NL-17-130, Relief Request IP3-ISl-RR-13 - Inservice Inspection Interval Extension

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Relief Request IP3-ISl-RR-13 - Inservice Inspection Interval Extension
ML17297A455
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 10/18/2017
From: Vitale A
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-130
Download: ML17297A455 (6)
v • d • e


Text

NL-17-130 October 18, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike, OWFN-2 F1 Rockville, MD 20852-2738 Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, N.Y. 10511-0249 Tel (914) 254-6700 Anthony J Vitale Site Vice President

SUBJECT:

Relief Request IP3-ISl-RR lnservice Inspection Interval Extension Indian Point Unit 3

REFERENCE:

Docket No. 50-286 License No. DPR-64 Entergy letter NL-17-021 to NRC, "Notification of Permanent Cessation of Power Operations," dated February 8, 2017(ML17044A004)

Dear Sir or Madam:

Pursuant to 10 CFR 50.55a(z)(1 ), Entergy Nuclear Operations, Inc. (Entergy) requests Nuclear Regulatory Commission (NRC) approval of the attached Relief Request IP3-ISl-RR-13 for Indian Point Unit 3 (IP3). The Code of Record for the current fourth 10-year interval is the American Society of Mechanical Engineers (ASME)Section XI Boiler and Pressure Vessel (B&PV) Code, 2001 Edition with Addenda through 2003.

Specifically, Entergy proposes to extend the current 10 year lnservice Inspection (ISi) interval 12 months beyond the one year extension already allowed by the ASME Section XI, paragraphs IWA-2430(d)(1) and (d)(3). This interval extension is in deference to the recent decision to permanently cease power operations of IP3 by April 30, 2021 (Reference).

Entergy proposes to apply this additional 12 month extension to the third inspection period of the fourth 10 year interval, which will extend the end of the third inspection period from July 20, 2020 to July 20, 2021. Entergy requests approval of this proposed alternative by October 1, 2018 to support the IP3 Spring 2019 refueling outage (RF0-20) schedule.

NL-17-130 Docket No. 50-286 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, AJV/cdm

Attachment:

Indian Point Unit 3 Relief Request No. IP3-ISl-RR lnservice Inspection Interval Extension cc:

Mr. Richard Guzman, Senior Project Manager, NRG NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRG Region 1 NRG Resident Inspectors Office Ms. Alicia Barton, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

NL-17-130 ATTACHMENT INDIAN POINT UNIT 3 RELIEF REQUEST NO. IP3-ISl-RR-13 INSERVICE INSPECTION INTERVAL EXTENSION ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT N.UCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

1

Indian Point Unit 3 Fourth 10-year ISi Interval Relief Request No. IP3-ISl-RR-13 lnservice Inspection Interval Extension Proposed Alternative NL-1.7-130 Docket No. 50-286 Attachment Page 1 of 3 In Accordance with 10 CFR 50.55a(z)(1)

Alternative Provides Acceptable Level of Quality and Safety

1. ASME Code Component(s) Affected The affected components are the Indian Point Unit 3 (IP3) Fourth Ten-Year lntervai lnservice Inspection (ISl)/Containment lnservice Inspection (Cll) components contained in the ISi and Cll Program Plan (Reference 1 ). Specifically, the American Society of Mechanical Engineers (ASME)

Boiler and Pressure Vessel (BPV) Code,Section XI, (Reference 2) Examination Categories and Items affected are the Class 1, 2, and 3 pressure retaining components and their supports in accordance with ASME Section XI, subsections IWA, IWB, IWC, IWD, IWE, IWF, IWL, and the Risk Informed ISi Program (RI-ISi Program) Examination Category R-A.

2. Applicable Code Edition and Addenda

The code of record for the IP3 ISi fourth interval is the ASME Section XI Code, 2001 Edition through 2003 Addenda.

3. Applicable Code Requirement

Paragraph IWA-2430(d) of ASME BPV Code,Section XI, requires compliance with ten (10) year intervals for components inspected under Program B, and paragraphs IWA-2430(d)(1) and (d)(3) allow an extension of the interval by as much as one (1) year. The IP3 fourth inspection interval is defined by Inspection Program B (IWA-2432).

4. Reason for Request

The current IP3 Fourth Ten-Year Interval ISl/Cll Program Plan became effective on July 21, 2009 and is scheduled to expire on July 20, 2020 (see Table 1 below). The IP3 ISl/Cll Program Plan established the fourth 10 year interval in accordance with the Code of Federal Regulations (CFR),

Title 10, Part 50, Section 55a, Codes and standards (10 CFR 50.55a), and is compliant with ASME Section XI, Division 1, Rules for Inspection and Testing of Components of Light Water Cooled Plants. The inspection schedule for the IP3 fourth 10 year interval is divided into three periods ranging in length from 3 to 4 years. Approximately one third of the 10 year interval's inspections are normally scheduled to be completed during each period, except for items that may be deferred until the end of the interval. As described in Table 1 below, the RFO 20 refueling outage is scheduled to commence in the Spring' of 2019, and is the last refueling outage currently scheduled to be completed during the fourth 10 year interval.

Table 1 NL-17-130 Docket No. 50-286 Attachment Page 2 of 3 IP3 Fourth Interval Inspection Periods Summary Dates Inspection Period Start Period End Years of Plant Plant Refueling Outages Operation Period Date Date Within Period within Period 1

July 21, 2009 July 20, 2013 4 years RF0-16 (Spring 2011)

RF0-17 (Sprino 2013) 2 July21,2013 July 20, 2016 3 years RF0-18 (Spring 2015) 3 July 21, 2016 July 20, 2020*

4 years RF0-19 (Spring 2017)

RF0-20 (Spring 2019)

  • 1P3's Fourth Ten-Year Interval ISl/Cll Program Plan was originally effective from July 21, 2009, through and including July 20, 2019.

ASME BPV Code,Section XI, (2001 Edition, 2003 Addenda) paragraphs IWA-2430(d)(1) and (d)(3) allow the interval to be extended as much as one year. Accordingly, the fourth interval has been extended 365 days, and the IP3 Fourth Ten-Year Interval ISl/Cll Program Plan was rescheduled from July 21, 2009 to July 20, 2020.

As a result of the recent decision to permanently cease operation of IP3 by April 30, 2021 (Reference 3), Entergy hereby requests approval to extend the expiration date for the end of the IP3 Fourth Ten-Year Interval ISl/Cll Program Plan from July 20, 2020 to July 20, 2021. This 12 month interval extension will allow Entergy to more effectively schedule and perform the inspections to be completed during RFO 20. This proposed extension of the fourth interval extension will also serve to extend the beginning of the fifth interval by the same 12 month duration, thereby eliminating the need to transition to the requirements of a new ASME Code Edition just prior to permanent plant shutdown.

5. Proposed Alternative and Basis for Use

Entergy proposes to extend the current fourth 10 year ISi interval by 12 months (in addition to the one year extension allowed by the ASME Section XI Code) to accommodate the recent decision to cease operation of IP3 by April 30, 2021. Table 2 below provides a list of the refueling outages scheduled during the proposed fourth 10 year ISi interval. This 12 month extension will allow one additional refueling outage (RFO 21) to complete the remainder of the inspections scheduled for the fourth 10 year interval. These inspections would only be completed if the current plan to permanently cease operation of IP3 is changed in the future. It should be noted that inspections such as the thermal fatigue inspections identified as a result of industry operating experience, as well as any follow up inspections from previously identified non-conforming conditions, will still be completed as required by Materials Reliability Program (MRP)-146, Revision 1, and the ASME Section XI Code.

Entergy has determined that the alternative proposed in this relief request provides an acceptable level of quality and safety. The inspections and non-destructive examinations of the applicable IP3 systems, structures, and components (SSCs) have been performed to the extent practical and possible as permitted by existing designs, equipment arrangements, available access, and radiological conditions for the fourth ten year interval from 2009 to 2017. The inspections and examinations completed to date provide assurance that the ISi Program and applicable SSCs have been maintained in accordance with the ASME Section XI Code requirements.

NL-17-130 Docket No. 50-286 Attachment Page 3 of 3 The ASME Section XI Code requires that 100 percent of the scheduled inspections be completed during the 10 year ISi interval and that pre-determined percentages be completed during each of the three inspection periods within the interval. The percentage of examinations (Visual, Surface and Volumetric) required for IP3 by ASME Section XI, Table IWB-2412-1, were completed during the first two periods of the current fourth 10 year interval and first refueling outage of the third period. The proposed extension of the current 1 O year inspection interval will not result in a decrease in safety because the inspections completed to date have not identified any active degradation mechanisms which could impact the SSCs affected by this relief request. Not having to perform the remainder of the fourth interval inspections by deferring the inspections from RFO 20 to RFO 21 would result in additional flexibility and optimization of the required resources, and a reduction in the personnel radiation exposure associated with performing these inspections. The expected personnel radiation dose avoidance by not performing these inspections is 1.0 person-Roentgen equivalent man (Rem).

Table 2 IP3 Proposed Fourth Interval Inspection Periods Summary*Dates Inspection Period Start Period End Years of Plant Plant Refueling Outages Operation Period Date Date Within Period within P~riod 1

July 21, 2009 July 20, 2013 4 years RF0-16 (Spring 2011)

RF0-17 (Spring 2013) 2 July 21, 2013 July 20, 2016 3 years RF0-18 (Spring 2015)

RF0-19 (Spring 2017) 3 July 21, 2016 July 20, 2021 5 years RF0-20 (Spring 2019)

RF0-21 (Spring 2021)

6. Duration of Proposed Alternative

This relief request is applicable to Entergy's ISl/Cll Program for the fourth 10 year interval for IP3.

The duration of the proposed alternative is to July 20, 2021.

7. References
1. Entergy letter NL-09-097 to NRC, "Fourth Ten-Year Interval lnservice Inspection and Containment lnservice Inspection Program Plan, Indian Point Unit Number 3," dated July 21, 2009 (ML092080147)
2. ASME Boiler and Pressure Vessel Code,Section XI, 2001 Edition through 2003 Addenda, American Society of Mechanical Engineers, New York
3. Entergy letter NL-17-021 to NRC, "Notification of Permanent Cessation of Power Operations," dated February 8, 2017(ML17044A004)
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