2CAN050905, Response to Request for Additional Information for Alternative - PRR-ANO2-2009-1

Response to Request for Additional Information for Alternative - PRR-ANO2-2009-1

ML091410403
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/21/2009
From:	David Bice Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN050905, PRR-ANO2-2009-1
Download: ML091410403 (5)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4710 David B. Bice Acting Manager, Licensing Arkansas Nuclear One 2CAN050905 May 21, 2009 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Request for Additional Information for the Request for Alternative - PRR-ANO2-2009-1 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

REFERENCES:

1. Entergy Letter to NRC dated March 20, 2009, Request for Alternative From the Requirements of ASME OM Code - 2004 Edition -

PRR-ANO2-2009-1 (2CAN030903)

2. Email from Alan Wang (NRC) to Robert W. Clark (Entergy), ANO-2 Request for Information Regarding Request for Alternative ANO-2 RR PRR-ANO2-2009-1 (ME0921), dated April 28, 2009

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) proposed alternative PRR-ANO2-2009-1 for the Arkansas Nuclear One, Unit 2 (ANO-2) Inservice Testing (IST) Program. The proposed alternative pertains to parameters monitored in accordance with the American Society of Mechanical Engineers (ASME) Operation and Maintenance (OM) Code requirements during the quarterly testing of the Low Pressure Safety Injection (LPSI) pumps. During the submittal review process, the Nuclear Regulatory Commission (NRC) determined that additional information was required in order to complete the review of the Entergy request. The Request for Additional Information (RAI) was transmitted to ANO-2 on April 28, 2009, via email (Reference 2). The response to the RAI is to be provided within 45 days of the email.

The attachment to this letter provides the response to the RAI.

This letter contains no new commitment.

2CAN050905 Page 2 of 2 If you have any questions, or require additional information, please contact me.

Sincerely, DBB/rwc

Attachment:

Response to RAI 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 2CAN050905 Response to RAI

Attachment to 2CAN050905 Page 1 of 2 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION By letter dated March 20, 2009, Entergy submitted a request for an alternative for the Arkansas Nuclear One, Unit 2 (ANO-2) Inservice Testing (IST) Program. The proposed alternative is to categorize the Low Pressure Safety Injection (LPSI) pumps as Group B during operation in Modes 1 through 4, and as Group A during Modes 5 and 6. This will allow for a reduction of monitored parameters during the quarterly on-line testing. This reduction of monitored parameters maintains an acceptable level of quality and safety. The NRC staff has reviewed the March 20, 2009, request and has determined that additional information is required to complete their review. Each portion of the Request for Additional Information (RAI) is listed below. The ANO-2 responses are listed directly after each RAI.

1. Please provide the most recent vibration data for the quarterly and comprehensive flow tests for each pump.

Vibration is measured at three points on each motor. These are east-west, north-south, and axial.

The latest quarterly vibration measurements (in inches per seconds) are provided below.

Pump 2P-60A Pump 2P-60B Motor Outboard #1 0.156 (West) 0.188 (East)

Motor Outboard #2 0.103 (North) 0.136 (South)

Axial (Top) 0.114 0.089 Date Data was Taken February 15, 2009 March 25, 2009 Comprehensive flow testing is not a requirement of the current Code of Record (ASME OM Part 6) for ANO-2. Flow testing is performed during outages using installed flow instrumentation in accordance with Generic Letter 89-04, Position 9. The flow during this full flow test was between 4250 and 4350 gallons per minute (gpm). Vibration measurements (in inches per seconds) were taken on March 29, 2008, during this full flow test.

Pump 2P-60A Pump 2P-60B Motor Outboard #1 0.113 (West) 0.079 (East)

Motor Outboard #2 0.108 (North) 0.112 (South)

Axial (Top) 0.027 0.024

Attachment to 2CAN050905 Page 2 of 2

2. Under the Flow Measurements Section, first paragraph, it is stated, flow measurement using portable flow measurement equipment would not be practical on a quarterly basis to achieve the required accuracy for Group A Testing. Please provide more information as to why using portable flow measurement equipment during quarterly testing is impractical.

The LPSI pumps are tested quarterly through an orificed minimum recirculation line designed to pass 100 gpm. The ultrasonic flow meter accuracy associated with the equipment available at ANO is +/- 2% of reading on pipe greater than 6 inches in diameter and +/- 5% on pipe less than 6 inches in diameter. The Code required accuracy for flow measurement is +/- 2% and there is no installed piping in the recirculation loop where portable flow measurement can be installed that is greater than 6 inches in diameter.

Therefore, to obtain the +/- 2% Code accuracy with portable flow measurement equipment, modification of the piping would be required. Also, calibration and repeatability factors increase the total flow meter error. Since quarterly pump differential pressure is trended, there is little value added by also monitoring variations in flow measurement or attempting to adjust recirculation flow to a specific value.

3. Under the Flow Measurements Section, second paragraph, it is stated ALARA and personnel safety issues would be eliminated by re-categorizing the pumps.

Please provide more information about the personnel safety issues that are incurred during Group A testing and the personnel dose reduction that would be achieved with the proposed alternative.

The location on the pump motor where the vibration data is collected is approximately 12 feet above the floor. There is a platform installed for pump 2P-60A that allows for easy and safe vibration data collection. There is no platform for pump 2P-60B. A step ladder must be used to collect the vibration data. Using the vibrations data collector takes two hands, one to operate the collector and one to hold the vibration probe. To safely use the ladder, the continuous use of three points of contact is required. Collecting vibration data on pump 2P-60B presents a challenge to this requirement.

The current dose rate at both LPSI pumps is 6-12 mrem/hour and the data collection takes less than one-half hour per pump. Four quarterly tests on each of the two pumps are assumed per year. The anticipated dose savings that would be achieved with the proposed alternative would be between 24 and 48 mrem/year. 24 mrem/year would be the dose savings using the minimum dose rate and the maximum stay time.