ML20141F388

Safety Evaluation Authorizing Licensee Request for Extension of First ISI Interval to 970924

ML20141F388
Person / Time
Site:	Waterford
Issue date:	06/30/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20141F382	List: ML20141F379 ML20141F388
References
NUDOCS 9707020330
Download: ML20141F388 (3)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THE RELIEF RE0 VEST FOR THE FIRST TEN YEAR INSERVICE INSPECTION INTERVAL e

i ENTERGY OPERATIONS. INC.

l WATERFORD STEAM ELECTRIC STATION. UNIT 3 l DOCKET NO. 50-382 i

1.0 INTRODUCTION

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i The Technical Specifications for Waterford Steam Electric Station, Unit 3 i

(Waterford 3) state that the inservice inspection of the American Society of

. Mechanical Engineers (ASME) Code Class 1, 2 and 3 components shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel

! Code and applicable addenda as required by 10 CFR 50.55a(g), except where specific written relief has been granted by the Commission pursuant to j'

10 CFR 50.55a(g)(6)(1). 10 CFR 50.55a(a)(3) states that alternatives to the requirements of paragraph (g) may be used, when authorized by the Nuclear Regulatory Commission (NRC), if (1) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulties without a j compensating increase in the level of quality and safety.

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2 and 3 components (including supports) shall meet the requirements, except the design and access provisions and the 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. The regulations require that inservice examination of components and system pressure tests conducted during the first ten-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. The applicable ASME Code,Section XI, for the Waterford 3, first ten-year inservice inspection (ISI) interval is the 1980 Edition through Winter 1981 addendum. The components (including supports) may meet the requirements set forth in subsequent editions and addenda of the ASME Code incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subiect to Commission approval.

Pursuant to 10 CFR 50.55a(g)(5), if the licensee determines that conformance with an examination requirement of Section XI of the ASME Code is not practical for its facility, information shall be submitted to the Commission in support of that determination and a request made for relief from the ASME 9707020330 970630 ENCLOSURE PDR ADOCK 05000382 G PDR

Code requirement. After evaluation of the determination, pursuant to 10 CFR 50.55a(g)(6)(1), the Commission may grant relief and may impose alternative requirements that are determined to be authorized by law, will not endanger life, property, or the common defense and security, and are otherwise in the public interest, giving due consideration to the burden upon the licensee that could result if the requirements were imposed.

In a letter dated June 16, 1997, Entergy Operations, Inc. submitted to the NRC its request for further extension of the current inservice inspection interval which was previously extended to July 1,1997, to an end date of September 24, 1997, which was necessitated as a result of a transformer failure. The NRC staff has reviewed and evaluated the licensee's request for further extension of the inspection interval, pursuant to 10 CFR 50.55a(a)(3)(ii) for Waterford 3.

2.0 DISCUSSION COMP 0NENT:

All Class 1, Class 2 and Class 3 pressure retaining components.

EXAMINATION REQUIREMENT:

The applicable ASME Code,Section XI, 1980 Edition through Winter 1981 Addenda, Table IWB-2500-1, IWC-2500-1 and IWD-2500-1, requires a hydrostatic test on all Class 1, 2 and 3 pressure retaining components at or near the end of the inservice inspection interval. The same Code also requires that a hydrostatic test be performed following repair / replacement of all Class 1, 2 and 3 components.

LICENSEE'S REQUEST FOR RELIEF:

The licensee requests further extension of the first inservice inspection interval beyond July 1, 1997, which was previously authorized under NRC Safety Evaluation dated August 2, 1994, to a new end date of September 24, 1997.

This extension of the inspection interval will allow the licensee to work under the premises of the current inservice inspection and test programs for the remainder of the refueling outage 8 (RF 8). The start date of the second ten-year interval as currently specified in the NRC Safety Evaluation dated August 2,1994, is July 1,1997, which would now overlap the first insnection interval. However, the licensee states that all pressure tests associated with and performed during the current RF 8 outage will only be credited to the first inservice inspection interval.

LICENSEE'S BASIS FOR REIEF:

The RF 8 at Waterford 3 began on April 11, 1997. The system pressure tests were scheduled to be performed prior to startup of the unit at the end of the outage. On May 28, 1997, a fault occurred in a startup transformer which prevented performance of the scheduled pressure tests. It is highly unlikely I

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that the scheduled system pressure tests can be conducted prior to July 1, 1997, which is the end date of the first inspection interval. Therefore, it is necessary to extend the inspection interval to perform the required pressure tests under the requirements of the inservice inspection program that is currently applicable.

UCENSEE'S PROPOSED ALTERNATIVE:

Extension of the first inspection interval to include September 24, 1997.

3.0 EVALUATION The staff has reviewed the licensee's request for extension of the first inservice inspection interval beyond July 1,1997, which was previously authorized under NRC Safety Evaluation dated August 2, 1994, to a new end date of September 24, 1997. As required by the ASME Code,Section XI, an inservice inspection program plan was established for the first inservice inspection interval which was reviewed by the staff. No deviations from the applicable Code or the NRC regulations were found. Due to the failure of a transformer on May 28, 1997, however, the implementation schedules for performance of l system pressure tests were affected and the licensee is unable to complete the tests within the time frame of the inspection interval. The staff has determined that a change of the first interval end date from July 1,1997, to September 24, 1997, with no change of duration for the second inspection interval and the system pressure tests being credited to the first interval, will not increase risk to the public health and safety. Based on the low impact on the overall effect of the requested extension of interval, it would be a hardship without a compensating increase in the level of quality and safety to require the licensee to revise their program plan and/or preclude use of Code cases authorized by the NRC for the first inspection interval.

4.0 CONCLUSION

The staff has determined that due to the extension of the RF 8 as a result of transformer failure and consequent delays in conducting system pressure tests, the proposed extension of the end date of the first inservice inspection interval from July 1,1997 to September 24, 1997, is a viable option to complete the required syr, tem pressure tests under the requirements of the current program plan. There will be no impact on the health and safety of the public since the duration of the second interval including the start and end dates remains unchanged and the system pressure tests will be credited only to the first inspection intervals Any change to the requirements of the system pressure test beyond the program plan, creates hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Therefore, the proposed extension of the inspection interval from July 1, 1997, to an'end date of September 24, 1997, is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for Waterford 3.

Principal Contributor: P. Patnaik Date: June 30, 1997 l

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