ML20205D567

Discusses Info Provided in EOI Submittals Dtd 961104,961115 & 990121,which Identified Each & Every Pipe Line for Which Relief Would Be Applied.Forwards SE Supporting Alternative Program Which Includes Evaluation of Flaws

ML20205D567
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/31/1999
From:	Gramm R NRC (Affiliation Not Assigned)
To:	Hutchinson C ENTERGY OPERATIONS, INC.
Shared Package
ML20205D571	List: ML20205D567 ML20205D606
References
GL-90-05, GL-90-5, TAC-M97750, TAC-MA2397, TAC-MA3963, TAC-MA4919, NUDOCS 9904020241
Download: ML20205D567 (4)

Text

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. h eer g . h

._ k UNITED STATES

} NUCLEAR REGULATORY COMMISSION j' WASHINGTON, D.C. 30000 4001 March 31, 1999

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Mr. C. Randy Hutchinson Vice President, Operations ANO Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801

SUBJECT:

ARKANSAS NUCLEAR ONE, UNITS 1 AND 2, REQUEST FOR GENERIC RELIEF FROM ASME SECTION XI FOR SERVICE WATER SYSTEM MICROBIOLOGICALLY INDUCED CORROSION FLAWS (TAC NOS. M97750, MA4919, MA2397 AND MA3963)

Dear Mr. Hutchinson:

The Nuclear Regulatory Commission staff has evaluated the information provided in your submittal dated November 4,1996 (OCAN119602), supplemented with a minor correction on November 15,1996 (OCAN119608), and further supplemented by your letter dated January 21, 1999 (OCAN019902), which identified each and every pipe line for which the relief would be applied.

Based on the evaluation of your relief request, we concluded that the performance of an immediate Code repair after each and every newly discovered flaw caused by microbiologically induced corrosion (MIC) would have constituted undue burden (create undue hardship) upon ['

Arkansas Nuclear One (ANO) since the repair may exceed the time limits imposed by the 4 l

I governing Technical Specification (TS). This would necessitate the isolation of portions of the / i service water system that are otherwise structurally sound and capable of performing their intended safety function. Isolating portions of the service water system to perform a Code i repair is not in the best interest of plant safety, given the limited size of the typical flaw resulting r l from this degradation mechanism combined with the monitoring and assessment features built V bl into your alternative program.

Your attemative nrogram includes evaluation of the flaws consistent with the guidelines and acceptance criteria of Generic Letter (GL) 90-05. Upon discovery, each flaw will be documented in your corrective action system. Identification of a structurally inadequate portion of piping will result in the associated piping being declared inoperable and an appropriate TS

- a:' ion will be taken. The through wall flaws that have been demonstrated to not impact the structural capability of the piping segment will be monitored and an augmented inspection program performed on a quarterly basis. You have further stated that all the flaws will be repaired at the next outage exceeding 30 days, but no later than the next scheduled refueling outage. You stated that piping replacements are part of an ongoing effort where tne service 4 water piping !s prioritized and replaced based on ultrasonic testing results. This altemative will be authorized until the completion of the service wate- @ lng replacement project.

While the impracticality of the Code requirements was not shown, the staff finds that relief may be granted pursuant to 10 CFR 50.55a(a)(3)(ii) because compliance with the requirement would 9904020241 990331 (W PDR ADOCK 05000313 - '

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p7 l-Mr. C. Randy Hutchinson - result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff's evaluation and conclusions are contained in the Enclosure.

Tre staff has completed its evaluation of this matter and we are, therefore, closing TAC Nos. M97750 and MA4919.

In addition, by letters dated July 13,1998 (2CAN079802), and October 22,1998 l

(2CAN109804),' the licensee requested relief for two non Code repairs submitted in accordance with the guidance provided in GL 90-05 for leaks identified in service _ water system return piping from the spent fuel pcol cooler. Both of the identified service water leaks were located on piping identified by I;,1e No. 2HBC-81 which is within the scope of the generic relief authorized by this cover letter. Based on conversations with members of your staff on February 10,1999, it has been determined that the piping ~ segments containing the above mentioned leaks have been replaced. Since these pre-identified leaks are within the scope of the generic relief request and that all of the required corrective actions have been completed, the staff has determined that no further review is required for the relief requests dated July 13,1998 (2CAN079802) and Octot,er 22,1998 (2CAN109804). :The staff has completed its evaluation of this matter and we are, therefore, closing TAC Nos. MA2397 and MA3963.

Sincerely, ORIGINAL SIGNED BY:_

Robert A. Gramm, Chief, Section 1 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368

Enclosure:

- As stated

- cc w/ encl: See next page DISTRIBUTION:

Docket File PUBLIC PD41 r/f R. Gramm J. Zwolinski/S. Black G. Georgiev OGC ACRS G. Hi'l (2) ' D. Lange, EDO K. Brockman, RIV N. Hilton C. Norsworthy (RCN) C. Nolan L. Berry DoCJment Name: G:\ANOFINAL\REL97750.WPD

• See Previous Concurrence OFC PDIV-1/PM PDIV-1/PM PDIV-1/LAs ECGB/BC OGC PDIV-1/SC ,

NAME' dn/vw CNolar LBerry k GBacchi* SUttal* RGrb DATE 1 /10/99 J //o /99 - hlY/99 3 /03/99 3/24/99 3/3Y99 l COPY YES/NO YES/NO hES)NO YES/NO YES/NO (75)NO OFFICfAt' RECORD COPY l.

L .

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o Mr. C. Randy Hutchinson 1 result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff's evaluation and conclusions are contained in the Enclosure.

The staff has completed its evaluation of this matter and we are, therefore, closing TAC Nos. M97750 and MA4919.

In addition, by lettera dated July 13,1998 (2CAN079802), and October 22,1998 (2CAN109804), the licensee requested relief for two non-Code repairs submitted in accordance with the guidance provided in GL 90-05 for leaks identified in service water system return piping from the spent fuel pool cooler. Both of the identified service water leaks were located on piping identified by line No. 2HBC-81 which is within the scope of the generic relief authorized by this cover letter. Based on convercations with members of your staff on February 10,1999, l It has been determined that the piping segments containing the above mentioned leaks have been replaced. Since these pre-identified leaks are within the scope of the generic relief request and that all of the required corrective actions have been completed, the staff has determined that no further review is required for the relief requests dated July 13,1998 (2CAN079802) and October 22,1998 (2CAN109804). The staff has completed its evaluation of this matter and we are, therefore, closing TAC Nos. MA2397 and MA3963.

Sincerely, 1 1

W Robert A. Gramm, Chief, Section 1 Project Dioctorate IV & Decommissioning l Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-313 and 50-368 )

Enclosure:

As stated cc w/ encl: See next page L

.y. ..

• Mr. C. Randy Hutchinson Entergy Operations, Inc. Arkansas Nuclear One, Units 1 & 2 cc:

Executive Vice President Vice President, Operations Support

& Chief Op$ rating Officer Entergy Operations, Inc.

. Entergy Operations, Inc. P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway Director, Division of Radiation P. O. Box 651

' Control and Emergency Management Jackson, MS 39205 Arkansaa Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 Manager, Rockville Nuclear Ucer sing Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County

. Pope County Courthouse RusselMlle, AR 72801 L