GNRO-2015/00068, Supplemental Letter to GNRO-2015-00037: Application to Revise the Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing to Provide Relief Request in Format.

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Supplemental Letter to GNRO-2015-00037: Application to Revise the Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing to Provide Relief Request in Format.
ML15310A220
Person / Time
Site: Grand Gulf Entergy icon.png
Issue date: 11/06/2015
From: Kevin Mulligan
Entergy Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GNRO-2015/00068
Download: ML15310A220 (8)
v • d • e


Text

Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Tel. (601) 437-7500 GNRO-2015/00068 November 6,2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Supplemental Letter to Grand Gulf Nuclear Generating Station Letter GNRO-2015-00037: Application to Revise the Grand Gulf Nuclear Station Unit 1 Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing to Provide Relief Request in Format Requested by Nuclear Regulatory Commission (GG-IST-2015-1 )

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Reference:

GNRO-2015-00037: Application to Revise the Grand Gulf Nuclear Station Unit 1 Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing

Dear Sir or Madam:

This letter is being submitted to supplement the above referenced letter and to reformat , Description and Assessment of the Proposed Alternative to the ASME Code in accordance with request from the NRC on October 1, 2015. Please accept the attachment in this letter in place of Attachment 2 of Letter GNRO-2015/00037.

Pursuant to 10 CFR 50.55a(z)(2), Entergy Operations Inc. (Entergy) requests an alternative from the inservice testing (1ST) requirements of American Society Mechanical Enginee~ing (ASME) OM Code, for the Grand Gulf Nuclear Station (GGNS) Unit 1. Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.~

to Administrative Controls Program Tests, indicates that Surveillance Requirements (SRs) 3.0.2 and 3.0.3 cannot be applied to Technical Specification (TS) 5.5 for tests that are not associated with a TS SR. The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. The proposed alternative from the frequency specifications of the ASME OM Code is needed due to undue hardship without a compensating increase in the level of quality or safety. The proposed alternative for GGNS Unit 1 is provided in the attachment to this letter.

GNRO-2015/00068 Page 2 of 3 As requested in Letter GNRO-2015/00037 approval of the proposed amendment is requested.

Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Mississippi Official.

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103. '

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of November, 2015.

Sincerely,

~ .._---- 2 KJM/ram

Attachment:

Description and Assessment of Proposed Alternative to the ASME Code cc: with Attachment Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555

GNRO-2015/00068 Page 3 of 3 cc: without Attachment(s)

Mr. Mark Dapas Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission ATTN: Mr. M. Orenak, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Dr. Mary Currier, M.D., M.P.H State Health Officer Mississippi Department of Health P.O. Box 1700 Jackson, MS 39215-1700 Email: mary.currier@msdh.ms.gov

Attachment to GNRO-2015/00068 Description and Assessment of Proposed Alternative to the ASME Code

Attachment to GNRP-2015/00068 DESCRIPTION AND ASSESSMENT OF THE PROPOSED ALTERNATIVE TO THE ASME CODE Grand Gulf Relief Request GG-IST-2015-1 Request in Accordance with 10 CFR 50.55a(z)(2)

Alternative Provides Acceptable Level of Quality and Safety 1.0 ASME CODE COMPONENTS AFFECTED All pumps and valves contained within the Inservice Testing Program scope.

2.0 APPLICABLE CODE EDITION AND ADDENDA ASM~ OM Code-2001 Edition with addenda through and including the ASME OMb Code-2003 Addenda except that for Main Steam Safety Relief Valve testing GGNS implments Mandatory Appendix I, Paragraphs 1-3410(a) &(d) of the ASME OM Code-2004 Edition with no addenda. II 3.0 APPLICABLE CODE REQUIREMENTS This request applies to the frequency specifications of ASME OM Code. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

Code Paragraph Description -

ISTA-3120(a) "The frequency for the inservice testing shall be in accordance with the requirements of Section 1ST."

ISTB-3400 Frequency of Inservice Tests ISTC-3510 Exercising Test Frequency ISTC-3540 Manual Valves ISTC-3630(a) Frequency ISTC-3700 Position Verification Testing ISTC-5221 (c)(3) "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

ISTC-5260 Explosively Actuated Valves Appendix I, 1-1320 Test Frequencies, Class 1 Pressure Relief Valves Appendix I, 1-1330 Test Frequency, Class 1 Nonreclosing Pressure Relief Devices Appendix I, 1-1340 Test Frequency, Class 1 Pressure Relief Valves That are Used for Thermal Relief Application Appendix I, 1-1350 Test Frequency, Class 2 and 3 Pressure Relief Valves Appendix I, 1-1360 Test Frequency, Class 2 and 3 Nonreclosing Pressure Relief Devices Appendix I, 1-1370 Test Frequency, Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix I, 1-1380 Test Frequency, Class 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves

Attachment to GNRP-2015/00068 Appendix I, 1-1390 Test Frequency, Class 2 and 3 Pressure Relief Devices That are Used for Thermal Relief Application Appendix II, 11- Performance Improvement Activities 4000{a)(1 )

Appendix II, 11- Optimization of Condition-Monitoring Activities 4000{b)(1)(e) 4.0 REASON FOR REQUEST In RIS 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," and EGM 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests,"

the NRC stated that the current TS allowance to apply SR 3.0.2 and SR 3.0.3 to the Inservice Testing Program would no longer be permitted. In response, OMN-20, which provides allowances similar to SR 3.0.2, was approved and is proposed to be used as an alternative to the test periods specified in the OM code. The proposed change substitutes an approved Code Case for existing TS requirements that the NRC has determined are legally, but not technically, unacceptable as a TS allowance.

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (z)(2) , relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG 1482, Revision 1), and Owners applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TS) Surveillance Requirements (SRs). The TS allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (TS 3.0.2). However, Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests, states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be times when a surveillance test could be required (i.e., its frequency could expire), but plant conditions are not risk conducive or the testing may not even be possible until sometime after a plant condition or associated Limited Condition Operation (LCO) is within its applicability.

The NRC recognized this potential issue in the TS by allowing a frequency tolerance as described in TS 3.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility.

Attachment to GNRP-2015/00068 Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to better align with the plant conditions and other maintenance and testing activities. Providing a tolerance band assures operational flexibility for scheduling surveillance tests to minimize conflicts between the need to complete the surveillance and plant conditions.

5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE The proposed alternative is OMN-20, "Inservice Test Frequency," which addresses testing periods for pumps and valves specified in ASME OM Section 1ST, 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.

This request is being made in accordance with 10 CFR 50.55a(a)(z)(2) and is considered an alternative that provides an acceptable level of quality and safety for the following reasons:

1) For 1ST testing periods up to and including 2 years, Code Case OMN-20 provides an allowance to extend the 1ST testing periods by up to 25%. The period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g.,

performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified. The test period extension and the statements regarding the appropriate use of the period extension are equivalent to the existing TS SR 3.0.2 allowance and the statements regarding its use in the SR 3.0.2 Bases. Use of the SR 3.0.2 period extension has been a practice in the nuclear industry for many decades and there is no evidence that the period extensions affect component reliability.

2) For 1ST testing periods of greater than 2 years, OMN-20 allows an extension of up to 6 months. The ASME OM Committee determined that such an extension is appropriate. The 6-month extension will have a minimal impact on component reliability considering that the most probable result of performing any inservice test is satisfactory verification of the test acceptance criteria. As such, pumps and valves will continue to be adequately assessed for operational readiness when tested in accordance with the requirements specified in 10 CFR 50.55a(f) with the frequency extensions allowed by Code Case OMN-20.
3) As stated in EGM 2012-001, if an Inservice Test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed Inservice Test on the Operability of TS equipment will be assessed under the licensee's Operability Determination Program.

6.0 DURATION OF PROPOSED ALTERNATIVE The proposed alternative is requested to be permanent, effective through the term of the license, or until Code Case OMN-20 is incorporated into a future revision of Regulatory Guide 1.192, whichever occurs first.

Attachment to GNRP-2015/00068 7.0 PRECEDENTS The NRC approved the use of OMN-20 for Quad Cities on February 14, 2013 (NRC ADAMS Accession Number ML13042A348).

8.0 REFERENCES

  • ASME OM Code-2001 Edition with addenda through and including the ASME OMb Code-2003 Addenda except that for Main Steam Safety Relief Valve testing GGNS implments Mandatory Appendix I, Paragraphs 1-3410(a) &(d) of the ASME OM Code-2004 Edition with no addenda."

Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Kevin Mulligan Site Vice President Tel. (601) 437-7500 GNRO-2015/00068 November 6,2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Supplemental Letter to Grand Gulf Nuclear Generating Station Letter GNRO-2015-00037: Application to Revise the Grand Gulf Nuclear Station Unit 1 Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing to Provide Relief Request in Format Requested by Nuclear Regulatory Commission (GG-IST-2015-1 )

Grand Gulf Nuclear Station, Unit 1 Docket No. 50-416 License No. NPF-29

Reference:

GNRO-2015-00037: Application to Revise the Grand Gulf Nuclear Station Unit 1 Technical Specifications to Remove the Inservice Testing Program and to Clarify SR Usage Rule Application to Section 5.5 Testing

Dear Sir or Madam:

This letter is being submitted to supplement the above referenced letter and to reformat , Description and Assessment of the Proposed Alternative to the ASME Code in accordance with request from the NRC on October 1, 2015. Please accept the attachment in this letter in place of Attachment 2 of Letter GNRO-2015/00037.

Pursuant to 10 CFR 50.55a(z)(2), Entergy Operations Inc. (Entergy) requests an alternative from the inservice testing (1ST) requirements of American Society Mechanical Enginee~ing (ASME) OM Code, for the Grand Gulf Nuclear Station (GGNS) Unit 1. Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.~

to Administrative Controls Program Tests, indicates that Surveillance Requirements (SRs) 3.0.2 and 3.0.3 cannot be applied to Technical Specification (TS) 5.5 for tests that are not associated with a TS SR. The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to suit the plant conditions and other maintenance and testing activities. The proposed alternative from the frequency specifications of the ASME OM Code is needed due to undue hardship without a compensating increase in the level of quality or safety. The proposed alternative for GGNS Unit 1 is provided in the attachment to this letter.

GNRO-2015/00068 Page 2 of 3 As requested in Letter GNRO-2015/00037 approval of the proposed amendment is requested.

Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Mississippi Official.

This letter contains no new commitments. If you have any questions or require additional information, please contact James Nadeau at 601-437-2103. '

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th day of November, 2015.

Sincerely,

~ .._---- 2 KJM/ram

Attachment:

Description and Assessment of Proposed Alternative to the ASME Code cc: with Attachment Mr. John P. Boska, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555

GNRO-2015/00068 Page 3 of 3 cc: without Attachment(s)

Mr. Mark Dapas Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 East Lamar Boulevard Arlington, TX 76011-4511 U.S. Nuclear Regulatory Commission ATTN: Mr. M. Orenak, NRRlDORL Mail Stop OWFN/8 G14 11555 Rockville Pike Rockville, MD 20852-2378 NRC Senior Resident Inspector Grand Gulf Nuclear Station Port Gibson, MS 39150 Dr. Mary Currier, M.D., M.P.H State Health Officer Mississippi Department of Health P.O. Box 1700 Jackson, MS 39215-1700 Email: mary.currier@msdh.ms.gov

Attachment to GNRO-2015/00068 Description and Assessment of Proposed Alternative to the ASME Code

Attachment to GNRP-2015/00068 DESCRIPTION AND ASSESSMENT OF THE PROPOSED ALTERNATIVE TO THE ASME CODE Grand Gulf Relief Request GG-IST-2015-1 Request in Accordance with 10 CFR 50.55a(z)(2)

Alternative Provides Acceptable Level of Quality and Safety 1.0 ASME CODE COMPONENTS AFFECTED All pumps and valves contained within the Inservice Testing Program scope.

2.0 APPLICABLE CODE EDITION AND ADDENDA ASM~ OM Code-2001 Edition with addenda through and including the ASME OMb Code-2003 Addenda except that for Main Steam Safety Relief Valve testing GGNS implments Mandatory Appendix I, Paragraphs 1-3410(a) &(d) of the ASME OM Code-2004 Edition with no addenda. II 3.0 APPLICABLE CODE REQUIREMENTS This request applies to the frequency specifications of ASME OM Code. The frequencies for tests given in the ASME OM Code do not include a tolerance band.

Code Paragraph Description -

ISTA-3120(a) "The frequency for the inservice testing shall be in accordance with the requirements of Section 1ST."

ISTB-3400 Frequency of Inservice Tests ISTC-3510 Exercising Test Frequency ISTC-3540 Manual Valves ISTC-3630(a) Frequency ISTC-3700 Position Verification Testing ISTC-5221 (c)(3) "At least one valve from each group shall be disassembled and examined at each refueling outage; all valves in a group shall be disassembled and examined at least once every 8 years."

ISTC-5260 Explosively Actuated Valves Appendix I, 1-1320 Test Frequencies, Class 1 Pressure Relief Valves Appendix I, 1-1330 Test Frequency, Class 1 Nonreclosing Pressure Relief Devices Appendix I, 1-1340 Test Frequency, Class 1 Pressure Relief Valves That are Used for Thermal Relief Application Appendix I, 1-1350 Test Frequency, Class 2 and 3 Pressure Relief Valves Appendix I, 1-1360 Test Frequency, Class 2 and 3 Nonreclosing Pressure Relief Devices Appendix I, 1-1370 Test Frequency, Class 2 and 3 Primary Containment Vacuum Relief Valves Appendix I, 1-1380 Test Frequency, Class 2 and 3 Vacuum Relief Valves, Except for Primary Containment Vacuum Relief Valves

Attachment to GNRP-2015/00068 Appendix I, 1-1390 Test Frequency, Class 2 and 3 Pressure Relief Devices That are Used for Thermal Relief Application Appendix II, 11- Performance Improvement Activities 4000{a)(1 )

Appendix II, 11- Optimization of Condition-Monitoring Activities 4000{b)(1)(e) 4.0 REASON FOR REQUEST In RIS 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," and EGM 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests,"

the NRC stated that the current TS allowance to apply SR 3.0.2 and SR 3.0.3 to the Inservice Testing Program would no longer be permitted. In response, OMN-20, which provides allowances similar to SR 3.0.2, was approved and is proposed to be used as an alternative to the test periods specified in the OM code. The proposed change substitutes an approved Code Case for existing TS requirements that the NRC has determined are legally, but not technically, unacceptable as a TS allowance.

Pursuant to 10 CFR 50.55a, "Codes and standards," paragraph (z)(2) , relief is requested from the frequency specifications of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality or safety.

ASME OM Code Section 1ST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG 1482, Revision 1), and Owners applied the surveillance extension time period (i.e., grace period) contained in the plant Technical Specifications (TS) Surveillance Requirements (SRs). The TS allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (TS 3.0.2). However, Regulatory Issue Summary 2012-10, NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests, states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be times when a surveillance test could be required (i.e., its frequency could expire), but plant conditions are not risk conducive or the testing may not even be possible until sometime after a plant condition or associated Limited Condition Operation (LCO) is within its applicability.

The NRC recognized this potential issue in the TS by allowing a frequency tolerance as described in TS 3.0.2. The lack of a similar tolerance applied to OM Code testing places an unusual hardship on the plant to adequately schedule work tasks without operational flexibility.

Attachment to GNRP-2015/00068 Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to better align with the plant conditions and other maintenance and testing activities. Providing a tolerance band assures operational flexibility for scheduling surveillance tests to minimize conflicts between the need to complete the surveillance and plant conditions.

5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE The proposed alternative is OMN-20, "Inservice Test Frequency," which addresses testing periods for pumps and valves specified in ASME OM Section 1ST, 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.

This request is being made in accordance with 10 CFR 50.55a(a)(z)(2) and is considered an alternative that provides an acceptable level of quality and safety for the following reasons:

1) For 1ST testing periods up to and including 2 years, Code Case OMN-20 provides an allowance to extend the 1ST testing periods by up to 25%. The period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g.,

performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used repeatedly merely as an operational convenience to extend test intervals beyond those specified. The test period extension and the statements regarding the appropriate use of the period extension are equivalent to the existing TS SR 3.0.2 allowance and the statements regarding its use in the SR 3.0.2 Bases. Use of the SR 3.0.2 period extension has been a practice in the nuclear industry for many decades and there is no evidence that the period extensions affect component reliability.

2) For 1ST testing periods of greater than 2 years, OMN-20 allows an extension of up to 6 months. The ASME OM Committee determined that such an extension is appropriate. The 6-month extension will have a minimal impact on component reliability considering that the most probable result of performing any inservice test is satisfactory verification of the test acceptance criteria. As such, pumps and valves will continue to be adequately assessed for operational readiness when tested in accordance with the requirements specified in 10 CFR 50.55a(f) with the frequency extensions allowed by Code Case OMN-20.
3) As stated in EGM 2012-001, if an Inservice Test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed Inservice Test on the Operability of TS equipment will be assessed under the licensee's Operability Determination Program.

6.0 DURATION OF PROPOSED ALTERNATIVE The proposed alternative is requested to be permanent, effective through the term of the license, or until Code Case OMN-20 is incorporated into a future revision of Regulatory Guide 1.192, whichever occurs first.

Attachment to GNRP-2015/00068 7.0 PRECEDENTS The NRC approved the use of OMN-20 for Quad Cities on February 14, 2013 (NRC ADAMS Accession Number ML13042A348).

8.0 REFERENCES

  • ASME OM Code-2001 Edition with addenda through and including the ASME OMb Code-2003 Addenda except that for Main Steam Safety Relief Valve testing GGNS implments Mandatory Appendix I, Paragraphs 1-3410(a) &(d) of the ASME OM Code-2004 Edition with no addenda."
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