ML092720921

Notification of Inspection (NRC Inspection Report 05000382/2009005) and Request for Information

ML092720921
Person / Time
Site:	Waterford
Issue date:	09/29/2009
From:	Ray Kellar Region 4 Engineering Branch 1
To:	Kowalewski J Entergy Operations
References
IR-09-005
Download: ML092720921 (12)

See also: IR 05000382/2009005

Text

UNITED STATES

NUC LE AR RE G UL AT O RY C O M M I S S I O N

R E GI ON I V

612 EAST LAMAR BLVD , SU I TE 400

AR LI N GTON , TEXAS 76011-4125

September 29, 2009

Joseph Kowalewski, Vice President, Operations

Entergy Operations, Inc.

Waterford Steam Electric Station, Unit 3

17265 River Road

Killona, LA 70057-3093

SUBJECT: WATERFORD STEAM ELECTRIC STATION, UNIT 3 - NOTIFICATION OF

INSPECTION (NRC INSPECTION REPORT 05000382/2009005) AND

REQUEST FOR INFORMATION

Dear Mr. Kowalewski:

From November 2-13, 2009, reactor inspectors from the U. S. Nuclear Regulatory

Commissions (NRC) Region IV office will perform the baseline inservice inspection at the

Waterford Steam Electric Station, Unit 3, using NRC Inspection Procedure 71111.08, "Inservice

Inspection Activities," and Temporary Instruction 2515/172, "Reactor Coolant System Dissimilar

Metal Butt Welds." Experience has shown that this inspection is a resource intensive inspection

both for the NRC inspectors and your staff. In order to minimize the impact to your onsite

resources and to ensure a productive inspection, we have enclosed a request for documents

needed for this inspection. These documents have been divided into two groups. The first

group (Section A of the enclosure) identified information to be provided prior to the inspection to

ensure that the inspectors are adequately prepared. The second group (Section B of the

enclosure) identifies the information the inspectors will need upon arrival at the site. It is

important that all of these documents are up to date and complete in order to minimize the

number of additional documents requested during the preparation and/or the onsite portions of

the inspection.

We have discussed the schedule and information required for these inspection activities with

your staff and understand that our regulatory contact for this inspection will be Mr. Jim Pollock of

your licensing organization. Our inspection dates are subject to change based on your updated

schedule of outage activities. If there are any questions about this inspection or the material

requested, please contact the lead inspector Ramon Azua at (817) 319-4376

(ray.azua@nrc.gov) or Michael Bloodgood at (817) 276-6544 (michael.bloodgood@nrc.gov).

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document

system (ADAMS). ADAMS is accessible from the NRC web site at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Entergy Operations, Inc. -2-

Sincerely,

/RA/

Ray Kellar, P.E., Chief

Engineering Branch 1

Division of Reactor Safety

Docket: 50-382

License: NPF-38

Enclosure:

Inservice Inspection Document Request

Senior Vice President

Entergy Nuclear Operations

P. O. Box 31995

Jackson, MS 39286-1995

Senior Vice President and

Chief Operating Officer

Entergy Operations, Inc.

P. O. Box 31995

Jackson, MS 39286-1995

Vice President, Operations Support

Entergy Services, Inc.

P. O. Box 31995

Jackson, MS 39286-1995

Senior Manager, Nuclear Safety

and Licensing

Entergy Services, Inc.

P. O. Box 31995

Jackson, MS 39286-1995

Site Vice President

Waterford Steam Electric Station, Unit 3

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

Director

Nuclear Safety Assurance

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

Entergy Operations, Inc. -3-

General Manager, Plant Operations

Waterford 3 SES

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-0751

Manager, Licensing

Entergy Operations, Inc.

17265 River Road

Killona, LA 70057-3093

Chairman

Louisiana Public Service Commission

P. O. Box 91154

Baton Rouge, LA 70821-9154

Parish President Council

St. Charles Parish

P. O. Box 302

Hahnville, LA 70057

Director, Nuclear Safety & Licensing

Entergy, Operations, Inc.

440 Hamilton Avenue

White Plains, NY 10601

Louisiana Department of Environmental

Quality, Radiological Emergency Planning

and Response Division

P. O. Box 4312

Baton Rouge, LA 70821-4312

Chief, Technological Hazards

Branch

FEMA Region VI

800 North Loop 288

Federal Regional Center

Denton, TX 76209

Entergy Operations, Inc. -4-

Electronic distribution by RIV:

Regional Administrator (Elmo.Collins@nrc.gov)

Deputy Regional Administrator (Chuck.Casto@nrc.gov)

DRP Director (Dwight.Chamberlain@nrc.gov)

DRP Deputy Director (Anton.Vegel@nrc.gov)

DRS Director (Roy.Caniano@nrc.gov)

DRS Deputy Director (Troy.Pruett@nrc.gov)

Senior Resident Inspector (Mark.Haire@nrc.gov)

Resident Inspector (Dean.Overland@nrc.gov)

Branch Chief, DRP/E (Jeff.Clark@nrc.gov)

Senior Project Engineer, DRP/E (Ray.Azua@nrc.gov)

WAT Site Secretary (Linda.Dufrene@nrc.gov)

Public Affairs Officer (Victor.Dricks@nrc.gov)

Team Leader, DRP/TSS (Chuck.Paulk@nrc.gov)

RITS Coordinator (Marisa.Herrera@nrc.gov)

Regional Counsel (Karla.Fuller@nrc.gov)

Congressional Affairs Officer (Jenny.Weil@nrc.gov)

OEMail Resource

Inspection Reports/MidCycle and EOC Letters to the following:

ROPreports

DRS STA (Dale.Powers@nrc.gov)

OEDO RIV Coordinator (Leigh.Trocine@nrc.gov)

SUNSI Review Completed: ___Y___ ADAMS: 7 Yes No Initials: _RVA

7 Publicly Available Non-Publicly Available Sensitive 7 Non-Sensitive

R:\REACTORS\W3 ISI RFI - RVA ML09270921

SPE:DRP/PBE RI:DRS/EB1 C:DRS/EB1

RVAzua MRBloodgood RLKellar

/RA/ /RA/ /RA/

09/29/09 09/29/09 09/29/09

OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

INSERVICE INSPECTION DOCUMENT REQUEST

Inspection Dates: November 2-13, 2009

Inspection Procedures: IP 71111.08 "Inservice Inspection (ISI) Activities"

TI 2515/172 "Reactor Coolant System Dissimilar Metal Butt Welds"

Inspectors: Ramon Azua, Senior Project Engineer (Lead Inspector - ISI)

Michael Bloodgood, Reactor Inspector

A. Information Requested for the In-Office Preparation Week

The following information should be sent to the Region IV office in hard copy or

electronic format (ims.certrec.com preferred), in care of Ramon Azua, by October 26,

2009, to facilitate the selection of specific items that will be reviewed during the onsite

inspection week. The inspector will select specific items from the information requested

below and then request from your staff additional documents needed during the onsite

inspection week (Section B of this enclosure). We ask that the specific items selected

from the lists be available and ready for review on the first day of inspection. *Please

provide requested documentation electronically if possible. If requested documents are

large and only hard copy formats are available, please inform the inspector(s), and

provide subject documentation during the first day of the onsite inspection. If you have

any questions regarding this information request, please call the inspector as soon as

possible.

A.1 ISI/Welding Programs and Schedule Information

a) A detailed schedule (including preliminary dates) of:

i) Nondestructive examinations (NDEs) planned for Class 1 & 2 systems

and containment, performed as part of your ASME Section XI, Risk

Informed (if applicable), and augmented ISI programs during the

upcoming outage.

Provide a status summary of the NDE inspection activities vs. the

required inspection period percentages for this Interval by category per

ASME Section XI, IWX-2400 (Do not provide separately if other

documentation requested contains this information)

ii) Reactor pressure vessel head (RPVH) examinations planned for the

upcoming outage.

iii) Examinations planned for Alloy 82/182/600 components that are not

included in the Section XI scope. (If applicable)

iv) Examinations planned as part of your Boric Acid Corrosion Control

Program (Mode 3 walkdowns, bolted connection walkdowns, etc.)

-1- Enclosure

v) Welding activities that are scheduled to be completed during the

upcoming outage (ASME Class 1, 2, or 3 structures, systems, or

components (SSCs)).

b) A copy of ASME Section XI Code Relief Requests and associated NRC Safety

Evaluations applicable to the examinations identified above.

c) A list of NDE reports (ultrasonic, radiography, magnetic particle, dye penetrate,

Visual VT-1, VT-2, and VT-3), which have identified relevant conditions on Code

Class 1 & 2 systems since the beginning of the last refueling outage. This should

include the previousSection XI pressure test(s) conducted during start up and

any evaluations associated with the results of the pressure tests. Also, include in

the list the NDE reports with relevant conditions in the RPVH penetration nozzles

which have been accepted for continued service. The list of NDE reports should

include a brief description of the SSC where the relevant condition was identified.

d) A list with a brief description (e.g., system, material, pipe size, weld number, and

NDE performed) of the welds in Code Class 1 and 2 systems which have been

fabricated due to component repair/replacement activities since the beginning of

the last refueling outage, or are planned to be fabricated this refueling outage.

e) If reactor vessel weld examinations required by the ASME Code are scheduled to

occur during the upcoming outage, provide a detailed description of the welds to

be examined and the extent of the planned examination. Please also provide

reference numbers for applicable procedures that will be used to conduct these

examinations.

f) Copy of any 10 CFR Part 21 reports applicable to your SSCs within the scope of

Section XI of the ASME Code that have been identified since the beginning of the

last refueling outage.

g) A list of any temporary non-code repairs in service (e.g., pinhole leaks).

h) Please provide copies of the most recent self assessments for the ISI, Welding,

and Alloy 600 Programs.

A.2 Reactor Pressure Vessel Head (RPVH)

a) Provide the detailed scope of the planned NDE of the reactor vessel head which

identifies the types of NDE methods to be used on each specific part of the

vessel head to fulfill commitments made in response to NRC Bulletin 2002-02

and NRC Order EA-03-009 or ASME Code Case N-729-1. Also, include

examination scope expansion criteria and planned expansion sample sizes if

relevant conditions are identified. (If applicable)

b) A list of the standards and/or requirements that will be used to evaluate

indications identified during NDE of the reactor vessel head (e.g., the specific

-2- Enclosure

industry or procedural standards which will be used to evaluate potential leakage

and/or flaw indications).

A.3 Boric Acid Corrosion Control Program (BACCP)

a) Copy of the procedures that govern the scope, equipment and implementation of

the inspections required to identify boric acid leakage and the procedures for

boric acid leakage/corrosion evaluation.

b) Please provide a list of leaks (including Code class of the components) that have

been identified since the last refueling outage and associated corrective action

documentation. If during the last cycle, the Unit was shutdown, please provide

documentation of containment walkdown inspections performed as part of the

BACCP.

c) Please provide a copy of the most recent self-assessment performed for the

BACCP.

A.4 Steam Generator Tube (SGT) Inspections

a) A detailed schedule of:

i) SGT inspection, data analyses, and repair activities for the upcoming

outage. (If occurring)

ii) SG secondary side inspection activities for the upcoming outage. (If

occurring)

b) Please provide a copy of your SG ISI Inspection Program and Plan. Please

include a copy of the Operational Assessment from last outage and a copy of the

following documents as they become available:

i) Degradation Assessment

ii) Condition Monitoring Assessment

c) If you are planning on modifying your Technical Specifications such that they are

consistent with TSTF-449, please provide copies of your correspondence with

the NRC regarding deviations from the STS.

d) Copy of SG history documentation given to vendors performing eddy current (ET)

testing of the SGs during the upcoming outage.

e) Copy of SG Eddy Current Data Analyst Guidelines and Site Validated Eddy

Current Technique Specification Sheets (ETSS). Additionally, please provide a

copy of EPRI Appendix H ETSS Qualification Records.

-3- Enclosure

f) Identify and quantify any SGT leakage experienced during the previous operating

cycle. Also provide documentation identifying which SG was leaking and

corrective actions completed or planned for this condition (If applicable).

g) Provide past history of the condition and issues pertaining to the secondary side

of the steam generators (including items such as loose parts, fouling, top of tube

sheet condition, crud removal amounts, etc.)

h) Please provide copies of your most recent self assessments of the SG

monitoring, loose parts monitoring, and secondary side water chemistry control

programs.

i) Please also indicate where the primary, secondary, and resolution analyses are

scheduled to take place.

j) Please provide a summary of the scope of the SGT examinations, including

examination methods such as Bobbin, Rotating Pancake, or Plus Point, and the

percentage of tubes to be examined. *Do not provide these documents

separately if already included in other information requested.

A.5 Materials Reliability (MRP-139) Program Activities

a) A list of, with verification, that the baseline inspections of all applicable Dissimilar

Metal Butt Welds (DMBWs) have been completed by September 30, 2009.

b) Verification that baseline inspection of hot leg and cold leg temperature DMBWs

have been included in the inspection program and that the schedules for the

baseline inspections are consistent with the baseline schedules in MRP-139.

c) A list and schedule (examination dates) of all DMBW examinations planned for

the upcoming refueling outage. If none are scheduled, then data from previous

examinations should be available for review.

d) A list and schedule for any welding to be performed on DMBWs in the upcoming

outage. If no welding will be performed then records of previous welding on

DMBWs and postweld NDE documentation.

e) A list and schedule of any stress improvement (SI) activities planned for the

upcoming refueling outage. If none are scheduled then have qualification reports

for any SIs previously performed.

f) Documentation and description of how the baseline and inservice inspection

specifications in MRP-139 are satisfied at your facility.

g) A list of weld locations controlled by MRP-139 which includes the MRP-139 weld

category, pre-mitigation volumetric examination date, type of mitigation or stress

improvement, post mitigation volumetric examination date, and plans for future

MRP-139 required examinations.

-4- Enclosure

A.6 Additional information related to all ISI activities

a) A list with a brief description of ISI, BACCP, and SGT inspection related issues

(e.g., condition reports) entered into your corrective action program since the

beginning of the last refueling outage. For example, a list based upon data base

searches using key words related to piping or SG tube degradation such as: ISI,

ASME Code,Section XI, NDE, cracks, wear, thinning, leakage, rust, corrosion,

boric acid, or errors in piping/SGT examinations.

b) Please provide names and phone numbers for the following program leads:

ISI contacts (Examination, planning)

Containment Exams

RPVH Exams

Snubbers and Supports

Repair and Replacement Program Manager

Licensing Contact

Site Welding Engineer

Boric Acid Corrosion Control Program

SG Inspection Activities (site lead and vendor contact)

B. Information to be provided onsite to the inspector(s) at the entrance meeting (November

2, 2009):

B.1 ISI / Welding Programs and Schedule Information

a) Updated schedules for ISI/NDE activities, including SGT inspections, planned

welding activities, and schedule showing contingency repair plans, if available.

b) For ASME Code Class 1 and 2 welds selected by the inspector from the lists

provided from section A of this enclosure, please provide copies of the following

documentation for each subject weld:

i) Weld data sheet (traveler)

ii) Weld configuration and system location

iii) Applicable Code Edition and Addenda for weldment

iv) Applicable Code Edition and Addenda for welding procedures

v) Applicable weld procedures (WPS) used to fabricate the welds

vi) Copies of procedure qualification records (PQRs) supporting the WPS

from B.1.b.v

vii) Copies of mechanical test reports identified in the PQRs above

viii) Copies of the nonconformance reports for the selected welds (If

applicable)

ix) Radiographs of the selected welds and access to equipment to allow

viewing radiographs (If RT was performed)

x) Copies of the preservice examination records for the selected welds.

-5- Enclosure

xi) Copies of welder performance qualifications records applicable to the

selected welds, including documentation that welder maintained

proficiency in the applicable welding processes specified in the WPS (at

least six months prior to the date of subject work)

xii) Copies of NDE personnel qualifications (VT, PT, UT, RT), as applicable

c) For the ISI related corrective action issues selected by the inspector(s) from

section A of this enclosure, provide a copy of the corrective actions and

supporting documentation.

d) For the NDE reports with relevant conditions on Code Class 1 & 2 systems

selected by the inspector from section A above, provide a copy of the

examination records, examiner qualification records, and associated corrective

action documents.

e) A copy of (or ready access to) most current revision of the ISI Program Manual

and Plan for the current Interval.

f) For the NDEs selected by the inspector from section A of this enclosure, provide

copy of the NDE procedures used to perform the examinations (including

calibration and flaw characterization/sizing procedures). For ultrasonic

examination procedures qualified in accordance with ASME Code,Section XI,

Appendix VIII, provide documentation supporting the procedure qualification

(e.g., the EPRI performance demonstration qualification summary sheets). Also,

include qualification documentation of the specific equipment to be used (e.g.,

ultrasonic unit, cables, and transducers including serial numbers) and NDE

personnel qualification records.

B.2 Reactor Pressure Vessel Head (RPVH)

a) Provide the NDE personnel qualification records for the examiners who will

perform examinations of the RPVH.

b) Provide drawings showing the following: (If a visual examination is planned for

the upcoming refueling outage)

i) RPVH and CRDM nozzle configurations

ii) RPVH insulation configuration

The drawings listed above should include fabrication drawings for the nozzle attachment

welds as applicable.

c) Copy of NDE reports from the last RPVH examination.

d) Copy of evaluation or calculation demonstrating that the scope of the visual

examination of the upper head will meet the 95 percent minimum coverage

required by NRC Order EA-03-009 or ASME Code Case N-729-1 (If a visual

examination is planned for the upcoming refueling outage).

-6- Enclosure

e) Provide a copy of the procedures that will be used to identify the source of any

boric acid deposits identified on the RPVH. If no explicit procedures exist which

govern this activity, provide a description of the process to be followed including

personnel responsibilities and expectations.

f) Provide a copy of the updated calculation of effective degradation years (EDY)

for the RPVH susceptibility ranking.

g) Provide copy of the vendor qualification report(s) that demonstrates the detection

capability of the NDE equipment used for the RPVH examinations. Also, identify

any changes in equipment configurations used for the RPVH examinations which

differ from that used in the vendor qualification report(s).

B.3 Boric Acid Corrosion Control Program (BACCP)

a) Please provide boric acid walkdown inspection results, an updated list of boric

acid leaks identified so far this outage, associated corrective action

documentation, and overall status of planned boric acid inspections.

b) Please provide any engineering evaluations completed for boric acid leaks

identified since the end of the last refueling outage. Please include a status of

corrective actions to repair and/or clean these boric acid leaks. Please identify

specifically which known leaks, if any, have remained in service or will remain in

service as active leaks.

B.4 Steam Generator Tube (SGT) Inspections

a) Copies of the Examination Technique Specification Sheets (ETSS) and

associated justification for any revisions.

b) Copy of the guidance to be followed if a loose part or foreign material is identified

in the SGs.

c) Please provide a copy of the ET procedures used to perform the SGT

inspections (specifically calibration and flaw characterization/sizing procedures,

etc.). Also include documentation for the specific equipment to be used.

d) Please provide copies of your responses to NRC and industry operating

experience communications such as Generic Letters, Information Notices, etc.

(as applicable to SGT inspections) *Do not provide these documents separately if

already included in other information requested such as the degradation

assessment.

e) List of corrective action documents generated by the vendor and/or site with

respect to SG inspection activities.

-7- Enclosure

B.5 Codes and Standards

a) Ready access to (i.e., copies provided to the inspector(s) for use during the

inspection at the onsite inspection location, or room number and location where

available):

i) Applicable Editions of the ASME Code (Sections V, IX and XI) for the

inservice inspection program and the repair/replacement program.

ii) EPRI and industry standards referenced in the procedures used to

perform the SGT eddy current examination.

Inspector Contact Information:

Ramon Azua Michael Bloodgood

Senior Project Engineer Reactor Inspector

817-319-4376 817-276-6544

ray.azua@nrc.gov michael.bloodgood@nrc.gov

Mailing Address:

US NRC Region IV

Attn: Ramon Azua

612 E. Lamar Blvd, Suite 400

Arlington, TX 76011

-8- Enclosure