1CAN021002, Response to Second Set of Requests for Additional Information on the Third 10-Year Inservice Inspection Interval Relief Requests

Response to Second Set of Requests for Additional Information on the Third 10-Year Inservice Inspection Interval Relief Requests

ML100470758
Person / Time
Site:	Arkansas Nuclear
Issue date:	02/09/2010
From:	David Bice Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN021002
Download: ML100470758 (9)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-5338 David Bice Acting Manager, Licensing Arkansas Nuclear One 1CAN021002 February 9, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Response to Second Set of Requests for Additional Information On the Third 10-Year Inservice Inspection Interval Relief Requests Arkansas Nuclear One, Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCES:

1. Entergy letter to the NRC, dated May 29, 2009, Requests for Relief From ASME Section XI Volumetric, Surface and Visual Examination Requirements - Third 10-Year Interval (1CAN050902)

2. Email from Kaly Kalyanam (NRC) to Robert W. Clark (Entergy), dated August 5, 2009, RAI on Relief Requests for Limited Exams during Third 10-Year Interval (TAC Nos. ME1439, 1440, 1441, 1442, 1443, and 1444)

3. Entergy letter to the NRC, dated October 28, 2009, Response to Request for Additional Information on the Third 10-Year Inservice Inspection Interval (1CAN100901)

4. Email from Kaly Kalyanam (NRC) to Robert W. Clark (Entergy), dated December 22, 2009, Request for Additional Information on the Third Ten Year 10-Year Inservice Inspection Interval Requests for Relief ANO1-ISI-015, -016, -017, -018, -019, and -020

Dear Sir or Madam:

In Reference 1, Entergy Operations, Inc. (Entergy) submitted its third 10-year Inservice Inspection (ISI) interval requests for limited examinations in multiple American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, examination categories for Arkansas Nuclear One, Unit 1 (ANO-1). The relief requests were submitted in accordance with 10 CFR 50.55a(g)(5)(iii).

10 CFR 50.55a(g)(5)(iii) requires information to be submitted to the NRC to support the determination that the ASME requirements were impractical. Based on the NRCs acceptance review of the Reference 1 submittal, it was determined that additional information was required to support the bases for limited examination in all requests, and therefore, demonstrate

1CAN021002 Page 2 of 2 impracticality. The request for additional information (RAI) was provided to ANO-1 via Reference 2. The response to this set of RAIs was provided to the NRC in Reference 3. Based upon review of the response to the RAIs in Reference 3, the NRC provided a second set of RAIs via Reference 4 to the site. This submittal provides the information requested in Reference 4.

This letter contains no new commitments.

If you have any questions or require additional information, please contact me.

Sincerely, DBB/rwc

Attachment:

Responses to Second Set of NRC RAIs on Third 10-Year Inservice Inspection Interval Requests for Relief 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-8 B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 1CAN021002 Responses to Second Set of NRC RAIs on Third 10-Year Inservice Inspection Interval Requests for Relief

Attachment to 1CAN021002 Page 1 of 6 REQUEST FOR ADDITIONAL INFORMATION ON THE THIRD TEN YEAR 10-YEAR INSERVICE INSPECTION INTERVAL REQUESTS FOR RELIEF ANO1-ISI-015, -016, -017, -018, -019 AND -020 1.0 SCOPE By letter dated May 29, 2009 (Agencywide Documents Access & Management System (ADAMS) ML091520610), supplemented by letter dated October 28, 2009 (ADAMS ML093070060), the licensee, Entergy Operations, Inc., submitted Requests for Relief (RR)

ANO1-ISI-015, ANO1-ISI-016, ANO1-ISI-017, ANO1-ISI-018, ANO1-ISI-019, and ANO1-ISI-020, from the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, for Arkansas Nuclear One, Unit 1 (ANO-1).

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(g)(5)(iii), the licensee has submitted the subject requests for relief for limited examinations in multiple ASME Code Examination Categories. The ASME Code requires that 100% of the examination volumes, or surface areas, described in Tables IWB-2500 and IWF-2500 be performed during each interval. The licensee stated that 100% of the ASME Code-required volumes, or surface areas, are impractical to obtain at ANO-1.

10 CFR 50.55a(g)(5)(iii) states that when licensees determine that conformance with ASME Code requirements is impractical at their facility, they shall submit information to support this determination. The NRC will evaluate such requests based on impracticality, and may impose alternatives, giving due consideration to public safety and the burden imposed on the licensee.

Pacific Northwest National Laboratory (PNNL) has reviewed the information submitted by the licensee, and based on this review, determined the following information is required to complete the evaluation.

2.0 REQUEST FOR ADDITIONAL INFORMATION 2.1 General Information Required on All Requests for Relief 2.1.1 Based on the licensees submittals, it is unclear which edition and addenda of ASME Code,Section XI, is applicable to the specific components listed in the individual relief requests. For example, in ANO1-ISI-015, the licensee lists the 1992 Edition and the 1995 Edition through the 1996 Addenda as having applicable inservice (ISI) requirements for the subject components, and in ANO1-ISI-016, the licensee lists the 1992 Edition and the 1980 Edition through the 1981 Addenda. The licensee states that the 1995 Edition through the 1996 Addenda of ASME Code was mandated for implementation of the ASME Code,Section XI, Appendix VIII examinations during the interval, however, this does not clear up the multiple ASME Code applicability issues.

Attachment to 1CAN021002 Page 2 of 6 Please confirm the ASME Code of record for the third interval inservice inspection program at ANO-1, how the licensee arrived at this edition/addenda of the ASME Code, and the specific requirements for each of the subject components listed in each request for relief. If the 1992 Edition was the primary ASME Code of record invoked for the third 10-year interval, confirm that no Addenda were included.

The Code of record for the third ANO-1 ISI interval is the 1992 Edition with portions of later Addenda as described in Section 2 of the ISI Program. ANO-1 was issued a safety evaluation from the NRC via letter 1CNA089904 dated August 25, 1999, to perform a Risk Informed alternative to the 1992 Edition of the ASME Code Section XI, inspection requirements for Class 1, Category B-J piping welds (excluding socket welds) contained in Table IWB-2500-1. The alternative was for the 1st Period of the 3rd Interval and for the remaining license term of the plant.

The specific requirements for each component:

Exam App Code Year Exam Comp ID Date for NDE Requirements01-005 11/9/2008 1995 w/96 addenda Volumetric 01-006 11/9/2008 1995 w/96 addenda Volumetric 05-014 10/10/2002 1980 w/81 addenda Volumetric 05-015 10/10/2002 1980 w/81 addenda Volumetric 05-021 4/28/2007 1995 w/96 addenda Volumetric 01-F-01-20 10/1/1999 1980 w/81 addenda Volumetric 01-F-21-40 5/4/2004 1980 w/81 addenda Volumetric 01-F-41-60 12/10/2005 1980 w/81 addenda Volumetric 09-001 03/30/2001 1995 w/96 addenda Volumetric 18-010 04/25/2007 1995 w/96 addenda Volumetric 23-055 10/18/2005 1995 w/96 addenda Volumetric 09-006 03/30/2001 1995 w/96 addenda Volumetric 22-099W 03/29/2001 1992 Surface

Attachment to 1CAN021002 Page 3 of 6 01-032 05/06/2007 1992 Visual 01-033 05/06/2007 1992 Visual 01-034 05/06/2007 1992 Visual 2.1.2 Provide the start and end dates for the ANO-1 third 10-year inservice inspection interval.

Start of third interval was 7/1997 and ended 10/2008 (interval extension was requested and granted).

2.2 Request for Relief ANO1-ISI-016, Examination Category B-D, Item B3.110, Full Penetration Welded Nozzles in Vessels 2.2.1 It is unclear from the licensees submittals which wave mode corresponds to each insonification angle. Clarify the wave modality and the corresponding insonification angles used for all ultrasonic examinations performed on the pressurizer nozzle-to-head welds.

Wave modality and corresponding insonification angles are 0° longitudinal, 45° shear, 60° shear, and 70° shear.

2.2.2 Provide the inspection dates for all welds listed in this request for relief for the ANO-1 third 10-year ISI.

See Response to RAI in Paragraph 2.1.1 above.

2.3 Request for Relief ANO1-ISI-018, Examination Category B-J, Items B9.11, B9.21 and B9.31, Pressure Retaining Welds in Piping 2.3.1 The 1992 Edition of the ASME Code,Section XI requires a surface examination for Examination Category B-J, Item B9.21, and both a surface and volumetric examination for Items B9.11 and B9.31 for the subject Class 1 piping welds.

However, neither the original submittal nor the response to the request for additional information state that the surface examinations were required or performed for welds listed in Table 2.3.1. Please confirm whether the required surface examinations were performed for the subject welds, whether these surface examinations were full ASME Code examinations (>90% coverage), and describe any indications that were detected.

Attachment to 1CAN021002 Page 4 of 6 Table 2.3.1 - Examination Category B-J Code Item Weld ID Weld Type Coverage Obtained B9.11 09-001 D RCP Pump-to-Pipe Weld 50.0%

B9.21 18-010 Pressurizer Spray Valve-to-Pipe Weld 50.0%

B9.21 23-055 High Pressure Injection to B2 loop Elbow-to-Valve 41.0%

Weld B9.31 09-006 Pipe-to-HPI Nozzle Weld 50.0%

As stated in the response to 2.1.1 above, ANO implemented a Risk Informed alternative to the 1992 Edition of the ASME Code Section XI, inspection requirements for Class 1, Category B-J piping welds (excluding socket welds) contained in Table IWB-2500-1. Under the Risk Informed alternative, the requirement for performing surface examinations on Class 1 components was eliminated.

2.3.2 State the material of construction of the weld and base metal (e.g., wrought stainless steel) for each component listed in Table 2.3.1.

Component ID 09-001: A-351-CF8M to SA-240, TP-316 Component ID 09-006: SA-106, GR. C with SS clad Component ID 18-010: A-376, TP-316 Component ID 23-055: A-312, TP-316 2.3.3 In the licensees original submittal, it states, ASME Section XI, Table IWB-2500-1, Examination Category B-J, Pressure Retaining Welds in Piping, Items B9.11, B9.21, and B9.32, all require 100% volumetric examination of the Class 1 pipe welds identified through the risk-informed process. Stating that the pipe welds were identified through the risk-informed process leads the reviewer to believe that these welds fall under examination category R-A, Risk Informed Piping Examinations. Please confirm what the appropriate examination category, either B-J or R-A, was used to evaluate these Class 1 piping welds.

ANO-1 developed a pilot plant application of risk-informed ISI for Class 1 piping and submitted the results of the study to the NRC for review per correspondence dated June 3, 1998 (1CAN069804). This pilot application was based on ASME Code Case N-560 and provided an alternative to the 1992 Edition of the ASME Code Section XI inspection requirements for Class 1, Category B-J piping welds (excluding socket welds) contained in Table IWB-2500-1. The NRC reviewed the ANO-1 pilot plant study and issued a Safety Evaluation, authorizing the proposed alternative provided above, in letter dated August 25, 1999 (1CNA089904) to perform a Risk Informed alternative, based on Code Case N-560. Under the pilot program, the R-A designation for examination category did not exist. However, all examination selections and examinations were performed per the RI requirements.

Attachment to 1CAN021002 Page 5 of 6 2.4 Request for Relief ANO1-ISI-019, Examination Category B-K-1, Item B10.20, Integral Attachments for Piping, Pumps, and Valves 2.4.1 The 1992 Edition of the ASME Code,Section XI, Examination Category B-K-1, Item Number B10.20 requires a surface examination of integrally welded pump attachments. The description of the integrally welded attachment for this relief request is referring to a piping attachment which would correspond to Item B10.10 of Category B-K-1. Please verify the correct item number and examination category applied to the pipe support integral attachment weld in this relief request.

ASME Code Case N-509 was invoked in the third ISI inspection interval. The correct item number and examination category (B-K-1/B10.20) was applied to this component.

The licensee may have invoked ASME Code Case N-509, Alternative Rules for the Selection and Examination of Class 1, 2 and 3 Integrally Welded Attachments,Section XI, Division 1, which lists Examination Category B-K, and states requirements for this, and other integral attachment, welds. However, no mention of the use of ASME Code Case N-509 has been stated. ASME Code Case N-509 is conditionally acceptable according to an earlier revision of Regulation Guide 1.147, Inservice Inspection Code Case Acceptability, which may have been in effect at the start of the licensees third 10-year inspection interval. The NRC condition for acceptable use was that a minimum 10% sample of integrally welded attachments for each item in each ASME Code class shall be examined during each interval.

State whether ASME Code Case N-509 was invoked and confirm that the listed condition for acceptance was applied for all Class 1, 2 and 3 integral attachment welds.

ASME Code Case N-509 was invoked in the third ISI inspection interval and the 10%

sample requirements were met.

2.5 Request for Relief ANO1-ISI-020, Examination Category F-A, Item F1.40, Supports 2.5.1 The licensee has requested relief from the visual examination of Reactor Pressure Vessel (RPV) Support Skirt Circumferential Weld 01-032, and states that no access is available due to insulation blocks that are impractical to remove. However, the licensee was able to conduct remote visual examinations on the other two RPV support skirt components listed in the relief request by using a fiberscope through cut-outs in the support skirt. It is unclear from the licensees sketch provided why access to Weld 01-032 was not feasible. Please provide technical justification of why the visual examination could not be performed using the fiberscope, or whether the visual examination may be completed via other remote technology.

Attachment to 1CAN021002 Page 6 of 6 The space between the insulation package and the support skirt flange, sole plate and pedestal is a very narrow opening as illustrated in the previously submitted sketch.

The fiberscope was required to negotiate this narrow space for approximately 40 inches and then turn 90° to be inserted into the RPV skirt access hole. From that position, weld 01-032 is approximately 13 inches above the access hole. The fiberscope is incapable of another 90° articulation and subsequent positioning to provide a satisfactory distance and viewing angle necessary to perform a qualified examination.