ML20044F617

Provides Evaluation Re Licensee Requesting Relief from Certain ASME Code Requirements for Snubber Functional Testing

ML20044F617
Person / Time
Site:	Arkansas Nuclear
Issue date:	05/19/1993
From:	Chan T Office of Nuclear Reactor Regulation
To:	Yelverton J ENTERGY OPERATIONS, INC.
References
TAC-M83083, TAC-M83084, NUDOCS 9305280321
Download: ML20044F617 (4)

Text

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UNITED STATES f*

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NUCLEAR REGULATORY COMMISSION

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wAsmucTou. o. c. zosss May 19, 1993 Docket Nos. 50-313 and 50-368 Mr. Jerry W. Yelverton Vice President, Operations AND Entergy Operations, Inc.

Route 3 Box 137G Russellville, Arkansas 72801

SUBJECT:

RELIEF REQUEST FOR SNUBBER TESTING, ARKANSAS NUCLEAR ONE, UNITS 1&2 (ANO-1&2) (TAC NOS. M83083 AND M83084)

By letter dated March 26, 1992, Entergy Operations, Inc., the licensee for ANO-l&2, requested relief from certain ASME Code requirements for snubber functional testing. The NRC staff has reviewed the request and provides its evaluation as follows.

Title 10 of the Code of Federal Regulations,10 CFR 50.55a, requires (in part) that inservice testing of certain ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where alternatives are authorized or relief is granted by the Commission pursuant to 10 CFR 50.55a(a)(3)(i),

(a)(3)(ii), or (f)(6)(i).

In order to obtain authorization or relief, the licensee must demonstrate that (1) the proposed alternatives provide an acceptable level of quality and safety, (2) compliance would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety, or (3) conformance is impractical for its facility.

ASME Code Section XI, Article IWF-5400, " Inservice Tests for Snulners Less Than 50 Kips" requires that an additional sample of 10% of the total 'iumber of snubbers shall be tested when a snubber fails. The licensee propose to conduct additional sample testing at ANO in accordance with the Code requirements except for the case where only one type of snubber fails.

If the failure occurs to only one type of si.ubber, the licensee proposes to conduct the additional sample testing in accordance with the AND Technical Specifications (TSs).

The AN0 TS requirements do not differentiate between snubbers less than 50 kips (IWF-5400) and snubbers 50 kips and greater (IWF-5300). TS Sections 4.16.1.d and 4.7.8.d for ANO-l&2, respectively, state that if during functional testing, additional sampling is required due to failure of only one type of snubber, the functional testing results shall be rer:ewed at that time to determine if additional samples should be limited to the type of snubber which has failed the functional testing.

In the March 26, 1992 letter, the licensee states that in some instances targeting the selection of additional test samples to snubbers of the same 1

type as the failed snubber would adequately address Code requirements, and in 9305280321 930519 P

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Mr. Jerry W. Yelverton.

fact may be conservative following certain types of failure.

By making the determination of the sampling selection on a case-by-case basis, assurance will be provided that those instances which warrant a non-specific additional sample are addressed, as well as those situations in which a more specific sample is appropriate. The licensee further states that the determination will be based upon engineering judgement on important factors such as failure mechanism, operating environments, size and manufacturer. With this approach, the licensee states that it will be able to determine the extent of what appears to be a generic concern.

Based on the above information, the staff concludes that the licensee's alternative sampling method is acceptable because it provides a level of assurance of snubber reliability that is comparable to the ASME Code by tailoring the sample to be examined to the specific problem identified.

In addition, to satisfy the requirements of Functional Tests, as stipulated in the ANO-l&2 TSs, the licensee must ensure that snubbers placed in the same locations as snubbers which failed the previous functional test shall be retested at the time of the next functional test, but shall not be included in the sample plan.

Accordingly, pursuant to 10 CFR 50.55a(a)(3)(i), the staff is granting relief from the additional sampling requirements of Article IWF-5400 of Section XI of the ASME Code, as requested by the licensee, since the licensee's proposed alternative provides an acceptable level of quality and safety. The staff has determined that the granting of relief is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.

In making this determination, the staff has given due consideration to the burden that could result if the applicable ASME Code requirements were imposed on your facilities. This letter grants the relief identified above for ANO-l&2.

This action closes TAC Nos. MS3083 and MS3084.

Sincerely, ORIGINAL SIGNED BY:

Terence L. Chan, Acting Director Project Directorate IV-1 Division of Reactor Projects - III/IV/V Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION:

Docket File JRoe PNoonan ACRS (10)

THurley/FMiraglia NRC & LPDRs MVirgilio TAlexion ABeach, RIV JPartlow PD4-1 r/f TChan RBevan JNorberg OGC JLieberman GHill(4)

ERossi OC/LFDCB OPA JMitchell

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D/PD4-k NAME boM b TAlexiob lRBevan N JNorberg MYoung TChanh bh/93 f hh/93 5/12/93 5/14/93 i //7 /93 DATE ' ') /Ff/93

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I Mr. Jerry W. Yelverton !

fact may be conservative following certain types of failure. By making the determination of the sampling selection on a case-by-case basis, assurance will be provided that those instances which warrant a non-specific additional sample are addressed, as well as those situations in which a more specific sample is appropriate. The licensee further states that the determination will be based upon engineering judgement on important factors such as failure mechanism, operating environments, size and manufacturer. With this approach, the licensee states that it will be able to determine the extent of what ~

appears to be a generic concern.

l Based on the above information, the staff concludes that the licensee's i

alternative sampling method is acceptable because it provides a level of i

assurance of snubber reliability that is comparable to the ASME Code by i

tailoring the sample to be examined to the specific problem identified.

In l

addition, to satisfy the requirements of Functional Tests, as stipulated in i

the ANO-1&2 TSs, the. licensee must ensure that snubbers placed in the same r

locations as snubbers which failed the previous functional test shall be' retested at the time of the next functional test, but shall not be included in the sample plan.

1 Accordingly-pursuant to 10 CFR 50.55a(a)(3)(1), the staff is granting relief from the additional sampling requirements of Article IWF-5400 of Section XI of the ASME Code, as requested by the licensee, since the licensee's proposed t

alternative provides an acceptable level of quality and safety. The staff has determined that the granting of relief is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in-the public interest.

In making this determination, the staff has given due consideration to the burden that could result if the applicable ASME Code i

requirements were imposed on your facilities. This letter grants the relief identified above for ANO-1&2.

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This action closes TAC Nos. M83083 and M83084.

Sincerejy, NW

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rence L. Chan, Acting Director Project Directorate IV-I Division of Reactor Projects - III/IV/V-Office of Nuclear Reactor Regulation cc:

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Entergy Operations, Inc.

Arkansas Nuclear One, Units 1 & 2 E

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cc:

Mr. Donald C. Hintz, President Mr. John R. McGaha and Chief Executive Officer Vice President, Operations Support l

Entergy Operations, Inc.

Entergy Operations, Inc.

P. O. Box 31995 P. O. Box 31995 Jackson, Mississippi 39286 Jackson, Mississippi 39286 Mr. Robert B. McGehee Mr. James J. Fisicaro Wise, Carter, Child & C naway Director, Licensing P. O. Box 651 Entergy Operations, Inc.

Jackson, Mississippi 39205 Route 3 Box 137G Russellville, Arkansas 72801 Mr. Charles B. Brinkman, Manager j

Washington. Nuclear Operations Mr. Nicholas S. Reynolds ABB Combustion Engineering Nuclear Power Winston & Strawn 12300 Twinbrook Parkway, Suite 330 1400 L Street, N.W.

Rockville, Maryland 20852 1

Washington, D.C.

20005-3502 Admiral Kinnaird R. McKee, USN (Ret) l Mr. Robert B. Borsum 214 South Morris Street

't Licensing Representative Oxford, Maryland 21654 4

B&W Nuclear Technologies

'l 1700 Rockville Pike, Suite 525 Mr. - Michael B. ~ Sellman 1

Rockville, Maryland 20852 General Manager, Plant Operations l

Entergy Operations, Inc.

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Senior Resident Inspector Route 3, Box 137G U.S. Nuclear Regulatory Commission Russellville, Arkansas 72801 1-Nuclear P1 ant Road i

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Russellville, Arkansas 72801 Regional Administrator, Region IV t

U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington,- Texas-76011 l

Honorable Joe W. Phillips i

County Judge of Pope County Pope County Courthouse Russellville, Arkansas 72801 Ms. Greta Dicus, Director Division of Radiation Control and Emergency Management-t JArkansas Department of Health -

~4815 West Markham Street Little Rock, Arkansas 72205-3867 i

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