ML16160A092

Relief Request GG-IST-2015-1 Related to the Inservice Testing Program

ML16160A092
Person / Time
Site:	Grand Gulf
Issue date:	06/16/2016
From:	Shaun Anderson, James Kim Plant Licensing Branch IV
To:	Entergy Operations
Kim J, NRR/DORL/LPLIV-2, 415-4125
References
CAC MF7117, GG-IST-2015-1
Download: ML16160A092 (9)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 16, 2016 Vice President, Operations Entergy Operations, Inc.

Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRAND GULF NUCLEAR STATION, UNIT 1 - RELIEF REQUEST GG-IST-2015-1 RELATED TO THE INSERVICE TESTING PROGRAM (CAC NO. MF7117)

Dear Sir or Madam:

By letter dated September 15, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15259A042), as supplemented by letters dated November 6, November 23, and December 2, 2015 (ADAMS Accession Nos. ML15310A220, ML15327A180, and ML15337A255, respectively), Entergy Operations, Inc. (Entergy, the licensee), submitted request for relief GG-IST-2015-1 to the U.S. Nuclear Regulatory Commission (NRC), proposing alternatives to certain requirements of the American Society of Mechanical Engineers (ASME)

Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the inservice testing (IST) program at Grand Gulf Nuclear Station, Unit 1 (GGNS) for the third 10-year IST program interval, which began on December 1, 2007, and is scheduled to end on November 30, 2017.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(z)(2), the licensee requested to use the proposed alternatives in GG-IST-2015-1 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

Based on the enclosed safety evaluation, the NRC staff determines that for alternative request GG-IST-2015-1, the proposed alternatives provide reasonable assurance that the affected components are operationally ready. The NRC staff concludes that complying with the specified ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes alternative request GG-IST-2015-1 for Grand Gulf Nuclear Station, Unit 1 for the third 10-year IST program interval, which began on December 1, 2007, and is scheduled to end on November 30, 2017.

All other ASME OM Code requirements for which relief was not specifically requested and approved, remain applicable.

If you have any questions, please contact James Kim at (301) 415-4125 or by e-mail at James.Kim@nrc.gov.

Sincerely,

~/,,/-

Shaun M. Anderson, Acting Chief Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF GG-IST-2015-1 RELATED TO THE INSERVICE TESTING PROGRAM FOR THE THIRD 10-YEAR INTERVAL GRAND GULF NUCLEAR STATION. UNIT 1 ENTERGY OPERATIONS. INC.

DOCKET NO. 50-416

1.0 INTRODUCTION

By letter dated September 15, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15259A042), as supplemented by letters dated November 6, November 23, and December 2, 2015 (ADAMS Accession Nos. ML15310A220, ML15327A180, and ML15337A255, respectively), Entergy Operations, Inc. (Entergy, the licensee), submitted request for relief GG-IST-2015-1 to the U.S. Nuclear Regulatory Commission (NRC), proposing alternatives to certain requirements of the American Society of Mechanical Engineers (ASME)

Code for Operation and Maintenance of Nuclear Power Plants (OM Code), for the inservice testing (IST) program at Grand Gulf Nuclear Station, Unit 1 (GGNS) for the third 10-year IST program interval, which began on December 1, 2007, and is scheduled to end on November 30, 2017.

Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(z)(2), the licensee requested to use the proposed alternatives in GG-IST-2015-1 on the basis that the ASME OM Code requirements present an undue hardship without a compensating increase in the level of quality or safety.

2.0 REGULATORY EVALUATION

The regulation in 10 CFR 50.55a(f), "lnservice testing requirements," requires, in part, that IST of certain ASME Code Class 1, 2, and 3 components must meet the requirements of the ASME OM Code and applicable addenda, except where alternatives have been authorized pursuant to 10 CFR 50.55a(z)(1) or 10 CFR 50.55a(z)(2).

The regulations in 10 CFR 50.55a(z), state, in part, that alternatives to the requirements of 10 CFR 50.55a(f) may be authorized by the NRC if the licensee demonstrates that: (1) the proposed alternative provides 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.

Enclosure

Based on the above, and subject to the NRC's findings with respect to authorizing the proposed alternatives to the ASME OM Code given below, the NRC staff concludes that regulatory authority exists for the licensee to request and the Commission to authorize the alternatives requested by the licensee.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Alternative Request GG-IST-2015-1 Applicable Edition of OM Code The GGNS third 10-year IST interval began on December 1, 2007, and is scheduled to end on November 30, 2017. The applicable ASME OM Code edition and addenda for the GGNS third 10-year IST program interval are the 2001 Edition with addenda through, and including, the 2003 Addenda, except that for main steam safety relief valve testing, GGNS implements Mandatory Appendix I, paragraphs 1-3410(a) and (d) of the 2004 Edition with no addenda.

Applicable Code Requirements This request for relief applies to the frequency specification of the ASME OM Code for all pump and valve testing contained within the IST program scope. The applicable ASME OM Code sections include the following:

Code Paragraph Description The frequency for the inservice testing shall be ISTA-3120(a) in accordance with the requirements of Section IST.

ISTB-3400 Frequency of lnservice Tests ISTC-3510 Exercising Test Frequency ISTC-3540 Manual Valves ISTC-3630(a) Frequency ISTC-3700 Position Verification Testing At least one valve from each group shall be disassembled and examined at each refueling ISTC-5221 (c)(3) outage; all valves in a group shall be disassembled and examined at least once every 8 years.

ISTC-5260 Explosively Actuated Valves

Code Paragraph Description Test Frequencies - Class 1 Pressure Relief Appendix I, 1-1320 Valves Test Frequency - Class 1 Nonreclosing Appendix I, 1-1330 Pressure Relief Devices Test Frequency - Class 1 Pressure Relief Appendix I, 1-1340 Valves that are used for Thermal Relief Application Test Frequency - Classes 2 and 3 Pressure Appendix I, 1-1350 Relief Valves Test Frequency - Classes 2 and 3 Appendix I, 1-1360 Nonreclosing Pressure Relief Devices Test Frequency - Classes 2 and 3 Primary Appendix I, 1-1370 Containment Vacuum Relief Valves Test Frequency - Class 2 and 3 Vacuum Relief Appendix I, 1-1380 Valves Except for Primary Containment Vacuum Relief Valves Test Frequency - Classes 2 and 3 Pressure Appendix I, 1-1390 Relief Devices that are used for Thermal Relief Application Appendix 11, ll-4000(a)(1) Performance Improvement Activities Appendix 11, ll-4000(b)(1)(e) Optimization of Condition-Monitoring Activities

Reason for Request

In its letter dated December 2, 2015, the licensee stated, in part:

ASME OM Code Section IST establishes the inservice test frequency for all components within the scope of the Code. The frequencies (e.g., quarterly) have always been interpreted as "nominal" frequencies (generally as defined in Table 3.2 of NUREG 1482, Revision 1) and Owners applied the surveillance extension time period (i.e. grace period) contained in the plant Technical Specifications (TS) Surveillance Requirements (SRs). The TS allow for a less than or equal to 25% extension of the surveillance test interval to accommodate plant conditions that may not be suitable for conducting the surveillance (TS 3.0.2). However, Regulatory Issue Summary 2012-10, NRC Staff Position

on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests, states that SR 3.0.2 and 3.0.3 cannot be applied to TS 5.5 for tests that are not associated with a TS SR.

The lack of a tolerance band on the ASME OM Code inservice test frequency restricts operational flexibility. There may be times when a surveillance test could be required (i.e., its frequency could expire), but plant conditions are not risk conducive or the testing may not even be possible until sometime after a plant condition or associated Limited Condition Operation (LCO) is within its applicability.

Thus, just as with TS required surveillance testing, some tolerance is needed to allow adjusting OM Code testing intervals to better align with the plant conditions and other maintenance and testing activities. Providing a tolerance band assures operational flexibility for scheduling surveillance tests to minimize conflicts between the need to complete the surveillance and plant conditions.

Pursuant to 10 CFR 50.55a(z)(2), the licensee requested relief from the frequency specification of the ASME OM Code. The basis of the relief request is that the Code requirement presents an undue hardship without a compensating increase in the level of quality and safety.

Proposed Alternative In its letter dated December 2, 2015, the licensee stated, in part:

The proposed alternative is OMN-20, "lnservice Test Frequency," which addresses testing periods for pumps and valves specified in ASME OM 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) and is necessary as compliance with the OM Code requirements would result in hardship/unusual difficulty without a compensating increase in quality or safety.

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 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 lnservice Test is not performed within its frequency, SR 3.0.3 will not be applied. The effect of a missed lnservice Test on the Operability of TS equipment will be assessed under the licensee's Operability Determination Program.

3.2 NRC Staff Evaluation Historically, licensees have applied, and the NRC staff has accepted, the standard TS definitions for IST intervals (including allowable interval extensions) to ASME OM Code-required testing (NUREG-1482, Revision 2, Section 3.1.3, "Scheduling of lnservice Tests, October 2013 (ADAMS Accession No. ML13295A020)). Recently, the staff reconsidered the allowance of using TS testing intervals and interval extensions for IST not associated with TS SRs. As noted in Regulatory Issue Summary 2012-10, "NRC Staff Position on Applying Surveillance Requirements 3.0.2 and 3.0.3 to Administrative Controls Program Tests," dated August 23, 2012 (ADAMS Accession No. ML12079A393), the NRC determined that programmatic test frequencies can not be extended in accordance with the TS SR 3.0.2. This includes all IST described in the ASME OM Code not specifically required by the TS SRs.

Following this development, the NRC staff sponsored and co-authored an ASME OM Code inquiry and Code case to modify the ASME OM Code to include TS-like test interval definitions and interval extension criteria. The resultant ASME Code Case OMN-20 was approved by the ASME Operation and Maintenance Standards Committee on February 15, 2012, with the NRC representative voting in the affirmative. ASME Code Case OMN-20 was subsequently published in conjunction with the ASME OM Code, 2012 Edition. The licensee proposes to adopt ASME Code Case OMN-20.

Requiring the licensee to meet the ASME OM Code requirements, without an allowance for defined frequency and frequency extensions for IST of pumps and valves, results in a hardship without a compensating increase in the level of quality and safety. Based on the prior acceptance by the NRC staff of the similar TS test interval definitions and interval extension criteria, the staff finds that implementation of the test interval definitions and interval extension criteria contained in ASME OM Code Case OMN-20 is acceptable. Allowing usage of ASME Code Case OMN-20 provides reasonable assurance of operational readiness of pumps and valves subject to the ASME OM Code IST.

4.0 CONCLUSION

As set forth above, the NRC staff determines that for alternative request GG-IST-2015-1, the proposed alternatives provide reasonable assurance that the affected components are operationally ready. The NRC staff concludes that complying with the specified ASME OM Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Accordingly, the NRC staff concludes that the licensee has adequately addressed all of the regulatory requirements set forth in 10 CFR 50.55a(z)(2). Therefore, the NRC staff authorizes alternative request GG-IST-2015-1 for Grand Gulf Nuclear Station, Unit 1 for the third 10-year IST program interval, which began on December 1, 2007, and is scheduled to end on November 30, 2017.

All other ASME Code, Section XI requirements for which relief was not specifically requested and approved, remain applicable.

Principal Contributor: John Billerbeck Date: June 16, 2016

All other ASME OM Code requirements for which relief was not specifically requested and approved, remain applicable.

If you have any questions, please contact James Kim at (301) 415-4125 or by e-mail at James.Kim@nrc.gov.

Sincerely,

/RAJ Shaun M. Anderson, Acting Chief Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

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PUBLIC RidsNrrDorlDpr Resource RidsACRS_MailCTR Resource LPL4-2 R/F RidsNrrDorllp14-2 Resource RidsRgn4MailCenter Resource RidsNrrPMGrandGulf Resource RidsNrrLAPBlechman Resource RidsNRRDeEpnb Resource JBillerbeck, NRR JBowen, EDO, RIV ADAMS A ccess1on No. ML16160A092 . *S ee memo d at e d May 31 2016 OFFICE NRR/DORL/LPL4-2/PM NRR/DORL/LPL4-2/LA NRR/DE/EPNB/BC* NRR/DORL/LPL4-2/BC(A)

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