ML100970659

Request for Alternative ANO2-ISI-003 to Use 2001 Edition Through 2003 Addenda in Lieu of the 2004 Edition for Fourth 10-Year Inservice Inspection Interval

ML100970659
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/26/2010
From:	Markley M Plant Licensing Branch IV
To:	Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
ANO2-ISI-003, TAC ME1452
Download: ML100970659 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 26, 2010 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 SUB..IECT: ARKANSAS NUCLEAR ONE, UNIT 2 - REQUEST FOR RELIEF AN02-ISI-003, ALTERNATIVE TO USE 2001 EDITION THROUGH 2003 ADDENDA IN LIEU OF THE 2004 EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI (TAC NO. ME1452)

Dear Sir or Madam:

By letter dated June 8, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML091600248), Entergy Operations, Inc. (Entergy, the licensee),

submitted Request for Relief AN02-ISI-003, pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federa/ Regu/ations (10 CFR). In its submittal, the licensee proposed 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 (lSI) program. Specifically, the licensee proposes to update the ANO-2 lSI program to the requirements in the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, rather than the 2004 Edition, which is the latest edition/addenda approved for use in 10 CFR 50.55a(b)(2). The proposed alternative is applicable to ANO-2's fourth 10-year lSI interval which began on March 26,2010.

The ASME Code,Section XI activities (e.g., lSI, repair/replacement, pressure testing, and non destructive examination at Arkansas Nuclear One, Unit 1, ANO-2, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station, Unit 3 are standardized and corporately administered by Entergy. With the approval of this request, all lSI programs for the Entergy southern plants will be based on the same version of the ASME Code (2001 Edition with the 2003 Addenda), which will allow the licensee to return to one standard process.

The Nuclear RegUlatory Commission (NRC) staff has reviewed the licensee's request for approval of the alternative. On the basis of its review, the staff has concluded that the proposed alternative will provide an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of the proposed alternative for the fourth 10-year lSI interval at ANO-2.

All other ASME Code,Section XI requirements for which an alternative was not specifically requested and approved in this relief request remain applicable, inclUding third-party review by the Authorized Nuclear Inservice Inspector.

-2 The NRC staffs safety evaluation is enclosed.

Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF AN02-ISI-003 USE OF ASME CODE, SECTION XI, 2001 EDITION THROUGH 2003 ADDENDA ARKANSAS NUCLEAR ONE, UNIT 2 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368

1.0 INTRODUCTION

By letter dated June 8,2009 (Reference 1), Entergy Operations, Inc. (Entergy, the licensee),

submitted Request for Relief AN02-ISI-003, pursuant to paragraph 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR). In its submittal, the licensee proposed an alternative to the requirements of 10 CFR 50.55a(g)(4)(ii) pertaining to the 1O-year update of the Arkansas Nuclear One, Unit 2 (ANO-2) inservice inspection (lSI) program. Specifically, the licensee proposes to update the ANO-2 lSI program to the requirements in the 2001 Edition through the 2003 Addenda of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, rather than the 2004 Edition, which is the latest edition/addenda approved for use in 10 CFR 50.55a(b)(2). The proposed alternative is applicable to ANO-2's fourth 1O-year lSI interval which began on March 26, 2010.

2.0 REGULATORY EVALUATION

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1,2, and 3 components (including supports) will meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, "Rules for Inservice Inspection (lSI) of Nuclear Power Plant Components," to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that inservice examination of components and system pressure tests conducted during the first 1O-year lSI interval and subsequent intervals comply with the requirements in the latest edition and addenda of Section XI of the ASME Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein.

Pursuant to 10 CFR 50.55a(a)(3), alternatives to requirements may be authorized by the NRC if the licensee demonstrates that: (i) the proposed alternative provides an acceptable level of Enclosure

-2 quality and safety, or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

3.0 TECHNICAL EVALUATION

3.1 Licensee's Request for Alternative 3.1.1 Code Requirements The Code of record for ANO-2's fourth 1O-year lSI program interval is the 2004 Edition of the ASME Code,Section XI.

3.1.2 Licensee's Proposed Alternative Entergy proposes to use the alternative requirements in the 2001 Edition through the 2003 Addenda of the ASME Code,Section XI, subject to the limitations and modifications contained in 10 CFR 50.55a(b )(2).

3.1.3 Basis for Proposed Alternative In its letter dated June 8, 2009, the licensee stated:

ASME [Code] Section XI activities (e.g. lSI, 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 Steam Electric Station, Unit 3] (W3) are standardized and corporately administered by Entergy.

In accordance with the requirements of 10 CFR 50.55a(g)(4)(ii), the ANO-1, GGNS, RBS, and W3 lSI programs were updated to the 2001 Edition through the 2003 Addenda of ASME Code,Section XI, on May 31,2008. To maintain standardization of the Entergy southern plants, the ANO-2 repair/replacement, pressure testing, and NDE programs were updated to the 2001 Edition through the 2003 Addenda of ASME Code,Section XI, concurrent with the updates at the other Entergy southern plants as approved by NRC staff letter dated December 20, 2007 (Reference 2). The ANO-2 lSI program was not updated at that time.

The ANO-2 fourth 10-year lSI interval began on March 26, 2010. The regulations in 10 CFR 50.55a(g)(4)(ii) require Entergy to update the ANO-2 lSI program to the 2004 Edition of ASME Code,Section XI; therefore, Entergy would be required to maintain two different lSI programs for its southern fleet and two different programs at the ANO site.

In its letter dated June 8, 2009, the licensee stated:

Entergy believes that updating the ANO-2 lSI 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 lSI activities such as selection, planning, scheduling, performance, and assessments provide ANO-2 with a wealth of

-3 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.

The licensee also noted that while there were changes to ASME Code,Section XI in the 2004 Edition, these changes were not necessary to ensure an acceptable level of quality and safety and they were not made to address a deficiency in the ASME Code that adversely impacted safety.

3.2 NRC Staff Evaluation The licensee's proposed alternative would allow ANO-2 to update its fourth 10-year lSI program interval to the 2001 Edition through the 2003 Addenda of ASME Code,Section XI, rather than the 2004 Edition currently incorporated by reference in 10 CFR 50.55a(b). The ANO-2 fourth 10-year lSI interval began on March 26, 2010.

The changes incorporated into the 2004 Edition of ASME Code,Section XI, were evaluated by the NRC staff when the 10 CFR 50.55a(b)(2) regulations were changed to incorporate, by reference, the 2004 Edition of ASME Code,Section XI. The staff did not find it necessary to mandate that plants following earlier editions and addenda of ASME Code,Section XI implement any of the changes incorporated into the 2004 Edition of Section XI. However, the staff did mandate the requirements found in 10 CFR 50.55a(g)(6)(ii)(D), "Reactor vessel head inspections," and 10 CFR 50.55a(g)(6)(ii)(E), "Reactor coolant pressure boundary visual inspections." In its letter dated June 8, 2009, the licensee stated that the requirements in 10 CFR 50.55a(g)(6)(ii)(D) and (E) have been implemented at ANO-2. Therefore, the staff concludes that an lSI program following the requirements of the 2001 Edition through the 2003 Addenda of ASME Code,Section XI, subject to the limitations and modifications of 10 CFR 50.55a(b) and the requirements of 10 CFR 50.55a(g)(6)(ii)(D) and (E), will provide an acceptable level of quality and safety.

The proposed alternative will allow the use of a common Code of record for the Entergy southern plants and the ANO plant site. The common Code of record will be 2001 Edition through the 2003 Addenda of ASME Code,Section XI, for all five Entergy southern plants.

There are distinct advantages in implementing the same code requirements at multiple sites for a licensee. The advantages include the reduction of administrative burden of maintaining different sets of procedures and requirements and results in a significant decrease in the chances of applying the wrong requirements.

Based on the above, the NRC staff has determined that the licensee's proposed alternative will ensure implementation of the lSI programs at ANO-2 is more efficient and effective. Therefore, the staff concludes that the licensee's proposed alternative will provide an acceptable level of quality and safety.

4.0 CONCLUSION

The NRC staff has reviewed the licensee's proposed Relief Request AN02-ISI-003 submittal and concludes that the licensee's proposed alternative provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the NRC staff authorizes the use of

-4 Relief Request AN02-ISI-003 for the use of the 2004 Edition of the ASME Code,Section XI, for ANO-2 for the fourth 10-year lSI interval, which began on March 26, 2010. All other ASME Code,Section XI requirements for which relief was not specifically requested and approved in the subject requests for relief remain applicable, including third-party review by the authorized Nuclear Inservice Inspector.

5.0 REFERENCES

1. Bice, D. B., Entergy Operations, Inc., letter to U.S. Nuclear Regulatory Commission, "Request for Alternative to Use 2001 Edition Through 2003 Addenda in Lieu of the 2004 Edition, Arkansas Unit One, Unit 2, Docket No. 50-368, License No. NPF-6," dated June 8, 2009 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML091600248).

2. Hiltz, T. G., U.S. Nuclear Regulatory Commission, letter to Timothy G. Mitchell, Entergy Operations, Inc., "Arkansas Nuclear One, Unit 2 - ISI-2007-1, Request to Use a Later Edition and Addenda of American Society of Mechanical Engineers Boiler and Pressure Vessel Code (TAC No. MD6603)," dated December 20,2007 (ADAMS Accession No. ML073390442).

Principal Contributor: Keith Hoffman Date: April 26, 2010

-2 The NRC staff's safety evaluation is enclosed.

Sincerely, IRN Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ DISTRIBUTION:

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