ML20324A641
| ML20324A641 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/19/2020 |
| From: | Thomas Wengert NRC/NRR/DORL/LPL4 |
| To: | Keele R Entergy Operations |
| Wengert T | |
| References | |
| L-2020-LLR-0110 | |
| Download: ML20324A641 (5) | |
Text
From:
Wengert, Thomas Sent:
Thursday, November 19, 2020 10:20 AM To:
Keele Jr, Riley D Cc:
Clark, Robert; BICE, DAVID B (ANO); Dixon-Herrity, Jennifer
Subject:
RE: ANO Final RAI RE: Relief Request ANO1-ISI-034 (EPID L-2020-LLR-0110)
Attachments:
ANO Final RAI Regarding RR ANO1-ISI-034.pdf On November 17, 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 proposed alternative (ANO1-ISI-034) to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-770-5, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR
[Pressurized Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material with or without Application of Listed Mitigation Activities, for Arkansas Nuclear One, Unit 1.
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: Tuesday, November 17, 2020 3:46 PM To: Keele Jr, Riley D Cc: Clark, Robert ; BICE, DAVID B (ANO)
Subject:
ANO Draft RAI RE: Relief Request ANO1-ISI-034 (EPID L-2020-LLR-0110)
By letter dated August 11, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20227A112), Entergy Operations, Inc. (the licensee), proposed an alternative (ANO1-ISI-034) to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-770-5, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material with or without Application of Listed Mitigation Activities, as conditioned by Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50) 55a(g)(6)(ii)(F), for the deferral of the volumetric examination of the High Pressure Injection (HPI) Nozzle D dissimilar metal weld at Arkansas Nuclear One, Unit 1 (ANO-1).
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:
900 Mail Envelope Properties (DM8PR09MB7368A77E8AB2A1BC04B185988FE00)
Subject:
RE: ANO Final RAI RE: Relief Request ANO1-ISI-034 (EPID L-2020-LLR-0110)
Sent Date:
11/19/2020 10:19:53 AM Received Date:
11/19/2020 10:19:00 AM 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 2890 11/19/2020 10:19:00 AM ANO Final RAI Regarding RR ANO1-ISI-034.pdf 156472 Options Priority:
Normal Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
11/17/2020 10:02:59 AM REQUEST FOR ADDITIONAL INFORMATION (RAI)
OFFICE OF NUCLEAR REACTOR REGULATION Issue Date: 11/19/20 RELIEF REQUEST ANO1-ISI-034 DEFERRAL OF VOLUMETRIC EXAMINATION OF HIGH PRESSURE INJECTION NOZZLE D DISSIMILAR METAL WELD Entergy Operations, Inc.
Dockets:
05000313-PWR-Arkansas Nuclear 1 EPIDS:
L-2020-LLR-0110 By letter dated August 11, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20227A112), Entergy Operations, Inc. (the licensee), proposed an alternative (ANO1-ISI-034) to the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-770-5, Alternative Examination Requirements and Acceptance Standards for Class 1 PWR [Pressurized Water Reactor] Piping and Vessel Nozzle Butt Welds Fabricated with UNS N06082 or UNS W86182 Weld Filler Material with or without Application of Listed Mitigation Activities, as conditioned by Title 10 of the Code of Federal Regulations Part 50 (10 CFR 50) 55a(g)(6)(ii)(F), for the deferral of the volumetric examination of the High Pressure Injection (HPI) Nozzle D dissimilar metal weld at Arkansas Nuclear One, Unit 1 (ANO-1). The licensee requested authorization of its proposed alternative under the requirements of 10 CFR 50.55a(z)(1), such that, The proposed alternative would provide an acceptable level of quality and safety.
Requirement/Issue The U.S. Nuclear Regulatory Commission (NRC) staff review has found that the licensees supporting technical basis addresses the structural integrity concern but does not adequately address the basis for leak tightness through the period of the extended inspection frequency in order to be authorized under 10 CFR 50.55a(z)(1).
However, in Section V of the proposed alternative, the licensee identified the regulatory requirements for another option for authorization of this request under 10 CFR 50.55a(z)(2), Hardship without a compensating increase in quality and safety. In Section II of the enclosure to the letter dated August 11, 2020, the licensee provided a hardship basis for the proposed alternative.
The requested extension would allow the next volumetric examination of HPI nozzle D weld to be performed during the same refueling outage as the next required volumetric examination of the other three HPI nozzle welds at ANO-1 (i.e., the dissimilar metal welds at HPI nozzles A, B, and C), which were last examined during the fall 2016 refueling outage (1R26) and are due for reexamination in fall 2022 (1R30). Performance of all four high pressure injection nozzle welds in such a coordinated manner would result in personnel dose savings for the site, promoting As Low As Reasonably Achievable (ALARA) practices associated with this significant non-destructive examination (NDE) activity, and minimizes the human performance challenges by allowing a more focused approach to work by performing the inspection in one outage versus two.
11/17/2020 10:02:59 AM Request To facilitate the NRC staff's review of the licensee's proposed alternative under 10 CFR 50.55a(z)(2), the following additional information is needed to reach a regulatory decision.
RAI-1
Provide an estimate of the radiological dose savings that would be realized by the proposed alternative by performing the inspections all at one time. Include within this estimate all duplication of effort required for the examination for the D HPI nozzle weld alone versus performing the examination in coordination with the other nozzle welds.
RAI-2
Due to the continuing COVID-19 public health emergency, provide an estimate of the additional number of licensee staff and contractors required to perform this examination during the spring 2021 refueling outage and any other relevant details to address minimizing the potential impact on licensee/contractor personnel and to the local community.