ML20196J153
| ML20196J153 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 07/29/1997 |
| From: | Hughey W ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-97-00072, GNRO-97-72, NUDOCS 9708040011 | |
| Download: ML20196J153 (4) | |
Text
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Entsrgy Opxrations,Inc.
h PO. Box 756 Port G bson, MS 39150 Tel 601437-6470 W.K.Hughey Denctor Nuclear Safety & Hajutatory Affcers July 29,1997 Document Control Desk U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555
Subject:
AdditionalInformation for the Approval of ASME Code Case N-546 Grand Gulf Nuclear Station Docket No. 50-416 Licente NoTNPF-29 Arkansas Nuclear One-Units 1 and 2 Dock-as. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 River Bend Station Docket No. 50-458 License No. NPF-47 GNRO-97/00072 Gentlemen:
Regarding recent verbal communication with your Staff, Entergy is submitting this response in reference to NRC approval of Code Case N-546 " Alternative Requirement for Qualification y
of VT-2 Examination Personnel Section XI, Division 1."
On May 12,1997, additional information for the approval of ASME Code Cases N-509 and N-546 was submitted to the Staff for review. In this letter, we committed to the NRC condition associated with Code Case N-509.
However, we did not fully understand the three conditions that were proposed for the lt approval of Code Case N-546. It appears the conditions were redundant to existing ASME Section XI requirements and currently required by 10 CFR 50.55a.
The conditions proposed by the Staff for Code Case N-546 were:
1.
Develop procedural guidelines for obtaining consistent, quality VT-2 visual exarninations, 2.
Document and maintain records to verify the qualification of persons to perform VT-2 l
visual examinations,
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3.
Implement independent review and evaluation of detected leakage by persons other than those that performed the VT-2 visual examinations.
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af GNRO 37/00072 Page 2 of 4 Code Case N-546 states that it is an alternative to IWA-2300, " Qualification of Nondestructive Examination Personnel," and has no provisions for providing alternatives to other Code requirements. Our previous correspondence provided some information that we believe addresses the subject conditions:
Condition I - The requirements of IWA-2210, " Visual Examinations," require visual exarninations (VT-1, VT-2, and VT-3) be conducted in accordance with ASME Section V, Article 9 with written procedures that have been demonstrated to the provisions of Table IWA-2210-1.Section V, Article 9 requires written procedures that must include specific attributes which control the consistency and quality of the examinations.
Condition 2 - The requirements of IWA-1400(k), " Owner's Responsibility," state that the Owner is responsible for maintenance of adequate inspection, examination, test, flaw evaluation, and repair and replacement records such as radiographs, diagrams, drawings, ca!culations,
- 'examin'ations and test data, description of pitded' ores ure',"ahd dvide'ncd'of p'ersonnel d
qualifications.
Condition 3 - The requirements of IWA-1400(n) that require the Ownr ;o be responsible for the documentation of a Quality Assurance Program in accordance with Title 10, Code of Federal Regulations, Part 50.
We believe our correspondence affirmed that the proposed conditions were satisfied by our existing programs in accordance with the above Code requirements.
Our initial response to the proposed conditions was that they were being imposed to establish controls which augment current Code requirements. However, the proposed conditions were not specific enough to determine the particular augmentation being sought by the Staff. Therefore, we indicated in our May 12,1997, correspondence that our sites met the intent of the conditions through compliance with IWA-2210, IWA-1400(k), and IWA-1400(n). We believed that this clarification was appropriate to demonstrate a mutual understanding between Entergy and the NRC thus allowing a consistent implementation throughout all Entergy sites and affording a collaborative understanding between Entergy, NRR and the NRC regional office.
During the week of June 1,1997, the Staff verbally communicated that they had accepted our commitment to the condition imposed on Code Case N-509. However, our response to the conditions imposed on Code Case N-546 had been rejected. Your Staff indicated that the basis of denial was due to the Licensees' refusal to commit to the proposed conditions.
Several teleconferences were subsequently held with the Staff. Our conversations focused on the rationale for the proposed conditions associated with Code Case N-546 and the basis of the Staff's denial. Subsequently, we agreed to submit correspondence confirming our commitment to the proposed conditions associated with Code Case N-546, along with an explanation of the method to l
be used for implementation.
l Your Staff has stated that the three conditions imposed for the approval of Code Case N-546 do not exceed or augment the requirements of the Code as referenced by our correspondence. It was also stated that compliance with the aforementioned Code requirements would satisfy the Staff's conditions. The Staff further explained that even though current requirements of the Code adequately address the imposed conditions, the conditions are warranted because code cases are stand-alone documents that are alternatives to Entergy's Code of Record. In essence, they are not required to be used in conjunction with the applicable Code for which the code case is issued. Our understandir5 of the Staffs position is that without imposing the three conditions, a licensee would not be reouMu to comply with IWA-2210, IWA-1400(k) and IWA-1400(n) when implementing Code Case N 54G Frtergy's understanding of the Code and the method for code case implementation differs frorn te above statement.
GNRO-97/00072 Page 3 of 4 Assuming Code Case N-546 is implemented by a licensee with only the requirements contained in the code case and the three coriditions Fpecified by the Staff, then a sig.d ant reduction in other ASME Section XI requirements has occurred which has not been addressed by previously issued NRC N-546 approval Safety Evaluations that were reviewed by Entergy personnel.
For instance, the VT-2 inspections may be performed without the oversight of an Authorized Inspector because e
IWA-1400(f) is not specified in the code case nor was it a condition imposed by the Staff for the Licensee to possess an arrangement with an Authorized Inspection Agency; the VT-2 results may not be evaluated to the requirements of IWB/lWC/ LWD-3000 because this is not specified by the code case or conditions required by the Staff; corrective measures may not be required because IWA-5250 is r20t e.pec!4m!in the-cede.ome-
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nor was it a condition imposed by the Staff addressing corrective measures.
The reduction of these code requirements, and others, do not appear to have been addressed by the Safety Evaluations that were issued to other licensees for ihe use of Code Case N-546. Any reduction in ASME Section XI requirements could be construed as a reduction in safety and should be subject to rigorous evaluation in order to ensure that an acceptable level of safety is maintained.
If our understanding of the Staff's position is correct, we believe that one could infer that any code case that is approved, including those approved for generic use in Regulatory Guide 1.147, can be implemented with no regarc for other Code requirements other than those specifically contained in the code case or those imposed as a part of NRC code case approval. Apart from the above, Entergy plans to implement Code Case N-546, follov.ing NRC approval, as an alternative to IWA-2300 only, in addition, consistent with past practices, Entergy will implement Code Case N-546 by complying with all provisions of ASME Section XI when performing VT-2 inspections.
Therefore, Entergy commits to NRC Condition 1 and willimplement this condition in accordance with ASME Section XI, IWA-2210. Secondly, Entergy commits to NRC Condition 2 and will implement this condition in accordance with ASME Section XI, IWA-1400(k). Finally, Entergy commits to NRC Condition 3 and will imp!ement this condition in accordance with ASME Section XI, IWA-1400(n).
Should you have any questions regarding this correspondence, please contact Riley Ruffin at 601-437-2167.
Yours truly, l
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cc:
Ms. J. L. Heredity-Dixon, GGNS Senior Resident Mr. L. J. Smith (Wise Carter)
Mr. N. S. Reynolds
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Mr. H. L. Thomas
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Mr. E. W. Merschoff
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Regicnal Administrator U.S. Nuclear Regulatory Commission i
Region IV l
611 Ryan Plaza Drive, Suite 400 l
Arlington, TX 76011 I
1 GNRO-97/00072 Page 4 of 4 cc: (cont'd)
Mr J. N. Donchew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 NRC Senior Resident inspector Arkansas Nuclear One 1448 S. R. 333 Russellville, AR 72801 NRC Resident inspector Waterford 3 Sleam ElectriqStatiou v+*
WMSB4326 P. O. Box B Killona, LA 70066 NRC Resident inspector River Bend Station P. O. Box 1051 St. Francisville, 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 l
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 9A1 Washington, D.C. 20555