View source for 2CAN031101, Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend the Type a Test Frequency to 15 Years

{{Adams
| number = ML110660225
| issue date = 03/07/2011
| title = Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend the Type a Test Frequency to 15 Years
| author name = Schwarz C
| author affiliation = Entergy Operations, Inc
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000368
| license number = NPF-006
| contact person = 
| case reference number = 2CAN031101
| document type = Letter type:, Request for Additional Information (RAI)
| page count = 8
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:Entergy Operations, Inc.
1448 S.R. 333 Russellville, AR 72802 Tel 479-858-3110 Christopher J. Schwarz Vice President - Operations Arkansas Nuclear One 2CAN031101 March 7, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
Response to the Request for Additional Information Regarding License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

==REFERENCES:==
: 1. Entergy letter dated June 17, 2010, License Amendment Request Technical Specification Change to Extend the Type A Test Frequency to 15 Years (2CAN061003)
: 2. NRC email dated February 15, 2011, RAI on the LAR for Revision of TS 6.5.16 (TAC No. ME4090)

==Dear Sir or Madam:==

Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TS) via Reference 1. Specifically, the change would allow for the extension of the ten-year frequency of the ANO-2 Type A or Integrated Leak Rate Test (ILRT) required by TS 6.5.16 to 15 years on a permanent basis.
In Reference 2, the NRC determined that additional information was needed to complete the review of Reference 1. Attached are the requests for additional information and corresponding responses.
There are no new commitments in this letter.
If you have any questions or require additional information, please contact Stephenie Pyle at 479-858-4704.

2CAN031101 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 7, 2011.
Sincerely, Original signed by Christopher J. Schwarz CJS/rwc

==Attachment:==
Request for Additional Information cc:     Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 NRC Senior Resident Inspector Arkansas Nuclear One P. O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Kaly Kalyanam MS O-8B1 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Bernard R. Bevill Arkansas Department of Health Radiation Control Section 4815 West Markham Street Slot #30 Little Rock, AR 7220

Attachment to 2CAN031101 Request for Additional Information

Attachment to 2CAN031101 Page 1 of 5 REQUEST FOR ADDITIONAL INFORMATION

===RAI-1===
Condition 2 in the Nuclear Regulatory Commission (NRC) safety evaluation report (SER) for topical report (TR) NEI 94-01 Revision 2-A states that The licensee submits a schedule of containment inspections to be performed prior to and between Type A tests. (Refer to NRC SER Section 3.1.1.3). In addition, Section 9.2.3.2 of NEI 94-01, Revision 2-A, Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, states that in order to provide continuing supplemental means of identifying potential containment degradation, three general visual examinations of accessible containment surfaces (exterior and interior) must be performed between Type A tests and one visual examination prior to a Type A test, if the interval is extended to 15 years.
The purpose of the condition is for the licensee to provide an approximate schedule of inspections of containment surfaces (concrete and steel) covering a typical 15-year interval between and prior to Type A tests that would demonstrate to the NRC staff the licensees understanding and proper implementation of the requirement in Section 9.2.3.2 of NEI 94-01, Revision 2-A. Please note that the NRC staff is not looking for repetition of regulatory requirements and code provisions, as was provided in the LAR, but how they are implemented in order to meet the requirement. Please provide an approximate explicit schedule of containment inspections, in tabular format, covering a typical 15-year ILRT interval at ANO-2 that would clearly and explicitly demonstrate how the requirement in Section 9.2.3.2 of NEI 94-01 would be met. Please provide this information for (a) concrete and (b) steel liner components of the containment pressure boundary. Since the last Type A test at ANO-2 was conducted in November 2000, the next one would be scheduled to be performed by November 2015 if the ILRT interval is extended. ANO-2 could provide a schedule covering this period as a typical example.
An example of such an inspection schedule for steel (only) containment surfaces based on Subsection IWE can be found in Table 1 of the NRC Safety Evaluation report for Nine Mile Point, Unit 2 (ML100730032).

===RESPONSE===
The examinations performed in accordance with the Arkansas Nuclear One, Unit 2 (ANO-2)
American Society of Mechanical Engineers (ASME) Code, Section XI, Subsection IWE/IWL program satisfy the general visual examinations requirements specified in 10 CFR 50, Appendix J, Option B. ASME Code, Section XI, Subsection IWE assures that at least three general visual examinations of metallic components will be conducted before the next Type A test if the Type A test interval is extended to 15 years. This meets the requirements of Section 9.2.3.2 of NEI 94-01, Revision 2-A and Condition 2 in Section 4.1 of the NRC safety evaluation for NEI 94-01, Revision 2.
Visual examinations of accessible concrete containment components in accordance with ASME Code, Section XI, Subsection IWL are performed every five years, resulting in at least three IWL examinations being performed during a 15-year Type A test interval.

Attachment to 2CAN031101 Page 2 of 5 In addition to the IWL examinations, ANO-2 performs a visual inspection of the accessible interior and exterior of the ANO-2 Containment Building Structure prior to any Type A test.
This examination is performed in sufficient detail to identify any evidence of deterioration which may affect the reactor buildings structural integrity or leak tightness. The areas that are inspected include the external surface of the building, the tendon access area, the basement of the building and the wall inside the main steam safety enclosure. The examinations of the inside of the building are performed during Mode 5 or 6. The examination is conducted in accordance with approved plant procedures to satisfy the requirements of the 10 CFR 50 Appendix J Testing Program. The activity is coordinated with the IWL examinations to the extent possible.
Together, these examinations assure that at least three general visual examinations of the accessible containment surfaces (exterior and interior) and one visual examination immediately prior to a Type A test will be conducted before the next Type A test if the Type A test interval is extended to 15 years, thereby meeting the requirements of Section 9.2.3.2 of NEI 94-01, Revision 2-A and Condition 2 in Section 4.1 of the NRC safety evaluation for NEI 94-01, Revision 2.
The following provides an approximate schedule for the containment surface examinations, assuming the Type A test frequency is extended to 15 years.

Attachment to 2CAN031101 Page 3 of 5 General Visual         General Visual Examination of        Examination of Calendar Year          Type A Test (ILRT)
Accessible Exterior   Accessible Interior Surface            (Liner) Surface 2000 (Refueling X                      X                      X Outage 2R14) 2001 2002 (2R15) 2003 (2R16)                                                                  X 2004 2005 (2R17)                                           X 2006 (2R18)                                                                  X 2007 2008 (2R19) 2009 (2R20)                                                                  X 2010                                              X 2011 (2R21) 2012 (2R22)                                                                  X 2013 2014 (2R23)                                           X 2015 (2R24)                    X                      X                      X It should be noted that ANO-2 operates on an 18-month fuel cycle and that the last Type A test was performed in November 2000 during refueling outage 2R14. Based on a 15-year Type A test interval, the next Type A test would be scheduled for 2R24 (2015).

===RAI-2===
The licensees response to Condition 3 in the LAR, submitted June 17, 2010, relates only to the accessible areas of the containment structure potentially subject to degradation. Please provide information of instances during implementation of the containment ISI program in accordance with IWE/IWL at ANO-2, where existence of or potential for degraded conditions in inaccessible areas of the concrete containment structure and metallic liner were identified and evaluated based on conditions found in accessible areas, as required by 10 CFR 50.55a(b)(2)(viii)(E) and 10 CFR 50.55a(b)(2)(ix)(A). If there were any instances of such conditions, discuss the findings and actions taken.

Attachment to 2CAN031101 Page 4 of 5

===RESPONSE===
In accordance with the IWE program, the inaccessible portions of the liner plate are the basemat liner plate, those sections under duct work and under the moisture barrier. This is less than 20% of the total area. From the IWL program, the only inaccessible areas are the buried sections of containment. This represents less than 5% of the total area. To date, there have been no instances in relation to IWE or the IWL examinations where conditions were identified in accessible areas that would indicate the presence of degradation in these inaccessible areas. The ANO-2 IWE/IWL program contains requirements to evaluate the acceptability of the inaccessible areas, if such conditions were identified, in accordance with 10 CFR 50.55a(b)(2)(ix)(A) and 10 CFR 50.55a(b)(2)(viii)(E).
A discussion of the ANO-2 operating experience and evaluation results of the moisture barrier examinations was provided in Entergy submittal dated January 17, 2011 (2CAN011102), in response to a request for additional information related to this same License Amendment Request (Reference Item 2.4).

===RAI-3===
Condition 3 in Section 4.1 of the NRC SE for NEI 94-01, Revision 2-A, requires that licensees address the areas of containment structure potentially subject to degradation. Section 3.1.3 of the NRC SE, in part, states that licensees referencing NEI 94-01, Revision 2-A, in support of a request to amend their TS should also explore/consider such inaccessible degradation susceptible areas in plant-specific inspections, using viable, commercially available non-destructive examination (NDE) methods (such as boroscopes, guided wave techniques, etc.- see Report ORNL/NRC/LTR-02/02, "Inspection of Inaccessible Regions of Nuclear Power Plant Containment Metallic Pressure Boundaries," June 2002 (ADAMS Accession No. ML061230425), for recommendations to support plant-specific evaluations. Please refer to NRC SER Section 3.1.3 and Resolution of NEI Comment 6, for a complete discussion of areas potentially subject to degradation and background for Condition 3.
The staff's intent of this statement in the SER is that licensees should explore and consider NDE techniques such as those discussed in the reference or other methods for inspections of inaccessible degradation-susceptible areas of the containment pressure boundary to support plant-specific evaluations of inaccessible areas, as these advanced technologies become commercially available and viable for implementation in practice in the future. While the staff understands that these techniques may not be commercially viable at the present time, the licensee is requested to identify areas in the ANO-2 containment that are inaccessible and degradation-susceptible, and acknowledge that these NDE technologies would be explored and considered in the future for the examination of inaccessible degradation-susceptible areas of the containment, as these technologies become commercially viable.

Attachment to 2CAN031101 Page 5 of 5

===RESPONSE===
As noted in the response to RAI 2 above, the only areas that the ANO-2 IWE/IWL program identifies as inaccessible are the basemat liner plate, those sections under duct work, under the moisture barrier and the buried sections of concrete. The examinations that have been performed to date have not identified any condition in the accessible areas that would suggest the presence of degradation in these inaccessible areas. Based on this information, ANO-2 has not implemented any new technologies to inspect the inaccessible areas to date.
However, Entergy actively participates in various nuclear utility owners groups, ASME Code committees, and with NEI to maintain cognizance of ongoing developments within the nuclear industry. Industry operating experience is also continuously reviewed to determine its applicability to ANO-2. New, commercially available technologies for the examination of the inaccessible areas of containment are explored and considered as part of these activities.}}