2CAN040904, Response to Requests for Additional Information for Relief Request VRR-ANO2-2008-1 Frequency of Leak Rate Testing of the Service Water Boundary Isolation Valves
| ML091210325 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/30/2009 |
| From: | David Bice Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN040904 | |
| Download: ML091210325 (6) | |
Text
2CAN040904 April 30, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Response to Requests for Additional Information for Relief Request VRR-ANO2-2008-1 Frequency of Leak Rate Testing of the Service Water Boundary Isolation Valves Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6
REFERENCES:
- 1. Entergy Letter to NRC dated August 21, 2008, Request for Relief VRR-ANO2-2008-1 Frequency of Leak Rate Test of the Service Water Boundary isolation Valves (2CAN080803)
- 2. Email from Alan Wang (NRC) to Robert W. Clark (Entergy), ANO-2 Request for Additional Information Regarding VRR-ANO2-2008-1 dated April 3, 2009
Dear Sir or Madam:
In Reference 1, Entergy Operations, Inc. (Entergy) proposed an alternative to the requirements of ASME/ANSI OMa-1988, Part 10 (OM-10), pertaining to the frequency of the leak rate test for two service water boundary isolation valves at Arkansas Nuclear One, Unit 2 (ANO-2). During the submittal review process, questions were raised by the Nuclear Regulatory Commission (NRC). The Requests for Additional Information (RAIs) were transmitted to ANO-2 on April 3, 2009, via email (Reference 2). The RAIs are associated with information concerning the time and cost to perform normal inspections and, with a sample size of two, the actions that are proposed to be taken to assess and verify the second valve is operable if the first valve fails to meet its acceptance criteria. The responses to RAIs are to be provided within 30 days of the email.
The attachment to this letter provides the response to the RAIs.
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One
2CAN040904 Page 2 of 2 This letter contains one new commitment, which is summarized in Attachment 2.
If you have any questions or require additional information, please contact me.
Sincerely, DBB/rwc Attachments 1.
Response to RAIs
- 2.
List of Regulatory Commitments cc:
Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 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
2CAN040904 Response to RAIs to 2CAN040904 Page 1 of 1 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION By letter dated August 21, 2008, Entergy submitted a request for alternative for Arkansas Nuclear One, Unit 2 (ANO-2) pertaining to the Inservice Testing Program. The proposed alternative is requested when using the requirements of ASME/ANSI OMa-1988, Part 10 (OM-10), pertaining to the frequency of the leak rate test for two service water boundary isolation valves at ANO-2. The NRC staff has reviewed the August 21, 2008, request and has determined that additional information is required to complete their review. Requests for Additional Information (RAIs) are listed below. The ANO-2 responses are listed directly after each RAI.
- 1. In addition to the hardship as described in the letter dated August 21, 2008, provide the cost, man-hours, total time for inspection, and radiation exposures for performing the Code required test.
In addition to the hardships discussed in the original relief request, it is estimated to take approximately 125 man-hours per valve to perform the Code required test. This is approximately $4400 per valve for the test. Each test takes approximately two (2) days to perform. To remove one loop of service water from service, the estimated dose consequence is less than 10 mrem.
- 2. Valves 2CV-1541-1 and 2CV-1560-2 are of the same type, experience the same operating conditions, and therefore, should experience the same failure mechanisms. If the tested valve fails to meets its acceptance criteria, discuss what measures or actions are proposed to assess and verify the operability of the other valve.
ANO-2 will perform a sample test plan similar to the plan described in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 1 for disassembly and inspection of check valves as an alternative to the test frequency required by the OM Code (Section 4.1.4). One of the two valves will be leak tested each refueling outage on a rotating basis. If problems are found with the sample valve that results in leakage in excess of the limiting value for operability described in the test procedure, both valves will be tested during the same outage to verify operability. These requirements are included as a commitment in Attachment 2 of this submittal.
to 2CAN040904 List of Regulatory Commitments to 2CAN040904 Page 1 of 1 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.
COMMITMENT TYPE (Check one)
SCHEDULED COMPLETION DATE ONE-TIME ACTION CONTINUING COMPLIANCE ANO-2 will perform a sample test plan similar to the plan described in NUREG-1482, Guidelines for Inservice Testing at Nuclear Power Plants, Revision 1 for disassembly and inspection of check valves as an alternative to the test frequency required by the OM Code (Section 4.1.4). One of the two valves will be leak tested each refueling outage on a rotating basis. If problems are found with the sample valve that results in leakage in excess of the limiting value for operability described in the test procedure, both valves will be tested during the same outage to verify operability.
9 Upon approval of relief request