2CAN010401, Arkansas, Unit 2 - License Renewal Application Clarifications
| ML040300229 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 01/22/2004 |
| From: | Cotton S Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN010401, TAC MB8402 | |
| Download: ML040300229 (10) | |
Text
EJ'nterl Entergy Operations, Inc.
,Entergy 1448 S.
R.
333 Russelville, AR 72802 Tel 501 858 5000 2CAN010401 January 22, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
License Renewal Application Clarifications TAC No. MB8402 Arkansas Nuclear One - Unit 2 Docket No. 50-368 License No. NPF-6
Dear Sir or Madam:
By letter dated October 14, 2003 (2CAN100302), Entergy submitted the Arkansas Nuclear One, Unit 2 (ANO-2) License Renewal Application (LRA). During the week of December 1, 2003, the NRC performed an on-site audit of the ANO-2 aging management programs. As a result of this audit, the following are clarifications to the LRA:
Audit item 2521: The cover letter that transmitted the ANO-2 LRA listed the programs contained in Appendix B as commitments. It did not define as commitments the programs and activities identified in Appendix A of the LRA, which
,-contains the ANO-2 Safety Analysis Report (SAR) supplement. As discussed during the on-site audit, Entergy agrees that the SAR supplement information contained in Appendix A is also a description of requirements associated with license renewal including requirements related to time-limited aging analyses. Once the license is renewed, the information in Appendix A is incorporated into the SAR.
Audit item 2528: The following will be added to note (a) of Table 5.2-12 as a part of the SAR update required upon issuance of the renewed license: The ANO-2 specimen capsule withdrawal schedule will be revised to withdraw and test a standby capsule to cover the peak fluence expected through the end of the period of extended operation.
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2CAN010401 Page 2 Audit item 2554: The exceptions to the Generic Aging Lessons Learned (NUREG-1801) table for "preventive actions" of the Diesel Fuel Monitoring Program described in Appendix B, Section B. 1.7 states, "No additives are used (other than biocide) beyond what the refiner adds during production." To clarify, biocide and stabilizers are added, but no corrosion inhibitors are used. A small amount of fluid is periodically drained from the bottom of the storage tanks to prevent water buildup and subsequent corrosion.
Audit item 2556: The high-voltage, low-current cables for the high range radiation monitors and excore detectors of the Environmental Qualification (EQ) of Electrical Components Program described in Appendix B, Section B. 1.8, are not subject to aging management review, since they are maintained within their qualified life under the ANO-2 EQ program. The ANO-2 EQ program includes the entire length of cable from the detector to the control room instrumentation; however, 1 OCFR50.49 only requires the cables in harsh environments to be included in the EQ program.
Entergy will continue to include these specific cables in the EQ program even though not required by IOCFR50.49.
Audit item 2570: The exceptions to NUREG-1 801 for "parameters monitored/inspected" of the Diesel Fuel Monitoring Program described in Appendix B, Section B.1.7, is being clarified as follows: For ANO-2, Entergy has chosen to apply the standards specified by American Society of Testing and Materials (ASTM) D1796. ASTM standards D1796 and D2709 address two different viscosity ranges with some overlap between them. The ANO-2 fuel oil viscosity lies in the overlap region; therefore, the use of either ASTM standard is acceptable.
Audit item 2571: Consistent with onsite program documentation, the Structures Monitoring Program described in Appendix B, Section B.1.27, manages the aging effects associated with cranes. Appendix B, Section B.0.6, Table B-1 for NUREG-1801 Section XI.M23 points to the Structures Monitoring Program by stating "See Structures Monitoring Programn. This was not intended to imply a one-to-one correlation and comparison between XI.M23 and the ANO-2 Structures Monitoring Program for managing aging effects associated with cranes. The Structures Monitoring Program is compared to NUREG-1801 program XI.S6.
NUREG-1801 program Xl.M23 identifies visual inspection as the method for detection of aging effects. This is the same method (i.e., visual inspection) used in the ANO-2 Structures Monitoring Program for managing aging effects associated with cranes. NUREG-1801 program XI.M23 also states that "functional tests are also performed to assure their (crane) integrity." Since functional tests are primarily associated with active components, visual inspection alone is adequate to ensure aging effects on passive components are managed. Therefore, use of the Structures Monitoring Program to manage aging effects associated with cranes is appropriate and consistent with previously approved aging management programs for cranes.
Audit item 2581: Detailed information was not provided in the Periodic Surveillance and Preventive Maintenance and Service Water Integrity Programs described in Appendix B, Sections B.1.18 and B.1.24, respectively, with respect to managing loss of material due to selective leaching. Specific details are not available at this time; however, prior to entering the period of extended operation, Entergy will
2CANO1 0401 Page 3 develop an enhancement to these programs. The enhancement will include the scope, method, and types of inspections or testing that will be performed to manage loss of material due to selective leaching. This method will consider accepted industry practices for managing loss of material due to selective leaching.
Audit item 2583: Ferritic stainless steel tubes in the shutdown cooling heat exchanger of the Heat Exchanger Monitoring Program described in Appendix B, Section B.1.12, will be monitored, where practical, using appropriate non-destructive examination (NDE) techniques such as eddy current testing with specific NDE processes suitable for ferritic stainless material. Although others are being developed and tested, one technique used in the industry is a modified version of eddy current called remote field testing (RFT). The selection of the RFT technique, or other appropriate examination techniques, will be based on industry experience available at the time of program implementation.
Audit item 2584: The acceptance criterion for the tube eddy current inspections of the Heat Exchanger Monitoring Program described in Appendix B, Section B.1.12, will be wall-loss less than 60% through-wall. This follows industry practice that considers 60% wall loss a conservative standard for requiring evaluation of the need for possible corrective action. The NRC found this acceptance criterion for eddy current testing of heat exchanger tubes reasonable in NUREG-1723, Section 3.2.10.3, because it is conservatively based on a combination of code requirements and industry practice.
Audit item 2588: The reference section provided for the ANO-2 program is Section B.1.13 in Appendix B, Table B-1, for NUREG-1801 Number XI.M3. The correct LRA section for the referenced ANO-2 program is Section B.1.14. An additional program, Bolting and Torquing Activities (Section B. 1.2), should also have been listed in the ANO-2 program column. The scope of the Inservice Inspection Program (Section B.1.14) includes reactor vessel bolting. In addition, the "Preventive Actions" section of Bolting and Torquing Activities (Section B. 1.2),
includes the use of proper lubricants on reactor vessel bolting to manage the aging effect of cracking.
Audit item 2595: Wall thickness will be the parameter monitored for the Wall Thinning Monitoring Program described in Appendix B, Section B. 1.29. The method of detection of the aging effects will be non-destructive examinations using industry-accepted methods, such as ultrasonic testing, to determine wall thickness of susceptible components.
In addition, during a phone conversation with the NRC Staff on December 16, 2003, the following responses were provided to draft requests for additional information (RAls):
Draft RAI 2.2-2: Tables 2.3.3-1 through 2.3.3-11 do not list certain components that are subject to an aging management review, such as reducers, enlargers, flanges, caps, test ports, and the like. Confirm if these components have been grouped in the tables as component type piping."
Response: Components that are subject to aging management review, such as reducers, enlargers, flanges, caps, and test ports, have been grouped in Tables
2CAN01 0401 Page 4 2.3.3-1 through 2.3.3-11 as component type piping' because they are made of the same materials, are exposed to the same environments, and experience the same aging effects.
Draft RAI 2.2-3: License renewal boundary drawings such as LRA-M-217, sheet I (location F7) and LRA-M-2217, sheet 1 (location G5), show twin basket and Y" strainers, respectively, within the scope of license renewal and subject to an aging management review. However, these components are not listed in the corresponding tables (Tables 2.3.3-1 through 2.3.3-11). Confirm if strainers are considered in the LRA as part of the component type "filter" and/or "filter housing."
Response: The license renewal drawings show twin basket strainers and Y" strainers as being subject to aging management review. The external strainer bodies are listed in the LRA tables as component type "filter housing," and the internal stainless steel elements are listed in the tables as component type "filter."
Draft RAI 2.2-4: Section 2.1.1 states that license renewal boundary drawings were prepared to indicate components subject to an aging management review.
However, the license renewal drawing legends indicate that the highlighted portions of the systems with flags represent the systems and components that are within the scope of license renewal. Components subject to an aging management review are listed in the tables of Section 2.3 for all the systems in scope. There appears to be an inconsistency between the drawing legend and the LRA statement. Please clarify which one is correct.
Response: Section 2.1.1 states, "License renewal drawings were prepared to indicate components subject to aging management review." This statement is correct. License renewal boundary flags and color highlighting are used to indicate the piping and components within the scope of license renewal that are subject to aging management review. The drawings are intended to be an aid used in conjunction with the tables in Section 2.0 of the LRA to "identify and list those structures and components subject to an aging management review" as required by 10 CFR 54.21(a)(1).
Scoping was performed at the system level. Systems and structures that perform intended functions are in scope as indicated in Tables 2.2-1 a, 2.2-1 b, and 2.2-3.
Systems and structures that are not within the scope of license renewal are listed in Tables 2.2-2 and 2.2-4. If a system is in scope, then all of the components in that system are conservatively considered within the scope of license renewal for the purpose of identifying components and structures that are subject to aging management review. Screening is then performed to determine which components are subject to aging management review. For screening in accordance with 10 CFR 54.21 (a)(1), structures and components subject to aging management review are those that perform an intended function without moving parts or a change in configuration or properties and that are not subject to replacement based on a qualified life or specified time period. The license renewal boundary on the drawings may be defined as the boundary between the portion of the system that performs an intended function (requires an aging management review) and the portion of the system that does not perform an intended function (does not require an aging management review).
2CAN010401 Page 5 Draft RAI 2.3.3.3-1: Does "valve" mean "valve body" for the pressure boundary intended function (also added as audit item 2612)?
Response: Throughout the ANO-2 LRA, when there is a reference to a "valve," it is referring to the "valve body" for the intended function of pressure boundary.
However, in a couple of instances, e.g., Tables 2.3.3-4 and 3.3.2-4 for the alternate AC diesel generator system, flow control is incorrectly listed as an intended function for a valve in addition to pressure boundary. The flow control function for these valves is performed by the internals of the valve, which are active components not subject to aging management review. Flow control is not an intended function for valves.
Entergy is also providing the following two corrections to the LRA:
A reference to EPRI TR-104213, "Bolted Joint Maintenance and Applications Guide," was inadvertently included in Section A.2.1.2 of Appendix A. This reference will be removed from the text to be included in the SAR because this level of detail is considered inappropriate for inclusion into the SAR.
A reference to EPRI TR-1 07396, "Closed Cooling Water Chemistry Guidelines," was inadvertently included in Section A.2.1.32 of Appendix A. This reference will be removed from the text to be included in the SAR because this level of detail is considered inappropriate for inclusion into the SAR.
New commitments contained in this submittal are summarized in the attachment. Should you have any questions concerning this submittal, please contact Ms. Natalie Mosher at (479) 858-4635.
I declare under penalty of perjury that the foregoing is true and correct. Executed on January 22, 2004.
Sincerely, Sherrie R. Cotton Director, Nuclear Safety Assurance SRC/nbm Attachment
2CAN010401 Page 6 cc:
Dr. Bruce S. Mallett 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. Thomas Alexion Mail Stop 0-7 D1 Washington, DC 20555-0001 U. S. Nuclear Regulatory Commission Attn: Mr. Greg Suber Mail Stop 0-11 F1 Washington, DC 20555-0001 Mr. Bernard R. Bevill Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867
Attachment to 2CAN010401 List of Regulatory Commitments
Attachment to 2CAN01 0401 Page 1 of 3 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Check One SCHEDULED ONE-
)
COMPLETION TIME CONTINUING DATE COMMITMENT ACTION COMPLIANCE (If Required)
The following will be added to note (a) of X
Upon issuance of Table 5.2-12 as a part of the SAR renewed license update required upon issuance of the renewed license: The ANO-2 specimen capsule withdrawal schedule will be revised to withdraw and test a standby capsule to cover the peak fluence expected through the end of the period of extended operation.
The high-voltage, low-current cables for X
July 17, 2018 the high range radiation monitors and excore detectors of the Environmental Qualification (EQ) of Electrical Components Program described in Appendix B, Section B.1.8, are not subject to aging management review, since they are maintained within their qualified life under the ANO-2 EQ program. The ANO-2 EQ program includes the entire length of cable from the detector to the control room instrumentation; however, 10CFR50.49 only requires the cables in harsh environments to be included in the EQ program. Entergy will continue to include these specific cables in the EQ program even though not required by 1 OCFR50.49.
Attachment to 2CAN010401 Page 2 of 3 Detailed information was not provided in the Periodic Surveillance and Preventive Maintenance and Service Water Integrity Programs described in Appendix B, Sections B.1.18 and B. 1.24, respectively, with respect to managing loss of material due to selective leaching. Specific details are not available at this time; however, prior to entering the period of extended operation, Entergy will develop an enhancement to these programs. The enhancement will include the scope, method, and types of inspections or testing that will be performed to manage loss of material due to selective leaching. This method will consider accepted industry practices for managing loss of material due to selective leaching.
X July 17, 2018 Ferritic stainless steel tubes in the X
July 17, 2018 shutdown cooling heat exchanger of the Heat Exchanger Monitoring Program described in Appendix B, Section B.1.12, will be monitored, where practical, using appropriate non-destructive examination (NDE) techniques such as eddy current testing with specific NDE processes suitable for ferritic stainless material.
The acceptance criterion for the tube X
July 17, 2018 eddy current inspections of the Heat Exchanger Monitoring Program described in Appendix B, Section B.1.12, will be wall-loss less than 60%
through-wall.
Wall thickness will be the parameter X
July 17, 2018 monitored for the Wall Thinning Monitoring Program described in Appendix B, Section B.1.29. The method of detection of the aging effects will be non-destructive examinations using industry-accepted methods, such as ultrasonic testing, to determine wall thickness of susceptible components.
Attachment to 2CAN01 0401 Page 3 of 3 A reference to EPRI TR-104213, "Bolted X
Upon issuance of Joint Maintenance and Applications renewed license Guide," was inadvertently included in Section A.2. 1.2 of Appendix A. This reference will be removed from the text to be included in the SAR because this level of detail is considered inappropriate for inclusion into the SAR.
A reference to EPRI TR-107396, X
Upon issuance of "Closed Cooling Water Chemistry renewed license Guidelines," was inadvertently included in Section A.2.1.32 of Appendix A. This reference will be removed from the text to be included in the SAR because this level of detail is considered inappropriate for inclusion into the SAR.