ML20316A010

NRR E-mail Capture - ANO-1 and ANO-2 - Final RAI Concerning Relief Request EN-20-RR-01

ML20316A010
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/02/2020
From:	Thomas Wengert NRC/NRR/DORL/LPL4
To:	Keele R Entergy Nuclear Operations
Wengert T
References
L-2020-LLR-0076
Download: ML20316A010 (5)

Text

From: Wengert, Thomas Sent: Monday, November 2, 2020 3:32 PM To: Keele Jr, Riley D Cc: Clark, Robert; BICE, DAVID B (ANO); Dixon-Herrity, Jennifer

Subject:

RE: ANO-1 and ANO-2 -- Final RAI Concerning Relief Request EN-20-RR-01 (EPID L-2020-LLR-0076)

Attachments: ANO-1 and -2 Final RAI Concerning EN-20-RR-01.pdf On October 29, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff sent Entergy Operations, Inc. (Entergy) the draft Request for Additional Information (RAI) identified below.

This RAI relates to Relief Request EN-20-RR-01, which would allow the use of the alternative requirements of Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, as described below, for Arkansas Nuclear One, Units 1 and 2.

Entergy subsequently informed the NRC staff that the information requested by the staff was understood and that no additional clarification of the RAI was necessary. A publicly available version of this final RAI (attached with Draft removed) will be placed in the NRCs Agencywide Documents Access and Management System (ADAMS). As agreed, please provide a response to this RAI within 30 days of the date of this request.

From: Wengert, Thomas Sent: Thursday, October 29, 2020 9:24 AM To: Keele Jr, Riley D Cc: Clark, Robert ; BICE, DAVID B (ANO) ; Dixon-Herrity, Jennifer

Subject:

ANO-1 and ANO-2 -- Draft RAI Concerning Relief Request EN-20-RR-01 (EPID L-2020-LLR-0076)

By letter dated May 27, 2020 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20148M343), Entergy Operations, Inc. (the licensee) submitted a relief request (EN RR-01) to use the alternative requirements of Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, 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 in lieu of certain American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, IWA-1000, IWA-4000, and IWA-6000 requirements at Arkansas Nuclear One, Units 1 and 2. The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal and determined that additional information is required to complete the review.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information, as described in the attached request for additional information (RAI), is required for the staff to complete its review of this application. This RAI is identified as draft at this time to confirm your understanding of the information that the NRC staff needs to complete the evaluation. If the request for information is understood, please respond to this RAI within 30 days of the date of this request.

Please contact me if you would like to arrange a conference call with the NRC staff to clarify this request

for additional information.

Tom Wengert Project Manager - Arkansas Nuclear One NRR/DORL/LPL4 (301) 415-4037

Hearing Identifier: NRR_DRMA Email Number: 872 Mail Envelope Properties (DM8PR09MB73680A8E0F07E79BEB48F2348F100)

Subject:

RE: ANO-1 and ANO-2 -- Final RAI Concerning Relief Request EN-20-RR-01 (EPID L-2020-LLR-0076)

Sent Date: 11/2/2020 3:32:00 PM Received Date: 11/2/2020 3:32:00 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 "Keele Jr, Riley D" <rkeele@entergy.com>

Tracking Status: None Post Office: DM8PR09MB7368.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2848 11/2/2020 3:32:00 PM ANO-1 and -2 Final RAI Concerning EN-20-RR-01.pdf 179905 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION (RAI)

OFFICE OF NUCLEAR REACTOR REGULATION Issue Date: 11/2/2020 Relief Request No. EN-20-RR-01 Proposed Alternative to Use ASME Code Case N-752 Entergy Operations, Inc.

Dockets: 05000313-PWR-Arkansas Nuclear 1,05000368-PWR-Arkansas Nuclear 2 EPIDS: L-2020-LLR-0076 By letter dated May 27, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20148M343), Entergy Operations, Inc. (the licensee) submitted a relief request to use the alternative requirements of Code Case N-752, Risk-Informed Categorization and Treatment for Repair/Replacement Activities in Class 2 and 3 Systems,Section XI, Division 1, 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 in lieu of certain ASME Boiler and Pressure Vessel Code,Section XI, IWA-1000, IWA-4000, and IWA-6000 requirements. The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensees submittal and determined that additional information is required to complete the review.

Background

Section 5.2.D, Feedback and Process Adjustment, of the licensees relief request describes how the licensee will review changes to the plant, operational practices, applicable plant and industry operational experience, and update the probabilistic risk assessment (PRA) and categorization and treatment processes, as appropriate. The licensee states, in part, that the approach is consistent with the feedback and adjustment process of [Title 10 of the Code of Federal Regulations (10 CFR) Section 50.69(b)(1)(v]).

Regulatory Basis Compliance with 10 CFR 50.69(b)(1)(v) includes:

The inservice testing requirements in 10 CFR 50.55a(f); the inservice inspection, and repair and replacement (with the exception of fracture toughness), requirements for ASME Class 2 and Class 3 SSCs [structures, systems, and components] in 10 CFR 50.55a(g); and the electrical component quality and qualification requirements in Section 4.3 and 4.4 of IEEE [Institute of Electrical and Electronics Engineers] 279, and Sections 5.3 and 5.4 of IEEE 603-1991, as incorporated by reference in 10 CFR 50.55a(h).

Whereas, 10 CFR 50.69(e) is titled Feedback and process adjustment and states:

(1) RISC [Risk-Informed Safety Class]-1, RISC-2, RISC-3 and RISC-4 SSCs. The licensee shall review changes to the plant, operational practices, applicable plant and industry operational experience, and, as appropriate, update the PRA and SSC categorization and treatment processes. The licensee shall perform this review in a timely manner but no longer than once every two refueling outages.

10/26/2020 10:08:40 AM

(2) RISC-1 and RISC-2 SSCs. The licensee shall monitor the performance of RISC-1 and RISC-2 SSCs. The licensee shall make adjustments as necessary to either the categorization or treatment processes so that the categorization process and results are maintained valid.

(3) RISC-3 SSCs. The licensee shall consider data collected in § 50.69(d)(2)(i) for RISC-3 SSCs to determine if there are any adverse changes in performance such that the SSC unreliability values approach or exceed the values used in the evaluations conducted to satisfy § 50.69(c)(1)(iv). The licensee shall make adjustments as necessary to the categorization or treatment processes so that the categorization process and results are maintained valid.

RAI-1

Explain how 10 CFR 50.69(b)(1)(v) addresses the feedback and adjustment process or provide an update of Section 5.2.D of Relief Request EN-20-RR-01, referencing the rule that addresses the feedback and adjustment process.

10/26/2020 10:08:40 AM