ML100540183

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Relief Request to Use a Portion of a Later Edition of the ASME OM Code for Main Steam Safety Relief Valve Inservice Testing
ML100540183
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 03/15/2010
From: Markley M
Plant Licensing Branch IV
To:
Entergy Operations
Lyon, C F, NRR/DLPM, 415-2296
References
TAC ME2433
Download: ML100540183 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 15, 2010 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - REQUEST TO USE PORTION OF LATER EDITION TO THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE FOR OPERATION AND MAINTENANCE OF NUCLEAR POWER PLANTS (TAC NO. ME2433)

Dear Sir or Madam:

By letter dated October 22,2009, as supplemented by letter dated December 14, 2009, Entergy Operations, Inc. (Entergy, the licensee), requested approval to use a portion of a later edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (1ST) program at Grand Gulf Nuclear Station, Unit 1 (GGNS). Specifically, approval was requested to apply the requirements of Mandatory Appendix I, paragraphs 1-3410(a) and (d), of the 2004 Edition of ASME OM Code for main steam safety relief valve 1ST. The licensee requested approval for the remainder of GGNS's third 10-year 1ST interval, which began on December 1, 2007, and ends on November 30,2017.

The licensee's request was made pursuant to paragraph 50.55a(f)(4)(iv) of Title 10 of the Code of Federal Regulations (10 CFR) and in accordance with the guidance provided in Nuclear Regulatory Commission (NRC) Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI." Based on the information provided in your request, pursuant to 10 CFR 50.55a(f)(4)(iv), the NRC staff approves the use of the 2004 Edition of ASME OM Code, Mandatory Appendix I, paragraphs 1-3410(a) and (d) at GGNS for main steam safety relief valve 1ST for the remainder of the third 1O-year 1ST interval.

- 2 The results of the NRC staff review are provided in the enclosed safety evaluation. If you have any questions, please contact the NRC Project Manager, Fred Lyon, at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

As stated cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO USE OF A LATER EDITIOI\\J OF THE ASME OM CODE FOR MAIN STEAM SAFETY RELIEF VALVE INSERVICE TESTING FOR THE THIRD 10-YEAR INTERVAL ENTERGY OPERATIONS, INC.

GRAND GULF NUCLEAR STATION, UNIT 1 DOCKET NO. 50-416

1.0 INTRODUCTION

By letter dated October 22, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092960344), as supplemented by letter dated December 14, 2009 (ADAMS Accession No. ML093490371), Entergy Operations, Inc. (Entergy, the licensee),

requested approval to use a portion of a later edition of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) for the inservice testing (1ST) program at Grand Gulf Nuclear Station, Unit 1 (GGNS).

Specifically, approval was requested to apply the requirements of Mandatory Appendix I, paragraphs 1-341 O(a) and (d), of the 2004 Edition of ASME OM Code for main steam safety relief valve 1ST. The licensee requested approval for the remainder of GGNS's third 10-year 1ST interval, which began on December 1,2007, and ends on November 30, 2017.

2.0 REGULATORY EVALUATION

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a, "Codes and standards,"

requires that 1ST of certain ASME Code Class 1, 2, and 3 pumps and valves be performed at 120-month (1 O-year) 1ST program intervals in accordance with the specified ASME Code and applicable addenda incorporated by reference in the regulations, except where alternatives have been authorized or relief has been requested by the licensee and granted by the Nuclear Regulatory Commission (NRC) pursuant to paragraphs (a)(3)(i), (a)(3)(ii), or (f)(6)(i) of 10 CFR 50.55a. In accordance with 10 CFR 50.55a(f)(4)(ii), licensees are required to comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in the regulations 12 months prior to the start of each 120-month 1ST program interval. In accordance with 10 CFR 50.55a(f)(4)(iv), 1ST of pumps and valves may meet the requirements set forth in subsequent editions and addenda that are incorporated by reference in 10 CFR 50.55a(b), subject to NRC approval. Portions of editions or addenda may be used provided that all related requirements of the respective editions and addenda are met. NRC guidance Enclosure

- 2 contained in Generic Letter (GL) 89-04, "Guidance on Developing Acceptable Inservice Testing Programs," dated April 3, 1989 (ADAMS Legacy Library Accession No. 8903300105), provides alternatives to ASME Code requirements which are acceptable. Further guidance is given in GL 89-04, Supplement 1, dated April 4, 1995 (ADAMS Legacy Library Accession No. 9503280042), and NUREG-1482, Revision 1, "Guidance for Inservice Testing at Nuclear Power Plants," dated January 2005 (ADAMS Accession No. ML050550290). NRC Regulatory Issue Summary (RIS) 2004-12, "Clarification on Use of Later Editions and Addenda to the ASME OM Code and Section XI," dated July 28,2004 (ADAMS Accession No. ML042090436),

also provides guidance for use of later Code editions.

The NRC staff's evaluation with respect to granting or denying the licensee's request is given below.

3.0 TECHNICAL EVALUATION

3.1 Affected Components All main steam safety relief valves (20 installed valves) in the GGNS 1ST program (Dikkers Valves Model G-471).

3.2 Applicable Code The applicable Code of record for GGNS is the ASME OM Code, 2001 Edition through 2003 Addenda. This Code requires that active Category A and B valves be tested nominally every 3 months, with certain exceptions.

3.3 Proposed Portion of Subsequent Code Edition and Addenda The licensee requested approval to use the portions of the 2004 Edition of the ASME OM Code related to 1ST of Class 1 Main Steam Pressure Relief Valves with Auxiliary Actuating Devices.

Paragraph 50.55a(b) of 10 CFR incorporates by reference the 2004 Edition of the ASME OM Code for 1ST programs (73 FR 52730, dated September 10, 2008).

Specifically, the licensee would apply the requirements of the 2004 Edition of the ASME OM Code, Mandatory Appendix I, paragraphs 1-341 O(a) and (d), which state:

(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 1-341 O(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.

- 3 The licensee proposes to apply these paragraphs to all of the 20 installed main steam safety relief valves in the 1ST program at GGNS.

3.4 Technical Bases The 2004 Edition of the ASME OM Code for 1ST programs was incorporated by reference into 10 CFR 50.55a(b), subject to the limitations and modifications imposed by 10 CFR 50.55a(b)(3).

There are no additional limitations or modifications imposed by 10 CFR 50.55a(b)(3) on the use of Mandatory Appendix I, paragraphs 1-3410(a) and (d), with regard to 1ST of Class 1 Main Steam Pressure Relief Valves with Auxiliary Actuating Devices.

3.5 Duration of Proposed Request The duration of the proposed request is for the remainder of GGNS's third 10-year 1ST interval, which began on December 1,2007, and ends on November 30,2017.

3.6

NRC Staff Evaluation

The requirements of 10 CFR 50.55a(f)(4)(iv) allow licensees to use subsequent editions and addenda of the ASME OM Code, provided that editions and addenda are incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed in 10 CFR 50.55a(b)(3), 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 10 CFR 50. 55a(b) allow use of the 2004 Edition of the ASME OM Code, subject to the modifications and limitations imposed by 10 CFR 50.55a(b)(3).

The licensee has requested approval to test the Class 1 main steam pressure relief valves in accordance with Mandatory Appendix I, paragraphs 1-3410(a) and (d) of the 2004 Edition of the ASME OM Code. There are no further limitations or modifications imposed by 10 CFR 50.55a(b)(3) on the use of paragraphs 1-3410(a) and (d) with regard to 1ST of Class 1 Main Steam Pressure Relief Valves with Auxiliary Actuating Devices. The NRC staff identified no additional related requirements in the specified ASME OM Code edition that need to be met in order to implement the use of Mandatory Appendix I, paragraphs 1-341 O(a) and (d).

4.0 CONCLUSION

Based on the above, the NRC staff determines the licensee's request is acceptable. Therefore, pursuant to 10 CFR 50.55a(f)(4)(iv), the staff approves the request to use the 2004 Edition of the ASME OM Code, Mandatory Appendix I, paragraphs 1-3410(a) and (d) for the remainder of the third 10-year 1ST interval at GGNS.

Principal Contributor: J. Billerbeck Date: IVlarch 15, 2010

- 2 The results of the NRC staff review are provided in the enclosed safety evaluation. If you have any questions, please contact the NRC Project Manager, Fred Lyon, at 301-415-2296 or via e-mail at fred.lyon@nrc.gov.

Sincerely, IRA!

Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPLIV rlf RidsAcrsAcnw_MailCTR Resource RidsNrrDciCptb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrLA~IBurkhardt Resource RidsNrrPMGrandGulf Resource RidsOgcRp Resource RidsRgn4MailCenter Resource JBillerbeck, NRR ADAMS Accession No: ML100540183

  • memo dated OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/CPTB/BC NRR/LPL4/BC NAME FLyon BSingal for JBurkhardt AMcMurtray*

MMarkley DATE 3/12/10 3/10/10 2/18/10 3/15/10 OFFICIAL AGENCY RECORD