GNRO-2009/00070, Supplement to Request to Use Portion of Later Edition to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for Main Steam Safety Relief Valve Inservice Testing

Supplement to Request to Use Portion of Later Edition to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for Main Steam Safety Relief Valve Inservice Testing

ML093490371
Person / Time
Site:	Grand Gulf
Issue date:	12/14/2009
From:	Burford F Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2009/00070
Download: ML093490371 (5)

Text

~Entergy GNRO-2009/00070 December 14, 2009 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001 Entergy Operations, Inc.

PO. Box 756 Port Gibson, MS 39150 Tel 601 437 2800

SUBJECT:

Supplement to Request to Use Portion of Later Edition to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for Main Steam Safety Relief Valve Inservice Testing Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

REFERENCES:

1. NRC Regulatory Issue Summary 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28, 2004

2. GNRO-2009/00060, Letter dated October 22, 2009, "Request to Use Portion of Later Edition to the American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants for Main Steam Safety Relief Valve Inservice Testing"

Dear Sir or Madam:

Pursuant to 10CFR50.55a(f)(4)(iv) and in accordance with the guidance provided in NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," (Reference 1), Entergy Operations, Inc. (Entergy) requests approval to use a portion of a later code edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the Grand Gulf Nuclear Station (GGNS) Inservice Testing (1ST) Program. Specifically, Entergy requests approval to implement Mandatory Appendix I, Paragraphs 1-3410(a) and (d) of the 2004 Edition of the ASME OM Code at GGNS for Main Steam Safety Relief Valve Inservice Testing.

This letter is a supplement to and supersedes the prior letter (Reference 2) previously submitted to NRC.

Paragraph 10CFR50.55a(f)(4)(ii) requires the use of the latest edition and addenda that have been incorporated by reference 12 months prior to the beginning of each 120-month interval. For GGNS, the current 120-month interval uses the 2001 Edition of the ASME OM Code through 2003 Addenda. Licensees that plan to use for their 1ST program later editions and addenda of the ASME OM Code that have been incorporated

GNRO-2009/00070 Page 2 of 2 by reference into 10CFR50.55a must submit a request for NRC approval pursuant to 10CFR50.55a(f)(4)(iv) prior to its use.

As noted in NRC RIS 2004-12, licensees seeking to use later editions and addenda of the ASME OM Code, pursuant to 10CFR50.55a(f)(4)(iv) for inservice testing items are not required to seek alternatives pursuant to 10CFR50.55a(a)(3) or relief pursuant to 10CFR50a(f)(5)(iv).

The request is detailed in the attachment to this letter. Entergy requests NRC approval by March 15, 2010, to support testing planned for the seventeenth refueling outage (RF-17), which is currently scheduled to begin in Spring of 2010.

This letter contains no commitments. Should you have any questions regarding this submittal, please contact Michael Larson, at 601-437-6685.

Sii~

F.G. Burford Acting - Licensing Manager FGB/MJL

Attachment:

10CFR50.55a Request Number GGNS-2009-01, Refueling Outage 17 Main Steam Safety Relief Valve Inservice Testing cc:

NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 U. S. Nuclear Regulatory Commission ATIN: Mr. Elmo E. Collins (w/a)

Regional Administrator, Region IV 612 East Lamar Drive, Suite 400 Arlington, TX 76011-4005 U.S. Nuclear Regulatory Commission ATIN: Mr. Carl F. Lyon, NRR/ADRO/DORL (w/2)

Mail Stop OWFN/8 B1 11555 Rockville Pike Rockville, MD 20852-2378

Attachment to GNRO-2009/00070 10CFR50.55a Request Number GGNS-2009-01 Refueling Outage 17 Main Steam Safety Relief Valve Inservice Testing

Attachment to GNRO-2009/00070 Page 1 of2 Request in Accordance with 10 CFR 50.55a(f)(4)(iv)

For Use of Subsequent ASME Code Edition and Addenda Pursuant to 10CFR 50.55a(f)(4)(iv) and in accordance with the guidance provided in NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) and Section XI," Entergy Operations, Inc. (Entergy) requests approval to use a portion of a later code edition of the ASME OM Code for the Grand Gulf Nuclear Station (GGNS) Inservice Testing (1ST) Program.

Specifically, Entergy requests approval to implement Mandatory Appendix I, Paragraphs 1-3410(a) and (d) of the 2004 Edition of the ASME OM Code at GGNS for Main Steam Safety Relief Valve Inservice Testing.

PLANT/UNIT:

INTERVAL:

ASMECODE COMPONENTS AFFECTED:

APPLICABLE CODe EDITION AND ADDENDA:

GGNS, Unit 1 Third 10 Year Inservice Testing Interval Main Steam Safety Relief Valve (20 valves installed)

Model: G-471 Manufacturer: Dikkers Valves For GGNS, the current 120-month 1ST program interval uses the 2001 Edition of the ASME OM Code through the 2003 Addenda, which includes the following (from Mandatory Appendix I) requirement:

1-3400 Disposition After Testing or Maintenance 1-3410 Class I Main Steam Pressure Relief Valves With Auxiliary Actuating Devices (a) Valves and accessories that comply with their respective acceptance criteria for the tests specified may be returned to service without further testing, except for on-line testing as required by 1-3410(d).

(d) Each valve that has been maintained or refurbished in place, removed for maintenance and testing, or both, and reinstalled shall be remotely actuated at reduced or normal system pressure to verify open and close capability of the valve before resumption of electric power generation. Set-pressure verification is not required.

Attachment to GNRO-2009/00070 Page 2 of2 Request in Accordance with 10 CFR 50.55a(f)(4)(iv)

For Use of Subsequent ASME Code Edition and Addenda PROPOSED SUBSEQUENT CODE EDITION AND ADDENDA (OR PORTION):

Entergy requests approval to use a portion of Mandatory Appendix I to the 2004 Edition of the ASME OM Code at GGNS for Main Steam Safety Relief Inservice Testing.

Federal Register, Volume 73, Number 176, dated September 10, 2008 (73 FR 52730),

,incorporates by reference the 2004 Edition of the ASME OM Code in 10CFR50.55a(b)(3). The specific paragraphs to be used are 1-3410(a) and (d), which are copied as follows:

1-3400 Disposition After Testing or Maintenance 1-3410 Class I Main Steam Pressure Relief Valves With Auxiliary Actuating Devices (a) Valves and accessories that comply with their respective acceptance criteria for the tests specified may be returned to service without further testing, except as required by 1-3410(d).

(d) Each valve with an auxiliary actuating device that has been removed for maintenance or testing and reinstalled after meeting the requirements of 1-3310, shall have the electrical and pneumatic connections verified either through mechanical/electrical inspection or test prior to the resumption of electric power generation. Main disc movement and set-pressure verification are not required.

RELATED 10CFR50.55a(f)(4)(iv) states:

REQUIREMENTS:

Inservice tests ofpumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in paragraph (b) of this section, subject to the limitations and modifications listed in paragraph (b) of this section, and subject to Commission approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions or addenda are met.

The requirements of Mandatory Appendix I, Paragraphs 1-3410(a) and (d) of the 2004 Edition of the ASME OM Code are not modified by 10CFR50.55a(b).

Reviews of differences between our current Code of Record, 2001 Edition of the ASME OM Code through the 2003 Addenda, and the 2004 Edition of the ASME OM Code did not result in identification of any related requirements to Mandatory Appendix I, Paragraphs 1-3410(a) and (d).

DURATION OF PROPOSED REQUEST:

STATUS:

The duration of the proposed request is for the remainder of GGNS's Third 10 Year Inservice Testing Interval, which began on December 1, 2007, and ends on November 30,2017.

Submitted for Nuclear Regulatory Commission approval.