ML20217F258
| ML20217F258 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/26/1998 |
| From: | Chandu Patel NRC (Affiliation Not Assigned) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M99537, NUDOCS 9803310327 | |
| Download: ML20217F258 (7) | |
Text
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,. ! Mr. Charle's M. Duggor :
. March 26, 1998
' Vice President Operations Entergy Operations, Inc.
P. O. Box B -
Killona, LA 70066 L
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE WATERFORD - 3 SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC NO.
M99537).
f Daar Mr. Dugger:
The Nuclecr Regulatory Commission (NRC), with assistance from its contractor, the Idaho
. National Engineering and Environmental Laboratory (INEEL),' is reviewing and evaluating the
. second 10-year interval inservice inspection program plan and associated requests for relief
' for Waterford Steam Electric Station, Unit 3 (Waterford-3) submitted by letter dated July 1, 1997.' Additional information is required from Entergy Operations, Inc., in order for the NRC staff to complete its review.
We request that you provide your response to our enclosed request for additional information
- (RAI) within sixty days to meet our review schedule. In addition, please send a copy of the RAI response to our contractor, INEEL, at the following address:
MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 ldaho Falls, Idaho 83415-2209 Sincerely, ORIGINAL SIGNED BY:
Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Request For AdditionalInformation cc w/ enc!: See next page i
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March 26, 1998 Mr. Charles M. Dugger Vice President Operations Entergy Operations, Inc.
P. O. Box B Killona, LA 70066
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING THE WATERFORD-3 SECOND 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN AND ASSOCIATED REQUESTS FOR RELIEF (TAC NO.
M99537)
Dear Mr. Dugger:
The Nuclear Regulatory Commission (NRC), with assistance from its contractor, the Idaho National Engineering and Environmental Laboratory (INEEL), is reviewing and evaluating the second 10-year interval inservice inspection program plan and associated requests for relief for Waterford Sterm Electric Station, Unit 3 (Waterford 3) submitted by letter dated July 1, 1997. Additional information is required from Entergy Operations, Inc., in order for the NRC staff to complete its review.
We request that you provide your response to our enclosed request for additional information (RAI) within sixty days to meet our review schedule, in addition, please send a copy of the RAI response to our contractor, INEEL, at the following address:
MichaelT. Anderson INEEL Research Center 2151 North Boulevard P.O. Box 1625 Idaho Falls, Idaho 83415-2209 Sincerely, D
A4 f. f Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects !!!/IV Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
Request For Additional Information cc w/enet: See next page J
1 i
-j Mr. Charles M. Dugger Entergy Operations, Inc.
Waterford 3 oc' l
I 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 Jackson, MS 39286 Parish President Council St. Charles Parish Director' P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville,l.A 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 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 j
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ENTERGY OPERATIONS INC.
WATERFORD-3 DOCKET NUMBER 50-382 Reauest for Additional Information - Second 10-Year Interval inservice (ISI) Inspection Proaram Elan 1.
Scope / Status of Review 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 requirements, except design and access provisions and preservice examination requirements, set forth in Section XI of the ASME Code, " 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 inspection intervals 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 an 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. The Entergy Operations Inc. (the licensee), has prepared the Entergy Operations Waterford-3 Steam Electric Station Inservice inspection Plan, Second 10-Year /nterval, Revision 0, to meet the requirements of the 1992 Edition with portions of the 1993 Addenda of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI.
The staff has reviewed the available information in the Entergy Operations Waterford-3 Steam Electric Station Inservice Inspection Plan, Second 10-Year Interval, Revision 0, submitted on July 1,1997, and the requests for relief from the ASME Code Section XI requirements.
2.
AdditionalInformation Reauired Based on the above review, the staff has concluded that additionalinformation and/or clarification is required to complete the review of the ISI Program Plan.
A.
The licensee has identified ten Code Cases that will be used at Waterford-3.
Of these, four are approved in NRC Regulatory Guide 1.147, Revision 11.
~
Three have been approved in SERs dated 9/4/97 and 9/17/97. The remaining three have not been approved. The licensee states that the Code Cases that were not approved in Revison 11 of NRC Regulatory Guide 1.147 are included in the draft of Revision 12. The licensee also stated that "since approval of the Draft Reg Guide is imminent, these Code Cases have been irscluded in the Waterford-3 Second Interval ISI Plan. If Revision 12 has not been approved prior to the end of the 1" period or when needed by the plant, relief will be submitted to cover the areas addressed by the Code Cases."
ENCLOSURE
2 IWA-2441(c) of Section XI equires that Code Cases shall be in effect at the time the inspection Plan is filed with the regulatory and enforcement authorities having jurisdiction at the plant site. Also,in accordance with 10 CFR 50.55a(c)(3),
10 CFR 50.55a(d)(2), and 10 CFR 50.55a(e)(2), ASME Code Cases may be used as altematives to Code requirements. When used, these Code Cases must be implemented in their entirety. The licensee may adopt an approved Code Case by providing written notification to the NRC. Published Code Cases awaiting approval and subsequent listing in Regulatory Guide 1.147 may be adopted only if the licensee requests, and the NRC authorizes, their use on a case-by-case basis.
l To complete the review of the licensee's submittal, all Code Cases to be used in the inspection plan are required to have NRC approval. The licensee should provide requests for relief for Code Cases not yet approved in RG 1.147, Revision 11, or withdraw unapproved Code Cases from the Waterford-3 Program Plan.
B.
Provide a list of all procedures that will be used in the implementation of the ISI Program Plan. Identify the procedure and provide its title and the general descriptions of the components to which each procedure is applicable.
C.
lWB-1220, IWC-1220, and IWD 1220 of ASME Section XI provide rules for l
exempting certain Class 1,2 and 3 components from examination. Appendix F gives nonmandatory guidance for inspection plan development. F-2500(b) states that inspection plans should include specific exemptions applied to each system covered by Section XI. To complete the review of the Waterford 3 Program Plan, provide the specific exemption criteria applied to each system covered by Section XI.
D.
Section 1.1 of the Waterford-3 ISI Program states that flow diagrams that show the Program / Class boundaries are attached. The table of contents specifies flow diagrams, and Section 1.17 provides a list of the applicable flow diagrams for the ISI Program. However, the referenced flow diagrams cannot be located. Provide the flow diagrams listed in the ISI Program.
E.
It appears that Pressurizer Nozzle-to-Safe End Welds16-017,26-010,26-006,26-001, and 25-029 are dissimilar metal welds and should fall within Examination Category B-F instead of Examination Category B J, as listed. The staff believes that the subject welds are incorrectly classified. This is supported by the 1992 edition of the Code, which includes, under Exam Category B-J, the statement
" dissimilar welds not covered under Category B-F." The subject pressurizer welds are covered under Category B-F. Therefore, these welds should be reclassified as B-F and the examination sample for B-J welds adjusted accordingly. Confirm that this change will be made by including these changes in the itemized listing of component examinations. Also, provide information concoming any other examination items that may fall within B-F that are planned under B-J that may affect examination percentages.
F.
In the licensee's submittal, many items in Categories B-G-1 and B-G-2 have
. remarks " examine only if disassembled." The subject items in Examination i
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' Categories B-G 1 and B-G-2 are also selected for examination under Categories B L-2, and B-M-2 for internal inspections, which are performed when disassembled. The licenses states in Note 1'of Section 5, "Because
~ B-G-1 and B G-2 bolting contained ir pumps and valves is only required to be inspected when the component is disassembled and inspected to the requirements of B-L-2 or B-M-2, percentages of completion for each period -
- may not meet the requirements of Table IWB-2412-1."
It is unclear why the licensee states that " bolting contained in pumps and valves is only required to be inspected when the component is disassembled and inspected to the requirements of B-L-2 or B-M-2." Table IWB 2500-1, Examination Category B-G-1 and B-G-2, Note 1 states that bolting may be examined: (a) in.
place under tension: (b) when the connection is disassembled; or (c) when the bolting is removed. Note 2 states, in part, that for pumps, and valves, examinations are limited to those components " selected" for examinations under Examination Categories, B-L-2, and B-M 2.
The program plan cannot be approved if " percentages of completion for each
- period may not meet the requirements of Table IWB-2412-1." Provide a detailed inspection plan for Category B-G-1 and B-G 2 that will meet the requirements of IWB-2412-1, independent from disassembling the subject component.
G.
The licensee intends to utilize Code Case N-481 for Examination Category B-L-1, Pressure Retaining Welds in' Pump Casings. Code Cases, when used, must be implemented in their entirety. N-481 (d) requires that an evaluation be performed to demonstrate the safety and serviceability of the pump casing. Code Case N-481 (e) states that a report of this evaluation shall be submitted to the regulatory and enforcement authorities having jurisdiction at the plant site for the review. Provide information concerning the status of the required evaluation.
H.
Provide the staff with the status of the augmented reactor pressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A), effective September 8, 1992,Cand provide a technical discussion describing how the regulation was/will be implemented at Waterford-3 Nuclear Plant. Include in the discussion a description of the approach and any specialized techniques or equipment that was/will be used to complete the required augmented examination.10 CFR 50.55a(g)(6)(ii)(A)(2) requires that essentially 100% of the volume of each weld be examined. Confirm that " essentially 100%" of each Examination Category B1.10 l weld (RPV shell welds) has been examined, or that an attemative has been submitted for staff review. Also, provide the percent of the volume examined for each weldi
? Note: Plants with erester that 40 months remaining in the interval on the effective date of the rule were required to perform the augmented examination in that interval.
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Verify that there are no requests for relief in addition to inose submitted if additional requests for relief are required, the licensee should submit them for staff review.
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