ML032801700

Relaxation Request from NRC Order EA-03-009 Regarding the Bare Metal Visual Examination

ML032801700
Person / Time
Site:	Arkansas Nuclear
Issue date:	10/09/2003
From:	Dyer J Office of Nuclear Reactor Regulation
To:	Anderson C Entergy Operations
Alexion T W, NRR/DLPM, 415-1326
Shared Package
ml032801713	List: ML032801700 ML032801705
References
EA-03-009, TAC MB8927
Download: ML032801700 (4)

Text

October 9, 2003 Mr. Craig G. Anderson Vice President Operations, ANO Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT 2 (ANO-2) - RELAXATION REQUEST FROM NRC ORDER EA-03-009 REGARDING THE BARE METAL VISUAL EXAMINATION (TAC NO. MB8927)

Dear Mr. Anderson:

By letter dated May 8, 2003, as supplemented by letters dated June 26, August 2 (two letters) and 27, and October 2, 2003, you submitted a relaxation request from NRC Order EA-03-009.

Specifically, you requested authorization to not perform a bare metal visual examination of 100 percent (%) of the reactor pressure vessel (RPV) head surface for ANO-2. Instead, you proposed an alternative examination of the RPV head to include a limited visual examination, enhanced ultrasonic testing examination, and low frequency eddy current testing examination.

The staff has completed its review and concludes that the proposed alternative examination of the RPV head provides reasonable assurance of structural integrity of the head. Further inspection of the head surface in accordance with Section IV.C.(1)(a) of the Order would result in hardship without a compensating increase in the level of quality and safety. Thus, you have demonstrated good cause for the requested relaxation. Therefore, pursuant to Section IV, Paragraph F of the Order, I hereby authorize the proposed relaxation and alternative inspection for the RPV head surface at ANO-2 for one standard operating cycle, subject to the following condition:

"Should there be any evidence of corrosive product coming from any of the inaccessible areas on the reactor pressure vessel (RPV) head, the relaxation is rescinded until such time that the licensee can provide adequate information to the staff that ensures that the RPV head is not degraded in the inaccessible areas."

The staffs related Safety Evaluation (SE) is enclosed.

Pursuant to 10 CFR 2.790, we have determined that the enclosed SE does not contain proprietary information. However, we will delay placing the SE in the public document room for ten working days from the date of this letter to provide you with the opportunity to comment on the proprietary aspects only. If you believe that any information in the enclosure is proprietary, please identify such information line by line and define the basis pursuant to the criteria of 10 CFR 2.790.

This authorization is based, in large part, on the understanding that because of the unique shroud structure and insulation package design at ANO-2, the period of time between the issuance of the Order on February 11, 2003, and the current refueling outage, did not provide

sufficient time to properly plan for the performance of the bare metal visual examination. However, since there is ample time to plan for the next refueling outage and this relaxation is only for this operating cycle, a bare metal visual examination of the ANO-2 RPV head must be conducted at that time. If it is not your intention to conduct a bare metal visual examination during the next refueling outage, please engage my staff well in advance.

Be aware that when RPV head inspections are performed using American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.

Sincerely,

/RA/

J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/o Encl: See next page

However, since there is ample time to plan for the next refueling outage and this relaxation is only for this operating cycle, a bare metal visual examination of the ANO-2 RPV head must be conducted at that time. If it is not your intention to conduct a bare metal visual examination during the next refueling outage, please engage my staff well in advance.

Be aware that when RPV head inspections are performed using American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Code) requirements, acceptance criteria, or qualified personnel, those activities and all related activities fall within the jurisdiction of the ASME Code. Therefore, Order-related inspection activities may be subject to third party review, including those by the Authorized Nuclear Inservice Inspector.

Sincerely,

/RA/

J. E. Dyer, Director Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/o Encl: See next page DISTRIBUTION:

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Accession No.: ML032801700 *parallel concurrence OFFICE PDIV-1/PM PDIV-1/LA EMCB/SC OGC PDIV-1/SC PDIV-1/D NAME TAlexion: DJohnson TChan* MYoung* RGramm* HBerkow*

DATE 10/07/03 10/7/03 10/07/03 10/07/03 10/07/03 10/07/03 OFFICE DLPM/D NRR/ADPT NRR/D NAME LMarsh* BSheron JDyer DATE 10/07/03 10/8/03 10/9/03 DOCUMENT NAME: C:\ORPCheckout\FileNET\ML032801700.wpd OFFICIAL RECORD COPY

Arkansas Nuclear One cc:

Executive Vice President County Judge of Pope County

& Chief Operating Officer Pope County Courthouse Entergy Operations, Inc. Russellville, AR 72801 P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Mr. Mike Schoppman Framatome ANP, Richland, Inc.

Suite 705 1911 North Fort Myer Drive Rosslyn, VA 22209 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064

Vice President, Operations Support Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 March 2001