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| ==1.0 INTRODUCTION== | | ==1.0 INTRODUCTION== |
| By letter dated June 24, 2009, Agencywide Documents Access and Management System Accession No. ML091820325, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request IP3-ISI-RR-02 to the Nuclear Regulatory Commission (NRC) for the fourth 1O-yearinservice inspection (lSI) interval at Indian Point Nuclear Generating Unit No.3 (IP3). The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations. This safety evaluation addresses the merits of the request for relief from ASME Code requirements proposed by the licensee. The licensee requested relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i). | | By letter dated June 24, 2009, Agencywide Documents Access and Management System Accession No. ML091820325, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request IP3-ISI-RR-02 to the Nuclear Regulatory Commission (NRC) for the fourth 1O-yearinservice inspection (lSI) interval at Indian Point Nuclear Generating Unit No.3 (IP3). The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations. This safety evaluation addresses the merits of the request for relief from ASME Code requirements proposed by the licensee. The licensee requested relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i). |
| 2.0 REGULATORY REQUIREMENTS The lSI of ASrvlE Code Class 1, 2, and 3 components is to be performed in accordance with the requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Code and applicable editions and addenda as required by 10 CFR 50.55a(g), except where specific relief has been granted by the NRC. Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components and their integral attachments must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASrvlE Code, Section XI, "Rules for Inservice Inspection (lSI) of Nuclear Power Plant Components," to the extent practical within the limitation of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1O-yearinterval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed in 10 CFR 50.55a(b). The applicable ASrvlE Code of record for the fourth 1O-year interval ISI program at IP3 is the 2001 Edition through the 2003 Addenda of the ASME Enclosure | | |
| -2Code, Section XI. The fourth 1 O-year interval lSI program at IP3 extends from July 2009 until July 2019. Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternatives provide an acceptable level of quality and safety or (ii) 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 submitted Relief Request RR-02 pursuant to 10 CFR 50.55a(3)(i) as an alternative to the requirements of Paragraph 2600 of the ASME Code, Section XI. | | ===2.0 REGULATORY=== |
| 3.0 TECHNICAL EVALUATION 3.1 Component Identification Relief Request IP3-ISI-RR-02 addresses all ASME Code Class 1, 2, and 3 welds and areas that are subject to surface or volumetric examination. | | |
| 3.2 Licensee's Proposed Alternative The 2001 Edition through the 2003 Addenda of the ASME Code, Section XI, Subarticle 2600 requires that a reference system be established for all welds and areas subject to surface or volumetric examination. Subarticle IWA-2600 also states that each weld and area shall be located and identified by a system of reference points. The reference system shall permit identification of each weld, location of each weld centerline, and designation of regular intervals along the length of the weld. Pursuant to 10 CFR 50.55a(a)(3)(i), Relief Request IP3-ISI-RR-02 proposed an alternative to the requirements of the ASME Code, Section XI, Subarticle IWA-2600. In this request, the licensee specifically requested authorization to mark individual welds and areas as the surface or volumetric examinations are being performed in lieu of the requirements of Subarticle IWA-2600, which mandates the marking of all welds and areas subject to surface or volumetric examination prior to the actual performance of the lSI examinations. The licensee provided the following justification for its proposed alternative: The weld reference system described below shall be used for locating welds on existing piping and components and new installations. Datum reference markings will be established in the event that recordable indications are to be reported. Such datum points shall either be marked on the component or have their locations adequately described in the inspection documentation so that subsequent relocation can be achieved. The method proposed for the identification of indication locations is identical to the one employed at IP3 during the first, second, and third inspection intervals. The current code requirements include the establishment of a weld reference system which includes the initial marking of weld joints. At the time of | | REQUIREMENTS The lSI of ASrvlE Code Class 1, 2, and 3 components is to be performed in accordance with the requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Code and applicable editions and addenda as required by 10 CFR 50.55a(g), except where specific relief has been granted by the NRC. Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components and their integral attachments must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASrvlE Code, Section XI, "Rules for Inservice Inspection (lSI) of Nuclear Power Plant Components," to the extent practical within the limitation of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1O-yearinterval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed in 10 CFR 50.55a(b). The applicable ASrvlE Code of record for the fourth 1O-year interval ISI program at IP3 is the 2001 Edition through the 2003 Addenda of the ASME Enclosure |
| | -2Code, Section XI. The fourth 1 O-year interval lSI program at IP3 extends from July 2009 until July 2019. Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternatives provide an acceptable level of quality and safety or (ii) 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 submitted Relief Request RR-02 pursuant to 10 CFR 50.55a(3)(i) as an alternative to the requirements of Paragraph 2600 of the ASME Code, Section XI. |
| | |
| | ===3.0 TECHNICAL=== |
| | |
| | EVALUATION |
| | |
| | ===3.1 Component=== |
| | |
| | Identification Relief Request IP3-ISI-RR-02 addresses all ASME Code Class 1, 2, and 3 welds and areas that are subject to surface or volumetric examination. |
| | |
| | ===3.2 Licensee's=== |
| | Proposed Alternative The 2001 Edition through the 2003 Addenda of the ASME Code, Section XI, Subarticle 2600 requires that a reference system be established for all welds and areas subject to surface or volumetric examination. Subarticle IWA-2600 also states that each weld and area shall be located and identified by a system of reference points. The reference system shall permit identification of each weld, location of each weld centerline, and designation of regular intervals along the length of the weld. Pursuant to 10 CFR 50.55a(a)(3)(i), Relief Request IP3-ISI-RR-02 proposed an alternative to the requirements of the ASME Code, Section XI, Subarticle IWA-2600. In this request, the licensee specifically requested authorization to mark individual welds and areas as the surface or volumetric examinations are being performed in lieu of the requirements of Subarticle IWA-2600, which mandates the marking of all welds and areas subject to surface or volumetric examination prior to the actual performance of the lSI examinations. The licensee provided the following justification for its proposed alternative: The weld reference system described below shall be used for locating welds on existing piping and components and new installations. Datum reference markings will be established in the event that recordable indications are to be reported. Such datum points shall either be marked on the component or have their locations adequately described in the inspection documentation so that subsequent relocation can be achieved. The method proposed for the identification of indication locations is identical to the one employed at IP3 during the first, second, and third inspection intervals. The current code requirements include the establishment of a weld reference system which includes the initial marking of weld joints. At the time of |
| -3 construction of IP3, the application of a reference system which included the marking of welds before or during the preservice examination was not required by the code and, accordingly welds were not marked. A reference system for controlling the selection and documentation of datum points has been in effect since preservice inspections were performed in the early 1970's. The datum and conventions established at that time have been retained to promote consistency in the recording of data. The general conventions used at IP3 for establishing weld reference datum points include: Reference system for pipe: | | -3 construction of IP3, the application of a reference system which included the marking of welds before or during the preservice examination was not required by the code and, accordingly welds were not marked. A reference system for controlling the selection and documentation of datum points has been in effect since preservice inspections were performed in the early 1970's. The datum and conventions established at that time have been retained to promote consistency in the recording of data. The general conventions used at IP3 for establishing weld reference datum points include: Reference system for pipe: |
| The datum point for a circumferential weld on a horizontal pipe is the intersection of the top centerline of the pipe and the weld centerline. | | The datum point for a circumferential weld on a horizontal pipe is the intersection of the top centerline of the pipe and the weld centerline. |
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Category:Code Relief or Alternative
MONTHYEARML21299A0032021-10-28028 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
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
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)
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
ML19039A1492019-02-25025 February 2019
Issuance of Relief Request IP3-ISI-RR-14 Alternative Examination Required by ASME Code Case N-724-4
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
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)
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
ML18099A3732018-04-0909 April 2018
04/09/2018 E-mail from R. Guzman to R. Walpole, Verbal Authorization for Relief Request IP2-ISI-RR-06
ML18059A1562018-03-0606 March 2018
Safety Evaluation for Relief Request IP2-ISI-RR-05 Alternative Examination Volume Required by ASME Code Case N-729-4
ML18005A0662018-01-23023 January 2018
Safety Evaluation of Relief Requests ISI-RR-20, ISI-RR-21, and ISI-RR-22 Regarding the Fourth 10-Year Interval of the Inservice Inspection Program
CNRO-2017-00022, Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 12017-11-17017 November 2017
Relief Request Number EN-17-RR-1 - Proposed Alternative to Use ASME Code Case N-513-4, Evaluation Criteria for Temporary Acceptance of Flaws in Moderate-Energy Class 2 or 3 Piping, Section XI, Division 1
ML17174B1442017-07-12012 July 2017
Relief Request for EN-ISI-16-1 Regarding Use of Later Edition and Addenda of the ASME Code
ML17069A2832017-03-16016 March 2017
Relief Request No. IP3-ISI-RR-09, for Alternative to the Depth Sizing Qualification Requirement
ML16358A4442017-01-11011 January 2017
Relief from the Requirements of the ASME Code Regarding Alternate IP3-RR-10 to the Full Circumferential Inspection Requirement of Code Case N-513-3
ML16167A0812016-07-15015 July 2016
Request for Alternative IP2-ISI-RR-03 to Weld Reference System Examination Required by ASME Code Subarticle IWA-2600
ML16096A2692016-06-0606 June 2016
Arkansas; Grand Gulf; James A. Fitzpatrick; Indian Point; Palisades; Pilgrim; River Bend; and Waterford - Relief Request RR-EN-15-2, Proposed Alternative to Use ASME Boiler and Pressure Vessel Code Case N-786-1
ML16053A0252016-03-0303 March 2016
IP2-ISI-44-18, Relief from the Requirements of the ASME Code
CNRO-2015-00017, Entergy Submits Relief Request RR EN-15-1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Waster Service, Section XI, D2015-06-0505 June 2015
Entergy Submits Relief Request RR EN-15-1 - Proposed Alternative to Use ASME Code Case N-789-1, Alternative Requirements for Pad Reinforcement of Class 2 and 3 Moderate Energy Carbon Steel Piping for Raw Waster Service, Section XI, Division
ML14198A3312014-07-23023 July 2014
Safety Evaluation for Relief Request IP3-ISI-RR-06 for Reactor Vessel Weld Examinations (Tac No. MF3345)
NL-13-041, Relief Request IP2-ISI-RR-17: Code Case N-770-1 Weld Inspection Frequency Extension2013-02-20020 February 2013
Relief Request IP2-ISI-RR-17: Code Case N-770-1 Weld Inspection Frequency Extension
ML12334A3172012-12-0303 December 2012
Relief Request IP2-ISI-RR-15 - Proposed Alternative to the Use of a Weld Reference System
NL-12-065, 2012 Summary Report for In-Service Inspection and Repairers and Replacements2012-06-13013 June 2012
2012 Summary Report for In-Service Inspection and Repairers and Replacements
NL-12-069, Unit Number 2, Relief Request IP2-1SI-RR-15 - Proposed Alternative to the Use of a Weld Reference System2012-05-23023 May 2012
Unit Number 2, Relief Request IP2-1SI-RR-15 - Proposed Alternative to the Use of a Weld Reference System
ML11105A1222011-04-25025 April 2011
Relief from the Requirements of the ASME Code to Perform Essentially 100 Percent Volumetric Examination of the Weld and Adjacent Base Material for the Third 10-Year Inservice Inspection
ML11109A0162011-04-25025 April 2011
Relief Request No. IP2-ISI-RR-12, Reactor Vessel Shell-To-Flange Weld Inspection for the Fourth 10-Year Inservice Inspection Interval (Tac No. ME5180)
NL-10-136, Submittal of 10 CFR 50.55a Relief Request IP2-ISI-RR-12 for 4th Ten-Year Inservice Inspection Interval2010-12-14014 December 2010
Submittal of 10 CFR 50.55a Relief Request IP2-ISI-RR-12 for 4th Ten-Year Inservice Inspection Interval
ML1017400482010-07-15015 July 2010
Relief Request RR-11 for the Fourth 10-Year Inservice Inspection Interval
NL-10-061, CFR 50.55a Relief Requests RR-3-49 and RR-3-50 from Examinations of Component Welds with Less than Essentially 100% Examination Coverage for Third Ten-Year Inservice Inspection Interval2010-07-0505 July 2010
CFR 50.55a Relief Requests RR-3-49 and RR-3-50 from Examinations of Component Welds with Less than Essentially 100% Examination Coverage for Third Ten-Year Inservice Inspection Interval
ML1015303122010-06-0707 June 2010
Relief Request RR-02 for the Fourth 10-Year Inservice Inspection Interval
NL-09-022, Supplement to Request for Relief 3-48 and 3-47 (I) to Support Refuel Outage 15 Inservice Inspection Program2009-02-0606 February 2009
Supplement to Request for Relief 3-48 and 3-47 (I) to Support Refuel Outage 15 Inservice Inspection Program
NL-09-0111, Submittal of Relief Requests No. 3-45, 3-46, 3-47(I) and 3-48 to Support the Unit 3 Refuel Outage 15 Inservice Inspection Program2009-01-22022 January 2009
Submittal of Relief Requests No. 3-45, 3-46, 3-47(I) and 3-48 to Support the Unit 3 Refuel Outage 15 Inservice Inspection Program
NL-09-003, Supplemental Response to Request for Additional Information on Request for Relief to Extend the Inservice Inspection Interval for the Reactor Vessel Weld Examination2009-01-20020 January 2009
Supplemental Response to Request for Additional Information on Request for Relief to Extend the Inservice Inspection Interval for the Reactor Vessel Weld Examination
NL-08-096, Request for Relief to Extend Inservice Inspection Interval for the Reactor Vessel Weld Examination and Request for License Amendment for Submittal of ISI Information and Analyses2008-07-0808 July 2008
Request for Relief to Extend Inservice Inspection Interval for the Reactor Vessel Weld Examination and Request for License Amendment for Submittal of ISI Information and Analyses
ML0721304872007-09-0505 September 2007
Relief Request No. RR-01
NOC-AE-06002031, Request for Relief from ASME Boiler and Pressure Vessel Code, Section XI Requirements for Use of Penetrameters in Radiographic Examinations2006-06-14014 June 2006
Request for Relief from ASME Boiler and Pressure Vessel Code, Section XI Requirements for Use of Penetrameters in Radiographic Examinations
ML0602600762006-02-0808 February 2006
Relief Request (RR) No. 74
NL-05-0720, Request for Relief to Extend the Third 10-Year Inservice Inspection Interval for the Reactor Vessel Weld Examination2005-06-0808 June 2005
Request for Relief to Extend the Third 10-Year Inservice Inspection Interval for the Reactor Vessel Weld Examination
ML0509401362005-04-0404 April 2005
Relief, Relaxation of First Revised Order on Reactor Vessel Nozzles
ML0507700102005-03-18018 March 2005
Relaxation of First Revised Order on Reactor Vessel Nozzles
ML0427406642004-10-14014 October 2004
Relief Request Nos. R-33, R-71, R 3-40(A) and R-41, James A. FitzPatrick Nuclear Power Plant, Indian Point Nuclear Generating Unit Nos. 2 and No. 3 and Pilgrim Nuclear Power Station
ML0427406282004-10-14014 October 2004
Relief Request Nos. 65, 66, 3-34 and 3-35 Regarding Alternative Nondestructive Examination Qualification Requirements
ML0425203922004-10-0505 October 2004
Relief, Requirements of American Society of Mechanical Engineers Boiler & Pressure Vessel Code, Section III, 1965 Edition, & Section XI, 1989 Edition, for Repair & Inspection of Reactor Pressure Vessel Head Penetrations
ML0418901542004-07-0707 July 2004
Relief, Relief Request Nos. RR-67 and RR 3-36, TAC Nos. MC1698 and MC1699
ML0410700882004-07-0606 July 2004
Relief Request to Use American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Case N-600
ML0408205162004-03-22022 March 2004
Relief Request Nos. RR-68, RR3-37, and PRR-34 (TAC MC1559, MC1560, & MC1561)
ML0408506682004-03-19019 March 2004
Relief Request Nos. 70 and 3-39 Regarding Alternative Depth Sizing Criteria.(Tac MC1696 & MC1697)
ML0408600062004-03-19019 March 2004
Relief Request No. RR 63 Regarding risk-informed Inservice Inspection Program
ML0335000092003-12-16016 December 2003
Inservice Testing Program Relief Request Nos. 47 and 48, MB9111 and MB9112
2021-02-24
[Table view]
Category:Letter
MONTHYEARIR 07200051/20244022024-11-20020 November 2024
NRC Independent Spent Fuel Storage Security Inspection Report No. 07200051/2024402 (Public)
ML24240A1692024-09-18018 September 2024
Cy 2023 Summary of Decommissioning Trust Fund Status
IR 05000003/20240022024-08-0606 August 2024
NRC Inspection Report 05000003/2024002, 05000247/2024002, 05000286/2024002
PNP 2024-030, Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 02024-08-0202 August 2024
Update Report for Holtec Decommissioning International Fleet Decommissioning Quality Assurance Program Rev. 3 and Palisades Transitioning Quality Assurance Plan, Rev 0
ML24171A0122024-06-18018 June 2024
Reply to a Notice of Violation EA-24-037
ML24156A1162024-06-0404 June 2024
Correction - Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations
ML24151A6482024-06-0303 June 2024
Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities
IR 05000003/20240052024-05-21021 May 2024
And 3 - NRC Inspection Report Nos. 05000003/2024005, 05000247/2024005, 05000286/2024005, 07200051/2024001, and Notice of Violation
ML24128A0632024-05-0707 May 2024
Submittal of 2023 Annual Radiological Environmental Operating Report
L-24-009, HDI Annual Occupational Radiation Exposure Data Reports - 20232024-04-29029 April 2024
HDI Annual Occupational Radiation Exposure Data Reports - 2023
ML24116A2412024-04-25025 April 2024
Annual Environmental Protection Plan Report
ML24114A2282024-04-23023 April 2024
Annual Radioactive Effluent Release Report
L-24-007, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI)2024-03-29029 March 2024
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations – Holtec Decommissioning International, LLC (HDI)
IR 05000003/20240012024-03-20020 March 2024
NRC Inspection Report Nos. 05000003/2024001, 05000247/2024001, and 05000286/2024001 (Cover Letter Only)
ML24080A1722024-03-20020 March 2024
Reply to a Notice of Violation EA-2024-010
ML24053A0642024-02-22022 February 2024
2023 Annual Fitness for Duty Program Performance Data Report and Fatigue Management Program Data Report
IR 05000003/20230042024-02-22022 February 2024
NRC Inspection Report Nos. 05000003/2023004, 05000247/2023004, 05000286/2023004, and 07200051/2023004 and Notice of Violation
ML24045A0882024-02-22022 February 2024
Correction to the Technical Specifications to Reflect Appropriate Pages Removed and Retained by Previous License Amendments
ML24011A1982024-01-12012 January 2024
ISFSI, Notice of Organization Change for Site Vice President
ML23342A1082024-01-0909 January 2024
– Independent Spent Fuel Storage Installation Security Inspection Plan
ML23353A1742023-12-19019 December 2023
ISFSI, Emergency Plan, Revision 23-04
L-23-019, Proof of Financial Protection 10 CFR 140.152023-12-18018 December 2023
Proof of Financial Protection 10 CFR 140.15
ML23326A1322023-12-0505 December 2023
Issuance of Amendment No. 67, 300 & 276 to Implement the Independent Spent Fuel Storage Installation Only Emergency Plan
ML23339A0442023-12-0505 December 2023
Issuance of Amendment No. 68, 301 and 277 Regarding Changes to Implement the Independent Spent Fuel Storage Installation Physical Security Plan
ML23338A2262023-12-0404 December 2023
Signed Amendment No. 27 to Indemnity Agreement No. B-19
ML23356A0212023-12-0101 December 2023
American Nuclear Insurers, Secondary Financial Protection (SFP) Program
ML23242A2772023-11-30030 November 2023
NRC Letter Issuance - IP LAR for Units 2 and 3 Renewed Facility Licenses and PDTS to Reflect Permanent Removal of Spent Fuel from SFPs
ML23338A0482023-11-30030 November 2023
ISFSI, Report of Changes to Physical Security, Training and Qualification, Safeguards Contingency Plan, and ISFSI Security Program, Revision 28
ML22339A1572023-11-27027 November 2023
Letter - Indian Point - Ea/Fonsi Request for Exemptions from Certain Emergency Planning Requirements for 10 CFR 50.47 and 10 CFR Part 50, Appendix E
IR 05000003/20230032023-11-21021 November 2023
NRC Inspection Report Nos. 05000003/2023003, 05000247/2023003, 05000286/2023003, and 07200051/2023003
ML23100A1252023-11-17017 November 2023
Letter and Enclosure 1 - Issuance Indian Point Energy Center Units 1, 2, and 3 Exemption for Offsite Primary and Secondary Liability Insurance Indemnity Agreement
ML23100A1172023-11-17017 November 2023
NRC Response - Indian Point Energy Center Generating Units 1, 2, and 3 Letter with Enclosures Regarding Changes to Remove the Cyber Security Plan License Condition
ML23050A0032023-11-17017 November 2023
Letter - Issuance Indian Point Unit 2 License Amendment Request to Modify Tech Specs for Staffing Requirements Following Spent Fuel Transfer to Dry Storage
ML23100A1432023-11-16016 November 2023
Letter - Issuance Indian Point Energy Center Generating Units 1, 2, and 3 Exemption Concerning Onsite Property Damage Insurance (Docket Nos. 50-003, 50-247, 50-286)
L-23-012, Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point2023-11-13013 November 2023
Master Decommissioning Trust Agreement Changes for Indian Point Nuclear Generating Units 1, 2 and 3, Pilgrim Nuclear Power Station, Palisades Nuclear Plant and the Non-Qualified Trust for Big Rock Point
ML23064A0002023-11-13013 November 2023
NRC Issuance for Approval-Indian Point EC Units 1, 2 and 3 Emergency Plan and Emergency Action Level Scheme Amendments
ML23306A0992023-11-0202 November 2023
And Indian Point Energy Center, Notification of Changes in Schedule in Accordance with 10 CFR 50.82(a)(7)
ML23063A1432023-11-0101 November 2023
Letter - Issuance Holtec Request for Indian Point Energy Center Generating Units 1, 2, and 3 Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47 and Part 50
ML23292A0262023-10-19019 October 2023
LTR-23-0211-RI Thomas Congdon, Executive Deputy, Department of Public Service, Chair, Indian Point Decommissioning Oversight Board, Letter Independent Spent Fuel Storage Installation Inspection and Office of the Inspector General Report-RI
ML23289A1582023-10-16016 October 2023
Decommissioning International - Registration of Spent Fuel Casks and Notification of Permanent Removal of All Indian Point Unit 3 Spent Fuel Assemblies from the Spent Fuel Pit
ML23270A0082023-09-27027 September 2023
Registration of Spent Fuel Casks
ML23237A5712023-09-22022 September 2023
09-22-2023 Letter to Dwaine Perry, Chief, Ramapo Munsee Nation, from Chair Hanson, Responds to Letter Regarding Opposition of the Release and Dumping of Radioactive Waste from Indian Point Nuclear Power Plant Into the Hudson River
ML23242A2182023-09-12012 September 2023
IPEC – NRC Response to the Town of New Windsor, Ny Board Certified Motion Letter Regarding Treated Water Release from IP Site (Dockets 50-003, 50-247, 50-286)
ML23250A0812023-09-0707 September 2023
Registration of Spent Fuel Casks
ML23255A0142023-08-31031 August 2023
LTR-23-0211 Thomas Congdon, Executive Deputy, Department of Public Service, Chair, Indian Point Decommissioning Oversight Board, Letter Independent Spent Fuel Storage Installation Inspection and Office of the Inspector General Report
IR 05000003/20230022023-08-22022 August 2023
NRC Inspection Report 05000003/2023002, 05000247/2023002, 05000286/2023002, and 07200051/2023002
ML23227A1852023-08-15015 August 2023
Request for a Revised Approval Date Regarding the Indian Point Energy Center Permanently Defueled Emergency Plan and Emergency Action Level Scheme
ML23222A1442023-08-10010 August 2023
Registration of Spent Fuel Casks
ML23208A1642023-07-26026 July 2023
Village of Croton-on-Hudson New York Letter Dated 7-26-23 Re Holtec Wastewater
ML23200A0422023-07-19019 July 2023
Registration of Spent Fuel Casks
2024-09-18
[Table view]
Category:Safety Evaluation
MONTHYEARML23339A0442023-12-0505 December 2023
Issuance of Amendment No. 68, 301 and 277 Regarding Changes to Implement the Independent Spent Fuel Storage Installation Physical Security Plan
ML23326A1322023-12-0505 December 2023
Issuance of Amendment No. 67, 300 & 276 to Implement the Independent Spent Fuel Storage Installation Only Emergency Plan
ML23243A8452023-11-30030 November 2023
Enclosure 3: Issuance - IP LAR for SE Renewed Facility Licenses and PDTS to Reflect Permanent Removal of Spent Fuel from SFPs
ML23050A0022023-11-17017 November 2023
Enclosure 2 - Safety Evaluation for Indian Point Unit 2 License Amendment Request to Modify Technical Specifications for Staffing Requirements Following Spent Fuel Transfer to Dry Storage
ML23100A1172023-11-17017 November 2023
NRC Response - Indian Point Energy Center Generating Units 1, 2, and 3 Letter with Enclosures Regarding Changes to Remove the Cyber Security Plan License Condition
ML23064A0002023-11-13013 November 2023
NRC Issuance for Approval-Indian Point EC Units 1, 2 and 3 Emergency Plan and Emergency Action Level Scheme Amendments
ML23067A0822023-11-0101 November 2023
Enclosure 2 - Issuance Indian Point Energy Center Generating Units 1, 2, and 3 Safety Exemption Evaluation for Certain Emergency Planning Requirements of 10 CFR 50.47 and Part 50
ML23117A2172023-05-0101 May 2023
Safety Evaluation for Quality Assurance Program Manual Reduction in Commitment
ML21091A3052022-02-28028 February 2022
Issuance of Amendment No. 272 Revision to Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device (EPID L-2020-LLA-0051) (Non-Proprietary)
ML21074A0002021-04-22022 April 2021
Issuance of Amendment No. 270 Permanently Defueled Technical Specifications
ML21083A0002021-04-14014 April 2021
Issuance of Amendment No. 63 Permanently Defueled Technical Specifications
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
ML20297A3332020-11-23023 November 2020
Enclosure 3, Safety Evaluation for Transfer of Renewed Facility Operating Licenses to Holtec International, Owner, and Holtec Decommissioning International, LLC, Operator
ML20226A2722020-08-18018 August 2020
Request to Use a Provision of a Later Edition of the ASME BPV Code, Section XI
NL-20-050, Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline2020-06-24024 June 2020
Response to U.S. Nuclear Regulatory Commission Region I Letter Regarding Algonquin Incremental Market Project Pipeline
ML20100H9922020-06-0202 June 2020
Issuance of Amendment No. 269 Proposed Technical Specification Changes to City Water Surveillance Requirement and Condensate Storage Tank Required Action A.1
ML20122A2622020-05-0404 May 2020
Correction to Amendment No. 294 Dated April 28, 2020, Permanently Defueled Technical Specifications
ML20081J4022020-04-28028 April 2020
Issuance of Amendment No. 294 Permanently Defueled Technical Specifications
ML20078L1402020-04-15015 April 2020
Issuance of Amendment Nos. 62, 293, and 268 Changes to Emergency Plan for Post-Shutdown and Permanently Defueled Condition
ML20099A1822020-04-13013 April 2020
Issuance of Relief Request IP3-IST-RR-001 - Alternative to Certain Requirements of the ASME Code for Extension of the Fourth 10-Year Inservice Test Interval
ML20071Q7172020-04-10010 April 2020
Issuance of Amendment Nos. 292 and No. 267 Changes to Technical Specification Sections 1.1, 4.0, and 5.0 for a Permanently Defueled Condition
ML19333B8682019-12-18018 December 2019
Approval of Certified Fuel Handler Training and Retraining Program
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
ML19175A0422019-09-11011 September 2019
Arkansas Units 1 and 2; Grand Gulf, Unit 1; Indian Point 2 and 3; Palisades; River Bend, Unit 1; Waterford Unit 3 - Issuance of Amendments to Adopt TSTF-529, Clarify Use and Application Rules
ML19209C9662019-09-0404 September 2019
Issuance of Amendment No. 290 Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool
ML19065A1012019-03-21021 March 2019
Issuance of Amendment No. 61 and No. 289 Deletion of License Conditions Related to Decommissioning Trust Provision
ML19039A1492019-02-25025 February 2019
Issuance of Relief Request IP3-ISI-RR-14 Alternative Examination Required by ASME Code Case N-724-4
ML18337A4222018-12-20020 December 2018
Issuance of Amendment No. 265 One-Time Extension of 10 CFR Part 50, Appendix J, Type a, Integrated Leakage Rate Test Interval
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)
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
ML18142A4312018-05-31031 May 2018
Safety Evaluation for Relief Request IP2-ISI-RR-06 Approval of Alternative to Use Embedded Weld Repair
ML18059A1562018-03-0606 March 2018
Safety Evaluation for Relief Request IP2-ISI-RR-05 Alternative Examination Volume Required by ASME Code Case N-729-4
ML18005A0662018-01-23023 January 2018
Safety Evaluation of Relief Requests ISI-RR-20, ISI-RR-21, and ISI-RR-22 Regarding the Fourth 10-Year Interval of the Inservice Inspection Program
ML17348A6952018-01-11011 January 2018
Issuance of Amendment Connection of Non-Seismic Boric Acid Recovery System to the Refueling Water Storage Tank (CAC No. MF9578; EPID L-2017-LLA-0202)
ML17320A3542017-12-22022 December 2017
Issuance of Amendments Amendment of Inter-Unit Transfer of Spent Fuel (CAC Nos. MF8991 and MF8992; EPID L-2016-LLA-0039)
ML17315A0002017-12-0808 December 2017
Issuance of Amendments Cyber Security Plan Implementation Schedule (CAC Nos. MF9656, MF9657, and MF9658; EPID: L-2017-LLA-0217)
ML17174B1442017-07-12012 July 2017
Relief Request for EN-ISI-16-1 Regarding Use of Later Edition and Addenda of the ASME Code
ML17065A1712017-03-27027 March 2017
Safety Evaluation Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
ML17069A2832017-03-16016 March 2017
Relief Request No. IP3-ISI-RR-09, for Alternative to the Depth Sizing Qualification Requirement
ML16336A4922017-01-27027 January 2017
Transmittal Letter: Order Approving Transfer of Master Decommissioning Trust Funds for Indian Point, No. 3 & FitzPatrick Nuclear Plant from the Power Authority of the State of New York to Entergy Nuclear Operations, Inc.
ML16358A4442017-01-11011 January 2017
Relief from the Requirements of the ASME Code Regarding Alternate IP3-RR-10 to the Full Circumferential Inspection Requirement of Code Case N-513-3
ML16215A2432016-11-15015 November 2016
Issuance of Amendment Nos. 285 and 261 Conditional Exemption from End-of-Life Moderator Temperature Coefficient
ML16179A1782016-09-14014 September 2016
Safety Evaluation for Relief Request IP2-ISI-RR-01, Examination of Upper Pressurizer Welds
ML16251A6202016-09-13013 September 2016
Entergy Fleet Request for Approval of Change to the Entergy Quality Assurance Program Manual (CAC Nos. MF7086 - MF7097)
ML16167A0812016-07-15015 July 2016
Request for Alternative IP2-ISI-RR-03 to Weld Reference System Examination Required by ASME Code Subarticle IWA-2600
ML16147A5192016-07-14014 July 2016
Safety Evaluation for Relief Request IP2-ISI-RR-02 Alternative Examination Volume Required by Code Case N-729-1
ML16096A2692016-06-0606 June 2016
Arkansas; Grand Gulf; James A. Fitzpatrick; Indian Point; Palisades; Pilgrim; River Bend; and Waterford - Relief Request RR-EN-15-2, Proposed Alternative to Use ASME Boiler and Pressure Vessel Code Case N-786-1
ML16093A0282016-05-31031 May 2016
Entergy Services, Inc., Proposed Alternative to Utilize ASME Code Case N-789-1, Relief Request RR-EN-15-1, Revision 1
ML16064A2152016-04-12012 April 2016
Issuance of Amendments Cyber Security Plan Implementation Schedule
2023-05-01
[Table view] |
Text
UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 June 7,2010 Vice President, Operations Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 INDIAN POINT NUCLEAR GENERATING UNIT NO.3 -RELIEF REQUEST RR-02 FOR THE FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL (TAC NO. ME1576)
Dear Sir or Madam:
By letter dated June 24, 2009, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request IP3-ISI-RR-02 to the Nuclear Regulatory Commission (NRC) for the fourth 1O-year inservice inspection (lSI) interval at Indian Point Nuclear Generating Unit NO.3 (IP3). The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASIVIE Code),Section XI, pertaining to the requirements for marking welds and areas subject to surface or volumetric examinations. The NRC staff concludes that the licensee's proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface or volumetric examinations during the fourth 1O-year lSI interval at Indian Point 3 will be appropriately marked to ensure that examinations are successfully performed and indications are properly identified. The NRC staff also concludes that establishing a reference system for all welds and areas subject to surface or volumetric examinations in accordance with the requirements of the ASME Code,Section XI, Subarticle IWA-2600 will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Therefore, the licensee's proposed alternative in Request IP3-ISI-RR-02 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the fourth 10-year lSI interval at Indian Point 3.
-2If you have any questions, please contact the Indian Point Project Manager, John Boska, at (301) 415-2901.
Sincerely, Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286
Enclosure:
As stated cc w/encl: Distribution via Listserv UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. RR-02 ENTERGY NUCLEAR OPERATIONS, INC. INDIAN POINT NUCLEAR GENERATING UNIT NO.3 DOCKET NO. 50-286
1.0 INTRODUCTION
By letter dated June 24, 2009, Agencywide Documents Access and Management System Accession No. ML091820325, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted Relief Request IP3-ISI-RR-02 to the Nuclear Regulatory Commission (NRC) for the fourth 1O-yearinservice inspection (lSI) interval at Indian Point Nuclear Generating Unit No.3 (IP3). The licensee requested an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, pertaining to the requirements for marking welds and areas subject to surface and/or volumetric examinations. This safety evaluation addresses the merits of the request for relief from ASME Code requirements proposed by the licensee. The licensee requested relief pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i).
2.0 REGULATORY
REQUIREMENTS The lSI of ASrvlE Code Class 1, 2, and 3 components is to be performed in accordance with the requirements of Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," of the ASME Code and applicable editions and addenda as required by 10 CFR 50.55a(g), except where specific relief has been granted by the NRC. Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components and their integral attachments must meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASrvlE Code,Section XI, "Rules for Inservice Inspection (lSI) of Nuclear Power Plant Components," to the extent practical within the limitation of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1O-yearinterval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed in 10 CFR 50.55a(b). The applicable ASrvlE Code of record for the fourth 1O-year interval ISI program at IP3 is the 2001 Edition through the 2003 Addenda of the ASME Enclosure
-2Code,Section XI. The fourth 1 O-year interval lSI program at IP3 extends from July 2009 until July 2019. Pursuant to 10 CFR 50.55a(a)(3), alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of 10 CFR 50.55a may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternatives provide an acceptable level of quality and safety or (ii) 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 submitted Relief Request RR-02 pursuant to 10 CFR 50.55a(3)(i) as an alternative to the requirements of Paragraph 2600 of the ASME Code,Section XI.
3.0 TECHNICAL
EVALUATION
3.1 Component
Identification Relief Request IP3-ISI-RR-02 addresses all ASME Code Class 1, 2, and 3 welds and areas that are subject to surface or volumetric examination.
3.2 Licensee's
Proposed Alternative The 2001 Edition through the 2003 Addenda of the ASME Code,Section XI, Subarticle 2600 requires that a reference system be established for all welds and areas subject to surface or volumetric examination. Subarticle IWA-2600 also states that each weld and area shall be located and identified by a system of reference points. The reference system shall permit identification of each weld, location of each weld centerline, and designation of regular intervals along the length of the weld. Pursuant to 10 CFR 50.55a(a)(3)(i), Relief Request IP3-ISI-RR-02 proposed an alternative to the requirements of the ASME Code,Section XI, Subarticle IWA-2600. In this request, the licensee specifically requested authorization to mark individual welds and areas as the surface or volumetric examinations are being performed in lieu of the requirements of Subarticle IWA-2600, which mandates the marking of all welds and areas subject to surface or volumetric examination prior to the actual performance of the lSI examinations. The licensee provided the following justification for its proposed alternative: The weld reference system described below shall be used for locating welds on existing piping and components and new installations. Datum reference markings will be established in the event that recordable indications are to be reported. Such datum points shall either be marked on the component or have their locations adequately described in the inspection documentation so that subsequent relocation can be achieved. The method proposed for the identification of indication locations is identical to the one employed at IP3 during the first, second, and third inspection intervals. The current code requirements include the establishment of a weld reference system which includes the initial marking of weld joints. At the time of
-3 construction of IP3, the application of a reference system which included the marking of welds before or during the preservice examination was not required by the code and, accordingly welds were not marked. A reference system for controlling the selection and documentation of datum points has been in effect since preservice inspections were performed in the early 1970's. The datum and conventions established at that time have been retained to promote consistency in the recording of data. The general conventions used at IP3 for establishing weld reference datum points include: Reference system for pipe:
The datum point for a circumferential weld on a horizontal pipe is the intersection of the top centerline of the pipe and the weld centerline.
Dimensions are taken in a clockwise direction when viewing along the direction of system flow, which is marked on the line isometric drawing. The datum point for a circumferential weld on a vertical pipe is the intersection of the weld centerline and the centerline through the outside (extrados) of the elbow or bend that is in the direction of the lower weld number. The datum for a longitudinal weld is the weld centerline and the intersecting circumferential weld. Reference system for vessels: The datum for circumferential welds is the intersection of the weld centerline and the centerline of the adjacent longitudinal weld. Dimensions are taken in a clockwise direction when viewed from the top.
Where there is no intersecting weld, the datum point is drawn from an existing structural point (e.g., the centerline of hot leg manway). This is identified on the data sheet for the weld examination.
The datum for longitudinal welds is the intersection of the weld centerline and the centerline of the intersecting upper circumferential weld. The weld reference system currently in use at IP3 has been performing satisfactorily for the first, second, and third 1O-year intervals.
The locations of indications have been positively identified using the aforementioned conventions.
Entergy believes the weld reference system currently in use at IP3 provides an acceptable level of safety and quality to address the requirements of Subsections IWA-2600 and 111-4300.
Therefore, the marking of weld joints is not necessary.
-3.3 NRC Staff Evaluation The ASME Code requires that a reference system be established for all welds and areas subject to surface or volumetric examinations. Each such weld and area shall be located and identified by a system of reference points. The system shall permit identification of each weld, location of each weld centerline, and designation of regular intervals along the length of the weld.
The licensee proposed to utilize the method of identification used during the first three inspection intervals. The weld reference system described by the licensee in its submittal will be used for locating welds on existing piping and components and new installations. Datum reference markings will be established in the event that recordable indications are to be reported. Such datum points shall either be marked on the component or have their locations adequately described in the inspection documentation so that subsequent relocation can be achieved.
The licensee noted that at the time of construction of IP3, the application of a reference system which included the marking of welds before or during the preservice examination was not required by the ASME Code and, accordingly welds were not marked. The licensee's current reference system for controlling the selection and documentation of datum points has been in effect since preservice inspections were performed in the early 1970's. The datum and conventions established at that time have been retained by the licensee to promote consistency in the recording of data. The NRC staff notes that establishing a new weld reference system is a major effort. To establish a weld reference system in accordance with ASME Code requirements would require many hours of work and many person-rem of radiation dose to locate the welds, remove the insulation, mark the welds, and re-install the insulation. Not all welds are required to be examined during inservice inspections, but they would all have to be located and marked to implement the new weld reference system. Therefore, the NRC staff concludes that to require a weld reference system that conforms to the ASME Code of Record would result in a hardship without a compensating increase in the level of quality and safety.
4.0 CONCLUSION
The NRC staff concludes that the licensee's proposed alternative will provide reasonable assurance that all welds which receive the ASME Code-required surface or volumetric examinations during the fourth 1O-year lSI interval at IP3 will be appropriately marked to ensure that examinations are successfully performed and indications are properly identified. The NRC staff also concludes that establishing a reference system for all welds and areas subject to surface or volumetric examinations in accordance with the requirements of the ASME Code,Section XI, Subarticle IWA-2600 will result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Therefore, the licensee's proposed alternative in Request IP3-ISI-RR-02 is authorized pursuant to 10 CFR 50.55a(a)(3)(ii) for the
-5fourth 10-year lSI interval at IP3. All other requirements of the ASME Code,Section XI, for which relief has not been specifically requested and approved remain applicable, including party review by the Authorized Nuclear Inservice Inspector.
Principal Contributors:
C. Sydnor J. Boska Date: June 7,2010
-2If you have any questions, please contact the Indian Point Project Manager, John Boska, at (301) 415-2901.
Sincerely, /raJ Nancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286
Enclosure:
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