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EPID:L-2020-LLR-0160, Arkansas, Units 1 and 2; Grand Gulf, Unit 1; River Bend, Unit 1; and Waterford, Unit 3, Relief Request Number EN-20-RR-003, Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-711-2, Alternative Examination Cove (Open) |
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MONTHYEARML20365A0882020-12-30030 December 2020 Arkansas, Units 1 and 2; Grand Gulf, Unit 1; River Bend, Unit 1; and Waterford, Unit 3, Relief Request Number EN-20-RR-003, Proposed Alternative to Use American Society of Mechanical Engineers Code Case N-711-2, Alternative Examination Cove Project stage: Request ML21022A1692021-01-22022 January 2021 NRR E-mail Capture - Entergy Fleet (ANO, Grand Gulf, River Bend, and Waterford) - Acceptance Review for RR EN-20-RR-003, Proposed Alternative to Use ASME Code Case N-711-2 Project stage: Acceptance Review ML21299A0032021-10-28028 October 2021 And Waterford Steam Electric Station, Unit 3 - Approval of Request for Alternative EN-20-RR-003 from Certain Requirements of the ASME Code Project stage: Other 2021-01-22
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Category:Code Relief or Alternative
MONTHYEARML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines ML23270B9932023-09-29029 September 2023 Request to Update ASME Boiler & Pressure Vessel Code Relief Request SE with NRC-Approved Revision of Bwrip Guidelines (GG-ISI-020 & RBS-ISI-019) (EPID L-2022-LLR-0090) - Non-Proprietary ML23142A1062023-05-24024 May 2023 Authorization and Safety Evaluation for Alternative Request No. ANO1-ISI-035 ML22073A0952022-04-0707 April 2022 Approval of Request for Alternative from Certain Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (EPID L-2021-LLR-0084) (NON-PROPRIETARY) ML21293A0962021-10-28028 October 2021 Relief ANO2-R&R-012 Concerning Proposed Alternative for Repair of Reactor Vessel Closure Head Penetration 46 ML21294A0672021-10-28028 October 2021 Inservice Testing Program Relief Request VRR-GGNS-2021-1, Alternative Request for Pressure Isolation Valve Testing Frequency ML21299A0032021-10-28028 October 2021 And Waterford Steam Electric Station, Unit 3 - Approval of Request for Alternative EN-20-RR-003 from Certain Requirements of the ASME Code ML21258A4082021-09-21021 September 2021 Request to Update ASME Code Relief Request Safety Evaluations with NRC-Approved Revision of Boiling Water Reactor Vessel and Internals Project Guidelines ML21230A2062021-09-0303 September 2021 Proposed Alternative to Use ASME OM Code Case OMN-28 ML21216A2202021-08-0505 August 2021 Proposed Alternative to Eliminate Certain Documentation Requirements for Pressure Retaining Bolting ML21168A0562021-07-0909 July 2021 Approval of Request for Alternative from Certain Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code ML21118B0392021-05-19019 May 2021 Approval of Request for Alternative from Certain Requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code ML21054A3302021-02-24024 February 2021 Approval of Alternative IP3-ISI-RR-16 to American Society of Mechanical Engineers Code Case N-513-4 Inspection Requirement ML20365A0012021-01-19019 January 2021 Relief Request 5-8 Related to ASME Code Case N-729-4 Supplemental Examination Requirements of Reactor Vessel Closure Head Penetration Nozzles ML20282A7642020-10-16016 October 2020 Request for Withholding Information from Public Disclosure for Palisades Nuclear Plant - Relief Request 5-8 for Alternate Repair of Reactor Closure Head Penetration Nozzles ML20275A3432020-10-0101 October 2020 Verbal Authorization for Proposed Alternative (RR 5-8) Reactor Vessel Closure Head Penetration Repairs ML20269A2002020-09-30030 September 2020 Request to Use a Provision of Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI (EPID L2020-LLR-0117 ML20272A1662020-09-30030 September 2020 Attachment 3 - Framatome Document No. ANP-3876, Revision 1Q1NP, Response to NRC Request for Additional Information of Palisades Relief Request Number RR 5-8, Repair of Reactor Pressure Vessel Head Penetration, Inservice Inspection Program, ML20267A3872020-09-23023 September 2020 Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations ML20267A3882020-09-23023 September 2020 Attachment 1 - Relief Request Number RR 5-8, Proposed Alternative to ASME Section XI Code Requirements for Repair of Reactor Pressure Vessel Head Penetrations CNRO-2020-00016, Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv)2020-08-12012 August 2020 Entergy Nuclear Operations, Inc - Relief Request EN-RR-20-002: Proposed Use of Subsequent ASME Code Edition and Addenda in Accordance with 10 CFR 50.55a(g)(4)(iv) ML20121A1932020-05-0606 May 2020 Alternative Requests for the Fifth 10 Year Interval Inservice Testing of Low Pressure Safety Injection Pumps and Service Water Valves ML20119A0732020-04-29029 April 2020 Withdrawal of Requested Alternatives for the Fifth 10-Year Interval Inservice Testing of Service Water Pumps and Visual Examination of Snubbers ML20099D9552020-04-17017 April 2020 Request to Use Provisions in the 2013 Edition of the ASME Boiler and Pressure Vessel Code for Performing Non-Destructive Examinations ML20083J9682020-03-26026 March 2020 Approval of Request for Alternative ANO 2-PT-002 End-of-Internal System Leakage Test for Extended Reactor Coolant Pressure Boundary Piping ML20022A2582020-01-28028 January 2020 Re-Issuance of Approval of Relief Request WF3-RR-19 2, Relief from the Requirements of Asme Code Section XI Regarding Alternate Repair of Degraded Drain Line of Chemical and Volume Control ML20002A0202020-01-13013 January 2020 Approval of Relief Request WF3-RR-19-2, Relief from the Requirements of Asme Code Section XI Regarding Alternate Repair of Degraded Drain Line of Chemical and Volume Control System ML19269C5342019-09-27027 September 2019 Proposed Alternative to Use Encoded Phased Array Ultrasonic Examination Techniques ML19254A6032019-09-19019 September 2019 Units 2 and 3; Palisades Nuclear Plant; River Bend; and Waterford Steam Electric Station, Unit 3 - Relief Request No. EN-19-RR-1, Use of ASME Code Case N-831-1 ML19247B1972019-09-0909 September 2019 Approval of Relief Request W3-ISI-032,Relief from the Requirements of ASME Code Section XI Regarding Volumetric Examination ML19232A0252019-08-27027 August 2019 Authorization of Proposed Alternative to ASME Code Section XI, IWA-4000, Repair/Replacement Activities 2CAN071902, Request for Alternative ANO 2-PT-002 End-of-Interval System Leakage Test for Extended Reactor Coolant Pressure Boundary Piping2019-07-25025 July 2019 Request for Alternative ANO 2-PT-002 End-of-Interval System Leakage Test for Extended Reactor Coolant Pressure Boundary Piping W3F1-2019-0052, CFR 50.55a Relief Number WF3-RR-19-2, Proposed Alternative to Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 1 in Accordance with 10 CFR 50.55a(z)(2)2019-07-18018 July 2019 CFR 50.55a Relief Number WF3-RR-19-2, Proposed Alternative to Code Case N-666-1, Weld Overlay of Class 1, 2, and 3 Socket Welded Connections, Section XI, Division 1 in Accordance with 10 CFR 50.55a(z)(2) ML19184A5542019-07-15015 July 2019 Request for Relief ANO1-ISI-032 from the ASME Code Section XI Visual Examination Requirements for the Fourth 10-Year Inservice Inspection Interval ML19135A4442019-06-21021 June 2019 Issuance of Relief Request I4R-22 Relief from the Requirements of the ASME Code ML19156A4002019-06-11011 June 2019 Request for Alternative ANO2-ISI-021 to Permit Continued Application of the 2007 Edition Through the 2008 Addenda of ASME Code ML19161A2572019-06-0404 June 2019 BWR Fleet Msv/Srv - Testing Frequency Relief Request NRC Pre-Application Meeting June 4, 2019 ML19098A0342019-04-30030 April 2019 Units 1 and 2; Limerick, Units 1 and 2; Peach Bottom, Units 2 and 3, and Quad Cities, Units 1 and 2 - Revision to Approved Alternative to Use BWR Vessel and Internal Proj Guidelins ML19039A1492019-02-25025 February 2019 Issuance of Relief Request IP3-ISI-RR-14 Alternative Examination Required by ASME Code Case N-724-4 JAFP-19-0023, Relief Request Associated with the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography for Ferritic and Austenitic Piping Welds2019-02-15015 February 2019 Relief Request Associated with the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography for Ferritic and Austenitic Piping Welds CNRO-2019-00002, Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 12019-01-31031 January 2019 Relief Request Number EN-19-RR-1, Proposed Alternative to Use ASME Code Case N-831-1, Ultrasonic Examination in Lieu of Radiography for Welds in Ferritic or Austenitic Pipe Section XI, Division 1 RBG-47913, Request for Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii) Proposed Alternative to CFR 50.55a Examination Requirements for Third Interval Volumetric Exams (RBS-ISI-021)2018-11-30030 November 2018 Request for Alternative in Accordance with 10 CFR 50.55a(g)(5)(iii) Proposed Alternative to CFR 50.55a Examination Requirements for Third Interval Volumetric Exams (RBS-ISI-021) W3F1-2018-0065, Request for Relief from ASME Section XI Volumetric Examination Requirements - Third 10-Year Interval, W3-ISI-0322018-11-30030 November 2018 Request for Relief from ASME Section XI Volumetric Examination Requirements - Third 10-Year Interval, W3-ISI-032 ML18310A0132018-11-16016 November 2018 Relief from the Requirements of the ASME Code to Use Boiling Water Reactor Vessel Internals Guidelines as an Alternative ML18299A2732018-11-0707 November 2018 Request for Relief from Requirements of Asme Code RBS-ISI-016 from the Requirements of the ASME Code for Pressure Retaining Welds in Control Rod Housings (EPID-L-2018-LLR-0042) ML18251A0042018-09-18018 September 2018 Safety Evaluation for Relief Request IP3-ISI-RR-11, RR-12, RR-15 Approval of Alternative Associated with Extension of Fourth Interval Reactor Vessel and Piping Weld Inspections (EPID: L-2017-LLR-0124,0127) JAFP-18-0076, End of Interval Relief Request Associated with the Fourth Ten-Year Lnservice Inspection (ISI) Interval2018-07-26026 July 2018 End of Interval Relief Request Associated with the Fourth Ten-Year Lnservice Inspection (ISI) Interval ML18193B0302018-07-18018 July 2018 Safety Evaluation for Relief Request IP3-ISI-RR-13 Fourth Ten-year Inservice Inspection Interval Extension ML18128A0672018-06-0808 June 2018 Arkansas, Units 1 and 2; Grand Gulf, Unit 1; Indian Point Unit Nos. 2 and 3; Palisades; Pilgrim; River Bend Station, Unit 1; and Waterford, Unit-3 Relief Request No. EN-17-RR-1, Alternative to Use ASME Code Case N-513-4 JAFP-18-0052, Proposed Alternative to Utilize Code Case N-8792018-05-30030 May 2018 Proposed Alternative to Utilize Code Case N-879 2023-09-29
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October 28, 2021
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2; GRAND GULF NUCLEAR STATION, UNIT 1; RIVER BEND STATION, UNIT 1; WATERFORD STEAM ELECTRIC STATION, UNIT 3 -
APPROVAL OF REQUEST FOR ALTERNATIVE EN-20-RR-003 FROM CERTAIN REQUIREMENTS OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE (EPID: L-2020-LLR-0160)
LICENSEE INFORMATION
Recipients Name and Address : Mrs. Mandy Halter Vice President, Regulatory Assurance Entergy Services, LLC M-ECH-29 1340 Echelon Parkway Jackson, MS 39213
Licensee: Entergy Operations, Inc.
Plant Names and Units: Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; River Bend Station, Unit 1; Waterford Steam Electric Station, Unit 3
Docket Nos.: 50-313, 50-368, 50-416, 50-458, and 50-382
APPLICATION INFORMATION
Submittal Date: December 30, 2020
Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML20365A088
Supplement Date(s): NA
Supplement ADAMS Accession No.: NA
Licensee Proposed Alternative No. or Identifier: EN-20-RR-003
Applicable Regulation: Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.55a(z)(1)
Applicable Code Requirements: American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code)Section XI coverage requirements described in Examination Categories B-F, B-J, Table IWB-2500, and Examination Categories C-F-1, C-F-2, Table IWC-2500. The licensee is also using ASME Code Case N-716-1, Alternative Piping Classification and Examination Requirements,Section XI, Division 1.
Applicable Code Edition and Addenda: ASME Code,Section XI, 2007 Edition through 2008 Addenda.
Brief Description of the Proposed Alternative: The licensee has requested to apply the examination volumes described in ASME Code Case N-711-2, Alternative Examination Coverage Requirements for Examination Category B-F, B-J, C-F-1, C-F-2, and R-A Piping Welds, in instances where coverage of the examination volumes do not meet the essentially 100 percent requirements due to configuration and material limitations (essentially 100 percent coverage is achieved when the applicable examination coverage is greater than 90 percent).
The licensee also stated that they will follow the conditions placed on ASME Code Case N-711-1 in Regulatory Guide (RG) 1.147, Inservice Inspection Code Case Acceptability, ASME Section XI, Division 1 restricting the use of the code case for preservice examinations or when the postulated degradation mechanisms are primary water stress corrosion cracking (PWSCC) and crevice corrosion.
For additional details on the licensees submittal, please refer to the document located at the ADAMS Accession No. identified above.
REGULATORY EVALUATION
Adherence to Section XI of the ASME Code is mandated by 10 CFR 50.55a(g)(4), Inservice inspection standards requirement for operating plants, which states, in part, that ASME Code Class 1, 2, and 3 components will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in the ASME Code,Section XI.
Section 10 CFR 50.55a(z), Alternative to codes and standards requirements, of 10 CFR states, in part, that alternatives to the requirements of 10 CFR 50.55a(b)-(h) may be used, when authorized by the Director, Office of Nuclear Reactor Regulation, if (1) the proposed alternatives would provide an acceptable level of quality and safety or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The licensee has submitted this request on the basis that a proposed alternative would provide an acceptable level of quality and safety.
TECHNICAL EVALUATION
The alternate inspection volumes described in ASME Code Case N-711-2 are chosen based on the locations where degradation and cracking are expected to occur and take features such as counterbore into account. While the inspection volumes in ASME Code Case N-711-1 are usually in different areas than those described in ASME Code,Section XI, these new inspection volumes in ASME Code Case N-711-2 are usually larger than those in ASME Code,Section XI.
ASME Code Case N-711-2 is very similar to ASME Code Case N-711-1, which is currently listed in RG 1.147 as conditionally approved for use. The conditions described in RG 1.147 are that Code Case N-711-1 shall not be used to redefine the required examination volume for preservice examinations or when the postulated degradation mechanism for piping welds is PWSCC or crevice-corrosion degradation mechanisms.
In ASME Code Case N-711-1, 100 percent of the alternative inspection volume must be examined, with no provision for missing small areas of the alternative inspection volume. This larger inspection volume and combined with the lack of flexibility for missing small amounts of the volume has made the implementation of ASME Code Case N-711-1 challenging in some instances. ASME Code Case N-711-2 makes only one change from Code Case N-711-1. In ASME Code Case N-711-2 the requirement is that the examinations performed are required to cover essentially 100 percent of the new inspection volume as opposed to 100 percent of the new inspection volume. This is a relatively small change and provides flexibility when performing and evaluating the examinations with no significant impact on the examination.
The proposed alternative EN-20-RR-003 states that the licensee will continue to comply with the U.S. Nuclear Regulatory Commission (NRC) conditions placed on the use of ASME Code Case N-711-1. The use of ASME Code Case N-711-2 will not be used to redefine the required examination volume for preservice examinations or when the postulated degradation mechanism for piping welds is PWSCC or crevice-corrosion degradation mechanisms.
As the change in ASME Code Case N-711-2 is minor, and the conditions for the use of Code Case N-711-1 will be followed by the licensee in this proposed alternative, the NRC staff determines that the licensees proposed alternative is acceptable because it provides reasonable assurance that the reduction in inspection volume would not have a significant impact on the examinations ability to find flaws if they are present.
CONCLUSION
The NRC staff has determined that the proposed alternative in the licensees request referenced above would provide an acceptable level of quality and safety.
The NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(1).
The NRC staff authorizes the use of proposed alternative EN-20-RR-003 at Arkansas Nuclear One, Unit 1 to May 30, 2027; at Arkansas Nuclear One, Unit 2 to March 25, 2030; at Grand Gulf Nuclear Station, Unit 1 to November 30, 2026; and at River Bend Station, Unit 1 and Waterford Steam Electric Station, Unit 3 to November 30, 2027.
All other ASME BPV Code,Section XI requirements for which an alternative was not specifically requested and approved in this proposed alternative remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Stephen Cumblidge, NRR
Date: October 28, 2021
Jennifer L. Dixon-Herrity, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
ML21299A003 *concurrence via email OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NRR/DNRL/NPHP/BC*
NAME SLingam PBlechman MMitchell DATE 10/25/21 10/26/21 10/25/21 OFFICE NRR/DORL/LPL4/BC NAME JDixon-Herrity DATE 10/28/21