JAFP-13-0126, Core Plate Rim Hold Down Bolting, Plant Specific Analysis and Inspection Plan Revision, License Renewal Commitment 23
| ML13273A358 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 09/27/2013 |
| From: | Chris Adner Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-13-0126 TAC ME9698 | |
| Download: ML13273A358 (4) | |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 JAFP-13-0126 September 27, 2013 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Subject:
Core Plate Rim Hold Down Bolting, Plant Specific Analysis and Inspection Plan -
Revision, License Renewal Commitment #23 (TAC No. ME9698)
James A. FitzPatrick Nuclear Power Plant Docket No.
50-333 License No.
References:
- 1. Letter, Entergy to USNRC, James A. FitzPatrick Nuclear Power Plant, License Renewal Application, JAFP-06-0109, dated July 31, 2006
- 2. Letter, Entergy to USNRC, James A. FitzPatrick Nuclear Power Plant, License Renewal Application, Amendment 5, JAFP-07-0019, dated February 1, 2007
- 3. Letter, USNRC to Entergy, Safety Evaluation Report Related to the License Renewal of James A. FitzPatrick Nuclear Power Plant, NUREG-1905, dated April, 2008
- 4. Letter, Entergy to USNRC, Core Plate Rim Hold Down Bolting, Plant Specific Analysis and Inspection Plan, License Renewal Commitment #23, JAFP 0122, dated September 28, 2012
Dear Sir or Madam:
On July 31, 2006, Entergy Nuclear Operations, Inc. (ENO) submitted the License Renewal Application (LRA) for the James A. FitzPatrick Nuclear Power Plant (JAFNPP) [Reference 1].
On February 1, 2007, ENO submitted Amendment 5 to the LRA in response to subsequent requests for additional information (RAI) and the results of the Aging Management Program (AMP) and Aging Management Review audits [Reference 2].
Specifically, Entergy Commitment #23 of Attachment 1 in Reference 3 states the following:
Enhance the BWR Vessel Internals Program to perform inspections of the core plate rim hold down bolts.
Appendix A.2.2.7 Core Plate is revised to add that JAFNPP will perform one of the following:
- 1. Install core plate wedges prior to the period of extended operation, or,
- 2. Complete a plant-specific analysis to determine acceptance criteria for continued inspection of core plate rim hold down bolting in accordance with BWRVIP-25 and submit the inspection plan, along with acceptance criteria and justification for the Chris M. Adner Licensing Manager - JAF
JAFP-13-0126 Page 2 of 2 inspection plan, to the NRG two years prior to the period of extended operation for NRG review and approval.
If Option 2 is selected, the analysis to determine acceptance criteria will address the information requested in RA ls 3. 1.2-2A and 4. 7. 3.2-1.
How We Addressed the Commitment JAF submitted a letter [Reference 4] on September 28, 2012, in response to this commitment.
JAF chose to complete a plant specific analysis to satisfy Option 2 of the commitment. JAF-RPT-12-00009 Rev. 0, "Proposed Core Plate Bolt Inspection Protocol and Technical Bases,"
summarizes the evaluations performed to show the susceptibility of the JAF core plate bolts to known degradation mechanisms, the relaxation of bolt preload over 60 years of operation, the flaw tolerance of the bolts, and the number of bolts required to prevent horizontal displacement of the core plate assembly assuming both no credit and credit for the aligner pin and bracket assemblies. Section 3 of the report, Inspection Protocol, concludes that no further inspections of the JAF core plate bolts are required during the period of extended operation.
JAF-RPT-12-00009 Rev. O was included as Attachment 1 to Reference 4 and it provided justification for performing no further core plate bolt inspections during the period of extended operation. However, the next section explains JAF's revised plan.
Revised Plan for What We Are Doing Currently Based on conversations with the NRC Project Team, this letter is being submitted to replace the Plan submitted under Reference 4 and revise Commitment 23 of Attachment 1 in Reference 3.
JAF will inspect 50% of the bolts every other outage by VT-3 from the top starting with R022 in October, 2016. This is an acceptable plan because the protocol is in line with commitments other plants in the industry have made while seeking relief from the current BWRVIP-25 inspection guidelines. This plan will remain in place until BWRVIP guidance on inspecting core plate bolting is revised.
The Attachment contains a list of commitments. Questions concerning this submittal may be addressed to Mr. Mark Dooley, Engineering Programs & Components Manager, at 315-349-6529.
Chris M. Adner Licensing Manager - JAF CA/mh
Attachment:
Commitment Table cc:
Regional Administrator, Region I JAF Resident Inspector Mr. Mohan Thadani, Senior Project Manager New York State Department of Public SeNice (PSC)
New York State Energy and Research Development Authority (NYSERDA)
JAFP-13-0126 Attachment Commitment Table (1 Page)
JAFP-13-0126 Attachment Commitment Table Page 1 or 1 This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.
Commitment Type Scheduled Completion date One-Time Action Continuing Compliance JAF will inspect 50% of the core plate hold down bolts every other refueling outage, commencing with RFO 22, using the VT-3 method in accordance with the JAF Reactor Vessel Internals Inspection Program until BWRVIP-25 is revised.
JAF will implement the revised BWRVIP-25 inspection guidance for the core plate bolts.
X Following revision of BWRVIP-25 guidance in accordance with BWRVIP-94 Rev 1 guidelines.