ML16057A177

Supplement to Request for Approval of Pilgrim Relief Request (PRR)-52, Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) Pressure Testing of Mechanical Joints as a Result of Performance of a Repair/Replacement Activity and Use of

ML16057A177
Person / Time
Site:	Pilgrim
Issue date:	02/16/2016
From:	Perkins E P Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.16.011, PRR-52
Download: ML16057A177 (2)

Text

En tei-gEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth. MA 02360February 16, 2016U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Supplement to Request for Approval of Pilgrim Relief Request (PRR)-52,"Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) Pressure Testingof Mechanical Joints as a Result of Performance of a Repair/ReplacementActivity and Use of Code Case N-795"Pilgrim Nuclear Power StationDocket No.: 50-293Renewed License No.: DPR-35

REFERENCE:

Entergy Letter to NRC, Request for Approval of Pilgrim Relief Request (PRR)-52, "Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) PressureTesting of Mechanical Joints as a Result of Performance of aRepair/Replacement Activity and Use of Code Case N-795," dated October 21,2015 (2.15.074)LETTER NUMBER: 2.16.011

Dear Sir or Madam:

The referenced letter requested an alternative to specific portions of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for In-service inspection of Nuclear Power Plant Components," pursuant to 10 Code of FederalRegulations (CFR) 50.55a(z)(2). This is a request for alternative on the basis that compliancewith the specified requirements as described in this request would result in hardship or unusualdifficulty without a compensating increase in the level of quality and safety. However, the statedbasis in the first paragraph of the referenced letter was that "the proposed alternative providesan acceptable level of quality and safety" which corresponds to a request for alternativepursuant to 10 Code of Federal Regulations (CFR) 50.55a(z)(1).This letter updates the basis for the request for alternative submitted in the first paragraph of thereferenced letter as follows:Pursuant to 10 Code of Federal Regulations (CFR) 50.55a(z)(2), Pilgrim Nuclear PowerStation (PNPS) hereby requests an alternative to specific portions of the American Societyof Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules forIn-service Inspection of Nuclear Power Plant Components," on the basis that compliancewith the specified requirements as described in this request would result in hardship orunusual difficulty without a compensating increase in the level of quality and safety.If you have questions concerning this letter, please contact me at 508-830-8323./iJP1/2~1 Entergy Nuclear Operations, Inc. Letter No. 2.16.011Pilgrim Nuclear Power Station Page 2There are no new commitments included in this letter.Sincerely,Everett (Chip) P. Per Ins,-Jr.Manager, Regulatory AssuranceEPP/mwcc: Mr. Daniel H. DormanRegional Administrator, Region IU.S. Nuclear Regulatory Commission2100 Renaissance Blvd., Suite 100King of Prussia, PA 19406-2713Ms. Booma Venkataraman, Project ManagerOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory Commission*Mail Stop O-8C2AWashington, DC 20555NRC Senior Resident InspectorPilgrim Nuclear Power Station En tei-gEntergy Nuclear Operations, Inc.Pilgrim Nuclear Power Station600 Rocky Hill RoadPlymouth. MA 02360February 16, 2016U.S. Nuclear Regulatory CommissionAttn: Document Control DeskWashington, DC 20555-0001

SUBJECT:

Supplement to Request for Approval of Pilgrim Relief Request (PRR)-52,"Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) Pressure Testingof Mechanical Joints as a Result of Performance of a Repair/ReplacementActivity and Use of Code Case N-795"Pilgrim Nuclear Power StationDocket No.: 50-293Renewed License No.: DPR-35

REFERENCE:

Entergy Letter to NRC, Request for Approval of Pilgrim Relief Request (PRR)-52, "Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) PressureTesting of Mechanical Joints as a Result of Performance of aRepair/Replacement Activity and Use of Code Case N-795," dated October 21,2015 (2.15.074)LETTER NUMBER: 2.16.011

Dear Sir or Madam:

The referenced letter requested an alternative to specific portions of the American Society ofMechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, "Rules for In-service inspection of Nuclear Power Plant Components," pursuant to 10 Code of FederalRegulations (CFR) 50.55a(z)(2). This is a request for alternative on the basis that compliancewith the specified requirements as described in this request would result in hardship or unusualdifficulty without a compensating increase in the level of quality and safety. However, the statedbasis in the first paragraph of the referenced letter was that "the proposed alternative providesan acceptable level of quality and safety" which corresponds to a request for alternativepursuant to 10 Code of Federal Regulations (CFR) 50.55a(z)(1).This letter updates the basis for the request for alternative submitted in the first paragraph of thereferenced letter as follows:Pursuant to 10 Code of Federal Regulations (CFR) 50.55a(z)(2), Pilgrim Nuclear PowerStation (PNPS) hereby requests an alternative to specific portions of the American Societyof Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section Xl, "Rules forIn-service Inspection of Nuclear Power Plant Components," on the basis that compliancewith the specified requirements as described in this request would result in hardship orunusual difficulty without a compensating increase in the level of quality and safety.If you have questions concerning this letter, please contact me at 508-830-8323./iJP1/2~1 Entergy Nuclear Operations, Inc. Letter No. 2.16.011Pilgrim Nuclear Power Station Page 2There are no new commitments included in this letter.Sincerely,Everett (Chip) P. Per Ins,-Jr.Manager, Regulatory AssuranceEPP/mwcc: Mr. Daniel H. DormanRegional Administrator, Region IU.S. Nuclear Regulatory Commission2100 Renaissance Blvd., Suite 100King of Prussia, PA 19406-2713Ms. Booma Venkataraman, Project ManagerOffice of Nuclear Reactor RegulationU.S. Nuclear Regulatory Commission*Mail Stop O-8C2AWashington, DC 20555NRC Senior Resident InspectorPilgrim Nuclear Power Station