ML22164A801
| ML22164A801 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 06/13/2022 |
| From: | Jury K Entergy Services |
| To: | Office of Nuclear Reactor Regulation |
| Lingam S | |
| References | |
| Download: ML22164A801 (9) | |
Text
Highly sensitive, confidential and proprietary ENTERGY OPERATIONS, INC.
PRE-SUBMITTAL MEETING 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 June 14, 2022
2 Purpose of Meeting
- Describe a planned relief request for a 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, at Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station, Unit 1, (RBS) and Waterford Steam Electric Station, Unit 3 (WF3).
o Background o Proposed Alternative o Relief Request Basis o Precedent o Schedule
- Obtain feedback from NRC Staff on proposed relief request.
3 Background
Code Case N-752 provides for risk-informed categorization and treatment requirements for performing repair/replacement activities on delineated Class 2 and 3 pressure retaining items or their associated supports. Code Case N-752 may be applied on a system basis or on individual items in selected systems.
Code Case N-752 is based on Arkansas Nuclear One (ANO), Unit 2 (ANO-2), relief request ANO2-R&R-004, Revision 1, dated April 17, 2007 (ML071150108). The NRC approved relief request ANO2-R&R-004, Revision 1, in a safety evaluation dated April 22, 2009 (ML090930246). This ANO-2 relief request was developed to serve as an industry pilot for implementing a risk-informed repair/replacement process that included a risk-informed categorization process and treatment requirements.
The NRC subsequently approved ANO relief request EN-RR-20-001, Revision 1, in a safety evaluation dated May 19, 2021 (ML21118B039). EN-RR-20-001, Revision 1, implements Code Case N-752 for ANO Units 1 & 2.
4 Proposed Alternative Pursuant to 10 CFR 50.55a(z)(1), Entergy proposes to implement ASME Code Case N-752, as an alternative to the ASME Code requirements, for GGNS, RBS, and WF3.
ASME Code Case N-752 includes provisions for exempting Class 2 or Class 3 items categorized as Low Safety Significance (LSS) from the repair/replacement requirements (e.g., IWA-4000) of the ASME Section XI Code. In addition, it exempts compliance to IWA-1400(n) [in 2007 Edition/2008 Addenda] which invokes the requirement for a QA Program in accordance with either 10 CFR 50, Appendix B, or ASME NQA-1.
The related Entergy QAPM revision was approved by the NRC in the Safety Evaluation dated May 19, 2021 (ML21132A279).
5 Relief Request Basis Use of the proposed alternative is based upon 10 CFR 50.55a(z)(1) which states: Implementation of a proposed alternative that would provide an acceptable level of quality and safety.
Code Case N-752 specifies requirements for performing risk-informed categorization and treatment for performing repair/replacement activities on Class 2 and 3 pressure retaining items or associated supports. The Code Case N-752 categorization process provides a comprehensive methodology for determining the safety significance of items - HSS or LSS. This categorization process is technically identical to that approved by the NRC under relief request ANO2-R&R-004, Revision 1.
Repair/replacement activities performed on items determined to be HSS must continue to comply with the ASME Section XI Code. Repair/replacement activities performed on LSS items may comply with alternative treatment requirements that are defined by the Owner but must comply with all provisions of paragraph -1420 of Code Case N-752.
6 Precedent Entergy Relief Request EN-RR-20-001, Revision 1, dated May 19, 2021 (ML21118B039).
Entergy Relief Request ANO2-R&R-004, Revision 1, dated April 22, 2009 (ML090930246).
7 Schedule Entergy plans to submit the relief request by June 30, 2022 Authorization will be requested by July 1, 2023, to support planning of future repair/replacement activities associated with Grand Gulf Nuclear Station, Unit 1, River Bend Station, Unit 1, and Waterford 3 Steam Electric Station.
8 Questions?
entergy