ML15112A101

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Lr Hearing - Nrc'S Draft ACRS Slides
ML15112A101
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/21/2015
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Office of Nuclear Reactor Regulation
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Download: ML15112A101 (34)
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IPRenewal NPEmails From: Green, Kimberly Sent: Tuesday, April 21, 2015 3:57 PM To: Louie, Richard (rlouie@entergy.com)

Subject:

NRC's Draft ACRS Slides Attachments: IP ACRS SubCommittee 4-23 Briefing 04-22-15.pdf

Rich, Attached is our current draft ACRS presentation.

Kim 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 5085 Mail Envelope Properties (Kimberly.Green@nrc.gov20150421155600)

Subject:

NRC's Draft ACRS Slides Sent Date: 4/21/2015 3:56:36 PM Received Date: 4/21/2015 3:56:00 PM From: Green, Kimberly Created By: Kimberly.Green@nrc.gov Recipients:

"Louie, Richard (rlouie@entergy.com)" <rlouie@entergy.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 82 4/21/2015 3:56:00 PM IP ACRS SubCommittee 4-23 Briefing 04-22-15.pdf 503703 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Advisory Committee on Reactor Safeguards License Renewal Subcommittee Indian Point Nuclear Generating Units 2 and 3 Status Briefing April 23, 2015 Division of License Renewal Office of Nuclear Reactor Regulation

Presentation Outline

  • History of LRA and Staff Review
  • Timely Renewal Activities for Indian Point 2 (IP2)
  • SER Supplement 2
  • Staffs Ongoing Review 1

License Renewal Application

- Supplemented May 3 and June 21, 2007

- 16 amendments to LRA

  • Operating License Expiration Dates

- IP2: September 28, 2013

- IP3: December 12, 2015 2

Safety Evaluation Report

- Staffs initial evaluation and findings

- ACRS letter

- Changes to LRA since August 2009

- Operating experience since GALL Report, Revision 1

- Changes to LRA since August 2011

- Reactor Vessel Internals inspection plan and program 3

Timely Renewal

  • Administrative Procedure Act

- At least 5 years before expiration of existing license

- Sufficient application

  • Existing license will not be deemed to have expired until the application has been finally determined
  • Continue to meet all of the regulations and license conditions of the existing license 4

Timely Renewal (cont.)

  • Licensees Voluntary Actions

- Implement IP2 commitments

- Update IP2 UFSAR

  • NRCs Activities

- Acknowledgement letter

- Conducted Temporary Instruction (TI) 2516 inspections 5

License Renewal Inspections Mel Gray, Branch Chief, Engineering Branch 1, Division of Reactor Safety Michael Modes, Senior Inspector Region I 6

License Renewal Inspection Results

- Specific to applicants in timely renewal

- Satisfies completion of IP 71003 inspection requirements

- March 2012: 4 commitments implemented; 2 commitments needed further assessment

- May 2013: 30 commitments implemented; 11 commitments needed further assessment

- September 2013: 10 commitments implemented

  • No findings identified
  • Fall 2015: IP3 Commitment Inspection scheduled 7

Reactor Oversight Process (IMC 0305)

Strategic Performance Areas Safety Cornerstones Baseline Inspection Performance Indicator Results Results Significance Significance Threshold Threshold Action Matrix Regulatory Response 8

Indian Point Historical Performance IP2 & IP3 2009-2014 IP3 July 2009 - June 2010 (White PI)

Licensee Regulatory Degraded Multiple Repetitive Unacceptable Response Response Cornerstone Degraded Performance Cornerstone All Inputs are 1 or 2 White 2 White or 1 Multiple Yellow Overall Green; Inputs; Yellow Input; Inputs or 1 Red Unacceptable Cornerstone Cornerstone Cornerstone Input; Cornerstone Performance; Objectives Objectives Objectives Met w/ Objectives Met w/ Plants not Fully Met Fully Met Moderate Significant permitted to Degradation in Degradation in Operate w/in this Safety Safety Performance Column; Performance Unacceptable Margin to Safety 9

Baseline Inspection Results

  • Inspection Results for CY2014

- Indian Point Unit 2 and 3 performance placed the units in the Licensee Response Column of the Action matrix for all of CY2014

- Approximately 8300 inspection hours

- All performance indicators in the Green band

- 13 findings of very low safety significance (Green) 10

SER Supplement 2

  • Supplement 2 to the SER issued November 6, 2014

- Reactor Vessel Internals Inspection Plan and Program

- Annual Updates in 2011, 2012, and 2013

- Buried Piping and Tanks Inspection Program

- Other AMPs

  • No changes to time-limited aging analyses
  • Conclusion is unchanged
  • List of Commitments in Appendix A

- IP2: completed with exception of three

- IP3: will complete by December 12, 2015 with exception of two 11

RVI Program - Background

  • 4/30/2007 - IP2 and IP3 LRA submitted

- Consistent with GALL Report, Rev. 1

- LRA Commitment 30 to implement industry program

  • 1/12/2009 - EPRI submitted MRP-227, Rev. 0 for NRC review
  • 7/14/2010 - Applicant submitted LRA Amendment 9 -

AMP for RVI based on MRP-227, Rev. 0

  • 6/22/2011 - NRC issued Rev. 0 of SE of MRP-227, Rev. 0 12

RVI Program- Background (cont.)

  • 9/28/2011 - Applicant submitted RVI Inspection Plan based on MRP-227, Rev. 0 and SE, Rev. 0, meeting Commitment 30 date
  • 12/16/2011 - NRC issued Rev. 1 of SE for MRP-227, Rev. 0
  • 2/3/2012 - NRC endorsed MRP-227-A for referencing in licensing applications related to PWR RVI inspection
  • 2/17/2012 - Applicant submitted update to RVI Inspection Plan consistent with MRP-227-A + updated AMP
  • 11/6/2014 - RVI Inspection Plan for IP2 & IP3 first approved by NRC staff for a Westinghouse-design reactor 13

MRP-227-A Process

  • Generic components for each PWR vendor were evaluated
  • Each component screened for eight aging mechanisms
  • Screened-in components put through Failure Modes, Effects and Consequences Analysis (FMECA)
  • Risk rankings developed based on FMECA
  • FMECA results, plus some analytical work, used to develop final inspection recommendations
  • All components assigned to one of four inspection categories 14

Reactor Vessel Internals for Typical Westinghouse Reactor 15

MRP-227-A Component Categorization

  • Primary - Highest susceptibility category, will be inspected (lead components)
  • Expansion - High to moderate susceptibility with some tolerance for degradation. Not lead component.

Inspected if degradation found in lead components.

  • No Additional Measures - Low susceptibility and/or no functional impact of failure. No augmented inspections recommended, but may be inspected under ASME Code,Section XI as applicable.
  • Existing Program - Susceptible to aging effects, but existing programs such as ASME,Section XI Inservice Inspection deemed adequate to detect aging 16

IP2 and IP3 RVI Program Staff Review

  • Staff review concentrated on:

- AMP Elements

- Applicant/Licensee Action Items (A/LAIs)

- ISG updated GALL, Rev. 2 guidance consistent with MRP-227-A

  • A/LAIs 1, 2, 3, 5, 7 and 8 applicable to Westinghouse plant such as IP2 and IP3 17

RVI Program A/LAI 1: Plant-Specific Applicability

  • A/LAI 1

- Applicant must assess its plant design and operating history and demonstrate MRP-227-A is applicable

- Ensure operating conditions assumed for generic components during development of MRP-227-A are valid for the specific plant

- MRP-227-A basic applicability criteria:

  • Base load operation
  • Low leakage core before 30 years
  • No plant-specific modifications

- Generic staff concerns that basic criteria were not sufficient led to MRP letter 2013-025 additional criteria:

  • Core design (relates to RVI fluence and temperature assumptions)
  • Fabrication - no cold work (relates to SCC susceptibility) 18

RVI Program A/LAI 1 - Plant-Specific Applicability (cont.)

  • Applicant Evaluation

- Applicant showed IP2 and IP3 meet basic and additional criteria

  • Staff Finding

- MRP-227-A is applicable to IP2 and IP3

- Applicant adequately addressed A/LAI 1 19

RVI Program A/LAI 2 - RVI Components within Scope of License Renewal

  • A/LAI 2

- Recommends applicants ensure that all RVI components within scope of LR are covered by generic components in MRP-191.

If not, modify plant-specific program to address the components not covered.

  • Applicant Evaluation

- Determined all components

  • Have an equivalent generic component, or
  • Have an equivalent generic component, but different material

- Plant-specific screening and FMECA for components with different materials - no differences in aging management

  • Staff Finding

- Applicant adequately evaluated differences in material, thus applicant adequately addressed A/LAI 2.

20

RVI Program A/LAI 3: Plant-Specific Programs

  • A/LAI 3

- Recommends a justification of the adequacy of plant-specific program, or modify program to manage aging for the PEO

  • Applicant Evaluation

- Split pins are only component with plant-specific program for IP2 & IP3

- IP3 split pins previously replaced with SCC-resistant material (cold-worked Type 316 stainless steel)

- Commitment 50 to replace IP2 split pins during 2016 RFO

- Applicant justified replacement date with a statistical analysis of remaining life

  • Staff Finding

- Applicant adequately addressed A/LAI 3 based on replacement of split pins with SCC-resistant material (IP3), or commitment to do so (IP2) 21

Split Pin Location Lower Part of Control Rod Guide Tube Assembly Split Pin Location 22

RVI Program A/LAI 5: Application of Physical Measurements

  • A/LAI 5

- Recommends licensees identify plant-specific acceptance criteria to be used when performing physical measurements

  • Applicant Evaluation

- Applicable to IP hold-down springs

- Applicant explained how measurements evaluated

  • Linear interpolation between initial and 60-year minimum height to determine acceptable height at first measurement
  • If spring height unacceptable, a follow-up measurement will be performed, or spring replaced
  • Staff Finding

- Applicant clarified how acceptable spring height is determined

- Staff also performed audit of detailed spring height calculation

- Applicant adequately addressed A/LAI 5 23

Hold-Down Spring 24

RVI Program A/LAI 7: Plant-specific Evaluation of Cast Austenitic Stainless Steel

  • A/LAI 7

- Licensees must demonstrate functionality of CASS components through end of life considering loss of fracture toughness due to thermal embrittlement (TE ) and irradiation embrittlement (IE)

  • Applicant Evaluation

- Applicable to lower support column caps at IP

- Initially made Commitment 47 to provide detailed analysis prior to PEO

- In response to staff RAIs, the applicant:

  • Performed screening for column caps - TE screened out
  • Showed pre-existing flaws in column caps unlikely
  • Showed service-induced cracking of column caps unlikely
  • Provided link to an alternate lead component for IASCC and IE (core barrel lower girth weld) 25

RVI Program A/LAI 7: Plant-specific Evaluation of Cast Austenitic Stainless Steel

  • Staff Finding

- Applicant provided sufficient information to provide reasonable assurance of functionality of the column caps through PEO because:

  • Screened out TE, therefore only IE applicable, column caps thus equivalent to wrought stainless steel
  • Showed pre-service and in-service flaws very unlikely
  • Provided a link to a primary component that is a good predictor for IASCC and IE

- Applicant adequately addressed A/LAI 7

- Staff agreed with deletion of Commitment 47 26

Westinghouse Lower Support Column Bodies 27

RVI Program A/LAI 8: Submittal of Information for Staff Review and Approval

  • A/LAI 8

- Recommends submission of an RVI AMP and Inspection Plan +

for current LR applicants, submit FSAR supplement, TS markup and TLAAs related to RVI

- For fatigue TLAAs, A/LAI recommends these account for reactor water environmental effects

  • Applicant Evaluation

- Applicant provided AMP and Inspection Plan

- Applicant committed to update RVI fatigue TLAAs to account for environmental effects as recommended by A/LAI 8

  • Staff Finding

- Applicant adequately addressed A/LAI 8 because it provided the recommended information and made commitment to revise fatigue TLAAs 28

RVI Program Conclusion

  • RVI AMP - Applicant has demonstrated

- Effects of aging will be adequately managed per 54.21(a)(3)

- FSAR supplement adequate per 54.21(d)

  • RVI Inspection Plan implements elements of RVI AMP in an acceptable manner

- Program is consistent with the generic RVI inspection and evaluation guidelines of MRP-227-A

- Adequately addressed all of the applicable A/LAIs

- RVI Inspection Plan addresses the conditions of the final SE for MRP-227, Revision 0 29

SER Conclusion

  • On the basis of its review of the LRA, the staff determines that the requirements of 10 CFR 54.29(a) have been met.
  • Additional information provided by Entergy Nuclear Operations, Inc., does not alter the staffs conclusions stated in the SER 30

Staffs Ongoing Review

  • Annual Update in December 2014

- Changes to plant since December 2013 that materially affect LRA

  • RAI response to LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks 31
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