ML20058G943
| ML20058G943 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 12/03/1993 |
| From: | Oconnor P Office of Nuclear Reactor Regulation |
| To: | Hutchinson C ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M88076, NUDOCS 9312100188 | |
| Download: ML20058G943 (10) | |
Text
._
December 3, 1993 Docket No. 50-416 Mr. C. Randy Hutchinson Vice President, Operations GGNS i
Entergy Operations, Inc.
Post Office Box 756 j
Port Gibson, Mississippi 39150 j
i
Dear Mr. Hutchinson:
I
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO ALTERNATIVES T0 10 CFR 50.55A(f) AND (g), 10-YEAR INSERVICE INSPECTION AND INSERVICE TESTING UPDATE - GRAND GULF NUCLEAR STATION (TAC NO. M88076)
The staff is continuing its review of your submittal dated October 21, 1993, in which you proposed alternatives to the requirements of 10 CFR 50.5a(f) and (g) regarding automatic licensee endorsement of the latest edition of the ASME code every 10 years.
To permit us to continue our review on our current schedule, we require that the information requested in the enclosure be provided during the meeting scheduled with the staff on December 6, 1993.
This requirement affects fewer than ten respondents and, therefore, is not I
subject to Office of Management and Budget review under Public Law 96-511.
Sincerely, ORIGINAL SIGNED BY:
Paul W. O'Connor, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation j
Enclosure:
Comments and Questions cc w/ enclosure:
See next page DISTRIBUTION-Docket-Files NRC & Local PDRs PD4-1 Reading P. Noonan E. Adensam J. Roe W. Beckner P. O'Connor E. Merschoff, RII 1
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December 3, 1993 Docket No. 50-416 Mr. C. Randy Hutchinson Vice President, Operations GGNS Entergy Operations, Inc.
Post Office Box 756 Port Gibson, Mississippi 39150
Dear Mr. Hutchinson:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO ALTERNATIVES TO 10 CFR I
50.55A(f) AND (g), 10-YEAR INSERVICE INSPECTION AND INSERVICE TESTING UPDATE - GRAND GULF NUCLEAR STATION (TAC N0. M88076)
The staff is continuing its review of your submittal dated October 21, 1993, in which you proposed alternativas to the requirements of 10 CFR 50.5a(f) and (g) regarding automatic licensee endorsement of the latest edition of the ASME code every 10 years.
To permit us to continue our review on our cunent schedule, we require that the information requested in the enclosure be provided during the meeting scheduled with the staff on December 6,1993.
This requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under Public Law 96-511.
Sincerely, ORIGINAL SIGNED BY:
Paul W. O'Connor, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation t
Enclosure:
Comments and Questions cc w/ enclosure:
See next page DISTRIBUTION:
Docket File NRC & Local PDRs PD4-1 Reading P. Noonan E. Adensam J. Roe W. Beckner P. O'Connor E. Herschoff, RII ACRS (10)
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,E WASHINGTON, D.C. 20556-0001 s., s., f tecember 3, 1993 Docket No. 50-416 Mr. C. Randy Hutchinson Vice President, Operations GGNS Entergy Operations, Inc.
Post Office Box 756 Port Gibson, Mississippi 39150
Dear Mr. Hutchinson:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO ALTERNATIVES TO 10 CFR 50.55A(f) AND (g), 10-YEAR INSERVICE INSPECTION AND INSERVICE TESTING UPDATE - GRAND GULF NUCLEAR STATION (TAC NO. MB8076)
The staff is continuing its review of your submittal dated October 21, 1993, in which you proposed alternatives to the requirements of 10 CFR 50.5a(f) and (g) regarding automatic licensee endorsement of the latest edition of the ASME code every 10 years.
To permit us to continue our review on our current schedule, we require that the information requested in the enclosure be provided during the meeting scheduled with the staff on December 6,1993.
This requirement affects fewer than ten respondents and, therefore, is not subject to Office of Management and Budget review under Public Law 96-511.
Sincerely, r
Paul W. O'Connor, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation
Enclosure:
Comments and Questions cc w/ enc ksure:
See next page
Mr. C. Randy Hutchinson Entergy Operations, Inc.
Grand Gulf Nuclear Station cc:
Mr. H. W. Keiser, Exec. Vice President Mr. D. L. Pace and Chief Operating Officer GGNS General Manager Entergy Operations, Inc.
Entergy Operations, Inc.
P. O. Box 31995 P. O. Box 756 Jackson, Mississippi 39286-1995 Port Gibson, Mississippi 39150 Robert B. McGehee, Esquire The Honorable William J. Guste, Jr.
Wise, Carter, Child & Caraway Attorney General P. O. Box 651 Department of Justice Jackson, Mississippi 39205 State of Louisiana P. O. Box 94005 Nicholas S. Reynolds, Esquire Baton Rouge, Louisiana 70804-9005 Winston & Strawn 1400 L Street, N.W. - 12th Floor Dr. F. E. Thompson, Jr.
Washington, D.C.
20005-3502 State Health Officer State Board of Health Mr. Sam Mabry, Director P. O. Box 1700 Division of Solid Waste Management Jackson, Mississippi 39205 Mississippi Department of Natural Resources Office of the Governor P. O. Box 10385 State of Mississippi Jackson, Mississippi 39209 Jackson, Mississippi 39201 President, Mike Morre, Attorney General Claiborne County Board of Supervisors Frank Spencer, Asst. Attorney General Port Gibson, Mississippi 39150 State of Mississippi Post Office Box 22947 Regional Administrator, Region 11 Jackson, Mississippi 39225 U.S. Nuclear Regulatory Comission 101 Marietta St., Suite 2900 Mr. Jerrold G. Dewease Atlanta, Georgia 30323 Vice President, Operations Support Entergy Operations, Inc.
Mr. W. W. Watson P.O. Box 31995 Project Manager Jackson, Mississippi 39286-1995 Bechtel Power Corporation P.O. Box 808, 4600 W. Main Mr. Michael J. Meisner Russellville, Arkansas 72801 Director, Nuclear Safety and Regulatory Affairs Mr. K. G. Hess Entergy Operations, Inc.
Bechtel Power Corporation P.O. Box 756 P. O. Box 2166 Port Gibson, Mississippi 39150 Houston, Texas 77252-2166 1
Mr. Rudolph H. Bernhard Senior Resident Inspector i
U.S. Nuclear Regulatory Comission Route 2, Box 399 Port Gibson, Mississippi 39150
i ENCLOSURE Coments and Questions for Entergy Meeting December 6, 1993 4
I.
Demonstrate Process i
1 A.
Identification of revisions in applicable Code edition.
B.
Determination of which revisions are safety significant and how these will be implemented. Criteria.
C.
For medium impact revisions, describe criteria for addressing the accumulated impact from a safety standpoint.
D.
Determination of revisions that are relaxations of previous requirements and the implementation of these.
E.
Flow-chart the process, if possible.
II.
Questions or Items to be Addressed.
A.
List the assumptions for the breakdown of the costs savings of $3M estimated for Grand Gulf.
B.
Because a number of points Entergy makes in the request seem to be related to the ASME Code process rather than representing regulatory issues, discuss why the request was made to the NRC rather than working for changes to concerns the utility has with the ASME Code process.
C.
Page 10:
Entergy uses the word " worthwhile" to characterize the justification for many of the Code changes. Code changes are either editorial or technical.
" Worthwhile" is not a criterion.
Changes are made by the Code comittees because they are deemed necessary for clarity or for technical reasons. Why does Entergy feel that the Code consensus process is not sufficiently structured to prevent incorporation of unnecessary revisions? The NRC's view is that the industry, through the consensus process, believes that many of the revisions are necessary because they address impracticalities or relax requirements determined not to be nececary to safety.
Entergy's representatives on the Code comittees have been involved in a number of the revisions made to the Code.
D.
Page 11:
Entergy claims that licennes have historically objected to the Code incorporation process of i0 CFR 50.55a not being justified in accordance with the backfit provisions of 10 CFR t
50.109 and that the Comission has "corsistently responded by quoting the General Counsel opinion" that the incorporation is not a backfit because it is based on a cor.sensus standard. What is the basis for Entergy's contention that the objections by licensees is widespread? The staff is aware of only one licensee comenting one time during a public coment period for proposed 1
rulemaking.
Furthermore, the staff is not aware of any informal objections being made at any previous Code meetings.
E.
Page 12: The alternative appears to be internally inconsistent.
The first paragraph indicated that the applicable Code edition for successive 120-month inspection intervals will be the latest edition and addenda " committed to by the licensee as of the approval date of this proposed alternative... and subject to the following paragraphs." The next paragraph states that "[1]n lieu of the above referenced Code edition and addenda, inservice examinations... will comply with the requirements of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of 10 CFR 50.55a 12 months prior to the start of the 120-month inspection interval... for which there is a substantial increase in the overall protection of the public health and safety...." What does Entergy intend for the portions of the Code which do not represent the " substantial increase" in safety? Will the requirements of the prior edition be maintained? If so, the language "in lieu of" should probably be "in addition to."
Please clarify the intent.
F.
Page 13: Related to the discussion in "E" above, do options (1) and (2) imply that Entergy will declare having updated to the later edition which in fact only portions of the later revision were incorporated? How will Entergy determine whether or not the Comission has " reviewed or approved" the combination of requirements as "related" requirements?
G.
Page 14:
In option (3), Enterg3 indicates that, in updating at the 120-month interval, the " licensee would still be required to evaluate the regulatory analyses of the latest edition and addenda of the Code incorporated by reference in paragraph (b) of 10 CFR 50.55a 12 months prior to the start of the 120-month inspection interval." This implies that the regulatory analysis of revisions incorporated in the intervening 120 months will not be reviewed.
How will the licensee ensure that changes which were made in earlier editions, carried through to the later edition, which the Comission identified in the regulatory analysis as significant are incorporated into the inspection and testing programs? Does the statement also imply that Entergy will be depending solely on the NRC's regulatory analysis, which has a general industry basis, to identify safety significant issues? How does this ensure that any issues that may be safety significant on a plant-specific basis are addressed?
Entergy further states that "[t]here would be no requirement to evaluate generalizations about potential safety increases contained in the regulatory analyses which are not referenced to specific Code changes or specific combinations of changes." The regulatory analysis does not address the cumulative effect of each change, but rather relies on the integration of the overall changes to ensure an acceptable level of safety which allows 2
a.
endorsement of the edition and addenda into the regulations. The regulatory analysis has never been structured to be used in the manner Entergy describes.
H.
Page 15:
In support of the justification for the proposed process ensuring an acceptable level of quality and safety, Entergy indicates that "[1]ater NRC approved Code editions and addenda (or portions thereof) would be adopted provided a substantial increase in safety would result and was cost justified." When the NRC authorizes alternatives pursuant to 10 CFR 50.55a(a)(3)(1), cost is not an acceptable basis. The statement seems to imply that the regulatory analysis is always based on cost justification, when in fact, even under the provisions of 10 CFR 50.109, there are three criteria where "backfit" does not apply:
(1) compliance, (2),
adequate protection, and (3) defining or redefining what level of protection to the public should be regarded as adequate. The regulatory analysis for incorporation of Code changes is not per se a backfit analysis.
In fact, the NRC does not "backfit" Code editions. When a change to 10 CFR 50.55a implements requirements which are beyond those in the Code or accelerates a schedule for requirements in the Code, a "backfit" analysis is performed and is discussed in the regulatory analysis, such as was the implementation schedule for reactor vessel weld examinations in the rulemaking effective September 8,1992. Additionally, the majority of the revisions in the Code are relaxations which tend to " redefine" what level of safety should be regarded as adequate and tend to decrease costs, other than procedure and program administrative type changes. Technological changes may be necessary over the life of a plant due to the accumulated effect of Code revisions, particularly in light of industry experience identifying problems areas where more emphasis is needed and the allowance for relaxations where less emphasis may be acceptable.
I.
Page 15:
Entergy states that the "' automatic Code endorsement' process as currently implemented tends to undermine processes subject to 10 CFR 50.109" by demanding utility resources to perform facility or procedure modifications which do not routinely provide substantial increases in safety, and that the regulatory relief process may also create a burden. Would not the proposed process described in the alternative, if adequately implemented on a plant-specific basis which does not rely on the NRC regulatory analysis, require a substantial allocation of resources on the level of implementing the latest edition of the Code and requesting relief where necessary?
J.
Page 16: What is the " additional licensee evaluation" which is referenced in the context of determining the safety impact of a potential change?
K.
Page 16:
Entergy states that 10 CFR 50.55a " currently prohibits licensees" from using later editions without Commission approval.
The original basis for the regulations requiring Commission 3
approval for using later editions, or portions thereof, was to preclude implementation of requirements (or relaxations) that, in combination with requirements of earlier editions could result in a decrease in overall safety, while still including an allowance for a licensee to request implementation if it could show that overall safety would not be decreased. The NRC has a process of approving later editions or portions the::f through endorsement of ASME Code cases through reference in footnoi.? 6 of 10 CFR 50.55a. Therefore, to state that the regulatio.is " prohibit" licensees from using later editions of the Code is an inappropriate characterization of the provisions of 10 CFR 50.55a(f)(4)(iv) and (g)(4)(iv).
L.
Page 16: Entergy states that "[c]hanges (i.e. backfits) to the Code editions and addenda which do provide a substantial increase to public health and safety have been, and would continue to be, imposed upon licensee by the Commission through processes separate from the update of Code references in 10 CFR 50.55a (e.g. specific rulemaking, Generic Letters, Bulletins)." The Comission does not perform a backfit analysis of the changes to the Code, as noted above. The two cases where a backfit analysis may be performed for rulemaking for 10 CFR 50.55a are (1) when requirements are imposed that are beyond the scope of the Code or the previous regulations, and (2) where an accelerated schedule of Code requirements of an edition incorporated in 10 CFR 50.55a(b) is imposed. The Comission has required an accelerated schedule only in a few cases over the existence of 10 CFR 50.55a. The basis for
+
allowing licensees to wait to incorporate changes during the 120-month updates is that the integrated effect of Code editions, taken in their entirety, balance out safety. While Entergy may see a concern in the Comission not more frequently imposing Code requirements on an accelerated basis, it could also be viewed from another perspective which is inherent to the basis for the use of Codes and Standards in the regulations. Similarly, if the Commission believed that the Codes and Standards decreased safety in revisions that are considered for incorporation, limitations and modifications to the editions are stated in the regulation.
H.
Pages 16 and 17: Explain Paragraph (c) regarding using portions of later editions of the Code.
It is unclear what is meant by
"[i]t is noted that any increase to public health and safety would not be substantial since such changes are processed by the Comission separate from the ' incorporation by reference."
N.
Page 17: As discussed above, the NRC's regulatory analysis does not explicitly address the integrated effect of revisions to the i
Code.
Entergy states in Paragraph (e) that "the regulatory analyses are sufficiently detailed in expressing the Comission's opinion on the interrelationships of any changes to the Code editions and addenda" and implies that the licensee will rely on the regulatory analysis to determine the related requirements for implementing only portions of later editions. The regulatory 4
analysis addresses changes on a change-by-change basis and only generally states that the integrated effect provides an acceptable level of safety.
In light of this discussion, is Entergy's position in Paragraph (e) affected?
0.
Page 21: What failure rates for motor-operated valves and pumps were used for the reduction in core damage frequency discussed?
P.
Page 21, Item 6: Give examples of the "various pilot studies" and identify the level of resources diverted to Code changes. What resources are currently being diverted to implement Code changes that "the Commission has already determined will only provide slight changes to public risk, if any," and what is the basis for this statement?
Q.
Page 21:
In the burden reduction, it discusses that the submittal of relief requests imposes resource and financial burden.
Entergy has not requested an alternative to the provisions in 10 CFR 50.55a (f)(6)(1) or (g)(6)(1) for impracticalities necessitating relief from the Code requirements.
Entergy further states that the relief request process does not represent a substantial cost, yet the proposed alternative is "less burdensome." Please explain the basis for this conclusion.
R.
Explain how IPEs will be used in this process.
Entergy's discussion under Item 5, Page 19, appears to make a risk-based argument that inservice inspection (ISI) and inservice testing (IST) have an inconsequential impact on plant safety. How does this relate to your intended implementation of the proposed alternative? Is it Entergy's contention that ISI and IST requirements can be eliminated from, or not incorporated in, the programs if it is determined they do not impact safety based on a PRA/IPE type analysis?
S.
Generic Letter (GL) 89-04 allowed licensees to continue to rely on relief requests that had been previously submitted and did not conflict with the eleven positions included in Attachment I to the generic letter. The basis of this provision of GL 89-04 was to eliminate the backlog of inservice testing relief request review.
Part of the justification for this not creating a safety concern was, aside from the fact that most utilities were implementing the relief requests upon submittal rather than upon NRC approval, was that all relief requests submitted in the plants' next 10-year update would be reviewed.
Except for ANO-2, each of the Entergy plants has relief requests that were approved under this provision of GL 89-04 which have not, in fact, been specifically evaluated and which possibly would not be approved in cases where technology changes preclude the need for relief. Technological changes form part of the basis for 10-year updates required by 10 CFR 50.55a.
How will Entergy address this issue at the next 10-year update under the propcred alternative?
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T.
Does Entergy intend to " standardize" the ISI and IST programs at the four plants? If not, except for tiie differences between specific designs, how will implementation of certain Code requirement: at one site impact the justification for not implementing the requirements at the other sites? How will Entergy justify not implenenting " substantial safety" issues on an accelerated basis, much as the concerns expressed in the NRC allowing later implementation during 10-year updates?
U.
Explain how the licensees will maintain a status of the programs and which requirements of which editions apply. How will decision; of the use or nonuse of certain portions be documented?
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