ML043200233

Indian Point Nuclear Generating Unit No. 2 Reactor Vessel Surveillance Capsule Withdrawal Schedule Change

ML043200233
Person / Time
Site:	Indian Point
Issue date:	11/16/2004
From:	Laufer R J NRC/NRR/ADRO/DORL/LPLI-1
To:	Kansler M R Entergy Nuclear Operations
Milano P, NRR/DLPM , 415-1457
References
TAC MC5069
Download: ML043200233 (9)

Text

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

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

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

Dear Kansler:

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requestedapproval of the proposed changes to the reactor vessel surveillance capsule withdrawalschedule 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, asspecified 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 changesto 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 staff's evaluation is enclosed.Sincerely,/RA/Richard J. Laufer, Chief, Section 1Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor RegulationDocket No. 50-247

Enclosure:

As stated cc w/encl: See next page November 16, 2004Mr. 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 VESSELSURVEILLANCE CAPSULE WITHDRAWAL SCHEDULE CHANGE(TAC NO. MC5069)

Dear Kansler:

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc., (the licensee), requestedapproval of the proposed changes to the reactor vessel surveillance capsule withdrawalschedule 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, asspecified 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 changesto 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 staff's evaluation is enclosed.Sincerely,/RA/Richard J. Laufer, Chief, Section 1Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor RegulationDocket No. 50-247

Enclosure:

As stated cc w/encl: See next pageDISTRIBUTIONPUBLICPDI-1 R/FOGCACRSG. Matakas, R-IS. LittleP. MilanoM. KhannaR. LauferS. CoffinAdams Accession No.

ML043200233OFFICEPDI-1/PMPDI-1/LAEMCB/SCOGC PDI-1/SCNAMEPMilanoSLittleSCoffinHMcGurrenRLauferDATE11/15/0411/15/0411/15/0411/16/0411/16/04OFFICIAL RECORD COPY Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Gary J. TaylorChief Executive Officer Entergy Operations, Inc.

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

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

Indian Point Energy Center 295 Broadway, Suite 2

P.O. Box 249 Buchanan, NY 10511-0249Mr. Christopher SchwarzGeneral Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1

P.O. Box 249 Buchanan, NY 10511-0249Mr. Danny L. PaceVice President Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Brian O'GradyVice President, Operations Support Entergy Nuclear Operations, Inc.

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

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

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

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

Indian Point Energy Center 295 Broadway, Suite 1

P.O. Box 249 Buchanan, NY 10511-0249Mr. Patric ConroyManager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 295 Broadway, Suite 1

P. O. Box 249 Buchanan, NY 10511-0249Mr. John M. FultonAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Regional Administrator, Region IU.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406Senior Resident Inspector's 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, PresidentNew York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399Mr. Paul EddyElectric Division New York State Department of Public Service 3 Empire State Plaza, 10 th FloorAlbany, NY 12223Mr. Charles Donaldson, EsquireAssistant Attorney General New York Department of Law 120 Broadway New York, NY 10271Mayor, Village of Buchanan236 Tate Avenue Buchanan, NY 10511Mr. Ray AlbaneseExecutive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592Ms. Stacey LousteauTreasury Department Entergy Services, Inc.

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

25 Wing & Wing Garrison, NY 10524Mr. Paul LeventhalThe Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036Mr. Karl CoplanPace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603Mr. Jim RiccioGreenpeace 702 H Street, NW Suite 300 Washington, DC 20001Mr. Robert D. SnookAssistant 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 LochbaumNuclear Safety Engineer Union of Concerned Scientists 1707 H Street NW, Suite 600 Washington, DC 20006 EnclosureSAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO THE REACTOR VESSEL MATERIALS SURVEILLANCE PROGRAMENTERGY NUCLEAR OPERATIONS, INCINDIAN POINT NUCLEAR GENERATING UNIT NO. 2DOCKET NO. 50-24

71.0INTRODUCTION

By letter dated November 10, 2004, Entergy Nuclear Operations, Inc. (Entergy, the licensee),requested approval of a revision to the reactor vessel surveillance specimen withdrawalschedule 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.

2.0REGULATORY EVALUATION

2.1Section 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 50The Nuclear Regulatory Commission (NRC) has established requirements and criteria in10 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 staff's criteria for the design andimplementation of RV material surveillance programs for operating LWRs. The rule, in part, requires RV surveillance program designs and withdrawal schedules to meet the requirementsof 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 andPressure Vessel Code (ASME Code) to which the RV was purchased, although later editions ofASTM 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 andapproved prior to implementation. The applicable criteria in ASTM E185-82 are discussed in the Section 3.1 of this safety evaluation (SE).2.2NRC Administrative Letter (AL)97-004 and NRC Memorandum and Order CLI-96-13On September 30, 1997, the NRC issued AL 97-004 to all holders of operating licenses fordomestic nuclear power plants (with the exception of those who have ceased operations of theirfacilities or have certified that fuel has been permanently removed from the reactor). In this AL,the NRC staff summarized the Commission's 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 thisMemorandum 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 requirethe NRC staff to review and approve the changes through the NRC's license amendmentprocess (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 ReactorVessels) 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 staffdocument its review and verification of such conformance.

3.0TECHNICAL EVALUATION

3.1Evaluation Criteria of ASTM Standard Practice E185-82For IP2, Entergy is applying the requirements of ASTM Standard Practice E185-82, as its basisfor 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 theend-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 F (56 C), threecapsules 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, andalloying chemistry).*For plants with projected RTNDT between 100 F (56 C) and 200 F (111 C), foursurveillance 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 F (111 C), five surveillance capsules arerequired 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 inthree, 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 ofsurveillance 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 StandardPractice 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 requiredcapsule 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 betweenthe 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 F. As stated above, since the RTNDT value is greater than 200 F, ASTM E185-82requires 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 newwithdrawal 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.

3.2Changes Proposed to the Withdrawal Schedule for IP2The licensee's November 10, 2004, letter provides the updated RV surveillance capsulewithdrawal 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 2.53x10 18 n/cm 2, 4.55x10 18 n/cm 2, 1.02x10 19 n/cm 2, and 4.92x10 18 n/cm 2, respectively, asreported in Westinghouse letter IPP-01-079, dated April 26, 2001. Note that the fluences didnot 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 IP2surveillance program. The licensee indicated in its November 10, 2004, letter that in addition to the four capsules thathave already been withdrawn and tested, that two additional capsules (Capsules U and W) willbe 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 forCapsule 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 1.5x10 19 n/cm 2 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 verifiedthat the four capsules that have been withdrawn to date, do comply with the withdrawalschedule of ASTM E185-79. The licensee's proposed change to the surveillance capsulewithdrawal 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 removalwill be 1.3x10 19 n/cm 2 and that the lead factor for the capsule is 1.2. The licensee alsoindicated 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 1.5x10 19 n/cm 2 and that the lead factor for the capsule is 1.2. In addition, the licensee indicatedthat it has a spare capsule, Capsule X, included in its reactor vessel surveillance capsulewithdrawal program.As stated above, ASTM E185-82 requires that the fifth capsule be removed at a time when theneutron fluence projected for the capsule is between the limiting fluence value projected for theRVs at the EOL and two times that value. This criteria will be met by Capsule W for the currentoperating term for IP2, therefore, the NRC staff finds that the licensee adequately meetsASTM E185-82 for its remaining capsule in its program.

4.0CONCLUSION

The NRC staff has reviewed Entergy's proposed withdrawal schedules for IP2, and hasdetermined that the changes to the schedule will continue to meet the RV surveillance capsulewithdrawal 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 theRV withdrawal schedule, as proposed in the licensee's November 10, 2004, letter is acceptable for implementation.This SE does not provide acceptance of the proposed withdrawal schedule for a possible periodof extended operation for IP2. The staff will evaluate the applicability of the withdrawalschedule for an extended period of operation should the licensee submit a license renewal application for IP2.Principal Contributor: M. Khanna

Date: November 16, 2004