GO2-24-100, Response to Request for Additional Information Regarding Request for Fourth Ten-Year Interval Inservice Testing
| ML24310A123 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/04/2024 |
| From: | Hauger J Energy Northwest |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| GO2-24-100 | |
| Download: ML24310A123 (1) | |
Text
Jeremy S. Hauger Columbia Generating Station P.O. Box 968, PE30 Richland, WA 99352-0968 509.377.8727 jshauger@energy-northwest.com GO2-24-100 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR FOURTH TEN-YEAR INTERVAL INSERVICE TESTING
References:
- 1. Letter from Energy Northwest to NRC, Relief Request for the Columbia Generating Station Fourth Ten-Year Interval Inservice Testing, dated June 11, 2024 (ADAMS Accession Number ML24164A214)
- 2. Letter from NRC to Energy Northwest, Request for Additional Information - Relief Request for Fourth Ten-Year Interval Inservice Testing, dated October 16, 2024 (ADAMS Accession Number ML24296B185)
Dear Sir or Madam:
By Reference 1, Energy Northwest submitted a relief request pertaining to the fourth 10-year interval of the Columbia Generating Station Inservice Testing Program. By Reference 2, the Nuclear Regulatory Commission requested additional information related to the Energy Northwest submittal.
The enclosure to this letter contains the information requested in Reference 2.
There are no regulatory commitments made in this submittal.
November 4, 2024 ENERGY NORTHWEST
GO2-24-100 Page 2 of 2 If you have any questions or require additional information, please contact Mr. R. M.
Garcia at 509-377-8463.
Executed this ____ day of November, 2024.
Respectfully, Jeremy S. Hauger Vice President, Engineering
Enclosure:
Response to Request for Additional Information - Relief Request for Fourth Ten-Year Interval Inservice Testing cc:
NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspector/988C CD Sonoda - BPA/1399 EFSECutc.wa.gov - EFSEC E Fordham - WDOH R Brice - WDOH L Albin - WDOH
DocuSigned by:
~Jc!:~
GO2-24-100 Enclosure Page 1 of 3 Response to Request for Additional Information -
Relief Request for Fourth Ten-Year Interval Inservice Testing
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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 Testing (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.
GO2-24-100 Enclosure Page 2 of 3 NRC Request EMIB-RAI-4IST-12-01 Alternative Request 4IST-12 (RV05), Section 5, Proposed Alternative and Basis for Use, first paragraph states:
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 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 the 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.
Energy Northwest Response to EMIB-RAI-4IST-12-01 With License Amendment 247, Energy Northwest was approved to utilize Nuclear Energy Institute (NEI) 94-01, Revision 3-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, which delineates a performance-based approach for surveillance testing frequencies. The ability to extend surveillance frequencies for these components is based on performance history of the component and risk insights. This same allowance was not approved for Inservice Testing (IST) components, leaving the IST components to continue following testing frequency requirements of American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition through 2006 Addenda.
Energy Northwest is requesting relief from the ASME OM Code frequency requirements, and will apply the NEI 94-01, Revision 3-A, guidance, as well as the conditions and limitations specified in NEI 94-01, Revision 2-A, to the valve position indication (VPI) testing frequencies for the IST components listed in Alternative Request 4IST-12. This approval will align the VPI testing frequencies to those of the 10 CFR Part 50, Appendix J
GO2-24-100 Enclosure Page 3 of 3 components. The VPI testing frequency for the applicable components will be eligible for performance-based testing interval extension, in accordance with NEI 94-01, Revision 3-A. If a component exceeds its administrative limit or fails its VPI testing, the surveillance will be reset to the base frequency of 30 months. Only after meeting the requirements of NEI 94-01, Revision 3-A, would the frequency be eligible for an extended interval. Energy Northwests 10 CFR Part 50, Appendix J, Option B performance-based leakage testing program will govern VPI testing interval frequency for the approved components in lieu of the testing frequency requirements in ASME OM Code, 2004 Edition through 2006 Addenda, Subsection ISTC-3700, Position Verification Testing.