ML20197A186
| ML20197A186 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 07/01/2020 |
| From: | Thomas Wengert NRC/NRR/DORL/LPL4 |
| To: | Keele R Entergy Operations |
| Wengert T | |
| References | |
| L-2020-LLE-0093 | |
| Download: ML20197A186 (7) | |
Text
From: Wengert, Thomas Sent: Wednesday, July 1, 2020 4:14 PM To: Keele Jr, Riley D Cc: Clark, Robert; BICE, DAVID B (ANO); Dixon-Herrity, Jennifer; Lee, Samson
Subject:
ANO-1/ANO-2 Acceptance Review Draft Supplemental Information Request -
Exemption Request from 10 CFR 50 Appendix B Requirements to Support Application of ASME Code Case N-752 (EPID L-2020-LLE-0093)
Attachments: ANO Draft Request for Supplemental Information for Exemption from Appendix B Requirements for N-752 Items.pdf By letter dated May 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20148M344), Entergy Operations, Inc. (Entergy, the licensee) submitted an exemption request for Arkansas Nuclear One, Units 1 and 2 (ANO). The licensee is requesting an exemption from the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, for the American Society of Mechanical Engineers (ASME)Section XI, Repair/Replacement Programs that are in the scope of Code Case N-752, Risk-informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and Class 3 Systems,Section XI, Division 1.
To complete its acceptance review of this application, the Nuclear Regulatory Commission (NRC) staff requires supplemental information, as described in the attached draft supplemental information request. In accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-109, Revision 2, Acceptance Review Procedures, dated January 16, 2017 (ADAMS Accession No. ML16144A521), Enclosure 2, Guide for Performing Acceptance Reviews, Section 4.1, Discussion of Information Insufficiencies with the Licensee, a conference call should be arranged with the NRC staff no more than 5 working days from this notification to discuss the information required to supplement the application. The licensee may supplement the application within 13 working days following the conference call, as described in LIC-109, Revision 2.
If you have any questions, please contact me at (301) 415-4037.
Tom Wengert USNRC Project Manager - Arkansas Nuclear One NRR/DORL/LPL4 (301) 415-4037
Hearing Identifier: NRR_DRMA Email Number: 680 Mail Envelope Properties (SA9PR09MB59200AF29610821775D17FE28F6C0)
Subject:
ANO-1/ANO-2 Acceptance Review Draft Supplemental Information Request -
Exemption Request from 10 CFR 50 Appendix B Requirements to Support Application of ASME Code Case N-752 (EPID L-2020-LLE-0093)
Sent Date: 7/1/2020 4:14:09 PM Received Date: 7/1/2020 4:14:00 PM From: Wengert, Thomas Created By: Thomas.Wengert@nrc.gov Recipients:
"Clark, Robert" <RCLARK@entergy.com>
Tracking Status: None "BICE, DAVID B (ANO)" <DBICE@entergy.com>
Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Lee, Samson" <Samson.Lee@nrc.gov>
Tracking Status: None "Keele Jr, Riley D" <rkeele@entergy.com>
Tracking Status: None Post Office: SA9PR09MB5920.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1749 7/1/2020 4:14:00 PM ANO Draft Request for Supplemental Information for Exemption from Appendix B Requirements for N-752 Items.pdf 171841 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
DRAFT SUPPLEMENTAL INFORMATION NEEDED EXEMPTION REQUEST FROM APPENDIX B REQUIREMENTS TO SUPPORT APPLICATION OF ASME CODE CASE N-752 ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNITS 1 AND 2 DOCKET NOS. 50-313, 50-368, AND 72-13 By letter dated May 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20148M344), Entergy Operations, Inc. (Entergy, the licensee) submitted an exemption request for Arkansas Nuclear One, Units 1 and 2 (ANO). The licensee is requesting an exemption from the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, for the American Society of Mechanical Engineers (ASME)Section XI, Repair/Replacement Programs that are in the scope of Code Case N-752, Risk-informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and Class 3 Systems,Section XI, Division 1.
On May 27, 2020, in conjunction with the exemption request, the licensee submitted a relief request (ADAMS Accession No. ML20148M343) to use the alternative requirements of ASME Code Case N-752 for determining the risk-informed categorization and for implementing alternative treatment for repair/replacement activities on moderate and high energy Class 2 and 3 items.
The U.S. Nuclear Regulatory Commission (NRC) staff performed an acceptance review of the exemption request in accordance with Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-109, Revision 2, Acceptance Review Procedures, dated January 16, 2017 (ADAMS Accession No. ML16144A521), and determined that the application is unacceptable for review, with opportunity to supplement, because it is lacking sufficient information for the NRC staff to independently verify that the licensees alternative treatments requirements for low safety significant (LSS) items are adequate to assure that they will provide reasonable confidence that the LSS components will perform their safety related functions under design basis conditions. The items required for sufficiency of the exemption request are described below.
Item 1 - Environmental Consideration Background/Regulatory Basis The regulation at 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, states, in part:
(a) Licensing, regulatory, and administrative actions eligible for categorical exclusion shall meet the following criterion: The action belongs to a category of actions which the Commission, by rule or regulation, has 1
declared to be a categorical exclusion, after first finding that the category of actions does not individually or cumulatively have a significant effect on the human environment.
(b) Except in special circumstances, as determined by the Commission upon its own initiative or upon request of any interested person, an environmental assessment or an environmental impact statement is not required for any action within a category of actions included in the list of categorical exclusions set out in paragraph (c) of this section.
The regulation at 10 CFR 51.22(c) identifies the categories for actions that are categorically excluded from the requirement to prepare an environmental assessment or an environmental impact statement.
In Section 5 on page 7 of the enclosure to the exemption request dated May 27, 2020, the licensee provided its environmental consideration. The licensee stated that the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(22).
However, the exclusion at 10 CFR 51.22(c)(22) applies to the Issuance of a standard design approval under [10 CFR part 52], not 10 CFR part 50. The NRC staff notes that 10 CFR 51.22(c)(25) specifies the criteria that must be met for categorical exclusions associated with the granting of an exemption request, not 10 CFR 51.22(c)(22).
Supplemental Information Required Clarify the environmental considerations applicable to this exemption request. If the licensee determines that a categorical exclusion can be applied under 10 CFR 51.22(c)(25), describe how the criteria in this regulation are satisfied. If the criteria for categorical exclusion cannot be satisfied, discuss the applicable environmental considerations that apply with respect to the exemption request.
Item 2 - Quality Assurance Program
Background
In the referenced relief request, Entergy stated that it will implement the Quality Assurance (QA)
Program exemption applicable to ASME Section XI, paragraph IWA-1400(n) and IWA-4000 when performing repair/replacement activities on LSS items. As stated in Code Case N-752, this code case exemption only applies if compliance with 10 CFR 50, Appendix B, or NQA-1 is not required by the NRC at the Owners facility. To address this issue, Entergy submitted an exemption request for the NRCs approval to exempt ANO-1 and ANO-2 from compliance with Entergys 10 CFR 50, Appendix B, QA Program when performing repair/replacement activities on LSS items in accordance with Code Case N-752. In the associated relief request, Entergy stated that its proposed QA Program exemption for this code case application is consistent with the NRCs position on risk-informed programs as specified in 10 CFR 50.69(b)(1)(ix). However, if the exemption is not granted by the NRC, then this QA Program exemption will not and cannot be implemented by Entergy when performing repair/replacement.
In the relief request, Entergy stated that it will implement the exemptions on IWA-1400(j) and IWA-4000 applicable to repair/replacement programs and plans. In lieu of these ASME Section XI administrative controls, Entergy will establish Owner-defined administrative controls as required by paragraph -1420(a) of Code Case N-752 activities in accordance with this code 2
case. Entergy will implement the exemption on IWA-4000 applicable to repair/replacement activities. Article IWA-4000 of the ASME Section XI Code specifies administrative, technical, and programmatic requirements for performing repair/replacement activities on pressure retaining items and their supports. As specified in IWA-4110(b), repair/replacement activities include welding, brazing, defect removal, metal removal by thermal means, rerating, and removing, adding, and modifying items or systems. These requirements are applicable to procurement, design, fabrication, installation, examination, and pressure testing of items within the scope of this Division. In lieu of these IWA-4000 requirements, Entergy will perform repair/replacement activities on LSS items in accordance with an Owner-defined program that complies with paragraph -1420 of Code Case N-752.
In the relief request, Entergy stated that it will implement the documentation exemptions on IWA-6210(d), IWA-6210(e), and IWA-6350. These ASME Section XI paragraphs address preparation and retention of various ASME Section XI records such as Form NIS-2, IWA-4160 verification of acceptability evaluations, IWA-4311 evaluations, Repair/Replacement Plans, and reconciliation documentation. In lieu of these ASME Section XI forms and evaluations, the following repair/replacement activity records shall be retained in accordance with Entergys Owner-defined program for performing repair/replacement activities on LSS items:
x Repair/replacement activity documentation x Evaluations of LSS items that do not comply with requirements of the applicable Construction Code, standards, specifications, and/or design specifications x Evaluations and documentation of design and configuration changes, including material changes.
Regulatory Basis x The General Design Criteria (GDC) of Appendix A to 10 CFR Part 50 establish minimum requirements for the principal design criteria for water-cooled nuclear reactors. GDC 1, Quality Standards and Records, incorporates the quality requirements of 10 CFR Part 50, Appendix B, as criteria for the design, fabrication, erection, and testing of SSCs within the scope of 10 CFR Part 50, Appendix A. ANO-1 and ANO-2 were designed and constructed to meet the intent of the GDC of the Atomic Energy Commission (AEC) as originally proposed in July 1967.
x The regulation in Appendix B, Quality Assurance Criterial for Nuclear Power Plants and Fuel Reprocessing Plants, of 10 CFR Part 50, provides quality assurance (QA) requirements for the design Appendix B to 10 CFR 50 provides QA requirements for the design, construction, and operation of structures, systems, and components (SSCs) that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. These requirements apply to all activities that affect SSC safety-related functions. The general requirements contained in 10 CFR 50, Appendix B, are supplemented by industry standards and NRC regulatory guides that describe specific practices that have been found acceptable by the industry and the staff. While both 10 CFR 50, Appendix B, and the industry standards include provisions for the application of the QA practices commensurate with the importance to safety of the SSCs for which these practices are applied, other regulations require that the explicit criteria of 10 CFR 50, Appendix B, still be applied.
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x The regulation in 10 CFR 50.55a, Codes and Standards, lists the standards that have been approved for incorporation by reference. The regulation in 10 CFR 55a(a)(1)(ii) specifies ASME B&PV Code Section XI.
x The regulation in 10 CFR 50.54(a)(4) requires licensees to submit changes that reduce commitments in a QA Program description for NRC review prior to implementation.
Changes that do not reduce commitments are submitted in accordance with the requirements of 10 CFR 50.71(e).
x The regulation in 10 CFR 50.34(b)(6)(ii) requirements are established for information related to managerial and administrative controls. This information is normally provided by a licensee in a QA Program description; the regulation in 10 CFR 50.34(b)(6)(ii) requires that the information include a discussion of how the applicable 10 CFR Part 50, Appendix B, requirements are satisfied.
x ASME Code Case N-752, Risk-Informed Categorization and Treatments for Repair/Replacement Activities in Class 2 and 3 SystemsSection XI, Division 1, includes provisions for risk-informed categorization of pressure-retaining and components supports for Class 2 and 3 systems exempting Class 2 or Class 3 items categorized as LSS and includes provisions for alternative requirements from the QA requirements of ASME Section XI, IWA-1400(o), which invokes the requirement for a QA Program in accordance with either 10 CFR Part 50 Appendix B or NQA-1.
It is NRC staffs position that the subject exemption request does not include sufficient information to describe the alternative treatments requirements for LSS items that will be implemented by the licensee if the associated relief request for implementation of Code Case N-752 is approved.
Supplemental Information Required Provide a markup of the proposed changes that the licensee will make to the ANO-1 and ANO-2 QA Program description based on the scope of the SSCs exempted from 10 CFR Part 50 Appendix B, the basis for this exemption request. The markup should address, at a minimum:
x A description of those portions of QA Program that remain applicable to the exempted SSCs (e.g., design control, procurement, installation, configuration control, nonconformance, and corrective action).
x A description of the administrative controls for repair/replacement activities.
x A description of the methodology for evaluating changes in configuration, design, fabrication, examination, and pressure-testing requirements used in repair/replacement activities that will ensure structural integrity and leak tightness of the system are sufficient to support design bases functional requirements of the system.
x A detailed description of what constitutes the Owners requirements or modified Owners requirements as permitted by the licensing basis.
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x A detailed description of the program or process that will provide confidence that the items used for repair/replacement activities meet the Construction Code to which the original item was constructed.
x A detailed test program to assure all testing activities required to demonstrate pressure testing of repair/replacement activities be performed in accordance with the requirements of Code of Construction selected for the repair/replacement activity.
x A detailed methodology for performance of repair/replacement activities and associated non-destructive examination (NDE).
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