ML20132C385
| ML20132C385 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/16/1996 |
| From: | Chandu Patel NRC (Affiliation Not Assigned) |
| To: | Sellmam M ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M95744, NUDOCS 9612180315 | |
| Download: ML20132C385 (5) | |
Text
Mr. Michael B. Se11can December 16, 1996 Vice Presid:nt Operations Entergy Opsrations, Inc.
P. O. Box B Killona, LA 70066
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RELIEF REQUEST ASSOCIATED WITH WATERFORD 3 STEAM ELECTRIC STATION FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN (TAC NO. M95744)
Dear Mr. Sellman:
The Nuclear Regulatory Commission (NRC) staff is reviewing the request for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI requirements associated with the first 10-year interval inservice inspection program plan for Waterford 3 Steam Electric Station submitted in your June 3, 1996, letter. Additional information is required from Entergy Operations Inc., in order for the staff to complete its review.
Request for information is provided in the enclosure.
We request that you provide response within 60 days to meet the staff's inservice inspection program plan review schedule.
In addition, to expedite the review process, please send a copy of the response to NRC's contractor, INEL, at the following address:
Michael T. Anderson INEL Research Center 2151 North Boulevard PO Box 1625 Idaho Falls, ID 83415-2209 Sincerely, ORIGINAL SIGNED BY Tim Polich for:
Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Request for Additional Information cc w/ encl:
See noxt page DISTRIBUTION:
l[j f Docket File PUBLIC PD4-1 r/f C. Patel W. Beckner C. Hawes J. Roe J. Dyer, RIV E. Adensam (EGA1)
)
Document Name: WAT95744.RAI 0FC PM/PD4-1 (A)LA/PD4-1 b
NAME CPatel Q/
CHawes ('/MJ DATE u //6 /96 l}//b/96 j $OON COPY YES/NO YES/N0 0FFICIAL RECORD COPY j
k hoh 0 0382 i
G PDR i
J
m._
p nio uqk UNITED STATES g
t s j
NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 20006 41001
)
%,*****,o December 16, 1996 i
1 i
Mr. Michael B. Sellman l
Vice President Operations l,
Entergy Operations, Inc.
P. O. Box B Killona, LA 70066
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE RELIEF REQUEST i
ASSOCIATED WITH WATERFORD 3 STEAM ELECTRIC STATION FIRST 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN (TAC NO. M95744) l
Dear Mr. Sellman:
j The Nuclear Regulatory Commission (NRC) staff is reviewing the request for relief from the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI requirements associated with the first 10-year interval inservice inspection program plan for Waterford 3 Steam i
Electric Station submitted in your June 3,1996, letter. Additional information is required from Entergy Operations Inc., in order for the staff to complete its review. Request for information is provided in the enclosure.
We request that you provide response within 60 days to meet the staff's j'
inservice inspection program plan review schedule.
In addition, to expedite j
the review process, please send a copy of the response to NRC's contractor, j
INEL, at the following address:
Michael T. Anderson INEL Research Center 2151 North Boulevard 4
2 PO Box 1625 1
Idaho Falls, ID 83415-2209 Sincerely, M[
t Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Request for Additional Information cc w/ encl: See next page
t Mr. Michael B. Sellman Entergy Operations, Inc.
Waterford 3 cc:
Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident Inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc.
Killona, LA 70066 P. O. Box 31995 l
Jackson, MS 39286 Parish President Council l
St. Charles Parish Director P. O. Box 302 l
Nuclear Safety Hahnville, LA 70057 Entergy Operations, Inc.
P. O. Box B Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 l
Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc.
One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 i
Licensing Manager Entergy Operations, Inc.
P. O. Box B Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 i
f l
1
ENTERGY OPERATIONS, INC.,
WATERFORD 3 STEAM ELECTRIC STATION DOCKET NUMBER 50-382 Reauest for Additional Information - First 10-Year Interval Inservice Inspection (ISI) Reauest 1.
Scone / Status of Review i
l 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 as American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Class 1, Class 2 and Class 3 meet the l
requirements, except design and access provisions and preservice examination requirements, set forth in the 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 tests conducted during the successive 120-month l
inspection interval shall 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 start of a successive 120-month interval, 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 and subject to Nuclear Regulatory Commission (NRC) approval.
l The staff has reviewed the information provided by the licensee in the June 3, 1996, submittal.
2.
Additional Information Reauired The staff has concluded that the following information and/or clari-fication is required in order to complete the review of this request:
A.
State the specific paragraph of the Regulations (10 CFR 50.55a) under which the request is submitted and provide supporting justification as discussed below.
The Regulations provide that a licensee may propose an alternative to CFR or Code requirements in accordance with 10 CFR l
50.55a(a)(3)(1) or 10 CFR 50.55a(a)(3)(ii).
Pursuant to 10 CFR i
50.55a(a)(3)(1), the proposed alternative must be shown to provide an acceptable level of quality and safety, i.e., essentially, be l
equivalent to the original requirement in terms of quality and l
safety.
Pursuant to 10 CFR 50.55a(a)(3)(ii), the licensee must show that compliance with the original requirement results in a hardship i
l or unusual difficulty without a compensating increase in the level l
ENCLOSURE
t t
- i t
of quslity and safety.
Examples of hardship and/or unusual difficulty include, but are not limited to, excessive radiation j
exposure, disassembly of components solely to provide access for examinations, and development of sophisticated tooling that would result in only minimil increases in examination coverage. A
{
licensee may also sutait a request for relief from ASME requirements.
In accordance with 10 CFR 50.55a(g)(5)(iii), if a licensee determines that conformance with certain Code requirements is impractical for its facility, the licensee shall notify the Comission and submit, as specified in 650.4, information to support that determination. When a licensee determines that an inservice ins section requirement is impractical, e.g., the system would have to se redesigned, or a component would have to be replaced to enable j
inspection, the licensee should cite 10 CFR 50.55a(g)(5)(iii). The NRC may, giving due consideration to the burden placed on the j
licensee, impose an alternative examination requirement.
1 B.
This request describes the limitations associated with examining the i
reactor vessel support integral attachment welds. However, the configuration is not adequately described.
Provide a detailed sketch of the examination area for this request, including all limitations.
C.
The Code requires surface examination of all four integral i
attachment welds. The proposed alternative examination is to VT-3 i
examine only two of the subject welds.
Provide a basis for i
examination of only two welds when the Code requires examination of all four.
D.
Provide the cumulative radiological exposure associated with the VT-3 visual examinations of the two integral welded attachments proposed two and the exposure associated with performing the VT-3 visual examinations on all four reactor vessel integrally welded l
attachments.
l 4
)