W3F1-2025-0054, Inservice Test Program Request Fr Alternative VRR-WF3-2025-01
| ML25352A097 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/18/2025 |
| From: | Couture P Entergy Operations |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| W3F1-2025-0054, VRR-WF3-2025-01 | |
| Download: ML25352A097 (0) | |
Text
Phil Couture Senior Manager Fleet Regulatory Assurance - Licensing 601-368-5102 Entergy Operations, Inc., 1340 Echelon Parkway, Jackson, MS 39213 W3F1-2025-0054 10 CFR 50.55a December 18, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Inservice Testing Program Request for Alternative VRR-WF3-2025-01 Waterford Steam Electric Station, Unit 3 NRC Docket No. 50-382 Renewed Facility Operating License No. NPF-38 In accordance with 10 CFR 50.55a, "Codes and Standards," paragraph (z)(2), Entergy Operations, Inc. (Entergy) hereby requests U.S. Nuclear Regulatory Commission (NRC) approval of the enclosed Waterford Steam Electric Station, Unit 3 (WF3). This request proposes an alternative to the requirements of American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), ISTC-5240 and Mandatory Appendix I, Subsection I-1320 Test Frequencies, Class 1 Pressure Relief Valves. This subsection requires Class 1 pressure relief valves to be tested every 5 years and a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval.
WF3 Class 1 Relief Valve SI MVAAA404B test scope requires a unit shutdown and cooldown, was inadvertently removed from the Refueling Outage #26 [RFO26] scope and is now added onto upcoming Refueling Outage #27 [RFO27], (scheduled to start in the Fall 2026), scope, which would result in exceeding the 20% sampling requirement within any 24-month interval.
The other valve within its group, SI MVAAA404A, was tested on January 21, 2024, and the subject valve SI MVAAA404B was last tested on April 22, 2022. Therefore, SI MVAAA404B 24-month testing schedule is January 20, 2026, after that date, WF3 will not be in compliance with the OM Code. The test date would be exceeded by approximately nine months for this valve group 24-month sampling interval. Entergy is proposing a one-time extension in accordance with 10 CFR 50.55a(z)(2) because compliance with the IST requirement would result in hardship without a compensating increase in quality and safety because performing the test requires that the plant be in a cold shutdown condition.
The Enclosure to this letter contains the subject IST Request for Alternative.
W3F1-2025-0054 Page 2 of 2 This letter contains no new regulatory commitments.
Should you have any questions or require additional information, please contact Regulatory and Emergency Preparation Manager, John Twarog, at (504) 739-6747.
Respectfully, Phil Couture PC/rrp
Enclosure:
Inservice Testing (IST) Request for Alternative VRR-WF3-2025-01 cc:
NRC Region IV Regional Administrator NRC Senior Resident Inspector WF3 NRC Project Manager WF3 Philip Couture Digitally signed by Philip Couture Date: 2025.12.18 08:38:37 -06'00'
Enclosure W3F1-2025-0054 Inservice Testing (IST) Request for Alternative VRR-WF3-2025-01
W3F1-2025-0054 Enclosure Page 1 of 6 TABLE OF CONTENTS 1.0 TITLE AND REQUEST FOR ALTERNATIVE NUMBER................................................... 2 2.0 INTERVAL......................................................................................................................... 2 3.0 APPLICABLE CODE AND ADDENDA.............................................................................. 2 4.0 COMPONENT CODE CATEGORY / CLASS.................................................................... 2 5.0 VALVE GROUP................................................................................................................ 2 6.0 SYSTEM AND COMPONENT FUNCTION....................................................................... 2 7.0 OM CODE TEST REQUIREMENT................................................................................... 3 8.0 REASON FOR RELIEF REQUEST.................................................................................. 3 9.0 PROPOSED ALTERNATIVE TESTING AND DURATION............................................... 4 10.0 BASIS / JUSTIFICATION FOR RELIEF REQUEST......................................................... 4 11.0 PRECEDENCE................................................................................................................. 6
12.0 REFERENCES
.................................................................................................................. 6
W3F1-2025-0054 Enclosure Page 2 of 6 1.0 TITLE AND REQUEST FOR ALTERNATIVE NUMBER Inservice Testing (IST) Program Request for Alternative VRR-WF3-2025-01 for SI MVAAA404 B, Shutdown Cooling Loop 1 Suction Relief Valve (also denoted as SI-404B).
2.0 INTERVAL The 4th 10-Year IST Interval began on December 1, 2017, and ends November 30, 2027.
3.0 APPLICABLE CODE AND ADDENDA American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code), 2004 Edition with addenda through, and including, the ASME OMb Code, Addenda (OMb-2006).
4.0 COMPONENT CODE CATEGORY / CLASS The subject valve, SI-404B, is an ASME Code Category C, Class 1 relief valve.
5.0 VALVE GROUP There are two valves within the valve group, SI-404A and SI-404B.
Component Number Class Component Description Manufacturer Model Media Inlet Size SI-404A 1
RC Loop 2 Shutdown Cooling Suction Header Relief Valve Muller JMB WR-B Water 1
inch SI-404B 1
RC Loop1 Shutdown Cooling Suction Header Relief Valve Muller JMB WR-B Water 1
inch 6.0 SYSTEM AND COMPONENT FUNCTION The Shutdown Cooling (SDC) System is used to reduce the temperature of the Reactor Coolant System (RCS) and provide long term cooling in post shutdown periods from hot shutdown temperature to refueling temperatures. The SDC System consists of two independent and duplicate trains to achieve the required redundancy.
The SDC System is isolated from the RCS during normal plant power operation. Each SDC suction line is equipped with three isolation valves in a series arrangement. Valves SI-401A(B) and SI-405A(B) are located inside containment, while valves SI-407A(B) are located outside containment. With this arrangement, a redundant parallel SDC path is
W3F1-2025-0054 Enclosure Page 3 of 6 available should a single failure preclude the availability of one of the SDC trains. Each valve inside containment is provided with an interlock to prevent opening until RCS pressure is less than 392 PSIA. In addition, during normal operation, the circuit breakers for motor operated valves SI-401A and SI-401B are locked in the open position to prevent inadvertent opening.
Figure 1, Pipe and Flow diagram SI-404A(B) is a 1-inch Mueller model JMB45WRB relief valve. It provides protection from thermal over-pressurization between SI-401A(B) and SI-405A(B). The rated design pressure / temperature for SI-404A(B) is 2485 PSIG / 650 °F. The relief flow is released to the Reactor Drain Tank (RDT).
7.0 OM CODE TEST REQUIREMENT Mandatory Appendix I, Subsection I-1320 Test Frequencies, Class 1 Pressure Relief, requires Class 1 pressure relief valves tested at least once every 5 years, starting with initial electric power generation. No maximum limit is specified for the number of valves to be tested within each interval; however, a minimum of 20% of the valves from each valve group shall be tested within any 24-month interval.
8.0 REASON FOR RELIEF REQUEST SI-404B was planned to be tested in refueling outage #26 [RFO26] Spring 2025 and was requested initially to be scoped in the refueling outage. However, during the scope selection process, the valve was mistakenly removed from the outage scope. The outage team was not aware of the 20% sampling requirement and removed the work order based on remaining time left on the master work order. The WF3 Engineering team was not aware of the valve removal until outage completion. This issue was identified after outage completion while reviewing the scope for refueling outage #27
[RFO27].
W3F1-2025-0054 Enclosure Page 4 of 6 The other valve within the group SI-404A was tested on January 21, 2024, and the subject valve SI-404B was tested on April 22, 2022. Therefore, SI-404B should be tested prior to January 20, 2026, to meet the 24-month sampling requirement.
This situation was entered into the Entergy Corrective Action Program. An Extent of Condition review was performed and confirmed there were no additional cases of missed testing from the RFO26 relief valve scope.
9.0 PROPOSED ALTERNATIVE TESTING AND DURATION Entergy plans to test this valve as soon as practical to return to compliance with the OM Code. Performance of the valve test during online operations is not practical due to valve being located inside containment building and requires a refueling outage (Cold Shutdown) to allow valve access; therefore, the work order has been added onto the plant forced outage item. However, due to uncertainty of a plant forced outage opportunity, Entergy is proposing a one-time extension for approximately nine months until the next refueling outage #27 [RFO27] which is currently scheduled for the Fall of 2026. This extension is requested in accordance with 10 CFR 50.55a(z)(2), because compliance with the IST requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety because performing the test requires that the plant be in a cold shutdown condition.
10.0 BASIS / JUSTIFICATION FOR RELIEF REQUEST Entergy proposes extending the test interval for SI-404B to allow for testing during the next scheduled refueling outage. A review of past component performance and industry Operating Experience (OE) does not indicate any history of chronic failure with this series of valves. Therefore, Entergy has concluded that the proposed alternative test frequency provides reasonable assurance of operational readiness for SI-404B until it is tested during the next refueling outage. Therefore, in accordance with 10 CFR 50.55a(z)(2), this test interval extension until refueling outage is requested on the basis that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Following is supporting basis for the relief request.
- 1. There are no Surveillance requirements or Limiting Conditions for Operation in the WF3 Technical Specification specifically for SI-404B. The discharge of SI-404B relief valve is connected to the RDT, which is located inside containment. There is a normally isolated boundary valve (SI-401B) from the RCS pressure boundary.
SI-404B has no safety function (Containment Isolation or Safety Injection) in the Final Safety Analysis Report (FSAR) Section 3.9.3.3 and Table 3.9-1.
- 2. WF3 10-year IST plan is still within ASME OM Code compliance. SI-404B has not exceeded the 5-year test frequency requirement in the OM code I-1320 and the WF3 10-Year plan and will not exceed the 5-year test requirement from this request.
- 3. Recent inspection for SI-404B and SI-404A (other valve in the group) shows no notable abnormalities, adverse trends, or valve degradation issues. The IST test
W3F1-2025-0054 Enclosure Page 5 of 6 history listed in Tables 1 and 2 shows there were no as-found set-pressure test failures in the past twenty years within this group valves.
- 4. SI-404B, is installed to protect isolated segments of SDC Suction piping that could be thermally pressurized as a result of heating from some heat source, but thermal relief valves are widely viewed as having no safety-related function in mitigating the consequences of accidents or ensuring any other system safety function.
Table 1, SI-404A Test History Test Date As Found Result Note Lift Test Leakage Test Visual Inspection 01/21/2024 SAT SAT SAT 10/07/2020 SAT SAT SAT 04/28/2017 SAT SAT SAT Valve seat cleaned/
reworked 04/27/2014 SAT SAT SAT 04/21/2011 SAT SAT SAT 05/07/2008 SAT SAT SAT 04/30/2005 SAT SAT SAT Table 2, SI-404B Test History Test Date As Found Test Result Note Lift Test Leakage Test Visual Inspecti on 04/22/2022 SAT SAT SAT 01/19/2019 SAT SAT SAT 11/15/2015 SAT SAT SAT 10/29/2012 SAT
- UNSAT SAT
- It was noted that there was one case of as-found seat leakage failure from SI-404B in 2012, however, the premature lifting and seat leakage during plant operation will be conservative for thermal relief function. This section of piping is only in service and un-isolated during the use of SDC conditions.
==
Conclusion:==
Based on the performance history and safety significance review of the subject valve, the test extension approximately nine months beyond the OM code requirement I-1320 Sampling Requirement, would not compromise safe operation of the plant until the next refueling outage #27 [RFO27].
W3F1-2025-0054 Enclosure Page 6 of 6 11.0 PRECEDENCE In the following precedents, the NRC authorized an alternative request to defer the inservice test of pressure relief valves within the respective programs. The approved duration was for the remainder of the current operating cycle until the subsequent scheduled refueling outages where the subject valves would be tested. The basis and duration for the identified precedent alternative requests are similar to that being presented herein for WF3.
- 1. NRC letter to H. B. Robinson Steam Electric Plant Unit No. 2, "Relief Request RA-19-0428 for One Time Pressure Relief Valve Test Frequency Extension,"
ML20199M275, dated August 19, 2020.
- 2. NRC letter to Tennessee Valley Authority, " Watts Bar Nuclear Plant, Unit 1 -
Authorization and Safety Evaluation for Alternative Request No. IST-RR-9,"
ML21244A345, dated September 20, 2021.
- 3. NRC letter to Constellation Energy Generation LLC "R. E. GINNA Nuclear Power Plant - Alternative Request Associated with Inservice Testing of Loop B Letdown Relief Valve - VR-04," ML24332A090, dated August 4, 2025.
12.0 REFERENCES
None