ML20134D027

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Requests Addl Info Re Requested Alternatives to Title 10 of Code of Federal Regulations,Update of Inservice Inspection Programs for Arkansas Nuclear Steam Electric Station,Unit 3 to Find Program Acceptable
ML20134D027
Person / Time
Site: Grand Gulf, Arkansas Nuclear, River Bend, Waterford  Entergy icon.png
Issue date: 10/09/1996
From: Beckner W
NRC (Affiliation Not Assigned)
To: Dewease J
ENTERGY OPERATIONS, INC.
References
TAC-M94454, TAC-M94471, TAC-M94472, TAC-M94473, TAC-M94488, NUDOCS 9610110320
Download: ML20134D027 (10)


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Jerrold G. Dewease October 9, 1996 Vice Presid::nt Operations Support Entergy Operations, Inc.

4 P. O. Box 31995 i

Jackson, MS 39266-1995 i-

SUBJECT:

UPDATE OF INSERVICE INSPECTION (ISI) PROGRAMS FOR ARKfJSAS NUCLEAR ONE, GRAND GULF NUCLEAR STATION, RIVER BEND STATION, AND WATERFORD i

STEAM ELECTRIC STATION, UNIT 3, (TAC NOS. M94471, M94472, M94454, l

M94488,M94473) o i

Dear Mr. Dewease:

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By letter dated January 5, 1996, Entergy Operations, Inc. (E01), licensee for i

Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend i

Station, and Waterford Steam Electric Station, Unit 3, requested alternatives i

to Title 10 of the Code of Federal Regulations, Section 50.55a, " Codes and j

Standards," under the provisions of paragraphs (a)(3)(1) and (a)(3)(ii). Our

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review with respect to authorizing alternatives as part of E0I's ISI programs for the five nuclear units has progressed to where we need additional l

information for us to find the programs acceptable. Our contractor, Idaho National Engineering Laboratory (INEL) has prepared the enclosure by our j

direction. You are requested to respond within 60 days so that we may i

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complete the review on schedule.

In responding to this request, please send a i

i copy to:

Michael T. Anderson, INEL Research Center, 2151 North Boulevard,

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P. O. Box 1625, Idaho Falls, Idaho 83415-2209.

j If there are any questions on this matter, please contact David L. Wigginton at (301) 415-1301.

Sincerely, Original signed by William D. Beckner, Director Project Directorate IV-1 l

Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation i

Docket Nos. 50-313, 50-368, 50-416, 50-458, and 50-382 r

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Enclosure:

Request for Additional Information i

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October 9, 1996 Jerrold G. Dewease Vice President Operations Support Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39266-1995

SUBJECT:

UPDATE OF INSERVICE INSPECTION (ISI) PROGRAMS FOR ARKANSAS NUCLEAR

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ONE, GRAND GULF NUCLEAR STATION, RIVER BEND STATION, AND WATERFORD STEAM ELECTRIC STATION, UNIT 3, (TAC NOS. M94471, M94472, M94454, M94488,M94473)

Dear Mr. Dewease:

By letter dated January 5, 1996, Entergy Operations, Inc. (E0I), licensee for

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Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3, requested alternatives to Title 10 of the Code of Federal Regulations, Section 50.55a, " Codes and Standards," under the provisions of paragraphs (a)(3)(1) and (a)(3)(ii). Our review with respect to authorizing alternatives as part of E01's ISI programs for the five nuclear units has progressed to where we need additional information for us to find the programs acceptable. Our contractor, Idaho National Engineering Laboratory (INEL) has prepared the enclosure by our direction. You are requested to respond within 60 days so that we may complete the review on schedule.

In responding to this request, please send a copy to:

Michael T. Anderson, INEL Research Center, 2151 North Boulevard, P. O. Box 1625, Idaho Falls, Idaho 83415-2209.

If there are any questions on this matter, please contact David L. Wigginton at (301) 415-1301.

Sincerely, U Y D. /$eA

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William D. Beckner, Director Project Directorate IV-1 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-368, 50-416, 50-458, and 50-382

Enclosure:

Request for Additional Information cc w/ enc 1: See next page

. = -._.. - _- _ -

1 Entergy Operations, Inc.

Arkansas Nuclear One, Units *

  • 2 i

cc:

l Executive Vice President Vice President, Operations Support

& Chief Operating Officer Entergy Operations, Inc.

1 Entergy Operations, Inc.

P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 i

Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Vice President Operations, ANO i

1448 S. R. 333 l

Winston & Strawn Russellville, AR 72801 1400 L Street, N.W.

i Washington, DC 20005-3502 Manager, Rockville Nuclear Licensing Framatone Technologies a

1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 j

London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 4

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 i

County Judge of Pope County i

Pope County Courthouse i

Russellville, AR 72801

Entergy Operations, Inc.

Grand Gulf Nuclear Station cc:

Executive Vice President General Manager, GGNS

& Chief Operating Officer Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box 756 P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 1

Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi Port Gibson, MS 39150 P. O. Box 22947 Jackson, MS 39225 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Vice President, Operattars Support 611 Ryan Plaza Drive, Suite 1000 Entergy Operations, inc.

Arlington, TX 76011

/.0. Box 31995 Jackson, MS 39286-1995 Senior Resident Inspector U. S. Nuclear Regulatory Commission Director, Nuclear Safety Route 2, Box 399 and Regulatory Affairs Port Gibson, MS 39150 Entergy Operations, Inc.

P.O. Box 756 Nuclear Operating Plant Services Port Gibson, MS 39150 Bechtel Power Corporation 9801 Washington Boulevard Gaithersburg, MD 2087C Vice President, Operations GGNS Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150

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1 i

l Entergy Operations, Inc.

River Bend Station cc:

Winston & Strawn Executive Vice President and 1400 L Street, N.W.

Chief Operating Officer l

Washington, DC 20005-3502 Entergy Operations, Inc.

P. O. Box 31995 Manager - Licensing Jackson, MS 39286 Entergy Operations, Inc.

]

River Bend Station General Manager - Plant Operations P. O. Box 220 Entergy Operations, Inc.

St. Francisv111e, LA 70775 River Bend Station l

P. O. Box 220 l

Director St. Francisville, LA 70775 i

Joint Operations Cajun 10719 Airline Highway Director - Nuclear Safety P. O. Box 15540 Entergy Operations, Inc.

4 Baton Rouge, LA 70895 River Bend Station P. O. Box 220 1

Senior Resident Inspector St. Francisv111e, LA 70775 i

P. O. Box 1050 St. Francisv111e, LA 70775 Vice President - Operations Support i

Entergy Operations, Inc.

4 President of West Feliciana P. O. Box 31995 Police Jury Jackson, MS 39286-1995 P. O. Box 1921 i

St. Francisville, LA 70775 Attorney General State of Louisiana j

Regional Administrator, Region IV P. O. Box 94095 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70804-9095 611_Ryan Plaza Drive, Suite 1000 4

Arlington, TX 76011 Wise, Carter, Child & Caraway P. O. Box 651 Ms. H. Anne Plettinger Jackson, MS 39205 3456 Villa Rose Drive Baton Rouge, LA 70806 Vice President & Controller Cajun Electric Power Cooperative Administrator 10719 Airline Highway Louisiana Radiation Protection Division P.O. Box 15540 P. O. Box 82135 Baton Rouge, LA 70895 Baton Rouge, LA 70884-2135 Vice President - Operations Entergy Operations, Inc.

River Bend Station P.O. Box 220 St. Francisville, LA 70775

Entergy Operations, Inc.

Waterford 3 i

cc:

Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 i

Baton Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident Inspector /Waterford NPS Support Post Office Box 822 i

Entergy Operations, Inc.

Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council i

St. Charles Parish Director P. O. Box 302 Nuclear Safety Hahnville, LA 70057 Entergy Operations, Inc.

P. O. Box B Executive Vice-President j

Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.

Wise, Carter, Child & Caraway P. O. Box 31995 t

P. O. Box 651 Jackson, MS 39286-1995 l

Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc.

One American Place, Suite 1630 P. O. Box B Baton Rouge, en 70825-1697 Killona, LA 70066 Vice President Operations Licensing Manager Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box B P. O. Box B Killona, LA 70066 Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502

.I i

RE0 VEST FOR ADDITIONAL INFORMATION - SECOND OR THIRD 10-YEAR INTERVAL INSERVICE INSPECTION PROGRAM PLAN ARKANSAS NUCLEAR ONE. UNITS 1 AND 2. DOCKET NOS. 50-313 AND 50-368 GRAND GULF NUCLEAR STATION. DOCKET NO. 50-416 RIVER BEND STATION. DOCKET NO. 50-458 WATERFORD 3 STEAM ELECTRIC STATION. DOCKET NO. 50-382 1.

Scoce/ Status of Review Throughout the service life of a water-cooled nuclear power facility, 10 CFR 50.55a(g)(4) requires that components (including supports) that are l

classified as American Society of Mechanical Engineers (ASME) Boiler and j

Pressure Vessel Code Class 1, Class 2, and Class 3 meet the requirements, except design and access provisions and preservice examination requirements, set forth in ASME Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. This section of the regulations also requires that inservice examinations of components and system pressure tests conducted during successive 120-month inspection intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) on the date 12 months prior to the start of a successive 120-month interval, subject to the limitations and modifications listed therein. The components (including supports) may meet requirements set forth in subsequent editions and addenda of the Code that are incorporated by reference in 10 CFR 50.55a(b) subject to the limitations and modifications listed therein and subject to Nuclear Regulatory Commission (NRC) approval.

The licensee, Entergy Operations Inc., submitted a request for authorization to update the inservice inspection (ISI) program at each plant listed below to the 1992 Edition of the ASME Boiler and Pressure Vessel Code,Section XI, ENCLOSURE 4

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including portions of the 1993 Addenda. During a conference call held on April 8,1996, the NRC requested additional information concerning the differences between the 1989 Edition of Section XI and those edition / addenda the licensee is requesting to use. This information was supplied to the NRC in a letter dated July 12, 1996. After review of this information, it was determined that further clarification is required to complete the review of j

the second or third 10-year program plan.

2.

Additional Information Reauired l

Based on the above review, the staff has concluded that in order to authorize l

the licensee's alternative to the Code requirements, incorporation of the i

following conditions into the applicable request for relief is necessary.

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Confirm that the conditions stated below will be met.

A.

Entergy has proposed not to implement IWE and IWL prior to completion of rulemaking.

Rulemaking on this issue is currently being completed and the

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licensees should follow the requirements of this rulemaking, when referenced

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in CFR. A commitment to follow the rulemaking requirements when referenced in CFR should be included in the licensee's alternative.

B.

The INEL staff believes that the implementation of Appendix VIII will be l

governed by rulemaking and that at that time the licensee should follow all j

requirements of the rulemaking. Also, the INEL staff believes that j

implementing Appendix I of the 1989 Edition of ASME Section XI will provide an acceptable level of quality and safety until rulemaking on Appendix VIII is completed. At that time the licensee should update the programs to reflect l

the requirements of the rulemaking. A commitment to follow the rulemaking i

requirements when referenced in CFR should be included in the licensee's alternative.

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3 The following components of your request are found to be unacceptable and written commitments to satisfy the following are necessary in order to find your alternative acceptable:

C.

Entergy has proposed to implement, at will, any of the Code Cases incorporated into the most recent revision of Regulatory Guide 1.147 (Revision 11, October 1994). These Code Cases have received generic approval for use; however, the licensee must provide written notification to the NRC detailing which Code Cases will be adopted.

Code Cases are eventually incorporated into the Code, or annulled, and new cases are included in Regulatory Guide 1.147; therefore, notification must be submitted for each interval to ensure the Code Cases adopted do not conflict with one another or regulatory commitments and to maintain an accurate listing of Code Cases being used by the licensee. A commitment to include a listing of the Regulatory Guide 1.147 incorporated Code Cases that will be implemented, into the updated program plans, should be included in the licensee's alternative.

D.

The licensee proposed to continue using Code Cases approved for use by relief request during previous intervals that have not been incorporated into Regulatory Guide 1.147. To use these Code Cases in the program plans, a request for relief must be submitted detailing how the Code Case will be incorporated.

Each request for relief is valid for the interval in which it is submitted. This is required because new technologies, improved procedures, and enhanced qualifications may have been developed that could be used.

Furthermore, the updates being proposed by the licensee will be directly affected by several Code Cases being used by the various plants. Therefore, the licensee should submit updated requests for relief detailing how the various Code Cases will be implemented into the new program plans. A commitment to submit updated requests for relief detailing how the various Code Cases will be implemented into the new program plans, should be included in the licensee's alternative.

E.

The licensee :tated that it has not identified a requirement for the NRC to review and approve the actual programs.

However, the NRC is responsible

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4 for ensuring quality and safety of U.S. nuclear power plants. This responsibility requires the NRC to review the method of implementing ASME Section XI, the application of Code Cases, and the necessity for requests for relief submitted by the licensees in their respective inservice inspection program plans. Additionally,Section XI, IWA-1400* Owner's Responsibility, assigns the licensee the responsibility of " preparation of plans and schedules and fl11ng of these plans and schedules with enforcement and regulatory authorities having jurisdiction at the plant site." Furthermore, IWA-1310, Components Subject To Inspection And Testing, states "The seiection of components for the inservice inspection plan is subject to review by the regulatory and enforcement authorities having jurisdiction at the plant site."

To meet the subject Code requirement and enable the NRC to perform these tasks, the licensee should submit their program plan for review. A commitment to submit their program plans for review should be included in the licensee's alternative.

The schedule for timely completion of this review requires that the licensee provide, by the requested date, the above requested information and/or clarifications regarding the Arkansas Nuclear One, Units 1 and 2, Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station Second or Third 10-Year Interval Inservice Inspection Program Plan.

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