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Request for Relief Request IP2-ISI-RR-01 Examination of Upper Pressurizer Welds
	ML15317A131
Person / Time
Site:	Indian Point
Issue date:	10/29/2015
From:	Coyle L; Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-15-138
	Download: ML15317A131 (7)
	v • d • e

Enep ula otes Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Lawrence Coyle Site Vice President NL-1 5-1 38 October 29, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Request for Relief Request IP2-lSI-RR-01 Examination of Upper Pressurizer Welds Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(g)(5)(iii), Entergy Nuclear Operations, Inc. (Entergy) requests relief to use an alternative to the 2007 edition with the 2008 Addenda of ASME Section Xl requirements in Table IWB-2500-1 Category B-B, Notes 2 and Note 4. This requires that the volumetric examination coverage stipulated by Figures IWB-2500-1 and 2 be performed on 100%

of the Code Class 1 circumferential welds and the adjoining 1 foot section of one longitudinal weld that intersects the circumferential weld. This relief request is for the Fifth 10-year ISI Interval is scheduled to start June 1, 2016 when IP-2 updates to the 2007 Edition/2008 Addenda of ASME Section Xl for performing ISI.

Entergy Nuclear Operations, Inc. (Entergy) is submitting, enclosed, Relief Request No. 1 (IP2-1SI-RR-01) 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(g)(5)(iii) because of certainty the inspection cannot be made. The requirements of 10 CFR 50.55a(g)(5)(iii) are:

"ISI program update: Notification of impractical ISI Code requirements. If the licensee has determined that conformance with a Code requirement is impractical for its facility the licensee must notify the NRC and submit, as specified in § 50.4, information to support the determinations. Determinations of impracticality in accordance with this section must be based on the demonstrated limitations experienced when attempting to comply with the Code requirements during the inservice inspection interval for which the request is being submitted. Requests for relief made in accordance with this section must be submitted to the NRC no later than 12 months after the expiration of the initial or subsequent 120-month inspection interval for which relief is sought."

NL-1 5-138 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,

Attachment:

10 CFR 50.55a Request No. IP2-1SI-RR-01 Proposed Alternative in Accordance With 10 CFR 50.55a(g)(5)(iii) 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-1 5-1 38 10 CFR 50.55a REQUEST NO. IP2-1SI-RR-0l PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)

ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-15-138 Docket No. 50-247 Attachment Page 1 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-01 Proposed Alternative in Accordance With 10 CFR 50.55a(g)(5)(iii)

Examination of Upper Pressurizer Welds

1. ASME COMPONENT IDENTIFICATION Class:

1

References:

IWB-2500- 1, Category B-B, Figure IWB-2500- 1 and 2 Examination Category: B-B Item Numbers:

B2.11, B2.12

==

Description:==

Inspection of Pressurizer Upper Shell-To-Head Circumferential and Longitudinal Welds Component Numbers:

PZRC-5 and PZRL-4 Reference Drawings:

9321-F-2545

2. APPLICABLE ASME CODE REQUIREMENTS The 2007 edition with the 2008 Addenda of ASME Section Xl requires in Table IWB-2500-1 Category B-B, Notes 2 and Note 4, that the volumetric examination coverage stipulated by Figures IWB-2500-1 and 2 be performed on 100% of the Code Class 1 circumferential welds and the adjoining 1 foot section of one longitudinal weld that intersects the circumferential weld per head.

3. REASON FOR REQUEST The upper circumferential (PZRC-5) and longitudinal (PZRL-4) welds are enclosed in a biological and missile shield and are completely inaccessible for volumetric examination. Gaining access to perform the examinations at these two locations is considered impractical without a major plant redesign and modification, and is the reason for this relief request. No Code examination can be performed, so this request is being proposed in advance of the scheduling requirement.

4. IMPRACTICALITY OF COMPLIANCE Pursuant to 10 CFR 50.55a(g)(5)(iii) relief is requested on the basis that compliance with the Code requirement is impractical. The pressurizer, insulation and shielding at Indian Point Unit 2 (IP2) was designed and fabricated to Codes in effect during the late 1960's and did not incorporate the clearances needed for the examination of the upper pressurizer welds.

The pressurizer was first installed and insulated, then the concrete biological shield was installed, and next all the piping in the top of the pressurizer was welded. The annular area between the vessel and the biological shield wall measures about eight inches, of which half is filled with asbestos insulation (see attached drawing 9321-F - 2545 for the illustration of that clearance measurement). The upper circumferential (PZRC-5) and longitudinal (PZRL-4) welds are enclosed in this biological and missile shield and are therefore completely inaccessible for volumetric examination. The NRC staff approval of a similar request (ML072130487) for the

NL-1 5-1 38 Docket No. 50-247 Attachment Page 2 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-01 Proposed Alternative in Accordance With 10 CFR 50.55a(g)(5)(iii)

Examination of Upper Pressurizer Welds fourth interval and stated in the Safety Evaluation; "The NRC staff determined that in order for the licensee to gain access to the subject welds to perform ASME Code-required volumetric examinations, the PZR and piping would have to be redesigned, including the removal of the asbestos insulation and the removal and modification of the concrete biological shield surrounding the PZR. These modifications would place a burden on the licensee."

5. PROPOSED ALTERNATIVE AND BASIS FOR USE The examination of the accessible portions of the shell-to-bottom head circumferential and intersecting longitudinal weld (PZRC-1 and PZRL-1) will be performed as required by IWB-2500.

Alternatively for the upper pressurizer welds, it is proposed that they be visually examined (VT-2) during each refueling outage for evidence of leakage during system pressure tests performed in accordance with IWB-2500, Category B-P. It is expected that any through wall defects would be detected by this examination prior to the failure of the pressurizer based on the expectation that the component will experience leakage before a catastrophic failure ("leak before break"). Additionally, the IP2 Improved Technical Specifications (TS) Bases, Section B3.4.15, state the IP2 leakage detection system has the capability of detecting leakage increases of 0.5 to 1.0 gallons per minute.

Also IP2 TS 3.4.15 requires the monitoring of atmospheric radioactivity in containment.

The level of inspections proposed for the fifth interval has been in effect for the previous inspection intervals at Indian Point Unit 2. Based on the reliable operating history of this and similar vessels at other plants, the performance of VT-2 examinations for leakage, the TS required monitoring, approval of this request continues to provide reasonable assurance of the leak tightness of the upper pressurizer welds (PZRC-5 and PZRL-4).

6.

DURATION OF PROPOSED RELIEF REQUEST The proposed duration of this request is for the Fifth Inspection Interval starting June 1, 2016 and currently scheduled to end May 31, 2026.

7. PRECEDENTS Indian Point Unit 2 Fourth Interval Relief Request, RR-01, dated February 28, 2007 was similar and approved by the NRC on September 5, 2007 (TAC NO. MD4695, ADAMS Accession NO. ML072130487)

8. ATTACHMENTS Drawing 9321-F -2545

NL-15-138 Docket No. 50-247 Attachment Page 3 of 4 Indian Point Unit 2 Nuclear Plant 10 CFR 50.55a Request No: IP2-1SI-RR-01 Alternative in Accordance With 10 CFR 50.55a(g)(5)(iii)

Examination of Upper Pressurizer Welds Proposed Drawing 9321-F - 2545