ML022840060
| ML022840060 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/24/2002 |
| From: | Richard Laufer NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Milano, P , NRR/DLPM, 415-1457 | |
| References | |
| TAC MB5503, TAC MB5504 | |
| Download: ML022840060 (10) | |
Text
October 24, 2002 Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
RELIEF REQUEST NOS. 59 AND 3-30 FROM AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE SECTION XI, INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (TAC NOS. MB5503 AND MB5504)
Dear Mr. Kansler:
In a letter dated July 1, 2002, you submitted Relief Request Nos. 59 and 3-30 for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 3), respectively. Relief was requested from the repair requirements of Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) in order to use electric discharge machining (EDM) for contingency repairs on reactor pressure vessel (RPV) head penetration nozzles. Specifically, you requested authorization to use the alternative requirements of later editions of the ASME Code to qualify the EDM process should repairs on the RPV head nozzles or J-groove welds become necessary. You stated that the EDM process would be used, if necessary, to excavate cracks from primary water stress corrosion or other defects and to remove weld crown surfaces of repair welds to facilitate performance of final nondestructive examination (NDE).
The NRC staff reviewed the proposed alternative in Relief Request Nos. 59 and 3-30. The results are provided in the enclosed safety evaluation. The NRC staff has concluded that the proposed alternative to the ASME Code requirements in Relief Request Nos. 59 and 3-30, is acceptable. Pursuant to 10 CFR 50.55a(a)(3)(i), the proposed alternative is authorized for the remainder of the third inservice inspection interval that is for IP2 until April 3, 2006, and for IP3 until July 20, 2009.
M. Kansler If you should have any questions, please contact Patrick Milano at 301-415-1457. This completes the NRC staffs action on TAC No. MB1564.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247
Enclosure:
Safety Evaluation cc w/encl: See next page
M. Kansler If you should have any questions, please contact Patrick Milano at 301-415-1457. This completes the NRC staffs action on TAC No. MB1564.
Sincerely,
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247
Enclosure:
Safety Evaluation cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-1 R/F SRichards RLaufer SCoffin PMilano CLong BPlatchek, R-I SLittle GHill (2)
OGC HNeih, EDO ACRS Accession Number: ML022840060 OFFICE PDI-1:PM PDI-1:LA EMCB:SC* OGC* PDI-1:SC NAME PMilano SLittle SCoffin RHoefling RLaufer DATE 10/24/02 10/24/02 10/16/02 10/10/02 10/24/02 OFFICIAL RECORD COPY
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Mr. Jerry Yelverton Mr. Joseph DeRoy Chief Executive Officer General Manager Operations Entergy Operations Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Indian Point Nuclear Generating Unit 3 Jackson, MS 39213 295 Broadway, Suite 3 P.O. Box 308 Mr. Fred Dacimo Buchanan, NY 10511-0308 Vice President Operations Entergy Nuclear Operations, Inc. Mr. John Kelly Indian Point Nuclear Generating Units 1 & 2 Director of Licensing 295 Broadway, Suite 1 Entergy Nuclear Operations, Inc.
P.O. Box 249 440 Hamilton Avenue Buchanan, NY 10511-0249 White Plains, NY 10601 Mr. Robert J. Barrett Ms. Charlene Fiason Vice President - Operations Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 3 440 Hamilton Avenue 295 Broadway, Suite 3 White Plains, NY 10601 P.O. Box 308 Buchanan, NY 10511-0308 Mr. John McCann Manager, Nuclear Safety and Licensing Mr. Dan Pace Indian Point Nuclear Generating Unit 2 Vice President Engineering Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 295 Broadway, Suite 1 440 Hamilton Avenue P.O. Box 249 White Plains, NY 10601 Buchanan, NY 10511-0249 Mr. James Knubel Mr. Harry P. Salmon, Jr.
Vice President Operations Support Director of Oversight Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. Lawrence G. Temple Mr. John Donnelly General Manager Operations Licensing Manager Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 2 Indian Point Nuclear Generating Unit 3 295 Broadway, Suite 1 295 Broadway, Suite 3 P.O. Box 249 P.O. Box 308 Buchanan, NY 10511-0249 Buchanan, NY 10511-0308
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Mr. Thomas Walsh Mr. J. Spath, Program Director Secretary - NFSC New York State Energy, Research, and Entergy Nuclear Operations, Inc. Development Authority Indian Point Nuclear Generating Unit 2 17 Columbia Circle 295 Broadway, Suite 1 Albany, NY 12203-6399 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Paul Eddy Electric Division Regional Administrator, Region I New York State Department U.S. Nuclear Regulatory Commission of Public Service 475 Allendale Road 3 Empire State Plaza, 10th Floor King of Prussia, PA 19406 Albany, NY 12223 Senior Resident Inspector, Indian Point 2 Mr. Charles Donaldson, Esquire U. S. Nuclear Regulatory Commission Assistant Attorney General 295 Boradway, Suite 1 New York Department of Law P.O. Box 38 120 Broadway Buchanan, NY 10511-0038 New York, NY 10271 Resident Inspectors Office, Indian Point 3 Mr. Ronald Schwartz U.S. Nuclear Regulatory Commission SRC Consultant 295 Broadway, Suite 3 64 Walnut Drive P.O. Box 337 Spring Lake Heights, NJ 07762 Buchanan, NY 10511-0337 Mr. Ronald J. Toole Mr. John M. Fulton SRC Consultant Assistant General Counsel Toole Insight Entergy Nuclear Operations, Inc. 605 West Horner Street 440 Hamilton Avenue Ebensburg, PA 15931 White Plains, NY 10601 Mr. Charles W. Hehl Ms. Stacey Lousteau SRC Consultant Treasury Department Charles Hehl, Inc.
Entergy Services, Inc. 1486 Matthew Lane 639 Loyola Avenue Pottstown, PA 19465 Mail Stop: L-ENT-15E New Orleans, LA 70113 Mayor, Village of Buchanan 236 Tate Avenue Mr. William M. Flynn, President Buchanan, NY 10511 New York State Energy, Research, and Development Authority Mr. Ray Albanese 17 Columbia Circle Executive Chair Albany, NY 12203-6399 Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Alex Matthiessen
Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:
Executive Director Riverkeeper, Inc.
25 Wing & Wing Garrison, NY 10524 Paul Leventhal The Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036 Karl Copeland Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603 Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REQUEST FOR RELIEF NOS. 59 AND 3-30 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 5-286
1.0 INTRODUCTION
By letter dated July 1, 2002, Entergy Nuclear Operations, Inc. (ENO or the licensee), submitted Relief Request Nos. RR-59 and RR-3-30 for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 3), respectively. The licensee requested authorization from the U.S. Nuclear Regulatory Commission (NRC) to use an electrical discharge machining (EDM) process for repairs of reactor pressure vessel (RPV) head penetration nozzles or J-groove welds.
Specifically, the licensee requested authorization to use the alternative requirements of later editions of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) to qualify the EDM process should repairs be necessary. The RPV head penetration nozzles at IP2 and IP3 are considered to be susceptible to primary water stress corrosion cracking (PWSCC). These nozzles are manufactured from Inconel Alloy 600 with ASME Code Section II material designations of SB-166 or SB-167, which are in base material grouping P-No. 43. The licensee plans to utilize the EDM process to excavate PWSCC cracks or defects and remove weld crown surfaces of repair welds to facilitate performance of final non-destructive examination (NDE). The licensee proposes to qualify the EDM process in accordance with IWA-4461.4 of the 1995 Edition, 1997 Addenda of ASME Section XI to allow the use of thermal methods for metal removal without further mechanical processing.
2.0 REGULATORY EVALUATION
Part 50.55a, Codes and standards, of Title 10 of the Code of Federal Regulations (10 CFR 50.55a) requires licensees to comply with the ASME Code requirements for inservice inspections. Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) shall meet the requirements, except the design and access provisions and the preservice examination requirements, set forth in the ASME Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, to the extent practical within the limitations of design, geometry, and materials of construction of the components. Also, 10 CFR 50.55a(a)(3) states, in part, that alternatives to the requirements may be used provided the licensee demonstrates that (i) the proposed alternatives would provide an acceptable level of quality and safety or (ii) compliance with the specified requirements would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety. As part of the licensing basis for IP2 and IP3, the licensee must comply with the 1989 Edition of the ASME Code, with no Addenda.
2.1 Code Requirement Enclosure
In the 1989 Edition of the ASME Code, Subsection IWA-4120(a) of Section XI states that repairs shall be performed in accordance with the owners Design Specification and the original Construction Code (i.e., ASME Section III) of the component or system. Later editions and addenda of the ASME Code, either in their entirety or portions thereof, and code cases may be used.
When performing defect removal on P-No. 43 material, Subsection IWA-4322 states that [i]f thermal processes are used on P-No. 8 and P-No. 43 materials, a minimum of 1/16 in. material shall be removed from the thermally processed area.
3.0 TECHNICAL EVALUATION
3.1 Identification of Applicable Components:
Code Class: 1 Examination Category: B-E Item Numbers: B4.12, B4.13
Description:
Reactor Pressure Vessel (RPV) Head Penetration Nozzles Weld Identification Number: CH-101-101 (Closure Head) 3.2 Licensees Code Relief Request:
Pursuant to 10 CFR 50.55a(a)(3)(i), the licensee requested relief to conduct an alternative thermal removal requirements of IWA-4322 applicable to P-No. 43 materials due to the adverse effects of machining Alloy 600.
3.3 Licencees Proposed Alternative:
In lieu of the Code requirement of mechanically removing 1/16" of material from all thermally processed areas as required by IWA-4322, the licensee proposed to remove the material using the EDM process. The licensee proposed to qualify the EDM process in accordance with the qualification requirements from IWA-4461.4 of the 1995 Edition, 1997 Addenda of ASME Code,Section XI. The qualification requirements of IWA-4451.4 are summarized below:
- a. The qualification test shall consist of 2 coupons of the same P-No. Material to be cut in production.
- b. The qualification coupons shall be cut using the maximum heat input to be used in production.
- c. The thermally cut surface of each coupon shall be visually examined at 10X and shall be free of cracks. The owner shall specify the acceptable surface roughness for the application and shall verify that the qualification coupon meets the criterion.
- d. Each qualification test coupon shall be cross-sectioned, and the exposed surfaces shall be polished, etched with a suitable etchant, and visually examined at 10X. All sectioned surfaces shall be free of cracks.
- e. Corrosion testing of the thermally cut surface and heat-affected zone shall be performed if the cut surface is to be exposed to a corrosive media. Alternatively, corrosion
resistance of the thermally cut surface may be evaluated. The owner shall specify the acceptance criteria.
In addition to the requirements of IWA-4461.4, the licensee stated that it will perform the following:
- 1. Determine the thickness of the heat affected zone (oxide) layer on the cut surface by metallographic examination during EDM process qualification.
- 2. Based upon the heat affected zone (oxide) thickness measurements obtained during the EDM qualification process, remove the heat affected zone (oxide) layer from cut or excavated surfaces when performing repair activities on RPV head penetration nozzles or J-welds.
Based on this proposal, the licensee concluded that its alternative process would provide for an acceptable level of quality and safety with respect to the repair of the RPV head penetration nozzles and welds.
3.4 Staff Evaluation The NRC staff has evaluated the licensees request and supporting information to use Relief Request Numbers RR-59 and RR 3-30, for the EDM process for metal removal should repairs of RPV head penetration nozzles or J-groove welds become necessary at IP2 and IP3.
Although considered a thermal process for removing metal, since it uses an electrical arc, EDM leaves an extremely small oxide layer on the cut surface of the metal remaining after the removal process. The licensee has committed to removing that oxide layer by mechanical means (polishing) after metal removal by the EDM process. The amount of metal removed will be determined by the qualification requirements of Subsection IWA-4461.4 of ASME Code Section XI, 1995 Edition, 1997 Addenda, with the additional requirement that the licensee will determine the thickness of the resultant oxide layer on the cut surfaces as part of the EDM qualification. The thickness of the resultant oxide layer will be determined by metallographic examination. Based on the oxide thickness measurements obtained during the EDM process qualification, post-EDM polishing operations will be performed to ensure that the oxide surface layer is removed. Since Subsection IWA-4461.4 requires the thermally cut surface of each of the two test coupons to be free of cracks, and since the licensee has committed to remove the oxide surface layer, the NRC staff concludes that the proposed alternative provides an acceptable method of weld removal.
4.0 CONCLUSION
On the basis of the above evaluation, the NRC staff concludes that the use of the EDM process is acceptable as an alternative method of metal removal for weld repair or removal of weld crown surfaces of repair welds to facilitate performance of final NDE, should repairs of the RPV head penetration nozzles or J-welds at IP2 and IP3 be necessary. The proposed alternative
provides an acceptable level of quality and safety. Therefore, pursuant to 10 CFR 50.55a(a)(3)(i), the relief requests are authorized for the remainder of the third inservice inspection interval that is for IP2 until April 3, 2006, and for IP3 until July 20, 2009.
Principal Contributor: C. Long Date: October 24, 2002