As individual welds are examined, the extent of coverages contained in 151-001 are revised to reflect the most recent inservice inspection data.
However, if a weld (or portion of weld) is examined more than once during the Ten Year Interval, the extent of coverage recorded is an average of all ISI examination coverages within the interval.
In addition, new or different techniques and calibrations have allowed 100% coverage of certain welds listed in 151-001 during later examinations.
If 100% coverage is achieved during a later examination, relief is no longer required and the weld is withdrawn from the relief request. Since Revision 2 of the ISI program was reviewed by the NRC, a number of welds have been deleted from 151-001 i
when it was determined that full coverage of those welds could be achieved.
In some cases, an estimate of the percentage of Code required examination volume / area that can be examined was not provided on PSI data.
However, as ISI examination coverages supersede the PSI coverages, a revised percentage of coverage is provided in Relief Request ISI-001.
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9 Welds contained in ISI-001 which are categorized as Examination Category N/A are non-safety class welds in the Augmented Inservice Inspection Program for High-Energy Piping.as described in Paragraph 1.7 of the W3 ISI Program, or are exempt welds in the Supplemental Program for Intergranular Stress Corrosion Cracking as described in Paragraph 1.6 of the W3 ISI Program.
Future ISI program revisions will clarify this designation in the relief request.
i Paragraph 1.2.4 of the W3 ISI Program lists the Code Cases adopted j
for implementation and Code Case N-460 has not been applied at Waterford 3.
However, Waterford 3 plans to incorporate Code Case N-460 into the next revision of the ISI Program, thus resulting in the elimination of more welds from Relief Request 151-001.
In summary, it is expected that future examinations and the planned adoption of Code Case N-460 will result in continued revisions to Relief Request 151-001. All welds in Relief Request 151-001 which
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were added or revised in Revision 3, 4 or 5 of the ISI Program have been identified by revision bars-in the appropriate revision submittal.
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Reauest d:
1S1-012 requests relief 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:
(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 5
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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 function tests.
However, the same limitations should apply to the VT-2 performed-during the system hydrostatic test.
If relief is required, is relief y
from the VT-2 during hydrostatic testing of. Class 3 components'also needed? Please provide a clarification regarding the scope of this request.
Response d:
Relief Request ISI-012 addresses piping in areas of.the plant.that have been determined as inaccessible during plant operation.
As explained in the basis for relief, radiological conditions deter entry into the subject areas.
Therefore, the same deterrence applies to the examination of surrounding areas, such as floor areas or 1
equipment surfaces, which would require entry into-those areas.
Hydrostatic tests are performed during plant shutdown and the subject areas of the plant are considered accessible during plant shutdown.
Therefore, relief is not requested for the VT-2 examinations conducted during hydrostatic testing.
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Reauest 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.
4 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.
Response e:
A number of changes have been made to Relief Requests ISI-001, ISI-003, 1S1-006 and ISI-007 since receipt of the last NRC safety evaluation. Also, Request for Relief Nos. ISI-004, ISI-005,1S1-008 and ISI-009 were deleted or combined with other existing requests.
The majority of changes to ISI-003, ISI-006 and ISI-007 were made in i
Revision 4 of the ISI Program, as documented in submittal letter nos.
W3P90-ll62 and W3P90-1163 dated 8/10/90 and 9/6/90 respectively, i
Future changes to relief requests are expected due to ongoing examination results. Additions / changes subsequent to revision 2 of l
the W3 ISI Program are denoted by attachments to the submittal letters corresponding to each revision, and are identified by revision bars within the program revisions.
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