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Relief Request IP2-1SI-RR-02 Alternative Examination Volume Required by Code Case N-729-1
	ML15349B009
Person / Time
Site:	Indian Point
Issue date:	12/09/2015
From:	Coyle L; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-139
	Download: ML15349B009 (7)
	v • d • e

~Enterpqy Nuclear Indian Point Northeast Energy Center

=*'*~ t**450 Broadway, GSB

- P.O. Box 249 Buchanan, NY 10511-0249 Lawrence Coyle Site Vice President NL-1 5-1 39 December 9, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Relief Request IP2-1SI-RR-02 Alternative Examination Volume Required by Code Case N-729-1 Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

Dear Sir or Madam:

Pursuant to 10CFR50.55a(z)(2), Entergy Nuclear Operations, Inc. (Entergy) requests relief to use an alternative to the 2007 edition with the 2008 Addenda of ASME Section Xl as augmented by Code Case N-729-1 requirements with limitations/modifications for use stated in 10CFR50.55a(g)(6)(ii)(D)(3). This relief request is for the Fifth 10-year ISI Interval which is scheduled to start June 1, 2016 when IP-2 updates to the 2007 Editionl2008 Addenda of ASME Section Xl for performing ISI.

Entergy is submitting, enclosed, Relief Request No. 02 (IP2-1SI-05-RR-02) for Indian Point Unit No. 2 (IP2). This relief request is for the Fifth 10-year Inservice Inspection (ISI) Interval made in accordance with 10 CFR 50.55a(z)(2). The 10 CFR 50.55a(z)(2) requirements are as follows:

"Alternatives to codes and standardsrequirements. Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation, or Director, Office of New Reactors, as appropriate. A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:

(2) Hardship without a compensatingincrease in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety."

NL-1 5-1 39 Docket No. 50-247 Page 2 of 2 If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

Sincerely, LC/sp

Attachment:

10 CFR 50.55a Request No. IP2-1SI-RR-02 Proposed Alternative in Accordance With 10 CFR 50.55a(z)(2) cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT TO NL-15-139 10 CFR 50.55a REQUEST NO. IP2-1SI-RR-02 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CER 50.55a(z)(2)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

NL-1 5-1 39 Docket No. 50-247 Attachment Page 1 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-02 Proposed Alternative in Accordance With 10 CFR 50.55a(z)(2)

Examination Volume Required by Code Case N-729-1

1. ASME COMPONENT IDENTIFICATION Code Class: 1

References:

Code Case N-729-1 Examination Category: Not Applicable Item Number: B4.20 (N-729-1 Item No.)

Description:

Code Case N-729-1 Examination Volume

2. APPLICABLE ASME CODE & 10 CFR 50.55a REQUIREMENTS The code of record for the Indian Point Unit 2 (IP2) Inservice Inspection Fifth Interval is the ASME Section XI Code, 2007 Edition including the 2008 Addenda as augmented by Code Case N-729-1 with limitations/modifications for use stated in 10 CFR 50.55a(g)(6)(ii)(D)(3).

Code Case N-729-1, Section 2500 states that components shall be examined as specified in Table 1 of Code Case N-729-1 and if obstructions or limitations prevent examination of the volume or surface required by Figure 2 for one or more nozzles, the analysis of Appendix I shall be used to demonstrate the adequacy of the examination volume or surface of each nozzle.'

10CFR50.55a(g)(6)(ii)(D)(6) states that Appendix I of ASME Code Case N-729-1 shall not be implemented without prior NRC approval.

Code Case N-729-1, Figure 2, Examination Volume for Nozzle Base Metal and Examination Area for Weld and Nozzle Base Metal, identifies the examination volume or surface as "a = 1.5 in.

(38 mm) for Incidence Angle, 8, _<30 deg and for all nozzles > 4.5 in. (115 mm) OD or 1 in. (25 mm) for Incidence Angle, 8, > 30 deg; or to the end of the tube, whichever is less."

3. REASON FOR REQUEST The design of the RPV head penetration nozzles (see Figure 1) includes a threaded section, approximately 3/4 inches long, at the bottom of the nozzles. The dimensional configuration at some nozzles is such that the inspectable distance from the lowest point of the toe of the J-groove weld to the bottom of the scanned region is less than the 1 inch and 1 1/2 inch lower boundary limit as defined in Figure 2 of Code Case N-729-1. There is no current qualified volumetric inspection technique to interrogate the physical geometry of the threaded region at the nozzle end.

Inspection by surface examination techniques is an available option to meet the current regulatory requirement; however radiation dose rates under the head near the J-groove weld areas are expected to be in the 3 to 5 Rem/hour range. Additionally, the area under the head is posted as a

NL-1 5-139 Docket No. 50-247 Attachment Page 2 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-02 Proposed Alternative in Accordance With 10 CFR 50.55a(z)(2)

Examination Volume Required by Code Case N-729-1 locked high radiation area and high contamination area. Performance of the required exam is considered a hardship as a result.

Figqure 1 reference datum - bottom of J-qroove weld t* Chamfer region (approx. 0.25")

Uweadd region approximatelY O.75

4. PROPOSED ALTERNATIVE AND BASIS FOR USE Pursuant to 10 CFR 50.55a(z)(2) an alternative is requested to the use of Code Case N-729-1, Figure 2. An alternative examination volume to that defined in Figure 2 of the Code Case will be

NL-1 5-1 39 Docket No. 50-247 Attachment Page 3 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-02 Proposed Alternative in Accordance With 10 CFR 50.55a(z)(2)

Examination Volume Required by Code Case N-729-1 used. The relaxed volume based upon fiaw analysis (Reference 1) is the same volume used in the fourth interval and previously approved by the NRC. The alternative examination volume provides reasonable assurance of structural integrity, and meeting the Code requirements would result in hardship without a compensating increase in level of quality and safety. The alternative examination volume and basis follows.

IP2 will perform qualified volumetric examinations (UT) in accordance with 10 CER 50.55a for circumferential and axial flaw detection from the inside surface of each RPV head penetration nozzle from 1-inch and 1 1/2/ inch above the J-groove weld (i.e., the upper boundary limit defined in Figure 2 of Code Case N-729-1) and extending down the nozzle to at least the top of the threaded region. Table 1 provides the minimum inspection coverage required to ensure that a postulated axial through-wall flaw in the un-inspected area of the CRDM penetration nozzle will not propagate into the pressure boundary formed by the J-groove weld prior to a subsequent inspection (i.e. 2 Effective Full Power Years, EFPY). The time estimates are more than the time between successive inspections. This exam provides reasonable assurance that structurally significant flaws will not exist at or above the weld root and assure that operation between refueling outages can be accomplished without pressure boundary leakage from the examined nozzles. Reference I provides the supporting flaw analysis information used in developing Table 1.

TABLE 1 IP2 RPV Head Penetrations - Minimum Inspection Coverage Requirements Below the J-Groove Weld to Ensure Structural Integrity and Leak Tightness Between Inspections Nozzle Penetration Angle of (x Minimum Required UT Time (EFPY) to No. Incidence Coverage Below J-Groove Weld Reach the Lowest (Degrees) with > 2 EFPY by Crack Growth Point of the Toe of Evaluaion (Inches) the J-Groove Weld 1 through 25 0to 23.3 0.55 4.6 26 through 69 24.8 to 38.6 0.45 4.4 70 through 81 44.3 0.25 8.4 82 through 89 45.4 0.25 6.8 90 through 97 48.7 0.18 5.0 Note:

(1) Length below the lowest point at the toe of the J-groove weld (downhill side) that has an operating stress level of 20 ksi: 0.86 inches at nozzles 1 through 25; 0.40 inches at nozzles 26 through 69; 0.32 inches at nozzles 70 through 81 0.34 inches at nozzles 82 through 89, and 0.32 inches at nozzles 90 through 97.

NL-15-139 Docket No. 50-247 Attachment Page 4 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-02 Proposed Alternative in Accordance With 10 CFR 50.55a(z)(2)

Examination Volume Required by Code Case N-729-1 Our ultrasonic inspection vendor has verified that their system is qualified in accordance with 10 CFR 50.55a for circumferential and axial flaw detection below the J- groove weld extending to the distance specified in Table 1.

5. DURATION OF PROPOSED ALTERNATIVE Relief is requested for the Fifth Inspection Interval starting June 1, 2016 and currently scheduled to end May 31, 2026.

6. PRECEDENTS

1. Safety Evaluation for Unit 3, "Relaxation of First Revised Order on Reactor Vessel Nozzles, Indian Point No. 2 (TAO NO. MC9230, ADAMS Accession NO.

ML0600090142) dated February 27, 2006.

2. Indian Point Unit 2 Fourth Interval Relief Request, RR-09, dated July 1, 2009 was essentially the same and approved by the NRC on March 1, 2010 (TAO NO. MEl1658, ADAMS Accession NO. ML100570081)

3. Indian Point Unit 3 Fourth Interval Relief Request, RR-04, dated December 23, 2009 was essentially the same and approved by the NRC on October 1, 2010 (TAO NO. ME301 7).

7. REFERENCES

1. Entergy Letter to NRC, NL-09-1 30 (contains Westinghouse proprietary information), dated 9/24/09 (TAO NO. ME1 658, ADAMS Accession NO. ML092800242)

~Enterpqy Nuclear Indian Point Northeast Energy Center

=*'*~ t**450 Broadway, GSB