ML24101A388
| ML24101A388 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, River Bend, Waterford  |
| Issue date: | 04/10/2024 |
| From: | Couture P Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| CNRO2024-00009 | |
| Download: ML24101A388 (1) | |
Text
Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102 Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 CNRO2024-00009 10 CFR 50.55a April 10, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
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 Grand Gulf Nuclear Station, Unit 1 NRC Docket No. 50-416 Renewed Facility Operating License No. NPF-29 River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 By letter dated June 30, 2022 (Reference 1), as supplemented by letters dated April 21, 2023 (Reference 2), and January 12, 2024 (Reference 3), Entergy Operations, Inc. (Entergy) submitted a proposed alternative to the American Society of Mechanical Engineers (ASME)
Boiler and Pressure Vessel Code,Section XI, "Rules for Inservice Inspection of Nuclear Power Plant Components," for Grand Gulf Nuclear Station, Unit 1 (GGNS), River Bend Station, Unit 1, (RBS) and Waterford Steam Electric Station, Unit 3 (WF3). Specifically, pursuant to 10 CFR 50.55a(z)(1), Entergy requested authorization to use the alternative requirements of 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 Boiler and Pressure Vessel Code,Section XI, IWA-1000, IWA-4000, and IWA-6000 requirements.
The Nuclear Regulatory Commission (NRC) staff has reviewed the request and determined that additional confirmation of certain information is required to complete their review (Reference 4).
CNRO2024-00009 Page 2 of 3 The Request for Confirmation of Information (RCI) and the associated response are provided in the Enclosure.
This letter contains no new regulatory commitments.
Should you have any questions or require additional information, please contact me at 601-368-5102.
Respectfully, Phil Couture PC/gpn/dlw
Enclosure:
Response to Request for Confirmation of Information
References:
- 1) Entergy letter to the U. S. NRC, "Relief Request Number EN-RR-22-001 -
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," ML22181B114, dated June 30, 2022.
- 2) Entergy letter to the U.S. NRC, "Responses to Request for Additional information concerning Relief Request Number EN-RR-22-001 - 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," ML23111A213, dated April 21, 2023.
- 3) Entergy letter to the U.S. NRC, "Response to 2nd Round Request for Additional Information concerning Relief Request Number EN-RR-22-001 -
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," ML24012A196, dated January 12, 2024
- 4) U.S. NRC email to Entergy, "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)," dated March 27, 2024.
Philip Couture Digitally signed by Philip Couture Date: 2024.04.10 13:44:39 -07'00'
CNRO2024-00009 Page 3 of 3 cc:
NRC Region IV-Regional Administrator NRC Senior Resident Inspector-GGNS NRC Senior Resident Inspector-RBS NRC Senior Resident Inspector-WF3 NRC Project Manager-GGNS NRC Project Manager-RBS NRC Project Manager-WF3 NRC Project Manager-Entergy Fleet
ENCLOSURE CNRO2024-00009 Response to Request for Confirmation of Information
CNRO2024-00009 Enclosure Page 1 of 4 Response to Request for Confirmation of Information NOTE: The U.S. Nuclear Regulatory Commission (NRC) staffs Request for Confirmation of Information (RCI) is shown in italics within this enclosure to distinguish from the Entergy Operations, Inc. (Entergy) response.
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 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, 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:
CNRO2024-00009 Enclosure Page 2 of 4
- 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 program] 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 Bend, 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.
- 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 SARs, 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
CNRO2024-00009 Enclosure Page 3 of 4 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.
CNRO2024-00009 Enclosure Page 4 of 4 Entergys Response to RCI No. 1:
Entergy confirms that safety-related Class 2 and 3 structures, systems, and components (SSCs) categorized as Low Safety Significance (LSS) when implementing Code Case N-752 at Arkansas Nuclear One Units 1 and 2 (ANO) are being treated in accordance with existing Quality Assurance Program (QAP) procedures and processes that fall under the jurisdiction of Appendix B to 10 CFR Part 50.
Entergy confirms that safety-related Class 2 and 3 SSCs categorized as LSS when implementing Code Case N-752 at Grand Gulf Nuclear Station (GGNS), River Bend Station (RBS), and Waterford 3 (WF3), when authorized, will be treated in accordance with existing QAP procedures and processes that fall under the jurisdiction of Appendix B to 10 CFR Part 50.
Entergys Response to RCI No. 2:
Entergy confirms that the additional supplemental requirements and controls, as described in the Entergy letter dated April 30, 2021 (Reference 1), 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 implemented and have been incorporated into the existing QAP procedures used for the procurement of safety-related Class 2 and 3 LSS SSCs for ANO. The existing QAP procedures will be used for the procurement of safety-related Class 2 and 3 LSS SSCs for GGNS, RBS, and WF3 following authorization.
Reference:
- 1. Entergy letter to U.S. NRC, "Supplement to Response to Request for Additional Information Reduction of Commitment to the Entergy Operations Quality Assurance Program Manual Description," ML21120A326, dated April 30, 2021.