NL-04-090, Indian, Units 2 and 3, Response to NRC Bulletin 2004-01 Regarding Inspection of Alloy 82/182/600 Materials Used in Pressurizer Penetrations and Steam Space Piping Connections
| ML042160354 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/26/2004 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BL-04-001, NL-04-090 | |
| Download: ML042160354 (8) | |
Text
Entergy Nuclear Northeast Indian Point Energy Center
'Entergy 450 Broadway, GSB R0. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration July 26, 2004 NL-04-090 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Indian Point Nuclear Generating Units No. 2 and No. 3 Docket No. 50-247, and 50-286 Response to NRC Bulletin 2004-01 Regarding Inspection of Alloy 82/182/600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections
References:
- 1. NRC letter dated May 28, 2004, NRC Bulletin 2004-01: Inspection of Alloy 82/182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors.
Dear Sir or Madam:
On May 28, 2004, the Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. The NRC requested that all pressurized water reactor addressees provide description of their pressurizer heater and steam space penetrations and inspection plans for the forthcoming and subsequent refueling outages.
Entergy Nuclear Operations, Inc is providing the response to Bulletin 2004-01 in Attachment 1 for Indian Point Nuclear Generating Units No. 2 (IP2) and No. 3 (IP3). There are no new commitments made in this letter regarding NRC question number 2 as it is not applicable to either IP2 or IP3.
If you have any questions, please contact Mr. Pat Conroy at 914-734-6668.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 7-& , 2004.
VesHyly ours, Fred R. Dacimo Site Vice President Indian Point Energy Center cc: next page
NL-04-090 Page 2 of 2 cc:
Mr. Hubert J. Miller Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555-0001 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Senior Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511-0038 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203
Attachment 1 to NL-04-090 Response to NRC Bulletin 2004-01, Inspection of Alloy 8211821600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKETS 50-247 AND 50-286
NL-04-090 Attachment I Page 1 of 5 Response to Bulletin 2004-01 for Indian Point Units 2 and 3 Inspection of Alloy 8211821600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections On May 28, 2004, the Nuclear Regulatory Commission (NRC) issued Bulletin 2004-01, Inspection of Alloy 821182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. The 60-day response to the bulletin for Indian Point Units 2 (1P2) and 3 (IP3)is provided below.
NRC Request 1(a):
A description of the pressurizer penetrations and steam space piping connections at your plant.
At a minimum, this description should include materials of construction (e.g., stainless steel piping and/or weld metal, Alloy 600 piping/sleeves, Alloy 821182 weld metal or buttering, etc.),
joint design (e.g., partial penetration welds, full penetration welds, bolted connections, etc.),
and, in the case of weldedjoints, whether or not the weld was stress-relieved prior to being put into service. Additional information relevant with respect to determining the susceptibility of your plant's pressurizer penetrations and steam space piping connections to PWSCC should also be included.
Entergy Response to Request 1(a):
The IP2 and IP3 pressurizers are low alloy steel vessels internally clad with austenitic stainless steel (type 304 or equivalent). The shells consist of SA 320 Grade B material while the upper and lower heads consist of SA 216, Grade WCC. Each pressurizer was furnished with six 3/4",
stainless steel level instrument nozzles, two 34"stainless steel temperature instrument nozzles and one 1", stainless steel sample nozzle. Three level and one temperature 3/4" nozzles are located in the upper head and three level and one temperature nozzle in the lower head. The 1" sample nozzle is located in the lower head. The SA-182, F316 stainless steel nozzles are welded with a partial penetration stainless steel weld to the inside of the pressurizer and allowed to thermally expand radially through the vessel wall as the RCS heats up. Stainless steel materials in the IP2 and IP3 pressurizer nozzles and welded joints are not susceptible to the same PWSCC mechanism as the Alloy 82/182/600 materials.
The following table provides the pressurizer heater and steam space penetration descriptions for IP2 and IP3.
NL-04-090 Attachment 1 Page 2 of 5 IP2/IP3 Pressurizer Nozzle Description Penetration/ Penetration Size Joint Design Materials Description (#) (safe end material/weld material)N" '
Pzr Heater (78) N/A PP SS/SS Surge Line (1) 14", Sched. 140 FP SS/SS Spray Nozzle (1) 4", Sched. 160 FP SS/SS Relief Nozzle (1) 4", Sched. 160 FP SS/SS Safety Nozzle (3) 3.5" Special FP SS/SS Level Inst. Nozzle %", Sched. 160 PP SS/SS (6)
Temp. Inst. Nozzle 3/4", Sched 160 PP SS/SS (2)
Sample Nozzle (1) I inch, Sched 160 PP SS/SS Manway (1) 16 inch Bolted CS PP = Partial Penetration; FP = Full Penetration Note 1: base/safe end material is SA-1 82, F3 16 NRC Request 1(b):
A description of the inspection program for Alloy 82/1821600 pressurizer penetrations and steam space piping connections that has been implemented at your plant. The description should include when the inspections were performed; the areas, penetrations and steam space piping connections inspected; the extent (percentage) of coverage achieved for each location which was inspected; the inspection methods used; the process used to resolve any inspection findings; the quality of the documentation of the inspections (e.g., written report, video record, photographs); and, the basis for concluding that your plant satisfies applicable regulatory requirements related to the integrity of pressurizer penetrations and steam space piping connections. If leaking pressurizer penetrations or steam space piping connections were found, indicate what follow-up NDE was performed to characterize flaws in the leaking penetrations.
Entergy Response to Request 1(b):
As provided in the table above, the IP2 and the IP3 Pressurizer nozzles are stainless steel base material and stainless steel weld material. Since stainless steel materials in PWR environment are not susceptible to the same PWSCC mechanism as the Alloy 821182/600 materials, neither IP2 nor IP3 have implemented any augmented inspection programs for Alloy 82/182/600 materials for the pressurizer. The Inservice inspections of the IP2 and the IP3 pressurizers have been performed in accordance with the ASME Section Xl ISI program, the risk based ISI program and approved relief requests, which also includes piping welds on the Pressurizer safety, spray, surge and relief lines. Currently, piping welds on the surge line are selected for inspection. In addition, the system pressure tests of piping are performed during regular intervals of every refueling outage for Class 1 piping.
NL-04-090 Attachment 1 Page 3 of 5 Generic Letter (GL) 88-05, Bonrc Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, required four areas to be considered for ensuring that licensees boric acid inspection processes were adequate to identify reactor coolant pressure boundary (RCPB) leakage that could degrade carbon steel piping and components. This includes the following actions:
(1) A determination of the principal locations where leaks can cause degradation of the primary pressure boundary by boric acid corrosion.
(2) Establishing procedures for locating coolant leaks.
(3) Establishing methods for conducting examinations and performing engineering evaluations to establish the impact on the RCPB when leakage is located, and (4) Establishing corrective actions to prevent recurrences of boric acid corrosion.
The IP2 and the IP3 boric acid program has also been established under procedural control for compliance to our commitments for GL 88-05 as well as site wide improvements in boric acid identification and control. Although neither the IP2 nor the IP3 pressurizers contain Alloy 82/182/600 materials, visual inspections under the pressurizer (i.e. pressurizer heaters) were performed during each of the last refueling outages for both IP2 and for IP3. These inspections were performed without insulation removal. No boron deposits were identified during these inspections.
Previous IP2 and IP3 Pressurizer Inspection Findings and Repairs-As discussed above, the IP2 and the lP3 pressurizers have been inspected by visual, surface and volumetric methods as required by ASME Xl, IWB-2000, 1989 Edition with no Addenda, and NRC approved relief requests. No degradation has been identified during any of these inspections.
Basis for Concluding that Your Plant Will Satisfy Applicable Regulatory Requirements:
Since the IP2 and the IP3 pressurizer nozzles and penetrations were fabricated with stainless steel materials which are resistant to PWSCC and these nozzles and penetrations have been inspected in accordance with the ASME Section Xl requirements, it is concluded that the IP2 and the IP3 pressurizers are in full compliance with the applicable regulatory requirements.
NL-04-090 Attachment I Page 4 of 5 NRC Request 1(c):
A description of the Alloy 82/182/600 pressurizer penetration and steam space piping connection inspection program that will be implemented at your plant during the next and subsequent refueling outages. The description should include the areas, penetrations and steam space piping connections to be inspected; the extent (percentage) of coverage to be achieved for each location; inspection methods to be used; qualification standards for the inspection methods and personnel; the process used to resolve any inspection indications; the inspection documentation to be generated; and the basis for concluding that your plant will satisfy applicable regulatory requirements related to the structural and leakage integrity of pressurizer penetrations and steam space piping connections. If leaking pressurizer penetrations or steam space piping connections are found, indicate what follow-up NDE will be performed to characterize flaws in the leaking penetrations. Provide your plans for expansion of the scope of NDE to be performed if circumferential flaws are found in any portion of the leaking pressurizer penetrations or steam space piping connections.
Entergy Response to NRC Request 1(c):
IP2 and IP3 will continue to implement the ASME Section Xi inspection requirements for the pressurizer nozzles and penetrations. Stainless steel materials in the IP2 and IP3 pressurizer nozzles and welded joints are not susceptible to the same PWSCC mechanism as the Alloy 821182/600 materials. However, IP2 and IP3 will also continue to monitor industry experience relative to cracking of these components and will enhance these inspection programs in the future if it warranted to address any emerging degradation mechanism.
NRC Request 1(d)
In light of the information discussed in this bulletin and your understanding of the relevance of recent industry operating experience to your facility, explain why the inspection program identified in your response to item (1)(c) above is adequate for the purpose of maintaining the integrity of your facility's RCPB and for meeting all applicable regulatory requirements which pertain to your facility.
Entergy Response to NRC Request 1(d):
The proposed actions by Entergy for IP2 and for IP3 meet the expectations requested by Bulletin 2004-01 and are considered appropriate for maintaining the integrity of IP2's and IP3's RCPB and meet applicable regulatory requirements which pertain to IP2 and IP3.
NL-04-090 Attachment 1 Page 5 of 5 NRC Request 2:
Within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetrations and steam space piping connections, the subject PWR licensees should either:
(a) submit to the NRC a statement indicating that the inspections described in the licensee's response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, follow-up NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found, or (b) if the licensee was unable to complete the inspections described in response to item (1)(c) of this bulletin, submit to the NRC a summary of the inspections performed, the extent of the inspections, the methods used, a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, follow-up NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found. In addition, supplement the answer which you provided to item (1)(d) above to explain why the inspections that you completed were adequate for the purpose of maintaining the integrity of your facility's RCPB and for meeting all applicable regulatory requirements which pertain to your facility.
For lines attached directly to the pressurizer, with the exception of the surge line, the information requested in (1) and (2) above should be provided for any locations, including those remote from the pressurizer shell, which contain Alloy 82/182/600 materials which are exposed to conditions similar to those of the pressurizer environment.
Entergy Response to NRC Request 2:
Since neither the IP2 nor the IP3 pressurizers contain Alloy 821182/600 components, this requirement is not applicable to IP2 or to IP3.
Text
Entergy Nuclear Northeast Indian Point Energy Center
'Entergy 450 Broadway, GSB R0. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration July 26, 2004 NL-04-090 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Indian Point Nuclear Generating Units No. 2 and No. 3 Docket No. 50-247, and 50-286 Response to NRC Bulletin 2004-01 Regarding Inspection of Alloy 82/182/600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections
References:
- 1. NRC letter dated May 28, 2004, NRC Bulletin 2004-01: Inspection of Alloy 82/182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors.
Dear Sir or Madam:
On May 28, 2004, the Nuclear Regulatory Commission (NRC) issued NRC Bulletin 2004-01, Inspection of Alloy 82/182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. The NRC requested that all pressurized water reactor addressees provide description of their pressurizer heater and steam space penetrations and inspection plans for the forthcoming and subsequent refueling outages.
Entergy Nuclear Operations, Inc is providing the response to Bulletin 2004-01 in Attachment 1 for Indian Point Nuclear Generating Units No. 2 (IP2) and No. 3 (IP3). There are no new commitments made in this letter regarding NRC question number 2 as it is not applicable to either IP2 or IP3.
If you have any questions, please contact Mr. Pat Conroy at 914-734-6668.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on July 7-& , 2004.
VesHyly ours, Fred R. Dacimo Site Vice President Indian Point Energy Center cc: next page
NL-04-090 Page 2 of 2 cc:
Mr. Hubert J. Miller Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, DC 20555-0001 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Senior Resident Inspector's Office Indian Point Unit 2 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511-0038 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203
Attachment 1 to NL-04-090 Response to NRC Bulletin 2004-01, Inspection of Alloy 8211821600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKETS 50-247 AND 50-286
NL-04-090 Attachment I Page 1 of 5 Response to Bulletin 2004-01 for Indian Point Units 2 and 3 Inspection of Alloy 8211821600 Materials Used In Pressurizer Penetrations and Steam Space Piping Connections On May 28, 2004, the Nuclear Regulatory Commission (NRC) issued Bulletin 2004-01, Inspection of Alloy 821182/600 Materials Used In the Fabrication of Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors. The 60-day response to the bulletin for Indian Point Units 2 (1P2) and 3 (IP3)is provided below.
NRC Request 1(a):
A description of the pressurizer penetrations and steam space piping connections at your plant.
At a minimum, this description should include materials of construction (e.g., stainless steel piping and/or weld metal, Alloy 600 piping/sleeves, Alloy 821182 weld metal or buttering, etc.),
joint design (e.g., partial penetration welds, full penetration welds, bolted connections, etc.),
and, in the case of weldedjoints, whether or not the weld was stress-relieved prior to being put into service. Additional information relevant with respect to determining the susceptibility of your plant's pressurizer penetrations and steam space piping connections to PWSCC should also be included.
Entergy Response to Request 1(a):
The IP2 and IP3 pressurizers are low alloy steel vessels internally clad with austenitic stainless steel (type 304 or equivalent). The shells consist of SA 320 Grade B material while the upper and lower heads consist of SA 216, Grade WCC. Each pressurizer was furnished with six 3/4",
stainless steel level instrument nozzles, two 34"stainless steel temperature instrument nozzles and one 1", stainless steel sample nozzle. Three level and one temperature 3/4" nozzles are located in the upper head and three level and one temperature nozzle in the lower head. The 1" sample nozzle is located in the lower head. The SA-182, F316 stainless steel nozzles are welded with a partial penetration stainless steel weld to the inside of the pressurizer and allowed to thermally expand radially through the vessel wall as the RCS heats up. Stainless steel materials in the IP2 and IP3 pressurizer nozzles and welded joints are not susceptible to the same PWSCC mechanism as the Alloy 82/182/600 materials.
The following table provides the pressurizer heater and steam space penetration descriptions for IP2 and IP3.
NL-04-090 Attachment 1 Page 2 of 5 IP2/IP3 Pressurizer Nozzle Description Penetration/ Penetration Size Joint Design Materials Description (#) (safe end material/weld material)N" '
Pzr Heater (78) N/A PP SS/SS Surge Line (1) 14", Sched. 140 FP SS/SS Spray Nozzle (1) 4", Sched. 160 FP SS/SS Relief Nozzle (1) 4", Sched. 160 FP SS/SS Safety Nozzle (3) 3.5" Special FP SS/SS Level Inst. Nozzle %", Sched. 160 PP SS/SS (6)
Temp. Inst. Nozzle 3/4", Sched 160 PP SS/SS (2)
Sample Nozzle (1) I inch, Sched 160 PP SS/SS Manway (1) 16 inch Bolted CS PP = Partial Penetration; FP = Full Penetration Note 1: base/safe end material is SA-1 82, F3 16 NRC Request 1(b):
A description of the inspection program for Alloy 82/1821600 pressurizer penetrations and steam space piping connections that has been implemented at your plant. The description should include when the inspections were performed; the areas, penetrations and steam space piping connections inspected; the extent (percentage) of coverage achieved for each location which was inspected; the inspection methods used; the process used to resolve any inspection findings; the quality of the documentation of the inspections (e.g., written report, video record, photographs); and, the basis for concluding that your plant satisfies applicable regulatory requirements related to the integrity of pressurizer penetrations and steam space piping connections. If leaking pressurizer penetrations or steam space piping connections were found, indicate what follow-up NDE was performed to characterize flaws in the leaking penetrations.
Entergy Response to Request 1(b):
As provided in the table above, the IP2 and the IP3 Pressurizer nozzles are stainless steel base material and stainless steel weld material. Since stainless steel materials in PWR environment are not susceptible to the same PWSCC mechanism as the Alloy 821182/600 materials, neither IP2 nor IP3 have implemented any augmented inspection programs for Alloy 82/182/600 materials for the pressurizer. The Inservice inspections of the IP2 and the IP3 pressurizers have been performed in accordance with the ASME Section Xl ISI program, the risk based ISI program and approved relief requests, which also includes piping welds on the Pressurizer safety, spray, surge and relief lines. Currently, piping welds on the surge line are selected for inspection. In addition, the system pressure tests of piping are performed during regular intervals of every refueling outage for Class 1 piping.
NL-04-090 Attachment 1 Page 3 of 5 Generic Letter (GL) 88-05, Bonrc Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants, required four areas to be considered for ensuring that licensees boric acid inspection processes were adequate to identify reactor coolant pressure boundary (RCPB) leakage that could degrade carbon steel piping and components. This includes the following actions:
(1) A determination of the principal locations where leaks can cause degradation of the primary pressure boundary by boric acid corrosion.
(2) Establishing procedures for locating coolant leaks.
(3) Establishing methods for conducting examinations and performing engineering evaluations to establish the impact on the RCPB when leakage is located, and (4) Establishing corrective actions to prevent recurrences of boric acid corrosion.
The IP2 and the IP3 boric acid program has also been established under procedural control for compliance to our commitments for GL 88-05 as well as site wide improvements in boric acid identification and control. Although neither the IP2 nor the IP3 pressurizers contain Alloy 82/182/600 materials, visual inspections under the pressurizer (i.e. pressurizer heaters) were performed during each of the last refueling outages for both IP2 and for IP3. These inspections were performed without insulation removal. No boron deposits were identified during these inspections.
Previous IP2 and IP3 Pressurizer Inspection Findings and Repairs-As discussed above, the IP2 and the lP3 pressurizers have been inspected by visual, surface and volumetric methods as required by ASME Xl, IWB-2000, 1989 Edition with no Addenda, and NRC approved relief requests. No degradation has been identified during any of these inspections.
Basis for Concluding that Your Plant Will Satisfy Applicable Regulatory Requirements:
Since the IP2 and the IP3 pressurizer nozzles and penetrations were fabricated with stainless steel materials which are resistant to PWSCC and these nozzles and penetrations have been inspected in accordance with the ASME Section Xl requirements, it is concluded that the IP2 and the IP3 pressurizers are in full compliance with the applicable regulatory requirements.
NL-04-090 Attachment I Page 4 of 5 NRC Request 1(c):
A description of the Alloy 82/182/600 pressurizer penetration and steam space piping connection inspection program that will be implemented at your plant during the next and subsequent refueling outages. The description should include the areas, penetrations and steam space piping connections to be inspected; the extent (percentage) of coverage to be achieved for each location; inspection methods to be used; qualification standards for the inspection methods and personnel; the process used to resolve any inspection indications; the inspection documentation to be generated; and the basis for concluding that your plant will satisfy applicable regulatory requirements related to the structural and leakage integrity of pressurizer penetrations and steam space piping connections. If leaking pressurizer penetrations or steam space piping connections are found, indicate what follow-up NDE will be performed to characterize flaws in the leaking penetrations. Provide your plans for expansion of the scope of NDE to be performed if circumferential flaws are found in any portion of the leaking pressurizer penetrations or steam space piping connections.
Entergy Response to NRC Request 1(c):
IP2 and IP3 will continue to implement the ASME Section Xi inspection requirements for the pressurizer nozzles and penetrations. Stainless steel materials in the IP2 and IP3 pressurizer nozzles and welded joints are not susceptible to the same PWSCC mechanism as the Alloy 821182/600 materials. However, IP2 and IP3 will also continue to monitor industry experience relative to cracking of these components and will enhance these inspection programs in the future if it warranted to address any emerging degradation mechanism.
NRC Request 1(d)
In light of the information discussed in this bulletin and your understanding of the relevance of recent industry operating experience to your facility, explain why the inspection program identified in your response to item (1)(c) above is adequate for the purpose of maintaining the integrity of your facility's RCPB and for meeting all applicable regulatory requirements which pertain to your facility.
Entergy Response to NRC Request 1(d):
The proposed actions by Entergy for IP2 and for IP3 meet the expectations requested by Bulletin 2004-01 and are considered appropriate for maintaining the integrity of IP2's and IP3's RCPB and meet applicable regulatory requirements which pertain to IP2 and IP3.
NL-04-090 Attachment 1 Page 5 of 5 NRC Request 2:
Within 60 days of plant restart following the next inspection of the Alloy 82/182/600 pressurizer penetrations and steam space piping connections, the subject PWR licensees should either:
(a) submit to the NRC a statement indicating that the inspections described in the licensee's response to item (1)(c) of this bulletin were completed and a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, follow-up NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found, or (b) if the licensee was unable to complete the inspections described in response to item (1)(c) of this bulletin, submit to the NRC a summary of the inspections performed, the extent of the inspections, the methods used, a description of the as-found condition of the pressurizer shell, any findings of relevant indications of through-wall leakage, follow-up NDE performed to characterize flaws in leaking penetrations or steam space piping connections, a summary of all relevant indications found by NDE, a summary of the disposition of any findings of boric acid, and any corrective actions taken and/or repairs made as a result of the indications found. In addition, supplement the answer which you provided to item (1)(d) above to explain why the inspections that you completed were adequate for the purpose of maintaining the integrity of your facility's RCPB and for meeting all applicable regulatory requirements which pertain to your facility.
For lines attached directly to the pressurizer, with the exception of the surge line, the information requested in (1) and (2) above should be provided for any locations, including those remote from the pressurizer shell, which contain Alloy 82/182/600 materials which are exposed to conditions similar to those of the pressurizer environment.
Entergy Response to NRC Request 2:
Since neither the IP2 nor the IP3 pressurizers contain Alloy 821182/600 components, this requirement is not applicable to IP2 or to IP3.