NL-03-078, Relief Request RR 63, Risk-Informed Inservice Inspection (RI-ISI) Program

Relief Request RR 63, Risk-Informed Inservice Inspection (RI-ISI) Program

ML031340452
Person / Time
Site:	Indian Point
Issue date:	05/12/2003
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-03-078
Download: ML031340452 (23)

Text

~- En tergy Entergy Nuclear Northeast Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 5340 Fax 914 734 5718 Fred Dacimo Vice President, Operations May 12, 2003 NL-03-078 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-Pl -17 Washington, DC 20555-0001

Reference:

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 Relief Request RR 63, Risk-informed Inservice Inspection (RI-ISI) Program

1. EPRI TR-112657, Rev. B-A, "Revised Risk-Informed Inservice Inspection Evaluation Procedure"

2. USNRC letter to Electric Power Research Institute (EPRI), dated October 28,1999, regarding "Safety Evaluation Report Related to EPRI Risk-Informed Inservice Inspection Evaluation Procedure (EPRI TR-1 12657, Revision B, July 1999)"

3. USNRC letter from R. Laufer to M. Kansler, dated February 4, 2003, regarding "Relief Request No. RR 3-28 Regarding Risk-informed Inservice Inspection Program, Indian Point Nuclear Generating Unit No. 3 (TAC No. MB4637)"

Dear Sir:

Entergy Nuclear Operations Inc. (ENO) requests relief to use the proposed Risk-informed Inservice Inspection Program (RI-ISI, Attachment 1) as an alternative to current ASME Section Xl inspection requirements for Indian Point Unit 2 (IP2) Class 1, Item Category B-F and B-J welds pursuant to 10 CFR 50.55a(a)(3)(i). This RI-ISI Program has been developed in accordance with the EPRI methodology contained in EPRI TR-1 12657, Rev. B-A, "Revised Risk-informed Inservice Inspection Evaluation Procedure" (Reference 1). EPRI TR-1 12657 was approved by NRC Safety Evaluation Report, dated October 28, 1999 (Reference 2).

The attached IP2-specific Rl-ISI program supports the conclusion that the proposed alternative provides an acceptable level of quality and safety as required by 10 CFR 50.55a(a)(3)(i). Also, the proposed program for IP2 is similar to the program previously approved by the NRC for IP3 (Reference 3). NRC review comments on the IP3 program have been incorporated into the proposed program for IP2.

Nl-03-078 Docket 50-247 Page 2 of 2 ENO plans to implement the RI-ISI program during refueling outage 2R16, currently scheduled for October 2004. ENO requests approval by December 2003 to support planning activities in preparation for that outage There are no new commitments made in this letter. If you have any questions, please contact Mr. Kevin Kingsley at 914-734-5581.

Very,J}urs, Fred-.

Dacimo Vice President, Operations Indian Point Energy Center

Attachment:

1. Indian Point Nuclear Generating Unit No. 2 Risk-informed Inservice Inspection Program Plan, Rev. 0 cc:

Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555 Mr. Paul Eddy NYS Dept of Public Service 3 Empire State Plaza, 10/F Albany, NY 12223 Mr. Peter R. Smith, Acting President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Senior Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511-0038

ATTACHMENT I TO NL-03-078 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 RISK INFORMED INSERVICE INSPECTION PROGRAM, Rev. 0 (Relief Request RR 63)

ENTERGY NUCLEAR OPERATIONS, INC.

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

RISK-INFORMED INSERVICE INSPECTION PROGRAM PLAN INDIAN POINT UNIT 2 (REVISION 0)

Table of Contents

1.

Introduction...............................................

2 1.1 Relation to NRC Regulatory Guides 1.174 and 1.178............................... 2 1.2 PRA Quality...............................................

2

2.

Proposed Alternative to Current Inservice Inspection Programs.......................... 3 2.1 ASME Section X...............................................

3 2.2 Augmented Programs...............................................

3

3.

Risk-Informed ISI Process...............................................

3 3.1 Scope of Program......................

3 3.2 Consequence Evaluation......................

3 3.3 Failure Potential Assessment....................

4 3.4 Risk Characterization......................

4 3.5 Element and NDE Selection.......................

5 3.5.1 Additional Examinations........................

6 3.5.2 Program Relief Requests........................

6 3.6 Risk Impact Assessment.......................

6 3.6.1 Qualitative Analysis........................

7 3.6.2 Defense-in-Depth.......................

8

4.

Implementation and Monitoring Program..............................

9

5.

Proposed ISI Program Plan Change.............................

10

6.

References/Documentation.............................

10

7.

Enclosure A - Tables.............................

11 Page 1 of 20 Rev 0

1.

INTRODUCTION Indian Point Unit 2 is currently in the third inservice inspection (ISI) interval as defined by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Section XI Code for Program B. Pursuant to 10 CFR 50.55a(g)(4)(ii), the applicable ASME Section XI Code for Indian Point Unit 2 is the 1989 Edition, No Addenda.

The objective of this submittal is to request the use of a risk-informed inservice-inspection (Rl-ISI) process for Class 1 piping. The RI-ISI process used in this submittal is described in Electric Power Research Institute (EPRI) Topical Report (TR) 112657 Rev. B-A Revised Risk-informed Inservice Inspection Evaluation Procedure."

The RI-ISI application was also conducted in a manner consistent with ASME Code Case N-578 "Risk-informed Requirements for Class 1, 2, and 3 Piping, Method B."

1.1 Relation to NRC Regulatory Guides 1.174 and 1.178 As a risk-informed application, this submittal meets the intent and principles of Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions On Plant-Specific Changes to the Licensing Basis" and Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-informed Decisionmaking Inservice Inspection of Piping."

Further information is provided in Section 3.6.2 relative to defense-in-depth.

1.2 PRA Quality The Indian Point 2 Individual Plant Examination (IPE) model (August 1992) was used as the initial basis to evaluate the consequences of pipe ruptures during power operation.

The base core damage frequency (CDF) from internal events from the IPE is 3.13 E-5/yr. The additional contribution from internal flooding, developed during the IPE external events, was 6.66 E-6/yr.

Significant changes have been made to the IPE model. These changes were made to reflect new data, calculations, and modifications to the plant design and procedures.

Updated results based on the model update completed in 2002 were used to confirm that the consequence evaluations were current. The base CDF from the model including internal flooding is 2.27 E-5/yr.

The NRC review of the IPE concluded that the IPE process is capable of identifying the most likely severe accidents and severe accident vulnerabilities. The review did not identify any weaknesses or necessary improvements to the IPE model.

The updated model has undergone a Westinghouse Owners Group (WOG) PRA certification review and there were no significant findings identified that would impact the RI-ISI consequence evaluation.

Based on the results of past NRC staff reviews and the WOG certification peer review, Entergy Nuclear Northeast is confident that the level of detail and quality of the IP-2 IPE fully supports this risk informed regulation application.

Page 2 of 20 Rev 0

2.

PROPOSED ALTERNATIVE TO CURRENT ISI PROGRAM REQUIREMENTS 2.1 ASME Section Xi ASME Section X Examination Categories B-F and B-J currently contain the requirements for the nondestructive examination (NDE) of Class 1 piping components.

The alternative RI-ISI program for piping is described in EPRI TR-112657. The RI-ISI program will be substituted for the currently approved program for Class 1 piping (Examination Categories B-F and B-J) in accordance with 10 CFR 50.55a(a)(3)(i) by alternatively providing an acceptable level of quality and safety.

Other nonfelated portions of the ASME Section Xl Code will be unaFfected. EPRI TR-1 12657 provides the requirements for defining the relationship between the RI-ISI program and the remaining unaffected portions of ASME Section Xl.

2.2 Augmented Programs No augmented programs were affected by the RI-ISI application on Class 1 piping at Indian Point Unit 2.

3.

RISK-INFORMED ISI PROCESS The process used to develop the RI-ISI program conformed to the methodology described in EPRI TR-112657 and consisted of the following steps:

Scope Definition Consequence Evaluation Failure Potential Assessment Risk Characterization Element and NDE Selection Risk Impact Assessment Implementation Program Feedback Loop 3.1 Scope of Program The systems included in the RI-ISI program are provided in Table 3.1-1. The piping and instrumentation diagrams and additional plant information including the existing plant ISI program were used to define the Class 1 piping system boundaries.

3.2 Consequence Evaluation The consequence(s) of pressure boundary failures were evaluated and ranked based on their impact on core damage and containment performance (isolation, bypass and large, early release). The consequence evaluation included an assessment of shutdown and external events. The impact on these measures due to both direct and indirect effects was considered using the guidance provided in EPRI TR-112657.

Page 3 of 20 Rev 0

3.3 Failure Potential Assessment Failure potential estimates were generated utilizing industry failure history, plant specific failure history and other relevant information. These failure estimates were determined using the guidance provided in EPRI TR-1 12657.

Table 3.3-1 summarizes the failure potential assessment by system for each degradation mechanism that was identified as potentially operative.

3.4 Risk Characterization In the preceding steps, each run of piping within the scope of the program was evaluated to determine its impact on core damage and containment performance (isolation, bypass and large, early release) as well as its potential for failure. Given the results of these steps, piping segments are then defined as continuous runs of piping potentially susceptible to the same type(s) of degradation and whose failure will result in similar consequence(s).

Segments are then ranked based upon their risk significance as defined in EPRI TR-112657. The results of these calculations are presented in Table 3.4-1.

The large, early release frequency (LERF) from the Indian Point 2 (IP2) probabilistic risk assessment is 1.0279E-06Iyr. The accident types and their contribution to internal large, early release frequencies are identified in the table below.

Accident Types and Their Contribution to Internal Large Early Release Frequencies The IP2 R-ISI evaluations were done consistent with the requirements of EPRI TR-1 12657 including an assessment of the impact of postulated piping failure on LERF.

In assessing the change in risk, the proposed RI-ISI program was shown to be risk neutral from a core damage frequency as well as LERF perspective. That is, in the high Page 4 of 20 Accident Type Point Estimate Large

% Contribution to Early Release Frequency Point Estimate Large

(/yr)

Early Release Frequency Steam Generator Tube Ruptures, 7.8263E-07 76.14 SGTR Loss of Offsite Power / Station 6.4817E-08 6.31 Blackout, LOSP Interfacing Systems Loss of Coolant 6.4167E-08 6.24 Accidents, ISLOCA Internal Flooding Events 4.9091 E-08 4.78 Anticipated Transients Without 4.9229E-08 4.79 Scram, ATWS Transients 1.6686E-08 1.62 Loss of Coolant Accidents, LOCA 1.2318E-09 0.12 Reactor Vessel Rupture 8.4193E-1 1 0.01 Rev 0

and medium risk regions the number of inspections were increased or remained the same as compared to the existing Section XI program. In addition, the IP2 RI-ISI application only applies to Class 1 piping which is located inside containment.

Implementing the RI-ISI program only affects LOCA and based on the low contribution of LOCA to LERF, as shown in the Table, the change in LERF due to implementing the RI-ISI program is small.

3.5 Element and NDE Selection In general, EPRI TR-112657 requires that 25% of the locations in the high-risk region and 10% of the locations in the medium risk region be selected for inspection using appropriate NDE methods tailored to the applicable degradation mechanism.

In addition, per Section 3.6.4.2 of EPRI TR-112657, if the percentage of Class 1 piping locations selected for examination falls substantially below 10%, then the basis for selection needs to be investigated. For the Indian Point Unit 2 Station, the percentage of Class 1 welds selected for examination per the RI-ISI process is 7.4%. Investigation reveals that the percentage is less than 10% due to the high number of Class 1 welds in the Chemical and Volume Control System (CH) assigned to the low risk region. Indian Point 2 has 265 CH system low risk welds located primarily outboard of the regenerative heat exchanger in the charging and letdown piping. Since most of this piping is small bore piping with a low consequence of failure and thus low risk, the deviation from 10%

is considered acceptable.

One additional factor that was considered during the evaluation was that the overall percentage of Class 1 selections included both socket and non-socket welds.

The percentage of Class 1 selections was 7.4% when both socket and non-socket piping welds were considered.

This percentage increases to 11.0% when considering only those piping welds that are non-socket welded.

A brief summary is provided below, and the results of the selection process are presented in Table 3.5-1.

Totals I Description 826("

Class 1 Piping Welds 61 RI-ISI Program Selections Notes

1. Includes all non-exempt Examination Category B-F and B-J locations. All in-scope piping components, regardless of risk classification, will continue to receive Code required pressure testing, as part of the current ASME Section XI program. Vr-2 visual examinations are scheduled in accordance with the station's pressure test program that remains unaffected by the RI-ISI program.

Page 5 of 20 Rev 0

3.5.1 Additional Examinations The RI-ISI program in all cases will determine through an engineering evaluation the root cause of any unacceptable flaw or relevant condition found during examination. The evaluation will include the applicable service conditions and degradation mechanisms to establish that the element(s) will still perform their intended safety function during subsequent operation. Elements not meeting this requirement will be repaired or replaced.

The evaluation will include whether other elements in the segment or segments are subject to the same root cause conditions. Additional examinations will be performed on those elements with the same root cause conditions or degradation mechanisms as the identified flaw or relevant condition. The additional examinations will include high risk significant elements and medium risk significant elements, if needed, up to a number equivalent to the number of elements required to be inspected on the segment or segments during the current outage. If unacceptable flaws or relevant conditions are again found similar to the initial problem, the remaining elements identified as susceptible will be examined. An evaluation of the root cause and degradation mechanism shall be performed to determine the size of the second expansion sample to be examined in the current outage. No additional examinations will be performed if there are no additional elements identified as being susceptible to the same root cause conditions.

3.5.2 Program Relief Requests An attempt has been made to select RI-ISI locations for examination such that a minimum of >90% coverage (i.e., Code Case N-460 criteria) is attainable.

However, some limitations will not be known until the examination is performed, since some locations may be examined for the first time by the specified techniques.

At this time, the R-ISI examination locations that have been selected provide

>90% coverage.

In instances where locations may be found at the time of the examination that do not meet the >90% coverage requirement, the process outlined in EPRI TR-1 12657 will be followed.

No existing Indian Point Unit 2 relief requests are being withdrawn due to the RI-ISI application.

3.6 Risk Impact Assessment The RI-ISI program evaluation has been conducted in accordance with Regulatory Guide 1.174 and the requirements of EPRI TR-112657, and the risk from implementation of this program is expected to remain neutral or decrease when compared to that estimated from current requirements.

Page 6 of 20 Rev 0

This evaluation identified the allocation of segments into High, Medium, and Low risk regions of the EPRI TR-112657 and ASME Code Case N-578 risk ranking matrix, and then determined for each of these risk classes what inspection changes are proposed for each of the locations in each segment. The changes include changing the number and location of inspections within the segment and in many cases improving the effectiveness of the inspection to account for the findings of the R-ISI degradation mechanism assessment. For example, for locations subject to thermal fatigue, examinations will be conducted on an expanded volume and will be focused to enhance the probability of detection (POD) during the inspection process.

3.6.1 Qualitative Analysis Table 3.6-1 presents a summary of the proposed RI-ISI program versus the current Section Xl program.

Table 3.6-1 identifies on a per system basis:

the applicable risk category, the number of locations, the consequence rank and degradation mechanism which supports the risk

category, the number of locations inspected by the current section XI program, the number of locations proposed for the RI-ISI program, crediting where appropriate, inspections from the augmented inspection programs, the increase, decrease or no change in the number of locations inspected.

This assessment does not credit inspections required by augmented inspection programs unless these inspections are also credited in the Section Xl program, and the risk impact (change in risk) of the RI-ISI program as compared to the Section Xl program.

The final column (change in risk) of Table 3.6-1 provides a conclusion as to the impact on risk for the RI4SI program as compared to the Section Xl program.

The following discussion explains the terms used in this column:

For locations identified as risk category 6 or 7:

Negligible: As discussed in TR-112657 (section 3.7.1) the impact on risk of removing inspections from risk category 6 and 7 locations is negligible. Thus, the risk impact will be Negligible" for category 6 and 7 locations, whenever there is a reduction in the number of locations inspected.

Page 7 of 20 Rev 0

No Change: When there is no change in the number of locations inspected (i.e.

the same before, as after), the risk impact will be "No Change."

For locations identifed as risk category 1, 2, 3, 4 or 5.

No Change: As with risk category 6 and 7 locations, when there is no change in the number of locations inspected (i.e. the same before, as after), the risk impact is classified as "No Change." This will be conservative when the RI-ISI inspection calls for a larger inspection volume with its accompanying increase in probability of detection.

Improvement: When there is an increase in the number of locations being inspected, there is a resultant decrease in the risk associated with piping failure.

Thus, whenever the number of RI-ISI locations exceeds the number of Section Xl locations inspected, "Improvement" will be found in the Risk Impact column. This conservatively does not credit the added benefit of increased inspection volumes for applicable degradation mechanisms (e.g. thermal fatigue).

Increase: When there is a decrease in the number of locations being inspected, there is the potential for a resultant increase in the risk associated with piping failure. Thus, for locations not managed by an augmented inspection program, when the number of Section Xl locations exceeds the number of RI-ISI locations inspected, Increase" will be found in the Risk Impact column.

Because locations that are identified as "Improvement," "Negligible" or "No Change" do not adversely impact the change in risk assessment, the following discussion is focused on those locations identified as Increase."

As identified in Table 3.6-1, there is an overall increase of 14 inspection locations in the high-risk region (i.e. Risk Categories 1, 2, and 3). Also, as identified in this table, there is an overall decrease of 2 locations in the medium risk region (i.e.

Risk Categories 4 and 5). Overall, there is a net increase of 12 inspection locations in the high and medium risk regions. This shows an overall decrease in the risk associated with implementing the RI-ISI program, which meets the requirements of TR-112657 and Reg. Guide 1.174. In addition, a separate quantitative evaluation was conducted consistent with TR-1 12657, section 3.7 and as expected, met TR-1 12657 and Reg Guide 1.174 quantitative criteria.

3.6.2 Defense-in-Depth The intent of the inspections mandated by ASME Section Xl for piping welds is to identify conditions such as flaws or indications that may be precursors to leaks or ruptures in a system's pressure boundary.

Currently, the process for picking inspection locations is based upon structural discontinuity and stress analysis results. As depicted in ASME White Paper 92-01-01 Rev. 1, Evaluation of Inservice Inspection Requirements for Class 1, Category B-J Pressure Retaining Welds," this method has been ineffective in identifying leaks or failures. EPRI TR-112657 and Code Case N-578 provide a more robust selection process founded on actual service experience with nuclear plant piping failure data.

Page 8 of 20 Rev 0

This process has two key independent ingredients, that is, a determination of each location's susceptibility to degradation and secondly, an independent assessment of the consequence of the piping failure. These two ingredients assure defense in depth is maintained.

First, by evaluating a location's susceptibility to degradation, the likelihood of finding flaws or indications that may be precursors to leaks or ruptures is increased.

Secondly, the consequence assessment effort has a single failure criterion. As such, no matter how unlikely a failure scenario is, it is ranked High in the consequence assessment, and at worst Medium in the risk assessment (i.e., Risk Category 4), if as a result of the failure there is no mitigative equipment available to respond to the event.

In addition, the consequence assessment takes into account equipment reliability, and less credit is given to less reliable equipment.

All locations within the reactor coolant pressure boundary will continue to receive a system pressure test and visual VT-2 examination as currently required by the Code regardless of its risk classification.

4.

IMPLEMENTATION AND MONITORING PROGRAM Upon approval of the RI-ISI program, procedures that comply with the guidelines described in EPRI TR-1 12657 will be prepared to implement and monitor the program. The new program will be integrated into the Third In-service inspection interval. No changes to the Updated Final Safety Analysis Report are necessary for program implementation.

The applicable aspects of the ASME Code not affected by this change will be retained, such as inspection

methods, acceptance guidelines, pressure

testing, corrective

measures, documentation requirements, and quality control requirements.

Existing ASME Section Xi program implementing procedures will be retained and modified to address the RI-ISI process, as appropriate.

The monitoring and corrective action program will contain the following elements:

A. Identify B. Characterize C. (1) Evaluate, determine the cause and extent of the condition identified (2) Evaluate, develop a corrective action plan or plans D. Decide E. Implement F. Monitor G. Trend The RI-ISI program is a living program requiring feedback of new relevant information to ensure the appropriate identification of high safety significant piping locations.

EPRI is currently working within the industry to develop guidelines for reviewing and updating risk-informed programs that have been generated per EPRI TR-1 12657. Once these guidelines are available, ENO will review them and implement applicable criteria. In addition, significant changes may Page 9 of 20 RevO

require program adjustments as directed by NRC Bulletin or Generic Letter requirements, or by industry and plant specific feedback.

ENO will review the R-ISI program on an ASME interval basis consistent with industry guidance. In accordance with the Operating Experience Program, ENO will review and assess the significance of plant-specific and industry events (e.g. generic letters, bulletins, INPO notices) and update the RI-ISI program, as necessary, on a more frequent basis.

5.

PROPOSED ISI PROGRAM PLAN CHANGE A comparison between the R-ISI program and ASME Section XI Code 1989 Edition, No Addenda program requirements for in-scope piping is provided in Tables 5-1 and 5-2. Table 5-1 provides a summary comparison by risk region.

Table 5-2 provides the same comparison information, but in a more detailed manner by risk category, similar to the format used in Table 3.6-1.

Indian Point Unit 2 is currently in the third in-service inspection interval. Examinations shall be performed during the interval such that the period examination percentage requirements of ASME Section Xl, paragraph IWB-2412 are met.

6.

REFERENCESIDOCUMENTATION 6.1 Reference 6.1.1 EPRI TR-1 12657, "Revised Risk-informed Inservice Inspection Evaluation Procedure", Rev. B-A 6.1.2 ASME Code Case N-578, "Risk-informed Requirements for Class 1, 2, and 3 Piping, Method B,Section XI, Division 1" 6.1.3 Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-informed Decisions On Plant-Specific Changes to the Licensing Basis" 6.1.4 Regulatory Guide 1.178, "An Approach for Plant-Specific Risk-informed Decisionmaking Inservice Inspection of Piping" 6.2 Supporting Onsite Documentation 6.2.1 Report No. 17184-03, "RI-ISI Degradation Analysis for Indian Point Units 2 and 3.

6.2.2 Report No. 17184-02, "Consequence Evaluation of Class 1 Piping in Support of ASME qode Case N-578, Indian Point 3 Nuclear Power Plant" 6.2.3 Report No. 17184-06, "Segment Risk Ranking and Element Selection Results of Class 1 Piping In Support of ASME Code Case N-578, Indian Point 3 Nuclear Power Plant" 6.2.4 Report No. 17184-08, "RI-ISI Risk Impact Analysis for Indian Point Unit 3" 6.2.5 Memo to file, "Resolution of final IP2 RI-ISI comments" Page Oof 20 Rev 0

Enclosure A - Tables Table Table Table Table Table Table Table 3.1-1 3.3-1 3.4-1 3.5-1 3.6-1 5-1 5-2 (1 page)

(1 page)

(1 page)

(1 page)

(2 pages)

(1 page)

(2 pages)

Page 11 of 20 Rev 0

Table 3.1-1 System Selection and Segment / Element Definition

System Description

I ASME Code Class I

Number of Segments I

Number of Elements RC - Reactor Coolant System Class 1 66 253 CH - Chemical and Volume Control System Class 1 27 369 Si - Safety Injection System Class 1 38 183 AC -Auxiliary Cooling System (Residual Heat Removal)

Class 1 3

21 Totals 134 826 Page 12 of 20 RevO

Failure Potential Assessment Summary System( I Thermal Fatigue Stress Corrosion Cracking l

Localized Corrosion Flow Sensitive l

TASCS I

TT IGSCC I

TGSCC [ ECSCC [ PWSCC MiC I

PIT I

CC l

E-C FAC RC X

X CH X

l l

AC X

Note

1. Systems are described in Table 3.1-1.

Page 13 of 20 Rev 0 Table 3.3-1

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Table 3.5-1 Number of Elements Selected for Inspection by Risk Category Excluding Impact of FAC(1)

High Risk Region Medium Risk Region Low Risk Region System(2)

Category I Category 2 Category 3 Category 4 Category 5 Category 6 Category 7 Tota lelected Total lSelected Total lSelected Total lSelected Total lSelected Total lSelected Total lSelected RC 27 7

182 19 32 4

12 0

CH 5

2 49 5

50 5

265 0

Si 48 12 6

1 27 3

102 0

AC 6

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Total 86 23 239 26 109 12 380 0

12 0

Notes

1. The Flow Assisted Corrosion (FAC) Program is not applicable for Class 1 piping at the Indian Point Unit 2 Station. As such, the FAC Program has no impact on the figures shown in the table. The reference to the FAC Program has been retained solely for uniformity purpose with other RI-ISI application template submittals.

2.

Systems are described in Table 3.1-1.

Page 15 of 20 Rev 0

Table 3.6-1 Risk Impact Analysis Results System( 1) l Category 1 Consequence Failure Potential l

Inspections CDF Impact3)

LERF Impact(3)

Sytml Ctgr Rank DMs l

Rank Section Xl(2)l Rl-ISI l

Delta lw/

POD lW/o POD w/ POD lw/o POD RC 2

High TASCS,Tr Medium 1

2

+1 Improvement Improvement RC 2

High TASCS Medium 2

5

+3 Improvement l Improvement RC 4

High None Low 38 19

-19 Increase Increase RC 5

Medium TASCS Medium 0

4

+4 Improvement l Improvement RC 7

Low None Low 0

0 0

No change No change RC Total 41 30

-11 CH 2

High TASCS Medium 0

2

+2 Improvement Improvement CH 4

High None Low 0

5

+5 Improvement Improvement CH 5

Medium TASCS Medium 0

5

+5 Improvement Improvement OH 6

Medium None Low 0

0 0

No change No change CH Total 0

12

+12 Si 2

High TASCS, IGSCC Medium 0

4

+4 Improvement Improvement Si 2

High IGSCC Medium 4

8

+4 Improvement Improvement Si 4

High None Low 0

1

+1 Improvement Improvement Si 5

Medium IGSCC Medium 1

3

+2 Improvement Improvement Si 6

Medium None Low 3

0

-3 negligible negligible Si Total 8

16

+8 Page 16 of 20 Rev 0

.i

Risk Impact Analysis Results System(1l I Category

[Consequence l Failure Potential Inspections CDF mpact 3 l

LERF mpactf3)

Rank I

DMs Rank Section XI2' RIISI Delta w/ POD I W/o POD w/ POD wlo POD AC 2

High TASCS Medium 2

2 0

no change No change AC 4

High None Low 1

1 0

No change No change AC 6

Medium None Low 2

0

-2 Negligible Negligible AC Total 5

3

-2 Grand Total 54 61

+7 Notes

1. Systems are described in Table 3.1-1.

2.

Only those ASME Section Xl Code inspection locations that received a volumetric examination in addition to a surface examination are included in this count. Inspection locations previously subjected to a surface examination only are not considered in accordance with Section 3.7.1 of EPRI TR-1 12657.

3. Per Section 3.7.1 of EPRI TR-1 12657, the contribution of low risk categories 6 and 7 need not be considered in assessing the change in risk. Hence, the word 'negligible is given in these cases in lieu of values for CDF and LERF Impact. In those cases where no inspections were being performed previously via Section Xl, and none are planned for RI-ISI purposes, no change' is listed instead of negligible".

Page 17 of 20 Rev 0 Table 3.6-1

Table 5-1 Inspection Location Selection Comparison Between ASME Section Xl Code, 1989, No Addenda and EPRI TR-112657 by Risk Region High Risk Region Medium Risk Region Low Risk Region System()

Code Weld1 ASME Section XI EPRI TR-112657 Weld ASME Section XI EPRI TR-112657 Weld ASME Section XII EPRI TR-112657 SCount Vol/Sur Sur Only RI-ISI Othe(s Count VolUSur Sur Only R-ISI Other(3}

Count Vol/Sur Sur Only R-ISI Other 3>

RC B-F 2

2 0

1 20 20 0

8 B-J 25 1

7 6

194 18 30 15 12 0

6 0

CH B-J 5

0 2

2 99 0

27 10 265 0

58 0

SI B-J 48 4

13 12 33 1

6 4

102 3

20 0

AC B-J 6

2 0

2 2

1 0

1 13 2

0 0

B-F 2

2 0

1 20 20 0

8 Total

_B8236 39__7_

B-J 84 7

22 22 328 20 63 30 392 5

78 0

Notes

1. Systems are described in Table 3.1-1.

2.

The ASME Code Category is based on the 1989 Edition, No Addenda of the ASME Section Xl Code.

3.

The column labeled "Other" is generally used to identify augmented inspection program locations that are credited beyond those locations selected per the RI-ISI process, as addressed in Section 3.6.5 of EPRI TR-1 12657. This option was not applicable for the Indian Point Unit 2 RI-ISI application. The "Other" column has been retained in this table solely for uniformity purposes with other RI-ISI application template submittals.

Page 18 of 20 Rev 0

Table 5-2 Inspection Location Selection Comparison Between ASME Section Xl Code, 1989 Edition, No Addenda and EPRI TR-112657 by Risk Category System(t)

Risk Consequence Failure Potential Code Weld ASME Section XI EPRI TR-112657 Category l

Rank DMs Rank Category Count Vol/Sur lSur Only R-ISI I Other(2)

RC 2

High High TASCS Medium B-F 1

1 0

0 B-J 20 1

7 5

RC 2

High High TASCS, TT Medium B-F 5

0 0

1 B-J 5

0 0

1 B-F 20 20 0

8 RC 4

Medium High None Low B-J 162 18 15 1 1 RC 5

Medium Medium TASCS Medium B-J 32 0

14 4

RC 7

Low Low None Low B-J 12 0

5 0

CH 2

High High TASCS Medium B-J 5

0 2

2 CH 4

Medium High None Low B-J 49 0

18 5

CH 5

Medium Medium TASCS Medium B-J 50 0

8 5

CH 6

Low Low None Medium B-J 265 0

58 0

Si 2

High High TASCS. IGSCC Medium B-J 17 0

7 4

Si 2

High High IGSCC MEDIUM B-J 31 4

6 8

Si 4

Medium High None Low B-J 6

0 0

1 Si 5

Medium Medium IGSCC Medium B-J 27 1

5 3

Si 6

Low Medium None Low B-J 102 3

14 0

Page 19 of 20 Rev 0

Table 5-2 Inspection Location Selection Comparison Between ASME Section Xl Code, 1989 Edition, No Addenda and EPRI TR-112657 by Risk Category System Risk Consequence Failure Potential Code Weld ASME Section XI EPRI TR-112657 Category Rank Rank DMs Rank Category Count Vol/Sur Sur Only R-ISI Othe 2 )

AC 2

High High TASCS Medium B-J 6

2 0

2 AC 4

Medium High None Low B-J 2

1 0

1 AC 6

Low Medium None Low B-J 13 2

0 0

l es Systems are described in Table 3.1-1.

The column labeled "Other' is generally used to identify augmented inspection program locations that are credited beyond those locations selected per the RI-ISI process, as addressed in Section 3.6.5 of EPRI TR-1 12657. This option was not applicable for the Indian Point Unit 2 RI-ISI application. The "Other" column has been retained in this table solely for uniformity purposes with other RI-ISI application template submittals.

Page 20 of 20 Rev 0 Not 1.

2.