ML24088A009

NRR E-mail Capture - Entergy Fleet - Final Request for Confirmation of Information (RCI) Re Alternative Request EN-RR-22-001 Concerning ASME Code Case N-752 (L-2022-LLR-0054)

ML24088A009
Person / Time
Site:	Waterford, Grand Gulf, River Bend
Issue date:	03/27/2024
From:	Thomas Wengert NRC/NRR/DORL/LPL4
To:	Couture P Entergy Operations
Wengert T
References
L-2022-LLR-0054
Download: ML24088A009 (6)

Text

From: Thomas Wengert Sent: Wednesday, March 27, 2024 11:11 AM To: Couture III, Philip Cc: NORRIS, GREGORY P; Mahan, Howard; Jennie Rankin

Subject:

Entergy Fleet - Final Request for Confirmation of Information (RCI) RE:

Alternative Request EN-RR-22-001 Concerning ASME Code Case N-752 (L-2022-LLR-0054)

Attachments: Final RCI Regarding Entergy CC N-752 Alternative Request.pdf

On March 22, 2024, the U.S. Nuclear Regulatory Commission (NRC) staff sent Entergy Operations, Inc. (Entergy) the draft Request for Confirmation of Information (RCI) for Grand Gulf Nuclear Station, Unit 1, River Bend Station, Unit 1, and Waterford Steam Electric Station, Unit 3, identified below. This RCI relates to proposed Relief Request No. EN-RR-22-001 concerning an alternative to use ASME Code Case N-752, as described below.

Subsequently, the licensee informed the NRC staff that a clarification of this RCI was not necessary. A publicly available version of this final RCI (attached with Draft removed) will be placed in the NRCs Agencywide Documents Access and Management System (ADAMS). As agreed, please provide the response to this RCI within 30 days of this correspondence.

From: Thomas Wengert Sent: Friday, March 22, 2024 1:03 PM To: Couture III, Philip <pcoutur@entergy.com>

Cc: NORRIS, GREGORY P <GNORRIS@entergy.com>; Mahan, Howard <cmahan@entergy.com>; Jennie Rankin <Jennivine.Rankin@nrc.gov>

Subject:

Entergy Fleet - Draft Request for Confirmation of Information (RCI) RE: Alternative Request EN-RR-22-001 Concerning ASME Code Case N-752 (L-2022-LLR-0054)

By letter dated June 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22181B114), as supplemented by letters dated April 21, 2023 (ML23111A213), and January 12, 2024 (ML24012A196), Entergy Operations, Inc. (Entergy, the licensee) requested authorization of a proposed alternative in Relief Request No.

EN-RR-22-001 to the requirements of the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel Code (ASME Code),Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, for Grand Gulf Nuclear Station, Unit 1; River Bend Station, Unit 1; and Waterford Steam Electric Station, Unit 3. Specifically, Entergy requested 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, for determining the risk-informed categorization and for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items in lieu of certain ASME Code,Section XI, articles IWA-1000, IWA-4000, and IWA-6000 requirements.

Entergy submitted the request pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.55a Codes and Standards, on the basis that the proposed alternative would provide an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).

The U.S. Nuclear Regulatory Commission (NRC) staff have reviewed the application and supplements, and requests confirmation of certain information to complete its review of the licensees request, as described in the attached RCI. This RCI is identified as draft at this time to confirm your understanding of the information that the NRC staff needs to complete the evaluation. Please let me know if you would like to have a conference call with the NRC staff to clarify this request. In addition, lets discuss the timing for your response to this RCI.

Regards,

Tom Wengert Project Manager - Entergy Fleet NRR/DORL/LPL4 (301) 415-4037

Hearing Identifier: NRR_DRMA Email Number: 2443

Mail Envelope Properties (PH0PR09MB7403C86E4DCCA56A213B916B8F342)

Subject:

Entergy Fleet - Final Request for Confirmation of Information (RCI) RE Alternative Request EN-RR-22-001 Concerning ASME Code Case N-752 (L-2022-LLR-0054)

Sent Date: 3/27/2024 11:11:19 AM Received Date: 3/27/2024 11:11:00 AM From: Thomas Wengert

Created By: Thomas.Wengert@nrc.gov

Recipients:

"NORRIS, GREGORY P" <GNORRIS@entergy.com>

Tracking Status: None "Mahan, Howard" <cmahan@entergy.com>

Tracking Status: None "Jennie Rankin" <Jennivine.Rankin@nrc.gov>

Tracking Status: None "Couture III, Philip" <pcoutur@entergy.com>

Tracking Status: None

Post Office: PH0PR09MB7403.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 3256 3/27/2024 11:11:00 AM Final RCI Regarding Entergy CC N-752 Alternative Request.pdf 146874

Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR CONFIRMATION OF INFORMATION

BY THE OFFICE OF NUCLEAR REACTOR REGULATION

PROPOSED ALTERNATIVE REQUEST EN-RR- 22- 001

RISK -INFORMED CATEGORIZATION AND TREATMENT FOR REPAIR/REPLACEMENT

ACTIVITIES IN CLASS 2 AND 3 SYSTEMS, SECTION XI, DIVISION 1

ENTERGY OPERATIONS, INC.

GRAND GULF NUCLEAR STATION, UNIT 1

RIVER BEND STATION, UNIT 1

WATERFORD STEAM ELECTRIC STATION, UNIT 3

DOCKET NOS. 50- 416, 50- 458, AND 50- 382

By letter dated June 30, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22181B114), as supplemented by letters dated April 21, 2023 (ML23111A213), and January 12, 2024 ( ML24012A196), Entergy Operations, Inc. (Entergy, the licensee) requested authorization of a proposed alternative in Relief Request No. EN-RR- 22-001 to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code) , Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, for Grand Gulf Nuclear Station, Unit 1 (Grand Gulf); River Bend Station, Unit 1 (River Bend); and Waterford Steam Electric Station, Unit 3 (Waterford 3). Specifically, Entergy requested 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, for determining the risk-informed categorization and for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items in lieu of certain ASME Code, Section XI, articles IWA-1000, IWA-4000, and IWA-6000 requirements.

Entergy submitted the request pursuant to Title 10 of the Code of Federal Regulations (10 CFR)

Section 50.55a Codes and Standards, on the basis that the proposed alternative would provide an acceptable level of quality and safety in accordance with 10 CFR 50.55a(z)(1).

The NRC staff requests confirmation of certain information to complete its review of the licensees submittal.

Request for Confirmation of Information

Regulatory Basis

Appendix B to 10 CFR Part 50 establishes quality assurance ( QA) requirements for the design, fabrication, construction, and testing of SSCs. The pertinent requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs and include designing,

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purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying SSCs.

By letter dated May 19, 2021 (ML21132A279), the NRC staff issued a safety evaluation (SE) to Entergy, approving a proposed change to the Entergy Quality Assurance Program Manual (QAPM) under 10 CFR 50.54(a)(4) with specific quality assurance (QA) requirements under Appendix B to 10 CFR Part 50 for safety-related Class 2 and Class 3 components categorized as low safety significant (LSS) when implementing Code Case N-752 at Arkansas Nuclear One (ANO), Units 1 and 2. The NRC staffs approval of the changes to the QAPM at ANO were based on the specific QA requirements for safety-related LSS Class 2 and Class 3 components when implementing Code Case N-752 documented in the Entergy submittals dated October 26, 2020 (ML20300A324), April 5, 2021 (ML21095A244), and April 30, 2021 (ML21120A326). In the supplemental letter for the QAPM change, dated April 30, 2021, the licensee proposed the following addition to the Entergy QAPM:

c. For those [Entergy] 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, treatment of these LSS SSCs is performed in accordance with existing QAP [quality assurance p rogram]

procedures and processes which include supplemental controls to ensure the capability and reliability of the SSCs design basis function.

As noted in the above, the licensees QAPM change applies to all Entergy sites that are authorized to use Code Case N-752, which would include Grand Gulf, River B end, and Waterford 3, if the NRC staff authorizes the requested alternative to use the code case at these sites.

The Safety Analysis Reports (SARs) for ANO Units 1 (Amendment 31) and 2 (Amendment 30)

(ML23180A110 and ML22124A153, respectively ), state, in part:

Code Case N-752 provides a process for determining the risk-informed categorization and treatment for repair/replacement activities on pressure retaining Class 2 and 3 components and their associated supports. Components are categorized as either High Safety Significant (HSS) or Low Safety Significant (LSS).

Repair/replacement activities on Class 2 and 3 pressure retaining components and supports categorized as HSS shall continue to comply with the ASME XI Code and Entergy QAPM. Alternatively, Class 2 and 3 pressure retaining components and supports determined to be LSS in accordance with Code Case N-752 may comply with the alternative treatment requirements of Code Case N-752 including those specified below.

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1. Compliance with the repair/replacement requirements of ASME Section XI (e.g., IWA- 4000) is not required.

2. Compliance with the Entergy QAPM is not required.

Issue

The NRC staff notes that these revisions to the ANO Units 1 and 2 SAR s, following implementation of Code Case N-752, are not consistent with the changes the staff approved to the Entergy QAPM and could imply that the requirements of Appendix B to 10 CFR Part 50 no longer apply to safety-related Class 2 and Class 3 LSS SSCs.

Specifically, the SAR updates omit the approved alternative treatment, that ... treatment of these LSS SSCs is performed in accordance with existing QAP procedures and processes which include supplemental controls to ensure the capability and reliability of the SSCs design basis function. As written, the revised SAR language is not clear that  : (a) those components remain within the scope of 10 CFR Part 50, Appendix B, with respect to their licensing basis and enforcement actions, and (b) there are specific treatment requirements for safety-related Class 2 and Class 3 SSCs that are categorized as LSS when implementing Code Case N-752, which were the basis for the NRC staff authorizing the use of Code Case N-752 at ANO, Units 1 and 2.

The NRC staffs SE approved a reduction in commitment in accordance with 10 CFR 50.54(a)(4), not an exemption from the requirements of Appendix B to 10 CFR Part 50 under 10 CFR 50.12, Specific exemptions .

Request for Confirmation of Information

Please confirm that:

1. Safety-related Class 2 and 3 SSCs categorized as LSS when implementing Code Case N-752 at ANO (and thus Grand Gulf, River Bend, and Waterford 3 if the NRC staff authorizes the requested alternative) are being treated in accordance with existing QAP procedures and processes that fall under the jurisdiction of Appendix B to 10 CFR Part 50.

2. The additional supplemental requirements and controls, as described in the Entergy letter dated April 30, 2021, used to confirm with reasonable assurance that Class 2 and 3 LSS SSCs will remain capable of performing their intended safety-related functions under design basis conditions, are currently being implemented and have been incorporated into the existing ANO QAP procedures used for the procurement of safety-related Class 2 and 3 LSS SSCs and will also be incorporated into the Grand Gulf, River Bend, and Waterford 3 QAP procedures, if the NRC staff authorizes the requested alternative.

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