ML042890389
| ML042890389 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/15/2004 |
| From: | Holden C NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Milano P, NRR/DLPM , 415-1457 | |
| References | |
| EA-03-009, TAC MC3194 | |
| Download: ML042890389 (10) | |
Text
October 15, 2004 Mr. Michael R. Kansler, President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
RELAXATION OF FIRST REVISED ORDER ON REACTOR VESSEL NOZZLES, INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 (TAC NO. MC3194)
Dear Mr. Kansler:
In a letter dated May 19, 2004, as supplemented on August 23, 2004, Entergy Nuclear Operations, Inc. (the licensee), submitted requests for relaxation regarding the inspection of reactor pressure vessel (RPV) head nozzles at Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 3). The relaxations were requested from the interim inspection requirements in the Nuclear Regulatory Commissions (NRCs) First Revised Order Modifying Licenses, EA-03-009, dated February 20, 2004 (First Revised Order).
The NRC staff has reviewed the licensees requested relaxation to implement an alternative to the requirements of Section IV.C.(5)(a) of the First Revised Order for RPV head penetration nozzles at IP2. The results are provided in the enclosed safety evaluation. The relaxation requests for IP3 will be evaluated in a separate letter.
The NRC staff has concluded that the proposed alternative examination of the RPV head provides reasonable assurance of the structural integrity of the RPV head, penetration nozzles, and welds. Further inspections of the RPV head, in accordance with Section IV, paragraph C.(5)(a) of the First Revised Order, would result in hardship without a compensating increase in the level of quality and safety. Therefore, pursuant to Section IV, paragraph F, of the First Revised Order, the NRC staff authorizes the proposed alternative inspection for all future bare-metal visual examinations performed per Section IV, paragraph C.(5)(a), of the First Revised Order, for the RPV head at IP2.
If you should have any questions, please contact Patrick Milano at 301-415-1457.
Sincerely,
/RA/
Cornelius F. Holden, Director 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
October 15, 2004 Mr. Michael R. Kansler, President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
RELAXATION OF FIRST REVISED ORDER ON REACTOR VESSEL NOZZLES, INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 (TAC NO. MC3194)
Dear Mr. Kansler:
In a letter dated May 19, 2004, as supplemented on August 23, 2004, Entergy Nuclear Operations, Inc. (the licensee), submitted requests for relaxation regarding the inspection of reactor pressure vessel (RPV) head nozzles at Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and 3). The relaxations were requested from the interim inspection requirements in the Nuclear Regulatory Commissions (NRCs) First Revised Order Modifying Licenses, EA-03-009, dated February 20, 2004 (First Revised Order).
The NRC staff has reviewed the licensees requested relaxation to implement an alternative to the requirements of Section IV.C.(5)(a) of the First Revised Order for RPV head penetration nozzles at IP2. The results are provided in the enclosed safety evaluation. The relaxation requests for IP3 will be evaluated in a separate letter.
The NRC staff has concluded that the proposed alternative examination of the RPV head provides reasonable assurance of the structural integrity of the RPV head, penetration nozzles, and welds. Further inspections of the RPV head, in accordance with Section IV, paragraph C.(5)(a) of the First Revised Order, would result in hardship without a compensating increase in the level of quality and safety. Therefore, pursuant to Section IV, paragraph F, of the First Revised Order, the NRC staff authorizes the proposed alternative inspection for all future bare-metal visual examinations performed per Section IV, paragraph C.(5)(a), of the First Revised Order, for the RPV head at IP2.
If you should have any questions, please contact Patrick Milano at 301-415-1457.
Sincerely,
/RA/
Cornelius F. Holden, Director 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 Accession Number: ML042890389 OFFICE PDI-1:PM PDI-1:LA EMCB:SC OGC PDI-1:SC PDI:D NAME PMilano POBrien TChan DFruchter RLaufer CHolden DATE 09/28/04 09/28/04 SE dtd 09/16/04 10/4/04 10/7/04 10/12/04 OFFICIAL RECORD COPY
LETTER TO: Mr. Michael R. Kansler FROM: Cornelius F. Holden, Jr.
SUBJECT:
RELAXATION OF FIRST REVISED ORDER ON REACTOR VESSEL NOZZLES, INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 (TAC NO. MC3194)
DATE:
DISTRIBUTION:
PUBLIC R. Barrett P. Milano S. Burnell, OPA PDI-1 R/F C. Holden B. McDermott, R-I C. Miller, EDO W. Kane/S. Rosenberg B. Bateman G. Matakas, R-I SECY J. Dyer F. Congel E. Reichelt ACRS R. Borchardt R. Laufer W. Koo OGC B. Sheron T. Chan S. Little G. Hill (2)
T. Marsh/J. Lyons J. Luehman S. Bloom
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. Gary J. Taylor Ms. Charlene D. 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 T. Herron Mr. Michael J. Colomb Senior Vice President and Director of Oversight Chief Operating Officer Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. James Comiotes Mr. Fred Dacimo Director, Nuclear Safety Assurance Site Vice President Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 295 Broadway, Suite 1 295 Broadway, Suite 2 P.O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Patric Conroy Mr. Christopher Schwarz Manager, Licensing General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 295 Broadway, Suite 1 295 Broadway, Suite 1 P. O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. John M. Fulton Mr. Danny L. Pace Assistant General Counsel Vice President Engineering Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Regional Administrator, Region I Mr. Brian OGrady U.S. Nuclear Regulatory Commission Vice President, Operations Support 475 Allendale Road Entergy Nuclear Operations, Inc. King of Prussia, PA 19406 440 Hamilton Avenue White Plains, NY 10601 Senior Resident Inspectors Office Indian Point 2 Mr. John McCann U. S. Nuclear Regulatory Commission Director, Nuclear Safety Assurance P.O. Box 59 Entergy Nuclear Operations, Inc. Buchanan, NY 10511-0038 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 17 Columbia Circle Inglis, FL 34449 Albany, NY 12203-6399 Mr. William T. Russell Mr. Paul Eddy PWR SRC Consultant Electric Division 400 Plantation Lane New York State Department Stevensville, MD 21666-3232 of Public Service 3 Empire State Plaza, 10th Floor Mr. Alex Matthiessen Albany, NY 12223 Executive Director Riverkeeper, Inc.
Mr. Charles Donaldson, Esquire 25 Wing & Wing Assistant Attorney General Garrison, NY 10524 New York Department of Law 120 Broadway Mr. Paul Leventhal New York, NY 10271 The Nuclear Control Institute 1000 Connecticut Avenue NW Mayor, Village of Buchanan Suite 410 236 Tate Avenue Washington, DC, 20036 Buchanan, NY 10511 Mr. Karl Coplan Mr. Ray Albanese Pace Environmental Litigation Clinic Executive Chair 78 No. Broadway Four County Nuclear Safety Committee White Plains, NY 10603 Westchester County Fire Training Center 4 Dana Road Mr. Jim Riccio Valhalla, NY 10592 Greenpeace 702 H Street, NW Ms. Stacey Lousteau Suite 300 Treasury Department Washington, DC 20001 Entergy Services, Inc.
639 Loyola Avenue Mr. Robert D. Snook Mail Stop: L-ENT-15E Assistant Attorney General New Orleans, LA 70113 State of Connecticut 55 Elm Street Mr. William DiProfio P.O. Box 120 PWR SRC Consultant Hartford, CT 06141-0120 139 Depot Road East Kingston, NH 03827 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 RELAXATION OF FIRST REVISED ORDER MODIFYING LICENSES, EA-O3-009 BARE-METAL VISUAL EXAMINATION COVERAGE FOR REACTOR PRESSURE VESSEL HEAD INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 ENTERGY NUCLEAR OPERATIONS, INC.
DOCKET NO. 50-247
1.0 INTRODUCTION
The First Revised Order Modifying Licenses, EA-03-009 (Order), dated February 20, 2004 (ADAMS Accession No. ML040220181), requires specific examinations of the reactor pressure vessel (RPV) head and vessel head penetration (VHP) nozzles of all pressurized-water reactor (PWR) plants.Section IV, paragraph F, of the Order states that requests for relaxation of the Order associated with specific penetration nozzles will be evaluated by the Nuclear Regulatory Commission (NRC) staff using the procedure for evaluating proposed alternatives to the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, in accordance with Title 10 of the Code of Federal Regulations, Part 50, Section 55a(a)(3).Section IV, paragraph F, of the Order states that a request for relaxation regarding inspection of specific nozzles shall address the following criteria: (1) the proposed alternative(s) for inspection of specific nozzles will provide an acceptable level of quality and safety, or (2) compliance with this Order for specific nozzles would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
For Indian Point Nuclear Generating Unit No. 2 (IP2), and similar plants determined to have a moderate susceptibility to primary water stress corrosion cracking in accordance with Section IV, paragraphs A and B of the Order, the following inspections are required to be performed every refueling outage in accordance with Section IV, paragraph C.(5)(a) or paragraph C.(5)(b) of the Order.
(a) Bare-metal visual (BMV) examination of 100% of the RPV head surface (including 360E around each RPV head penetration nozzle). For RPV heads with the surface obscured by support structure interferences which are located at RPV head elevations downslope from the outermost RPV head penetration, a BMV inspection of no less than 95% of the RPV head surface may be performed provided that the examination shall include those areas of the RPV head upslope and downslope from the support structure interference to identify any evidence of boron or corrosive product. Should any evidence of boron or Enclosure
corrosive product be identified, the licensee shall examine the RPV head surface under the support structure to ensure that the RPV head is not degraded.
(b) For each penetration, perform a nonvisual NDE (nondestructive examination) in accordance with either (i), (ii), or (iii) below:
(i) Ultrasonic testing of the RPV head penetration nozzle volume (i.e., nozzle base material) from 2 inches above the highest point of the root of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) to 2 inches below the lowest point at the toe of the J-groove weld on a horizontal plane perpendicular to the nozzle axis (or bottom of the nozzle if less than 2 inches (see Figure IV-1 in the Order); OR from 2 inches above the highest point of the root of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) to 1.0 inch below the lowest point at the toe of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) and including all RPV head penetration nozzle surfaces below the J-groove weld that have an operating stress level (including all residual and normal operation stresses) of 20 ksi tension and greater (see Figure IV-2 in the Order). In addition, an assessment shall be made to determine if leakage has occurred into the annulus between the RPV head penetration nozzle and the RPV head low-alloy steel.
(ii) Eddy-current testing or dye-penetrant testing of the entire wetted surface of the J-groove weld and the wetted surface of the RPV head penetration nozzle base material from at least 2 inches above the highest point of the root of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) to 2 inches below the lowest point at the toe of the J-groove weld on a horizontal plane perpendicular to the nozzle axis (or the bottom of the nozzle if less than 2 inches) (see Figure IV-3 in the Order); OR from 2 inches above the highest point of the root of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) to 1.0 inch below the lowest point at the toe of the J-groove weld (on a horizontal plane perpendicular to the nozzle axis) and including all RPV head penetration nozzle surfaces below the J-groove weld have an operating stress level (including all residual and normal operation stresses) of 20 ksi tension and greater (see Figure IV-4 in the Order).
(iii) A combination of (i) and (ii) to cover equivalent volumes, surfaces, and leak paths of the RPV head penetration nozzle base material and J-groove weld as described in (i) and (ii). Substitution of a portion of a volumetric exam on a nozzle with a surface examination may be performed with the following requirements:
- 1. On nozzle material below the J-groove weld, both the outside diameter and inside diameter surfaces of the nozzle must be examined.
- 2. On nozzle material above the J-groove weld, surface examination of the inside diameter surface of the nozzle is permitted provided a surface examination of the J-groove weld is also performed.
In addition, the requirements of paragraph IV.C.(5)(a) and paragraph IV.C.(5)(b) shall be performed at least once over the course of every two refueling outages. Footnote 3 of the Order provides specific criteria for examination of repaired VHP nozzles.
By letter dated May 19, 2004, as supplemented on August 23, 2004, Entergy Nuclear Operations, Inc. (Entergy or the licensee), requested relaxation to implement an alternative to the requirements of Section IV.C.(5)(a) of the First Revised Order for RPV head penetration nozzles at IP2.
2.0 RELAXATION REQUEST FOR BMV EXAMINATION COVERAGE OF RPV HEAD 2.1 First Revised Order Requirements for Which Relaxation is Requested The licensee has requested relaxation from Section IV, paragraph C.(5)(a), of the First Revised Order. The specific relaxation requested is identified below.
2.2 Licensees Proposed Alternative The licensee will perform a BMV examination of no less than 95% of the RPV head surface.
The small area not being inspected is partially obscured by a reflective metal insulation (RMI) support ring located downslope from the outermost RPV head penetrations.
2.3 Licensees Basis for Proposed Alternative The licensee stated that the RPV head insulation package consists of RMI panels supported above the RPV head surface such that remote visual devices can be used to perform the BMV examination, without removing the RMI. The licensee stated that the outer wall of the RMI package, which includes the RMI support ring, rests on the RPV head downslope of the outermost penetration nozzles. Although this RMI support ring provides structural support for the other panels in the insulation package, the licensee stated it may not be considered as a support structure as intended in Section IV.C.(5)(a) of the First Revised Order, EA-03-009.
The licensee is, therefore, requesting a relaxation of the requirement for BMV examination of 100% of the RPV head surface. Because of the interference from this insulation component, the licensee proposed to perform a BMV examination of no less than 95% of the RPV head surface.
The licensee stated that they will inspect the upslope and downslope of the interference, and if evidence of boron or corrosive product is identified, the examination will be expanded to cover the affected area under the interference. The RMI support ring does not prevent the inspection of 360E around the RPV head penetration nozzles.
The licensee stated that although the RMI support ring is removable, the other components of the insulation package supported by the support ring and the control rod drive mechanism cooling shroud would have to be removed first. The licensee stated that this is a significant labor-intensive task. The licensee estimated that the dose to personnel removing and reinstalling the shroud and insulation would be approximately 7 man-rem for IP2. The licensee stated that additional stay-times in the radiation field required to perform the removal and reinstallation task represents a hardship without a compensating increase in the effectiveness of the BMV examination.
2.4 Staffs Evaluation The NRC staffs review of this relaxation request was based on criterion (2) of paragraph F of Section IV of the Order, which states:
Compliance with this Order for specific nozzles would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
Within the context of the licensees proposed alternative examination of the RPV head, the licensee has demonstrated the hardship that would result from implementing a BMV examination of 100% of the RPV head surface.
The licensee proposed to perform a BMV examination of no less than 95% of the RPV head surface. The small area not being inspected is partially obscured by the RMI package including the support ring located downslope from the outermost RPV head penetrations. The licensee stated that this RMI support ring provides structural support for the other panels in the insulation package. The licensee submitted a relaxation request because it was uncertain if the RMI support ring could be considered a support structure as intended in Section IV.C.(5)(a) of the Order. The licensee requested a relaxation of the requirement for BMV examination of 100% of the RPV head surface. Because of the interference from the insulation component, the licensee proposed to perform a BMV examination of no less than 95% of the RPV head surface.
The licensee stated that although the RMI support ring is removable, other components of the insulation package supported by the support ring and the control rod drive mechanism cooling shroud would have to be removed first. In response to a request for additional information (RAI) dated July 29, 2004, the licensee submitted a letter dated August 23, 2004, which provided the removal/reinstallation sequence of the insulation package. The licensee stated that the removal sequence is as follows:
- 1. Build scaffolding around the Reactor Pressure Vessel (RPV) Head
- 2. Unbolt control rod drive mechanism (CRDM) cooling shroud bolts (18 bolts at the base of the shroud support ring)
- 3. Install rigging
- 4. Lift the shroud approximately 4 feet high and maintain for the whole evolution
- 5. Establish laydown area for insulation panels
- 6. Remove D4 panel sections (total 18 panels)
- 7. Remove D3 panel sections (approx. 24 panels)
- 8. Remove D2 panel sections (approx. 24 panels)
- 9. Remove D1 panel sections (approx. 24 panels)
- 10. Reverse the sequence for reinstallation of the entire insulation support package.
The licensee estimates that the dose to personnel removing and reinstalling the shroud and insulation would be approximately 7 man-rem for IP2. The licensee stated in its response to the RAI that the RPV head surface that is obscured by the support ring is calculated at less than 5% with the inspection access from the upslope and downslope sides. Therefore, the planned inspection will cover at least 95% of the RPV head surface.
The licensee stated that they will inspect the upslope and downslope of the interference, and if evidence of boron or corrosive product is identified, the licensee will examine the RPV head surface under the support structure to ensure that the RPV head is not degraded. This is consistent with the requirements of Section IV.C.(5)(a) of the Order.
The licensee stated that during the prior BMV inspection (November 2002), the inspection coverage was 100% because a plant modification was implemented which replaced the originally installed Kaylo Block permanent insulation with the new RMI panels. The area under the new RMI support ring was previously cleaned and inspected with satisfactory results.
The safety issues that are addressed by the inspections mandated by the Order are degradation (corrosion) of the low-alloy steel RPV head, and reactor coolant pressure boundary integrity. Based upon the above information, the alternative BMV examination proposed by the licensee, provides reasonable assurance of the structural integrity of the RPV head, CRDM nozzles, and welds.
3.0 CONCLUSION
The NRC staff concludes that the licensees proposed alternative examination of the RPV head provides reasonable assurance of the structural integrity of the RPV head, CRDM nozzles, and welds. Further inspections of the RPV head, in accordance with Section IV, paragraph C.(5)(a) of the First Revised Order, EA-03-009, dated February 20, 2004, would result in hardship without a compensating increase in the level of quality and safety. Therefore, pursuant to Section IV, paragraph F, of the First Revised Order, EA-03-009, the staff authorizes the proposed alternative inspection for all future BMV examinations performed per Section IV.C.(5)(a) of the First Revised Order for the RPV head at IP2.
Principal Contributor: E. Reichelt Date: October 15, 2004