ML20141D711
| ML20141D711 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 05/12/1997 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-97-00042, GNRO-97-42, NUDOCS 9705200180 | |
| Download: ML20141D711 (8) | |
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Entergy Operations,Inc.
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RO. Box 756 Port Gibson, MS 39150 TeI 001437-6470 y
W.K.Hughey o.reewr Nuclear Safety & Re3Jatory May 12, 1997
- 5 Document Control Desk U.S. Nuclear Regulatory Commission Mail Station Pi-37 Washington, D.C.
20555
Subject:
Additional Information for the Approval of ASME Code Cases N-F09 and N-546 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Arkansas Nuclear One-Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Waterford 3 Steam Electric Station Docket No. 50-382 Licence No. NPF-38 River Bend Station Docket No. 50-458 License No. NPF-47 GNRO-97/00042 Gentlemen:
On June 20, 1996, requests for the subject Code Cases were submitted to the Nuclear Regulatory Commission (NRC) to obtain their approval for use at Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station.
On January 14, 1997, additional information was submitted to supplement our. previous submittal.
On March 13, 1997, we received a request for further information from your staff.
In our above submittals, we proposed the use of Code Case N-509 and N-546 pursuant to 10 CFR 50.55a (a) (3) (i). Your recent correspondence indicated that acceptance of the above alternatives is contingent on our implementing programs. The following information is being provided in response to the staff's request.
Additionally, on April 4, 1997, we were informed by your staff that data'for ANO-2 had been omitted from Table 2 of our code case submittal, dated January 14, 1997. The requested information is i }
fcund on page 5 of 7.in this submittal.
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Page 2 of 7 Code Case N-509, " Alternative Rules for the Selection and
' Examination of Class 1, 2,
and 3 Integrally Welded Attachments-
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Section XI, Division 1" Information Required by NRC:
Pursuant ' to 10 CFR 50. 55a (a) -(3) (i), the licensee proposed to use i
Code Case N-509, Alternative. Rules for the Selestion and
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Examination of Class 1,.2, and 3 Integrally Welded Attachments,
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Section XI Division 1" in lieu of the Code selection requirements for integrally welded attachments..To find Code, Case N-509 t
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acceptable for use, the staff has determined that a minimum examination sample of 10% of the total number of integral g
attachments in all non-exempt Class 1, 2, and 3 piping, pumps, and valves is necessary.
Confirm that this condition will be met.
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Entergy Response:
Entergy concurs and will ensure that the sample size equals or
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l exceeds 10% of the total number of integral attachments in all non-exempt' Class 1, 2, and 3 piping, pumps, and valves with the-following clarification. Entergy understands the staff's reference i
to " total number' to mean those integral attachments that meet the criteria contained in Note 1 to Table 2500-1 for Examination Categories B-K, C-C, and D-A as contained in Code Case N-509.
Code Case N-546, ' Alternative Requirements for Qualification of VT.
2 Examination Personnel'Section XI, Division 1" I
Information Required by NRC Pursuant to 10 CFR 50.55a (a) (3) (1), the licensee proposed the use of Code Case N-546.,
Requirements for Qualification of VT-2 Examination Personnel,Section XI, Division 1. "
To find this Code Case acceptable for use, the staff-has determined that the following conditions must be met:
Licensee's must 1) develop procedural guidelines for obtaining consistent, quality VT-2 visual examinations,;2) document and maintain records to verify the qualification of persons selected to perform VT-2 visual i
examinations, and 3) implement independent review and evaluation of detected leakage by persons other than those that. performed the VT-2 visual examinations. Confirm that these conditions will be met.
Entergy Response
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"The introduction to Regulatory. Guide 1.147; states, in part, that the use of specific Code cases may be' authorized by the Commission upon
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request. pursuant to paragraph 50.55a(a) (3) which' requires that proposed alternatives to the described requirements or-portions
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thereof-provide-an acceptable' level of quality.and safety.
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4 GNRO-97/00042 Page 3 of 7 The ASME meets regularly to consider proposed additions and revisions to the code and to formulate Code Cases to clarify the intent of existing requirements or provide new rules where rules are nonexistent, or as alternatives to existing rules.
ASME approved code Cases are issued with a specified edition and addenda of applicability for which the Code case is applicable.
Code cases are typically written to address a specific topic or requirement and when adopted the Code Case is used in conjunction with the Code to maintain a complete set of requirements.
Code Cases are not stand-alone documents and are applicable only as described in the code case (See attached Code Case N-546).
This explanation is provided as Entergy's basis for the following response to the Staff's proposed conditions for use of Code Case N-546.
NRC Condition 1:
The Code case only provides alternatives to IWA-2300,
' Qualification of Nondestructive Examination Personnel', the requirements for VT-2 examinations to be performed in accordance with written procedures that meet the requirements of ASME Section i
V, Article 9 is contained in IWA-2210
.Entergy has not requested an alternative or relaxation of these requirements. Therefore, if the NRC is not requiring actions above those already required by IWA-2210, then we believe that we meet the intent of the condition.
NRC Condition 2:
The Code Case only provides alternatives to IWA-2300, i
Qualification of Nondestructive Examination Personnel, the requirement for the Owner to maintain adequate evidence of personnel qualification is contained in IWA-1400 (k).
Entergy has not i
requested an alternative or relaxation of the Owner's responsibilities as defined in IWA-1400.
Therefore, if the NRC is not requiring rctions above those already required by IWA-1400(n),
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then we b-ile/e that we meet the intent of the condition.
l NRC Condition 3:
Entergy performs independent reviews of safety related activities as described by Entergy's Quality Assurance Programs and their implementing procedures.
This condition describes activities.that are controlled through programs that implement 10 CFR 50 Appendix B and not ASME Section XI.
ASME Section XI, IWA-1400(n) requires thc Owner to maintain the documentation of a Quality Assurance Program in accordance with i
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'j GNRO-97/00042' Page 4 of 7 f
I Title 10, Code.of Federal Regulations, Part 50, or ASME NQA-1, Parts II.and III, Basic Requirements and Supplements.
Section XI provides criteria for the evaluation of conditions detected'during Section XI inspections and examinations.
Section XI.
does not require independent reviews or evaluations from people-other than those performing the inspection or examination. This condition would result in a unique requirement not required by ASME Section XI for any imposed Section XI inspections or examinations.
It is not clear as to the significance of this condition for this specific inspection compared to all other inspections and examinations required by ASME Section XI.
Implementation of NRC Condition 3 would in some cases preclude the most knowledgeable individual of a system's operating characteristics and. specifications from reviewing and evaluating unacceptable system leakage discovered during VT-2 examinations if that individual had initially identified the system leakage.
If the NRC condition is intended to require independent. reviews and evaluations that are in excess of those already required by Entergy's Quality Assurance Programs, additional clarification is t'
necessary as this condition would affect Entergy's implementation of 10 CFR 50' Appendix B and not ASME Section XI. However, if the NRC's condition is to only reinforce those actions that are already addressed by our compliance with 10 CFR 50 Appendix B and our additional commitments to Regulatory Guide 1.33, then we believe that we meet the intent of the condition.
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- i, GNRO-97/000,42 s
Page 5 of.7
- The Edition and Addenda of ASME Section XI in affect at ANO-2
.As mentioned above, data for ANO-2 is being supplied in the table
- below, Repair / Replacement
. Inservice Inspection Current New.
Current New Facility Interval Interval Interval Interval Edition /
Edition /
. Edition /
Edition /
Addenda Addenda Addenda Addenda ANO-2 86/N/A N/A*
86/N/A N/A*
TABLE 2 Should you have any questions regarding this request, please contact Riley Ruffin at 601-437-2167.
Yours truly, WKH/RR/rr cc:
Mr. N.
S.
Reynolds Mr. J. Smith Mr.
H. L. Thomas Mr. J.
W.
Yelverton Regional Administrator U.S. Nuclear Hegulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C.
20555
'- ' ANO, Unit 2 will not be updating until March of 2000.
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E' GNRO-97/00042 Page 6 of 7'
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cc:
NRC Senior Resident Inspector Grand Gulf Nuclear Station P. O.
Box 756 Bald Hill Road Port Gibson, MS 39150 i
NRC Senior Resident Inspector i
Arkansas Nuclear One 1448 S. R.
333 Russellville, AR 72801 NRC Resident Inspector Waterford 3 Steam Electric Station Trailer 426 P. O. Box B Killona, LA 70066 NRC Resident Inspector River Bend Station l
P. O. Box 1051 St. Franciaville, LA 70775 Mr. George Kalman, Project Manager Office of Nuclear Reactor Regulation U.
S. Nuclear Regulatory Commission Region IV/ANO-1 & 2 Mail Stop 13H3 Washington, D.C.
20555 Mr. Chandu Patel, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Region IV/W3 Mail Stop 13H3 Washington, D.C.
20555 Mr. Ramon Azua, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Region IV/RB Mail Stop 13H3 Washington, D.C.
20555 Mr. Eugene.Imbro CBLA Task Force U.S.; Nuclear Regulatory Commission Office of Nuclear Reactor Regulation
' Mail'Stop 9Al Washington, D.C.
20555 l
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a CASE N-546 CASES OF ASME BOfLER AND PRESSURE VESSEL CODE Approval Date: August 24, 1995 See NumericalIndex for expiration and any reaffirmation detes.
accordance with the referenced standard (i.e., ANSI Case N 546 Alternative Requirements for QuallAcation of N45.2.6, ASNT SNT-TC 1 A, or ASNT CP 189) pro-VT 2 Examination Personnel vided the examination personnel are qualified in accord-Section XI, Division 1 ance with the following requirements.
(a) At least 40 hrs plant walkdown experience, such as that gained by licensed and nonlicensed operators, Inquiry: What alternative to the requirements of I '
rate personnel, system engineers, and inspec.
i IWA 2300 may be used for qualification of VT 2 visual II " " n ndestructive examination personnel.
examination personnel?
(b) At least 4 hrs of training on Section XI require-ments and plant specific procedures for VT-2 visual examination.
Reply. It is the opinion of the Committee that VT.
2 visual examination personnel need not be qualified (c) Vision test requirements of IWA-2321,1995 nor certified to comparable levels of competence in Edition.
1089 SUPP. 2 - NC
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