ML23104A105

NRR E-mail Capture - ANO-2 Final RAI Alternative Request for Life-of-Repair of RVCH Pen. 46

ML23104A105
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/10/2023
From:	Thomas Wengert NRC/NRR/DORL/LPL4
To:	Keele R Entergy Operations
Wengert T
References
L-2023-LLR-0000
Download: ML23104A105 (5)

Text

From: Thomas Wengert Sent: Friday, March 10, 2023 8:30 AM To: Keele Jr, Riley D Cc: CLARK, ROBERT W; Jennifer Dixon-Herrity

Subject:

ANO-2 Final RAI RE: Alternative Request for Life-of-Repair of RVCH Pen. #46 (EPID L-2023-LLR-0000)

Attachments: ANO Final RAI RE RVCH Pen 46 Nozzle Life-of-Repair Request.pdf On March 7, 2023, 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 the proposed alternative request ANO2-RR-23-001, concerning the half-nozzle repair of Reactor Vessel Closure Head Penetration #46 at Arkansas Nuclear One, Unit 2 (ANO-2).

Subsequently, Entergy confirmed that a clarification of this RAI was not needed and that it would provide a response to this RAI by March 30, 2023. 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).

From: Thomas Wengert Sent: Tuesday, March 07, 2023 9:31 AM To: Keele Jr, Riley D <rkeele@entergy.com>

Cc: CLARK, ROBERT W <RCLARK@entergy.com>; Jennifer Dixon-Herrity <Jennifer.Dixon-Herrity@nrc.gov>

Subject:

ANO-2 Draft RAI RE: Alternative Request for Life-of-Repair of RVCH Pen. #46 (EPID L-2023-LLR-0000)

By letter dated January 20, 2023 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23020A940), Entergy Operations, Inc. (the licensee) submitted a proposed alternative request (ANO2-RR-23-001) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(z)(1) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed alternative submittal includes the fracture mechanics evaluations of the triple point anomaly of the repair weld and the as-left flaw in the original J-groove weld to demonstrate the continued acceptability of previously repaired ANO-2 Reactor Vessel Closure Head Penetration Nozzle No. 46, through the remainder of the current renewed license (July 17, 2038). The licensee performed the nozzle repair, which had been authorized by the Nuclear Regulatory Commission (NRC) staff for one cycle of operation, during Refueling Outage 2R28 (fall 2021).

The 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.

Please contact me if you would like to set up a conference call with the NRC staff to clarify this request for information. If a clarification of this request is not necessary, please provide a response to this RAI by March 28, 2023.

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

Hearing Identifier: NRR_DRMA Email Number: 2040 Mail Envelope Properties (PH0PR09MB7403AA06B0FE0C57AF5480C28FBA9)

Subject:

ANO-2 Final RAI RE Alternative Request for Life-of-Repair of RVCH Pen. #46 (EPID L-2023-LLR-0000)

Sent Date: 3/10/2023 8:30:01 AM Received Date: 3/10/2023 8:29:00 AM From: Thomas Wengert Created By: Thomas.Wengert@nrc.gov Recipients:

"CLARK, ROBERT W" <RCLARK@entergy.com>

Tracking Status: None "Jennifer Dixon-Herrity" <Jennifer.Dixon-Herrity@nrc.gov>

Tracking Status: None "Keele Jr, Riley D" <rkeele@entergy.com>

Tracking Status: None Post Office: PH0PR09MB7403.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 2608 3/10/2023 8:29:00 AM ANO Final RAI RE RVCH Pen 46 Nozzle Life-of-Repair Request.pdf 139807 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

REQUEST FOR ADDITIONAL INFORMATION (RAI)

PROPOSED ALTERNATIVE REGARDING THE HALF-NOZZLE REPAIR OF REACTOR VESSEL CLOSURE HEAD PENETRATION NOZZLE NO. 46 ARKANSAS NUCLEAR ONE, UNIT 2 ENTERGY OPERATIONS, INC.

DOCKET NO. 50-368 By letter dated January 20, 2023 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML23020A940), Entergy Operations, Inc. (the licensee) submitted a proposed alternative request (ANO2-RR-23-001) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(z)(1) for Arkansas Nuclear One, Unit 2 (ANO-2). The proposed alternative submittal includes the fracture mechanics evaluations of the triple point anomaly of the repair weld and the as-left flaw in the original J-groove weld to demonstrate the continued acceptability of previously repaired ANO-2 Reactor Vessel Closure Head Penetration Nozzle No. 46, through the remainder of the current renewed license (July 17, 2038). The licensee performed the nozzle repair, which had been authorized by the Nuclear Regulatory Commission (NRC, the Commission) for one cycle of operation, during Refueling Outage 2R28 (fall 2021). To complete its review of the proposed alternative, the NRC staff requests additional information, as described below.

Regulatory Basis The inservice inspection, including repair and replacement activities, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code), Class 1, 2 and 3 components shall be performed in accordance with the requirements of Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the ASME Code and applicable editions and addenda as required by 10 CFR Part 50 paragraph 50.55a(g), except where specific written relief has been granted or proposed alternative authorized by the Commission.

RAI 1

In the triple anomaly analysis, the licensee identified an analysis limitation regarding the minimum fluid temperature for certain transients (refer to nonpublic enclosure 1 of the letter dated January 20, 2023, Section 5.3, Item 5, Subitem a). In the as-left J-groove weld flaw evaluation, the licensee identified a similar analysis limitation regarding the minimum fluid temperature for certain transients (refer to nonpublic enclosure 1 of the letter, Section 5.4, Item 1 for analysis limitations). Clarify whether the licensee will control these transients during plant operation in such a manner to ensure that the actual transients meet these analysis limitations.

If not, provide justification for why such control of the transients is not necessary, even though the analyses are based on the analysis limitations on the transients.

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RAI 2

In the triple anomaly analysis and as-left J-groove weld flaw evaluation, the licensee included weld residual stresses as part of the applied stresses. Provide a summary description of how the licensee estimated the weld residual stresses. In addition, if applicable, discuss any weld residual stress measurement data, other analysis results (e.g., benchmark results), or the conservatisms associated with the weld residual stress estimation that support the adequacy of the estimation.

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