2CAN060902, Request for Alternative to Use 2001 Edition Through 2003 Addenda in Lieu of the 2004 Edition
| ML091600248 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/08/2009 |
| From: | David Bice Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN060902 | |
| Download: ML091600248 (7) | |
Text
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One 2CAN060902 June 8, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Request for Alternative to Use 2001 Edition Through 2003 Addenda In Lieu of the 2004 Edition Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6
Dear Sir or Madam:
Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy Operations, Inc. (Entergy) requests an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii) pertaining to the 10-year update of the Arkansas Nuclear One, Unit 2 (ANO-2) Inservice Inspection (ISI) program to the 2004 Edition of the American Society of Mechanical Engineers (ASME), Boiler and Pressure Vessel Code,Section XI.
ASME Section XI activities (e.g., ISI, repair/replacement, pressure testing, and Non-Destructive Examination (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 corporately administered by Entergy.
On May 31, 2008, ANO-1, GGNS, RBS, and W3 ISI programs were updated to the 2001 Edition through the 2003 Addenda of Section XI in accordance with the 10-year update requirements of 10 CFR 50.55a(g)(4)(ii). Also, to comply with the NRC restriction in paragraph (xxiv) of 10 CFR 50.55a(b)(2), performance demonstration of ultrasonic examinations in accordance with the 2001 Edition (no addenda) of Appendix VIII was incorporated into the programs. The repair/replacement, pressure testing, and NDE programs for these units were updated to the 2001 Edition through the 2003 Addenda of the Code as well.
To maintain standardization of the Entergy southern units, concurrent with the updates at the other Entergy plants, Entergy updated the ANO-2 repair/replacements, pressure testing, and NDE programs as approved by NRC Safety Evaluation Report dated December 20, 2007, to the 2001 Edition through the 2003 Addenda of the Code. It should be noted that the ANO-2 ISI Program was not updated at that time.
2CAN060902 Page 2 of 3 The start date of the next 10-Year ISI interval for ANO-2 is March 26, 2010. Entergy is beginning the task of updating the ANO-2 ISI Program. As part of the process of updating the ANO-2 ISI Program, an inspection plan must be developed. Entergy ISI and NDE Personnel assist one another in the planning, performance, reporting, and assessing of ISI activities at all of the southern fleet. Until May 31, 2008, this had been one standard process at the Entergy southern plants since 2000. With the approval of this request, all the Entergy south units ISI programs will be based on the same version of the ASME Code (2001 Edition with the 2003 Addenda), which will allow Entergy to return to one standard process. Entergy believes this standard process improves the quality of the ISI programs at each of the units.
Additional information and justification is in the attached request for alternative. This submittal contains no new commitments.
If you have any questions or require additional information, please contact me.
Sincerely, DBB/rwc
Attachment:
Request for Relief ANO2-ISI-003
2CAN060902 Page 3 of 3 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
Attachment to 2CAN060902 Request for Relief ANO2-ISI-003
Attachment to 2CAN060902 Page 1 of 3 REQUEST FOR RELIEF ANO2-ISI-003 Code Classes: American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3
References:
ASME Section XI, 2001 Edition with 2003 Addenda ASME Section XI, 2004 Edition Examination Category: Various Item Number(s) Various
==
Description:==
Alternative Requirements for Update of the Fourth Interval ISI Program to an Earlier Edition of ASME Boiler and Pressure Vessel (B&PV) Code,Section XI.
Unit / Inspection Interval Arkansas Nuclear One, Unit 2 (ANO-2)/Fourth (4th) 10-Year Applicability: Interval I. CODE REQUIREMENTS 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(b)(2), for the fourth interval.
10 CFR 50.55a(g)(4)(ii) states that 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 Code incorporated by reference in paragraph (b) 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 (RG) 1.147, Revision 15, that are incorporated by reference in paragraph (b) of this section), subject to the limitations and modifications listed in paragraph (b) of this section.
Paragraph (b)(2) states that As used in this section, references to Section XI of the ASME Boiler and Pressure Vessel Code refer to Section XI, and include the 1970 Edition through the 1976 Winter Addenda, and the 1977 Edition (Division 1) through the 2004 Edition (Division 1), subject to the following limitations and modifications:
II. PROPOSED ALTERNATIVE Pursuant to 10 CFR 50.55a(a)(3)(i), Entergy requests authorization to utilize the alternative requirements in the 2001 Edition through the 2003 Addenda subject to the limitations and modifications contained in 10 CFR 55.55a. In implementing this proposal, Entergy will comply with all NRC conditions, limitations, and restrictions as specified in 10 CFR 50.55a for the 2001 Edition through the 2003 Addenda of the Code, including the augmented requirements. Code Cases will also be adopted per RG 1.147 for those cases applicable to the 2001 Edition through the 2003 Addenda.
Attachment to 2CAN060902 Page 2 of 3 III. BASIS FOR PROPOSED ALTERNATIVE ASME Section XI activities (e.g., ISI, repair/replacement, pressure testing, and Non-Destructive Examination (NDE) at Arkansas Nuclear One, Unit 1 (ANO-1), Arkansas Nuclear One, Unit 2 (ANO-2), Grand Gulf Nuclear Station (GGNS), River Bend Station (RBS), and Waterford 3 (W3) are standardized and corporately administered by Entergy.
On May 31, 2008, ANO-1, GGNS, RBS, and W3 ISI programs were updated to the 2001 Edition through the 2003 Addenda of Section XI in accordance with the 10-year update requirements of 10 CFR 50.55a(g)(4)(ii). Also, to comply with the NRC restriction in paragraph (xxiv) of 10 CFR 50.55a(b)(2), performance demonstration of ultrasonic examinations in accordance with the 2001 Edition (no addenda) of Appendix VIII was incorporated into the programs. The repair/replacement, pressure testing, and NDE programs for these units were updated to the 2001 Edition through the 2003 Addenda of the Code as well.
To maintain standardization of the Entergy southern units, concurrent with the updates at the other Entergy plants, Entergy updated the ANO-2 repair/replacements, pressure testing, and NDE programs as approved by NRC Safety Evaluation Report dated December 20, 2007, to the 2001 Edition through the 2003 Addenda of the Code. It should be noted that the ANO-2 ISI Program was not updated at that time.
The start date of the next 10-year ISI interval for ANO-2 is March 26, 2010. Entergy is beginning the task of updating the ANO-2 ISI Program. As part of the process of updating the ANO-2 ISI Program, an inspection plan must be developed. Entergy ISI and NDE Personnel assist one another in the planning, performance, reporting, and assessing of ISI activities at all of the southern fleet. Until May 31, 2008, this had been one standard process at the Entergy southern plants since 2000.
However, the Code selection must be performed in accordance with ASME,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components as required by 10 CFR 50.55a Codes and Standards. 10 CFR 50.55a(g)(4)(ii) requires:
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 Code incorporated by reference in paragraph (b) 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, Revision 15, that are incorporated by reference in paragraph (b) of this section), subject to the limitations and modifications listed in paragraph (b) of this section.
The latest change to paragraph (b) was published in the Federal Register/Vol. 73, No. 176/Wednesday, September 10, 2008/Rules and Regulations. This update referenced the 2004 Edition of Section XI in 10 CFR 50.55a(b).
Attachment to 2CAN060902 Page 3 of 3 Therefore, Entergy is required to update the ANO-2 ISI Program to the 2004 Code in accordance with 10 CFR 50.55a(b). This will require Entergy to maintain two different ISI programs for its southern fleet. Furthermore, ANO personnel will have to implement two versions of each of the ISI programs at their site (i.e. updated program at ANO-2 and existing program at ANO-1).
Although the 2004 Edition made changes to Section XI, these changes were not necessary to ensure an acceptable level of quality and safety. Nor were these changes made to address a deficiency in the Code that adversely impacted safety. In the latest revision to 10 CFR 50.55a the NRC did not mandate that other plants that have adopted earlier edition and addenda follow any of the new paragraphs in the 2004 Edition. The only new mandatory requirements are to follow Code Case N-722 and N-729-1, which have been previously implemented at ANO-2.
Entergy believes that updating the ANO-2 ISI Program to the 2001 Edition through the 2003 Addenda to be standard with the other southern Entergy plants will improve the level of quality and safety at ANO-2. This allows leveraging the knowledge from all five units to ISI activities such as selection, planning, scheduling, performance, and assessments provides ANO-2 with a wealth of experience to draw on as well as minimizing the time spent on developing and maintaining procedures that are different from the rest of the Entergy southern units.
IV. CONCLUSION 10CFR50.55a(a)(3) states:
Proposed alternatives to the requirements of paragraphs (c), (d), (e), (f), (g), and (h) of this section or portions thereof may be used when authorized by the Director of the Office of Nuclear Reactor Regulation. The applicant shall demonstrate that:
(i) The proposed alternatives would provide an acceptable level of quality and safety, or (ii) 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 requirements updating ANO-2 ISI Program to the 2001 Edition through the 2003 Addenda including the 10 CFR 50.55a conditions, limitations, and augmented requirements provides an acceptable level of quality and safety.
Therefore, Entergy requests authorization to perform the requested alternative to the Code requirement pursuant to 10 CFR 50.55a(a)(3)(i).