0CAN102002, Reduction of Commitment to the Entergy Operations Quality Assurance Program Manual Description
| ML20300A324 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  (DPR-051, NPF-006) |
| Issue date: | 10/26/2020 |
| From: | Gaston R Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| 0CAN102002 | |
| Download: ML20300A324 (25) | |
Text
10 CFR 50.54(a)(4) 0CAN102002 October 26, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Reduction of Commitment to the Entergy Operations Quality Assurance Program Manual Description Arkansas Nuclear One, Units 1 and 2 NRC Docket Nos. 50-313, 50-368, and 72-13 Renewed Facility Operating License Nos. DPR-51 and NPF-6 Appendix B to 10 CFR 50 provides Quality Assurance (QA) requirements for the design, construction, and operation of structures, systems and components (SSCs) that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. These requirements apply to all activities that affect SSC safety-related functions. The general requirements contained in 10 CFR 50, Appendix B, are supplemented by industry standards and NRC regulatory guides that describe specific practices that have been found acceptable by the industry and the staff.
In Reference 1, Entergy Operations, Inc. (Entergy) submitted a request for an exemption from 10 CFR 50, Appendix B, to support the use of American Society of Mechanical Engineers (ASME) Code Case N-752 (Reference 2) at Arkansas Nuclear One, Units 1 and 2 (ANO-1 and ANO-2, respectively). ASME Code Case N-752 includes provisions for exempting Class 2 or Class 3 items categorized as Low Safety Significance (LSS) from the QA requirements of paragraph IWA-1400(n) of the 2007 Edition / 2008 Addenda of ASME Section XI. IWA-1400(n) invokes the requirement for a QA Program in accordance with either 10 CFR 50, Appendix B, or ASME NQA-1.
During acceptance review of Reference 1, the NRC determined that supplemental information was required (Reference 3). Based on a discussion with the NRC on July 7, 2020, concerning Reference 1, Entergy decided to withdraw the exemption request via Reference 4. In lieu of the exemption request, Entergy is submitting this proposed revision to the Entergys Quality Assurance Program Manual (QAPM) for NRC review and approval in accordance with 10 CFR 50.54(a)(4) in support of the application of ASME Code Case N-752.
Adoption of the ASME Code Case N-752 exemption on IWA-1400(n) will represent a reduction Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing
0CAN102002 Page 2 of 4 in commitment with respect to the previously approved Entergy QAPM. The provisions of Code Case N-752 are similar to those of 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Plants," in that the provisions allow adjustment of the scope of items subject to special treatment controls (e.g.,
quality assurance, testing, inspection, condition monitoring, assessment, and evaluation) based on safety significance. Similarly, for Code Case N-752 items determined to be of LSS, alternative treatment requirements may be implemented. For equipment determined to be of High Safety Significant (HSS), requirements will not be changed. Code Case N-752 exempts Class 2 and 3 LSS SSCs from the repair/replacement requirements of ASME Section XI; it also allows exemption of the associated QA requirements [i.e., IWA-1400(n)] provided 10 CFR 50 Appendix B or NQA-1 is not required at the nuclear site.
Entergy proposes that treatment of safety-related Class 2 and 3 SSCs identified as LSS in accordance with ASME Code Case N-752 not be required to meet the requirements of the QAPM. Instead, Entergy will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function. Enclosure 1 provides details of this proposed change.
Reference 3 also had additional draft requests for information. While Entergy withdrew the exemption request and the NRC did not finalize the Requests for Additional Information (RAIs),
they were discussed during the July 7, 2020, conference call. Enclosure 2 provides additional information in response to the draft RAIs.
These changes will only be applicable to those Entergy sites who have received NRC approval for authorization to use Code Case N-752 as an alternative to ASME Code,Section XI.
Currently, only ANO-1 and 2 have applied for authorization to use Code Case N-752.
The QAPM, as revised and noted, continues to satisfy the requirements of 10 CFR 50, Appendix B and the Regulatory Guides and ANSI Standards referenced in the QAPM Table of Contents and QAPM Table 1. As such, it also continues to meet the requirements of 10 CFR 72.140(d) for Independent Spent Fuel Storage Installations and 10 CFR 71.101(f) for Packaging and Transportation of Radioactive Material.
Entergy will implement the change upon NRC acceptance, as specified in 10 CFR 50.54(a)(4)(iv).
No new regulatory commitments are included in this submittal.
If there are any questions or if additional information is needed, please contact Riley Keele, Manager, Regulatory Assurance, Arkansas Nuclear One, at 479-858-7826.
0CAN102002 Page 3 of 4 I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 26, 2020.
Respectfully, ORIGINAL SIGNED BY RON GASTON Ron Gaston RWG/rwc
Reference:
- 1.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Request for Exemption from 10 CFR 50, Appendix B to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN052004), dated May 27, 2020 (ML20148M344)
- 2.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Relief Request Number EN-20-RR-001 - Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN052003), dated May 27, 2020
- 3.
NRC email to Riley Keele (Entergy), ANO-1/ANO-2 Acceptance Review Draft Supplemental Information Request - Exemption Request from 10 CFR 50 Appendix B Requirements to Support Application of ASME Code Case N-752 (EPID L-2020-LLE-0093), dated July 1, 2020
- 4.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Withdraw of Request for Exemption from 10 CFR 50, Appendix B to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN072004), dated July 15, 2020 (ML20197A056)
Enclosures:
- 1.
Evaluation of the Proposed Change Attachments to Enclosure 1:
- 1.
Quality Assurance Program Manual Page Markup
- 2.
Retyped Quality Assurance Program Manual
- 2.
Response to NRC Feedback
0CAN102002 Page 4 of 4 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector - Arkansas Nuclear One NRC Project Manager - Arkansas Nuclear One Designated Arkansas State Official
ENCLOSURE 1 0CAN102002 EVALUATION OF THE PROPOSED CHANGE 0CAN102002 Page 1 of 4 EVALUATION OF THE PROPOSED CHANGE BACKGROUND In Reference 1, Entergy Operations, Inc. (Entergy) submitted a request for an exemption from 10 CFR 50, Appendix B, to support the use of American Society of Mechanical Engineers (ASME) Code Case N-752 (Reference 2) at Arkansas Nuclear One, Units 1 and 2 (ANO-1 and ANO-2, respectively). ASME Code Case N-752 includes provisions for exempting Class 2 or Class 3 items categorized as Low Safety Significance (LSS) from the QA requirements of paragraph IWA-1400(n) of the 2007 Edition/ 2008 Addenda of ASME Section XI. IWA-1400(n) invokes the requirement for a QA Program in accordance with either 10 CFR 50, Appendix B, or ASME NQA-1.
During acceptance review of Reference 1, the NRC determined that supplemental information was required (Reference 3). Based on a discussion with the NRC on July 7, 2020, concerning Reference 1, Entergy decided to withdraw the exemption request via Reference 4. In lieu of the exemption request, Entergy is submitting this proposed revision to the Entergys Quality Assurance Program Manual (QAPM) for NRC review and approval in accordance with 10 CFR 50.54(a)(4) in support of the application of ASME Code Case N-752.
Adoption of ASME Code Case N-752 exemption of IWA-1400(n) will represent a reduction in commitment with respect to the previously approved Entergy QAPM. The provisions of Code Case N-752 are similar to those of 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Plants," in that the provisions allow adjustment of the scope of items subject to special treatment controls (e.g.,
quality assurance, testing, inspection, condition monitoring, assessment, and evaluation) based on safety significance. Similarly, for Code Case N-752 items determined to be of LSS, alternative treatment requirements may be implemented. For equipment determined to be of High Safety Significant (HSS), requirements will not be changed. Code Case N-752 exempts Class 2 and 3 LSS SSCs from the repair/replacement requirements of ASME Section XI; it also allows exemption of the associated QA requirements [i.e., IWA-1400(n)] provided 10 CFR 50 Appendix B or NQA-1 is not required at the nuclear site.
Entergy proposes that treatment of safety-related Class 2 and 3 SSCs identified as LSS in accordance with ASME Code Case N-752 not be required to meet the requirements of the QAPM. Instead, Entergy will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function.
The consolidated Entergy QAPM, Revision 0 was initially approved by the U.S. Nuclear Regulatory Commission (NRC) in Reference 5 and as most recently approved in Reference 6 and documented in Revision 24 of the Entergy QAPM. Since then, fifteen (15) revisions have been made to the Entergy QAPM, primarily for organizational and responsibility changes. All but one of those changes were validated not to be a reduction in commitments to the previously approved QAPM in accordance with 50.54(a)(3). The one (1) reduction in commitment to the previously approved QAPM was approved by the NRC (Reference 7), but it was limited to grout and was incorporated into Revision 31 of the QAPM.
0CAN102002 Page 2 of 4 DESCRIPTION OF CHANGE Entergy proposes that treatment of safety-related SSCs identified as LSS in accordance with ASME Code Case N-752 not be required to meet the requirements of the QAPM. Instead, Engineering will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function.
The proposed changes will have no impact on:
The current QAPM organization titles or functions, or The authority or independence of persons or organizations performing Quality Assurance functions.
The following text is being proposed to be added to Section A.7 of the Entergy Operations, Inc.
(Entergy) Quality Assurance Programs Manual (QAPM).
A.7.c.
For those sites who have received NRC authorization to use the alternative repair/replacement categorization and treatment requirements of ASME Code Case N-752 in lieu of the corresponding sections of ASME Section XI as referenced in 10CFR 50.55a, Codes and Standards, treatment of Class 2 and 3 safety-related structures, systems, and components (SSCs) identified as low safety significant (LSS) in accordance with ASME Code Case N-752 is not required to meet the requirements of this manual. Instead, Engineering will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function.
to this Enclosure provides a mark-up of the QAPM with the proposed changes. provides a clean copy of the QAPM.
BASIS FOR CHANGE In the consolidated Entergy QAPM, Revision 0, a decision was made by Entergy and approved by the NRC in Reference 5, to reference only 10 CFR 50, Appendix B requirements in QAPM Section A.7 and Table 1 rather than including other regulatory requirements such as 10 CFR 50.55a, Codes and Standards as suggested in Standard Review Plan (SRP) 17.3, Section A.7. Since other regulatory requirements such as 10 CFR 50.55a were required to be met unless a specific exemption was obtained, listing these requirements provided no additional clarity or requirements to the QAPM. The quality assurance requirements of 10 CFR 50, Appendix B are complimentary and supplemental to the quality assurance requirements of 10 CFR 50.55a since the regulation provides no distinction between safety-related SSCs based upon risk.
Adoption of ASME Code Case N-752 represents a reduction in commitment with respect to the previously approved Entergy QAPM; thereby requiring NRCs review and approval of the QAPM revision prior to the approval of the Reference 1 relief request.
0CAN102002 Page 3 of 4 Code Case N-752 allows a distinction in treatment of HSS and LSS safety-related SSCs.
However, the provisions of Code Case N-752 are similar to those of 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems, and Components (SSCs) for Nuclear Power Plants," in that the provisions allow adjustment of the scope of items subject to special treatment controls (e.g., quality assurance, testing, inspection, condition monitoring, assessment, and evaluation) based on safety significance. Similarly, for Code Case N-752 items determined to be of LSS, alternative treatment requirements may be implemented. For equipment determined to be of HSS, requirements will not be changed. Code Case N-752 exempts Class 2 and 3 LSS SSCs from the repair/replacement requirements of ASME Section XI; it also allows exemption of the associated QA requirements [i.e., IWA-1400(n)]
provided 10 CFR 50 Appendix B or NQA-1 is not required at the nuclear site.
CONCLUSION The proposed changes will only be applicable to those Entergy sites who have received NRC approval for authorization to use Code Case N-752 as an alternative to ASME Boiler and Pressure Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components.
Currently only Arkansas Nuclear One, Units 1 and 2 have applied for authorization to use Code Case N-752. ASME Code Case N-752 includes provisions for exempting Class 2 or Class 3 items categorized as LSS from the QA requirements of the 2007 Edition/ 2008 Addenda of ASME Section XI, paragraph IWA-1400(n), which invokes the requirement for a QA Program in accordance with either 10 CFR 50, Appendix B, or ASME NQA-1 Entergy has verified that the Entergy QAPM will continue to comply with 10 CFR Part 50 Appendix B, Standard Review Plan 17.3, NUREG-0800 and 10 CFR 50.54(a)(3). The Entergy QAPM will also continue to satisfy the requirements of 10CFR71, Subpart H, and 10 CFR 72, Subpart G.
REFERENCES
- 1.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Request for Exemption from 10 CFR 50, Appendix B to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN052004), dated May 27, 2020 (ML20148M344)
- 2.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Relief Request Number EN-20-RR-001 - Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN052003), dated May 27, 2020
- 3.
NRC email to Riley Keele (Entergy), ANO-1/ANO-2 Acceptance Review Draft Supplemental Information Request - Exemption Request from 10 CFR 50 Appendix B Requirements to Support Application of ASME Code Case N-752 (EPID L-2020-LLE-0093),
dated July 1, 2020 0CAN102002 Page 4 of 4
- 4.
Entergy Operations, Inc. (Entergy) letter to the U. S. Nuclear Regulatory Commission (NRC), Withdraw of Request for Exemption from 10 CFR 50, Appendix B to Support Application of ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, (0CAN072004), dated July 15, 2020 (ML20197A056)
- 5.
NRC letter to Entergy Operations, Inc., Consolidation of Quality Assurance (QA) Program Into One Quality Assurance Program Manual for All Entergy Sites - Arkansas Nuclear One, Grand Gulf Nuclear Station, River Bend Station and Waterford Steam Electric Station (TAC No. M97893) (0CNA119808), dated November 6, 1998
- 6.
NRC letter to Entergy Operations, Inc., Arkansas Nuclear One, Units 1 and 2; Big Rock Point Plant; James A. Fitzpatrick Nuclear Power Plant; Grand Gulf Nuclear Station, Unit 1; Indian Point Nuclear Generating, Unit Nos. 1, 2, and 3: Palisades Nuclear Plant; Pilgrim Nuclear Power Station; River Bend Station, Unit 1; Vermont Yankee Nuclear Power Station; and Waterford Steam Electric Station, Unit 3 - Issuance of Amendment RE:
Request for Approval of Change to the Entergy Quality Assurance Program Manual and Associated Plant Technical Specifications Regarding Staff Qualifications (TAC Nos.
ME7774 to ME7786) (0CNA121206), dated December 28, 2012.
- 7.
NRC letter to Entergy Services, Inc., Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; James A. Fitzpatrick Nuclear Power Plant; Indian Point Energy Center, Units 1, 2, and 3; Palisades Nuclear Plant; Pilgrim Nuclear Power Station; River Bend Station, Unit 1; Waterford Station Electric Station, Unit 3; and Big Rock Point Nuclear Plant - ISFSI - Request for Approval of Change to the Entergy Quality Assurance Program Manual (CAC Nos. MF7090, MF7091, MF7092, MF7093, MF7094, MF7095, MF7096 and MF7097) (CNRI-2016-00006), dated September 13, 2016 (ML16251A620).
ATTACHMENT 1 TO ENCLOSURE 1 0CAN102002 QUALITY ASSURANCE PROGRAM MANUAL PAGE MARKUP (1 Page)
QUALITY ASSURANCE PROGRAM MANUAL 7
Revision 39 A.
(continued)
- 7.
- a.
Except where alternatives are identified, Entergy complies with the QA guidance documents listed on Table 1. If the guidance in one of these documents is in conflict with the QAPM, the guidance provided in the QAPM is the controlling guidance. Additionally, the following clarifications apply to all guidance documents listed in Table 1:
- 1.
For modifications and nonroutine maintenance, guidance applicable to construction-like activities is applicable to comparable plant activities. Except that the inspection of modifications, repairs, rework, and replacements shall be in accordance with the original design and inspection requirements or a documented approved alternative.
- 2.
The definitions provided by Regulatory Guide 1.74 and associated clarifications as described in Table 1 apply wherever the defined term is used in the QAPM and associated guidance documents.
- 3.
Clarification to a guidance document applies wherever the guidance document is invoked.
- 4.
In each of the ANSI standards, other documents (e.g., other standards, codes, regulations, tables, or appendices) are referenced or described. These other documents are only quality assurance program requirements if explicitly committed to in the QAPM. If not explicitly committed to, these documents are not considered as quality assurance program requirements, although they may be used as guidance.
- 5.
Guidance applicable to safety related items and activities is applicable to comparable items and activities controlled by 10 CFR 72 and transportation packages controlled by 10 CFR 71.
- b.
The NRC is to be notified of QAPM changes in accordance with 10 CFR 50.54(a)(3) or 10 CFR 50.54(a)(4).
- c.
For those sites who have received NRC authorization to use the alternative repair/replacement categorization and treatment requirements of Code Case N-752 in lieu of the corresponding sections of ASME Section XI, as referenced in 10 CFR 50.55a Codes and Standards, treatment of safety-related structures, systems, and components (SSCs) identified as low safety significant (LSS) Class 2 and 3 SSCs in accordance with ASME Code Case N-752 is not required to meet the requirements of this manual. Instead, Engineering will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function.
ATTACHMENT 2 TO ENCLOSURE 1 0CAN102002 RE-TYPED QUALITY ASSURANCE PROGRAM MANUAL PAGE (1 Page)
QUALITY ASSURANCE PROGRAM MANUAL 7
Revision 39 A.
(continued)
- 7.
- a.
Except where alternatives are identified, Entergy complies with the QA guidance documents listed on Table 1. If the guidance in one of these documents is in conflict with the QAPM, the guidance provided in the QAPM is the controlling guidance. Additionally, the following clarifications apply to all guidance documents listed in Table 1:
- 1.
For modifications and nonroutine maintenance, guidance applicable to construction-like activities is applicable to comparable plant activities. Except that the inspection of modifications, repairs, rework, and replacements shall be in accordance with the original design and inspection requirements or a documented approved alternative.
- 2.
The definitions provided by Regulatory Guide 1.74 and associated clarifications as described in Table 1 apply wherever the defined term is used in the QAPM and associated guidance documents.
- 3.
Clarification to a guidance document applies wherever the guidance document is invoked.
- 4.
In each of the ANSI standards, other documents (e.g., other standards, codes, regulations, tables, or appendices) are referenced or described. These other documents are only quality assurance program requirements if explicitly committed to in the QAPM. If not explicitly committed to, these documents are not considered as quality assurance program requirements, although they may be used as guidance.
- 5.
Guidance applicable to safety related items and activities is applicable to comparable items and activities controlled by 10 CFR 72 and transportation packages controlled by 10 CFR 71.
- b.
The NRC is to be notified of QAPM changes in accordance with 10 CFR 50.54(a)(3) or 10 CFR 50.54(a)(4).
- c.
For those sites who have received NRC authorization to use the alternative repair/replacement categorization and treatment requirements of Code Case N-752 in lieu of the corresponding sections of ASME Section XI, as referenced in 10 CFR 50.55a Codes and Standards, treatment of safety-related structures, systems, and components (SSCs) identified as low safety significant (LSS) Class 2 and 3 SSCs in accordance with ASME Code Case N-752 is not required to meet the requirements of this manual. Instead, Engineering will develop program elements describing treatment of these LSS SSCs to ensure continued capability and reliability of the design basis function.
ENCLOSURE 2 0CAN102002 RESPONSE TO NRC FEEDBACK 0CAN102002 Page 1 of 11 RESPONSE TO NRC FEEDBACK NRC FEEDBACK Provide a markup of the proposed changes that the licensee will make to the ANO-1 and ANO-2 QA Program description based on the scope of the SSCs exempted from 10 CFR Part 50 Appendix B, the basis for this exemption request, and a detailed description of the proposed changes to the program elements. The descriptions should address, at a minimum:
A description of those portions of QA Program that remain applicable to the exempted SSCs (e.g., design control, procurement, installation, configuration control, nonconformance, and corrective action).
A description of the administrative controls for repair/replacement activities.
A description of the methodology for evaluating changes in configuration, design, fabrication, examination, and pressure-testing requirements used in repair/replacement activities that will ensure structural integrity and leak tightness of the system are sufficient to support design bases functional requirements of the system.
A detailed description of what constitutes the Owners requirements or modified Owners requirements as permitted by the licensing basis.
A detailed description of the program or process that will provide confidence that the items used for repair/replacement activities meet the Construction Code to which the original item was constructed.
A detailed test program to assure all testing activities required to demonstrate pressure testing of repair/replacement activities be performed in accordance with the requirements of Code of Construction selected for the repair/replacement activity.
A detailed methodology for performance of repair/replacement activities and associated non-destructive examination (NDE).
RESPONSE
A mark-up of proposed changes to the Entergy QA Program description is provided in. Treatment requirements for performing risk-informed repair/replacement activities are specified in paragraphs -1420(a) through (j) of Code Case N-752. Entergys plans to implement the treatment requirements of Code Case N-752 are described below:
Paragraph -1420(a): "The Owner shall establish administrative controls for these repair/replacement activities."
Entergys existing ASME Section XI Repair/Replacement Program is implemented in accordance with Repair/Replacement Program procedures that delineate programmatic and administrative requirements for managing, controlling, and documenting the performance of ASME Section XI repair/replacement activities. These Repair/Replacement Program 0CAN102002 Page 2 of 11 procedures, in turn, reference or invoke other Entergy procedures that administratively control processes critical to or supportive of the performance of repair/replacement activities such as, but not limited to, those listed below:
Design control Configuration control Procurement Work management planning and instructions Control of materials, parts, and components Installation Control of welding and postweld heat treatment (PWHT)
Control of nondestructive examinations (NDE)
Pressure testing Corrective action / non-conformances Based on Code Case N-752, Entergy intends to implement a new Risk-Informed Repair/Replacement Program. Like the existing ASME Section XI Repair/Replacement Program, the new Risk-Informed Repair/Replacement Program will be implemented in accordance with a procedure(s) that delineates programmatic and administrative requirements for managing, controlling, and documenting the performance of repair/replacement activities on Class 2 and 3 LSS items. Additionally, existing Repair/Replacement Program procedures will be revised, as appropriate, to ensure that a clear distinction exists between repair/replacement activities performed in accordance with the ASME Section XI Code (i.e., IWA-4000) and those performed under Code Case N-752. Finally, the new Risk-Informed Repair/Replacement Program procedure(s) will reference or invoke other existing Entergy procedures that administratively control processes, such as those listed above, critical to or supportive of the performance of risk-informed repair/replacement activities. These other existing Entergy procedures will also be revised, as necessary, to facilitate implementation of the Code Case N-752 Risk-Informed Repair/Replacement Program.
Table 1 describes Entergy process procedures and QA Program applicability for performing repair/replacement activities. As shown in Table 1, the Entergy process procedures (e.g.,
design control, procurement) used to support performance of repair/replacement activities in accordance with Entergys existing ASME Section XI Repair/Replacement Program will also be used to support performance of repair/replacement activities under Entergys proposed Code Case N-752 Repair/Replacement Program.
Paragraph -1420(b): "The fracture toughness requirements of the original Construction Code and Owners Requirements shall be met."
All Class 2 and 3 LSS items at ANO will continue to comply with the fracture toughness requirements of the original Construction Code and Owners Requirements (e.g., design specifications) even if an alternative Construction Code or standard is selected in accordance with paragraph -1420(e) or -1420(g). Therefore, no changes in fracture toughness requirements, where such requirements exist, will be made as a result of implementing Code Case N-752.
0CAN102002 Page 3 of 11 Paragraph -1420(c): "Changes in configuration, design, materials, fabrication, examination, and pressure testing requirements used in the repair/replacement activity shall be evaluated, as applicable, to ensure the structural integrity and leak tightness of the system are sufficient to support the design bases functional requirements of the system."
Entergy procedures and processes, as described below, will be used to ensure that structural integrity and leak tightness of Class 2 and 3 LSS items are sufficient to support the design basis functional requirements of the system when changes are made in configuration, design, materials, fabrication, examination, and pressure testing to support performance of repair/replacement activities in accordance with Code Case N-752.
Changes to the configuration, design, materials, fabrication, examination, and pressure testing requirements used to support repair/replacement activities on Class 2 and 3 items are performed in accordance with Entergys existing design change process. The Entergy design change process is a comprehensive process that ensures all applicable code, design specification, regulatory, licensing, quality assurance, operational, special process, programmatic, installation, inspection, and testing requirements are appropriately evaluated and met. The technical rigor of the Entergy design change process including use of design inputs, technical and programmatic reviews, and design verification ensures that structural integrity and leak tightness of modified items are sufficient to support the design basis functional requirements of the system. Additionally, all design changes are evaluated and processed in accordance with Entergys 10 CFR 50.59 process. Entergys existing design change process is presently used to implement design changes to Class 2 and 3 items and will also be used to implement design changes to Class 2 and 3 LSS items under Code Case N-752.
Changes to configuration, design, materials, fabrication, examination, and pressure testing requirements in Owners Requirements (e.g., design specification) are also addressed below [paragraph -1420(d)].
Paragraph -1420(d): "Items used for repair/replacement activities shall meet the Owners Requirements or revised Owners Requirements as permitted by the licensing basis."
As background, Owners Requirements are defined by the ASME Section XI Code as follows:
"Those requirements prepared by or for the Owner that (1) define the requirements for an item when a Construction Code is not specified, (2) address plant specific requirements of the Construction Code that must be identified by the Owner, or (3) invoke plant specific requirements that are in excess of Construction Code requirements." It is important to note that Owners Requirements are generally included in each items Design Specification which is the case at ANO-1 and ANO-2. Therefore, the term Owners Requirements may be considered synonymous with design specification.
Based on paragraph -1420(d), all items used for repair/replacement activities must comply with the applicable design specification or a later revision of the design specification provided the revised design specification complies with applicable licensing basis requirements. This requirement is not unique to Code Case N-752 but is similar to IWA-4221(a) of the ASME Section XI Code which states in part:
An item to be used for repair/replacement activities shall meet the Owners Requirements.
Owners Requirements may be revised.
0CAN102002 Page 4 of 11 Entergys existing ASME Section XI Repair/Replacement Program procedure requires that all replacement items be procured in accordance with the design specification as required by IWA-4221(a). Likewise, Entergys proposed Code Case N-752 Risk-Informed Repair/Replacement Program procedure will also require Class 2 and 3 LSS items to be procured in accordance with the design specification as required by paragraph -1420(d).
Therefore, the procurement process with respect to the design specification or Owners Requirements will be identical under both repair/replacement programs.
Design specifications provide the basis for construction or manufacture of items to be used in the plant. Therefore, revisions to design specifications must be properly controlled to ensure technical adequacy while maintaining compliance with the plants licensing basis. Changes or revisions to design specifications are processed in accordance with Entergys procedures for administering revisions to design specifications. As part of this process, proposed changes to the design specification are evaluated, as appropriate, in accordance with Entergys 10 CFR 50.59 procedures to ensure compliance with licensing basis documents. Should it become necessary to make a change to licensing basis documents to support the design specification revision, the necessary change is then prepared, reviewed, and approved in accordance with Entergys 10 CFR 50.59 process for revising licensing basis documents. To conclude, Entergys design specification revision process is the same regardless of whether the specification change is made to support the existing ASME Section XI Repair/Replacement Program or its proposed Code Case N-752 Risk-Informed Repair/Replacement Program.
Based on Code Case N-752, Entergy is proposing to procure Class 2 and 3 LSS items as nonsafety-related when used in repair/replacement activities performed in accordance with Entergys Code Case N-752 Risk-Informed Repair/Replacement Program. While this is the case, Entergy engineering will specify supplemental procurement requirements and controls, as appropriate, to confirm with reasonable confidence that Class 2 and 3 LSS items remain capable of performing their safety related functions under design-basis conditions. Design specifications and licensing basis documents for Class 2 and 3 LSS items will be revised to allow use of this Code Case N-752 alternative. Revisions to design specifications and licensing basis documents will be processed as described above.
Paragraph -1420(e): "Items used for repair/replacement activities shall meet the Construction Code to which the original item was constructed.
Alternatively, items used for repair/replacement activities shall meet the technical requirements of a nationally recognized code, standard, or specification applicable to that item (e.g., ASME, ANSI, AWS, AISC, AWWA, API 650, API 620, MSS SPs, or TEMA), as permitted by the licensing basis."
Based on paragraph -1420(e), items used for repair/replacement activities are required to comply with the Construction Code to which the original items were constructed. This requirement is identical to IWA-4221(b)(1) of the ASME Section XI Code and defines how replacement items are generally procured.
Paragraph -1420(e) also allows an item used for repair/replacement activities to meet the technical requirements of a nationally recognized code, standard, or specification applicable to the item and as permitted by the licensing basis. The Code Case N-752 alternative is similar to IWA-4221(c) of the ASME Section XI Code which is provided below.
0CAN102002 Page 5 of 11 As an alternative to (b) above, the item may meet all or portions of the requirements of different Editions and Addenda of the Construction Code, or Section III when the Construction Code was not Section III All or portions of later different Construction Codes may be used as listed below:
(1) Piping, piping subassemblies, and their supports: B31.1 to B31.7 to Section III.
(2) Pumps, valves, and their supports: from B31.1 to Draft Code for Pumps and Valves for Nuclear Power to Section III.
(3) Vessels and their supports: Section VIII to Section III.
(4) Atmospheric and 0 psig to 15 psig (0 kPa to 100 kPa) storage tanks and their supports: Section VIII, API 620, or API 650 to Section III.
Procurement of Class 2 and 3 LSS items in accordance with the technical requirements of an alternative code, standard, or specification as permitted by paragraph -1420(e) of Code Case N-752 is discussed below.
Use of Alternative Codes, Standards, and Specifications An alternative code, standard, or specification may be used to procure a replacement item provided the alternative code, standard or specification is nationally recognized (e.g.,
ASME, ANSI, AWS) and determined to be applicable to the item. For example, piping whose original Construction Code was ASME B31.1 may be procured in accordance with the ASME Section III Construction Code, or vice versa, since both of these Construction Codes include code rules applicable to piping. Likewise, piping materials originally procured under one material specification, such as SA-376, can be procured to another material specification, such as SA-312, because both material specifications specify rules for stainless steel piping. However, if an alternative code, standard, or specification is used, the fracture toughness requirements of the original Construction Code and Owners Requirements still must be met as specified in paragraph -1420(b). Finally, the use of the alternative code, standard, or specification must be permitted by the licensing basis.
Technical Requirements of Alternative Codes, Standards, and Specifications When procuring a replacement Class 2 or 3 LSS item to a nationally recognized alternative code, standard, or specification, the replacement item must comply with all technical requirements of the alternative code, standard, or specification. Compliance with the administrative requirements of the alternative code, standard, or specification is not required.
As background, technical and administrative requirements are defined in Footnote 4 of Code Case N-752 as follows: "Construction Code requirements may be technical or administrative. Technical requirements are those requirements that could affect materials, design, fabrication, or examination and affect the pressure boundary or component support function. Administrative requirements are those that do not affect pressure boundary or component support function (e.g., quality assurance1, certification, Code Symbol Stamping, Data Reports, and Authorized Inspection)." These definitions are consistent with those provided in IWA-4222.
1 This reference to quality assurance requirements refers to Construction Code quality assurance requirements such as those in NCA-3800 and NCA-4000 of the ASME Section III Code. It does not apply to quality assurance requirements specified in 10CFR 50, Appendix B.
0CAN102002 Page 6 of 11 The exemption of administrative requirements is not unique to Code Case N-752. For example, IWA-4131 of the ASME Section XI Code includes a small items exemption.
According to this exemption, Class 1, 2, and 3 piping, tubing, valves, fittings, and associated supports that meet the small size criteria of IWA-4131.1 may be procured in accordance with the technical requirements (only) of the Construction Code. Compliance with the administrative requirements of the Construction Code is not required.
IWA-4131.2(a) also notes that the quality assurance requirements of NCA-3800 need not be met for ASME Section III items provided certain Owner measures or controls are in-place. Other exemption examples on code administrative requirements are provided below:
ASME Section III, NB-2610, NC-2610, and ND-2610 exempts small products from having to comply with most NCA-3800 requirements.
ASME Section XI, IWA-4143 exempts the application of the "NA" and "NPT" Code Symbol Stamps for repair/replacement activities performed at the Owners plant.
For Class 1, 2, and 3 items meeting the small items size criteria of IWA-4131.1, repair/replacement activities need only comply with the technical requirements of IWA-4400 and IWA-4510 while also being exempt from Repair/Replacement Plans, pressure testing, services of an Authorized Inservice Agency, and completion of NIS-2 forms.
In summary, paragraph -1420(e) allows Owners to procure replacement Class 2 and 3 LSS items in accordance with the technical requirements of alternative codes, standards, or specifications without having to comply with the administrative requirements of the codes, standards, or specifications. In reality, this alternative primarily benefits Owners who are considering procurement of a replacement item to the ASME Section III Code when the original Construction Code was not ASME Section III. In this case, the administrative requirements of the ASME Section III Code are likely excessive when compared to those in the original Construction Code applicable to the item and, most likely, other components and items in the system. That said, unlike technical requirements, the administrative requirements of a particular code, standard, specification do not affect the integrity of the pressure boundary or the component support function. Therefore, when an alternative code, standard, or specification is used in procurement, compliance with its technical requirements will ensure that the procured Class 2 or 3 LSS item remains capable of performing its safety-related functions under all design basis conditions.
Entergys proposed Code Case N-752 Risk-Informed Repair/Replacement Program will require procurement of replacement items in accordance with the original Construction Code or the technical requirements of an alternative code, standard, or specification as permitted by paragraph -1420(e). If the alternative of paragraph -1420(e) is used, then the design specification (i.e., Owners Requirements) applicable to the original item will be revised to allow use of replacement items procured to the technical requirements of an alternative code, standard, or specification. As previously explained, the revision to the design specification will be processed in accordance with Entergys procedures for administering revisions to design specifications. As part of this process, the proposed change to the design specification will be evaluated, as appropriate, in accordance with Entergys 10 CFR 50.59 procedures to ensure 0CAN102002 Page 7 of 11 compliance with licensing basis documents. Should it become necessary to make a change to licensing basis documents to support the design specification revision, the required change will be prepared, reviewed, and approved in accordance with Entergys 10 CFR 50.59 process for revising licensing basis documents.
Paragraph -1420(f): "The repair methods of nationally recognized post construction codes and standards (e.g., PCC-2, API-653) applicable to the item may be used."
Post Construction Codes and standards, such as the ASME PCC-2 Code, were specifically developed for operating power plants and provide repair methods that are not included in original Construction Codes. Some of these repair methods have been incorporated into ASME Section XI Code Cases. However, none of the repair method of nationally recognized post construction codes and standards can be used for performing repair/replacement activities until the design specification for the applicable Class 2 or 3 LSS items has been revised to allow use of the post construction code or standard. The process for revising design specifications to use post constructions codes and standards is described below [paragraph -1420(g)].
Paragraph -1420(g): "Performance of repair/replacement activities, and associated NDE, shall be in accordance with the Owners Requirements and, as applicable, the Construction Code, or post construction code or standard, selected for the repair/replacement activity. Alternative examination methods may be used as approved by the Owner. NDE personnel may be qualified in accordance with IWA-2300, in lieu of the Construction Code."
The repair/replacement activity requirements of paragraph -1420(g) are similar to those specified in IWA-4411 of the ASME Section XI Code. According to IWA-4411, welding, brazing, fabrication, and installation is required to be performed in accordance with the Owners Requirements (i.e., design specification) and Construction Code applicable to the item; alternatively, repair/replacement activities may be performed in accordance with a revised design specification and later Editions/Addenda of the Construction Code or a later different Construction Code, Code Cases, or the additional alternatives outlined in IWA-4411.
Entergys new Code Case N-752 Risk-Informed Repair/Replacement Program procedure(s) will include the following provisions to ensure repair/replacement activities performed on Class 2 or 3 LSS items comply with all requirements of paragraph -1420(g).
Repair/replacement activities including associated NDE will be required to comply with the design specification applicable to the item for which the repair/replacement activities will be performed. Revisions (i.e., changes) to the design specification will be processed in accordance with Entergys procedures for administering revisions to design specifications as described above [paragraph -1420(d)].
Repair/replacement activities including associated NDE will also be required to comply with the Construction Code, post construction code or standard selected for the repair/replacement activity. Before an alternative Construction Code or post-construction code or standard can be used, its use must first be approved by the design specification applicable to the item. However, under all conditions including use of alternative Construction Codes and post construction codes or standards, the facture toughness 0CAN102002 Page 8 of 11 requirements of the original Construction Code and Owners Requirements shall be met as specified in paragraph -1420(b). Design specification revisions to allow use of an alternative Construction Code, post-construction code or standard will be processed in accordance with Entergys procedures for administering revisions to design specifications as described above [paragraph -1420(d)].
Paragraph -1420(g) allows NDE personnel to be qualified in accordance with IWA-2300 in lieu of the applicable Construction Code. This alternative is already permitted by IWA-4511 of the ASME Section XI Code and provides an alternative to eliminate redundant NDE personnel qualifications.
To conclude, Entergys new Code Case N-752 Risk-Informed Repair/Replacement Program procedure(s) will outline programmatic and administrative requirements for performing repair/replacement activities. This procedure(s) will also provide reference to or specify use of various program procedures (e.g., Welding and NDE Program procedures) that are essential to the performance of repair/replacement activities. For example, welding and NDE procedures specify program requirements for procedure and personnel qualifications, fabrication, welding, defect removal, NDE, and welding/NDE documentation. These program procedures are based on various codes and standards and will be used to ensure compliance with Code Case N-752, applicable design specifications, and licensing basis requirements.
Paragraph -1420(h): "Pressure testing of the repair/replacement activity shall be performed in accordance with the requirements of the Construction Code selected for the repair/replacement activity or shall be established by the Owner."
Pressure testing requirements for repair/replacement activities performed on Class 2 and 3 LSS items will be specified in Entergys new Code Case N-752 Risk-Informed Repair/Replacement Program procedure(s). Pressure testing requirements will be based on the Construction Code selected for the repair/replacement activity or as otherwise specified in Entergys Code Case N-752 Risk-Informed Repair/Replacement Program procedure(s) as allowed by paragraph -1420(h). The pressure testing activity will be implemented in accordance with Entergy procedures which govern post-maintenance testing and/or pressure testing.
Paragraph -1420(i): "Baseline examination of the items affected by the repair/
replacement activity, if required, shall be performed in accordance with the requirements of the Owners program for periodic inspection of the item selected for examination."
Baseline or Preservice Inspection (PSI), as well as Inservice Inspection (ISI), of Class 2 and 3 LSS items affected by repair/replacement activities will continue to be performed in accordance Entergys programs governing periodic inspection of items. Entergys Risk-Informed Repair/Replacement Program procedure(s) will impose these PSI and ISI examination requirements as follows:
PSI/ISI of Class 2 and 3 LSS pressure retaining items or their associated supports will be performed in accordance with each Sites ISI program implemented in accordance with 10 CFR 50.55a.
0CAN102002 Page 9 of 11 In-Service Testing (IST) of pumps and valves that have been classified as Class 2 or 3 LSS will be performed in accordance with each Sites IST program implemented in accordance with 10 CFR 50.55a.
IST of snubbers that have been classified as Class 2 or 3 LSS will be performed in accordance with each Sites Snubber Testing program implemented in accordance with 10 CFR 50.55a.
Inspections of Class 2 and 3 LSS items performed under other plant programs, such as the Flow Accelerated Corrosion and Microbiologically Induced Corrosion, will continue to be performed under those programs for each site.
Paragraph -1420(i): "These provisions do not negate or affect Owner commitments to regulatory and enforcement authorities having jurisdiction at the plant site."
NRC approval to implement Code Case N-752 does not arbitrarily negate or overrule prior Entergy commitments to regulatory and enforcement authorities. Such commitments must still be met. Should it become necessary to make changes to regulatory commitments during or after implementation of Code Case N-752, such changes must be processed in accordance with NRC approved regulatory processes [e.g., 10 CFR 50.59; 10 CFR 50.55a(z)] and Entergy procedures that implement those regulatory processes.
CONCLUSION ASME Code Case N-752 includes provisions for exempting Class 2 or Class 3 items categorized as LSS from the QA requirements of paragraph IWA-1400(n) of the 2007 Edition /
2008 Addenda of ASME Section XI. IWA-1400(n) invokes the requirement for a QA Program in accordance with either 10 CFR 50, Appendix B, or ASME NQA-1. However, the treatment requirements of Code Case N-752 provide reasonable confidence that each Class 2 and 3 LSS item will remain capable of performing its design basis functions. The Code Case N-752 risk-informed process categorizes components based solely on consequence, which measures the safety significance of the component given that it ruptures (component failure is assumed with a probability of 1.0). In other words, even though the Class 2 or 3 LSS component or item is assumed to fail, its failure will not have an adverse effect on plant safety. This approach is conservative and does not allow the LSS categorization to be affected by changes in treatment.
Entergys proposed treatment requirements per ASME Code Case N-752 provide reasonable confidence that the Class 2 and 3 LSS item will remain capable of performing its safety-related functions under design basis-conditions. This approach to treatment is consistent with the NRCs quality assurance exemption and treatment requirements in 10 CFR 50.69(b)(1)(ix) and (d)(2) for RISC-3 safety-related structures, systems, and components that perform LSS functions.
0CAN102002 Page 10 of 11 Table 1 Entergy Procedures Applicability for Repair/Replacement Activities4 Entergy Safety-Related Process Procedures1,2 Existing ASME Section XI Repair/Replacement Program (Class 2 and 3 Items)
Proposed Code Case N-752 Repair/Replacement Program (Class 2 and 3 LSS Items3)
Process Procedure Applies Appendix B QA Program Applies Process Procedure Applies Appendix B QA Program Applies Existing Repair/Replacement Program Yes Yes No n/a Risk-Informed Repair/Replacement Program No n/a Yes No5 Design Control Yes Yes Yes No5 Configuration Control Yes Yes Yes No5 Procurement Yes Yes Yes No5,6 Work Management Planning/Instructions Yes Yes Yes No5 Control of Materials, Parts, Components Yes Yes Yes No5 Installation Yes Yes Yes No5 Control of Welding and PWHT Yes Yes Yes No5 Control of NDE Yes Yes Yes No5 Pressure Testing Yes Yes Yes No5 Corrective Action/ Nonconformances Yes Yes Yes No5 Notes:
- 1.
In general, the scope of Entergys safety-related procedures applies to both safety-related and nonsafety-related plant components.
- 2.
The requirements and controls in these procedures provide reasonable confidence that Class 2 and 3 items and Class 2 and 3 LSS items will remain capable of performing their safety-related functions under design basis conditions.
- 3.
The alternative treatment requirements of Code Case N-752 only apply to Class 2 and 3 LSS items. Class 2 and 3 HSS items must comply with the treatment requirements of the ASME Section XI Code.
0CAN102002 Page 11 of 11
- 4.
This table only applies to Class 2 and 3 repair/replacement activities to be consistent with Code Case N-752.
- 5.
Treatment (e.g., design control, configuration control, procurement, installation) of Class 2 and 3 LSS items will not be required to comply with the quality assurance provisions of 10 CFR 50, Appendix B. However, the procedures governing these treatment activities will be classified as safety-related and therefore, under the jurisdiction of 10 CFR 50, Appendix B.
- 6.
Although procurement will be performed in accordance with Entergy safety related procedures, Class 2 and 3 LSS items used in repair/replacement activities will be procured and controlled as nonsafety-related. Supplemental procurement requirements and controls will be specified, as appropriate, to confirm with reasonable confidence that Class 2 and 3 LSS items remain capable of performing their safety related functions under design-basis conditions.