ML15112A101

From kanterella
Jump to navigation Jump to search
Lr Hearing - NRCs Draft ACRS Slides
ML15112A101
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/21/2015
From:
Office of Nuclear Reactor Regulation
To:
References
Download: ML15112A101 (34)
v • d • e


Text

1 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

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:

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

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 7

- 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

8 Reactor Oversight Process (IMC 0305)

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

9 Indian Point Historical Performance Licensee

Response

Regulatory

Response

Degraded Cornerstone Multiple Repetitive Degraded Cornerstone Unacceptable Performance All Inputs are Green; Cornerstone Objectives Fully Met 1 or 2 White Inputs; Cornerstone Objectives Fully Met 2 White or 1 Yellow Input; Cornerstone Objectives Met w/

Moderate Degradation in Safety Performance Multiple Yellow Inputs or 1 Red Input; Cornerstone Objectives Met w/

Significant Degradation in Safety Performance Overall Unacceptable Performance; Plants not permitted to Operate w/in this Column; Unacceptable Margin to Safety IP2 & IP3 2009-2014 IP3 July 2009 - June 2010 (White PI)

10

  • 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)

Baseline Inspection Results

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 1/9/2012 - EPRI submitted MRP-227-A, incorporating Rev. 1 of SE 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

15 Reactor Vessel Internals for Typical Westinghouse Reactor

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
  • 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 IP2 and IP3 RVI Program Staff Review 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 22 Split Pin Location Lower Part of Control Rod Guide Tube Assembly

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 RVI Program A/LAI 5: Application of Physical Measurements 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

  • 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 SER Conclusion 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
Retrieved from "https://kanterella.com/w/index.php?title=ML15112A101&oldid=5192955"