1CAN040803, Withdrawal of Relief Request ANO1-ISI-011

Withdrawal of Relief Request ANO1-ISI-011

ML081120125
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/18/2008
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN040803, TAC MD8018
Download: ML081120125 (3)

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 1CAN040803 April 18, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Withdrawal of Relief Request ANO1-ISI-011 Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

Entergy letter dated January 22, 2008, Request for Relief from ASME Section XI Table IWB-2500-1 Requirements (1CAN010801)

(TAC No. MD8018)

Dear Sir or Madam:

By the reference letter, Entergy Operations, Inc. (Entergy) requested approval of proposed alternatives to the requirements of the 1992 Edition of ASME Section XI for Arkansas Nuclear One, Unit 1 (ANO-1), specifically the requirements of Examination Category B-J of Table IWB-2500-1 (ANO1-ISI-011).

On September 22, 1999, 10CFR50.55a was revised mandating the implementation of the 1995 Edition, through and including the 1996 Addenda of ASME Section XI, Appendix VIII, Performance Demonstration for Ultrasonic Examination Systems. These requirements are now implemented, as applicable, in the in-service inspection program for ANO-1.

The subject relief request identified a statement in the 1995 Edition with the 1996 Addenda of ASME Section XI, Appendix VIII, Supplement 2 that could not be complied with, e.g., "...the specimen inside surface and identification shall be concealed from the candidate". The applicable technique for examining the reactor vessel nozzle-to-pipe and pipe-to-nozzle welds is remotely from the inside surface. The qualification for the piping welds required access to the ID of the pipe, therefore the inside surface cannot be "concealed". This was addressed in the later addenda (2002) of Section XI, however; this addenda has not been approved by the Staff via a change to 10CFR50.55a.

Code Case N-696, Qualification Requirements for Appendix VIII Piping Examinations Conducted from the Inside Surface,Section XI, Division 1, addresses this very issue. In

1CAN040803 Page 2 of 3 paragraph 39(b) of the code case, it states, The flaw location and specimen identification shall be obscured as to maintain a blind test. These are essentially the same words in the 2002 Addenda of Section XI, Appendix VIII, Supplement 2 as noted above.

At the time the request for alternative was made, the NRC had not approved Code Case N-696 in Regulatory Guide (RG) 1.147. The latest revision to RG 1.147, (Rev. 15) was issued by the NRC in late January 2008, which documents the NRC approval of Code Case N-696.

Based on the latest revision of the RG, Entergy hereby withdraws its request for the NRC approval of relief request ANO1-ISI-011.

The vendor procedures and personnel will be qualified for this application to the requirements of Code Case N-696. These requirements are identical to the requirements that were proposed in the subject relief request. This provides assurance that the piping welds are free of service related flaws and ensures plant safety and reliability.

This letter does not change any previous commitments.

If you have any questions or require additional information, please contact me.

Sincerely, DEJ/rwc

1CAN040803 Page 3 of 3 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