ML023170268
| ML023170268 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/13/2002 |
| From: | Milano P NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Milano, P , NRR/DLPM, 415-1457 | |
| References | |
| TAC MB6180 | |
| Download: ML023170268 (6) | |
Text
November 13, 2002 Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - STEAM GENERATOR EXAMINATION PROGRAM FOR 2002 REFUELING OUTAGE (TAC NO.
MB6180)
Dear Mr. Kansler:
By letter dated August 21, 2002, Entergy Nuclear Operations, Inc. (Entergy) provided its proposed steam generator examination program for refueling outage (RFO) 2R15 at Indian Point Nuclear Generating Unit No. 2 (IP2). The program was submitted to the U.S. Nuclear Regulatory Commission (NRC) for review in accordance with IP2 Technical Specification (TS) 4.13.C.1. In a safety evaluation supporting Amendment No. 226 dated April 2, 2002, the NRC staff noted that Entergy had not performed an analysis to determine the plugging criteria for the replacement steam generators. However, Entergy committed to providing a summary of this analysis at least 60 days prior to the first inservice inspection, including the loads considered, the tube support plate conditions (locked or unlocked), a list of guidelines used to support the plugging criteria, and a summary of any departure from the guidelines. On the basis of this commitment, Entergy included this analysis in its August 21 submittal.
During the review of the steam generator examination program, the NRC staff found that Entergy plans to inspect a representative sample of steam generator tubes and internals during RFO 2R15. Entergy will inspect, using eddy current techniques, 100% of the active tubes in all four steam generators with a bobbin coil probe. In addition, Entergy will inspect localized regions of the tubes (e.g., U-bends and the expansion transitions in the hot leg top-of-tubesheet) with a rotating probe containing a Plus Point coil. The NRC staff noted that Entergy does not plan to inspect dings or dents with a rotating probe. However, based on industry experience, there is a low likelihood of dings and dents cracking after the first cycle of operation in steam generators with thermally treated tubing. Should unexpected degradation mechanisms occur in the IP2 steam generators, the NRC staff appreciates that the degradation would be identified through the other planned steam generator tube inspections. Entergy indicated that expansion of the steam generator tube inspection scope will comply with the TSs and the Electric Power Research Institute Pressurized Water Reactor Steam Generator Examination Guidelines. Thus, the NRC staff finds the planned inspections satisfactory.
Entergy submitted Westinghouse Report WCAP-15909, Regulatory Guide 1.121 Analysis for the Indian Point Unit 2 Steam Generators, dated August 2002 which was performed to determine the replacement steam generator tube structural limits. The report stated that the worst-case scenario demonstrated that remaining tube wall thickness can be 0.024 inch and still exhibit adequate margin of safety against steam generator tube burst or collapse. This is consistent with the bases for the steam generator tube plugging limit defined in the TSs.
M. Kansler Therefore, Entergy concluded the Regulatory Guide (RG) 1.121 analysis confirmed the adequacy of the current steam generator tube plugging limits contained in the TSs.
The NRC staff noted that Entergy stated that the structural limit criteria are not applicable to circumferential cracks, and that if circumferential cracks were to occur, they would be considered through a degradation specific program. During a conference call between the NRC staff and representatives from Entergy on September 13, 2002, Entergy clarified the following:
1.
Circumferential cracks, should they occur, would be assessed on a case-by-case basis to determine whether they challenged the steam generator tube structural integrity.
2.
Circumferential cracks, should they occur, would be plugged on detection, regardless of size. The staff acknowledges this is common industry practice for circumferential cracks.
3.
If in the future Entergy were to consider leaving a circumferential crack in service, it would notify the NRC in accordance with a previous commitment, documented in a letter to the NRC dated November 7, 2000 (ADAMS Accession No. ML003769327).
The staff noted that the TS plugging limit for steam generator tubing includes assumptions about flaw growth and nondestructive evaluation uncertainties. If circumferential cracks were to occur (or any degradation for that matter), Entergy should consider evaluating the appropriateness of these assumptions.
The staff found that Entergys submittal contained the information in accordance with its prior commitment. Although the staff did not conduct a detailed review of the RG 1.121 analysis, the staff was able to determine, based on the information discussed above, that Entergys conclusions were reasonable and consistent with the plugging limit used for almost all domestic steam generators.
If you should have any questions, please contact me at 301-415-1457.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247 cc: See next page
M. Kansler Therefore, Entergy concluded the Regulatory Guide (RG) 1.121 analysis confirmed the adequacy of the current steam generator tube plugging limits contained in the TSs.
The NRC staff noted that Entergy stated that the structural limit criteria are not applicable to circumferential cracks, and that if circumferential cracks were to occur, they would be considered through a degradation specific program. During a conference call between the NRC staff and representatives from Entergy on September 13, 2002, Entergy clarified the following:
1.
Circumferential cracks, should they occur, would be assessed on a case-by-case basis to determine whether they challenged the steam generator tube structural integrity.
2.
Circumferential cracks, should they occur, would be plugged on detection, regardless of size. The staff acknowledges this is common industry practice for circumferential cracks.
3.
If in the future Entergy were to consider leaving a circumferential crack in service, it would notify the NRC in accordance with a previous commitment, documented in a letter to the NRC dated November 7, 2000 (ADAMS Accession No. ML003769327).
The staff noted that the TS plugging limit for steam generator tubing includes assumptions about flaw growth and nondestructive evaluation uncertainties. If circumferential cracks were to occur (or any degradation for that matter), Entergy should consider evaluating the appropriateness of these assumptions.
The staff found that Entergys submittal contained the information in accordance with its prior commitment. Although the staff did not conduct a detailed review of the RG 1.121 analysis, the staff was able to determine, based on the information discussed above, that Entergys conclusions were reasonable and consistent with the plugging limit used for almost all domestic steam generators.
If you should have any questions, please contact me at 301-415-1457.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247 cc: See next page DISTRIBUTION:
PUBLIC PDI-1 R/F S. Richards R. Laufer L. Lund, EMCB P. Milano C. Khan K. Karwoski P. Eselgroth, R-I D. Lew, R-I S. Little B. Platchek, R-I ACRS OGC ADAMS ACCESSION NO.: ML023170268 See previous concurrence OFFICE PDI-1\\PM PDI-1\\LA EMCB\\SC*
PDI-1\\SC NAME PMilano SLittle LLund RLaufer DATE 11/08/02 11/8/02 11/ 01/02 11/8/02 Official Record Copy
Indian Point Nuclear Generating Station Unit 2 Mr. Jerry Yelverton Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Mr. Fred Dacimo Vice President - Operations Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Units 1 & 2 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Robert J. Barrett Vice President - Operations Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Units 3 295 Broadway, Suite 3 P.O. Box 308 Buchanan, NY 10511-0308 Mr. Dan Pace Vice President Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James Knubel Vice President Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher J. Schwarz General Manager Operations Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 2 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. John Kelly Director of Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene Fiason Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John McCann Manager, Nuclear Safety and Licensing Indian Point Nuclear Generating Unit 2 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Mr. Harry P. Salmon, Jr.
Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Thomas Walsh Secretary - NFSC Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 2 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector, Indian Point 2 U. S. Nuclear Regulatory Commission 295 Broadway, Suite 1 P.O. Box 38 Buchanan, NY 10511-0038
Indian Point Nuclear Generating Station Unit 2 Mr. William M. Flynn, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. J. Spath, Program Director New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy Electric Division New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue Mail Stop: L-ENT-15E New Orleans, LA 70113 Alex Matthiessen 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