CNRO-2007-00004, Supplement to Request for Alternative RBS-ISI-005
| ML070520353 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/14/2007 |
| From: | Burford F Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNRO-2007-00004 | |
| Download: ML070520353 (6) | |
Text
Entergy Entergy Operations, Inc.
1340 Echelon Parkway Jackson, Mississippi 39213-8298 Tel 601-368-5758 F. G. Burford Acting Director Nuclear Safety & Licensing CNRO-2007-00004 February 14, 2007 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Supplement to Request for Alternative RBS-ISI-005 River Bend Station Docket No. 50-458 License No. NPF-47
REFERENCES:
- 1.
Entergy Operations, Inc. letter CNRO-2006-00043 to the NRC dated September 22, 2006
- 2.
Entergy Operations, Inc. letter CNRO-2006-00047 to the NRC dated, 2006
Dear Sir or Madam:
In Reference #1, Entergy Operations, Inc. (Entergy) submitted Request for Alternative GG-ISI-003, which requested approval to extend the second Inservice Inspection (ISI) interval for piping at Grand Gulf Nuclear Station (GGNS) to the end of its sixteenth refueling outage.
In Reference #2, Entergy submitted a similar request, Request for Alternative RBS-ISI-005, for River Bend Station (RBS). In an e-mail to Entergy dated November 21, 2006, the NRC staff requested additional information needed to conclude its review of GG-ISI-003.
Because of the similarity between GG-ISI-003 and RBS-ISI-005, by this letter Entergy is responding to the NRC's questions as they apply to RBS-ISI-005. The responses are contained in the enclosure. Should you have any questions regarding this submittal, please contact Guy Davant at (601) 368-5756.
Entergy requests that the NRC approve RBS-ISI-005 by November 1, 2007 in order to support the upcoming fall 2007 refueling outage.
on
CNRO-2007-00004 Page 2 of 2 This letter contains no new commitments.
Sincerely, FGBIG $ Digh
Enclosure:
Response to Request for Additional Information cc:
Mr. W. A. Eaton (ECH)
Mr. J. E. Venable (RBS)
Dr. Bruce S. Mallet Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector River Bend Station P.O. Box 1050 St. Francisville, LA 70775 U.S. Nuclear Regulatory Commission Attn: Mr. B. K. Vaidya MS 0-7 D1 Washington, DC 20555-0001
ENCLOSURE CNRO-2007-00004 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION
Enclosure to CNRO-2007-00004 Page 1 of 3 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR ALTERNATIVE RBS-ISI-005 RIVER BEND STATION
- 1) In Request for Alternative RBS-lSI-005 (submitted via Entergy letter CNRO-2006-00047 dated November 1, 2006) Entergy stated, URBS is planning to submit to the NRC staff a request for alternative to implement a risk-informed / safety-based inservice inspection (RISB) program. Entergy plans to implement the RIS_B ISI program during RF-1 5 currently scheduled for the spring 2009." Please confirm that should the to-be-requested risk-informed inservice inspection (RI-ISI) program not be found acceptable, all examinations as required by the current ISI program will be performed by the end of the inspection interval.
Response
If the to-be-requested RI-ISI program, based on ASME Code Case N-716, is not accepted by the staff, Entergy plans to submit a different request for alternative to establish an RI-/SI program at River Bend Station (RBS) based on ASME Code Case N-578, which the staff has approved for several licensees. With such a submittal, Entergy would also seek an additional extension of the second interval, if necessary.
In the unlikely event that the staff does not approve a RI-I program based on either code case, Entergy would then perform the necessary Code-required examinations for the second interval
- 2)
In order to better understand the time intervals, please provide dates (month/year) of when the second 1 0-year interval started and when will it end.
Response
The second 10-year ISI interval began December 1997 and ends November 2007.
With the requested extension, the second interval would end following the completion of FBS' fifteenth refueling outage (RF-15), which is currently scheduled for the spring 2009 (approximately six months beyond the Code-allowed one-year extension).
- 3)
Table IWB-2412-1 requires that a minimum of 50% of the required ASME Section XI examinations be completed by the end of the second period of an inspection interval.
(a) What is the current inspection period RBS is in?
(b)
Provide the number and/or percentage of inspections of Class 1 and 2 piping welds that have been completed so far as required under the existing ASME Section XI Inservice Inspection Program.
Response
(a) RBS is currently in the third period of the second ISI interval
Enclosure to CNRO-2007-00004 Page 2 of 3 (b) By the end of the last refueling outage (RF-13), 75% of the piping weld examinations required by ASME Section Xl had been completed thus far in the second ISI interval for Examination Categories B-F, B-J, C-F-I, and C-F-2.
Therefore, RBS has met the minimum requirement specified in Table IWB-2412-1.
- 4)
Clarify which edition and addenda are the code of record at RBS for the current ISI interval.
Response
The ISI code of record for RBS is ASME Section XI 1992 Edition with portions of the 1993 Addenda applicable to pressure testing [see the NRC's safety evaluation report dated December 12, 1996 (TAC No. M94488)].
- 5)
As outlined in NRC Information Notice 98-44, "Ten-year Inservice (ISI) Inspection Program Update for Licensees that Intend to Implement Risk-Informed ISI of Piping,*
the licensee must provide adequate justification, along with a clear indication of the inspection that will continue before the implementation of the RI-ISI program. During the delay, licensees would be required to continue augmented inspection programs, such as inspections for intergranular stress corrosion cracking, inspections required for flaws dispositioned by analysis, system pressure tests, and inspection of components other than piping.
(a) If the approval of the risk informed / safety-based inservice inspection (RISB) program has not been approved during the fourteenth refueling outage (RF-14),
what type of inspections will continue prior to refueling outage fifteen (RF-15), if any, to achieve acceptable levels of quality and safety while awaiting approval of the submitted RI-ISI program request?
(b)
If the RI-ISI program is approved prior to RF-14, how will the RI-ISI program be implemented?
Response
During the delay, Entergy plans to perform required augmented inspection programs as committed to the staff in various correspondence.
(a) Augmented inspections pertaining to intergranular stress corrosion cracking (IGSCC) are scheduled to be performed during RF-14; no other piping weld inspections are currently planned prior to RF-15. If the to-be-requested RI-IS1 program is not approved by RF-15, Entergy will perform required inspections as discussed in the response to Question #1.
Enclosure to CNRO-2007-00004 Page 3 of 3 (b) Because of scheduling requirements, Entergy cannot commit to implement a RISB Program during RF-14 (currently scheduled to begin during the fall 2007) if approved prior to RF-14. Entergy intends to start implementing the RIS_B Program at RBS during the plant's third period of the second inspection interval, By the end of the previous refueling outage (RF-13), 75% of the piping weld examinations required by ASME Section Xl had been completed thus far in the second ISl interval for Examination Categories B-F, B-J, C F-I, and C-F-2. To ensure the performance of 100% of the required examinations during the current (second) ten-year ISl interval, 25% of the inspection locations selected for examination per the RISB process will be examined in the third period of the interval. The third ISl interval will implement 100% of the inspection locations selected for examination per the RISB Program. Examinations shall be performed such that the period percentage requirements of ASME Section Xl are met.