ML20117L184

Requests Approval to Delete Code Required VT-2 Exam for Addl Class 3 Components as Defined by ASME Section XI,1980 Edition,Winter 1981 Addenda,Exam Category D-A

ML20117L184
Person / Time
Site:	Waterford
Issue date:	09/11/1996
From:	James Fisicaro ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-96-0141, W3F1-96-141, NUDOCS 9609130018
Download: ML20117L184 (6)

Text

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Enttrgy Operati:ns,inc.

Killona. LA 70066 i Tel 504 739 6242

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mes J. Fisicaro Nb*5$'?

l W3F1-96-0141 A4.05 PR September 11,1996 l l

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk  ;

Washington, D.C. 20555 l

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Request to Delete Visual Examination of Piping Determined to be .j Not Readily Accessible During Operation l (Relief No.1S1-012, Rev. 6) j Gentlemen: l

. Entergy Operations, Inc. requests approval to delete the Code required VT-2.  !

examination for additional Class 3 components as defined by ASME Section XI, 1980 Edition, Winter 1981 Addenda, Examination Category D-A (ltem D1.10). This i code requires a visual examination of the specified pressure retaining components once each inspection period during a system functional or inservice test.

In revision 5 of this relief request, the Commission has already granted relief from visual examination of the piping identified in Groups 2 and 3. This submittal requests that the piping listed in Group 1 also be exempt from the specified Code examinations. This relief is requested based on the examination area not being readily amssible.

The piping identified in Group 1 is piping which is located in a covered pipe trench.

The pipe trench is approximately 29 feet in length and 40 inches wide. Access to the trench requires the removal of two layers of 2" thick steel plates and one layer of 1" thick steel plate. There are approximately 12 plates in all, each weighing 2000 to 2500 pounds. The lines identified in Group 1 will be pressure tested to the extent required by Section XI or Code Case N-498 once during each Ten Year Inspection Interval as applicable.

9609130018 960911 PDR p

ADOCK 05000382 PDR Mr[

l Request to Delete Visual Examination of Piping Determined to be i Not Readily Accessible During Operation

(Relief No.1S1-012, Rev 6) 1 Page 2 September 11,1996 i

Based on the foregoing discussion and that provided in Appendix 1, Waterford 3

! requests approval to delete the Code required visual examination of the piping

identified in Group 1. This request has been discussed with the Waterford 3, NRR, j Project Manager. Waterford 3 respectfully requests a timely review of this Relief 4

Request to allow for appropriate planning of Refuel 8 ISI activities, currently j scheduled for April,1997.

i' Should you have any questions regarding this matter, please contact me at (504) 739-6774 or Tim Gaudet at (504) 739-6666.

I Very truly yours, j

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N .

l James J. Fisicaro

Director Nuclear Safety

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JJF/DMU/tjs i Attachment l cc: L.J. Callan, NRC Region IV C.P. Patel, NRC-NRR i

R.B. McGehee l N.S. Reynolds

! NRC Resident inspectors Office f

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APPENDIX 1 RELIEF REQUEST Page 1 of 2 i

l A. Subject '

Request for Relief No.1S1-012, Rev. 6 Page 1 of 2 B. Component Classification ,

i Class 2 and 3 Examination Category C-H (Items C7.30 and C7.70), D-A (Item D1.10) and D-B (Item D2.10). j l

C. Examination Requirement A VT-2 examination conducted during a System Functional or Inservice test

[lWA-5211(b) and (c)] is required on systems or portions of systems which are required to operate or support the safety system function.

D. Relief Requested '

Total relief from the visual examination described above is requested for the l lines listed in Attachment 1 and their associated valves.

E. Basis for Relief Attachment 1 has been categorized into three (3) groups of piping. Each group is in an area of the plant that has been determined to be inaccessible or not readily accessible (Group 1 piping) during operation. Although a System Functional or Inservice test will not be performed on the lines (or portions of lines) listed in Attachment 1, these lines will be pressure tested to the extent required by Section XI or Code Case N-498-1 once during each Ten Year Inspection Interval as applicable.

Group 1 This group represents piping which is located in a covered pipe trench. The pipe trench is approximately 29 feet in length and 40 inches wide. Access to the trench requires the removal of two layers of 2" thick steel plates and one layer of 1" thick steel plate. There are approximately 12 plates in all, each weighing 2000 to 2500 pounds.

Appendix 1 4 Request for Relief No.1S1-012, Rev. 6 Page 2 of 2 Group 2 This group represents piping which has been determined to be inaccessible due to being located in a radioactive pipe chase. This piping runs from the Charging pumps to the Regenerative HX and is encased in lead brick shielding. To access the piping, the shielding must be removed. Radiation levels vary between 120-150 mr/hr with the shielding removed.

Group 3

This group represents piping which is located in an inaccessible radioactive pipe chase. Piping from several systems is contained within the pipe chase.

I This piping includes the line which runs from the Charging pumps to the Regenerative HX (same line in group 2), therefore, radiation levels during operation of the Charging pump are high (120-150 mr/hr). This area is completely enclosed behind a concrete block wall.

F. Schedule for Implementation First 10 year Interval i

s Appendix 1 Request for Relief No. ISI-012, Rev. 6 Attachment 1 to Appendix 1 Page 1 of 2 Component (s)- Lines listed below System (s) - Component Cooling (CC), Charging (CH), Feedwater (FW)

Relief - Located in areas which are inaccessible during operation.

1. 1) Piping Located in Covered Pipe Trench Line No. Size Flow Diagram Footage 3CH3-5A/B 3" G-168 sh. 2 42'4" 3CH3-7A/B 3" G-168 sh. 2 46'11" 3CH3-26A/B 3" G-168 sh. 2 43'4"  ;

3CH1-49 1" G-168 sh. 2 9"(total of 3) 1

1. 2) Piping Located in Radioactive Pipe Chase .

1 Line No. Size Flow Diagram Footage 2CH1-33 1" G-168 sh.1 1' 2CH2-53A/B 2" G-168 sh.1 & 2 124' 2CH2-1/2-54A/B 2-1/2" G-168 sh.1 6' 2CH1/2-233 1/2" G-168 sh.1 2' 2CH2-60A/B 2" G-168 sh.1 6'

1. 3) Piping Located in inaccessible Radioactive Pipe Chase Line No. Size Flow Diagram Footage 3CC20-2A 20" G-160 sh. 2 45' 3CC20-2B 20" G-160 sh. 2 32' 3CC20-3A 20" G-160 sh. 2 32' 3CC20-38 20" G-160 sh. 2 40' 3CC20-4A 20" G-160 sh.1 & 2 28' 3CC20-4B 20" G-160 sh.1 & 2 34' 3CC10-8A 10" G-160 sh.1 16' 3CC10-8B 10" g-160 sh.1 4' 3CC10-10A 10" G-160 sh.1 & 3 30' 3CC10-10B 10" G-160 sh.1 & 3 11' 3CC18-11A/B 18" G-160 sh.1 & 2 34'

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Appendix 1 Request for Relief No.1S1-012, Rev. 6 Attachment 1 to Appendix 1 Page 2 of 2

1. 3) Piping Located in inaccessible Radioactive Pipe Chase (Continued)

Line No. Size Flow Diagram Footage 3CC6-71A 6" G-160 sh.1 62' 3CC6-71B 6" G-160 sh.1 34' 3CC10-83A 10" G-160 sh.1 & 3 19' 3CC10-83B 10" G-160 sh.1 & 3 3' 3CC10-89A 10" G-160 sh.1 3' 3CC10-89B 10" G-160 sh.1 3' 3CC6-106A 6" G-160 sh. 2 & 3 32' !

3CC6-106B 6" G-160 sh. 2 & 3 42' 3CC20-107A 20" G-160 sh.1 & 2 40' 3CC20-107B 20" G-160 sh.1 & 2 83' 3CC8-119A/B 8" G-160 sh.1 13' 3CC8-139A/B 8" G-160 sh.1 56' 3CC4-145A 4" G-160 sh.1 & 3 19' 3CC4-145B 4" G-160 sh.1 & 3 21' 3CC18-156A/B 18" G-160 sh.1 & 2 27' 3CC16-202A 16" G-160 sh. 2 53' 3CC16-202B 16" G-160 sh. 2 , 27' 3CC16-203A 16" G-160 sh. 2 30' 3CC16-203B 16" G-160 sh. 2 25' 3CC10-289A 10" G-160 sh. 2 38' 3CC10-290B 10" G-160 sh. 2 40' 2CH2-53A/B 2" G-168 sh.1 & 2 80' 3EG2-4A 2" G-164 sh.1 58' 3EG2-5B 2" G-164 sh.1 60' 3FW6-19A 6" G-153 sh. 4 64' 3FW6-22B 6" G-153 sh. 4 92' 3FW4-46 4" G-153 sh. 4 22' '

3FW4-47 4" G-153 sh. 4 12' 3MS8-91A/B 8" G-151 8' i

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