ML20217C237
| ML20217C237 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 09/17/1997 |
| From: | Chandu Patel NRC (Affiliation Not Assigned) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M95897, NUDOCS 9710010278 | |
| Download: ML20217C237 (5) | |
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NUCLEAR REGULATORY COMMISSION 2
WASHINGTON, D.C. 30ee6 com
.....,o September 17, 1997 Mr. Charles M. Dugger Vice President Operations Entergy Operations, Inc.
P. O. Box B Killona, LA 70066
SUBJECT:
RESPONSE TO REQUEST FOR RELIEF FROM THE ASME CODE, SECTION III REQUIREMENTS FOR WATERFORD 3 (TAC NO. M95897)
Dear Mr. Dugger:
By letter dated July 1,1996, Entergy Operations, Inc. (E0I) i -
m ed an issue that a certain valve at Waterford Steam Electric Station, Unit 3 (Waterford 3) does not meet the design provisions stated in paragraph NC-7153 of Section III of the ASME Boi'er and Pressure Vessel Code (1971 Edition) for Class 2 components.
You requested that E01 be allowed to permanently retain the ine.alled configuration of a manual stop (block) valve located in series l
with an overpressure protection relief device in the Chemical and Volume Control System and use specific administrative controls to verify its position at Waterford 3.
In your July 1,1996, letter, you requested that the staff authorize the installea valve configuration at Waterford 3 as an alternative to ASME Code,Section III design requirements stateu in paragraphs NC-7153 pursuant to l? CFR 50.55a(a)(3). You stated that the manual block valve and relief valve configuration provides an acceptable level of quality and safety because stringent administrative controls are in place to ensure that the block valve remains locked open when the associated components are operable.
You also statt.d that, beccuse the block valve facilitates certain maintenance activities and its removal would result in significant cost, compliance with the above ASME Code requirement would result in hardship or unusual difficulties without a compensating increase in the level of quality and safety.
We have reviewed your requat for the staff to authorize your proposed f
alternative pursuant to 10 CFR 50.55a(a)(3). We find that ASME Code,Section III requirements for Quality Group B components (ASME Code Class 2 components)
O as ::tated in 10 CFR 50.55a(d), apply to nuclear power plants whose applications for construction permits (cps) were docketed after May 14, 1984.
jL The CP for Waterford 3 was d%.keted prior to May 14, 1984. Therefore, the regulations in 10 CFR 50.55a(d) concerning ASME Code,Section III design yk requirements for Class 2 components do not apply to Waterford 3.
Accordingly, authorizatien of an alternative to ASME Code,Section III design requirements pursuant to 10 CFR 50.55a(a)(3) is unnecessary and inappropriate for Waterford 3.
9710010278 970917 So" le!!"
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f September 17, 1997 Mr. Charles M. Dugger In the Final Safety Analysis Report, you committed to design and construct Waterford 3 in accordance with ASME Code,Section III design provisions.
In j
your July 1,1996, letter, you identified an ASME Code Class 2 manual block valve installed in the Waterford 3 plant that did not meet the design requirements of ASME Code,Section III, paragraphs NC-7153. The Nuclear Regulatory Commission staff views the discovered condition of non-compliance l
with the ASME Code,Section III design provisions as a deviation from plant l
licensing commitments. Accordingly, you may control (modify) your design in accordance with 10 CFR Part 50, Appendix B, or revise your licensing basis to l
accept the deviation as-is, by either performing an evaluation of the discovered condition pursuant to 10 CFR 50.59, or submitting a license amendment application.
On the basis of the above evaluation, the staff concludes that,9thorization of an alternative or relief from ASME Code,Section III design p 9 visions for ASME Code Class 2 components is unnecessary and inappropriate for 'Jaterford 3.
)
You may desire to conform the design or accept the discovered deviation from your licensing commitments as a " change" to Waterford 3 facility by evaluating it in accordance with 10 CFR 50.59, or otherwise requesting a license amendment.
This completes our actions on TAC No M95897.
Sincerely, Orig. signed by Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-382 cc:
See next page DISTRIBUTION:
Docket File. -
PUBLIC PD4-1 r/f G. Hill (2)
C. Patel W. Beckner C. Hawes T. Gwynn, RIV E. Adensam (EGAl)
J. Clifford ACRS T. Hiltz, RIV OGC Document Name: WAT95U7.LTR See previous concurrence
- OFC PM/PD4-1,n LA/PD4-1 OGC*
(/()h/Pph-1 C NAME CPatel/kw CHawes /7///M MYoung JC N k b l DATE 9 //7 /97 9////97 09/05/97 7/(7/97
'[
COPY
[E3/N0 YES/N0 YES/NO YES/@
OFFICIAL RECORD COPY
- j-Mr. Charles M. Dugger In the Final-Safety Analysis Report, you committed to design and construct Waterford 3.in accordance with ASME Code,Section III design provisions.
In-your July 1,1996, letter, you identified an ASME Code Class 2 manual block
- valve' installed in the Waterford 3 plant that did not meet the design requirements of ASME Code,Section III, paragraphs NC-7153. The Nuclear Regulatory Commission staff views the discovered condition of non-compliance with the ASME Code,Section III design provisions as a deviation from plant licensing commitments. Accordingly, you may desire to revise your licensing basis to accept the deviation as-is, and to either perform an evaluation of the discovered condition pursuant to 10 CFR 50.59, or submit a license amendment application.
On the basis of the above evaluation, the staff concludes that authorization of an alternative or relief from ASME Code i
ASME Code Class 2 components is unnecessary,Section III design provisions for and inappropriate for Waterford 3.
You may desire to accept.the discovered deviation from your licensing i
commitments as a " change" to Waterford 3 facility and evaluate it in I
accordance with 10 CFR 50.59, or otherwise request a license amendment.
This completes our actions on TAC No. M95897.
Sincerely, Chandu P. Patel, Project Manager f
Project Directorate IV-1
/
Division of Reactor Projects III/IV
/
Office of Nuclear Reactor Regulation Docket No. 50-382 cc:
See next page DISTRIBUTION:
Docket File
/UBLIC PD4-1 r/f G. Hill (2)
C. Patel W. Beckner C. Hawes T. Gwynn, RIV E. Adensam (EGA1)-
J. Clifford ACRS T. Hiltz, RIV OGC Document Name:
AT95897.LTR 0FC PM/PB4-1 LA/PD4-1 OGCMf foY (A)D/PD4-1 NAME CPatel/ww CHawes0/hd 2M/suf JClifford DATE / / /97 f/d/97 9/ /97
/ /97 COPY' YES/NO YES/NO MNO YES/N0 3
0FFICIAL RECOR)-COPY i
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Mr. Charles M. Dugger In the Final Safety Analysis Report, you comitted to design and const:uct Waterford 3 in accordance with ASME Code, Section 111 design provisions.
In ycur July 1,1996, letter, you identified an ASME Code Class 2 manual block valve installed in the Waterford 3 plant that did not meet the design requirements of ASME Code,Section III, paragraphs NC-7153. The Nuclear Regulatory Comission staff views the discovered condition of non-compliance with the ASME Code,Section III design provisions as a deviation from plant licensing commitments. Accordingly, you may control (modify) your design in accordance with 10 CFR Part 50, Appendix B, or revise your licensing basis to accept the deviation as-is, by either perfonning an evaluation of the discovered condition pursuant to 10 CFR 50.59, or submitting a license amendment application.
i On the basis of the abose evaluation, the staff concludes that authorization of an alternative or relief from ASME Code,Section III design provisions for ASME Code Class ? components is unnecessary and inappropriate for Waterford 3.
You may desire to conform the design or accept the discovered deviation from your licensing commitments as a " change" to Waterford 3 facility by evaluating it in accordance with 10 CFR 50.59, or otherwise requesting a license amendment.
This completes our actions on TAC No. M95897.
Sincerely,
$h 0 f Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket No. 50-382 cc: Sec next page
.J
Mr. Charles M. Dugger 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 F. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 l
Nuclear _ Safety & Regulatory Affairs 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 31Gv5 P. O. Box 651 Jackson, MS 39286-1995 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 Licensing Manager Entergy Operations, Inc.
P. O. Box B Killona, LA '70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502
.