ML041190424

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Correction to Safety Evaluation Associated with Relief Request No. RR 63 Regarding Risk-Informed Inservice Inspection Program
ML041190424
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 05/13/2004
From: Richard Laufer
NRC/NRR/DLPM/LPD1
To: Kansler M
Entergy Nuclear Operations
Milano P, NRR/DLPM , 415-1457
References
TAC MC0624
Download: ML041190424 (14)


Text

May 13, 2004 Mr. Michael R. Kansler, President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

CORRECTION TO SAFETY EVALUATION ASSOCIATED WITH RELIEF REQUEST NO. RR 63 REGARDING RISK-INFORMED INSERVICE INSPECTION (ISI) PROGRAM, INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 (TAC NO. MC0624)

Dear Mr. Kansler:

By letter dated March 19, 2004, the Nuclear Regulatory Commission (NRC) staff found the risk-informed inservice inspection (RI-ISI) program proposed by Entergy Nuclear Operations, Inc. (ENO) on May 12, 2003, to be an acceptable alternative to the requirements of Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code for certain Class 1 piping welds, based on a risk-informed alternative approach. Therefore, the staff authorized Relief Request No. RR 63, pursuant to 10 CFR 50.55a(a)(3)(i), through the end of the third 10-year ISI interval for Indian Point Nuclear Generating Unit No. 2 (IP2).

The NRC staff has subsequently found a discrepancy in its safety evaluation dated March 19, 2004, supporting Relief Request RR 63. Therefore, a corrected safety evaluation (SE) is enclosed. The corrected text appropriately characterizes the level of review and confidence in the technical adequacy of probablistic risk assessment that the staff has determined is sufficient for authorizing a RI-ISI program. This text, and the supporting staff review effort, is consistent with previously authorized RI-ISI programs. Although the corrections are found on page 4, as identified by the bars in the margin, the entire SE is being provided for completeness. Furthermore, the correction of the identified discrepancy did not alter the conclusions reached in the staffs original SE.

M. Kansler We regret any inconvenience caused by the errors in the SE. If you should have any questions, please do not hesitate to call Mr. Patrick Milano, Senior Project Manager, at 301-415-1457.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

As stated cc w/encl: See next page

M. Kansler We regret any inconvenience caused by the errors in the SE. If you should have any questions, please do not hesitate to call Mr. Patrick Milano, Senior Project Manager, at 301-415-1457.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION PUBLIC T. Chan B. McDermott, RGN-I G. Hill (2)

PDI-1 Reading M. Rubin C. Bixler, RGN-I J. Jolicoeur, EDO A. Howe P. Milano E. Reichelt OGC R. Laufer S. Little S. Dinsmore ACRS Accession Number: ML041190424 OFFICE PDI-1:PM PDI-1:LA EMCB:SC SPSB:SC OGC PDI-1:SC NAME PMilano SLittle TChan MRubin LEZ(NLO) RLaufer DATE 04/22/04 04/22/04 04/26/04 04/26/04 5/13/04 5/13/04 OFFICIAL RECORD COPY

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Gary Taylor Ms. Charlene Faison Chief Executive Officer Manager, Licensing Entergy Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John Herron Director of Oversight Senior Vice President and Entergy Nuclear Operations, Inc.

Chief Operating Officer 440 Hamilton Avenue Entergy Nuclear Operations, Inc. White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Mr. James Comiotes Director, Nuclear Safety Assurance Mr. Fred Dacimo Entergy Nuclear Operations, Inc.

Vice President, Operations Indian Point Energy Center Entergy Nuclear Operations, Inc. 295 Broadway, Suite 2 Indian Point Energy Center P.O. Box 249 295 Broadway, Suite 2 Buchanan, NY 10511-0249 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Mr. Christopher Schwarz Entergy Nuclear Operations, Inc.

General Manager, Plant Operations Indian Point Energy Center Entergy Nuclear Operations, Inc. 295 Broadway, Suite 2 Indian Point Energy Center P. O. Box 249 295 Broadway, Suite 2 Buchanan, NY 10511-0249 P.O. Box 249 Buchanan, NY 10511-0249 Mr. John M. Fulton Assistant General Counsel Mr. Dan Pace Entergy Nuclear Operations, Inc.

Vice President Engineering 440 Hamilton Avenue Entergy Nuclear Operations, Inc. White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Mr. Randall Edington 475 Allendale Road Vice President Operations Support King of Prussia, PA 19406 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Senior Resident Inspector, Indian Point 2 White Plains, NY 10601 U. S. Nuclear Regulatory Commission 295 Broadway, Suite 1 Mr. John McCann P.O. Box 38 Director, Nuclear Safety Assurance Buchanan, NY 10511-0038 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Peter R. Smith, President Mr. Dan C. Poole New York State Energy, Research, and PWR SRC Consultant Development Authority 20 Captains Cove Road Corporate Plaza West Inglis, FL 34449 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. William T. Russell PWR SRC Consultant Mr. Paul Eddy 400 Plantation Lane Electric Division Stevensville, MD 21666-3232 New York State Department of Public Service Mr. Alex Matthiessen 3 Empire State Plaza, 10th Floor Executive Director Albany, NY 12223 Riverkeeper, Inc.

25 Wing & Wing Mr. Charles Donaldson, Esquire Garrison, NY 10524 Assistant Attorney General New York Department of Law Mr. Paul Leventhal 120 Broadway The Nuclear Control Institute New York, NY 10271 1000 Connecticut Avenue NW Suite 410 Mayor, Village of Buchanan Washington, DC, 20036 236 Tate Avenue Buchanan, NY 10511 Mr. Karl Coplan Pace Environmental Litigation Clinic Mr. Ray Albanese 78 No. Broadway Executive Chair White Plains, NY 10603 Four County Nuclear Safety Committee Westchester County Fire Training Center Mr. Jim Riccio 4 Dana Road Greenpeace Valhalla, NY 10592 702 H Street, NW Suite 300 Ms. Stacey Lousteau Washington, DC 20001 Treasury Department Entergy Services, Inc. Mr. Robert D. Snook 639 Loyola Avenue Assistant Attorney General Mail Stop: L-ENT-15E State of Connecticut New Orleans, LA 70113 55 Elm Street P.O. Box 120 Mr. William DiProfio Hartford, CT 06141-0120 PWR SRC Consultant 139 Depot Road East Kingston, NH 03827

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. David Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELIEF REQUEST NO. RR 63 REGARDING RISK-INFORMED INSERVICE INSPECTION PROGRAM ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NUMBER 50-247

1.0 INTRODUCTION

By letter dated May 12, 2003 (Reference 1), Entergy Nuclear Operations, Inc. (Entergy or the licensee) proposed a risk-informed inservice inspection (RI-ISI) program as an alternative to a portion of their current inservice inspection (ISI) program for Indian Point Nuclear Generating Unit No. 2 (IP2). The scope of the RI-ISI program is limited to the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) Class 1 piping, Categories B-F and B-J welds.

The licensees RI-ISI program was developed in accordance with the methodology contained in the Electric Power Research Institute (EPRI) Report TR-112657, Revision B-A (Reference 2),

which was previously reviewed and approved by the Nuclear Regulatory Commission (NRC) staff in a safety evaluation dated October 28, 1999. The RI-ISI program proposed by the licensee is an alternative pursuant to Section 50.55a(a)(3)(i) of Title 10 of the Code of Federal Regulations (10 CFR). The licensee is requesting the alternative for the third 10-year ISI interval at IP2.

2.0 BACKGROUND

2.1 Applicable Requirements 10 CFR 50.55a(g) requires that ISI of the ASME Code Class 1, 2, and 3 components be performed in accordance with Section XI of the ASME Code, Rules for Inservice Inspection of Nuclear Power Plant Components (hereinafter called Code) and applicable addenda, except where specific relief has been granted by the Commission pursuant to 10 CFR 50.55a(g)(6)(i).

The regulation 10 CFR 50.55a(a)(3) states in part that alternatives to the requirements of paragraph (g) may be used, when authorized by the NRC, if the licensee demonstrates that the proposed alternatives would provide an acceptable level of quality and safety, or if the specified requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Enclosure

Pursuant to 10 CFR 50.55a(g)(4), ASME Code Class 1, 2, and 3 components (including supports) must meet the requirements set forth in the Code, to the extent practical within the limitations of design, geometry, and materials of construction of the components. The regulations require that ISI of components conducted during the first 10-year interval and subsequent intervals comply with the requirements in the latest edition and addenda of the Code incorporated by reference in 10 CFR 50.55a(b) 12 months prior to the start of the 120-month interval, subject to the limitations and modifications listed therein. IP2 is currently in the third period of its third ISI interval. IP2 began its third 10-year ISI interval on July 1, 1994.

The applicable edition of the ASME Code,Section XI, for IP2 is the 1989 Edition with no Addenda.

2.2 Summary of Proposed Approach The licensee has proposed to use an RI-ISI program for ASME Class 1 piping (Examination Categories B-F and B-J welds), as an alternative to the ASME Code,Section XI requirements.

The Code requires in part that for each successive 10-year ISI interval, 100% of Category B-F welds and 25% of Category B-J welds for the Code Class 1 non-exempt piping be selected for volumetric and/or surface examination, based on existing stress analyses and cumulative usage factors. The submittal follows the staff approved RI-ISI process and methodology delineated in EPRI TR-112657, Revision B-A. By assessing piping failure potential and piping failure consequences, and performing probabilistic risk assessment (PRA) and safety significance ranking of piping segments, the number of inspection locations is significantly reduced.

However, the program retains the fundamental requirements of the Code, such as inspection methods, acceptance guidelines, pressure testing, corrective measures, documentation requirements and quality control requirements. Thus, ISI program requirements of other non-related portions of the ASME Code,Section XI are unaffected.

The licensee stated that no augmented programs were affected by the RI-ISI application on Class 1 piping at IP2.

The implementation of an RI-ISI program for piping should be initiated at the start of a plants 10-year ISI interval consistent with the requirements of the ASME Code and Addenda committed to by the licensee in accordance with 10 CFR 50.55a. If the implementation begins within an existing interval, the examinations should be scheduled and distributed consistent with the ASME Code requirements (e.g., the minimum examinations completed at the end of the three inspection periods under ASME Code Program B should be 16 percent, 50 percent, and 100 percent, respectively, and the maximum examinations credited at the end of the respective periods should be 34 percent, 67 percent, and 100 percent).

It is also the NRC staffs view that the inspections for the RI-ISI program and for the balance of the ISI program should be on the same interval start and end dates. This can be accomplished by either implementing the RI-ISI program at the beginning of the interval or merging the RI-ISI program into the ISI program for the balance of the inspections if the RI-ISI program is to begin during an existing ISI interval. One reason for this view is that it eliminates the problem of having different Codes of record for the RI-ISI program and for the balance of the ISI program.

A potential problem with using two different interval start dates and hence two different Codes of record would be having two sets of repair/replacement rules depending upon which program identified the need for repair (e.g., a weld inspection versus a pressure test).

According to the information provided in Reference 1, IP2 is currently in the third period of its third ISI interval. The licensee stated the examinations will be performed during the interval such that the period examination percentage requirements of ASME Code,Section XI, paragraph IWB-2412 will be met.

3.0 EVALUATION Pursuant to 10 CFR 50.55a(a)(3), the NRC staff has reviewed and evaluated the licensees proposed RI-ISI program, including those portions related to the applicable methodology and processes contained in Reference 1, based on guidance and acceptance criteria provided in NRC Regulatory Guides (RGs) 1.174 (Reference 3) and 1.178 (Reference 4) and in Standard Review Plan (SRP) Chapter 3.9.8 (Reference 5).

3.1 Proposed Changes to the ISI Program The scope of the licensees proposed RI-ISI program is limited to ASME Class 1 piping welds for the following Examination Categories: B-F for pressure retaining dissimilar metal welds in vessel nozzles and B-J for pressure retaining welds in piping. The RI-ISI program is proposed as an alternative to the existing ISI requirements of the ASME Code,Section XI. A general description of the proposed changes to the ISI program is provided in Sections 3 and 5 of Reference 1.

During the course of its review, the staff concluded that the proposed RI-ISI program is consistent with the guidelines contained in EPRI TR-112657, which states that industry and plant-specific piping failure information, if any, is to be utilized to identify piping degradation mechanisms and failure modes, and consequence evaluations are to be performed using probabilistic risk assessments to establish piping segment safety ranking for determining new inspection locations. Thus, the staff concludes that the licensees application of the EPRI TR-112657 approach is an acceptable alternative to the current IP2 piping ISI requirements with regard to the number, locations, and methods of inspections, and provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3).

3.2 Engineering Analysis In accordance with the guidance provided in RGs 1.174 and 1.178, an engineering analysis of the proposed changes is required using a combination of traditional engineering analysis and supporting insights from the PRA. The licensee elaborated as to how the engineering analyses conducted for the IP2 RI-ISI program ensure that the proposed changes are consistent with the principles of defense-in-depth. This is accomplished by evaluating a locations susceptibility to a particular degradation mechanism and then performing an independent assessment of the consequence of a failure at that location. No changes to the evaluation of design-basis accidents in the final safety analysis report are being made by the RI-ISI process. Therefore, sufficient safety margins will be maintained.

The licensees RI-ISI program at IP2 is limited to ASME Class 1 piping welds. The licensee stated in its submittal that other non-related portions of the ASME Code will be unaffected by this program. Piping systems defined by the scope of the RI-ISI program were divided into piping segments. Pipe segments are defined as lengths of pipe whose failure leads to similar consequences and are exposed to the same degradation mechanisms. That is, some lengths

of pipe whose failure would lead to the same consequences may be split into two or more segments when two or more regions are exposed to different degradation mechanisms. The submittal states that failure potential categories were generated utilizing industry failure history, plant-specific failure history, and other relevant information using the guidance provided in EPRI TR-112657. The degradation mechanisms identified in the submittal include thermal fatigue including thermal stratification, cycling and striping (TASCS) and thermal transients (TT), and intergranular stress-corrosion cracking (IGSCC).

3.3 Probabilistic Risk Assessment (PRA)

As stated in its submittal, the licensee used the Individual Plant Examination (IPE) model dated August 1992, to evaluate the consequences of pipe rupture for the RI-ISI assessment. The staff evaluation report (SER) of the IPE, dated August 14, 1996, concluded that Revision 0 of the IP2 IPE satisfied the intent of Generic Letter (GL) 88-20, Individual Plant Examination for Severe Accident Vulnerabilities. The staffs SER did not report any significant weaknesses or deficiencies found during the review of the IP2 IPE. The current PRA was revised in 2002. The revised model underwent the Westinghouse Owners Group peer certification review. The licensee stated that there were no significant findings identified during the peer review that would impact the RI-ISI consequence evaluation. Results from the updated PRA were used to confirm that the consequence evaluations developed to support the RI-ISI submittal were current. The core damage frequency (CDF) and large early release frequency (LERF) for the revised model is 2.27E-5/year and 1.03E-6/year, respectively.

The staff did not review the IPE analysis to assess the accuracy of the quantitative estimates.

The staff recognizes that the quantitative results of the IPE are used as order of magnitude estimates for several risk and reliability parameters used to support the assignment of segments into three broad consequence categories. Inaccuracies in the models or in assumptions large enough to invalidate the broad categorizations developed to support RI-ISI should have been identified during the staffs review of the IPE and by the licensees model update control program. Minor errors or inappropriate assumptions will affect only the consequence categorization of a few segments and will not invalidate the general results or conclusions. The staff finds the quality of the licensees PRA sufficient to support the proposed RI-ISI program.

As required by Section 3.7 of the EPRI TR-112657, the licensee evaluated the change in risk expected from replacing the current ISI program with the RI-ISI program. The licensee performed a qualitative evaluation of the change in risk. The RI-ISI program inspects 14 more locations in the population of welds placed in the high risk category than the ASME Code,Section XI program inspected in the same population. The RI-ISI program will inspect two fewer locations in the population of welds placed in the medium risk locations than the ASME Code,Section XI program inspected in the same population. Even without considering the conservatism in that the decrease in risk from adding an inspection in a high risk weld is larger than the increase in risk from discontinuing an inspection at a medium risk weld, the net increase of 12 additional weld inspections in the high and medium risk weld population indicates that there is a reduction in risk associated with the implementation of the proposed RI-ISI program. As discussed in the EPRI TR-112657, discontinued inspections in the low risk significant population contribute negligibly to the change in risk and are not included in the change in risk estimate.

The staff finds the licensees process to evaluate and bound the potential change in risk reasonable because it accounts for the change in the number and location of elements inspected, and incorporates the difference in risk between the different locations. Therefore, the staff concludes that the implementation of the RI-ISI program as described in the licensees application will have a small impact on risk consistent with the guidelines of RG 1.174.

3.4 Integrated Decisionmaking As described in the licensees submittal, an integrated approach is utilized in defining the proposed RI-ISI program by considering in concert the traditional engineering analysis, risk evaluation, and the implementation and performance monitoring of piping under the program.

This is consistent with the guidelines of RG 1.178.

The selection of pipe segments to be inspected using the results of the risk category rankings and other operational considerations is described in Section 3.5 of the submittal. Table 3.5-1 of the submittal provides the number of locations and inspections by risk category for the various IP2 systems. Table 5-1 provides a table comparing the number of inspections required under the existing ASME Code,Section XI ISI program with the alternative RI-ISI program. The risk impact analysis results for each system are provided in Table 3.6-1. The licensee used the methodology described in EPRI TR-112657 to guide the selection of examination elements within high and medium risk ranked piping segments. The EPRI TR-112657 report describes targeted examination volumes (typically associated with welds) and methods of examination based on the type(s) of degradation expected. The staff has reviewed these guidelines and has determined that, if implemented as described, the RI-ISI examinations should result in improved detection of service-related degradations over those currently required by ASME Code,Section XI.

The staff finds that the location selection process is acceptable since it is consistent with the process approved for EPRI TR-112657, takes into account defense-in-depth, and includes consideration of degradation mechanisms in addition to those covered by augmented inspection programs.

3.5 Implementation and Monitoring Implementation and performance monitoring strategies require careful consideration by the licensee and are addressed in Element 3 of RG 1.178 and SRP 3.9.8. The objective of Element 3 is to assess the performance of the affected piping systems under the proposed RI-ISI program by implementing monitoring strategies that confirm the assumptions and analyses used in the development of the RI-ISI program. To approve an alternative pursuant to 10 CFR 50.55a(a)(3)(i), implementation of the RI-ISI program, including inspection scope, examination methods, and methods of evaluation of examination results, must provide an acceptable level of quality and safety. The licensee confirmed that the applicable portions of the ASME Code, such as inspection methods, acceptance guidelines, pressure testing, corrective measures, documentation requirements, and quality control requirements would be retained.

The licensee stated in Section 4 of the submittal that the RI-ISI program is a living program and its implementation will require feedback of new relevant information to ensure the appropriate identification of safety significant piping locations. The licensee stated that the RI-ISI program

will be reviewed on an ASME interval basis. In addition, significant changes may require more frequent adjustment as directed by NRC bulletin or GL requirements, or by industry and plant-specific feedback. The licensee stated that they will review and implement industry guidelines that are currently being developed for reviewing and updating RI-ISI programs that were developed using the EPRI TR-112657.

The licensees submittal presented the criteria for engineering evaluation and additional examinations if unacceptable flaws or relevant conditions are found during examinations. The submittal stated that the evaluation will include whether other elements in the segment or segments are subject to the same root cause conditions or degradation mechanisms as the identified flaw or relevant condition. The additional examinations will include high risk significant elements and medium risk significant elements, if needed, up to a number equivalent to the number of elements required to be inspected on the segment or segments during the current outage. If unacceptable flaws or relevant conditions are again found similar to the initial problem, the remaining elements identified as susceptible will be examined. An evaluation of the root cause and degradation mechanism shall be performed to determine the size of the second expansion sample to be examined in the current outage. No additional examinations will be performed if there are no additional elements identified as being susceptible to the same root cause conditions.

The proposed periodic reporting requirements meet existing ASME Code requirements and applicable regulations and, therefore, are considered acceptable. The staff finds that the proposed process for RI-ISI program updates meets the guidelines of RG 1.174 which provide that risk-informed applications should include performance monitoring and feedback provisions.

Therefore, the licensees proposed process for program updates is acceptable.

4.0 CONCLUSION

In accordance with 10 CFR 50.55a(a)(3)(i), proposed alternatives to regulatory requirements may be used when authorized by the NRC when the applicant demonstrates that the alternative provides an acceptable level of quality and safety. In this case, the licensee's proposed alternative is to use the risk-informed process described in the NRC-approved EPRI TR-112657. As discussed in Section 3.0 above, the staff concludes that the licensees proposed RI-ISI program, as described in its submittal, will provide an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i) with regard to the number of inspections, locations of inspections, and methods of inspections.

The staff finds that the results of the different elements of the engineering analysis are considered in an integrated decision-making process. The impact of the proposed change in the ISI program is founded on the adequacy of the engineering analysis and acceptable change in plant risk in accordance with RG 1.174 and 1.178 guidelines.

The IP2 methodology also considers implementation and performance monitoring strategies.

Inspection strategies ensure that failure mechanisms of concern have been addressed and there is adequate assurance of detecting damage before structural integrity is affected. The risk significance of piping segments is taken into account in defining the inspection scope for the RI-ISI program.

System pressure tests and visual examination of piping structural elements will continue to be performed on all Class 1, 2, and 3 systems in accordance with the ASME Code,Section XI program. The RI-ISI program applies the same performance measurement strategies as existing ASME Code requirements and, in addition, increases the inspection volumes at weld locations that are exposed to thermal fatigue.

The IP2 methodology provides for conducting an engineering analysis of the proposed changes using a combination of engineering analysis with supporting insights from a PRA. Defense-in-depth and quality are not degraded in that the methodology provides reasonable confidence that any reduction in existing inspections will not lead to degraded piping performance when compared to existing performance levels. Inspections are focused on locations with active degradation mechanisms as well as selected locations that monitor the performance of system piping.

On the basis of its review of the licensees proposed RI-ISI program, the NRC staff concludes that the program is an acceptable alternative to the current ISI program, which is based on ASME Code,Section XI, requirements for Class 1 welds. Therefore, the licensees proposed alternative is authorized pursuant to 10 CFR 50.55a(a)(3)(i) on the basis that the alternative provides an acceptable level of quality and safety. This safety evaluation authorizes application of the proposed RI-ISI program for the third 10-year ISI interval at IP2.

5.0 REFERENCES

1. Letter, dated May 12, 2003, Fred R. Dacimo to NRC, containing Indian Point Nuclear Generating Unit No. 2, Risk-Informed Inservice Inspection Program, Rev. 0 (Relief Request RR 63).
2. EPRI TR-112657, Revision B-A, Revised Risk-Informed Inservice Inspection Evaluation Procedure, January 2000.
3. NRC RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, July 1998.
4. NRC RG 1.178, An Approach for Plant-Specific Risk-Informed Decision Making:

Inservice Inspection of Piping, September 1998.

5. NRC NUREG-0800, Chapter 3.9.8, Standard Review Plan for Trial Use for the Review of Risk-Informed Inservice Inspection of Piping, September 1998.

Principal Contributors: E. Reichelt S. Dinsmore Date: May 13, 2004