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==Dear Kansler:==
==Dear Kansler:==
 
By {{letter dated|date=November 10, 2004|text=letter dated November 10, 2004}}, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.
By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.
The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.
The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.
Sincerely,
Sincerely,
                                                    /RA/
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247


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==Dear Kansler:==
==Dear Kansler:==
 
By {{letter dated|date=November 10, 2004|text=letter dated November 10, 2004}}, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.
By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H, Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.
The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.
The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.
Sincerely,
Sincerely,
                                                      /RA/
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247


==Enclosure:==
==Enclosure:==
As stated cc w/encl: See next page DISTRIBUTION PUBLIC         PDI-1 R/F     OGC           ACRS           G. Matakas, R-I S. Little       P. Milano     M. Khanna     R. Laufer       S. Coffin Adams Accession No. ML043200233 OFFICE     PDI-1/PM         PDI-1/LA         EMCB/SC           OGC             PDI-1/SC NAME       PMilano         SLittle           SCoffin           HMcGurren       RLaufer DATE       11/15/04         11/15/04         11/15/04         11/16/04       11/16/04 OFFICIAL RECORD COPY
As stated cc w/encl: See next page DISTRIBUTION PUBLIC PDI-1 R/F OGC ACRS G. Matakas, R-I S. Little P. Milano M. Khanna R. Laufer S. Coffin Adams Accession No. ML043200233 OFFICE PDI-1/PM PDI-1/LA EMCB/SC OGC PDI-1/SC NAME PMilano SLittle SCoffin HMcGurren RLaufer DATE 11/15/04 11/15/04 11/15/04 11/16/04 11/16/04 OFFICIAL RECORD COPY


Indian Point Nuclear Generating Unit No. 2 cc:
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. Gary J. Taylor                         Ms. Charlene D. Faison Chief Executive Officer                   Manager, Licensing Entergy Operations, Inc.                  Entergy Nuclear Operations, Inc.
Mr. Gary J. Taylor Chief Executive Officer Entergy Operations, Inc.
1340 Echelon Parkway                       440 Hamilton Avenue Jackson, MS 39213                         White Plains, NY 10601 Mr. John T. Herron                         Mr. Michael J. Colomb Senior Vice President and                 Director of Oversight Chief Operating Officer                 Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc.          440 Hamilton Avenue 440 Hamilton Avenue                        White Plains, NY 10601 White Plains, NY 10601 Mr. James Comiotes Mr. Fred Dacimo                           Director, Nuclear Safety Assurance Site Vice President                       Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Fred Dacimo Site Vice President Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc.           Indian Point Energy Center Indian Point Energy Center                 295 Broadway, Suite 1 295 Broadway, Suite 2                      P.O. Box 249 P.O. Box 249                               Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Patric Conroy Mr. Christopher Schwarz                    Manager, Licensing General Manager, Plant Operations          Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 2 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Christopher Schwarz General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc.           Indian Point Energy Center Indian Point Energy Center                 295 Broadway, Suite 1 295 Broadway, Suite 1                     P. O. Box 249 P.O. Box 249                              Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. John M. Fulton Mr. Danny L. Pace                          Assistant General Counsel Vice President Engineering                Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Danny L. Pace Vice President Engineering Entergy Nuclear Operations, Inc.
Entergy Nuclear Operations, Inc.          440 Hamilton Avenue 440 Hamilton Avenue                        White Plains, NY 10601 White Plains, NY 10601 Regional Administrator, Region I Mr. Brian OGrady                          U.S. Nuclear Regulatory Commission Vice President, Operations Support        475 Allendale Road Entergy Nuclear Operations, Inc.          King of Prussia, PA 19406 440 Hamilton Avenue White Plains, NY 10601                    Senior Resident Inspectors Office Indian Point 2 Mr. John McCann                            U. S. Nuclear Regulatory Commission Director, Nuclear Safety Assurance        P.O. Box 59 Entergy Nuclear Operations, Inc.          Buchanan, NY 10511-0038 440 Hamilton Avenue White Plains, NY 10601
440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspectors Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511-0038


Indian Point Nuclear Generating Unit No. 2 cc:
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. Peter R. Smith, President             Mr. Dan C. Poole New York State Energy, Research, and       PWR SRC Consultant Development Authority                   20 Captains Cove Road 17 Columbia Circle                         Inglis, FL 34449 Albany, NY 12203-6399 Mr. William T. Russell Mr. Paul Eddy                             PWR SRC Consultant Electric Division                         400 Plantation Lane New York State Department                 Stevensville, MD 21666-3232 of Public Service 3 Empire State Plaza, 10th Floor           Mr. Alex Matthiessen Albany, NY 12223                           Executive Director Riverkeeper, Inc.
Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy Electric Division New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
Mr. Charles Donaldson, Esquire             25 Wing & Wing Assistant Attorney General                 Garrison, NY 10524 New York Department of Law 120 Broadway                               Mr. Paul Leventhal New York, NY 10271                         The Nuclear Control Institute 1000 Connecticut Avenue NW Mayor, Village of Buchanan                 Suite 410 236 Tate Avenue                           Washington, DC, 20036 Buchanan, NY 10511 Mr. Karl Coplan Mr. Ray Albanese                           Pace Environmental Litigation Clinic Executive Chair                           78 No. Broadway Four County Nuclear Safety Committee       White Plains, NY 10603 Westchester County Fire Training Center 4 Dana Road                               Mr. Jim Riccio Valhalla, NY 10592                         Greenpeace 702 H Street, NW Ms. Stacey Lousteau                       Suite 300 Treasury Department                       Washington, DC 20001 Entergy Services, Inc.
639 Loyola Avenue Mail Stop: L-ENT-15E New Orleans, LA 70113 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Dan C. Poole PWR SRC Consultant 20 Captains Cove Road Inglis, FL 34449 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Alex Matthiessen Executive Director Riverkeeper, Inc.
639 Loyola Avenue                         Mr. Robert D. Snook Mail Stop: L-ENT-15E                       Assistant Attorney General New Orleans, LA 70113                     State of Connecticut 55 Elm Street Mr. William DiProfio                      P.O. Box 120 PWR SRC Consultant                        Hartford, CT 06141-0120 139 Depot Road East Kingston, NH 03827
25 Wing & Wing Garrison, NY 10524 Mr. Paul Leventhal The Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036 Mr. Karl Coplan Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Robert D. Snook Assistant Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120


Indian Point Nuclear Generating Unit No. 2 cc:
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. David Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006
Mr. David Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006


SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REACTOR VESSEL MATERIALS SURVEILLANCE PROGRAM ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247
Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REACTOR VESSEL MATERIALS SURVEILLANCE PROGRAM ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247


==1.0     INTRODUCTION==
==1.0 INTRODUCTION==
By {{letter dated|date=November 10, 2004|text=letter dated November 10, 2004}}, Entergy Nuclear Operations, Inc. (Entergy, the licensee),
requested approval of a revision to the reactor vessel surveillance specimen withdrawal schedule for Indian Point Nuclear Generating Unit No. 2 (IP2). The request was made due to the inability to withdraw capsule S from its location in the vessel.


By letter dated November 10, 2004, Entergy Nuclear Operations, Inc. (Entergy, the licensee),
==2.0 REGULATORY EVALUATION==
requested approval of a revision to the reactor vessel surveillance specimen withdrawal schedule for Indian Point Nuclear Generating Unit No. 2 (IP2). The request was made due to the inability to withdraw capsule S from its location in the vessel.
2.1 Section 50.60 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.60) and Appendix H to 10 CFR Part 50 The Nuclear Regulatory Commission (NRC) has established requirements and criteria in 10 CFR 50.60 for protecting the reactor vessels of U.S. light-water reactors (LWRs) against fracture. The rule requires U.S. light-water nuclear power reactors to meet the reactor vessel (RV) materials surveillance program requirements set forth in Appendix H to 10 CFR Part 50.
 
==2.0     REGULATORY EVALUATION==
 
2.1     Section 50.60 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.60) and Appendix H to 10 CFR Part 50 The Nuclear Regulatory Commission (NRC) has established requirements and criteria in 10 CFR 50.60 for protecting the reactor vessels of U.S. light-water reactors (LWRs) against fracture. The rule requires U.S. light-water nuclear power reactors to meet the reactor vessel (RV) materials surveillance program requirements set forth in Appendix H to 10 CFR Part 50.
Appendix H to 10 CFR Part 50 provides the NRC staffs criteria for the design and implementation of RV material surveillance programs for operating LWRs. The rule, in part, requires RV surveillance program designs and withdrawal schedules to meet the requirements of the edition of American Society for Testing and Materials (ASTM) Standard Practice E185 that is current on the issue date of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) to which the RV was purchased, although later editions of ASTM E185 may be used inclusive of the 1982 Edition of ASTM E185 (ASTM E185-82). The rule also requires proposed RV surveillance programs to be submitted to the NRC and approved prior to implementation. The applicable criteria in ASTM E185-82 are discussed in the Section 3.1 of this safety evaluation (SE).
Appendix H to 10 CFR Part 50 provides the NRC staffs criteria for the design and implementation of RV material surveillance programs for operating LWRs. The rule, in part, requires RV surveillance program designs and withdrawal schedules to meet the requirements of the edition of American Society for Testing and Materials (ASTM) Standard Practice E185 that is current on the issue date of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) to which the RV was purchased, although later editions of ASTM E185 may be used inclusive of the 1982 Edition of ASTM E185 (ASTM E185-82). The rule also requires proposed RV surveillance programs to be submitted to the NRC and approved prior to implementation. The applicable criteria in ASTM E185-82 are discussed in the Section 3.1 of this safety evaluation (SE).
2.2     NRC Administrative Letter (AL) 97-004 and NRC Memorandum and Order CLI-96-13 On September 30, 1997, the NRC issued AL 97-004 to all holders of operating licenses for domestic nuclear power plants (with the exception of those who have ceased operations of their facilities or have certified that fuel has been permanently removed from the reactor). In this AL, the NRC staff summarized the Commissions decision promulgated in Commission Memorandum and Order CLI-96-13, which was issued In the Matter of the Cleveland Electric Enclosure
2.2 NRC Administrative Letter (AL) 97-004 and NRC Memorandum and Order CLI-96-13 On September 30, 1997, the NRC issued AL 97-004 to all holders of operating licenses for domestic nuclear power plants (with the exception of those who have ceased operations of their facilities or have certified that fuel has been permanently removed from the reactor). In this AL, the NRC staff summarized the Commissions decision promulgated in Commission Memorandum and Order CLI-96-13, which was issued In the Matter of the Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Unit 1) on December 6, 1996. In this Memorandum and Order, the Commission found that, while 10 CFR Part 50, Appendix H, II.B.3 requires prior NRC approval for all withdrawal schedule changes, only certain changes require the NRC staff to review and approve the changes through the NRCs license amendment process (10 CFR 50.90 process). Specifically, only those changes that are not in conformance with the ASTM standard referenced in 10 CFR Part 50, Appendix H (ASTM E-185, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels) are required to be approved through the license amendment process, whereas changes that are determined to conform to the ASTM standard only require that the staff document its review and verification of such conformance.


Illuminating Company (Perry Nuclear Power Plant, Unit 1) on December 6, 1996. In this Memorandum and Order, the Commission found that, while 10 CFR Part 50, Appendix H, II.B.3 requires prior NRC approval for all withdrawal schedule changes, only certain changes require the NRC staff to review and approve the changes through the NRCs license amendment process (10 CFR 50.90 process). Specifically, only those changes that are not in conformance with the ASTM standard referenced in 10 CFR Part 50, Appendix H (ASTM E-185, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels) are required to be approved through the license amendment process, whereas changes that are determined to conform to the ASTM standard only require that the staff document its review and verification of such conformance.
==3.0 TECHNICAL EVALUATION==
 
3.1 Evaluation Criteria of ASTM Standard Practice E185-82 For IP2, Entergy is applying the requirements of ASTM Standard Practice E185-82, as its basis for meeting the RV surveillance capsule withdrawal requirements of 10 CFR Part 50, Appendix H. Table 1 of ASTM E185-82 requires that either a minimum of three, four, or five surveillance capsules be removed from the vessels, based on the limiting amount of RTNDT shift (limiting RTNDT) that is projected to occur at the clad-vessel interface location of the RV at the end-of-licensed plant life (EOL). ASTM E185-82 establishes the following criteria for determining the minimum number of capsules that are to be removed in accordance with a withdrawal schedule and the number of capsules that are to be tested:
==3.0     TECHNICAL EVALUATION==
For plants with projected RTNDT shifts (i.e., RTNDT) less than 100 EF (56 EC), three capsules are required to be removed from the RV and the first two capsules are required to be tested (for dosimetry, tensile-ductility, Charpy-V impact toughness, and alloying chemistry).
 
For plants with projected RTNDT between 100 EF (56 EC) and 200 EF (111 EC), four surveillance capsules are to be removed from the RV and the first three capsules are required to be tested.
3.1     Evaluation Criteria of ASTM Standard Practice E185-82 For IP2, Entergy is applying the requirements of ASTM Standard Practice E185-82, as its basis for meeting the RV surveillance capsule withdrawal requirements of 10 CFR Part 50, Appendix H. Table 1 of ASTM E185-82 requires that either a minimum of three, four, or five surveillance capsules be removed from the vessels, based on the limiting amount of RTNDT shift (limiting RTNDT) that is projected to occur at the clad-vessel interface location of the RV at the end-of-licensed plant life (EOL). ASTM E185-82 establishes the following criteria for determining the minimum number of capsules that are to be removed in accordance with a withdrawal schedule and the number of capsules that are to be tested:
For plants with projected RTNDT above 200 EF (111 EC), five surveillance capsules are required to be removed from the RV and the first four capsules are required to be tested.
* For plants with projected RTNDT shifts (i.e., RTNDT) less than 100 EF (56 EC), three capsules are required to be removed from the RV and the first two capsules are required to be tested (for dosimetry, tensile-ductility, Charpy-V impact toughness, and alloying chemistry).
Standard Practice ASTM E185-82 permits the last scheduled surveillance capsules in three, four, or five capsule withdrawal schedules to be removed without the implementation of testing. However, licensees who opt to pull their final required capsules without the implementation of testing are required by the Standard Practice to hold the capsules in storage.
* For plants with projected RTNDT between 100 EF (56 EC) and 200 EF (111 EC), four surveillance capsules are to be removed from the RV and the first three capsules are required to be tested.
Table 1 of ASTM Standard Practice E185-82 also provides specific criteria for removal of surveillance capsules. The removal times are based on criteria that the surveillance capsules be removed after a certain amount of power operation has elapsed or at various times when the RV shell is projected to achieve certain levels of neutron fluence. The intent of the Standard Practice is to achieve a set of testing data over a range of neutron fluences for the RV that bounds the current life of the plant. Of key importance are the removal criteria for the second to last and final capsules required for capsule withdrawal. For the second-to-last required capsule in a withdrawal schedule, the ASTM standard requires that the capsules be pulled at either 13 effective full-power years (EFPYs) or at the time when the capsule is equivalent to the limiting fluence projected for the clad-based metal interface of the RV at EOL, whichever time comes first. For the final capsule that is required for removal, ASTM E185-82 requires that the capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value.
* For plants with projected RTNDT above 200 EF (111 EC), five surveillance capsules are required to be removed from the RV and the first four capsules are required to be tested.
* Standard Practice ASTM E185-82 permits the last scheduled surveillance capsules in three, four, or five capsule withdrawal schedules to be removed without the implementation of testing. However, licensees who opt to pull their final required capsules without the implementation of testing are required by the Standard Practice to hold the capsules in storage.
Table 1 of ASTM Standard Practice E185-82 also provides specific criteria for removal of surveillance capsules. The removal times are based on criteria that the surveillance capsules be removed after a certain amount of power operation has elapsed or at various times when the RV shell is projected to achieve certain levels of neutron fluence. The intent of the Standard Practice is to achieve a set of testing data over a range of neutron fluences for the RV that bounds the current life of the plant. Of key importance are the removal criteria for the second
 
to last and final capsules required for capsule withdrawal. For the second-to-last required capsule in a withdrawal schedule, the ASTM standard requires that the capsules be pulled at either 13 effective full-power years (EFPYs) or at the time when the capsule is equivalent to the limiting fluence projected for the clad-based metal interface of the RV at EOL, whichever time comes first. For the final capsule that is required for removal, ASTM E185-82 requires that the capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value.
With respect to the current operating term, the IP2 RV has a limiting RTNDT value greater than 200 EF. As stated above, since the RTNDT value is greater than 200 EF, ASTM E185-82 requires that the licensee, at a minimum, remove five capsules from the reactor during the current operating period and test the first four capsules. The licensee has already removed four capsules and an additional two capsules will be removed, as specified by its proposed new withdrawal schedule. Since ASTM E185-82 only requires that one additional capsule be removed, this proposed schedule meets the requirements of the 1982 Edition of ASTM E185 for the reactor vessel surveillance program for IP2, and is acceptable to the staff.
With respect to the current operating term, the IP2 RV has a limiting RTNDT value greater than 200 EF. As stated above, since the RTNDT value is greater than 200 EF, ASTM E185-82 requires that the licensee, at a minimum, remove five capsules from the reactor during the current operating period and test the first four capsules. The licensee has already removed four capsules and an additional two capsules will be removed, as specified by its proposed new withdrawal schedule. Since ASTM E185-82 only requires that one additional capsule be removed, this proposed schedule meets the requirements of the 1982 Edition of ASTM E185 for the reactor vessel surveillance program for IP2, and is acceptable to the staff.
3.2     Changes Proposed to the Withdrawal Schedule for IP2 The licensees November 10, 2004, letter provides the updated RV surveillance capsule withdrawal schedule for IP2. The letter indicated that Capsules T, Y, Z, and V were removed from IP2 at 1.42 EFPY, 2.34 EFPY, 5.17 EFPY, and 8.6 EFPY, respectively, and that the neutron fluences reported for capsules T, Y, Z, and V at the time of withdrawal are 2.53x1018 n/cm2, 4.55x1018 n/cm2, 1.02x1019 n/cm2, and 4.92x1018 n/cm2, respectively, as reported in Westinghouse letter IPP-01-079, dated April 26, 2001. Note that the fluences did not necessarily increase with increasing EFPY because the lead factors varied from capsule to capsule. The letter also reported updated lead factors for the surveillance capsules in the IP2 surveillance program.
3.2 Changes Proposed to the Withdrawal Schedule for IP2 The licensees {{letter dated|date=November 10, 2004|text=November 10, 2004, letter}} provides the updated RV surveillance capsule withdrawal schedule for IP2. The letter indicated that Capsules T, Y, Z, and V were removed from IP2 at 1.42 EFPY, 2.34 EFPY, 5.17 EFPY, and 8.6 EFPY, respectively, and that the neutron fluences reported for capsules T, Y, Z, and V at the time of withdrawal are 2.53x1018 n/cm2, 4.55x1018 n/cm2, 1.02x1019 n/cm2, and 4.92x1018 n/cm2, respectively, as reported in Westinghouse letter IPP-01-079, dated April 26, 2001. Note that the fluences did not necessarily increase with increasing EFPY because the lead factors varied from capsule to capsule. The letter also reported updated lead factors for the surveillance capsules in the IP2 surveillance program.
The licensee indicated in its November 10, 2004, letter that in addition to the four capsules that have already been withdrawn and tested, that two additional capsules (Capsules U and W) will be removed from the IP2 RV in the future. The licensee also indicated that it has a spare capsule (Capsule X). The licensee noted that the withdrawal schedule for the three capsules, Capsules U, W, and X, are interchangeable, due to the common lead factor and the common materials in the capsules. In addition, the licensee indicated that the withdrawal schedule for Capsule W may be adjusted if the current IP2 license is extended beyond the current 40 years.
The licensee indicated in its {{letter dated|date=November 10, 2004|text=November 10, 2004, letter}} that in addition to the four capsules that have already been withdrawn and tested, that two additional capsules (Capsules U and W) will be removed from the IP2 RV in the future. The licensee also indicated that it has a spare capsule (Capsule X). The licensee noted that the withdrawal schedule for the three capsules, Capsules U, W, and X, are interchangeable, due to the common lead factor and the common materials in the capsules. In addition, the licensee indicated that the withdrawal schedule for Capsule W may be adjusted if the current IP2 license is extended beyond the current 40 years.
The limiting neutron fluence projected for the IP2 RV is approximately 1.5x1019 n/cm2 at EOL (32 EFPY). Capsules T, Y, Z, and V have been withdrawn and tested. The current withdrawal schedule was established based on the 1979 Edition of ASTM E185. The NRC staff verified that the four capsules that have been withdrawn to date, do comply with the withdrawal schedule of ASTM E185-79. The licensees proposed change to the surveillance capsule withdrawal schedule is based on the requirements of the 1982 Edition of ASTM E185, to the extent practicable, as required by Appendix H to 10 CFR Part 50.
The limiting neutron fluence projected for the IP2 RV is approximately 1.5x1019 n/cm2 at EOL (32 EFPY). Capsules T, Y, Z, and V have been withdrawn and tested. The current withdrawal schedule was established based on the 1979 Edition of ASTM E185. The NRC staff verified that the four capsules that have been withdrawn to date, do comply with the withdrawal schedule of ASTM E185-79. The licensees proposed change to the surveillance capsule withdrawal schedule is based on the requirements of the 1982 Edition of ASTM E185, to the extent practicable, as required by Appendix H to 10 CFR Part 50.
The licensee indicated that the projected neutron fluence for Capsule U at the time of removal will be 1.3x1019 n/cm2 and that the lead factor for the capsule is 1.2. The licensee also indicated that Capsule W will be removed from the reactor vessel at approximately 32 EFPY.
The licensee indicated that the projected neutron fluence for Capsule U at the time of removal will be 1.3x1019 n/cm2 and that the lead factor for the capsule is 1.2. The licensee also indicated that Capsule W will be removed from the reactor vessel at approximately 32 EFPY.
The licensee projected that the neutron fluence for Capsule W at the time of removal will be
The licensee projected that the neutron fluence for Capsule W at the time of removal will be 1.5x1019 n/cm2 and that the lead factor for the capsule is 1.2. In addition, the licensee indicated that it has a spare capsule, Capsule X, included in its reactor vessel surveillance capsule withdrawal program.
 
As stated above, ASTM E185-82 requires that the fifth capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value. This criteria will be met by Capsule W for the current operating term for IP2, therefore, the NRC staff finds that the licensee adequately meets ASTM E185-82 for its remaining capsule in its program.  
1.5x1019 n/cm2 and that the lead factor for the capsule is 1.2. In addition, the licensee indicated that it has a spare capsule, Capsule X, included in its reactor vessel surveillance capsule withdrawal program.
As stated above, ASTM E185-82 requires that the fifth capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value. This criteria will be met by Capsule W for the current operating term for IP2, therefore, the NRC staff finds that the licensee adequately meets ASTM E185-82 for its remaining capsule in its program.
 
==4.0      CONCLUSION==


The NRC staff has reviewed Entergys proposed withdrawal schedules for IP2, and has determined that the changes to the schedule will continue to meet the RV surveillance capsule withdrawal schedule criteria in ASTM E185-82, and is in compliance with 10 CFR Part 50, Appendix H, for the current operating period for IP2. The staff, therefore, concludes that the RV withdrawal schedule, as proposed in the licensees November 10, 2004, letter is acceptable for implementation.
==4.0 CONCLUSION==
The NRC staff has reviewed Entergys proposed withdrawal schedules for IP2, and has determined that the changes to the schedule will continue to meet the RV surveillance capsule withdrawal schedule criteria in ASTM E185-82, and is in compliance with 10 CFR Part 50, Appendix H, for the current operating period for IP2. The staff, therefore, concludes that the RV withdrawal schedule, as proposed in the licensees {{letter dated|date=November 10, 2004|text=November 10, 2004, letter}} is acceptable for implementation.
This SE does not provide acceptance of the proposed withdrawal schedule for a possible period of extended operation for IP2. The staff will evaluate the applicability of the withdrawal schedule for an extended period of operation should the licensee submit a license renewal application for IP2.
This SE does not provide acceptance of the proposed withdrawal schedule for a possible period of extended operation for IP2. The staff will evaluate the applicability of the withdrawal schedule for an extended period of operation should the licensee submit a license renewal application for IP2.
Principal Contributor: M. Khanna Date: November 16, 2004}}
Principal Contributor: M. Khanna Date: November 16, 2004}}

Latest revision as of 23:42, 15 January 2025

Reactor Vessel Surveillance Capsule Withdrawal Schedule Change
ML043200233
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 11/16/2004
From: Richard Laufer
NRC/NRR/ADRO/DORL/LPLI-1
To: Kansler M
Entergy Nuclear Operations
Milano P, NRR/DLPM , 415-1457
References
TAC MC5069
Download: ML043200233 (9)


Text

November 16, 2004 Mr. Michael R. Kansler, President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 RE: REACTOR VESSEL SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE CHANGE (TAC NO. MC5069)

Dear Kansler:

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H,Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.

The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

As stated cc w/encl: See next page

November 16, 2004 Mr. Michael R. Kansler, President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 RE: REACTOR VESSEL SURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE CHANGE (TAC NO. MC5069)

Dear Kansler:

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requested approval of the proposed changes to the reactor vessel surveillance capsule withdrawal schedule for the Indian Point Nuclear Generating Unit No. 2. The proposed changes were submitted pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix H,Section III.B.3, which requires that: (1) withdrawal schedules be submitted, as specified in 10 CFR 50.4, and (2) the proposed schedule must be approved by the Nuclear Regulatory Commission (NRC) prior to implementation.

The NRC staff has reviewed the changes proposed by the licensee and finds that the changes to the reactor pressure vessel surveillance capsule withdrawal schedule are consistent with the recommendations specified in American Society for Testing and Materials Standard Practice E185-82, as referenced by the requirements of 10 CFR Part 50, Appendix H. Therefore, the proposed changes are acceptable and are approved. The NRC staffs evaluation is enclosed.

Sincerely,

/RA/

Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION PUBLIC PDI-1 R/F OGC ACRS G. Matakas, R-I S. Little P. Milano M. Khanna R. Laufer S. Coffin Adams Accession No. ML043200233 OFFICE PDI-1/PM PDI-1/LA EMCB/SC OGC PDI-1/SC NAME PMilano SLittle SCoffin HMcGurren RLaufer DATE 11/15/04 11/15/04 11/15/04 11/16/04 11/16/04 OFFICIAL RECORD COPY

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Gary J. Taylor Chief Executive Officer Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Fred Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 2 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Christopher Schwarz General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Danny L. Pace Vice President Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Brian OGrady Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John McCann Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspectors Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511-0038

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy Electric Division New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue Mail Stop: L-ENT-15E New Orleans, LA 70113 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Dan C. Poole PWR SRC Consultant 20 Captains Cove Road Inglis, FL 34449 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Alex Matthiessen Executive Director Riverkeeper, Inc.

25 Wing & Wing Garrison, NY 10524 Mr. Paul Leventhal The Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036 Mr. Karl Coplan Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Robert D. Snook Assistant Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. David Lochbaum Nuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006

Enclosure SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REACTOR VESSEL MATERIALS SURVEILLANCE PROGRAM ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

1.0 INTRODUCTION

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc. (Entergy, the licensee),

requested approval of a revision to the reactor vessel surveillance specimen withdrawal schedule for Indian Point Nuclear Generating Unit No. 2 (IP2). The request was made due to the inability to withdraw capsule S from its location in the vessel.

2.0 REGULATORY EVALUATION

2.1 Section 50.60 of Part 50 of Title 10 of the Code of Federal Regulations (10 CFR 50.60) and Appendix H to 10 CFR Part 50 The Nuclear Regulatory Commission (NRC) has established requirements and criteria in 10 CFR 50.60 for protecting the reactor vessels of U.S. light-water reactors (LWRs) against fracture. The rule requires U.S. light-water nuclear power reactors to meet the reactor vessel (RV) materials surveillance program requirements set forth in Appendix H to 10 CFR Part 50.

Appendix H to 10 CFR Part 50 provides the NRC staffs criteria for the design and implementation of RV material surveillance programs for operating LWRs. The rule, in part, requires RV surveillance program designs and withdrawal schedules to meet the requirements of the edition of American Society for Testing and Materials (ASTM) Standard Practice E185 that is current on the issue date of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code) to which the RV was purchased, although later editions of ASTM E185 may be used inclusive of the 1982 Edition of ASTM E185 (ASTM E185-82). The rule also requires proposed RV surveillance programs to be submitted to the NRC and approved prior to implementation. The applicable criteria in ASTM E185-82 are discussed in the Section 3.1 of this safety evaluation (SE).

2.2 NRC Administrative Letter (AL)97-004 and NRC Memorandum and Order CLI-96-13 On September 30, 1997, the NRC issued AL 97-004 to all holders of operating licenses for domestic nuclear power plants (with the exception of those who have ceased operations of their facilities or have certified that fuel has been permanently removed from the reactor). In this AL, the NRC staff summarized the Commissions decision promulgated in Commission Memorandum and Order CLI-96-13, which was issued In the Matter of the Cleveland Electric Illuminating Company (Perry Nuclear Power Plant, Unit 1) on December 6, 1996. In this Memorandum and Order, the Commission found that, while 10 CFR Part 50, Appendix H, II.B.3 requires prior NRC approval for all withdrawal schedule changes, only certain changes require the NRC staff to review and approve the changes through the NRCs license amendment process (10 CFR 50.90 process). Specifically, only those changes that are not in conformance with the ASTM standard referenced in 10 CFR Part 50, Appendix H (ASTM E-185, Standard Practice for Conducting Surveillance Tests for Light-Water Cooled Nuclear Power Reactor Vessels) are required to be approved through the license amendment process, whereas changes that are determined to conform to the ASTM standard only require that the staff document its review and verification of such conformance.

3.0 TECHNICAL EVALUATION

3.1 Evaluation Criteria of ASTM Standard Practice E185-82 For IP2, Entergy is applying the requirements of ASTM Standard Practice E185-82, as its basis for meeting the RV surveillance capsule withdrawal requirements of 10 CFR Part 50, Appendix H. Table 1 of ASTM E185-82 requires that either a minimum of three, four, or five surveillance capsules be removed from the vessels, based on the limiting amount of RTNDT shift (limiting RTNDT) that is projected to occur at the clad-vessel interface location of the RV at the end-of-licensed plant life (EOL). ASTM E185-82 establishes the following criteria for determining the minimum number of capsules that are to be removed in accordance with a withdrawal schedule and the number of capsules that are to be tested:

For plants with projected RTNDT shifts (i.e., RTNDT) less than 100 EF (56 EC), three capsules are required to be removed from the RV and the first two capsules are required to be tested (for dosimetry, tensile-ductility, Charpy-V impact toughness, and alloying chemistry).

For plants with projected RTNDT between 100 EF (56 EC) and 200 EF (111 EC), four surveillance capsules are to be removed from the RV and the first three capsules are required to be tested.

For plants with projected RTNDT above 200 EF (111 EC), five surveillance capsules are required to be removed from the RV and the first four capsules are required to be tested.

Standard Practice ASTM E185-82 permits the last scheduled surveillance capsules in three, four, or five capsule withdrawal schedules to be removed without the implementation of testing. However, licensees who opt to pull their final required capsules without the implementation of testing are required by the Standard Practice to hold the capsules in storage.

Table 1 of ASTM Standard Practice E185-82 also provides specific criteria for removal of surveillance capsules. The removal times are based on criteria that the surveillance capsules be removed after a certain amount of power operation has elapsed or at various times when the RV shell is projected to achieve certain levels of neutron fluence. The intent of the Standard Practice is to achieve a set of testing data over a range of neutron fluences for the RV that bounds the current life of the plant. Of key importance are the removal criteria for the second to last and final capsules required for capsule withdrawal. For the second-to-last required capsule in a withdrawal schedule, the ASTM standard requires that the capsules be pulled at either 13 effective full-power years (EFPYs) or at the time when the capsule is equivalent to the limiting fluence projected for the clad-based metal interface of the RV at EOL, whichever time comes first. For the final capsule that is required for removal, ASTM E185-82 requires that the capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value.

With respect to the current operating term, the IP2 RV has a limiting RTNDT value greater than 200 EF. As stated above, since the RTNDT value is greater than 200 EF, ASTM E185-82 requires that the licensee, at a minimum, remove five capsules from the reactor during the current operating period and test the first four capsules. The licensee has already removed four capsules and an additional two capsules will be removed, as specified by its proposed new withdrawal schedule. Since ASTM E185-82 only requires that one additional capsule be removed, this proposed schedule meets the requirements of the 1982 Edition of ASTM E185 for the reactor vessel surveillance program for IP2, and is acceptable to the staff.

3.2 Changes Proposed to the Withdrawal Schedule for IP2 The licensees November 10, 2004, letter provides the updated RV surveillance capsule withdrawal schedule for IP2. The letter indicated that Capsules T, Y, Z, and V were removed from IP2 at 1.42 EFPY, 2.34 EFPY, 5.17 EFPY, and 8.6 EFPY, respectively, and that the neutron fluences reported for capsules T, Y, Z, and V at the time of withdrawal are 2.53x1018 n/cm2, 4.55x1018 n/cm2, 1.02x1019 n/cm2, and 4.92x1018 n/cm2, respectively, as reported in Westinghouse letter IPP-01-079, dated April 26, 2001. Note that the fluences did not necessarily increase with increasing EFPY because the lead factors varied from capsule to capsule. The letter also reported updated lead factors for the surveillance capsules in the IP2 surveillance program.

The licensee indicated in its November 10, 2004, letter that in addition to the four capsules that have already been withdrawn and tested, that two additional capsules (Capsules U and W) will be removed from the IP2 RV in the future. The licensee also indicated that it has a spare capsule (Capsule X). The licensee noted that the withdrawal schedule for the three capsules, Capsules U, W, and X, are interchangeable, due to the common lead factor and the common materials in the capsules. In addition, the licensee indicated that the withdrawal schedule for Capsule W may be adjusted if the current IP2 license is extended beyond the current 40 years.

The limiting neutron fluence projected for the IP2 RV is approximately 1.5x1019 n/cm2 at EOL (32 EFPY). Capsules T, Y, Z, and V have been withdrawn and tested. The current withdrawal schedule was established based on the 1979 Edition of ASTM E185. The NRC staff verified that the four capsules that have been withdrawn to date, do comply with the withdrawal schedule of ASTM E185-79. The licensees proposed change to the surveillance capsule withdrawal schedule is based on the requirements of the 1982 Edition of ASTM E185, to the extent practicable, as required by Appendix H to 10 CFR Part 50.

The licensee indicated that the projected neutron fluence for Capsule U at the time of removal will be 1.3x1019 n/cm2 and that the lead factor for the capsule is 1.2. The licensee also indicated that Capsule W will be removed from the reactor vessel at approximately 32 EFPY.

The licensee projected that the neutron fluence for Capsule W at the time of removal will be 1.5x1019 n/cm2 and that the lead factor for the capsule is 1.2. In addition, the licensee indicated that it has a spare capsule, Capsule X, included in its reactor vessel surveillance capsule withdrawal program.

As stated above, ASTM E185-82 requires that the fifth capsule be removed at a time when the neutron fluence projected for the capsule is between the limiting fluence value projected for the RVs at the EOL and two times that value. This criteria will be met by Capsule W for the current operating term for IP2, therefore, the NRC staff finds that the licensee adequately meets ASTM E185-82 for its remaining capsule in its program.

4.0 CONCLUSION

The NRC staff has reviewed Entergys proposed withdrawal schedules for IP2, and has determined that the changes to the schedule will continue to meet the RV surveillance capsule withdrawal schedule criteria in ASTM E185-82, and is in compliance with 10 CFR Part 50, Appendix H, for the current operating period for IP2. The staff, therefore, concludes that the RV withdrawal schedule, as proposed in the licensees November 10, 2004, letter is acceptable for implementation.

This SE does not provide acceptance of the proposed withdrawal schedule for a possible period of extended operation for IP2. The staff will evaluate the applicability of the withdrawal schedule for an extended period of operation should the licensee submit a license renewal application for IP2.

Principal Contributor: M. Khanna Date: November 16, 2004