ML080220099
| ML080220099 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/28/2008 |
| From: | Kimberly Green NRC/NRR/ADRO/DLR/REBB |
| To: | Balduzzi M Entergy Nuclear Operations |
| Green, Kimberly NRR/DLR/RLRB 415-1627 | |
| References | |
| Download: ML080220099 (13) | |
Text
January 28, 2008 Mr. Michael A. Balduzzi Senior Vice President and COO Entergy Nuclear Operations, Inc.
Regional Operations, NE 440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - REACTOR COOLANT SYSTEM AND STRUCTURES
Dear Mr. Balduzzi:
By letter dated April 23, 2007, as supplemented by letters dated May 3, 2007, and June 21, 2007, Entergy Nuclear Operations, Inc., submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.
Items in the enclosure were discussed with Mr. Robert Walpole, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-1627, or via e-mail at KJG1@nrc.gov.
Sincerely,
/RA/
Kimberly Green, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
As stated cc w/encl: See next page
ML080220099 OFFICE LA/DLR PM/DLR/RPB2 BC/DLR/RPB2 NAME S. Figueroa for I. King K. Green R. Franovich DATE 01/24/08 01/24/08 01/28/08
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)
REQUEST FOR ADDITIONAL INFORMATION (RAI)
REACTOR COOLANT SYSTEM AND STRUCTURES REACTOR COOLANT SYSTEM RAI 2.3A.1.2-1 Reactor Vessel Internals If failure of the following reactor vessel internals could potentially inhibit core coolability in an accident scenario, they would be subject to the requirement in 10 CFR 54.4(a)(2). Justify the exclusion of these components from the scope of license renewal:
(a) rectangular sample tubing (b) sample tubing springs RAI 2.3A.1.3-2 Reactor Coolant Pressure Boundary Pressurizer manway covers and insert plates have been identified as within the scope of license renewal and subject to an aging management review (AMR) in the LRA (see LRA Table 2.3.1-3-IP2 and 2.3.1-3-IP3). Please clarify whether the pressurizer manways themselves are within the scope of license renewal and subject to an AMR.
RAI 2.3A.1.3-3 Level sensor vents in the reactor vessel level indication system are not highlighted as compo-nents that are subject to an AMR (ref: license renewal drawing LRA-208798-0). The sensor vents appear to provide a reactor coolant pressure boundary. Please state whether the vents associated with the level sensors, as shown on license renewal drawing LRA-208798-0, have a pressure boundary function and, therefore, should be subject to an AMR. If not, justify their exclusion.
STRUCTURES RAI 2.4-1 LRA Table 2.2-3 lists the structures within the scope of license renewal, and Section 2.4 provides the scoping and screening results for these structures. LRA Table 2.2-4 lists the structures not within the scope of license renewal. Confirm whether the following structures, that are not included in either of the above tables, are within the scope of license renewal and subject to an AMR.
(i)
Pipe Penetration Tunnel (Ref. IP2 FSAR Section 1.11.4.10)
(ii)
Liquid Waste Storage Building (Ref. IP3 FSAR Sections 16.1.2 & 9.6.4)
(iii)
Condenser Tube Withdrawl/Removal Pit (Ref. IP3 FSAR, Chapter 1, Site Plan Drawing 64513 and IP2 FSAR Figure 10.2-3)
(iv)
Fuel Oil Storage Tank and its foundation at Buchanan Substation (since it provides backup fuel oil for emergency diesels and gas turbines)
ENCLOSURE
If the above structures are within the scope of license renewal, provide their scoping, screening and AMR results, as appropriate. If not, provide a justification for their exclusion. Also, update LRA Tables 2.2-3 or 2.2-4, as appropriate.
The staff also notes that the structure identified as Gas Turbine Substation Switchgear Structures and Foundation (IP3), in LRA Table 2.2-3 is not included in the subsection titled Description, in LRA Section 2.4.3. Include this structure in Section 2.4.3 and provide its scoping, screening and AMR results, or indicate where these structures and their components are addressed.
RAI 2.4.1-1 The first paragraph of Section 5.1.2.1 of the FSAR (IP2 & IP3) states that the containment structure serves as both a biological shield and a pressure container. The biological shield function is not listed among the intended functions for Containment Buildings in the Description paragraph of LRA Section 2.4.1 and Table 2.4-1. The definition of the shelter or protection (EN) function in LRA Table 2.0-1 is not consistent with the biological shield function (SH). The biological shield function is protection provided against radiation to plant personnel and the public, and not to safety-related equipment. Please clarify and include biological shield function as an intended function for Containment Buildings in the LRA.
RAI 2.4.1-2 From LRA Table 2.4-1, it is not clear if the following components of the Containment Buildings have been screened-in as components subject to an AMR.
(i)
Primary Shield Wall around the Reactor (ii)
Control Rod Drive Missile Shield (iii)
Retaining Wall at the Equipment Hatch Entrance and its Missile Shield (Fixed and Removable)
(iv)
Blowout Shield Plug (v)
Insulation for the Containment Building Liner (limits temperature rise in liner under accident conditions)
(vi)
Protective Coating for liner (vii)
Water proofing around fuel transfer tube (viii)
Waterproof membrane for containment wall against backfill (ix)
Reactor Cavity Seal Ring (see UFSAR Figures 5.1-6 and 5.1-7)
(x)
Seismic Class I Debris Screens at Containment Purge (Ref. FSAR Section 5.1.4.2.4)
(xi)
Stud anchors that anchor the containment liner plate to the concrete shell Please confirm and clarify their inclusion in LRA Table 2.4-1 or justify their exclusion. For the components that are included within scope and subject to an AMR, identify the appropriate AMR results.
RAI 2.4.1-3 Please confirm if the component identified as Structural Steel: beams, columns, plates, trusses in LRA Table 2.4-1 includes bracings, welds and bolted connections. Also confirm if the
pressurized channel shrouds that are used at liner welded joints (including those at penetrations) are included in a structure/commodity group. If not, justify their exclusion from an AMR. Also, confirm if the components identified as bellows penetrations in LRA Table 2.4-1 include the refueling bellows. If not, indicate where in the LRA the refueling bellows have been evaluated.
RAI 2.4.1-4 LRA Table 2.4-1 includes the components Polar Crane, rails and girders and Manipulator Crane, crane rails and girders. Please confirm if the column structure, bridge and trolley of the polar crane and the bridge, trolley and mast of the manipulator crane are screened-in as subject to an AMR. Also, confirm if fasteners and rail hardware associated with the polar crane and manipulator crane are within scope and subject to an AMR. If not, provide the technical bases for their exclusion. Indicate if there are any other hoists and lifting devices (e.g. Reactor Vessel Head Lifting Device, Reactor Internals Lifting Device) that may need to be included as components that are within scope and subject to an AMR. If so, please include in the table and provide associated scoping, screening and AMR results information relevant to the LRA.
RAI 2.4.1-5 LRA Table 2.4-1 lists the Equipment Hatch and Personnel Lock as Containment components subject to an AMR. It is not explicitly clear from Table 2.4-1 if the flange double-gaskets, hatch locks, hinges and closure mechanisms that help prevent loss of sealing/leak-tightness for these listed hatches are included within the scope of license renewal and subject to an AMR. Please confirm the inclusion or exclusion of these components within the scope of license renewal. If they were not included, but should be, please provide a description of their scoping and AMR. If they are included elsewhere in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for their exclusion.
RAI 2.4.2-1 LRA Table 2.4-2 does not include the debris wall, fixed coarse screens, fine mesh traveling screens, and gates at the intake structure. It also does not include metal decking, metal siding, grating and ventilation panels for the intake structure enclosure and manhole, ladder and sump of the service water valve pit. Please confirm if these components should be included within the scope of license renewal and subject to an AMR or not. If not, provide justification for excluding them. Please clarify explicitly what the structural steel component type in LRA Table 2.4-2 includes (e.g. beams, plates, welded/bolted connections etc.).
D-RAI 2.4.3-1 Section 2.4.3 of the LRA states that the fuel storage buildings have the following intended functions for 10 CFR 54.4(a)(1) and (a)(2): Maintain integrity of non-safety related components such that safety functions are not affected by maintaining pool water inventory (Units 2 and 3).
LRA Section 2.1.2.2, Screening of Structures, states that the screening of structural components and commodities was based primarily on whether they perform an intended function. LRA Table 3.5.2-3, Turbine Building, Auxiliary Building, and Other Structures Structural Components and Commodities (IP2 and IP3), identifies structural components
subject to aging management based on materials of construction and intended functions for components of structures including the fuel storage buildings. The intended functions listed in Table 3.5.2-3 (e.g., pressure boundary, missile barrier, and shelter or protection) agree with the intended functions listed in LRA Table 2.0-1, Intended Functions: Abbreviations and Definitions. However, the intended function for the fuel storage building listed in LRA Section 2.4.3 does not agree with the listed intended functions in LRA Tables 2.0-1 and 3.5.2-3.
Pursuant to 10 CFR 54.21, the LRA must identify and list those structures and components subject to an AMR. Clarify the LRA Section 2.4.3 description of the intended function(s) of the fuel storage building components using the list of intended functions from LRA Table 2.0-1. To satisfy the requirements of 10 CFR 54.21, the clarification must be adequate to reasonably identify the fuel building structural components subject to aging management by the component/commodity, material of construction, and intended functions listed in LRA Table 3.5.2-3.
RAI 2.4.3-2 Section 2.4.3 of the LRA states that the top of the spent fuel pit wall forms the north wall of each units fuel building. Unit 2 UFSAR Figure 1.2-4, Cross Section of Plant, indicates that at least part of the fuel building exterior wall is below grade. LRA Table 2.4-3 lists pressure boundary as an intended function for the concrete component exterior walls but does not list pressure boundary as an intended function of the concrete component, exterior walls-below grade, that represents the fuel building wall.
Update LRA Table 2.4-3 to include the pressure boundary intended function for the spent fuel pit wall that is below grade or provide justification for excluding this intended function.
RAI 2.4.3-3 LRA Table 2.4-3 does not include the leak chase channel of the IP3 spent fuel pit as a component subject to an AMR. Include this as a component as subject to an AMR or provide justification for its exclusion.
RAI 2.4.3-4 LRA Table 2.4-3 lists Cranes rails and girders as a component type subject to AMR. It is not clear if this component refers to just crane rails and girders or also refers to the cranes themselves. If it includes the cranes, identify which cranes have been determined to be within the scope of license renewal and if all relevant sub-components (...including bridge and trolley, rails, and girders) of these in-scope crane systems have been screened in as items requiring an AMR. Identify the specific cranes in each of these structures that are included within the above component type as within scope and subject to an AMR, and those that are excluded, with technical bases. Confirm if fasteners and rail hardware associated with this component type are in-scope and subject to AMR. If not, provide the technical bases for their exclusion. Are there any other hoists and lifting devices that may need to be included in-scope and subject to AMR?
If so, include in the table and provide associated scoping, screening and AMR results information relevant to the LRA.
RAI 2.4.3-5 Please confirm if the component identified as Structural Steel: beams, columns, plates in LRA Table 2.4-3 includes bracings, welds and bolted connections. If yes, explicitly state so. If not, indicate where they are included. If Battery Racks are used as a component (e.g. for emergency diesels), include it as a component subject to an AMR. Also identify Turbine Generator Pedestals and their structural bearing pads, Diesel Generator (DG) Pedestals and the concrete curb around DG foundations as being subject to an AMR.
RAI 2.4.4-1 From LRA Table 2.4-4, it is not clear if the following bulk commodities have been screened-in as components subject to an AMR.
(i)
Expansion Anchors (ii)
Vibration Isolation elements (iii)
Flood Curbs (iv)
Waterproofing membrane (v)
Sliding support bearings and sliding support surfaces Confirm if the above component types apply to the LRA and should be included and screened in as subject to an AMR or justify their exclusion. If they are in scope, include them in LRA Table 2.4-4 and provide AMR results. Also, explicitly state the specific materials that are classified as Other Materials in LRA Table 2.4-4.
RAI 2.4.4-2 Clarify the phrase within parentheses (insulation, or Insulation) in the description provided for intended function (1) for insulation in the fourth paragraph of LRA Section 2.4.4. Further, LRA Table 2.4-4 includes bulk commodity component types insulation jacket and insulation that are subject to an AMR. Based on information provided in LRA Table, it is unclear which insulation (with material) and insulation jacket are included in license renewal scope and are included in LRA Table 2.4-4. It is also unclear whether insulation and jacketing on the containment liner, reactor vessel, reactor coolant system, main steam and feed water systems have been included. Please provide the following information, limited to insulation that is used to control the maximum temperature of safety-related structural elements.
(a)
Specifically, identify the structures and structural components designated within the license renewal scope that have insulation and/or insulation jacketing, and identify their location in the plant. Identify locations of the thermal insulation that serves an intended function in accordance with 10 CFR 54.4(a)(2) and describe the scoping and screening results of thermal insulation and provide technical basis for its exclusion from the scope of license renewal.
(b)
For insulation and insulation jacketing materials associated with item (a) above that do not require aging management, submit the technical basis for this conclusion, including plant-specific operating experience.
(c)
For insulation and insulation jacketing materials associated with item (a) above that require aging management, indicate the applicable LRA sections that identify the aging management program(s) credited to manage aging.
RAI 3.5A.2-1 Table 3.5.1, Item 3.5.1-46, of the LRA states that aging of the fuel pool liners will be managed by the water chemistry program and monitoring of spent fuel pool water level in accordance with Technical Specifications and leakage from the leak chase channel. The table includes the following discussion:
Monitoring spent fuel pool water level in accordance with Technical Specifications and monitoring leakage from the leak chase channels (Unit 3) will also continue during the period of extended operation.
The monitoring program for Unit 2 differs from that specified for Unit 3 and from that credited in NUREG-1801. The Unit 3 and NUREG-1801 programs involve monitoring leakage from the leak chase channels.
Explain whether the spent fuel pool water level may be insensitive to leakage comparable to the rate of evaporation and could be masked by routine makeup water additions. If spent fuel pool leakage could be masked by evaporation and routine water additions, describe how the proposed monitoring at Unit 2 would provide acceptable indication of a degrading liner or describe an alternative monitoring method (e.g., monitoring of nearby wells).
Letter to Michael Balduzzi from Kimberly Green, dated January 28, 2008 DISTRIBUTION:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - REACTOR COOLANT SYSTEM AND STRUCTURES HARD COPY:
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Indian Point Nuclear Generating Units 2 and 3 cc:
Mr. Michael R. Kansler President & CEO/CNO Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Senior Vice President Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Sr. Vice President Engineering & Technical Services Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Anthony Vitale - Acting General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249 Mr. Oscar Limpias Vice President Engineering Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Joseph P. DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John A. Ventosa GM, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety & Licensing 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. Ernest J. Harkness Director, Oversight Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Patric W. Conroy Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. T.R. Jones - Acting Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanana, NY 10511-0249 Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
Indian Point Nuclear Generating Units 2 and 3 cc:
Mr. Paul D. Tonko President and CEO New York State Energy Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. John P. Spath New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 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 Senior Resident Inspectors Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 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. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Phillip Musegaas Riverkeeper, Inc.
828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Mr. R. M. Waters Technical Specialist Licensing 450 Broadway P.O. Box 0249 Buchanan, NY 10511-0249
Indian Point Nuclear Generating Units 2 and 3 cc:
Mr. Sherwood Martinelli 351 Dyckman Peekskill, NY 10566 Ms. Susan Shapiro, Esq.
21 Perlman Drive Spring Valley, NY 10977 John Sipos Assistant Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 Robert Snook Assistant Attorney General Office of the Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Ms. Kathryn M. Sutton, Esq.
Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Paul M. Bessette, Esq.
Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Martin J. ONeill, Esq.
Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 The Honorable Nita Lowey 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605