View source for W3F1-2018-0067, Response to NRC Request for Alternative to ASME Code Case N-770-2, Successive Examinations, Relief Request W3-ISI-031

{{Adams
| number = ML18323A611
| issue date = 11/19/2018
| title = Response to NRC Request for Alternative to ASME Code Case N-770-2, Successive Examinations, Relief Request W3-ISI-031
| author name = Halter M
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000382
| license number = NPF-038
| contact person = 
| case reference number = W3F1-2018-0067
| document type = Letter type:W, Response to Request for Additional Information (RAI)
| page count = 5
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5573 Mandy K. Halter Director, Nuclear Licensing 10 CFR 50.55a W3F1-2018-0067 November 19, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

==Subject:==
Response to NRC Request for Additional Information Regarding Request for Alternative to ASME Code Case N-770-2, Successive Examinations, Relief Request W3-ISI-031 Waterford Steam Electric Station, Unit 3 (Waterford 3)
NRC Docket No. 50-382 Facility Operating License No. NPF-38

==References:==
: 1. Entergy Operations, Inc. (Entergy) letter W3F1-2018-0060 to U. S.
Nuclear Regulatory Commission (NRC), "Request for NRC Alternative to ASME Code Case N-770-2, Successive Examinations, Relief Request W3-ISI-031," dated October 19, 2018 (ADAMS Accession Number ML18292A856)
: 2. NRC email to Entergy, "Request for Additional Information Regarding Relief Request W3-ISI-031 Code Case N-770-2," dated November 14, 2018 By letter dated October 19, 2018 (Reference 1), Entergy Operations, Inc. (Entergy) submitted Request for Alternative to the Requirements in ASME Code Case N-770-2, for the Waterford Steam Electric Station, Unit 3 (Waterford 3), for the Fourth Inservice Inspection (ISI) Interval of the ISI Program (Relief Request W3-ISI-031), pursuant to 10 CFR 50.55a.
By email correspondence dated November 14, 2018 (Reference 2), the NRC staff informed Entergy that they have reviewed the request and have determined that additional information is required to complete the review.
The enclosure to this letter provides the responses to the NRC request for additional information.
This submittal contains no new regulatory commitments.

W3F1-2018-006
Page 2 of 2 If you have any questions or require additional information, please contact the Acting Regulatory Assurance Manager, John V. Signorelli, at (504) 739-6032.
Respectfully, Mandy K. Halter MKH/mmz

==Enclosure:==
Response to NRC Request for Additional Information Regarding Relief Request W3-ISI-031 Code Case N-770-2 cc:     NRC Region IV Regional Administrator NRC Senior Resident Inspector - Waterford Steam Electric Station, Unit 3 NRR Project Manager

ENCLOSURE W3F1-2018-0067 Entergy Operations, Inc.
Request for Additional Information Regarding Relief Request W3-ISI-031 Code Case N-770-2

W3F1-2018-0067 Enclosure Page 1 of 2 Entergy Operations, Inc.
Request for Additional Information Regarding Relief Request W3-ISI-031 Code Case N-770-2

===Background===
By letter dated October 19, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18292A856), Entergy Operations Inc. (the licensee) submitted Relief Request W3-ISI-031 to Nuclear Regulatory Commission (NRC) review and approval.
Specifically, the licensee submitted a Request for Alternative to the American Society of Mechanical Engineers (ASME) Code Case N-770-2, as conditioned by 10 CFR 50.55a(g)(6)(ii)(F), for the volumetric examination of dissimilar metal butt welds associated with the suction and discharge piping of the Reactor Coolant Pumps at Waterford Steam Electric Station, Unit 3. The NRC staff has reviewed this request for alternative and has determined that the following additional information is needed in order to complete its review.
Requests for Additional Information (RAI)

===RAI 1===
Verify the following statements:
The NRC staff noted the licensee stated that it performed the required examination using techniques which were qualified in accordance with ASME Section XI, Appendix VIII, Supplement 10 for dissimilar metal welds and 10 CFR 50.55a, and administered by the Performance Demonstration Initiative (PDI) Program. This statement appears to be in compliance with the requirement to perform the required examination by Appendix VIII procedures to the maximum extent practical. Additionally, the licensee provided the results of the examinations performed during Refueling Outage 19 in Table 1 of its submittal dated October 19, 2018. These results indicate, for each of the subject welds of this proposed alternative, that 100% of the susceptible material volume was inspected.
Entergy Response The statements have been verified as correct.

W3F1-2018-0067 Enclosure Page 2 of 2

===RAI 2===
If verified, explain why a request for alternative is needed, given that the inspection results provided in Relief Request W3-ISI-031 satisfy the requirements specified in Section 2500(b) of ASME Code Case N-770-2.
Entergy Response Entergy is requesting approval for an alternative to Section 2500(a) of ASME Code Case N-770-2. Paragraph 2500(a) states that welds shall be examined as specified in Table 1, "Examination Categories." Inspection Item B requires that volumetric examinations will investigate the volume of material established in Figure 1, "Examination Volume for Welds NPS 2 (ND 50) or Larger."
In the request for alternative (Reference 1), Entergy provided the results of the examinations performed during Refueling Outage 19 in Table 1. The column titled "N-770-1 Coverage Total %" provides data showing that the examinations performed did not achieve the volume of coverage specified in Figure 1.
While Section 2500(b) of ASME Code Case N-770-2 states For cast stainless steel items for which no supplement is available in Appendix VIII, the required examination volume shall be examined by Appendix VIII procedures to the maximum extent practical including 100% of the susceptible material volume (non-stainless-steel volume)," Entergy interprets paragraph 2500(b) to be applicable to welds that are mitigated or in the process of mitigation. Entergy believes that 2500(b) is not applicable to the Waterford 3 components listed in the request for alternative (Reference 1). Following 2500(b) as written does not exempt the requirement to achieve the volume specified in Figure 1.}}