ML24296B185
| ML24296B185 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 10/16/2024 |
| From: | Mahesh Chawla NRC/NRR/DORL/LPL4 |
| To: | Ronnie Garcia Energy Northwest |
| References | |
| L-2024-LLR-0039 | |
| Download: ML24296B185 (4) | |
Text
From:
Mahesh Chawla Sent:
Wednesday, October 16, 2024 2:54 PM To:
Garcia, Richard M.
Cc:
Thomas Scarbrough; Gurjendra Bedi; Stewart Bailey; Jennie Rankin
Subject:
Final - Request for Additional Information - Columbia - Relief Request for Fourth Ten-Year Interval Inservice Testing - EPID: L-2024-LLR-0039 Attachments:
RAI-10349-R1-FINAL_101624.docx
Dear Mr. Garcia,
By letter dated June 11, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No.ML24164A214), Energy Northwest (the licensee) submitted Alternative Request 4IST-12 to the U.S. Nuclear Regulatory Commission (NRC) proposing the use of an alternative to specific requirements in the 2004 Edition through 2006 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Section IST, Rules for Inservice Testing of Light-Water Reactor Power Plants, at Columbia Generating Station (Columbia) associated with the Fourth Interval Inservice (IST) Program in accordance with 10 CFR 50.55a, paragraph (z)(1).
After reviewing the Licensees request, the NRC staff determined that additional information was required to complete its review. The draft request for additional information (RAI) is attached herewith.
On October 16, 2024, a clarification call was held with the NRC staff to discuss the requested draft information. This discussion did not result in any changes to the draft RAI. Therefore, the RAI is attached here as the final RAI. In an email later, you agreed to provide the response on the docket no later than 30 calendar days. Thanks Mahesh(Mac) Chawla, Project Manager Licensing Branch LPL4 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Phone: (301) 415-8371 Email: Mahesh.Chawla@nrc.gov OFFICE DORL/LPL4/PM DORL/LPL4/BC NAME MChawla JRankin DATE 10/16/24 10/16/24
Hearing Identifier:
NRR_DRMA Email Number:
2628 Mail Envelope Properties (SJ0PR09MB10405012EEC4C08C6E2883138F1462)
Subject:
Final - Request for Additional Information - Columbia - Relief Request for Fourth Ten-Year Interval Inservice Testing - EPID L-2024-LLR-0039 Sent Date:
10/16/2024 2:53:45 PM Received Date:
10/16/2024 2:53:00 PM From:
Mahesh Chawla Created By:
Mahesh.Chawla@nrc.gov Recipients:
"Thomas Scarbrough" <Thomas.Scarbrough@nrc.gov>
Tracking Status: None "Gurjendra Bedi" <Gurjendra.Bedi@nrc.gov>
Tracking Status: None "Stewart Bailey" <Stewart.Bailey@nrc.gov>
Tracking Status: None "Jennie Rankin" <Jennivine.Rankin@nrc.gov>
Tracking Status: None "Garcia, Richard M." <rmgarcia@energy-northwest.com>
Tracking Status: None Post Office:
SJ0PR09MB10405.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1605 10/16/2024 2:53:00 PM RAI-10349-R1-FINAL_101624.docx 23051 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
1 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION COLUMBIA - RELIEF REQUEST FOR FOURTH TEN-YEAR INTERVAL INSERVICE TESTING ENERGY NORTHWEST COLUMBIA GENERATING STATION, UNIT 2 DOCKET NO. 05000397 ISSUE DATE: N/A
=
Background===
By letter dated June 11, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24164A214), Energy Northwest (the licensee) submitted Alternative Request 4IST-12 to the U.S. Nuclear Regulatory Commission (NRC) proposing the use of an alternative to specific requirements in the 2004 Edition through 2006 Addenda of the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), Section IST, Rules for Inservice Testing of Light-Water Reactor Power Plants, at Columbia Generating Station (Columbia) associated with the Fourth Interval Inservice (IST) Program in accordance with 10 CFR 50.55a, paragraph (z)(1).
Regulatory Basis The NRC regulations in 10 CFR 50.55a(f)(4), Inservice testing standards requirement for operating plants, state, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the inservice test requirements (except design and access provisions) set forth in the ASME OM Code and addenda that become effective subsequent to editions and addenda specified in paragraphs 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in paragraph 10 CFR 50.55a(a)(1)(iv), to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The NRC regulations in 10 CFR 50.55a(z), Alternatives to codes and standards requirements, state:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation.
A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
EMIB-RAI-4IST-12-01 Alternative Request 4IST-12 (RV05), Section 5, Proposed Alternative and Basis for Use, first paragraph states:
2 As an alternative to the ISTC-3700 test interval of at least once every two years, Energy Northwest proposes that the verification position indication [VPI] testing of the valves listed in Section 1 be performed in conjunction with the local leak rate testing [LLRT] at a frequency in accordance with 10 CFR 50, Appendix J, Option B. Energy Northwest was approved to utilize this performance - based option for the Primary Containment Leakage Rate Testing (CLRT)
Program in NRC letter dated March 30, 2018 (ML18052B185). Option B of 10 CFR 50, Appendix J, permits the extension of the Appendix J seat leakage testing to a frequency corresponding to the specific valve performance. Valves whose leakage test results indicate good performance may have their testing interval increased based on these test results, not to exceed 75 months.
On March 30, 2018, the NRC issued License Amendment No. 247 for Columbia to utilize a risk-informed performance-based extension of 10 CFR Part 50, Appendix J seat leakage testing frequency as an update to the Technical Specifications. The submitted Alternative Request 4IST-12 proposes only a performance-based extension of the requirements of ASME OM Code, Subsection ISTC, paragraph ISTC-3700 for position verification testing requirement of every 2 years.
The licensee is requested to describe the relationship between the March 30, 2018, Appendix J License Amendment No. 247 and Alternative Request 4IST-12 for the applicable valves at Columbia with respect to the risk evaluation used to justify the Appendix J extension and the performance-based two successful leakage tests as described in the Alternative Request 4IST-
- 12.
OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/BC NRR/DEX/EMIB/BC NAME MChawla JRankin SBailey DATE 10/16/2024 10/16/2024 09/25/2024