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Category:Legal-Intervention Petition
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
[Table view] Category:Responses and Contentions
MONTHYEARML11257A1102011-09-14014 September 2011 Certificate of Service for Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention and for Reply Memorandum Regarding Timeliness and Admissibility of New Contentions ML11257A1092011-09-13013 September 2011 Reply Memorandum Regarding Timeliness and Admissibility of New Contentions Seeking Consideration of Environmental Implications of Fukushima Task Force Report in Individual Reactor Licensing Proceedings ML11257A1112011-09-13013 September 2011 Riverkeeper, Inc. and Hudson River Sloop Clearwater, Inc.'S Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Motion to Admit New Contention Regarding the Fukushima Task Force Report ML11228A0302011-08-11011 August 2011 the State of New York and the State of Connecticut'S Joint Answer in Opposition to Entergy'S Petition for Interlocutory Review of LBP-11-17 ML11217A0662011-07-29029 July 2011 Applicant'S Petition for Review of LBP-11-17 Granting Summary Disposition of Consolidated Contention NYS-35/36 ML11210B4192011-07-26026 July 2011 State of New York'S Response to Applicant'S Motion for Clarification of Licensing Board Admissibility Rulings on Contentions NYS-17B and NYS-37 ML11179A0922011-06-21021 June 2011 Letter Regarding New York State Department of Environmental Conservation Comments on the NRC Staff'S Final Supplemental Environmental Impact Statement in the Matter of Indian Point, Units 2 and 3, License Renewals ML11133A2882011-04-29029 April 2011 Indian Point, Units 2 & 3, State Submittal of Letter to Bring Two Recent Documents to Attention of the Board and Parties in Connection with NYS Contention-25 ML11117A1462011-04-19019 April 2011 Emergency Petition to Suspend All Pending Reactor Licensing Decisions and Related Rulemaking Decisions Pending Investigation of Lessons Learned from Fukushima Dahchi Nuclear Power Station Accident ML11229A8022011-03-22022 March 2011 Supplementary Certification Regarding Consultation ML11108A1062011-03-21021 March 2011 Combined Reply to Staff and Entergy'S Answers in Opposition to Clearwater'S Motion for Leave and Petition to Amend Contention EC-3 ML1108307802011-03-18018 March 2011 State of New York'S Combined Reply to Entergy and NRC Staff'S Answers to the State'S Proposed Contention 37 Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Its Deficient Analysis of Energy Alternatives ML1107601812011-03-16016 March 2011 Indian Point - Supplement to NRC Staff'S Answer to Riverkeeper, Inc.'S Motion for Leave to File a New Contention, and New Contention EC-8 Concerning NRC Staff'S Final Supplemental Environmental Impact Statement ML1107000972011-03-0404 March 2011 State of New York'S Combined Reply to the Answer of Entergy and NRC Staff to the State'S Proposed Amended Contention NYS-17B ML1106703812011-02-25025 February 2011 Combined Reply to NRC Staff and Entergy'S Answers in Opposition to Clearwater and Riverkeeper'S Joint Motion for Leave and Petition to Add New Contentions ML1107402862011-02-23023 February 2011 State of New York Withdrawal of Request for Enlargement of Page Limitation for the State'S Consolidated Answer to Separate Motions for Summary Disposition on Contention 35/36 ML1106604252011-02-23023 February 2011 State of New York'S Combined Reply to Entergy and Staff Cross-Motions for Summary Disposition on NYS Combined Contentions 35 and 36 Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1105602702011-02-18018 February 2011 Applicant'S Answer to Hudson River Sloop Clearwater, Inc. and Riverkeeper, Inc.'S New Contentions Concerning the Waste Confidence Rule ML1105605892011-02-18018 February 2011 Applicant'S Answer to Proposed Amended Contention, New York State 17B and the Associated Request for Exemption And/Or Waiver of 10 C.F.R. Section 51.23(b) ML1104604922011-02-10010 February 2011 State of New York Answer in Support of the Admission of Clearwater and Riverkeeper'S Proposed Waste Confidence Contentions ML1106802122011-02-0303 February 2011 State of New York New Contention 12-C Concerning NRC Staff'S December 2010 Final Environmental Impact Statement and Underestimation of Decontamination & Clean Up Costs Associated with Severe Reactor Accident in New York Metropolitan Area ML1030000602010-10-22022 October 2010 State of New York'S Joint Reply to Entergy and NRC Staff'S Separate Answers to the State'S Additional Bases for Previously-Admitted Contention NYS-25 ML1030101042010-10-12012 October 2010 Applicant'S Answer to Amended Contention New York State 25 Concerning Aging Management of Embrittlement of Reactor Pressure Vessel Internals ML1029101452010-10-0404 October 2010 Supporting Attachments to Applicants Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1028802972010-10-0404 October 2010 Letter from Martin J. O'Neill Counsel for Entergy Nuclear Operations, Inc. to Emile L. Julian Attachments 8 & 13 to Entergy'S Answer to New & Amended Contention New York State 26B & Riverkeeper TC-1B ML1029101422010-10-0404 October 2010 Applicant'S Answer to New and Amended Contention New York State 26B/Riverkeeper TC-1B (Metal Fatigue) ML1030105182010-09-14014 September 2010 State of Ny & Riverkeeper, Inc Submittal of Counter Statement of Material Fact, Combined Response to Entergy'S Motion for Summary Disposition of Combined Contentions NYS 26/26A & Rk TC-1/TC-1A, Declaration of Janice A. Dean.. ML1023712142010-08-16016 August 2010 Riverkeeper Opposition to Entergy'S Motion for Summary Disposition of Riverkeeper Technical Contention 2 (Flow-Accelerated Corrosion) ML1023001462010-08-13013 August 2010 Entergy'S Answer to Riverkeeper Inc.'S Motion to Compel Disclosure of Documents ML1022405782010-08-0202 August 2010 Applicant'S Reply to the State of New York'S & State of Connecticut'S Combined Reply to Entergy & NRC Staff Petitions for Interlocutory Review of LBP-10-13 ML1021100862010-07-26026 July 2010 the State of New York'S and State of Connecticut'S Combined Reply to Entergy and NRC Staff Petitions for Interlocutory Review of the Atomic Safety and Licensing Board'S Decision Admitting the State of New York'S Contentions 35 & 36 (LBP-10- ML1020300502010-07-15015 July 2010 Applicant'S Petition for Interlocutory Review of LBP-10-13 ML1011604152010-04-12012 April 2010 State of New York'S Combined Reply to Energy and NRC Staff Answers to the State'S New and Amended Contentions Concerning the December 2009 Severe Accident Mitigation Alternative Reanalysis ML1014503282010-04-0505 April 2010 Applicant'S Answer to New York State'S New and Amended Contentions Concerning Entergy'S December 2009 Revised SAMA Analysis ML1011004732010-04-0101 April 2010 Answer of the Attorney General of the State of Connecticut to State of New York'S Motion for Leave to File New & Amended Contentions Concerning the December 2009 Reanalysis of Severe Accident Mitigation Alternatives ML1005702402009-11-20020 November 2009 Answer of Richard Blumenthal, Attorney General of Connecticut to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-level Radioactive Waste at Indian Point ML0934803252009-11-20020 November 2009 Answer to Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML0934910432009-11-20020 November 2009 Indian Point - NRC Staff'S Answer to Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add New Contentions Based Upon New Information ML0935101942009-11-20020 November 2009 Town of Cortlandt'S Answer to Hudson River Sloop Clearwater, Inc'S Petition Presenting Supplemental Contentions EC-7 & SC-1 Re Storage of High-Level Radioactive Waste at Indian Point ML1005700112009-11-20020 November 2009 Answer of Riverkeeper, Inc. in Support of Hudson River Sloop Clearwater Inc.'S New Contentions EC-7 and SC-1 ML1008200282009-11-19019 November 2009 Answer of the State of New York to Hudson River Sloop Clearwater, Inc.'S Petition Presenting Supplemental Contentions EC-7 and SC-1 Concerning Storage of High-Level Radioactive Waste at Indian Point ML0930801292009-10-26026 October 2009 Hudson River Sloop Clearwater, Inc.'S Motion for Leave to Add a New Contention Based Upon New Information ML0909802072009-04-0707 April 2009 Lr - NRC Staff'S Answer to Hudson River Sloop Clearwater'S Petition to File New Contention, Based Upon New Information Regarding Environmental and Public Health Impacts of Using the Hudson River as a Drinking Water Supply ML0910502112009-04-0606 April 2009 Entergy'S Consolidated Response to Riverkeeper'S February & March 2009 Filings Concerning Consolidated Contention Riverkeeper EC-3/Clearwater EC-1 and Riverkeeper Contention TC-2 ML0909604702009-03-31031 March 2009 State of New York Combined Reply to Entergy Nuclear Operations, Inc., and NRC Staff in Support of Contentions 12-A, 16-A, 17-A, 33, and 34 ML0909302042009-03-24024 March 2009 Answer of Entergy Nuclear Operations, Inc. Opposing New and Amended Environmental Contentions of New York State ML0908401162009-03-24024 March 2009 Indian Point - NRC Staff'S Answer to Amended and New Contentions Filed by the State of New York and Riverkeeper, Inc., Concerning the Draft Supplemental Environmental Impact Statement ML0908608682009-03-18018 March 2009 Riverkeeper, Inc.'S Preservation of Right to Amend Contention TC-2 - Flow Accelerated Corrosion Based Upon NRC Staff'S Safety Evaluation Report with Open Items ML0906903032009-02-27027 February 2009 State of New York Contentions Concerning NRC Staff'S Draft Supplemental Environmental Impact Statement ML0904105002009-01-26026 January 2009 Entergy'S Reply to Riverkeeper'S Answer Opposing Interlocutory Appeal of Licensing Board Admission of Consolidated Contention 2011-09-14
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DOCKETED May 2, 2011 (8:30 a.m.)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF STATE OF NEW YORK OFFICE OF THE ATTORNEY GENERAL ERIC T. SCHNEIDERMAN DIVISION OF SOCIAL JUSTICE ATrORNEY GENERAL ENVIRONMENTALPROTECT1ON BUREAU April 29, 2011 Lawrence G. McDade, Chair Richard E. Wardwell Dr. Kaye D. Lathrop Atomic Safety and Licensing Board Administrative Judge Administrative Judge U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission. 190 Cedar Lane E.
Two White Flint North Mail Stop - T-3 F23 Ridgway, CO 81432 11545 Rockville Pike Two White FlintNorth Rockville, MD 20852-2738 11545 Rockville Pike Rockville, MD 20852-2738 Re: Indian Point Nuclear Generating Station, Unit 2 and Unit 3 Docket Nos. 50-247-LR/50-286-LR; ASLBP No. 07-858-03-LR-BDO0
Dear Administrative Judges:
The State submits this letter to bring two recent documents to the attention of the Board and the parties in connection with NYS Contention-25.
On September 15, 2010, New York State filed State of New York's Motion for Leave to File Additional Bases for Previously-Admitted Contentiop NYS-25 In Response to Entergy's July 14, 2010 Proposed Aging Management Program for Reactor Pressure Vessels and Internal Components, ML103050402. Included with the Motion was Additional Bases for Previously-Admitted Contention NYS-25 (Embrittlement of Reactor Pressure Vessels and Associated Internals). Id. Attachment. Among the proposed additional bases was:
3.4 Entergy's recently-proposed aging management program is also inadequate because it:
(a) does not specify with any meaningful precision when the replacement or repair of embrittled reactor vessel internal components will take place (NL-10-063 at 88);
(b) disavows taking any preventative action to manage the effects of embrittlement aging of reactor vessel internal components (NL- 10-063 at 86);
THE CAPITOL., ALBANY, N.Y. 12224-0341 0 PHONE (518) 473-3105 0 FAX (518) 473-2534
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(c) relies on less reliable remote-control VT-3 examinations to examine baffleformer assembly plates and edge bolts instead of the more-reliable volumetric ultrasonic testing (UT) (which Entergy states it will use to examine the nearby baffle-to-former bolting)
(NL-10-063 at 87; EPRI MRP-227 at 4-4 to 4-5, 4-14 to 4-16).
These deficiencies in the proposed aging management program violate 50 C.F.R. § 54.21 (c)(1) (iii) and could have profound safety consequences for the State and its citizens.
Id. Attachment at 2. In support of these bases the State provided, inter alia, the following:
7.5 Entergy did not disclose that certain visual examinations (class VT-3 examinations) would be done by remote control. EPRI MRP-227 at 4-4. Moreover, Entergy did not disclose that other visual examination methodologies (class VT- I and class EVT-1) have a greater degree of detection than class VT-3 examinations. Compare NL- 10-063 at 87 with EPRI MRP-227 at 4-4.
Id. Attachment at 3-4.
The State has found two documents on ADAMS, which according to ADAMS are dated March 22, 2011 and were posted on ADAMS on March 30, 2011, that provide additional direct support for proposed basis ¶ 3.4 (c) and that are supplemental to Supporting Evidence ¶ 7.5. The two documents, which are attached to this letter, are:
Reasons for Non-concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR) Materials Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0, 'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."' R.L. Tregoning RESIDE, ML 10770169 Comments for the Document Sponsor to Consider Pertaining to Non-Concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR)
Materials Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0,
'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."'
Michael J. Case RESIDE., ML110810787 Thank you for consideration of these documents.
Respectfully submitted, Assistant Attorney General cc: All individuals., parties, or NRC offices on the Service List
NYS April 29, 2011 letter Attachment Reasons for Non-concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR) Materials Reliability Program (MRP) Report 10 16596 (MRP-227), Revision 0, 'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."'
R.L. Tregoning RES/DE ML110770168
&
Comments for the Document Sponsor to Consider Pertaining to Non-Concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR)
Materials Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0, 'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."'
Michael J. Case RES/DE ML110810787
Reasons for Non-concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR) Materials Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0, 'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."'
R.L. Tregoning RES/DE The Materials Reliability Program's Report 1016596, Revision 0, "Pressurized Water Reactor (PWR) Internals Inspection and Evaluation" (MRP-227) provides the nuclear industry's requirements for conducting inspections of reactor vessel internals to satisfy commitments to conduct such inspections during the period of extended operation (i.e., license renewal).
Recognizing that many of these components have never been inspected throughout the first 40 years of operation, these commitments are necessary to provide the Nuclear Regulatory Commission (NRC) with reasonable assurance that the RVI components will continue to have acceptable performance under all licensing basis conditions. Inspection of components with high safety significance is especially important, even if the expectation is that degradation of these components is unlikely.
MRP-227 summarizes the results of industry's evaluation to identify the components that should be inspected. The industry first evaluated the susceptibility of each reactor vessel internal (RVI) component to one, or more, of eight degradation mechanisms. Components were judged to either be susceptible or not susceptible to one or more of these mechanisms. Then, a failure, modes, and effects analysis (FMECA) was conducted for those components initially identified as susceptible to degradation. The FMECA was used to further evaluate the likelihood of the materials susceptibility (e.g., low, medium, or high) and identify the severity of the damage that could occur if the component were to fail by the susceptible mechanism(s). Additional finite element simulation and engineering evaluations were also conducted for selected components to both verify and further evaluate the initial FMECA recommendations. These analyses, in total, were used to develop the MRP-277 recommended inspection categories for each RVI component.
The MRP-227 approach is generally adequate except that there is a high premium placed on a material's susceptibility. If a component is not deemed to be susceptible to one of the eight degradation mechanisms, then that component is not inspected regardless of the safety significance of the component. The potential deficiency with this rationale is that service failures tend to be driven by the local conditions (i.e., environment, stress, materials) at the failure location within the component and not the global conditions associated with the particular component. It is possible to have a good understanding and expectation of the global conditions, but much more difficult to accurately assess the local conditions that often lead to failure. One of the principal reasons for conducting inspections is to verify the expected component degradation and performance over the period of extended operations. The inspections also demonstrate the adequacy of relevant evaluations of component performance that are typically based on either laboratory or simulation testing.
The safety evaluation of MRP-227 (SE), in general, imposes several conditions and plant-specific action items that address many of the concerns that NRC staff has raised about possible gaps and inconsistencies in MRP-227 related both to the approach and the subsequent inspection recommendations. These conditions and action items are both appropriate and needed to provide NRC staff with reasonable assurance that the RVI components will perform their intended function under all licensing basis conditions. However, I believe that there is an additional condition which should be imposed to assure that the inspections are appropriate for identifying the degradation mechanism of concern in all components.
This additional condition is related to the recommended inspection methods. Of the eight degradation mechanisms, there are several that could lead to cracking within a component.
These mechanisms are fatigue, stress corrosion cracking (SCC), and irradiation-assisted stress corrosion cracking (IASCC). Often, MRP-227 recommends that either ultrasonic testing (UT) or enhanced visual testing level 1 (EVT-1) be performed to identify cracking due to these mechanisms. Both of these methods have been used in previous BWR and PWR RVI inspections and have generally been successful in identifying cracking before the ultimate failure of the inspected components. In my opinion, both of these examination methods are acceptable to identify such cracking during RVI inspections.
However, for several components, MRP-227 recommends that a less-sensitive visual inspection method :(i.e., VT-3) be used to identify cracking in the PWR RVI components. The VT-3 method, as identified within American Society of Mechanical Engineers* (ASME) Section Xl,.
Examination Category B-N-3 (and summarized in MRP-227), provides a set of relevant
-conditions (i.e., it is acceptable) for identifying
- 1. Structural distortion or displacement of parts to the extent that component function may be impaired;
- 2. Loose, missing, cracked, or fractured parts, bolting, or fasteners;
- 3. Corrosion or erosion that reduces the nominal section thickness by more than 5%;
- 4. Wear of mating surfaces that may lead to loss of function; and
- 5. Structural degradation of interior attachments such that the original cross-sectional area is reduced more than 5%
As indicated by the list, a VT-3 inspection is typically used to identify (1) gross deformation in a component, (2) missing or failed components, or (3) portions of a component or system that are missing or have failed (i.e., locking devices).
Conversely, the EVT-1 method, as summarized in MRP-227, contains additional requirements that are intended to improve the detection and characterization of discontinuities. As a result, EVT-1 inspections are capable of detecting small surface breaking cracks and sizing surface crack length when used in conjunction with sizing aids. As stated in MRP-227, EVT-1 is the appropriate non-destructive examination (NDE) method for detecting cracks in plates and their welded joints.
Part of the rationale provided by the industry, and accepted within the SE, is that those components that have been recommended for VT-3 and are susceptible to cracking have
significant margin prior to failure. Therefore, the cracking will be extensive and the associated component deformation will be large enough such that a VT-3 examination will identify this degradation before component integrity has been. comprised. However, the industry did not provide an evaluation of any of the components recommended for VT-3 examination to substantiate this claim. Further, operating experience has shown that extensive cracking in welds, heat-affected zones, and other susceptible locations can occur with little component deformation as the crack grows, especially ifthe component is subjected to a combination of relatively high residual stress fields and relatively low operating stresses. These conditions are anticipated for many of the RVI components that are susceptible to SCC and fatigue. Some of the RVI components may, over time, experience partial or total relief of high residual stresses due to the effects of radiation. While radiation lowers the applied stresses that can lead to cracking, it also decreases the material's inherent resistance to cracking such that IASCC may still occur. Like SCC and fatigue cracking, IASCC typically exhibits tight cracks with little gross component deformation at the relatively low applied stress levels expected within RVI components under normal operating conditions.
As described previously, my opinion is that the characteristics of the cracking which may occur due to fatigue, SCC, and IASCC mechanisms in RVI components are not amenable to discovery using the VT-3 method in a timely manner. The RVI components subjected to such mechanisms should be examined using EVT-1 or UT examination methods. Alternatively, other non-visual surface inspection methods such as eddy current testing are potentially acceptable for identifying cracking in RVI components, but no other such methods have been recommended within MRP-227. Therefore, my recommendation, which was not adopted in the SE, is that either the EV-T-1 or UT examination methods should be required for inspecting all RVI components that are susceptible to cracking as identified in MRP-227. I propose that this condition be imposed on those applicants/licensees that utilize MPR-227 as the basis for their aging management program for RVI components during the period of extended operations.
Comments for the Document Sponsor to Consider Pertaining to Non-Concurrence on "Draft Safety Evaluation for the Electric Power Research Institute's Topical Report (TR)
Materials Reliability Program (MRP) Report 1016596 (MRP-227), Revision 0, 'Pressurized Water Reactor (PWR) Internals Inspection and Evaluation Guidelines."'
Michael J. Case RESIDE I agree with Mr. Tregoning on the inadequacy of VT-3 inspection method for reactor internal inspections identified in MRP-227 for the following reasons:
- In the context of the regulatory application of this topical report (license renewal), it is the industry's (or licensee's) burden to present sufficient information as to why the particular inspection technique is effective in managing aging in the period of extended operation.
Given the lack of PWR internal inspections results, it is uncertain whether the VT-3 technique is effective as part of an aging management program to identify cracking in RVI components.
" Given this uncertainty and given the breadth of this program (all PWRs) and its potential application in the extended term and subsequent renewal periods (i.e. over the next 40 years), I believe it is premature to use a more relaxed inspection method until sufficient data on this issue is developed.
- The NRC can always relax its inspection requirements when new data is presented.
Conversely, by initially adopting a relaxed inspection method, the staff would have to demonstrate that a significant safety issue is involved in order to increase the requirements should experience demonstrate problems with the VT-3 technique.
If the relaxed inspection method is adopted, the NRC has no regulatory means to collect the results of these inspections to assess their effectiveness as an aging management program.
In conclusion, given the uncertainty of the effectiveness of the VT-3 technique, I agree with Mr.
Tregoning that the EVT-1 or UT technique should be adopted to identify cracking in RVI components until such time that the industry provides sufficient operational experience to substantiate the VT-3 technique as an effective aging management technique for identifying cracking in reactor vessel internal components.