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| issue date = 09/23/2010
| issue date = 09/23/2010
| title = Relief Request ANO2-ISI-005 to Extend the Inservice Inspection Interval for the Visual Examination of Accessible Interior to Reactor Vessel Attachment Weld, for Fourth 10-Year Interval
| title = Relief Request ANO2-ISI-005 to Extend the Inservice Inspection Interval for the Visual Examination of Accessible Interior to Reactor Vessel Attachment Weld, for Fourth 10-Year Interval
| author name = Markley M T
| author name = Markley M
| author affiliation = NRC/NRR/DORL/LPLIV
| author affiliation = NRC/NRR/DORL/LPLIV
| addressee name =  
| addressee name =  
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=Text=
=Text=
{{#Wiki_filter:UNITED NUCLEAR REGULATORY WASHINGTON, D.C.
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 23, 2010 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.
September 23, 2010 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc. 1448 S. R. 333 Russellville, AR 72802 SUB..ARKANSAS NUCLEAR ONE, UNIT 2 -REQUEST FOR RELIEF AN02-ISI-005, REQUEST TO EXTEND THE INSERVICE INSPECTION INTERVAL FOR THE VISUAL EXAMINATION OF ACCESSIBLE INTERIOR TO REACTOR VESSEL ATTACHMENT WELD (TAC NO. ME2566)  
1448 S. R. 333 Russellville, AR 72802 SUB..IECT:        ARKANSAS NUCLEAR ONE, UNIT 2 - REQUEST FOR RELIEF AN02-ISI-005, REQUEST TO EXTEND THE INSERVICE INSPECTION INTERVAL FOR THE VISUAL EXAMINATION OF ACCESSIBLE INTERIOR TO REACTOR VESSEL ATTACHMENT WELD (TAC NO. ME2566)


==Dear Sir or Madam:==
==Dear Sir or Madam:==
By letter dated November 4,2009, Entergy Operations, Inc. (the licensee), submitted, pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), a request for relief for the Arkansas Nuclear One, Unit 2 (ANO-2), for visual examination of the accessible interior attachment welds within and beyond the beltline region and a visual examination of the accessible core support structure surfaces of the reactor pressure vessel once each 10-year inservice inspection (lSI) interval.
By letter dated November 4,2009, Entergy Operations, Inc. (the licensee), submitted, pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), a request for relief for the Arkansas Nuclear One, Unit 2 (ANO-2), for visual examination of the accessible interior attachment welds within and beyond the beltline region and a visual examination of the accessible core support structure surfaces of the reactor pressure vessel once each 10-year inservice inspection (lSI) interval.
Specifically, the licensee requested permission to extend, from 10 to 20 years, the lSI interval that is required by Examination Categories B-N-2 and B-N-3 of Table IWB-2500-1 of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition, 2003 Addenda for the third 10-year lSI interval for ANO-2. This proposed alternative is applicable to the third 10-year lSI for the examination categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70 visual examinations.
Specifically, the licensee requested permission to extend, from 10 to 20 years, the lSI interval that is required by Examination Categories B-N-2 and B-N-3 of Table IWB-2500-1 of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition, 2003 Addenda for the third 10-year lSI interval for ANO-2. This proposed alternative is applicable to the third 10-year lSI for the examination categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70 visual examinations.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittal and determined that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes relief request AN02-ISI-005, until the end of the third 1 O-year lSI interval for Examination Categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70, at ANO-2, which are scheduled to be performed in 2018. All other requirements of the ASME Code, Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittal and determined that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes relief request AN02-ISI-005, until the end of the third 1O-year lSI interval for Examination Categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70, at ANO-2, which are scheduled to be performed in 2018.
-2 The NRC staffs safety evaluation is enclosed.
All other requirements of the ASME Code, Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
 
Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.
                                            -2 The NRC staffs safety evaluation is enclosed. If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Safety cc w/encl: Distribution via UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR RELIEF REQUEST REQUEST TO EXTEND B-N-2 AND B-N-3 COMPONENT ENTERGY OPERATIONS, ARKANSAS NUCLEAR ONE, UNIT DOCKET NO.  
Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368
 
==Enclosure:==
 
Safety Evaluation cc w/encl: Distribution via ListServ
 
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST AN02-ISI-005 REQUEST TO EXTEND B-N-2 AND B-N-3 COMPONENT EXAMINATIONS ENTERGY OPERATIONS, INC.
ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-382
 
==1.0    INTRODUCTION==
 
By letter dated November 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093090314), Entergy Operations, Inc. (Entergy, the licensee),
submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the approval for use of an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, Paragraph IWB-2412, Inspection Program B. The proposed alternative was requested under Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(a)(3)(ii).
The licensee requested approval for the use of alternative AN02-ISI-005, to extend the inservice inspection (lSI) interval for visual examinations of the Category B-N-2 components (Interior Attachments Within Beltline Region and Interior Attachments Beyond Beltline Region) and B-N-3 components (Core Support Structure), so that the examinations will be performed at the same time as the examinations of the B-A and B-D components (which are scheduled to occur in 2018).
 
==2.0    REGULATORY EVALUATION==
 
In accordance with 10 CFR 50.55a(g)(4), the licensee is required to perform lSI of ASME Code Class 1, 2, and 3 components and system pressure tests during the first 1O-year interval and subsequent 1O-year intervals that comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b),
subject to the limitations and modifications listed therein.
The ANO-2 Code of record for the inspection of ASME Code Class 1, 2, and 3 components is the 2001 Edition through 2003 Addenda of the ASME Code, Section XI. The regulations in 10 CFR 50.55a(a)(3) state, in part, that the Director of the Office of Nuclear Reactor Regulation may authorize an alternative to the requirements of 10 CFR 50.55a(g). For an alternative to be authorized, as per 10 CFR 50.55a(a)(3)(ii), the licensee must show that following the ASfVlE Enclosure
 
                                                -2 Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
2.1      Background The visual inspection of Category B-N-2 and B-N-3 components to discover whether flaws have initiated, whether pre-existing flaws have extended, and whether pre-existing flaws may have been missed in prior examinations has always been done at the same time as the visual and ultrasonic lSI of Category B-A and B-D components. The licensee submitted a request (Request for Alternative AN02-ISI-004) to extend the lSI of the Category B-A and B-D components from 10 to 20 years by separate letter dated October 29, 2009 (ADAMS Accession No. ML093030136). By letter dated September 21, 2010 (ADAMS Accession No. ML102450654), the NRC staff authorized Request for Alternative AN02-ISI-004. The examinations of Category B-A and B-D components are required to be performed at regular intervals, as defined in Section XI of the ASME Code. Performing all of these inspections at the same time reduces the number of times that the unit's full core and internals must be moved to gain access for the examinations, in addition to significant savings in dose and outage duration.
 
==3.0      TECHNICAL EVALUATION==
 
3.1      Description of Proposed Alternatives In AN02-ISI-005, the licensee proposes the interval for Category B-N-2 and B-N-3 inspections be the same as that for Category B-A and B-D inspections.
3.2      Components for Which Relief is Requested Examination Category                Item Number          Description B-N-2                    B13.50                Interior Attachments Within Beltline Region B-N-2                    B13.60                Interior Attachments Beyond Beltline Region B-N-3                    B13.70                Core Support Structure 3.3      Basis for Proposed Alternatives The basis for the alternative is that performing the visual inspections of the B-N-2 and B-N-3 components on a different schedule than the Category B-A and B-D components would result in significant hardship without a compensating increase in safety. The licensee indicates that the Category B-N-2 and B-N-3 components have been inspected regularly in the past and no significant indications were noted. Likewise, a review of the same Category B-N-2 and B-N-3 inspections at other, similar nuclear power plants have been performed many times without finding a significant indication.
Furthermore, in its letter dated November 4, 2009, the licensee notes that:
The reactor vessel would undergo, as a minimum, the Section XI Examination Category B-P pressure tests and visual examination conducted at the end of
 
                                                  -3 each refueling before plant start-up, as well as leak tests with visual examinations that precede each start-up following maintenance or repair activities.
3.4      NRC Staff Evaluation The NRC staff notes that the inspection of B-N-2 and B-N-3 components can only be done after the fuel and internals are removed from the reactor pressure vessel (RPV), and is usually only done at the same time as the lSI of Category B-A and B-D components. In addition, the licensee's request is consistent with the industry practice of performing the Category B-N-2 and B-N-3 on the same schedule for the lSI for Category B-A and B-D welds.
The licensee's request for alternative, AN02-ISI-004, to perform the B-A and B-D welds on a 20-year interval instead of a Code-required 10-year interval (i.e., postpone it to until the end of the third interval for Categories B-A and B-D components at ANO-2 on March 25, 2020, with the lSI examinations scheduled to occur in 2018) was reviewed by the NRC staff and by letter dated September 21, 2010 (ADAMS Accession No. ML102450654), the staff authorized the request.
The current relief request, AN02-ISI-005, to extend the lSI interval that is required by Examination Categories B-N-2 and B-N-3, is consistent with the industry practice stated in the previous paragraph.
The radiation exposure to establish the conditions for and perform the ASME examination categories B-N-2 and B-N-3 examinations would essentially double if the subject examinations were performed in an outage different from the RPV shell, lower head, and nozzle weld examinations. Additionally, the NRC staff notes that an unnecessary risk is created by the removal of the core barrel to perform a visual examination without a compensating increase in quality or safety.
Finally, all of the previous inspections of Category B-N-2 and B-N-3 components at ANO-2 have not found any significant indications of cracking or any other problems. No evidence of service induced degradation has been noted in the same inspections at other similar nuclear power plants. Additionally, the NRC staff notes that the change in interval for the inspections does not impact the defense-in-depth philosophy.
Based on the above, the NRC staff concludes that performing the examination of the RPV interior attachments and core support structure in an outage different from the RPV shell, head, and nozzle welds inspections would result in hardship or unusual difficulty without a compensating increase in quality or safety. Therefore, the proposed alternative is acceptable under the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval, March 25, 2020.


==1.0 INTRODUCTION==
==4.0     CONCLUSION==


By letter dated November 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093090314), Entergy Operations, Inc. (Entergy, the licensee), submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the approval for use of an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section XI, Paragraph IWB-2412, Inspection Program B. The proposed alternative was requested under Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(a)(3)(ii).
The NRC staff has completed its review of the submittal for AN02-ISI-005 regarding ANO-2.
The licensee requested approval for the use of alternative AN02-ISI-005, to extend the inservice inspection (lSI) interval for visual examinations of the Category B-N-2 components (Interior Attachments Within Beltline Region and Interior Attachments Beyond Beltline Region) and B-N-3 components (Core Support Structure), so that the examinations will be performed at the same time as the examinations of the B-A and B-D components (which are scheduled to occur in 2018).  
The staff concludes that performing the lSI of Category B-N-2 and B-N-3 components every 10 years as required by Section XI of the ASME Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff concludes


==2.0 REGULATORY EVALUATION==
                                                -4 that the Category B-N-2 and B-N-3 inspections may be performed as proposed and the alternative is authorized according to the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval for Categories B-N-2 and B-N-3 components at ANO-2, which are scheduled to be performed in 2018.
All other requirements of the ASME Code, Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
Principal Contributor: C. Fairbanks Date: September 23, 2010


In accordance with 10 CFR 50.55a(g)(4), the licensee is required to perform lSI of ASME Code Class 1, 2, and 3 components and system pressure tests during the first 1 O-year interval and subsequent 1 O-year intervals that comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b), subject to the limitations and modifications listed therein. The ANO-2 Code of record for the inspection of ASME Code Class 1, 2, and 3 components is the 2001 Edition through 2003 Addenda of the ASME Code, Section XI. The regulations in 10 CFR 50.55a(a)(3) state, in part, that the Director of the Office of Nuclear Reactor Regulation may authorize an alternative to the requirements of 10 CFR 50.55a(g).
                                                  -2 The NRC staffs safety evaluation is enclosed. If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
For an alternative to be authorized, as per 10 CFR 50.55a(a)(3)(ii), the licensee must show that following the ASfVlE Enclosure 
Sincerely,
-2 Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. 2.1 Background The visual inspection of Category B-N-2 and B-N-3 components to discover whether flaws have initiated, whether pre-existing flaws have extended, and whether pre-existing flaws may have been missed in prior examinations has always been done at the same time as the visual and ultrasonic lSI of Category B-A and B-D components.
                                                        /RA!
The licensee submitted a request (Request for Alternative AN02-ISI-004) to extend the lSI of the Category B-A and B-D components from 10 to 20 years by separate letter dated October 29, 2009 (ADAMS Accession No. ML093030136).
Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368
By letter dated September 21, 2010 (ADAMS Accession No. ML 102450654), the NRC staff authorized Request for Alternative AN02-ISI-004.
The examinations of Category B-A and B-D components are required to be performed at regular intervals, as defined in Section XI of the ASME Code. Performing all of these inspections at the same time reduces the number of times that the unit's full core and internals must be moved to gain access for the examinations, in addition to significant savings in dose and outage duration.
3.0 TECHNICAL EVALUATION 3.1 Description of Proposed Alternatives In AN02-ISI-005, the licensee proposes the interval for Category B-N-2 and B-N-3 inspections be the same as that for Category B-A and B-D inspections.
3.2 Components for Which Relief is Requested Examination Category Item Number Description B-N-2 B13.50 Interior Attachments Within Beltline Region B-N-2 B13.60 Interior Attachments Beyond Beltline Region B-N-3 B13.70 Core Support Structure 3.3 Basis for Proposed Alternatives The basis for the alternative is that performing the visual inspections of the B-N-2 and B-N-3 components on a different schedule than the Category B-A and B-D components would result in significant hardship without a compensating increase in safety. The licensee indicates that the Category B-N-2 and B-N-3 components have been inspected regularly in the past and no significant indications were noted. Likewise, a review of the same Category B-N-2 and B-N-3 inspections at other, similar nuclear power plants have been performed many times without finding a significant indication.
Furthermore, in its letter dated November 4, 2009, the licensee notes that: The reactor vessel would undergo, as a minimum, the Section XI Examination Category B-P pressure tests and visual examination conducted at the end of 
-3 each refueling before plant start-up, as well as leak tests with examinations that precede each start-up following maintenance or 3.4 NRC Staff Evaluation The NRC staff notes that the inspection of B-N-2 and B-N-3 components can only be done after the fuel and internals are removed from the reactor pressure vessel (RPV), and is usually only done at the same time as the lSI of Category B-A and B-D components.
In addition, the licensee's request is consistent with the industry practice of performing the Category B-N-2 and B-N-3 on the same schedule for the lSI for Category B-A and B-D welds. The licensee's request for alternative, AN02-ISI-004, to perform the B-A and B-D welds on a 20-year interval instead of a Code-required 10-year interval (i.e., postpone it to until the end of the third interval for Categories B-A and B-D components at ANO-2 on March 25, 2020, with the lSI examinations scheduled to occur in 2018) was reviewed by the NRC staff and by letter dated September 21, 2010 (ADAMS Accession No. ML 102450654), the staff authorized the request. The current relief request, AN02-ISI-005, to extend the lSI interval that is required by Examination Categories B-N-2 and B-N-3, is consistent with the industry practice stated in the previous paragraph.
The radiation exposure to establish the conditions for and perform the ASME examination categories B-N-2 and B-N-3 examinations would essentially double if the subject examinations were performed in an outage different from the RPV shell, lower head, and nozzle weld examinations.
Additionally, the NRC staff notes that an unnecessary risk is created by the removal of the core barrel to perform a visual examination without a compensating increase in quality or safety. Finally, all of the previous inspections of Category B-N-2 and B-N-3 components at ANO-2 have not found any significant indications of cracking or any other problems.
No evidence of induced degradation has been noted in the same inspections at other similar nuclear power plants. Additionally, the NRC staff notes that the change in interval for the inspections does not impact the defense-in-depth philosophy.
Based on the above, the NRC staff concludes that performing the examination of the RPV interior attachments and core support structure in an outage different from the RPV shell, head, and nozzle welds inspections would result in hardship or unusual difficulty without a compensating increase in quality or safety. Therefore, the proposed alternative is acceptable under the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval, March 25, 2020.


==4.0 CONCLUSION==
==Enclosure:==


The NRC staff has completed its review of the submittal for AN02-ISI-005 regarding ANO-2. The staff concludes that performing the lSI of Category B-N-2 and B-N-3 components every 10 years as required by Section XI of the ASME Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff concludes 
Safety Evaluation cc w/encl: Distribution via ListServ DISTRIBUTION:
-4 that the Category B-N-2 and B-N-3 inspections may be performed as proposed and the alternative is authorized according to the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval for Categories B-N-2 and B-N-3 components at ANO-2, which are scheduled to be performed in 2018. All other requirements of the ASME Code, Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.
PUBLIC LPL4 r/f RidsAcrsAcnw_lVIailCTR Resource RidsNrrDciCptb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMANO Resource RidsOgcRp Resource RidsRgn4MailCenter Resource CFairbanks, NRR/DCINIB ADAMS Accession No. ML102500128                                      *SE email I OFFICE NRR/LPL4/PM           NRR/LPL4/LA             NRRIDCI/CPTB       NRR/LPL4/BC NAME     NKalyanam             ...1Burkhardt          MMitchell*         MMarkley II DATE     9/22/10               9/17/10                 8/31/10             9/23/10 OFFICIAL RECORD COpy}}
Principal Contributor:
C. Fairbanks Date: September 23, 2010 
-2 The NRC staffs safety evaluation is enclosed.
If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.
Sincerely, /RA! Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.
Safety cc w/encl: Distribution via DISTRIBUTION:
PUBLIC LPL4 r/f RidsAcrsAcnw_lVIailCTR Resource RidsNrrDciCptb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMANO Resource RidsOgcRp Resource RidsRgn4MailCenter Resource CFairbanks, NRR/DCINIB ADAMS Accession No. ML 102500128
*SE email I OFFICE NRR/LPL4/PM NRR/LPL4/LA NRRIDCI/CPTB NRR/LPL4/BC NAME NKalyanam  
...1 Burkhardt MMitchell*
MMarkley II DATE 9/22/10 9/17/10 8/31/10 9/23/10 OFFICIAL RECORD COpy}}

Latest revision as of 14:40, 13 November 2019

Relief Request ANO2-ISI-005 to Extend the Inservice Inspection Interval for the Visual Examination of Accessible Interior to Reactor Vessel Attachment Weld, for Fourth 10-Year Interval
ML102500128
Person / Time
Site: Arkansas Nuclear Entergy icon.png
Issue date: 09/23/2010
From: Markley M
Plant Licensing Branch IV
To:
Entergy Operations
Kalyanam N, NRR/DORL/LPL4, 415-1480
References
ANO2-ISI-005, TAC ME2566
Download: ML102500128 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 23, 2010 Vice President, Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72802 SUB..IECT: ARKANSAS NUCLEAR ONE, UNIT 2 - REQUEST FOR RELIEF AN02-ISI-005, REQUEST TO EXTEND THE INSERVICE INSPECTION INTERVAL FOR THE VISUAL EXAMINATION OF ACCESSIBLE INTERIOR TO REACTOR VESSEL ATTACHMENT WELD (TAC NO. ME2566)

Dear Sir or Madam:

By letter dated November 4,2009, Entergy Operations, Inc. (the licensee), submitted, pursuant to paragraph 50.55a(a)(3)(ii) of Title 10 of the Code of Federal Regulations (10 CFR), a request for relief for the Arkansas Nuclear One, Unit 2 (ANO-2), for visual examination of the accessible interior attachment welds within and beyond the beltline region and a visual examination of the accessible core support structure surfaces of the reactor pressure vessel once each 10-year inservice inspection (lSI) interval.

Specifically, the licensee requested permission to extend, from 10 to 20 years, the lSI interval that is required by Examination Categories B-N-2 and B-N-3 of Table IWB-2500-1 of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition, 2003 Addenda for the third 10-year lSI interval for ANO-2. This proposed alternative is applicable to the third 10-year lSI for the examination categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70 visual examinations.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the licensee's submittal and determined that compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(ii), the NRC staff authorizes relief request AN02-ISI-005, until the end of the third 1O-year lSI interval for Examination Categories B-N-2 and B-N-3, Items B13.50, B13.60, and B13.70, at ANO-2, which are scheduled to be performed in 2018.

All other requirements of the ASME Code,Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

-2 The NRC staffs safety evaluation is enclosed. If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.

Sincerely, Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST AN02-ISI-005 REQUEST TO EXTEND B-N-2 AND B-N-3 COMPONENT EXAMINATIONS ENTERGY OPERATIONS, INC.

ARKANSAS NUCLEAR ONE, UNIT 2 DOCKET NO. 50-382

1.0 INTRODUCTION

By letter dated November 4, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML093090314), Entergy Operations, Inc. (Entergy, the licensee),

submitted a request to the U.S. Nuclear Regulatory Commission (NRC) for the approval for use of an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Paragraph IWB-2412, Inspection Program B. The proposed alternative was requested under Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.55a(a)(3)(ii).

The licensee requested approval for the use of alternative AN02-ISI-005, to extend the inservice inspection (lSI) interval for visual examinations of the Category B-N-2 components (Interior Attachments Within Beltline Region and Interior Attachments Beyond Beltline Region) and B-N-3 components (Core Support Structure), so that the examinations will be performed at the same time as the examinations of the B-A and B-D components (which are scheduled to occur in 2018).

2.0 REGULATORY EVALUATION

In accordance with 10 CFR 50.55a(g)(4), the licensee is required to perform lSI of ASME Code Class 1, 2, and 3 components and system pressure tests during the first 1O-year interval and subsequent 1O-year intervals that comply with the requirements in the latest edition and addenda of Section XI of the ASME Code, incorporated by reference in 10 CFR 50.55a(b),

subject to the limitations and modifications listed therein.

The ANO-2 Code of record for the inspection of ASME Code Class 1, 2, and 3 components is the 2001 Edition through 2003 Addenda of the ASME Code,Section XI. The regulations in 10 CFR 50.55a(a)(3) state, in part, that the Director of the Office of Nuclear Reactor Regulation may authorize an alternative to the requirements of 10 CFR 50.55a(g). For an alternative to be authorized, as per 10 CFR 50.55a(a)(3)(ii), the licensee must show that following the ASfVlE Enclosure

-2 Code requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

2.1 Background The visual inspection of Category B-N-2 and B-N-3 components to discover whether flaws have initiated, whether pre-existing flaws have extended, and whether pre-existing flaws may have been missed in prior examinations has always been done at the same time as the visual and ultrasonic lSI of Category B-A and B-D components. The licensee submitted a request (Request for Alternative AN02-ISI-004) to extend the lSI of the Category B-A and B-D components from 10 to 20 years by separate letter dated October 29, 2009 (ADAMS Accession No. ML093030136). By letter dated September 21, 2010 (ADAMS Accession No. ML102450654), the NRC staff authorized Request for Alternative AN02-ISI-004. The examinations of Category B-A and B-D components are required to be performed at regular intervals, as defined in Section XI of the ASME Code. Performing all of these inspections at the same time reduces the number of times that the unit's full core and internals must be moved to gain access for the examinations, in addition to significant savings in dose and outage duration.

3.0 TECHNICAL EVALUATION

3.1 Description of Proposed Alternatives In AN02-ISI-005, the licensee proposes the interval for Category B-N-2 and B-N-3 inspections be the same as that for Category B-A and B-D inspections.

3.2 Components for Which Relief is Requested Examination Category Item Number Description B-N-2 B13.50 Interior Attachments Within Beltline Region B-N-2 B13.60 Interior Attachments Beyond Beltline Region B-N-3 B13.70 Core Support Structure 3.3 Basis for Proposed Alternatives The basis for the alternative is that performing the visual inspections of the B-N-2 and B-N-3 components on a different schedule than the Category B-A and B-D components would result in significant hardship without a compensating increase in safety. The licensee indicates that the Category B-N-2 and B-N-3 components have been inspected regularly in the past and no significant indications were noted. Likewise, a review of the same Category B-N-2 and B-N-3 inspections at other, similar nuclear power plants have been performed many times without finding a significant indication.

Furthermore, in its letter dated November 4, 2009, the licensee notes that:

The reactor vessel would undergo, as a minimum, the Section XI Examination Category B-P pressure tests and visual examination conducted at the end of

-3 each refueling before plant start-up, as well as leak tests with visual examinations that precede each start-up following maintenance or repair activities.

3.4 NRC Staff Evaluation The NRC staff notes that the inspection of B-N-2 and B-N-3 components can only be done after the fuel and internals are removed from the reactor pressure vessel (RPV), and is usually only done at the same time as the lSI of Category B-A and B-D components. In addition, the licensee's request is consistent with the industry practice of performing the Category B-N-2 and B-N-3 on the same schedule for the lSI for Category B-A and B-D welds.

The licensee's request for alternative, AN02-ISI-004, to perform the B-A and B-D welds on a 20-year interval instead of a Code-required 10-year interval (i.e., postpone it to until the end of the third interval for Categories B-A and B-D components at ANO-2 on March 25, 2020, with the lSI examinations scheduled to occur in 2018) was reviewed by the NRC staff and by letter dated September 21, 2010 (ADAMS Accession No. ML102450654), the staff authorized the request.

The current relief request, AN02-ISI-005, to extend the lSI interval that is required by Examination Categories B-N-2 and B-N-3, is consistent with the industry practice stated in the previous paragraph.

The radiation exposure to establish the conditions for and perform the ASME examination categories B-N-2 and B-N-3 examinations would essentially double if the subject examinations were performed in an outage different from the RPV shell, lower head, and nozzle weld examinations. Additionally, the NRC staff notes that an unnecessary risk is created by the removal of the core barrel to perform a visual examination without a compensating increase in quality or safety.

Finally, all of the previous inspections of Category B-N-2 and B-N-3 components at ANO-2 have not found any significant indications of cracking or any other problems. No evidence of service induced degradation has been noted in the same inspections at other similar nuclear power plants. Additionally, the NRC staff notes that the change in interval for the inspections does not impact the defense-in-depth philosophy.

Based on the above, the NRC staff concludes that performing the examination of the RPV interior attachments and core support structure in an outage different from the RPV shell, head, and nozzle welds inspections would result in hardship or unusual difficulty without a compensating increase in quality or safety. Therefore, the proposed alternative is acceptable under the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval, March 25, 2020.

4.0 CONCLUSION

The NRC staff has completed its review of the submittal for AN02-ISI-005 regarding ANO-2.

The staff concludes that performing the lSI of Category B-N-2 and B-N-3 components every 10 years as required by Section XI of the ASME Code would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. The staff concludes

-4 that the Category B-N-2 and B-N-3 inspections may be performed as proposed and the alternative is authorized according to the provisions of 10 CFR 50.55a(a)(3)(ii) until the end of the third interval for Categories B-N-2 and B-N-3 components at ANO-2, which are scheduled to be performed in 2018.

All other requirements of the ASME Code,Section XI for which relief was not specifically requested and approved in the subject request for relief remain applicable, including third-party review by the Authorized Nuclear Inservice Inspector.

Principal Contributor: C. Fairbanks Date: September 23, 2010

-2 The NRC staffs safety evaluation is enclosed. If you have any questions, please contact Kaly Kalyanam at (301) 415-1480 or via e-mail at kaly.kalyanam@nrc.gov.

Sincerely,

/RA!

Michael T. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-368

Enclosure:

Safety Evaluation cc w/encl: Distribution via ListServ DISTRIBUTION:

PUBLIC LPL4 r/f RidsAcrsAcnw_lVIailCTR Resource RidsNrrDciCptb Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl4 Resource RidsNrrLAJBurkhardt Resource RidsNrrPMANO Resource RidsOgcRp Resource RidsRgn4MailCenter Resource CFairbanks, NRR/DCINIB ADAMS Accession No. ML102500128 *SE email I OFFICE NRR/LPL4/PM NRR/LPL4/LA NRRIDCI/CPTB NRR/LPL4/BC NAME NKalyanam ...1Burkhardt MMitchell* MMarkley II DATE 9/22/10 9/17/10 8/31/10 9/23/10 OFFICIAL RECORD COpy