NL-10-136, Submittal of 10 CFR 50.55a Relief Request IP2-ISI-RR-12 for 4th Ten-Year Inservice Inspection Interval
| ML103560598 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/14/2010 |
| From: | Robert Walpole Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-10-136 | |
| Download: ML103560598 (5) | |
Text
SEntergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Robert Walpole Licensing Manager Tel 914 734 6710 December 14, 2010 NL-10-136 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
10 CFR 50.55a Relief Request IP2-1SI-RR-12 For Fourth Ten-Year Inservice Inspection Interval Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26
Dear Sir or Madam:
Entergy Nuclear Operations, Inc. (Entergy) is submitting Relief Request No. IP2-1SI-RR-12 (Enclosure 1), for Indian Point Unit No. 2 (1P2). This relief request is for the Fourth 10-year Inservice Inspection (ISI) Interval.
The enclosed relief request evaluates the proposed alternative and concludes that it provides an acceptable level of quality and safety. The relief request is requested under the provisions of 1 OCFR 50.55a(a)(3)(i). Entergy requests approval of the relief request within 12 months of docketing which will allow time for implementation during the next refuel outage.
There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Licensing Manager at 914-734-6710.
Very truly yours,
Attachment:
- 1. IP2-1SI-RR-12 "Use of PDI Qualified Procedures, Personnel, and Equipment for Non-Appendix VIII Reactor Vessel Shell to Flange Weld Inspection cc:
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NL-10-136 Docket No. 50-247 Page 2 of 2 cc:
Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region I NRC Resident Inspector's Office Indian Point Mr. Paul Eddy, New York State Department of Public Service Mr. Francis J. Murry Jr., President and CEO NYSERDA TO NL-10-136 RELIEF REQUEST IP2-ISI-RR-12 USE OF PDI QUALIFIED PROCEDURES, PERSONNEL, AND EQUIPMENT FOR NON-APPENDIX VIII REACTOR VESSEL SHELL TO FLANGE WELD INSPECTION ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247
NL-10-136 Docket No. 50-247 Page 1 of 2 Indian Point Unit 2 Fourth 10-Year ISI Interval Relief Request IP2-ISI-RR-12 Use of PDI Qualified Procedures, Personnel, and Equipment for Non-Appendix VIII Reactor Vessel Shell to Flange Weld Inspection Proposed Alternative In Accordance with 10 CFR 50.55a(a)(3)(i)
- Alternative Provides Acceptable Level of Quality and Safety -
- 1. ASME Code Component(s) Affected Code Class:
1
References:
IWB-2500-1 Examination Category:
B-A Item Number:
B1.30
==
Description:==
Reactor Vessel Shell-to-Flange Weld
2. Applicable Code Edition and Addenda
The code of record for the Indian Point Unit 2 Inservice Inspection Fourth Interval is the ASME Section Xl Code, 2001 Edition, 2003 Addenda.
3. Applicable Code Requirement
ASME Section Xl, Category B-A, Item B1.30, Pressure Retaining Welds in Reactor Vessel specifies that a volumetric examination must be performed once per each 10 year interval. The 2001 Edition, 2003 Addenda of ASME Section Xl, Subsection IWA-2232, requires UT examination of the RPV shell-to-flange weld to be in accordance with ASME Code, Article 4 of Section V, as supplemented by Appendix I of Section Xl.
4. Reason for Request
Pursuant to 10CFR50.55a(a)(3)(i), relief is requested from the requirements of Subsection IWA-2232 since the vendor performing the inspection has qualified their equipment, procedures and personnel to the requirements of ASME Section Xl, 1995 Edition with 1996 Addenda, Appendix VIII, Supplements 4 and 6 as amended by 10 CFR 50.55a. Performing the inspection in accordance with the requirements of IWA-2232 would require the inspection vendor to also qualify their equipment, procedures and personnel to the requirements of Article 4 of Section V, as supplemented by Appendix I of ASME Xl. Since the inspection methods provided in Appendix VIII have been proven to be more effective in detecting and sizing flaws, the use of Section V techniques would require additional resources and result in a less effective inspection. The flange to shell drawing that will be developed as part of the examination program plan will be similar to the drawing in Enclosure four to Entergy letter NL-09-022, dated February 9, 2009, for the Unit 3 relief request RR-3-47(l) (TAC ME0413).
NL-10-136 Docket No. 50-247 Page 2 of 2
5. Proposed Alternative and Basis for Use
Pursuant to 10CFR50.55a(a)(3)(i), Entergy requests authorization to utilize the alternative requirements in ASME Section Xl, 1995 Edition with 1996 Addenda, Appendix VIII, Supplements 4 and 6 as amended by 10 CFR 50.55a in lieu of the requirements of IWA-2232, that requires UT examination of the RPV shell-to-flange weld to be in accordance with ASME Code, Article 4 of Section V, as supplemented by Appendix I of Section XI.
Appendix VIII requirements were developed and adopted to ensure the effectiveness of ultrasonic examinations within the nuclear industry by means of a rigorous, item specific performance demonstration containing flaws of various sizes, locations, and orientations. The performance demonstration process has established with a high degree of confidence, the capability of personnel, procedures, and equipment to detect and characterize flaws that could be detrimental to the structural integrity of the RPV. The PDI approach has demonstrated that for detection and characterization of flaws in the RPV the ultrasonic examination techniques are equal to or better than the requirements of the ASME Section V, Article 4 ultrasonic examination requirements.
Though Appendix VIII is not required for the RPV shell-to-flange weld examination, the use of Appendix VIII, Supplements 4 and 6 criteria for detection and sizing of flaws in this weld will be equal to or exceed the requirements of ASME Section V, Article 4. Therefore, the use of the proposed alternative will continue to provide an acceptable level of quality and safety, and approval is requested pursuant to 10 CFR 50.55a(a)(3)(i).
6. Duration of Proposed Alternative
Relief is requested for the Fourth Ten Year Interval (effective from March 2007 through May 2016).
7. Precedents
Similar relief requests have been previously approved for:
(1)
Indian Point 3, in an NRC letter dated April 20, 2009 (ADAMS Accession No.
MIL090920046)
(3)
Diablo Canyon, Units 1 and 2 in an NRC letter dated October 26, 2005 (ADAMS Accession No. ML052660331)
- 8. References None