ML20248H763

Forwards Rev 1 to Waterford Unit 3 Second Interval ISI Plan, in Response to NRC 980326 Rai.Extension of Sixty Day RAI Response Was Discussed W/Project Manager.Relief Request ISI2-010 Also Encl

ML20248H763
Person / Time
Site:	Waterford
Issue date:	06/04/1998
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20248H766	List: ML20248H763 ML20248H787
References
TAC-M99537, W3F1-98-0109, W3F1-98-109, NUDOCS 9806080241
Download: ML20248H763 (9)

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Tel 504 739 6242 C. Ewing,111 i

r uge; sagery a seguiawy em W3F1-98-0109 A4.05 PR June 4,1998 U.S. Nuclear Regulatory Commission i ATTN

Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Request for Additional Information Regs-ding the Waterford 3 Second 10-Year Interval inservice inspection Program Plan and Associated Requests for Relief (TAC Numbe- M99537)

Gentlemen:

Entergy Operations, Inc. submitted the Second 10-year Intervel Inservice Inspection (ISI) Plan for Waterford 3 Steam Electric Station by Letter W3F1-97-0170, dated July 1,1997. Additionalinformation regarding the submittal was subsequently requested via an NRC letter dated March 26,1998. Entergy personne! on May 14,1998, held a telephone conference call with NRC staff and its contractor to clarify the NRC Request for Additional Information (RAI). On May 26,1998, extension of the sixty day RAI response was discussed with the NRC Project Manager.

In accordance with the RAI and conference call discussions, the following information is provided to assist in the review of the Waterford 3 Steam Electric Station Inservice Inspection (ISI) Plan:

Attachment 1 RAI Responses Attachment 2 Waterford 3 SES ISI Plan (Revision 1)

(- Attachment 3 Listing of Waterford 3 SES ISI Plan j (Revision 1) Non-Administrative Changes

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i 99060e0241 990604 PDR ADOCK 05000382 g PDR x

_ _ _ _ _ _ _ _ _ _ _ - _ _ _ ____ n

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l Request for Additional Information Regarding the Waterford 3 Second 10-Year Interval inservice Inspection ,

Program Plan and Associated Requests for Relief I

(TAC Number M99537)  ;

W3F1-98-0109  !

Page 2 June 4,1998 I

Attachment 4 Waterford 3 SES Letter on Use of ASME Code Case N-481 Attachment 5 NRC Letter on ASME Code Case N-481 l Attachment 6 Relief Request ISl2-010 As requested in the RAl, a copy of the response information provided in this submittal is being forwarded to Idaho National Engineering and Environmental )

Laboratory (INEEL) to facilitate the NRC contractor's review. '

If you have any questions concerning this submittal, please contact myself at (504) 739-6242 or Kevin Hall at (504) 739-6423. 1 Very truly yours,  ;

G.C. Ewing Director Nuclear Safety & Regulatory Affairs l ECE/PRShtk Attachments (w/ Attachments) cc: E.W. Merschoff, NRC Region IV C.P. Patel, NRC NRR NRC Resident inspector (w/ Attachments & Drawings)

M.T. Anderson (INEEL) l (w/o Attachments) cc: J. Smith, N.S. Reynolds

ATTACHMENT 1 TO W3F1-98-0109 RAIRESPONSES

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l Attachment 1 l

Response to the Request for Additional information 1 Waterford 3 Second 10-Year interval inservice Inspection  !

! Program Plan l l

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1. ScopeIStatus of Review i

The staff has reviewed the available information in the Entergy Operations l Waterford-3 Steam Electric Station inservica inspection Plan, Second 10-Year  !

Interval, Revision 0, submitted by Letter W3F1-97-0170 on July 1,1997, and the requests for relief from the ASME Code Section XI requirements.

2. AdditionalInformation Reciuired Based on the above review, the staff requested additionalinformation and/or clarification. The questions and responses are as follows:

item A The licensee has identified ten Code Cases that willbe 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 9/17B7. The remaining three have not l been approved. The licensee states that the Code Cases that were nut approved in Revision 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 included in the Waterford-3 Second IntervalISI Plan. 1 If Revision 12 has not been approved prior to the end of the 1st period or when needed by the plant, relief will be submitted to cover the areas addressed by the Code Cases."

IWA-2441 (c) of Section XI requires that Code Cases shallbe in effect at the time the

!nspection 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 attematives to Code requirements. When used, these Code Cases must be l implemented in their entirety. The licensee may adopt an approved Code Case by i providing written notification to the NRC. Published Code Cases awaiting approval i and subsequent listing in Regul story Guide 1.147 may be adopted only if the l licensee requests, and the NRC authorizes, their use on a case-by-case basis.

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To complete the review of the licensee's submittal, all Code Cases to be used in the inspection plan are requimd 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.

Response to item A The five (5) Code Cases identified as being contained in Draft Revision 12 to Regulatory Guide 1.147 have been removed from the Waterford 3 ISI Plan (Revision 1), Section 3. Three of the Code Cases, N-416-1, N-509, and N-524 have been approved for use via corporate Entergy Operation, Inc. relief requests and are referenced in Section 4 of the plan. A request to invoke Code Case N-521 is included as Attachment 6 of this response. it has been determined that Code Cases N-498-1 and N-522 are not needed at this time; therefore, they will not be included in this submittal.

Item B Provide a list of allprocedures that will be usedin 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.

(Note: The NRC's contractor clarified this question during the May 14,1998, conference call, and limited the scope of this question to a list of the NDE procedures used in the implementation of ISI.)

Response to item B The following is a list of the NDE Procedures used at Waterford 3 in the implementation of ISI:

PROC. NO. TITLE QAP-369 Magnetic Particle Exam (Direct Magnetization and coil Methods) ASME,Section XI QAP-374 Lir"d Penetrant Examination (PT) Water Washable, Fluorescent ASME,Section XI

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l QAP-380 Magnetic Particle Examination (Yoke Method) ASME Section XI QAP-381 Liquid Penetrant Examination (PT) Solvent Removable ASME,Section XI f

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l QAP-384 Visual Examination VT-1 QAP-385 Visual Examination VT-2 QAP-386 Visual Examination VT-3 QAP-390 Ultrasonic Examination Similar and Dissimilar Metal Piping Welds (Sec XI)

QAP-391 Ultrasonic Examination for the Detection of Outer Diameter (OD) Degradation of Studs 2 inches or Greater with Bore Holes QAP-392 Manual Ultrasonic Examination for Vessel Nozzle Inside Radius OAP-393 Manual Ultrasonic Examination of Welds in Vessels OAP-396 Manual Ultrasonic Examination of Bolts and Studs QAP-398 Ultrasonic Examination for the Detection of Intergranular Stress Corrosion Cracking QAP-399 Ultrasonic Examination Procedure for the Sizing of IGSCC QAP-403 Visual Examination VT-2 for Code Case N-416-1 QAP-404 Eddy Current Examination of Reactor Coolant Pump Flywheels ite m C IWB-1220, IWC-1220, and IWD-1220 of ASME"Section XI provide mies for exempting cer;ein Class 1, 2 and 3 components imm examination. Appendix F gives nonmandatory guidance forinspection 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 exempt lon criteria applied to each system covered by Section XI.

Response to item C The exemption criteria have been added to the Waterford 3 SES ISI Plan in Sections 1.3,1.4,1.5, and 1.6.

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Ite m 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 Progmm.

Response to item D Enclosed with this submittal are the requested drawings which are listed in the Waterford 3 SES ISI Plan (Revision 1), Section 1.17 (Attachment 2).

Item 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 am 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 conceming any other examination items that may fall within B-F that are planned under B-J that may affect examination percentages.

Response to item E The only Class 1 dissimilar metal vessel welds are contained in the Pmssurizer.

Nozzle-to-Safe End Welds16-017,26-010,26-006,26-001, and 25-029 are the only welds that meet the category requirements. These welds were incorrectly classified and have been moved to Examination Category B-F. Five random Examination Category B-J piping welds have been added to Examination Category B-J to maintain the required examination percentages.

Item 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 ln Examination Categories B-G-1 and B-G-2 are also selected for examination under Categories B-L-2 and B-M-2 for intemalinspections, which are performed when disassembled. The licensee states in Note 1 of Section 5, "Because B-G-1 and B-G-2 bolting containedin pumps and 4

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1 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 pedod 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 forpumps, and valves, examinations are limited to those components " selected" for examinations under Examination Categodes, 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 espection plan for Category B-G-1 and B-G-2 that will meet the requirements ofIWB-2412-1, independent from disassembling the subject component.

Response to item F The Examination Categories B-G-1 and B-G-2 bolting examinations have been scheduled in the Waterford 3 SES ISI Plan, Revision 1 (See Section 6 of the plan for details) to meet the Table IWB-2412-1 percentage requirements.

Ite m 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 shallbe submitted to the regulatory and enforcement authorities havingjudsdiction at the plant site for the review. Provide information conceming the status of the required evaluation.

Response to item G Attachments 4 and 5 provide the required information concerning the status of the l required evaluation.

Ite m H Provide the staff with the status of the augmented reactorpressure vessel examinations required by 10 CFR 50.55a(g)(6)(ii)(A), effective September 8,1992, 1 and provide a technical discussion descdbing how the regulation washvill be

implemented at Waterford 3 Nuclear Plant. Include in the discussion a descdption of the approach and any specialized techniques or equipment that waskill be used to complete the r: quired augmented examination. 10 CFR 50.55a(g)(6)(ii)(A)(2) requires that " essentially 100%"of the volume of each weld be examined. Confinn that " essentially 100%" of each Examination Category B1.10 weld (RPV sheII welds)  ;

has been examined, or that an allemative has been submitted for staff review. Also, \

provide the percent of the volume examined for each weld.

Response to item H The Augmented Reactor Pressure Vessel examinations were completed at Waterford 3, during Refueling Outage 07. Relief will be required due to less than 90% coverage of several welds. Howeve, these exams are 1st interval ,

examinations and thus will be discussed under a future submittal as agreed to by the l NRC during the May 14,1998 conference call. I I

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Vedfy that there are no requests forreliefin addition to those submitted. If additional requests for relief are requimd, the licensee should submit them for staff review.

Response to item I Attachment 6, Relief Request 1S12-010, is a request for relief for your review. There are no other requests to be submitted at this time.

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