NL-09-087, Relief Request IP3-ISI-RR-01, IP3-ISI-RR-02, and IP3-ISI-RR-03 for Fourth Ten-Year Inservice Inspection Interval

Relief Request IP3-ISI-RR-01, IP3-ISI-RR-02, and IP3-ISI-RR-03 for Fourth Ten-Year Inservice Inspection Interval

ML091820325
Person / Time
Site:	Indian Point
Issue date:	06/24/2009
From:	Robert Walpole Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IP3-ISI-RR-01, IP3-ISI-RR-02, IP3-ISI-RR-03, NL-09-087
Download: ML091820325 (12)

Text

SPEntergy Enterty Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Robert Walpole Licensing Manager Tel (914) 734-6710 June 24, 2009 NL-09-087 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Relief Request IP3-ISI-RR-01, IP3-ISI-RR-02, and IP3-ISI-RR-03 For Fourth Ten-Year Inservice Inspection Interval Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (Entergy) is submitting Relief Request IP3-1SI-RR-01 (Enclosure 1), Relief Request IP3-1SI-RR-02 (Enclosure 2), and Relief Request IP3-lSI-RR-03 (Enclosure 3), for Indian Point Unit No. 3 (IP3). These relief requests are for the Fourth 10-year Inservice Inspection (ISI) Interval.The enclosed relief requests evaluate the proposed alternatives and conclude they provide an acceptable level of quality and safety. The relief requests are requested under the provisions of 10CFR 50.55a(a)(3)(i).

Entergy requests approval of the relief requests within 12 months of docketing which will allow time for implementation during the next refuel outage.zoq7 ljd-((

NL-09-087 Docket 50-286 Page 2 of 2 There are no new commitments identified in this submittal.

If you have any questions or require additional information, please contact Mr. Robert Walpole, Licensing Manager at 914-734-6710.

Sincerely, RW/sp Enclosures

1. Relief Request No: IP3-1SI-RR-01 Code Case N-753 2. Relief Request No: IP3-1SI-RR-02 Reference System 3. Relief Request No: IP3-ISI-RR-03 Code Case N-739-1 Proposed Alternative to Use ASME Proposed Alternative to Use Weld Proposed Alternative to Use ASME I cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector, IP3 Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

Enclosure:

1 TO NL-09-087 RELIEF REQUEST NO: IP3-ISI-RR-01 PROPOSED ALTERNATIVE TO USE ASME CODE CASE N-753 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 Indian Point Unit 3 Fourth 10-Year ISI Interval Relief Request No: IP3-ISI-RR-01 Revision 0 Page 1 of 2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)-Alternative Provides Acceptable Level of Quality and Safety-1. ASME Code Component(s)

Affected Code Class:

References:

Examination Category: Item Number:

Description:

Not Applicable ASME Section XI, 2001 Edition with 2003 Addenda, IWA-2321 (a)Code Case N-753 Not Applicable Not Applicable Alternative Requirements to the Visual Acuity Demonstration Requirements of IWA-2321 (a)2. Applicable Code Edition and Addenda The Code of Record for the Indian Point Unit 3 Inservice Inspection Fourth Interval is the ASME Section XI Code, 2001 Edition including the 2003 Addenda.3. Applicable Code Requirement IWA-2321(a) requires that NDE personnel be administered the following vision tests annually: "Personnel shall demonstrate natural or corrected near-distance acuity of 20/25 or greater Snellen fraction, with at least one eye, by reading words or identifying characters on a-near-distance test chart, such as a Jaeger chart, that meets the requirements of IWA-2322.

Equivalent measures of near-distance acuity may be used. In addition, personnel performing VT-2 or VT-3 visual examinations shall demonstrate natural or corrected far-distance acuity of 20/30 or greater Snellen fraction or equivalent with at least one eye." 4. Reason for Request Pursuant to 10 CFR 50.55a(a)(3)(i), authorization is requested on the basis that the proposed alternative, use of Code Case N-753, would provide an acceptable level of quality and safety.5. Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy requests authorization to utilize the alternative requirements in ASME Code Case N-753 in lieu of the requirements of IWA-2321 (a).

Relief Request No: IP3-1SI-RR-01 Page 2 of 2 Basis for Use Code Case N-753 provides an alternative to the visual acuity demonstration requirements of IWA-2321(a) that will allow the testing to be administered and documented by an Optometrist, Ophthalmologist, or other health care professional who administers vision tests.The visual acuity testing for NDE personnel performing ASME Section XI examinations is required to be administered annually.

In addition to this visual acuity testing, which is typically administered by utility personnel, many NDE personnel also have annual visual acuity testing in conjunction with routine eye examinations administered by an Optometrist, an Ophthalmologist, or other health care professional who administers vision tests.Optometrists, Ophthalmologists, and other health'care professionals who administer vision tests are typically educated and experienced in the proper techniques for vision testing, such as the Snellen fraction or Jaeger-chart.

methods required by ASME Section XI. This training and expertise provides a sound level of confidence that the Visual acuity testing administered will be a reliable indicator that the tested NDE personnel'.can satisfactorily perform Section XI non-destructive examinations.

The testing performed by Optometrists, Ophthalmologists, and other health care professionals who-'administer Ivision tests will satisfy IWA-2321 (a) requirements, including documentation which details the tests performed, compliance with IWA-2321 (a) criteria and the date the testing was administered.-

The use of Code Case N-753 alternative requirements allows the flexibility for utilities to accept visual acuity testing performed by outside health care professional in lieu of the visual acuity testing performed by in-house personnel.

In many instances this flexibility will eliminate duplicate testing and thus provide a reduction in-the costs and manpower associated with qualifying NDE personnel.

..Because Code Case N-753 does not change the qualification criteria in IWA-2321 (ap), the implementation of the included alternative requirements does not affect the level of quality or safety provided by NDE personnel.

6.-Duration of Alternativeis for the Fourth Ten Year Interval (effective from July 2009 thru July 2019).7. Precedents This request is essentially identical to the previous Entergy South Request CEP-ISI-012 which was approved on. March 6, 2009 in TAC Nos. MD8813, MD8814, MD8815, and MD8816.8. References

-None Enclosure 2 TO. NL-09-087 RELIEF REQUEST NO: IP3--ISI-RR-02

.PROPOSED ALTERNATIVE TO USE WELD REFERENCE SYSTEM ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 Indian Point Unit 3'Fourth 10-Year ISI Interval Relief Request No: IP3-ISI-RR-02 Revision 0 Page 1 of 3 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)-Alternative Provides Acceptable Level of Quality and Safety-1. ASME Code Component(s)

Affected Code Class: 1 and 2

References:

-.2 ..." -..- IWA-2600 --Examination Category:

Not Applicable Item Number: Not Applicable

==

Description:==

Weld Reference System 2. Applicable Code Edition and Addenda: The Code of Record for the Indian Point Unit 3 (IP3) Inservice Inspection Fourth Interval is the ASME Section XI Code, 2001 Edition including the 2003 Addenda.3. Applicable Code Requirement Subarticle IWA-2600 requires the establishment of a weld reference system for all welds and areas subject to surface or volumetric examination.

Each such weld area shall be located and identified by a system of reference points.Appendix III, Subarticle 111-4300 requires the identification of examination areas. Weld identification and location shall be shown on a weld identification plan. Welds shall be marked once before or during the preservice examination to establish a reference point.4. Reason for Request IP3 requests relief from the requirements of the weld reference system as specified in IWA-2600 and 111-4300.

Pursuant to 10 CFR 50.55a(a)(3)(i) authorization is requested on the basis that the proposed alternative would provide an acceptable level of quality and safety.5. Proposed Alternative and Basis for Use 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.

Relief Request No: IP3-ISI-RR-02

...Page 2 of 3 The method proposed for the identification of indication locations is identical to the one employed at IP3 during thefirst; second, and third inspection intervals.

Basis for Use The current code requiremehts include the establishment of a weld reference system which includes the initial marking of weld joints. 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 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-;dgneral!

cnventions 6Saat IP3 for establishing weld reference datum pointsinclude:-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 lowerweld number.---

-The datum for a longit-dinal weld is the weld centerline and the intersecting circumferential weld.Reference system for vessels:-The datum forcircumferential welds is the inters~ection-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 a hot leg manway). This-is identified on the.* datasheet for the weld examination.

-The datum for longitudinalwelds is the intersection of the weld centerline and the centerline of the intersecting upper circumferential Weld.

Relief Request No: IP3-ISI-RR-02 Page 3 of 3 The weld reference system currently in use at IP3 has been performing satisfactorily for the first, second,4 and third 10-Year Intervalsý 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.

6. Duration of Proposed Alternative-

--.-- -Relief is. requested for the Fourth Ten Year Interval (effective from July 2009 thru July 2019).7. Precedents This request is essentially identical to the previous Third 10-Year Inspection IntervalRelief 3-11 which was approved on 5/17/01 in TAc No. MA9757. -.. -8. Referehces-"" N o n e -<" ..- -- .-... , , .-" °: ; ./ '* "' -:. '- -:. ' ..' -: ": .. ..

Enclosure 3 TO NL-09-087 RELIEF REQUEST NO: IP3-ISI-RR-03 PROPOSED ALTERNATIVE-TO.

USE ASME CODE CASE.N-739-1 ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 Indian Point Unit 3 Fourth 10-Year ISI Interval Relief Request No: IP3-ISI-RR-03 Revision 0 Page 1 of 2 Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)-Alternative Provides Acceptable Level of Quality and Safety-1. ASME Code Component(s)

Affected.

--Code Class:_:, -. .

References:

Examination Category: Item Number:

Description:

ASME Section Xl, 2001 Edition with 2003 Addenda, Article IWA-2300 and Subsection IWL-2310 Code Case N-739-1 L-A and L-B 11.11, L1.12, L2.30 Request to Utilize the Alternative Requirements of Code Case N-739-1: Alternative Qualification Requirements for Personnel Performing Class CC Concrete and Post-Tensioning System Visual Examinations'

2. Applicable Code Edition and Addenda The Code of Record for the Indian Point Unit 3 Inservice Inspection Fourth Interval is the ASME Section X1 Code, 2001 Edition including the 2003 Addenda.3. Applicable Code Requirement IWA-2300 provides requirements for qualification of nondestructive, examination personnel.

IWL-2310 provides requirements for the qualification of personnel performing Class CC Concrete and Post-Tensioning System Visual Examinations.

Per 10 CFR 50.55a(b)(2)(viii)(F), personnel-that examine containment concrete surfaces and tendon hardware, wires, or strands must meet the qualification provisions in IWA-2300.

The"owner-defined" personnel qualification provisions in IWL-2310(d) are not approved for use.4. Reason for Request Pursuant to 10 CFR 50.55a(a)(3)(i), authorization is requested on the basis that the proposed alternative, use of Code Case N-739-1, would provide an acceptable level of quality and safety.5. Proposed Alternative and Basis for Use Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy requests authorization to utilize the alternative Relief Request No: IP3-ISI-RR-03 Page 2 of 2 requirements in ASME Code Case N-739-1 in lieu of the requirements of IWA-2300.Basis for Use The reason the NRC has included the modificationr in-lOCFR 5.55a(b)(2)(viii)(F), that prohibits licensees to utilize the "owner-defined" personnel qualification provisions in IWL-2310(d) is that they believe it is inappropriate to approve Code provisions that do not contain specific containment inspection guidance when prior experience demonstrates that specific containment inspection guidance is necessary.

In lieu of the IWL-2310(d) personnel qualification requirements, the 10 CFR 5.55a(b)(2)(viii)(F) modification requires that licensees implement the IWA-2300 personnel qualification provisions.

In response to this NRC concern, ASME. has-developed an alternative set of qualification requirements in Code Case N-739-1. This Code Case provides detailed criteria to qualify personnel who examine containment concrete surfaces and tendon hardware, wires, or strands.Similar to the requirements inJWA-2300, Code,:Case N-739-1 includes plant and Section -Xl:-'., Subsection IWL experience requirements.

as.well as detajled!training proficiency requirements for.personnel performing Class.CC concrete and, system yisualexaminations.

Entergy believes that the alternative requirements in Code*Case N-739-1 satisfy the NRC's concern of licensees utilizing Code requirements that do not contain specific containment guidance., In, addition, Entergy believes that the alternative requirements in Code Case N-739-1 provide an acceptable level of quality and safety to the requirements in IWA-2300.6. Duration of.Proposed Alternative

,._.--:._.-Relief_

is requestedfJortheFourth Ten Year Interval (effective from July 2009 thru July 2019).7. Precedents This request is essentially identical to the previous Entergy South Request CEP-CISI-001Q which was approved in NRC letter dated March-30, 2009, ADAMS Accession Number ML090630469.

8. References None