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MONTHYEARW3F1-2016-0036, Application to Revise Technical Specifications to Adopt TSTF-545, Rev 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code2016-07-25025 July 2016 Application to Revise Technical Specifications to Adopt TSTF-545, Rev 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code Project stage: Request W3F1-2016-0054, Request for Alternative to the ASME Code to Adopt Approved Code Case OMN-20, Inservice Test Frequency, Relief Request WF3-RR-2016-12016-08-10010 August 2016 Request for Alternative to the ASME Code to Adopt Approved Code Case OMN-20, Inservice Test Frequency, Relief Request WF3-RR-2016-1 Project stage: Request ML16263A1872016-08-16016 August 2016 NRR E-mail Capture - Acceptance Review Results - Proposed Alternative to Adopt ASME OM Code Case OMN-20, Inservice Testing Frequency - Waterford, Unit 3 Project stage: Acceptance Review ML16235A2282016-12-0909 December 2016 Request for Alternative Test Plan to American Society of Mechanical Engineers Code for Operation and Maintenance of Nuclear Power Plants Project stage: Other 2016-07-25
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Category:Letter type:W
MONTHYEARW3F1-2023-0056, Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242023-12-19019 December 2023 Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2023-0055, Reply to a Notice of Violation2023-12-14014 December 2023 Reply to a Notice of Violation W3F1-2023-0052, Core Operating Limits Report (COLR) - Cycle 26, Revision O2023-11-0707 November 2023 Core Operating Limits Report (COLR) - Cycle 26, Revision O W3F1-2023-0049, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal2023-09-28028 September 2023 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability - Withdrawal W3F1-2023-0048, Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-09-25025 September 2023 Special Report SR 2023-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0035, Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program2023-07-26026 July 2023 Application for Technical Specification Change to Revise Surveillance Requirements Included in the Surveillance Frequency Control Program W3F1-2023-0036, Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2023-05-0404 May 2023 Special Report SR-2023-003-01 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0032, Annual Radioactive Effluent Release Report (ARERR) 20222023-04-27027 April 2023 Annual Radioactive Effluent Release Report (ARERR) 2022 W3F1-2023-0033, Submittal of Annual Radiological Environmental Operating Report - 20222023-04-27027 April 2023 Submittal of Annual Radiological Environmental Operating Report - 2022 W3F1-2023-0025, Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.22062023-04-11011 April 2023 Annual Report of Individual Monitoring of Radiation Exposure for 2022 Per 10 CFR 20.2206 W3F1-2023-0018, Updated Final Supplemental Response to NRC Generic Letter 2004-022023-03-30030 March 2023 Updated Final Supplemental Response to NRC Generic Letter 2004-02 W3F1-2023-0022, Registration of Dry Fuel Storage Cask Use2023-03-22022 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0021, Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days2023-03-17017 March 2023 Submittal of Special Report SR 2023-003-00 Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0016, Registration of Dry Fuel Storage Cask Use2023-03-0303 March 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0014, Reply to a Notice of Violation; EA-22-1192023-02-20020 February 2023 Reply to a Notice of Violation; EA-22-119 W3F1-2023-0013, Notification of Readiness for Supplemental Inspection2023-02-15015 February 2023 Notification of Readiness for Supplemental Inspection W3F1-2023-0007, Registration of Dry Fuel Storage Cask Use2023-02-0606 February 2023 Registration of Dry Fuel Storage Cask Use W3F1-2023-0010, Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days2023-01-25025 January 2023 Special Report SR 2023-002-00, Radiation Monitor Inoperable Greater than 7 Days W3F1-2023-0002, SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days2023-01-0505 January 2023 SR 2023-001-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 30 Days W3F1-2022-0067, Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-022022-12-20020 December 2022 Commitment Change Notification for Generic Safety Issue 191 and Generic Letter 2004-02 W3F1-2022-0054, Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability2022-11-0101 November 2022 Revise Technical Specification 3/4.3.2 to Remove Exemption from Testing Certain Relays at Power to Support Elimination of Potential Single Point Vulnerability W3F1-2022-0063, Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 372022-10-27027 October 2022 Submittal of Emergency Preparedness Documents. Includes EP-001-001, Revision 37 W3F1-2022-0059, Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-5052022-10-13013 October 2022 Response to Clarification Questions Concerning Supplement to License Amendment Request to Adopt TSTF-505 W3F1-2022-0058, Reply to a Notice of Violation; EA-22-0332022-10-12012 October 2022 Reply to a Notice of Violation; EA-22-033 W3F1-2022-0049, Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-5052022-08-19019 August 2022 Response to Request for Additional Information Regarding License Amendment Requests to Adopt 10 CFR 50.69 and TSTF-505 W3F1-2022-0037, Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 242022-08-0808 August 2022 Submittal of Owner'S Activity Report Form for Inservice Inspection Performed During Operating Cycle 24 / Refuel 24 W3F1-2022-0044, SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-07-0606 July 2022 SR-2022-004-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0042, SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-06-27027 June 2022 SR-22-003-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0015, Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf.2022-05-16016 May 2022 Response to Request for Additional Information to License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - Ritstf. W3F1-2022-0026, Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 20222022-04-28028 April 2022 Report of Facility Changes, Tests, and Experiments and Commitment Changes for Two Year Period Ending April 28, 2022 W3F1-2022-0028, Annual Radiological Environmental Operating Report - 20212022-04-26026 April 2022 Annual Radiological Environmental Operating Report - 2021 W3F1-2022-0029, Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.22062022-04-26026 April 2022 Annual Report of Individual Monitoring of Radiation Exposure for 2021 Per 10 CFR 20.2206 W3F1-2022-0009, Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors2022-04-25025 April 2022 Supplement to Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components (Sscs) for Nuclear Power Reactors W3F1-2022-0031, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-2842022-04-25025 April 2022 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Reflect Location of Standby Capsules 3/W-104 and 6/W-284 W3F1-2022-0020, Review of Preliminary Accident Sequence Precursor Report2022-04-11011 April 2022 Review of Preliminary Accident Sequence Precursor Report W3F1-2022-0017, Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 20212022-04-0707 April 2022 Annual Report on Westinghouse Electric Company LLC Combustion Engineering Emergency Core Cooling System Performance Evaluation Models for Calendar Year 2021 W3F1-2022-0019, WAT-2022-02 Post Exam Analysis2022-03-0909 March 2022 WAT-2022-02 Post Exam Analysis W3F1-2022-0011, Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days2022-02-0808 February 2022 Special Report SR-22-002-00 for Waterford Steam Electric Station, Unit 3, Radiation Monitor Inoperable Greater than 7 Days W3F1-2022-0008, SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days2022-02-0101 February 2022 SR-22-001-00, Waterford Steam Electric Station, Unit 3, Radiation Monitors Inoperable Greater than 7 Days W3F1-2021-0074, Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-022021-12-16016 December 2021 Commitment Change Notification for Generic Safety Issue - 191 and Generic Letter 2004-02 W3F1-2021-0064, Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 2842021-11-30030 November 2021 Proposed Revision to Reactor Vessel Surveillance Capsule Withdrawal Schedule to Support Relocation of Capsules 104 and 284 W3F1-2021-0061, Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-10-14014 October 2021 Supplement to License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0063, Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery2021-10-12012 October 2021 Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Exercise Requirements Due to Severe Storm Recovery W3F1-2021-0050, Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt2021-10-0101 October 2021 Response to U. S. Nuclear Regulatory Commission Request for Additional Information Regarding License Amendment Request to Adopt W3F1-2021-0060, Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual2021-09-30030 September 2021 Response to Request for Additional Information Regarding License Amendment Request to Relocate Chemical Detection Systems Technical Specifications to Technical Requirements Manual W3F1-2021-0039, Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years2021-08-25025 August 2021 Application for Technical Specification Change to Revise Pressure/Temperature and Low Temperature Overpressure Protection for 55 Effective Full Power Years W3F1-2021-0055, Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual2021-08-20020 August 2021 Supplement to License Amendment Request to Relocate Boration Systems Technical Specifications to the Technical Requirements Manual W3F1-2021-0057, (Waterford 3) - Emergency Plan Revision 0522021-08-18018 August 2021 (Waterford 3) - Emergency Plan Revision 052 W3F1-2021-0054, License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 20202021-07-29029 July 2021 License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator (CPC) System and Control Element Assembly Calculator (Ceac) System, Dated July 23, 2020 W3F1-2021-0051, Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator2021-07-19019 July 2021 Revised Licensing Technical Report for the Common Q Core Protection Calculator System - License Amendment Request to Implement a Digital Upgrade to the Core Protection Calculator System and Control Element Assembly Calculator 2023-09-28
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Entergy Operations Inc.
17265 River Road Killona, LA 70057-3093 Tel 504-739-6685 Fax 504-739-6678 jjarrel@entergy.com John P. Jarrell, III Regulatory Assurance Manager Waterford 3 W3F1-2016-0054 10 CFR 50.55a August 10, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Request for Alternative to the ASME Code to Adopt Approved Code Case OMN-20, "Inservice Test Frequency."
Relief Request WF3-RR-2016-1 Waterford Steam Electric Station, Unit 3 Docket No. 50-382 License No. NPF-38
REFERENCE:
Entergy letter W3F1-2016-0036, Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing, and to Request an Alternative to the ASME Code dated July 25, 2016. [ADAMS Accession No. ML16207A532]
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(z)(2), Codes and Standards, Entergy Operations, Inc. (Entergy) hereby requests NRC approval of the attached relief request.
Entergy is requesting approval to use an alternative to the testing frequencies in the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code, by adoption of approved Code Case OMN-20, Inservice Test Frequency, for the third 10 year Inservice Testing (IST) interval. The details of this relief request are contained in Attachment 1.
This request was first combined with the license amendment request referenced above. The NRC staff has requested that it be submitted separately. This letter submits the relief request separately, as requested. Entergy requests approval of the relief request by July 25, 2017.
No new commitments have been identified in this letter.
If you have any questions or require additional information, please contact John Jarrell at 504-739-6685.
W3F1-2016-0054 Page 2 of 2 Attachments:
- 1. Relief Request WF3-RR-2016-1 cc: Mr. Kriss Kennedy Regional Administrator ridsrgn4mailcenter@nrc.gov NRC Senior Resident Inspector Frances.Ramirez@nrc.gov Chris.Speer@nrc.gov NRC Project Manager - Waterford 3 Dr. April Pulvirenti April.Pulvirenti@nrc.gov
Attachment 1 to W3F1-2016-0054 Relief Request WF3-RR-2016-1 to W3F1-2016-0054 Page 1 of 3 DESCRIPTION AND ASSESSMENT OF THE PROPOSED ALTERNATIVE TO THE ASME CODE Request in Accordance with 10 CFR 50.55a(z)(2)
Alternative Due To Hardship Without a Compensating Increase in Quality and Safety
1.0 DESCRIPTION
The request is to adopt a proposed alternative to the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code by adoption of approved Code Case OMN-20, "Inservice Test Frequency."
2.0 ASSESSMENT Technical Evaluation of the Proposed Alternative to the OM Code Section IST of Division 1 of the OM Code, which is incorporated by reference in 10 CFR 50.55a(a), specifies component test frequencies based either on elapsed time periods (e.g.,
quarterly, 2 years) or on the occurrence of a plant condition or event (e.g., cold shutdown, refueling outage).
ASME Code Case OMN-20, Inservice Test Frequency, has been approved for use by the ASME OM committee as an alternative to the test frequencies for pumps and valves specified in ASME OM Division 1, Section IST, 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.
Code Case OMN-20 is not referenced in the latest revision of Regulatory Guide 1.192 (August 2014) as an acceptable OM Code Case to comply with 10 CFR 50.55a(f) requirements as allowed by 10 CFR 50.55a(b)(6). The proposed alternative is to use Code Case OMN-20 to extend or reduce the IST frequency requirements for the third 10-year IST interval or until OMN-20 is incorporated into the next revision of Regulatory Guide 1.192.
ASME Code Components Affected The Code Case applies to pumps and valves specified in ASME OM Division 1, Section IST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code. Frequency extensions may also be applied to accelerated test frequencies (e.g., pumps in Alert Range) as specified in OMN-20.
For pumps and valves with test periods of 2 years of less, the test frequency allowed by OMN-20 and the current Technical Specification (TS) Inservice Testing Program (as modified by Surveillance Requirement (SR) 3.0.2 and Enforcement Guidance Memorandum (EGM) 2012-001) are the same. For pumps and valves with test frequencies greater than 2 years, OMN-20 allows the test frequency to be extended by 6 months. The current TS Inservice Testing (IST)
Program does not allow extension of test frequencies that are greater than 2 years.
to W3F1-2016-0054 Page 2 of 3
Applicable Code Edition and Addenda
ASME Code Case OMN-20 applies to ASME OM Division 1, Section IST, 2009 Edition through OMa-2011 Addenda and all earlier editions and addenda of ASME OM Code.
The Waterford Steam Electric Station, Unit 3 (Waterford 3) Code Edition and Addenda that are applicable to the program interval are the ASME OM Code 2001 Edition with addenda through and including the ASME OMb Code-2003 Adenda (referred to as OMB-2003) (reference Entergy Letter GNRI-96/00184) dated August 27, 1996, TAC M94454. The Waterford 3 current interval began on December 1, 2007 and ends November 30, 2017.
Applicable Code Requirement
This request is made in accordance with 10 CFR 50.55a(z)(2), and proposes an alternative to the requirements of 10 CFR 50.55a(f), which requires pumps and valves to meet the test requirements set forth in specific documents incorporated by reference in 10 CFR 50.55a(a).
ASME Code Case OMN-20 applies to Division 1, Section IST of the ASME OM Code and associated addenda incorporated by reference in 10 CFR 50.55a(a).
Reason for Request
NOTE: The discussions within this request for alternative refer to NUREG-1432, Standard Technical Specifications - Combustion Engineering Plants, Revision 4, SR numbering. The equivalent Waterford 3 SRs are 4.0.2 and 4.0.3.
The IST Program controls specified in Section 6.5.8 of the Waterford 3 TS provide: a) a table specifying certain IST frequencies; b) an allowance to apply SR 4.0.2 to inservice tests required by the OM Code and with frequencies of two years or less; c) an allowance to apply SR 4.0.3 to inservice tests required by the OM Code; and d) a statement that, Nothing in the ASME OM Code shall be construed to supersede the requirements of any TS. In Regulatory Issue Summary (RIS) 2012-10, "NRC Staff Position on Applying Surveillance Requirement 3.0.2 and 3.0.3 to Administrative Controls Program Tests," and EGM 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements that Extend Test Frequencies and Allow Performance of Missed Tests," the NRC stated that items b, c, and d of the TS IST Program were inappropriately added to the TS and may not be applied (although the EGM allows licensees to continue to apply those paragraphs pending a generic resolution of the issue).
In RIS 2012-10 and EGM 2012-001, the NRC stated that the current TS allowance to apply SR 3.0.2 and SR 3.0.3 to the IST Program would no longer be permitted. In response, OMN-20, which provides allowances similar to SR 3.0.2, was approved and is proposed to be used as an alternative to the test periods specified in the OM code. The proposed alternative substitutes an approved Code Case for the existing TS requirements that the NRC has determined are not legally acceptable as a TS allowance. This proposed alternative provides an equivalent level of safety as the existing TS allowance, while maintaining consistency with 10 CFR 50.55a and the ASME OM Code.
to W3F1-2016-0054 Page 3 of 3 Proposed Alternative and Basis for Use The proposed alternative is OMN-20, "Inservice Test Frequency," which addresses testing periods for pumps and valves specified in ASME OM Division 1, Section IST, 2009 Edition through OMa-2011 Addenda, and all earlier editions and addenda of ASME OM Code.
This request is being made in accordance with 10 CFR 50.55a(z)(2), in that the existing requirements are considered a hardship without a compensating increase in quality and safety for the following reasons:
- 1) For IST testing periods up to and including 2 years, Code Case OMN-20 provides an allowance to extend the IST testing periods by up to 25%. The period extension is to facilitate test scheduling and considers plant operating conditions that may not be suitable for performance of the required testing (e.g., performance of the test would cause an unacceptable increase in the plant risk profile due to transient conditions or other ongoing surveillance, test or maintenance activities). Period extensions are not intended to be used repeatedly, merely as an operational convenience to extend test intervals beyond those specified. The test period extension and the statements regarding the appropriate use of the period extension are equivalent to the existing TS SR 3.0.2 allowance and the statements regarding its use in the SR 3.0.2 Bases. Use of the SR 3.0.2 period extension has been a practice in the nuclear industry for many decades and elimination of this allowance would place a hardship on Entergy Operations, Inc. (Entergy), when there is no evidence that the period extensions affect component reliability.
- 2) For IST testing periods of greater than 2 years, OMN-20 allows an extension of up to 6 months. The ASME OM Committee determined that such an extension is appropriate.
The 6-month extension will have a minimal impact on component reliability considering that the most probable result of performing any inservice test is satisfactory verification of the test acceptance criteria. As such, pumps and valves will continue to be adequately assessed for operational readiness when tested in accordance with the requirements specified in 10 CFR 50.55a(f) with the frequency extensions allowed by Code Case OMN-20.
- 3) As stated in EGM 2012-001, if an inservice test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed inservice test on the operability of TS equipment will be assessed under the licensee's Operability Determination Program.
Duration of Proposed Alternative The proposed alternative is requested until the end of the current 10-year IST interval or until Code Case OMN-20 is incorporated into a future revision of Regulatory Guide 1.192, referenced by a future revision of 10 CFR 50.55a, whichever occurs first.
Precedents The NRC approved the use of OMN-20 for North Anna on March 27, 2014 (NRC ADAMS Accession Number ML14084A407).