1CAN030804, Revised Relief Request for 10 Year Update to the 120 Month Inservice Testing Interval, Arkansas Nuclear One, Unit 1

Revised Relief Request for 10 Year Update to the 120 Month Inservice Testing Interval, Arkansas Nuclear One, Unit 1

ML080730500
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	03/13/2008
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN030804, PRR-ANO1-2007-1
Download: ML080730500 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4619 Dale E. James Manager, Licensing Nuclear Safety Assurance Arkansas Nuclear One 1CAN030804 March 13, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Revised Relief Request for 10 Year Update To the 120 Month Inservice Testing Interval Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

Entergy Letter to the NRC dated November 29, 2007, Relief Requests for 10 Year Updates to the 120 Month Inservice Testing intervals

Dear Sir or Madam:

In the reference letter, Entergy Operations, Inc. (Entergy) requested alternatives for the Inservice Testing Program at Arkansas Nuclear One - Unit 1 (ANO-1), Grand Gulf Nuclear Station, River Bend Station and Waterford Steam Electric Station, Unit 3. These requests are needed to support the 120 month updates for the upcoming intervals.

The reference letter included a request for relief from certain requirements of the ASME OM Code 2001 Edition with addenda through OMb Code-2003 Addenda for the next ANO-1 IST interval (PRR-ANO1-2007-1). Table ISTB-5121-1, referenced in the original relief request, is from the 2004 Edition of the ASME code. The table that should have been referenced is ISTB-5200-1 in the 2001 Edition of the ASME code.

Both tables contain exactly the same criteria for establishing a vibration acceptance criterion.

Therefore there are no technical consequences due to this error. Minor editorial changes are also made to the relief request while correcting the table reference.

The revised relief request is attached.

This revised relief request contains no new commitments.

1CAN030804 Page 2 of 2 If you have any questions or require additional information, please contact Bob Clark at 479-858-4663.

Sincerely, DEJ/rwc

Attachment:

1. Request for Relief PRR-ANO1-2007-1 cc: Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Alan B. Wang MS O-7 D1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health & Human Services P.O. Box 1437 Slot H-30 Little Rock, AR 72203-1437

ATTACHMENT 1 1CAN030804 Request for Relief PRR-ANO1-2007-1 to 1CAN030804 Page 1 of 4 10 CFR 50.55a Request Number PRR-ANO1-2007-1 Proposed Alternative in Accordance with 10 CFR 50.55a(a)(3)(ii) 10 CFR 50.55a Request

Title:

P-4A, P-4B, P-4C Alternative Request PLANT/UNIT: Arkansas Nuclear One Unit 1 INTERVAL: Fourth 120 Month Inservice Testing Interval COMPONENTS Pumps: P-4A, P-4B, P-4C AFFECTED:

System: Service Water Under emergency conditions these vertical line-shaft pumps provide an assured source of cooling water and the ultimate heat sink to various safety related and safe shutdown components. In addition, they provide cooling water to non-safety related plant components during normal plant operation.

CODE EDITION AND ASME OM Code-2001 Edition with addenda through OMb Code-2003 ADDENDA: Addenda REQUIREMENTS: ISTB-5221 and ISTB-5223 "Group A and Comprehensive tests shall be conducted with the pump operating at a specified reference point. The test parameters shown in Table ISTB-3000-1 shall be determined and recorded as required by this paragraph."

REASON FOR Pursuant to 10 CFR 50.55a, Codes and Standards, paragraph RELIEF REQUEST: (a)(3)(ii), an alternative is requested when using the requirements of ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda (as listed above).

The service water system provides a continuous supply of cooling water to the two safety-related (essential) service water headers as well as the non-essential header related to main turbine generator and other plant support auxiliaries. During normal plant operation at power the heat removal demands of the service water system require the operation of at least two and frequently three pumps. After the to 1CAN030804 Page 2 of 4 10 CFR 50.55a Request Number PRR-ANO1-2007-1 system operation reaches a degree of stability, perturbation of flow to any of the on-line heat exchangers could have a severe adverse impact on plant operation with the potential for unacceptable flow and temperature transients. This situation precludes flow adjustments on specific heat loads and certainly throttling of pump or header isolation valves. As such, returning the system operating parameters to a prescribed unique reference value (either flow or differential pressure) is impractical and could result in an unreasonable and unwarranted risk to plant operation with little or no apparent gain in plant safety or reliability.

This alternative is a re-submittal of NRC approved Third Interval Relief Request-6 that was based on the ASME OM Code 1987 Edition with addenda through OMa-1988. This Fourth Interval alternative request is based on the ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda. The proposed relief is in accordance with Code Case OMN-16. The only substantive change to this alternative versus Relief Request-6 is the requirement to have at least one data point for each 20% of the maximum pump curve range. This change would not alter the previous NRC Safety Evaluation conclusions.

PROPOSED Following maintenance activities and when the pump is known to be ALTERNATIVE AND operating acceptably the reference curve will be either reconfirmed or BASIS: a new curve created as follows:

a. The subject flow rate will be varied over a specified range with the pump operating at or near its design basis flow rate.

Per SAR Table 9-8 a service water pump design capacity is 6500 gpm. This specified range, approximately 4000 gpm to 7500 gpm, will be beyond the theoretical "flat" portion of the pump performance curve.

b. For at least five (5) points over the test range, corresponding differential pressure and flow rate measurements will be recorded after flow stability is achieved at each point (minimum 2 minutes run time). The points will include at least one point below 5200 gpm, one point between 5200 gpm to 6500 gpm, and one point greater than 6500 gpm.

Instruments used for obtaining pump performance data will satisfy the accuracy and range requirements as set fourth in ISTB-3500.

to 1CAN030804 Page 3 of 4 10 CFR 50.55a Request Number PRR-ANO1-2007-1

c. The recorded curve data will be plotted graphically or electronically and an equivalent pump curve will be derived.

Individual acceptance criteria will be developed for each pump as follows:

a. For the Type A test, an acceptable range of operation will be established when pump differential pressure, corresponding to a specific flow rate, deviates by no more than 0.95 times the reference value for the lower limit and 1.10 times the reference value for the upper limit. For the Comprehensive test, an acceptable range of operation will be established when pump differential pressure, corresponding to a specific flow rate, deviates by no more than 0.95 times the reference value for the lower limit and 1.03 times the reference value for the upper limit.

b. For the Type A test and the Comprehensive test, an alert range of operation will be established when pump differential pressure, corresponding to a specific flow rate, falls between 0.95 times the reference value to 0.93 times the reference value.

c. Each of the pump's acceptance criteria curves shall be compared to the applicable and corresponding requirements for these pumps as set fourth in the ANO-1 Technical Specifications, Safety Evaluation Report, and Safety Analysis Report. This review will ensure that a pump cannot be declared operable if it is operating outside the requirements of any of these documents.

d. In the event that a pump's operational parameters fall outside of these stated ranges (Type A test: 0.93 times the reference value for the lower range and 1.1 times the reference value for the upper range) or greater than 1.03 times the reference value for the Comprehensive test in what is know as the "required action range", appropriate corrective actions will be implemented in accordance with ISTB-6200 (b).

e. The acceptance criteria for pump/motor vibration will be derived from Table ISTB-5200-1 based on reference values measured during typical pump operation, e.g., between approximately 4000 gpm and 7500 gpm. A curve of vibration levels versus flow rate is not required to be developed since to 1CAN030804 Page 4 of 4 10 CFR 50.55a Request Number PRR-ANO1-2007-1 vibration levels are essentially the same over the flow rates of interest.

Each of these pumps will be Type A and Comprehensive tested as follows: With the subject pump operating at a condition based on system demands, measurements for pump flow rate, differential pressure, and vibration will be recorded. Should any of the pump's operating points fall outside the plotted areas of acceptability, the appropriate corrective action as prescribed in ISTB-6200 will be applied.

Based on the determination that compliance with the ASME OM Code-2001 Edition with addenda through OMb Code-2003 Addenda requirements results in a hardship without a compensating increase in the level of quality or safety, this proposed alternative should be granted pursuant to 10 CFR 50.55a(a)(3)(ii).

DURATION: Arkansas Nuclear One Unit 1s Fourth 120-month Inservice Testing Interval (December 2, 2007 through December 1, 2017 based on TAC No. MA0275).

PRECEDENTS: Use of an alternative for similar requirements was previously granted for Arkansas Nuclear One Unit 1s Third 120-month Inservice Testing Interval (TAC No. MA0275).

REFERENCES:

TAC No. MA0275 related correspondences: September 26, 2000 (NRC); October 29, 1999 (EOI); October 9, 1998 (NRC); December 1, 1997 (EOI)

STATUS: Submitted for Nuclear Regulatory Commission review and approval by CNRO-2007-00042.