2CAN021905, Supplement to Request for Alternative ANO2-ISI-021
| ML19058A252 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 02/27/2019 |
| From: | Arnold T Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN021905 | |
| Download: ML19058A252 (7) | |
Text
2CAN021905 February 27, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
Supplement to Request for Alternative ANO2-ISI-021 Arkansas Nuclear One, Unit 2 Docket No. 50-368 Renewed Facility Operating License No. NPF-6
REFERENCE:
Entergy Letter dated September 6, 2018, Request for Alternative ANO2-ISI-021 to Permit Continued Application of the 2007 Edition through the 2008 Addenda of American Society of Mechanical Engineers (ASME)
Section XI Requirements, Arkansas Nuclear One, Unit 2 (2CAN091802)
Dear Sir or Madam:
By letter dated September 6, 2018 (Reference), Entergy Operations, Inc. (Entergy), requested an alternative for Arkansas Nuclear One, Unit 2 (ANO-2) during the fifth 10-year in-service inspection (ISI) interval. Specifically, Entergy requested that the Editions and Addenda of ASME Section XI for the fifth ISI interval be established consistent with other southern Entergy commercial nuclear power facilities.
Entergy also stated an intent to update Repair/Replacement, Pressure Test, and Nondestructive Examination (NDE) programs to the latest Edition of ASME Section XI approved by the NRC effective on or about November 30, 2026, with the corresponding conditions of 10 CFR 50.55a(b)(2) to coincide with the other Entergy south sites. Entergy is supplementing the subject request for alternative to clarify that the intent to perform the aforementioned update is not a request for NRC approval. Subsequently, Entergy has removed information that could be characterized as a request for approval with respect to the above programs. For ease of review, the attachment (Request for Alternative - ANO2-ISI-021) of the referenced original letter is being resubmitted in full, absent the aforementioned information which was removed.
Request for Alternative - ANO2-ISI-021 is included in attachment to this letter.
No new regulatory commitments are included in this response.
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-7826 Timothy L. Arnold Manager, Regulatory Assurance Arkansas Nuclear One
2CAN021905 Page 2 of 2 If there are any questions or if additional information is needed, please contact me.
Sincerely, ORIGINAL SIGNED BY TIMOTHY L. ARNOLD TLA/dbb
Attachment:
Request for Alternative - ANO2-ISI-021 cc:
Mr. Scott A. Morris 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. Thomas Wengert MS O-08B1A One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 72205
Attachment to 2CAN021905 REQUEST FOR ALTERNATIVE - ANO2-ISI-021
Attachment to 2CAN021905 Page 1 of 4 REQUEST FOR ALTERNATIVE ANO2-ISI-021 Code Classes:
ASME Section XI, Classes 1, 2, 3, MC, and CC
References:
ASME Section XI, 2007 Edition with 2008 Addenda ASME Section XI, 2013 Edition Examination Category: All Item Number(s):
All Components:
All within the ASME Section XI Boundaries including IWE and IWL Unit / Inspection Interval Applicability:
Arkansas Nuclear One, Unit 2 (ANO-2) / Fifth (5th) 10-Year Interval I.
CODE REQUIREMENTS Entergy Operations, Inc. (Entergy) is required to update the ANO-2 120-month Inservice Inspection (ISI) Program to the latest Edition and Addenda of the ASME B&PV Code,Section XI, approved by the NRC in 10 CFR 50.55a(a), for the 5th interval.
10 CFR 50.55a(g)(4)(ii) states:
Inservice examination of components and system pressure tests conducted during successive 120-month inspection intervals must comply with the requirements of the latest edition and addenda of the ASME Code incorporated by reference in paragraph (a) of this section 12 months before the start of the 120-month inspection interval (or the optional ASME Code Cases listed in NRC Regulatory Guide 1.147, when using ASME BPV Code,Section XI, or NRC Regulatory Guide 1.192, when using the ASME OM Code, as incorporated by reference in paragraphs (a)(3)(ii) and (iii) of this section), subject to the conditions listed in paragraph (b) of this section. However, a licensee whose inservice inspection interval commences during the 12 through 18-month period after August 17, 2017, may delay the update of their Appendix VIII program by up to 18 months after August 17, 2017. Alternatively, licensees may, at any time in their 120-month ISI interval, elect to use the Appendix VIII in the latest edition and addenda of the ASME BPV Code incorporated by reference in paragraph (a) of this section, subject to any applicable conditions listed in paragraph (b) of this section. Licensees using this option must also use the same Edition and Addenda of Appendix I as Appendix VIII, including any applicable conditions listed in paragraph (b) of this section.
In accordance with 10 CFR 50.55a(a)(1)(ii)(C)(53), the 2013 Edition of ASME Section XI is the latest NRC-approved version with the exception that IWB-3112(a)(3) and IWC-3112(a)(3) are not approved for use and may not be used.
Attachment to 2CAN021905 Page 2 of 4 II.
PROPOSED ALTERNATIVE The ANO-2 5th ISI Interval is scheduled to begin on or about1 March 26, 2020 and end on or about March 25, 2030. Based on the requirements of 10 CFR 50.55a(g)(4)(ii), ANO-2 would be required to update the 5th ISI Interval to meet the 2013 Edition of ASME Section XI, or later, if changes to 10 CFR 50.55a(a) are made prior to March 26, 2019, which approve a later Edition of ASME Section XI.
Pursuant to 10 CFR 50.55a(a)(z)(1), Entergy requests authorization to utilize the alternative requirements in the 2007 Edition through the 2008 Addenda of ASME Section XI, except for Subsubarticle IWA-2430, which ANO-2 will update to the 2013 Edition. The use of ASME Section XI 2007 Edition with the 2008 addenda and Subsubarticle IWA-2430 of the 2013 Edition will be used subject to the conditions contained in 10 CFR 55.55a(b)(2). Code Cases applicable to other than Subsubarticle IWA-2430 may also be adopted per Regulatory Guide (RG) 1.147 for those cases applicable to the 2007 Edition through the 2008 Addenda. In accordance with RG 1.147, Code Cases applicable to Subsubarticle IWA-2430 may be adopted for those cases applicable to the 2013 Edition.
III.
BASIS FOR PROPOSED ALTERNATIVE ASME Section XI activities (e.g., ISI, repair/replacement, pressure testing, and NDE) at Arkansas Nuclear One, Unit 1 (ANO-1), ANO-2, Grand Gulf Nuclear Station (GGNS), River Bend Station (RBS), and Waterford 3 (W3) are standardized and are intended to be corporately administered by Entergy.
On May 31, 2017, ANO-1, and on November 30, 2017, GGNS, RBS, and W3, updated the respective ISI programs to the 2007 Edition through the 2008 Addenda of Section XI in accordance with the requirements of 10 CFR 50.55a(g)(4)(ii). Under the provisions of Request for Alternative EN-ISI-16-1[2], ANO-2 was approved to use ASME Section XI, 2007 Edition through the 2008 Addenda for the performance of NDE, pressure testing and repair/replacement activities commencing on December 1, 2017, through the end of the current 4th ISI Interval in order to allow continued use of common Entergy procedures, processes, training, knowledge, and technical skills. This provision was limited to the remainder of the 4th ISI Interval and does not apply to the 5th ISI Interval.
Because of the difference in interval start dates for ANO-2 and the other four Entergy sites and the expiration of Request for Alternative EN-ISI-16, ANO-2 would be required to develop and maintain a separate and unique ISI program (including NDE, pressure testing, and repair/replacement) with unique supporting procedures affecting multiple organizations.
Additionally, ANO-2 would be required to create a unique skill set with unique training applicable to ANO-2 only. The aforementioned requirements minimize the potential for using shared resources of other Entergy sites, present human factors concerns when applying different criteria to the ANO units, and prevent the use of common site and fleet procedures.
1 The use of the term on or about is in reference to the interval or period adjustments permitted by IWA-2430.
Attachment to 2CAN021905 Page 3 of 4 Although many changes occurred in ASME Section XI between the 2007 Edition through the 2008 Addenda and the 2013 Edition, both editions continue to ensure an acceptable level of quality and safety. In addition, the changes were not incorporated in order to address a deficiency in the Code that adversely impacted safety. Note that the Augmented ISI requirements in 10 CFR 50.55a(g)(6)(ii) that have been deemed by the NRC as necessary to provide added assurance of structural reliability will continue to be met.
Entergy believes that continued application of the ANO-2 ISI Program which is based on the 2007 Edition through the 2008 Addenda of ASME Section XI (consistent with the other Entergy south plants) will enhance the effective management and implementation of the ASME Section XI programs at ANO-2 and the other sites. Approval of this request supports Entergys ability to maximize efficiencies and optimizes the use of internal operating experience because five units will be utilizing common procedures, processes, training, and knowledge.
The requested alternative does not apply to Subsubarticle of IWA-2430, i.e., the ANO-2 ISI program will be updated to the 2013 Edition for this Subsubarticle. By excluding Subsubarticle IWA-2430 from the proposed alternative, ANO-2 may use the provisions in the 2013 Edition that permits the Owner to reduce the interval and period without restrictions (no longer limited to one year) provided all examinations and tests required by the interval and period have been completed. With this provision, ANO-2 may shorten the 5th ISI interval to conclude on or about November 30, 2027, in order to align the interval with the other Entergy south sites, thus precluding the need for future relief.
IV.
DURATION OF THE PROPOSED INTERVAL This request for alternative is applicable to the ANO-2 Fifth 10-Year ISI Interval which begins on or about March 26, 2020, and is currently scheduled to end on March 25, 2030.
V.
PRECEDENT Similar requests for alternative affecting the ISI program have been submitted to and approved by the NRC as noted below:
- 1.
NRC SER dated April 26, 2010, Arkansas Nuclear One, Unit 2 Request for Relief ANO2-ISI-003, Alternative to Use 2001 Edition Through 2003 Addenda in Lieu of the 2004 Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel code,Section XI (TAC No. ME 1452) (2CNA041001) (ML100970659)
- 2.
NRC SER dated July 12, 2017, Arkansas Nuclear One, Unit 2 and Indian Point Nuclear Generating Station, Unit No. 3 - Relief Request EN-ISI-16-1 Regarding Use of Later Edition and Addenda of the ASME Code (CAC Nos. MF8905 and MF8906)
(2CNA071701) (ML17174B144)
Attachment to 2CAN021905 Page 4 of 4 V.
CONCLUSION 10 CFR 50.55a(a)(z), Alternatives to codes and standards requirements, states:
Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:
(z)(1)
Acceptable level of quality and safety. The proposed alternatives would provide an acceptable level of quality and safety; or (z)(2)
Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
As discussed in Section III above, the proposed alternative for continued application of the 2007 Edition through the 2008 Addenda of the ASME Section XI requirements, including the conditions of 10 CFR 50.55a(b)(2) and the augmented ISI requirements of 10 CFR 50.55a(g)(6)(ii) to the ANO-2 ISI Program provides an acceptable level of quality and safety by meeting ASME Section XI requirements approved by the NRC and which are in use by much of the commercial nuclear industry.
Based on the above, Entergy requests authorization to perform the requested alternative pursuant to 10 CFR 50.55a(z)(1).