ML032860042

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Relaxation Request from NRC Order EA-03-009 Regarding Incore Instrumentation Nozzles
ML032860042
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 10/09/2003
From: Berkow H
NRC/NRR/DLPM/LPD4
To: Krupa M
Entergy Operations
Alexion T W, NRR/DLPM, 415-1326
Shared Package
ML032860043 List:
References
EA-03-009, TAC MC0640
Download: ML032860042 (4)


Text

October 9, 2003 Mr. Michael A. Krupa, Director Nuclear Safety & Licensing Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213-8298

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT 2 (ANO-2) - RELAXATION REQUEST FROM U.S. NUCLEAR REGULATORY COMMISSION (NRC)

ORDER EA-03-009 FOR THE INCORE INSTRUMENTATION NOZZLES (TAC NO. MC0640)

Dear Mr. Krupa:

By letter dated September 24, 2003, as supplemented by letters dated September 26, and October 2 and 8, 2003, Entergy Operations Inc. (Entergy or the licensee) requested relaxation to implement an alternative to the requirements of Section IV, Paragraph C.(1)(b)(i), of the Order for all incore instrumentation nozzles.

Specifically, pursuant to the process specified in Section IV, Paragraph F of the Order, you requested relaxation from the requirement specified in Section IV, Paragraph C, Item (1)(b)(i),

to perform inspections using a three-step alternative, which involves the use of analysis techniques, ultrasonic testing, and surface examination.

Your letter dated September 24, 2003, superseded the original request submitted on September 3, 2003, and supplemented by letter dated September 12, 2003.

The NRC staff has completed its review and concludes that the proposed alternative examination of the reactor pressure vessel (RPV) head provides reasonable assurance of structural integrity of the head. Further inspection of the head surface in accordance with Section IV.C.(1)(b)(i) 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 authorize, for one operating cycle commencing with the startup from the Fall 2003 refueling outage, the proposed alternative inspection for all ICI head penetration nozzles at ANO-2, subject to the following condition:

If the NRC staff finds that the crack-growth formula in MRP-55 is unacceptable, Entergy shall revise its analysis that justifies relaxation of the Order within 30 days after the NRC informs Entergy of an NRC-approved crack-growth formula. If Entergys revised analysis shows that the crack growth acceptance criteria are exceeded prior to the end of the operating cycle which follows the current refueling outage, this relaxation is rescinded and Entergy will, within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, submit to the NRC written justification for continued operation. If the revised analysis shows that the crack growth acceptance criteria are exceeded during the subsequent operating cycle, Entergy shall, within 30 days, submit the revised analysis for NRC review. If the revised analysis shows that the crack growth acceptance criteria are not exceeded during either the upcoming operating cycle or the subsequent operating cycle, Entergy shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for the upcoming operating cycle and future cycles for RPV head penetrations will be based on an NRC-acceptable crack growth rate formula.

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.

Be aware that when vessel 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 activites 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/

Herbert N. Berkow, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/o Encl: See next page the crack growth acceptance criteria are not exceeded during either the upcoming operating cycle or the subsequent operating cycle, Entergy shall, within 30 days, submit a letter to the NRC confirming that its analysis has been revised. Any future crack-growth analyses performed for the upcoming operating cycle and future cycles for RPV head penetrations will be based on an NRC-acceptable crack growth rate formula.

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.

Be aware that when vessel 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 activites 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/

Herbert N. Berkow, Director Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

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

PUBLIC RidsOgcRp PDIV-1 Reading RidsAcrsAcnwMailCenter RidsNrrDlpmLpdiv (HBerkow)

GHill (2)

RidsNrrDlpmLpdiv1(RGramm)

RDavis RidsNrrPM(TAlexion)

RLorson, RIV Plants (RKL)

RidsNrrLA(DJohnson)

RidsRgn4MailCenter (AHowell)

RidsNrrPM(BVaidya)

RidsNrrPM(NKalyanam)

Package: ML032860043

    • No legal objection with edits Accession No. ML032860042
  • No Significant change from SE input Safety Evaluation: ML032860044 OFFICE PDIV-1/PM PDIV-1/LA EMCB/SC OGC PDIV-1/SC PDIV-1/D NAME BVaidya DJohnson TChan*

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RGramm HBerkow DATE 10/9/03 10/9/03 10/9/03 10/9/03 10/9/03 10/9/03 OFFICIAL RECORD COPY

Arkansas Nuclear One cc:

Executive Vice President

& Chief Operating Officer Entergy Operations, Inc.

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 County Judge of Pope County Pope County Courthouse Russellville, AR 72801

March 2001 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 Mr. Craig G. Anderson Vice President Operations, ANO Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801