1CAN051402, Arkansas, Unit 1, Notification of Revised License Renewal Commitments

Arkansas, Unit 1, Notification of Revised License Renewal Commitments

ML14139A469
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/2014
From:	Jeremy G. Browning Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN051402
Download: ML14139A469 (7)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Jeremy G. Browning Site Vice President Arkansas Nuclear One 1CAN051402 May 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Notification of Revised License Renewal Commitments Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

NRC letter to Entergy, Issuance of Renewed Facility Operating License, No. DPR-51, dated June 20, 2001 (ML011720024) (1CNA060101)

Dear Sir or Madam:

The purpose of this letter is to inform the NRC that Entergy Operations, Inc. is revising some of the commitments related to the above reference for Arkansas Nuclear One, Unit 1 (ANO-1). A discussion of the revised commitments is provided in Attachment 1.

This letter contains revised regulatory commitments, which are identified in Attachment 2.

Should you have any questions concerning this submittal, please contact Stephenie Pyle at 479.858.4704.

Sincerely, Original signed by Jeremy G. Browning JGB/nbm Attachments: 1. ANO-1 Revised License Renewal Commitments

2. List of Regulatory Commitments

1CAN051402 Page 2 of 2 cc: Mr. Marc L. Dapas Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Peter Bamford MS O-8B3 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment 1 to 1CAN051402 Arkansas Nuclear One, Unit 1 (ANO-1)

Revised License Renewal Commitments to 1CAN051402 Page 1 of 2 ANO-1 Revised License Renewal Commitments Commitment 17847 - Volumetric radiographic testing (RT) examination of the reactor building sump Penetration 68 (P-68) piping valves CV-4400 and CV-4446 (ANO-1 License Renewal Application (LRA) (1CAN010003), Appendix B, Section 4.3.7, Modify and Maintain Augmented Inspections Program) is revised to clarify the type of examination being performed as ultrasonic testing (UT). This commitment change was previously provided in correspondence dated January 30, 2014 (1CAN011405), and the revised justification follows:

Justification: The scope of the augmented examination related to this penetration remains unchanged. The change in the commitment is due to the type of examination to be performed.

The original commitment was to perform RT. The change is to perform UT examinations on the components at frequency as defined in the program documents.

The aging effect of loss of material and cracking determined a more appropriate examination process and the specific component to be examined, i.e., the valve itself or the piping and/or weld(s) to the valve. RT of valves CV-4400 and CV-4446 could give some indication of wall loss and internal configuration, but would not be effective to detect cracking. The attached pipe is much thinner than the valve, and the aging effects of corrosion and cracking would be manifested earlier in the thinner piping.

Commitment 17848 - New Pressurizer Examinations Program (ANO-1 LRA Appendix B, Section 3.4) for the inspection of the exterior portions of the pressurizer heater bundle is being corrected from a visual test (VT)-1 to a VT-2.

Justification: A typographical error was included in the ANO-1 LRA, Appendix B, Section 3.4.2, Pressurizer Heater Bundle Penetration Welds Examination. The LRA stated in-part, In addition, ANO-1 inspects the exterior portions of the heater bundle each outage in accordance with Examination Category B-P of American Society of Mechanical Engineers (ASME)

Section XI. In accordance with IWA-5242 as modified by Code Case N-533 for bolted connections, ANO-1 will remove the insulation surrounding the penetrations and perform a VT-1 inspection. The inspection method for the exterior portions of the pressurizer heater bundles was incorrectly stated in the LRA as VT-1. The inspection method is VT-2 in accordance with ASME Section XI, Table 2500-1 Examination Category B-P, and IWA-5242 as modified by Code Case N-533 for bolted connections.

Commitment 19358 - Performance of a one-time visual inspection of a reactor coolant pump (RCP) cover prior to the period of extended operation (PEO) (ANO-1 LRA, Appendix B, Section 4.3.7, ASME Section XI Augmented Inspections Program) is being revised to credit the results of a pump cover inspection performed for a Davis-Besse RCP in 2002 supplemented with water chemistry data and flaw tolerance evaluations.

Justification: ANO-1 originally committed to perform a one-time visual inspection of the pressure retaining surfaces of one RCP (i.e., pump casing and pump cover) prior to the period of extended operation. In refueling outage 1R22 (Spring 2010) the P-32C RCP rotating to 1CAN051402 Page 2 of 2 assembly and pump cover were replaced providing an opportunity for an inspection of the RCP cover. A visual inspection was performed on the pump casing, but the pump cover was not inspected because of high radiation exposure concerns (1.6 R/hr on contact). In lieu of a direct inspection, an alternate method to confirm the absence of aging effects of concern for the RCP cover was performed. This alternate method involved crediting examination of an identical RCP cover as well as evaluation of water chemistry data and a flaw tolerance evaluation. The results of these evaluations are discussed below.

The pump cover and thermal barrier region for a Davis-Besse RCP were inspected in 2002 with no findings or indications of concern observed. The pump cover was found suitable for reuse and is currently back in service at Davis-Besse. The pump covers for ANO-1 and Davis-Besse are both SA-351 Grade CF8M cast austenitic stainless steel and the RCPs are identical in design. The operating environment experienced by the pump covers at ANO-1 and Davis-Besse are very similar with the exception of specific parameter monitoring of the water chemistry for the closed cooling water system used to cool the RCP heat exchangers. A 150 ppb limit is imposed for chlorides and fluorides at Davis-Besse whereas the concentrations in the closed cooling water system for ANO-1 are not currently monitored and could have been above the threshold for stress corrosion cracking. As a result of this difference in operating environment, additional evaluations were performed as follows:

• An evaluation performed by Structural Integrity Associates of the water chemistry data for the closed cooling water system at ANO-1 concluded that stress corrosion cracking of the pump cover is not a concern.

• The results of a flaw tolerance evaluation performed by Structural Integrity Associates demonstrate that even in the very unlikely event that a flaw is initiated, the RCP cover can operate safely without the necessity of inspection for 88 years. These results supplement the conclusions of the water chemistry data evaluation, which concluded that stress corrosion cracking of the RCP cover is not a concern and, hence, not likely to initiate a flaw during the lifetime of the component.

The results of the evaluations discussed above provide the necessary evidence that the aging effects of concern for the RCP cover are not occurring at ANO-1 and that the RCP cover can perform its intended function during the PEO. Lastly it should also be noted that three of the four original ANO-1 RCP covers have been replaced as of 1R22 (Spring 2010), and the only remaining original pump cover (RCP P-32B) is tentatively scheduled for replacement in the Fall 2019 refueling outage(1R28).

Attachment 2 to 1CAN051402 List of Regulatory Commitments to 1CAN051402 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy Operations, Inc. in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED (Check One) COMPLETION COMMITMENT DATE ONE-TIME CONTINUING (If Required)

ACTION COMPLIANCE Commitment 17847 - Volumetric radiographic testing examination of the reactor building sump Penetration 68 (P-68) piping valves CV-4400 and CV-4446 (Arkansas Nuclear One, Unit 1 (ANO-1) License Renewal Application X May 20, 2014 (LRA), Appendix B, Section 4.3.7, Modify and Maintain Augmented Inspection Program) is revised to clarify the type of examination being performed as ultrasonic testing.

Commitment 17848 - New Pressurizer Examinations Program (ANO-1 LRA Appendix B, Section 3.4) for the inspection of the exterior portions of the X May 20, 2014 pressurizer heater bundle is being corrected from a visual testing (VT)-1 to a VT-2.

Commitment 19358 - Performance of a one-time visual inspection of a reactor coolant pump (RCP) cover prior to the period of extended operation (ANO-1 LRA, Appendix B, Section 4.3.7, American Society of Mechanical EngineersSection XI Augmented X May 20, 2014 Inspections Program) is being revised to credit the results of a pump cover inspection performed for a Davis-Besse RCP in 2002 supplemented with water chemistry data and flaw tolerance evaluations.