NL-17-059, Request IP2-ISI-RR-22 for Relief from Examination of Non-Regenerative Heat Exchanger Base Support Welded Attachments for Fourth Ten-Year Inservice Inspection Interval Closeout

Request IP2-ISI-RR-22 for Relief from Examination of Non-Regenerative Heat Exchanger Base Support Welded Attachments for Fourth Ten-Year Inservice Inspection Interval Closeout

ML17159A523
Person / Time
Site:	Indian Point
Issue date:	05/30/2017
From:	Vitale A Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-059
Download: ML17159A523 (8)

Text

Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB

~ Entergx P.O. Box 249 Buchanan , NY 10511-0249 Tel 914 254 6700 Anthony J. Vitale Site Vice President May 30, 2017 NL-17-059 U.S . Nuclear Regulatory Commission ATTN : Document Control Desk 11555 Rockville Pike, OWFN-2 F1 Rockville , MD 20852-2738

SUBJECT:

Request IP2-ISl-RR-22 for Relief from Examination of Non-Regenerative Heat Exchanger Base Support Welded Attachments for Fourth Ten-Year lnservice Inspection Interval Closeout Indian Point Unit No. 2 Docket No. 50-247 License No . DPR-26

Dear Sir or Madam :

The Indian Point Unit No. 2 (IP2) Fourth Ten-Year inservice inspection interval ended on May 31 , 2016. During the Fourth interval, IP2 completed the required in-service examinations in accordance with the program plan , except that the visual examination requirements stipulated in the ASME Section XI Code, 2001 Edition , 2003 Addenda , could not be met for the Non-Regenerative Heat Exchanger. Entergy Nuclear Operations, Inc.

(Entergy) has determined that conformance with the code requirement of essentially 100%

coverage of weld area examined was impractical due to various constraints and limitations.

Accordingly, pursuant to 10CFR 50.55a(g)(5)(iii) , Entergy submits the attached IP2 Relief Request IP2-ISl-RR-22 for NRC review and approval. The relief request proposes alternatives where the requirement of a VT-1 visual examination was not feasible due to the high dose that would be obtained . The alternatives and justifications are explained in the attachment. The alternatives and justifications provide an acceptable level of quality and safety and will not adversely impact the health and safety of the public.

Entergy requests approval of the relief request by February 2018 to support the IP2 Refueling Outage 2R23.

It was discovered that this same relief request was also required for the Third Ten-Year lnservice Inspection Interval , but documentation of the request could not be located . This discrepancy has been documented in Condition Report CR-IP2-2017-01587 in the Indian Point Corrective Action Program .

NL-17-059 Docket No. 50-247 Page 2 of 2 Should you have any questions concerning this letter or require additional information ,

please contact Mr. Robert Walpole , Manager, Regulatory Assurance at (914) 254-6710.

Sincerely, AJV/gd : Request IP2-ISl-RR-22 for Relief from Examination of Non-Regenerative Heat Exchanger Base Support Welded Attachments for Fourth Ten-Year lnservice Inspection Interval Closeout cc: Mr. Richard Guzman , Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman , Regional Administrator, NRC Region 1 NRC Resident Inspector's Office Mr. John B. Rhodes , President and CEO, NYSERDA Ms . Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT 1 to NL-17-059 Request IP2-ISl-RR-22 for Relief from Examination of Non-Regenerative Heat Exchanger Base Support Welded Attachments for Fourth Ten-Year lnservice Inspection Interval Closeout ENTERGY NUCLEAR OPERATIONS , INC.

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

NL-17-059 Docket No. 50-247 Attachment 1 Page 1 of 2 Indian Point Unit No. 2 Fourth 10-year ISi Interval Relief Request No. IP2-ISl-RR-22 Proposed Alternative In Accordance with 10 CFR 50.55a(g)(5)(iii) lnservice Inspection Impracticality

1. ASME Code Component(s) Affected Code Class: 3

References:

IWD-2500-1 Examination Categories: D-A Item Numbers: 01 .10

==

Description:==

Non-Regenerative Heat Exchanger Welded Attachments Component Number: NRHE-21-W Reference Drawings: A206921 , INSUL-206921

2. Applicable Code Edition and Addenda

The Code of Record for Indian Point Unit No. 2 (IP2) lnservice Inspection Fourth Ten-Year Interval is the ASME Section XI Code, 2001 Edition , 2003 Addenda .

3. Applicable Code Requirements ASME Section XI Code, 2001 Edition, 2003 Addenda , Sub-article IWD-2500 states in part, "Components shall be examined and tested as specified in Table IWD-2500-1 ." Table IWD-2500-1 requires an examination of applicable Class 3 pressure vessels welded attachments, which includes essentially 100% of the length of the attachment welded at each attachment subject to [VT-1 visual] examination .

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 Non-Regenerative Heat Exchanger vessel is fully covered with asbestos insulation at IP2. The welded attachments on both sides of the base support at the north and south side of the vessel are also covered with asbestos insulation and therefore are not accessible for the examination of the welds that attach the base support to the vessel.

(See attached drawing INSUL-206921 for the illustration of the Non-Regenerative Heat Exchanger No. 21 insulation details.)

NL-17-059 Docket No . 50-247 Attachment 1 Page 2 of 2

5. Reason for Request

The Non-Regenerative Heat Exchanger base support welded attachments are located in a high dose area. The welded attachments from the vessel to the base support are insulated with asbestos and cannot be accessed without the removal of the insulation . Gaining access to perform the examination at that location is considered impractical based on the high dose area and the personnel exposure that would result from the abatement and removal of the asbestos insulation, approximately 2.6 Rem . An attempt to examine the base support welded attachments was performed during the 2R22 (2016) refueling outage, but the interference from the insulation prevented the performance of the VT-1 exam ination of the base support welded attachments. Only a VT-2 visual examination (3 and one third-year frequency) was performed concurrent with an inservice leakage test on the Non-Regenerative Heat Exchanger Vessel ,

and a VT-3 visual examination of the base support was performed , with no unacceptable conditions identified .

6. Proposed Alternative and Basis for Use A VT-2 visual examination (3 and one third-year frequency) was performed concurrent with an inservice leakage test on the Non-Regenerative Heat Exchanger Vessel and a VT-3 visual inspection was also performed on the Non-Regenerative Heat Exchanger Vessel base support as alternative exam inations during the inspection interval. These examinations provide continued assurance that the structural integrity of the subject components is maintained .

Therefore , reasonable assurance of quality and safety is based on results of the VT-3 visual examination and VT-2 examination performed concurrent with the inservice leak test.

7. Duration of Proposed Alternative Relief is requested for the Fourth Ten-year Interval of the lnservice Inspection Program for IP2 which was effective from March 1, 2007, through May 31 , 2016.

8. Enclosure Drawings A206921 , INSUL-206921

ENCLOSURE Drawings A206921 and INSUL-20692

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