NL-03-183, Stations - Relief Request to Use ASME Code Case N-663

Stations - Relief Request to Use ASME Code Case N-663

ML033490593
Person / Time
Site:	Indian Point, Pilgrim
Issue date:	12/04/2003
From:	Kansler M Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ENO 2.03.126, NL-03-183, TAC MB6879, TAC MB6880, TAC MB6881, TAC MB6882
Download: ML033490593 (14)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

- Entergy 440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President December 4, 2003 NL-03-183 ENO 2.03.126 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001

SUBJECT:

Indian Point Nuclear Generating Units No. 2 and No. 3 Docket No. 50-247, and 50-286 Pilgrim Nuclear Power Station Docket No. 50-293 Relief Request to Use ASME Code Case N-663

References:

1. USNRC letter from Robert A. Gramm, dated August 26, 2003, regarding "Arkansas Nuclear One, Unit 1 (ANO-1); Grand Gulf Nuclear Station (GGNS); River Bend Station (RBS); and Waterford Steam Electric Station, Unit 3 (W3) - Request to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (CODE) Case N-663 (TAC NOS. MB6880, MB6881, MB6879, MB6882)"

Dear Sir:

Pursuant to 10CFR50.55a(a)(3)(i), Entergy Nuclear Operations, Inc. (ENO) hereby requests the Nuclear Regulatory Commission (NRC) to approve the use of an alternative to the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl requirements regarding the inspection of Class 2, Examination Categories C-F-1 and C-F-2 welds.

Enclosed are three (3) requests for relief (RRs) to use ASME Code Case N-663 for Indian Point Nuclear Generating Unit No. 2 (IP2, Enclosure 1), Indian Point Nuclear Generating Unit No. 3 (IP3, Enclosure 2), and Pilgrim Nuclear Power Station (Pilgrim, Enclosure 3). The proposed alternative would allow the plants to avoid unnecessary inspections and to conserve radiological dose, while still maintaining an acceptable level of quality and safety for the examination of the affected welds, in accordance with 10 CFR 50.55a(a)(3)(i).

These requests for relief for 1P2, 1P3, and Pilgrim are for their 3rd ISI Interval, and the applicable code of record is the 1989 Edition, No Addenda of the ASME Section Xl Code.

C(4-/7

Similar requests for relief have been granted to ANO-1, Grand Gulf, River Bend, and Waterford 3 plants (Reference 1).

Entergy requests approval of the IP2 relief request (Enclosure 1) by June 2004 to support its Fall 2004 refueling outage. Since these RRs are practically identical, Entergy requests that the IP3 and Pilgrim relief requests (Enclosures 2 and 3) be approved at the same time, although the next refueling outage for IP3 and Pilgrim are both scheduled for Spring 2005.

There are no new commitments made in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.

List of

Enclosures:

1. Indian Point Generating Station Unit No. 2, RR-68

2. Indian Point Generating Station Unit No. 3, RR 3-37

3. Pilgrim Nuclear Power Station, PRR-34

4. ASME Code Case N-663 (for information) cc:

Mr. Hubert J. Miller Resident Inspector's Office Regional Administrator, Region I Indian Point Unit 3 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 475 Allendale Road P.O. Box 337 King of Prussia, PA 19406-1415 Buchanan, NY 10511-0337 Mr. Patrick D. Milano, Sr. Project Manager Senior Resident Inspector's Office Project Directorate I Indian Point Unit 2 Division of Licensing Project Management U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation P.O. Box 38 U.S. Nuclear Regulatory Commission Buchanan, NY 10511-0038 Mail Stop 0-8-C2 Washington, DC 20555-0001 Senior Resident Inspector Pilgrim Nuclear Power Station Mr. Travis Tate, Project Manager License U.S. Nuclear Regulatory Commission Project Directorate I 600 Rocky Hill Road Division of Licensing Project Management Mail Stop 66 Office of Nuclear Reactor Regulation Plymouth, MA 02360 U.S. Nuclear Regulatory Commission Mail Stop 7-D-1 Washington, DC 20555-0001 2

Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223 Mr. Peter R. Smith, Acting President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 3

NL-03-183 / ENO Ltr 2.03.126 Enclosure I INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR-68 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

--Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Component(s) Affected Component Numbers: ASME Section Xi Class 2 piping welds Examination Category: C-F-1 and C-F-2 Item Number: C5.10 through C5.42, and C5.50 through C5.82

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements ASME Section XI IWC-2500 requires components be examined as specified in Table IWC-2500-1. These tables require a sampling of piping welds (as well as other components) be subjected to various types of non-destructive examinations (NDE, i.e.

volumetric and/or surface examinations.) For the total population of non-exempt Category C-F-1 and C-F-2 piping welds, 7.5%, but not less than 28 welds, require surface examination.

4. Reason for Request Code required surface examinations are applicable to the general population of C-F-1 and C-F-2 welds. The proposed alternatives as described in Code Case N-663 would require surface examination of areas identified as susceptible to outside surface attack, thus avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds.

5. Proposed Alternative Entergy proposes to use ASME Code Case N-663 in its entirety as an alternative to the surface examination requirements of Table IWC-2500-1 for examination categories C-F-1 and C-F-2. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Indian Point Unit 2 (IP2) Third Ten-Year Interval in accordance with Code Case N-663.

I

NL-03-183 I ENO Ltr 2.03.126 Enclosure I Basis for Use The subject item numbers in ASME Section Xl require a volumetric and/or surface exam on selected piping welds to ensure that generic degradation mechanisms are not active on either the inside diameter (I.D.) or the outside diameter (O.D.). However, these welds are selected using a deterministic set of requirements that are un-informed as to any possible degradation mechanisms. ASME Code Case N-663 provides an alternative to the current ASME Section Xl requirements for defining the number and location of surface examinations for piping components.

The ASME Section Xl Task Group on ISI Optimization, Report No. 92-01-01, Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds in Piping, dated July 1995, concluded (with 50 units responding with a total of 9333 welds inspected) only 2 welds (0.02%) were found to have flaws detected by Section Xl surface examinations. These flaws were determined to be fabrication-induced. In parallel with the above, several risk-informed Code cases have been developed for use on piping welds (e.g., ASME Code Cases N-560, N-577, and N-578). One of the methods for risk-informing piping examinations is via use of EPRI TR-1 12657, Rev. B-A, Revised Risk-informed Inservice Inspection Evaluation Procedure (NRC SER dated 10/28/99). Table 4-1, Summary of Degradation-Specific Inspection Requirements and Examination Methods, of the EPRI report lists the required degradation mechanisms to be evaluated in Class 1, 2, and 3 piping. It also identifies the risk-informed examination method required for each of these degradation mechanisms. The only degradation mechanism that requires a surface examination is O.D. chloride cracking. These two initiatives led ASME to investigate the value of surface examinations.

Code Case N-663 incorporates lessons learned from the risk-informed initiatives and industry examination experience into Section Xl by requiring that an evaluation be conducted to identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective. The results of this evaluation identify where O.D. degradation is most likely to occur by reviewing plant-specific programs and practices, and operating experience. If the potential for degradation is identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, implementing Code Case N-663 will identify appropriate locations for surface examination, if any, and eliminate unnecessary examinations. Other ASME Section XI examination requirements for the subject piping welds, including volumetric examinations and pressure testing, will continue to be performed.

Code Case N-663 was approved by the ASME Boiler and Pressure Vessel Code Committee on September, 17, 2002, but has not yet been included in the most recent listing of NRC approved code cases provided in Revision 13 of Regulatory Guide 1.147,

'Inservice Inspection Code Case Acceptability - ASME Section Xl Division 1."

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

2

NL-03-183 I ENO Ltr 2.03.126 Enclosure I Similar requests for relief have been granted to Entergy Operations, Inc.'s ANO-1, Grand Gulf, River Bend, and Waterford 3 plants (referenced TAC NOS. MB 6880, MB 6881, MB 6879, MB 6882, dated August 26, 2003.)

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for IP2.

7. Attachment Code Case N-663 (for information).

3

NL-03-183 I ENO Ltr 2.03.126 Enclosure 2 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST RR 3-37 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-I. ASME Code Component(s) Affected Component Numbers: ASME Section Xl Class 2 piping welds Examination Category: C-F-1 and C-F-2 Item Number: C5.10 through C5.42, and C5.50 through C5.82

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section Xl Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements ASME Section Xl IWC-2500 requires components be examined as specified in Table IWC-2500-1. These tables require a sampling of piping welds (as well as other components) be subjected to various types of non-destructive examinations (NDE, i.e.

volumetric and/or surface examinations.) For the total population of non-exempt Category C-F-1 and C-F-2 piping welds, 7.5%, but not less than 28 welds, require surface examination.

4. Reason for Request Code required surface examinations are applicable to the general population of C-F-1 and C-F-2 welds. The proposed alternatives as described in Code Case N-663 would require surface examination of areas identified as susceptible to outside surface attack, thus avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds.

5. Proposed Alternative Entergy proposes to use ASME Code Case N-663 in its entirety as an alternative to the surface examination requirements of Table IWC-2500-1 for examination categories C-F-I and C-F-2. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Indian Point Unit 3 (IP3) Third Ten-Year Interval in accordance with Code Case N-663.

1

NL-03-183 I ENO Ltr 2.03.126 Enclosure 2 Basis for Use The subject item numbers in ASME Section Xl require a volumetric and/or surface exam on selected piping welds to ensure that generic degradation mechanisms are not active on either the inside diameter (I.D.) or the outside diameter (O.D.). However, these welds are selected using a deterministic set of requirements that are un-informed as to any possible degradation mechanisms. ASME Code Case N-663 provides an alternative to the current ASME Section XI requirements for defining the number and location of surface examinations for piping components.

The ASME Section Xl Task Group on ISI Optimization, Report No. 92-01-01, Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds in Piping, dated July 1995, concluded (with 50 units responding with a total of 9333 welds inspected) only 2 welds (0.02%) were found to have flaws detected by Section Xl surface examinations. These flaws were determined to be fabrication-induced. In parallel with the above, several risk-informed Code cases have been developed for use on piping welds (e.g., ASME Code Cases N-560, N-577, and N-578). One of the methods for risk-informing piping examinations is via use of EPRI TR-1 12657, Rev. B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure (NRC SER dated 10/28/99). Table 4-1, Summary of Degradation-Specific Inspection Requirements and Examination Methods, of the EPRI report lists the required degradation mechanisms to be evaluated in Class 1, 2, and 3 piping. It also identifies the risk-informed examination method required for each of these degradation mechanisms. The only degradation mechanism that requires a surface examination is O.D. chloride cracking. These two initiatives led ASME to investigate the value of surface examinations.

Code Case N-663 incorporates lessons learned from the risk-informed initiatives and industry examination experience into Section Xi by requiring that an evaluation be conducted to identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective. The results of this evaluation identify where O.D. degradation is most likely to occur by reviewing plant-specific programs and practices, and operating experience. If the potential for degradation is identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, implementing Code Case N-663 will identify appropriate locations for surface examination, if any, and eliminate unnecessary examinations. Other ASME Section Xl examination requirements for the subject piping welds, including volumetric examinations and pressure testing, will continue to be performed.

Code Case N-663 was approved by the ASME Boiler and Pressure Vessel Code Committee on September, 17, 2002, but has not yet been included in the most recent listing of NRC approved code cases provided in Revision 13 of Regulatory Guide 1.147, Ulnservice Inspection Code Case Acceptability - ASME Section Xl Division I.,

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

2

NL-03-183 / ENO Ltr 2.03.126 Enclosure 2 Similar requests for relief have been granted to Entergy Operations, Inc.'s ANO-1, Grand Gulf, River Bend, and Waterford 3 plants (referenced TAC NOS. MB 6880, MB 6881, MB 6879, MB 6882, dated August 26, 2003.)

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for IP3.

7. Attachment Code Case N-663 (for information).

3

NL-03-183 / ENO Ltr 2.03.126 Enclosure 3 PILGRIM NUCLEAR POWER STATION THIRD TEN-YEAR INTERVAL INSERVICE INSPECTION PROGRAM RELIEF REQUEST PRR-34 Proposed Alternative In Accordance with 10CFR50.55a(a)(3)(i)

-Alternative Provides Acceptable Level of Quality and Safety-

1. ASME Code Component(s) Affected Component Numbers: ASME Section XI Class 2 piping welds Examination Category: C-F-1 and C-F-2 Item Number: C5.10 through C5.42, and C5.50 through C5.82

2. Applicable Code Edition and Addenda The Code of Record for the third Inservice Inspection Interval is ASME Section XI Code, 1989 Edition, No Addenda.

3. Applicable Code Requirements ASME Section XI IWC-2500 requires components be examined as specified in Table IWC-2500-1. These tables require a sampling of piping welds (as well as other components) be subjected to various types of non-destructive examinations (NDE, i.e.

volumetric and/or surface examinations.) For the total population of non-exempt Category C-F-1 and C-F-2 piping welds, 7.5%, but not less than 28 welds, require surface examination.

4. Reason for Request Code required surface examinations are applicable to the general population of C-F-1 and C-F-2 welds. The proposed alternatives as described in Code Case N-663 would require surface examination of areas identified as susceptible to outside surface attack, thus avoid unnecessary inspections and to conserve radiological dose, while still maintaining an adequate level of quality and safety for examination of the affected welds.

5. Proposed Alternative Entergy proposes to use ASME Code Case N-663 in its entirety as an alternative to the surface examination requirements of Table IWC-2500-1 for examination categories C-F-1 and C-F-2. All areas of the subject welds identified as susceptible to outside surface attack shall be surface examined during the Pilgrim Nuclear Power Station (Pilgrim)

Third Ten-Year Interval in accordance with Code Case N-663.

1

NL-03-183 I ENO Ltr 2.03.126 Enclosure 3 Basis for Use The subject item numbers in ASME Section Xi require a volumetric and/or surface exam on selected piping welds to ensure that generic degradation mechanisms are not active on either the inside diameter (I.D.) or the outside diameter (O.D.). However, these welds are selected using a deterministic set of requirements that are un-informed as to any possible degradation mechanisms. ASME Code Case N-663 provides an alternative to the current ASME Section Xi requirements for defining the number and location of surface examinations for piping components.

The ASME Section XI Task Group on ISI Optimization, Report No. 92-01-01, Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds in Piping, dated July 1995, concluded (with 50 units responding with a total of 9333 welds inspected) only 2 welds (0.02%) were found to have flaws detected by Section Xi surface examinations. These flaws were determined to be fabrication-induced. In parallel with the above, several risk-informed Code cases have been developed for use on piping welds (e.g., ASME Code Cases N-560, N-577, and N-578). One of the methods for risk-informing piping examinations is via use of EPRI TR-1 12657, Rev. B-A. Revised Risk-Informed Inservice Inspection Evaluation Procedure (NRC SER dated 10/28/99). Table 4-1, Summary of Degradation-Specific Inspection Requirements and Examination Methods, of the EPRI report lists the required degradation mechanisms to be evaluated in Class 1, 2, and 3 piping. It also identifies the risk-informed examination method required for each of these degradation mechanisms. The only degradation mechanism that requires a surface examination is O.D. chloride cracking. These two initiatives led ASME to investigate the value of surface examinations.

Code Case N-663 incorporates lessons learned from the risk-informed initiatives and industry examination experience into Section Xl by requiring that an evaluation be conducted to identify locations, if any, where a surface examination would be of benefit from a generic piping degradation perspective. The results of this evaluation identify where O.D. degradation is most likely to occur by reviewing plant-specific programs and practices, and operating experience. If the potential for degradation is identified, Code Case N-663 defines examination techniques, volumes, and frequencies. As such, implementing Code Case N-663 will identify appropriate locations for surface examination, if any, and eliminate unnecessary examinations. Other ASME Section Xl examination requirements for the subject piping welds, including volumetric examinations and pressure testing, will continue to be performed.

Code Case N-663 was approved by the ASME Boiler and Pressure Vessel Code Committee on September, 17, 2002, but has not yet been included in the most recent listing of NRC approved code cases provided in Revision 13 of Regulatory Guide 1.147, "Inservice Inspection Code Case Acceptability - ASME Section Xl Division I."

Compliance with the proposed alternatives described above will provide an adequate level of quality and safety for examination of the affected welds, and will not adversely impact the health and safety of the public.

2

NL-03-183 I ENO Ltr 2.03.126 Enclosure 3 Similar requests for relief have been granted to Entergy Operations, Inc.'s ANO-1, Grand Gulf, River Bend, and Waterford 3 plants (referenced TAC NOS. MB 6880, MB 6881, MB 6879, MB 6882, dated August 26, 2003.)

6. Duration of Proposed Alternative It is proposed to use the alternative for the remainder of the Third Inservice Inspection Interval for Pilgrim.

7. Attachment Code Case N-663 (for information).

3

ASME CODE CASE N-663 Approval Date: September 17,2002 Expiration Date: September 18, 2005 Case N-663 Alternative Requirements for Class 1 and 2 Surface Examinations Section Xl, Division 1 Inquiry: What alternative to the surface examination requirements for piping welds of Examination Catego-ries B-F, B-J, C-F-1, and C-F-2 may be used?

Reply: It is the opinion of the Committee that in lieu of the surface examination requirements for piping welds of Examination Category B-F (NPS 4 and larger),

B-J (NPS 4 and larger), C-F-1, and C-F-2, surface examinations may be limited to areas identified by the Owner as susceptible to outside surface attack.

Susceptibility to outside surface attack shall be deter-mined in accordance with Table 1.

Examination Category B-F less than NPS 4 and Examination Category B-J less than NPS 4 shall be examined in accordance with IWB-2500.

All areas identified as susceptible to outside surface attack shall be examined during each interval. The requirements of IWB-241 1, IWB-2412, IWC-241 1, and IWC-2412, as applicable, shall be met. Acceptance standards shall be in accordance with IWB-3514 or IWC-3514, as applicable. The areas shall be reexamined in the same sequence, during subsequent inspection intervals over the service lifetime of the piping item.

to the extent practical.

NL-03-183 I ENO 2.03.126 Enclosure 4 Page'l of 2

ASME CODE CASE N-663 TABLE 1 SUSCEPTIBILITY CRITERIA Mechanism Criteria External chloride stress

• austenitic stainless steel base metal, welds, or corrosion cracking heat affected zone (HAZ),

and

• operating temperature >1 50F, and

• a piping outside surface is within five pipe diameters of a probable leak path (e. g., valve stem) and is covered with nonmetallic insulation that is not in compliance with U.S.

NRC Regulatory Guide 1.36 (e.g., chloride content) or equivalent requirements or

• Austenitic stainless steel base metal, welds, or HAZ, and

• a piping outside surface is exposed to wetting from a concentrated chloride-bearing environment (e.g., seawater, brackish water, brine)

Other outside surface Items identified as susceptible to outside surface attack initiated mechanisms by a plant-specific service history review. This review should include plant-specific processes and programs that minimize chlorides and other contaminants.

NL-03-183 / ENO 2.03.126 Enclosure 4 Page 2 of 2