ML20058J868
| ML20058J868 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, Waterford  |
| Issue date: | 12/09/1993 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO-93-00159, GNRO-93-159, NUDOCS 9312140275 | |
| Download: ML20058J868 (6) | |
Text
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w ENTERGY PJI*'25" " ' ' " " " * '
Pyt Gt ;n LG 39150 id f/J : 437 2500 C. R. Hutchinson n cFv & a December 9,1993 g;gg;y,,
U.S. Nuclear Regulatory Commission Mail Station P1-137 Washington, D.C. 20555 t
Attention:
Document Control Desk
SUBJECT:
Proposed Alternative to 10CFR 50.55a(f) and (g),10-Year inservice Inspection & Inservice Testog Update, Supplementary Information Arkansas Nuclear One Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. DPR-51 & NPF-6 i
Grand Gulf Nuclear Station Unit 1 Docket No. 50-416 License No. NPF-29 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 GNRO-93/00159 i
i Gentlemen:
We believe our meeting on December 6 was fruitful in raising and addressing l
questions associated with Entergy's proposed alternative to the 10-year ISI/IST i
requirements of 10CFR50.55a.
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To assist your review and development of further questions we have provided the attached supplement to our original request which summarizes much of the programmatic detail discussed with you earlier this week, as well as some items that the length of the meeting prevented us from fully addressing.
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December 9,1993 1
GNRO-93/00159 Page 2 of 3 Should you have any questions, please contact George Zinke at 601-437-2459.
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Yours truly,
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GAZ/be attachment:
Supplement to Alternative to 10CFR50.55a(f) and (g) cc:
Mr. T. W. Alexion Mr. R. P Barkhurst
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Mr. R. H. Bernhard Mr. R. B. Bevan, Jr.
Mr. J. L. Blount Mr. P. L. Campbell Mr. J. L. Colvin Mr. S. D. Ebneter Mr. E. J. Ford Mr. C. R. Hutchinson Mr. G. Johnson Mr. H. W. Keiser Mr. L. D. Marsh Mr. R. B. McGehee Mr. J. L. Mihoan Mr. G. C. Millman
'I Mr. J. A. Norberg Mr. P. W. O'Connor J
Mr. N. S. Reynolds
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Ms. L. J. Smith
- J Mr. E. J. Sullivan Mr. F. W. Titus I
Mr. K. R. Wichman
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Mr. J. T. Wiggins Mr. D. L. Wigginton Mr. J. W. Yelverton Central File (GGNS)[ 7 )
DCC (ANO)
Records Center (W-3) 2 Corporate File [ 7 )
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GNRO-93/00159 Page 1 of 4 The following provides supplementary information concerning the proposed i
alternative to 10CFR 50.55a(f) and (g),10-Year Inservice inspection & Inservice Testing Update submitted for Commission approval on October 21,1993 by Entergy Operations, Inc.
l 1.
KEY PROGRAM ELEMENTS A. Purpose The purpose of the proposed alternative to 10CFR 50.55a(f) and (g),10-
.i Year Inservice inspection a inservice Testing Update, is to apply a l
systematic and disciplined process in 1) ensuring that cost beneficial l
Code changes which provide a substantial increase in the protection of the public health and safety are appropriately implemented, and 2) allowing responsible business decisions to be made with regard to Code changes which do not provide a substantial increase in the protection of the public health and safety or are not cost beneficial.
i B. Scope j
The proposed alternative would apply only to NRC-approved ASME code editions / addenda later than the current baseline. Changes to baseline commitments would not be subject to this attemative (i.e. proposed j
changes and/or relaxations would remain subject to the standard l
relief / exemption processes of 10CFRS0).
j Likewise, the limitations, modifications, and augmented inspection requirements contained in section (b) of 10CFR50.55a would not be i
subject to the proposed alternative program (i.e. compliance with these I
prescriptive requirements would continue to be required).
j C. Interval i
The proposed alternative would maintain the 10 year interval as currently established by 10CFR50.55a and the ASME code. Changes to the Code j
would be required to be evaluated for potential implementation prior to the beginning of each 10-year interval. Changes to the Code could be evaluated for implementation and implemented at any time during the l
respective 10-year interval.
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GNRO-93/00159 Page 2 of 4 D. Proposed ISI/IST Review Process
- 1. Screening Process a.
Prior to the beginning of each 10-year interval, each Entergy licensee would determine the differences between the current ISI/IST Program and the latest edition and addenda of the ASME Code approved by the NRC for use (i.e. incorporated in 10CFR50.55a by reference) 12 months prior to the start of the 10-year interval.
b.
A screening process may be applied that would identify which changes were to be incorporated into the ISI/IST Program without further evaluation, and which changes were to be evaluated for potential non-implementation.
- c. The need for new relief requests / proposed alternatives / and/or exemptions would also be evaluated. The subject of "new relief requests / proposed alternatives / and/or exemptions" is not affected l
by this submittal and would be subject to the current rules and processes of 10CFR50.
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- 2. Evaluation Process a.
All Code changes screened into the potential non-implementation grouping would be evaluated to determine if they could provide substantial safety benefit.
b.
Entergy would evaluate related requirements of the appropriate Code editions and addenda together. The determination of "related" involves engineering judgment. In general the definition of "related" requirements is those requirements which 1) must be used together in order to achieve the desired safety benefit, and 2) could result in an undesired reduction in safety if separated. The experience and expertise of Entergy personnel in Code-related issues is adequate to support this judgment.
c.
In general, the evaluation process would make use of Probabilistic Risk Assessment (PRA) tools to determine if the Code changes involved substantial safety increases. The criteria currently planned for use in this determination are as follows:
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GNRO-93/00159
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Page 3 of 4 1
involved substantial safety increases. The criteria currently I
planned for use in this determination are as follows:
Code changes which could result in an estimated reduction in core damage frequency > 1E-6/ reactor year would be judged to be substantial.
The effect of Code changes on containment performance would also be evaluated. A combination of the IPE Level 2 sequence screening criteria (containment release probability >1E-7) and conditional probability of early I
containment failure or bypass would be used.
These criteria are consistent with and more conservative than the criteria presented in Draft NUREG/BR-0058 Regulatory Analysis i
Guide!ines.
i d.
Use of PRA would intrinsically require an evaluation of PRA modeling and assumptions to ensure that 1) PRA was an
= appropriate tool for the evaluation and 2) the current assumptions concerning initiator and/or failure frequencies were valid. Code changes which are clearly safety-consequential but are not l
amenable to probabilistic evaluation will be implemented.
e.
Individual or groups of "related" changes which were judged to.
i have substantial safety benefit would be subject to a value/ impact i
(cost / benefit) analysis. The form of this value/ impact analysis would be similar to that presented in the GGNS IPE submittal.
l f.
Code changes being evaluated which met the test criteria for substantially increasing safety and for being cost beneficial, would be implemented. Code changes which either did not substantially increase safety or were not cost beneficial, would not be required to be implemented, but may be implemented for other reasons at the discretion of the licensee.
i g.
The applicable NRC regulatory analyses for the subject Code
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changes being evaluated would be reviewed, if available, to ensure Entergy personnel understand the Staffs safety insights. However l
NRC's regulatory analyses would not be relied on to determine safety significance or "related" requirements.
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GNRO-93/00159
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Page 4 of 4 3.
Documentation a.
The evaluations for those Code changes which were not I
implemented would be retained in permanent plant records, available for NRC inspection.
b.
The ISI/IST commitment status indicating which editions / addenda, and portions thereof, would be applicable for the upcoming 10-year interval would be docketed by each licensee at the beginning of l
each 10-year interval. Currently approved relief requests would be reviewed to determine if their bases were still technically valid for the upcoming interval. Those determined to have invalid bases would become null and void for the upcoming interval. Necessary relief requests (new and/or revised) would be submitted for NRC l
approval.
l Records of subsequent changes to the ISI/IST Program during the i
10-year interval would be retained in permanent plant records, i
aveilable for NRC inspection.
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e Necessary relief requests identified during the interval would i
continue to be submitted for NRC approval.
- 11. OTHER ISSUES Entergy recognizes that the proposed alternative also potentially affects its.
interface with the Authorized inspection Agency and the applicable State regulators. Entergy will carefully work out the appropriate interface details with the involved parties at the appropriate time. Entergy is presently aware
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of no concern related to ANI or State requirements which bear on NRC approval of the proposed alternative.
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