ML26006A081
| ML26006A081 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 01/09/2026 |
| From: | Tony Nakanishi Plant Licensing Branch IV |
| To: | Entergy Operations |
| References | |
| EPID L-2025-LLR-0068 | |
| Download: ML26006A081 (0) | |
Text
January 9, 2026 GRAND GULF NUCLEAR STATION, UNIT 1-AUTHORIZATION OF ALTERNATIVE REQUEST NO. GGNS-PT-001 RELATED TO VISUAL EXAMINATION OF INBOARD FEEDWATER LEAKAGE CONTROL PIPING (EPID L-2025-LLR-0068)
LICENSEE INFORMATION Licensee:
Entergy Operations, Inc.
Licensee Address:
Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150 Plant Name and Unit:
Grand Gulf Nuclear Station, Unit 1 Docket No.:
50-416 APPLICATION INFORMATION Submittal Date: June 30, 2025 Submittal Agencywide Documents Access and Management System (ADAMS) Accession No.: ML25181A776 Supplement Date(s): N/A Supplement ADAMS Accession No(s).: N/A Licensee Proposed Alternative No. or Identifier: GGNS-PT-001 Applicable Inservice Inspection (ISI) or Inservice Testing (IST) Program Interval and Interval Start/End Dates: Grand Gulf Nuclear Station, Unit 1 is currently in the fourth Inservice Inspection (ISI) which started December 1, 2017, and is currently scheduled to end on November 30, 2027.
Alternative Requested: The licensee requested an alternative under Title 10 of the Code of Federal Regulations (10 CFR), 50.55a(z)(2).
ISI Requirement: American Society of Mechanical Engineers (ASME),Section XI, IWB-5222(b) requires that Class 1 pressure retaining boundary which is not pressurized when the system valves are in the position required for normal reactor startup shall be pressurized and examined at or near the end of the inspection interval.
Applicable Code Edition and Addenda: The code of record is the ASME Section XI, 2007 Edition with 2008 Addenda.
Brief Description of the Proposed Alternative:
In lieu of the required pressure tests, the licensee is requesting to examine the Inboard Feedwater Leakage Control (FWLC) piping between valves E38F002A/B and E38F001B using VT-2 visual testing inspection method on the section of FWLC piping that experiences Class 2 pressure during the Class 2 system leakage test. This examination will be conducted in the last inspection period of the inspection interval.
For additional details on the licensees request, please refer to the documents located at the ADAMS Accession No. identified above.
Duration of the Proposed Alternative The proposed alternative is for the 4th 10-year ISI interval, which is currently scheduled to end on November 30, 2027.
REGULATORY EVALUATION Regulatory Basis: 10 CFR 50.55a(z)(2)
Adherence to Section XI of the ASME Boiler and Pressure Vessel Code (BPV Code) is mandated by 10 CFR 50.55a(g)(4), which states, in part, that ASME BPV Code Class 1, 2, and 3 components will meet the requirements, except the design and access provisions and the pre-service examination requirements, set forth in Section XI of editions and addenda of the ASME BPV Code (or ASME Operation and Maintenance (OM) Code for snubber examination and testing) that become effective subsequent to editions specified in paragraphs (g)(2) and (3) of this section and that are incorporated by reference in paragraph (a)(1)(ii) or (iv) for snubber examination and testing of this section, to the extent practical within the limitations of design, geometry, and materials of construction of the components.
Paragraph 10 CFR 50.55a(z) states, in part, that alternatives to the requirements of 10 CFR 50.55a(b)-(h) may be used, when authorized by the Director, Office of Nuclear Reactor Regulation, if (1) the proposed alternatives would provide an acceptable level of quality and safety or (2) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The licensee has submitted the request on the basis that compliance with the specified requirements of 10 CFR 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
TECHNICAL EVALUATION ASME Code,Section XI IWB-5222(b) requires that all Class 1 components within the reactor coolant pressure boundary, even if the component is not pressurized for normal reactor startup, be pressurized and examined undergo a system leakage test. The licensee is proposing to perform a pressure test complying with the Class 2 requirements at the Class 2 pressure on the piping between valves E38F002A/B and E38F001B.
The subject piping between valves E38F002A/B and E38F001B is part of the FWLC that is designed for remote manual actuation following a loss-of-coolant accident and is not used during normal plant operation.
Performing the leakage test beyond the inboard isolation valves would require conditions that place the plant in abnormal configurations or requires off-normal activities to pressurize the subject piping. These changes include replacing check valves with blind flanges and installing an external pressure source at a modified test connection to achieve the needed pressure. This would require insulation removal, scaffolding activities, rigging activities, ASME Code welding activities, insulation replacement and post modification testing. This could include damage to permanent plant equipment and seat leakage at downstream isolation valves, causing increased radiological exposure of approximately 1.280 person-Roentgen Equivalent Man (rem). The NRC staff finds that this reconfiguration and associated increased dose to personnel constitutes a hardship for the licensee.
The licensee is proposing to perform a VT-2 inspection for leakage on the section of FWLC piping that experiences Class 2 pressure during the Class 2 system leakage test. The licensees proposed alternative would expose the extended Class 1 boundary to a lower test pressure than the ASME Code-required RCS pressure corresponding to 100-percent power. The proposed test pressure would correspond to the expected operating pressure for each of the subject piping components for the FWLC system.
Performing the leakage test at a lower pressure for the components in the extended Class 1 boundary would potentially reduce the capability of the test to detect leakage in the Class 1 pressure boundary. However, as the proposed system pressure test for these components will be done under the same conditions the subject piping is exposed to when the system is placed into operation during plant startup or shutdown, the proposed test would provide assurance that the piping system is able to perform its intended function.
Based on the above, the NRC staff determines that compliance with the ASME Code requirements for the referenced piping components would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, the NRC staff finds the licensees proposed alternative acceptable.
CONCLUSION The NRC staff has determined that complying with the specified requirements described in the licensees request referenced above would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
The proposed alternative provides reasonable assurance of structural integrity of the subject FWLC piping between valves E38F002A/B and E38F001B.
The NRC staff concludes that the licensee has adequately addressed the regulatory requirements set forth in 10 CFR 50.55a(z)(2).
The NRC staff authorizes the use of proposed alternative GGNS-PT-001 at Grand Gulf Nuclear Station, Unit 1, for the 4th 10-year ISI interval, which is currently scheduled to end on November 30, 2027.
All other ASME BPV Code,Section XI, requirements for which an alternative was not specifically requested and authorized remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: Stephen Cumblidge Date: January 9, 2026 Tony Nakanishi, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation TONY NAKANISHI Digitally signed by TONY NAKANISHI Date: 2026.01.09 08:03:04 -05'00'
ML26006A081 NRR-028 OFFICE NRR/DORL/LPL4/PM NRR/DORL/LPL4/LA NRR/DORL/LPL4/BC NAME MMahoney PBlechman (ABaxter for)
TNakanishi DATE 01/05/2026 01/08/2026 01/09/2026