2CAN051301, Response to Request for Additional Information, Request for Relief ANO2-ISI-015
| ML13133A339 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 05/10/2013 |
| From: | Pyle S Entergy Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 2CAN051301, TAC ME0951 | |
| Download: ML13133A339 (2) | |
Text
2CAN051301 May 10, 2013 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Response to Request for Additional Information Request for Relief ANO2-ISI-015 Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6
REFERENCES:
- 1. Entergy letter to NRC, Request for Relief from American Society of Mechanical Engineers (ASME) Code,Section XI - Request for Relief ANO2-ISI-015, dated March 1, 2013 (2CAN031301) (ML12063A538)
- 2. Email from Kaly Kalyanam (NRC) to Robert W. Clark (ANO), Acceptance Review Result to Entergy - on RR No. ANO2-ISI-o15 (TAC No.
ME0951), dated April 2, 2013 (ML13092A340)
Dear Sir or Madam:
Entergy Operations, Inc. (Entergy) submitted Request for Relief ANO2-ISI-015, from the requirements of the ASME Code,Section XI for Arkansas Nuclear One, Unit 2 (ANO-2)
(Reference 1). The request pertains to the period pressure testing requirements for the ANO-2 reactor vessel flange seal leak detection piping.
Entergy determined that the required pressure test requirements are impractical due to the configuration and design of the system. Compliance with the specified requirements of this section of the code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The alternative that was proposed in Reference 1 is based on ASME Code Case N-805, Alternative to Class 1 Extended Boundary End of Interval or Class 2 System Leakage Testing of the Reactor Vessel Flange O-ring Leak Detection System.
The code case references two different paragraphs of the ASME Code,Section XI, one of which is IWC-5220. This paragraph details the requirements for the ASME Code Class 2 System Leakage Test. Sub-paragraph IWC-5221 discusses system pressure requirements for the system leakage test. IWC-5222(a) discusses the pressure retaining boundaries, and IWC-5222(b) discusses those boundaries that are excluded from the examination requirements.
Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Licensing Arkansas Nuclear One
2CAN051301 Page 2 of 2 During their review of the relief request, the NRC noted that the request cites both IWC-5222(a) and (b). As noted above, these two paragraphs only address the boundaries for the system leakage test. The alternative essentially affects the pressure at which the examination will be conducted and not alter the definition of the pressure retaining boundaries. The NRC requested a clarification as to which paragraph(s) of the ASME Code,Section XI, Entergy was requesting relief from for ANO-2 (Reference 2).
In response to the request for clarification, Entergy has determined that the correct ASME Code paragraphs were identified in the references of Request for Relief ANO2-ISI-015; the citations in the description of the relief request were in error. The correct paragraph of the ASME Code that Entergy is requesting relief from for ANO-2 is IWC-5220 with sub-paragraph IWC-5221 only.
The remaining discussion provided in Reference 1 is not impacted by this clarification.
This submittal contains no regulatory commitments.
If you have any questions or require additional information, please contact me.
Sincerely, Original signed by Stephenie L. Pyle SLP/rwc cc:
Mr. Arthur T. Howell Regional Administrator U. S. Nuclear Regulatory Commission, Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 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