1CAN111602, Fifth Ten-Year Interval Inservice Testing Program, Relief Request VRR-ANO1-2017-1

Fifth Ten-Year Interval Inservice Testing Program, Relief Request VRR-ANO1-2017-1

ML16321A412
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/16/2016
From:	Pyle S Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
1CAN111602
Download: ML16321A412 (5)

Text

Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-858-4704 Stephenie L. Pyle Manager, Regulatory Assurance Arkansas Nuclear One 1CAN111602 November 16, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

Fifth Ten-Year Interval Inservice Testing Program Relief Request VRR-ANO1-2017-1 Arkansas Nuclear One - Unit 1 Docket No. 50-313 License No. DPR-51

REFERENCE:

NRC Letter to Entergy Operations, Arkansas Nuclear One, Unit No. 1 -

Approval of Relief Request for Arkansas Nuclear One Unit 1 Fourth 10-Year Pump and Valve Inservice Testing Program (TAC Nos. MD7709 and MD7710), dated April 30, 2008 (ML081130082)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(z)(2), Entergy Operations, Inc. (Entergy) requests approval of the attached Relief Request VRR-ANO1-2017-1 for the Arkansas Nuclear One, Unit 1 (ANO-1) Fifth Ten-Year Interval Inservice Testing Program. The fifth ten-year interval is scheduled to begin December 1, 2017, and conclude on November 30, 2027.

Entergy requests relief from ASME OM Code-2004 Edition, with addenda through OMb Code-2006 Addenda, Appendix I, Paragraph I-8200 Seat Tightness Testing. Seat tightness testing shall be performed in accordance with the Owner's valve test procedure. This relief request is for the relief valve for the ANO-1 sodium hydroxide storage tank. As an alternative, the seat leakage test of this vacuum breaker valve will not be performed. Based on the determination that compliance with the ASME OM Code-2004 Edition, with addenda through OMb Code-2006 Addenda, requirements results in an unusual difficulty without a compensating increase in the level of quality or safety, this proposed alternative should be granted pursuant to 10 CFR 50.55a(z)(2). The details of the request are provided in the attached Relief Request VRR-ANO1-2017-1.

This alternative is a re-submittal of the ANO-1 Fourth Ten-Year Interval Relief Request VRR-ANO1-2007-1. That relief request was approved by the NRC in the reference above.

1CAN111602 Page 2 of 2 This letter contains no new regulatory commitment.

If you have any questions concerning this submittal, please contact me.

Sincerely, ORIGINAL SIGNED BY DAVID B. BICE ACTING REGULATORY ASSURANCE MANAGER FOR STEPHENIE L. PYLE SLP/rwc

Attachment:

Request for Relief - VRR-ANO1-2017-1 cc: Mr. Kriss Kennedy 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. Thomas Wengert MS O-08B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852

Attachment to 1CAN111602 Request for Relief VRR-ANO1-2017-1

Attachment to 1CAN111602 Page 1 of 2 Request for Relief VRR-ANO1-2017-1

1. American Society of Mechanical Engineers (ASME) Code Component(s) Affected Valve ID Function Category Class PSV-1617 NAOH TANK PRESSURE/VAC RELIEF C 3

2. Applicable ASME Code Edition and Addenda ASME Code for Operations and Maintenance of Nuclear Power Plants (OM Code) 2004 Edition, with addenda through OMb-2006

3. Applicable Code Requirement(s)

ASME OM Code-2004 Edition, with addenda through OMb Code-2006 Addenda, Appendix I, Paragraph I-8200:

Seat Tightness Testing - Seat tightness testing shall be performed in accordance with the Owner's valve test procedure.

4. Reason for Request Relief valve PSV-1617 has an active open safety function to relieve overpressure and vacuum conditions in the sodium hydroxide storage tank. Note that although the tank vent valve AV-10 is normally open to perform these functions, PSV-1617 is considered to be the primary and most reliable mechanism for performing this function. The seat leakage testing of PSV-1617 produces no useful information since PSV-1617 has no significant safety function in the closed position.

5. Proposed Alternative and Basis for Use Seat leakage testing of this vacuum breaker valve, PSV-1617, will not be performed.

This vacuum breaker valve, PSV-1617, has no significant safety function in the closed position. Furthermore, seat leakage is irrelevant since, in effect, PSV-1617 is normally bypassed by a line with a normally-open vent valve, AV-10.

Based on the determination that compliance with the ASME OM Code-2004 Edition, with addenda through OMb Code-2006 Addenda, requirements results in a hardship without a compensating increase in the level of quality or safety, this proposed alternative should be granted pursuant to 10 CFR 50.55a(z)(2).

Attachment to 1CAN111602 Page 2 of 2

6. Duration of Proposed Alternative Arkansas Nuclear One, Unit 1s Fifth Ten-Year Inservice Testing Interval (December 1, 2017, through November 30, 2027).

7. Precedent This alternative is a re-submittal of the ANO-1 Fourth Ten-Year Interval Relief Request VRR-ANO1-2007-1. That relief request was approved by the NRC in letter dated April 30, 2008 (ML081130082).

The previous relief request was based on the ASME OM Code 2001 Edition with addenda through OMb-2003 Addenda. This Fifth Ten-Year Interval relief request is based on the ASME OM Code-2004 Edition, with addenda through OMb Code-2006 Addenda. There have been no substantive changes to this relief request, to the OM Code requirements or to the basis for use, which would alter the previous NRC Safety Evaluation conclusions.