ML13150A264

Request for Additional Information Regarding Indian Point Nuclear Generating Unit No. 2 License Amendment Request Concerning PT-Limits and LTOP Requirements Docket No. 50-247

ML13150A264
Person / Time
Site:	Indian Point
Issue date:	06/13/2013
From:	Pickett D Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Pickett D
References
TAC MF0634
Download: ML13150A264 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 13, 2013 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO.2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST CONCERNING PT-LiMITS AND LTOP REQUIREMENTS (TAC NO. MF0634)

Dear Sir or Madam:

By letter dated February 6, 2013, (Agencywide Documents Access and Management System Accession No. ML13052A018) Entergy Nuclear Operations, Inc. (Entergy), the licensee for Indian Point Nuclear Generating Unit No.2 (IP2), submitted a license amendment request for the implementation of new reactor vessel heatup and cooldown curves (pressure temperature limits [P-T Limits]) and low temperature over pressure (LTOP) requirements for staff review and approval.

The staff of the Nuclear Regulatory Commission's Vessels and Internals Integrity Branch (EVIB) and Reactor Systems Branch (SRXB) is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). Based on our discussions we understand that a response to the EVIB RAI will be provided within 120 days of the date of this letter and the SRXB RAI will be provided within 30 days of the date of this letter.

Please contact me at (301) 415-1364 if you have any questions on this issue.

Sincerely,

~vp~

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286

Enclosure:

1) Request for Additional Information - EVIB Branch

2) Request for Additional Information - SRXB Branch cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION P-T LIMITS AND LTOP REQUIREMENTS VESSELS AND INTERNALS INTEGRITY BRANCH (EVIB)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO.2 DOCKET NO. 50-247 By letter dated February 6, 2013, (Agencywide Documents Access and Management System Accession No. ML13052A018) Entergy Nuclear Operations, Inc. (Entergy), the licensee for Indian Point Nuclear Generating Station, Unit No.2 (IP2), submitted a license amendment request for the implementation of new reactor vessel heatup and cooldown curves (pressure temperature limits [P-T Limits]) and low temperature over pressure (LTOP) requirements for staff review and approval.

In order to complete its review of the licensee's submittal, the U.S. Nuclear Regulatory Commission staff requires a response to the following questions:

RAI EVIB.1 Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix G requires that P-T limits be developed for the ferritic materials in the reactor vessel (RV) beltline (neutron fluence ;:::

1 x 1017 n/cm 2 , E> 1 MeV). Confirm that all materials projected to receive the above noted fluence or greater at 48 Effective Full-Power Years have been analyzed as beltline materials for the purpose of generating the supplied P-T limits.

RAI EVIB.2 It states in 10 CFR Part 50, Appendix G, Paragraph IV.A that:

"the pressure-retaining components of the reactor coolant pressure boundary

[RCPB] that are made of ferritic materials must meet the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code

[ASME Code, Section III], supplemented by the additional requirements set forth in [paragraph IV.A.2, "Pressure-Temperature (P-T) Limits and Minimum Temperature Requirements"] ... "

Therefore, 10 CFR Part 50, Appendix G requires that P-T limits be developed for the ferritic materials in the reactor vessel (RV) beltline (neutron fluence ;::: 1 x 1017 n/cm 2 , E > 1 MeV), as 2

well as ferritic materials not in the RV beltline (neutron fluence < 1 x 10 17 n/cm , E> 1 MeV).

Furthermore, 10 CFR Part 50, Appendix G requires that all RCPB components must meet the ASME Code,Section III requirements. The relevant ASME Code,Section III requirement that Enclosure 1

-2 will affect the P-T limits is the lowest service temperature requirement for all RCPS components specified in Section III, NS-2332(b).

The P-T limit calculations for ferritic RCPS components that are not RV beltline shell materials may define P-T curves that are more limiting than those calculated for the RV beltline shell materials due to the following factors:

1. RV nozzles, penetrations, and other discontinuities have complex geometries that may exhibit significantly higher stresses than those for the RV beltline shell region. These higher stresses can potentially result in more restrictive P-T limits, even if the reference temperature (RT NDT) for these components is not as high as that of RV beltline shell materials that have simpler geometries.

2. Ferritic RCPS components that are not part of the RV may have initial RTNDT values, which may define a more restrictive lowest operating temperature in the P -T limits than those for the RV beltline shell materials.

Consequently, please describe how the P-T limit curves submitted for IP2, and the methodology used to develop these curves, considered all RV materials (beltline and non-beltline) and the lowest service temperature of all ferritic RCPS materials, consistent with the requirements of 10 CFR Part 50, Appendix G.

REQUEST FOR ADDITIONAL INFORMATION P-T LIMITS AND LTOP REQUIREMENTS REACTOR SYSTEMS BRANCH (SRXB)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO.2 DOCKET NO. 50-247 By letter dated February 3, 2013, Entergy Nuclear Operations, Inc. (Entergy, the Licensee) proposed to revise Indian Point Nuclear Generating Unit No.2 Technical Specification 3.4, "Reactor Coolant System," as necessary to implement revised reactor vessel heatup and cooldown curves and low temperature overpressure (LTOP) requirements. The proposed revisions would replace the existing limits, which expire after 29.2 effective full power years (EFPY) of exposure, with new limits that are applicable up to 48 EFPY.

The Reactor Systems Branch staff has reviewed the request and determined that additional information is necessary to complete its review.

On Page 9 of 12 of Attachment 1 to the February 3,2013, license amendment request letter, the following is stated with respect to the currently applicable TS requirements:

The WCAP [Westinghouse Commercial Atomic Power Report] (Reference 1) for normal HU [heatup] and CD [cooldown] curves identifies the methodology under which the figures were generated, and was previously transmitted to the NRC (Reference 4).

These curves are based on latest available reactor vessel information and updated calculated fluences, which include the impact of Stretch Power Uprate.

The same passage then goes on to identify differences between the methods used to generate prior curves and those used to generate the proposed curves, but also states (Page 10 of 12):

The calculation for the LTOP curves uses a methodology identical to that of the existing curves, based on the source calculations for TS Amendment 262 (Reference 3). The LTOP curves in Reference 2 are based on the HUlCD curves established in Reference 1, and therefore the revised LTOP setpoints, and its family of associated curves, similarly reflect the increase in lifetime fluence for a service life of 48 EFPY.

RAI SRX8.1 Please clarify whether the proposed LTOP and HU/CD limits are based on a previously reviewed, or new, fluence calculation. Provide a description of the fluence calculation in sufficient detail to enable the staff to determine whether the calculations are acceptable (e.g.,

that the calculations adhere to NRC Regulatory Guide 1.190, "Calculational and Dosimetry Methods for Determining Pressure Vessel Neutron Fluence"), or provide a reference to previously docketed information that provides the same description.

Enclosure 2

June 13, 2013 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 SUB..IECT: INDIAN POINT NUCLEAR GENERATING UNIT NO.2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST CONCERNING PT-L1MITS AND LTOP REQUIREMENTS (TAC NO. MF0634)

Dear Sir or Madam:

By letter dated February 6, 2013, (Agencywide Documents Access and Management System Accession No. ML13052A018) Entergy Nuclear Operations, Inc. (Entergy), the licensee for Indian Point Nuclear Generating Unit No.2 (IP2), submitted a license amendment request for the implementation of new reactor vessel heatup and cooldown curves (pressure temperature limits [P-T Limits]) and low temperature over pressure (LTOP) requirements for staff review and approval.

The staff of the Nuclear Regulatory Commission's Vessels and Internals Integrity Branch (EVIB) and Reactor Systems Branch (SRXB) is reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). Based on our discussions we understand that a response to the EVI B RAI will be provided within 120 days of the date of this letter and the SRXB RAI will be provided within 30 days of the date of this letter.

Please contact me at (301) 415-1364 if you have any questions on this issue.

Sincerely, IRA!

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286

Enclosure:

1) Request for Additional Information - EVIB Branch

2) Request for Additional Information - SRXB Branch cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsNrrDorlLpl1-1 RidsNrrPMlndianPoint RidsNrrDeEvib LPL1-1 Reading File DWidrevitz, EVIB RidsNrrLAKGoldstein RidsAcrsAcnw_MailCTR RidsRgn1 MailCenter ABurritt, R1 BParks, SRXB RidsNrrDssSrxb ADAMS ACCESSION NO.: ML13150A264 *by memo OFFICE LPLI-1/PM LPLI-1/LA EVIB/BC SRXB/BC LPLI-1/BC(A)

NAME DPickett KGoldstein SRosenberg* CJackson RBeali DATE 06/12/13 06/03/13 05/06/13 06/12/13 06/13/13 OFFICIAL RECORD COPY