ML042370395
| ML042370395 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 08/23/2004 |
| From: | Gregory Suber NRC/NRR/DRIP/RLEP |
| To: | |
| Suber G, NRR/DRIP/RLEP 301-415-1124 | |
| References | |
| TAC MB8402 | |
| Download: ML042370395 (6) | |
Text
August 23, 2004 LICENSEE:
Entergy Operations, Inc.
FACILITY:
Arkansas Nuclear Station, Unit 2
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE HELD ON JULY 28, 2004, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY OPERATIONS, INC., CONCERNING A REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE ARKANSAS NUCLEAR STATION, UNIT 2, LICENSE RENEWAL APPLICATION (TAC NO. MB8402)
The U.S. Nuclear Regulatory Commission staff (the staff) and representatives of Entergy Operations, Inc., (Entergy) held a telephone conference call (telecon) on July 28, 2004, to discuss and clarify the applicants response to a request for additional information (RAI) concerning the Arkansas Nuclear Station License Renewal Application. provides a listing of the meeting participants. Enclosure 2 contains a RAI that was discussed with the applicant, including a brief description on the status of the item.
The applicant has had an opportunity to comment on this summary.
/RA/
Gregory F. Suber, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket No.: 50-368
Enclosures:
As stated cc w/enclosures: See next page
ML042370395 DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML042370395.wpd OFFICE PM:RLEP SE:RLEP LA:RLEP SC:RLEP NAME GSuber DChen MJenkins SLee DATE 8/23/04 8/ /04 8/16/04 8/23/04
DISTRIBUTION: Licensee: Entergy Operations, Inc. Re: ANO-2, Dated: August 23, 2004:
ADAMS Accession No.: ML042370395 HARD COPY RLEP RF G. Suber (PM)
E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff R. Gramm A. Howell T. Alexion L. Smith RIV R. Nease RIV
Arkansas Nuclear One, Unit 2 cc:
Executive Vice President
& Chief Operating Officer Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 Mr. Mike Schoppman Framatome ANP, Richland, Inc.
Suite 705 1911 North Fort Myer Drive Rosslyn, VA 22209 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.
P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 Garry Young 1448 SR 333 Russellville, AR 72802 Mr. Fred Emerson Nuclear Energy Institute 1776 I St., N.W., Suite 400 Washington, DC 20006-3708 Mr. Jeffrey S. Forbes Site Vice President Arkansas Nuclear One Entergy Operations, Inc.
1448 S. R. 333 Russellville, AR 72801 LIST OF PARTICIPANTS FOR TELEPHONE CONFERENCE CALL TO DISCUSS THE ARKANSAS NUCLEAR STATION, UNITS Unit 2, LICENSE RENEWAL APPLICATION July 28, 2004 Participants Affiliation Rajender Auluck U.S. Nuclear Regulatory Commission (NRC)
David Chen NRC Greg Cranston NRC Natalie Mosher Entergy Operations, Inc. (Entergy)
Alan Cox Entergy Michael Stroud Entergy Lori Potts Entergy Malcolm Patterson Information Systems Laboratories, Inc. (ISL)
Steve Pope ISL POTENTIAL OPEN ITEMS FOR ANO-2 LICENSE RENEWAL APPLICATION Section 3.2 Engineered Safety Feature RAI 3.2-11 Standard Review Plan - License Renewal (SRP-LR) Subsection 3.2.2.2.3.2 states that local loss of material from pitting and crevice corrosion could occur in certain engineered safety feature (ESF) systems components. The Generic Aging Lessons Learned (GALL) Report recommends further evaluation to ensure that this aging effect is adequately managed. In LRA Table 3.2.1, line Item 3.2.1-5, the applicant credits the Primary and Secondary Water Chemistry Control and Containment Leak Rate Test Programs with managing this aging effect. SRP-LR Subsection 3.2.2.2.3.2 recommends verification of the programs effectiveness and identifies one-time inspections as an acceptable method. The Staff also noted that, based on its review of the parameters monitored or locations inspected program element, both programs do not provide a means to allow the applicant to determine the presence or extent of pitting and crevice corrosion.
The applicant is requested to describe how the presence or extent of pitting and crevice corrosion will be detected for the ESF systems components subject to this aging effect, and to provide the basis for assurance that periodic inspections will provide an adequate sample (i.e., frequency and location).
Applicants Response For ESF system components, loss of material due to pitting and crevice corrosion is managed primarily by the Primary and Secondary Chemistry Control Program. This program is a preventive program that is not intended to detect the presence or extent of aging mechanisms.
The effectiveness of the water chemistry programs at ANO-2 has been confirmed through routine component inspections performed by chemistry, maintenance and engineering personnel. This includes the Primary and Secondary, Closed Cooling, and Auxiliary Systems Water Chemistry Programs. These visual inspections were performed when primary and secondary systems were opened for maintenance, when an adverse chemistry trend existed, or when requested by the chemistry or engineering departments. The areas inspected have included areas that are susceptible to the aging effects identified in the license renewal application including the aging mechanisms of pitting and crevice corrosion. In addition, for many reactor coolant system components included in the Primary and Secondary Water Chemistry Control Program, inspection activities within other aging management programs provide additional confirmation of the water chemistry programs effectiveness. These other programs include the Inservice Inspection (ISI), Alloy-600, Cast Austenitic Stainless Steel Evaluation, Pressurizer Examinations, Reactor Vessel Internals Inspection, and Steam Generator Integrity Programs. Some components, such as heat exchangers, have been inspected periodically providing repetitive evidence that water chemistry programs are adequately managing aging effects.
The GALL One Time Inspection Program XI.M32 focuses on the most susceptible material and environment combinations in the most susceptible locations. Items such as heat exchangers, piping and valves normally in standby, and system low points or stagnant areas are representative of these susceptible locations. At ANO-2, inspections have been performed in systems such as emergency feedwater (EFW) and emergency diesel generators (EDGs) which are normally in standby, steam generators, condensate storage tanks, feedwater heaters, moisture separator reheaters, chillers, main steam safety valves, and blowdown heat exchangers. All of these components are made of susceptible materials (stainless and carbon steel) and are exposed to environments (treated water and steam) that would be conducive to aging effects managed by the water chemistry programs. Many components in the steam generators are inspected under other aging management programs that provide additional assurance that significant degradation is not occurring and that the Primary and Secondary Water Chemistry Control Program is effective. These inspection activities include those implemented under the ISI and Steam Generator Integrity Programs. Results of steam generator component inspections are also applicable to main steam, main feedwater and EFW components with the same material and environment combinations.
As additional confirmation of the effectiveness of water chemistry programs, the ANO-2 review of operating experience included a review of condition reports (CRs), CR trending data, and interviews with site personnel regarding water chemistry program operating experience. The operating experience review did not identify component failures or significant adverse conditions that were the result of an ineffective water chemistry program. Also, the CR trending data did not identify recurrent component degradation occurring in the systems covered under these aging management programs. The review of CRs, CR trending data, and personnel interviews provided additional confirmation of water chemistry programs effectiveness.
The combination of inspections under the ISI Program, the Steam Generator Integrity Program, and maintenance and routine chemistry inspections as a whole, constitute a more thorough confirmation of water chemistry aging management program effectiveness than could be obtained from one-time inspections of a sample of items.
Staffs Comments GALL XI.M32 One-Time Inspection states:
The elements of the [one-time inspection] program include: (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation.
While the project team agrees that a large number of opportunities for inspection will occur prior to the period of extended operation, it is not clear that every material and environment combination for which loss of material from pitting and crevice corrosion is an applicable aging effect will be addressed. The staff requests that the applicant confirm that planned activities will provide an appropriate sample for each material and environment combination, or to provide for a review to confirm that each one has been adequately sampled prior to the period of extended operation?
Status: The applicant indicated that it understood the question, and agreed to provide a supplemental response to this question.