JAFP-11-0043, Deviation from BWRVIP-25 Inspection Requirements

Deviation from BWRVIP-25 Inspection Requirements

ML110890732
Person / Time
Site:	FitzPatrick
Issue date:	03/30/2011
From:	Joseph Pechacek Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BWRVIP-25, JAFP-11-0043
Download: ML110890732 (2)

Text

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-=-Entergy JAFP-11-0043 March 30, 2011 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-349-6766 Joseph Pechacek Licensing Manager - JAF

Dear Sir or Madam:

Deviation from BWRVIP-25 Inspection Requirements James A. FitzPatrick Nuclear Power Plant Docket No.

50-333 License No.

DPR-59 1.

BWR Vessel and Internals Project, BWR Core Plate Inspection and Flaw Evaluation Guidelines (BWRVIP-25), EPRI Report TR-107284, December 1996 BWRVIP-25 requires that 50% of the core plate rim hold-down bolts of BWR/2-5 plants without repair wedges be examined by enhanced VT-1 from below the core plate (or by UT from above core plate once the technique is developed). However, it was determined that the bolts cannot be inspected by UT due to configuration issues and it has recently been concluded that an EVT-1 exam does not provide meaningful results.

Accordingly, a technical justification for deviation from the BWRVIP guidance was developed.

The technical justification demonstrates that the core plate bolts have a relatively low susceptibility to cracking based on field experience and fabrication practices. In addition, should cracking occur in some bolts, the consequences are mitigated by redundancy in the bolting and associated alignment hardware. Finally, even with the extremely conservative assumptions of failures of both the bolting and the redundant hardware, the SLC system could be used to bring the reactor to a safe shutdown.

The BWRVIP is currently working on developing revised guidance for the com plate bolts and expects to complete that work, including gaining NRC approval of the revised guidance, by 2015. Until such time as new guidance is provided, the James A.

FitzPatrick Nuclear Power Plant (JAF) will perform VT-3 inspections of the core plate bolts from the top side on a periodic basis to ensure that significant degradation is not occurring. Given the low likelihood that the function of the core plate will be compromised by bolting failures, the VT-3 exams constitute an acceptable interim inspection strategy until such time as the BWRVIP develops revised guidance.

JAFP-11-0043 Page 2 of 2 This letter is being transmitted for information only and JAF is not requesting any action from the NRC staff.

Sho Id you have any questions concerning this letter, please contact Mr. Patrick S a la,Man er E gineering Programs and Components, at (315)-349-6174.

Josep Pechacek Licensing Manager Document Components:

001 Transmittal Letter JP/ed cc:

Mr. William Dean Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Office of the Resident Inspector U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. Bhalchandra K. Vaidya Project Manager, LPL1-1 Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulations, Mail Stop: 08C2A Washington, DC 20555 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223-1350 Mr. Jonathan Rowley U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Matt Mitchell U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Francis J. Murray Jr., President NYSERDA 17 Columbia Circle Albany, NY 12203-6399