ML080380429

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Request for Additional Information for the Review of the Indian Point Nuclear Generating Units 2 & 3, License Renewal Application - Balance of Plant, Fire Protection and Nickel Alloy
ML080380429
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 02/13/2008
From: Kimberly Green
NRC/NRR/ADRO/DLR
To: Balduzzi M
Entergy Nuclear Operations
Green, Kimberly NRR/DLR/RLRB 415-1627
References
Download: ML080380429 (14)
v • d • e


Text

February 13, 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 - BALANCE OF PLANT, FIRE PROTECTION AND NICKEL ALLOY

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 areas where additional information is needed to complete the review. During a telephone call on February 5, 2008, Entergy indicated that a telephone conference to discuss the draft request for information previously transmitted was not necessary. Therefore, enclosed is the staffs formal request for additional information. 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

ML080380429 OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR NAME KGreen SFigueroa RFranovich w/edit DATE 02/13/08 02/ 13/08 02/13/08

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)

REQUEST FOR ADDITIONAL INFORMATION (RAI)

BALANCE OF PLANT, FIRE PROTECTION AND NICKEL ALLOY Balance of Plant RAI 2.3A.2.2-1 Containment Spray The aging management review (AMR) boundary for a system is typically highlighted on license renewal drawings. However, the license renewal drawings provided to the staff did not contain a depiction of (a)(2) boundaries or components. Section 2.3.2.2 of the license renewal application (LRA) states: The containment spray system has no intended function for 10 CFR 54.4(a)(2).

On Unit 2 license renewal drawing LRA-9321-2735 (containment spray system), the piping line

  1. 187, including valve 872D 3/4-T58 was not highlighted, but it appears to be directly connected to safety-related spray piping. This piping is located downstream of the safety class boundary on the suction piping, 12-SI-151R- #181, from the refueling water storage tank (RWST) to the containment spray pump at branch connection, 2-SI-151R- #588, ending at valve 873B 2-T58.

Similarly, there is a non-highlighted mini-flow recirculation line from the pump. Piping downstream of the safety class boundary may not be required to perform the safety-related function, but may need to be included in scope under 10 CFR 54.4(a)(2).

Indicate whether portions of the above system(s) were evaluated for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). Identify all other instances, whereby a safety-related system, which has nonsafety-related components, was scoped in per 10 CFR 54.4(a)(1), but those nonsafety-related components were not identified as in scope for 10 CFR 54.4(a)(2).

RAI 2.3A.4.2-2 Auxiliary Feedwater Section 2.3.4.3 of the license LRA states: The AFW system has no intended function for 10 CFR 54.4(a)(2).

The following components on safety-related system(s) are not highlighted, but may need to be considered for 10 CFR 54.4(a)(2):

Indicate whether portions of the above system(s) were evaluated for inclusion within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). It is noted that in D-RAI 2.3A.2.2-1, above, the extent of condition has been requested.

ENCLOSURE

RAI 2.2B-2 Nonsafety-related SSCs directly connected to safety-related SSCs must be structurally sound in order to maintain the pressure boundary integrity of safety class piping. The nonsafety-related piping and supports up to and including the first seismic anchor beyond the safety/nonsafety interface may need to be in-scope in order to assure that the safety-related portion of the piping will be able to perform its intended function.

In the (a)(2) scoping document and LRA Table 2.2-2-IP3, the hydrogen gas system was labeled not in-scope. This system, along with the nitrogen system, has the function to provide the volume control tank (VCT) with gas for oxygen scavenging. Since the piping is directly connected to the VCT, the applicant should consider including the system in-scope for (a)(2) for potential physical interaction between the nonsafety and safety-related equipment.

Evaluate placing the hydrogen system and/or nitrogen system in-scope for (a)(2) and evaluate any other interfaces of gas system interaction with safety-related equipment.

RAI 2.3.0-2 Several LRA drawings identify various components as Not A Long Lived Component, i.e., the component is not subject to an aging management review (AMR).

  • Drawing LRA-9321-2720 and LRA-9321-27203 for Unit 2 and Unit 3, respectively, show several components for the component cooling water system to the reactor coolant pumps 21, 22, 23, and 24.

In NUREG-1800, Rev. 1, Section 2.1.3.2.2 describes long-lived structures and components as those that are not subject to periodic replacement based on a qualified life or specified time period. Furthermore, it states that replacement programs may be based on vendor recommendations, plant experience, or any means that establishes a specific replacement frequency under a controlled program.

Other license renewal applications typically have not designated pumps, motors, and heat exchangers as not long lived, i.e., these components, or portions thereof, are subject to an AMR.

a) Identify the component types serviced by the component cooling water system indicated in the above mentioned drawings that are shown as not long lived.

b) Provide a basis for designating these components as not long lived to include details on how the qualified life of the components was established and describe the program under which aging management activities for the components are performed, and any available plant-specific operating experience confirming the effectiveness of management activities.

Nonsafety-Related Components LRA Sections 2.1.1.2 and 2.1.2.1.2 describe the specific details for applying the methodology for identifying nonsafety-related portions of systems with a potential for adversely affecting safety-related functions in accordance with 10 CFR 54.4(a)(2). LRA Section 2.1.2.1.3 states that license renewal drawings were prepared to indicate portions of systems that support system intended functions with the exception of those systems in-scope for 10 CFR 54.4(a)(2) for physical interactions.

Because nonsafety-related system portions meeting 10 CFR 54.4(a)(2) for physical interactions are not indicated on the license renewal drawings, further information is required by the staff to complete its review to confirm that the licensee has adequately identified components in-scope for (a)(2).

For each of the following license renewal drawings identified below, describe the specific portions of the system piping that are within the scope of license renewal for meeting 10 CFR 54.4(a)(2) for physical interactions, or justify their exclusion.

RAI 2.3A.3.1-1. Spent Fuel Pit Cooling System (Unit 2)

1. Drawing LRA-9321-2720 (sheet 2) - piping within the spent fuel storage building co-located with safety-related component cooling system piping in the spent fuel building between locations D1 and A3.
2. Drawing LRA-227781 - refueling water purification piping outside the spent fuel storage building co-located with safety-related piping outside the spent fuel building between locations D1 and H1 associated with the spent fuel demineralizers.

RAI 2.3B.3.1-2. Spent Fuel Pit Cooling System (Unit 3)

1. Drawing LRA-9321-27513 (sheet 2) - piping within the spent fuel storage building co-located with safety-related component cooling system piping in the spent fuel storage building between locations E1 and H6.
2. Drawing LRA-9321-27513 (sheet 2) - piping outside the spent fuel storage building co-located with safety-related safety injection system piping outside the spent fuel storage building at locations F6 and G6 associated with the spent fuel demineralizers.

RAI 2.3A.3.2-1 Service Water System (Unit 2)

1. Drawing LRA-9321-2028 inch line #1502 city water to the three emergency diesel generator 40 gallon jacket water expansion tanks.
2. Drawing LRA-9321-2722 - instrument air compressor cooling water piping inside the control building that is co-located with the service water system piping between locations G1 and I6.
3. Drawing LRA-9321-2722 inch piping (at location B5) supplying service water to the main turbine lube oil coolers.
4. Drawing LRA-9321-2722 inch piping (at location A4) supplying service water to various conventional plant services.
5. Drawing LRA-9321-2722 inch piping (at location A3) between valves SWN-4 and SWN-5.
6. Drawing LRA-9321-2722 inch piping header # 472 between locations A2 to E2, downstream of valves SWN-591, SWN-593, SWN-595, SWN-597, and SWN-599.
7. Drawing LRA-9321-2722 inch piping header downstream of valves SWN-501, SWN-502, SWN-503, SWN-504, SWN-505, and SWN-506, including connecting piping to and near SWN-507 (at location F1).
8. Drawing LRA-209762 inch piping upstream of RCV-018 from waste condensate pump discharge via line #260 and #261, (at location H2) inside the Primary Auxiliary Building (PAB).
9. Drawing LRA-235117 inch line #12 inside the service water tunnel (at location C4).
10. Drawing LRA-235117 - 3/4-inch line #1578 from the blowdown tank room to radiation monitor R-49 (at location D4).
11. Drawing LRA-235117 - 3/4-inch line #1577 containing valves MW-594, MW-600, MW-596, together with 3/4-inch line #1577 from radiation monitors R-46 (at location B2) to R-49.
12. Drawing LRA-235117 inch line #1580 from radiation monitors R-46 to R-49 up to sump pump #25 (at location E4).
13. Drawing LRA-235122 inch and 3/4-inch line #1593 between radiation monitors R-47(at location B4), R-39 (at location D4), R-40 (at location B3), and R-48 (at location B2) and from location D2.
14. Drawing LRA-235122 - 3/4-inch line #1592 and 3/4-inch line #1611 from D2 to B1.
15. Drawing LRA-226037 - 2 lines to the Victoreen radiation monitor labeled purge water in, and purge water out including valves FCV-46-2 and FCV-46-3 (at locations D4 and E3, respectively).
16. Drawing LRA-226038 - sample line B to and from heat exchanger HTX-49-1 from location A4 to C4.
17. Drawing LRA-226038 - purge water out line D and purge water In line E, and purge water out including valves FCV-49-2 and FCV-49-3 (at locations D4 and E3, respectively).
18. Drawing LRA-242687 - purge water out line D and purge water in line E.

RAI 2.3B.3.2-1. Service Water System (Unit 3)

1. Drawing LRA-9321-20283 - 3/4-inch line #1033 city water to the three emergency diesel generator 40 gallon jacket water expansion tanks.
2. Drawing LRA-9321-20333 inch and 16-inch lines originating at valves SWN-6 and SWN-7 (at location F4) and FCV-1111 and FCV-1112 (at location F4).
3. Drawing LRA-9321-20333 - piping associated with service water strainer blowdown valves SWN 64-1 (at location C2), SWN-64-2 (at location C3), SWN-64-3 (at location C4), SWN 64-4 (at location C5), SWN 64-5 (at location C6), and SWN 64-6 (at location C7) up to its anchor.
4. Drawing LRA-9321-20333 inch and 8-inch lines originating between valves SWN-4 and SWN-5 (at location D-5), in their entirety.

RAI 2.3A.3.3-1 Component Cooling Water System (Unit 2)

Drawing LRA-9321-2730 - lines surrounding component cooling supply to #21 and #22 waste gas compressors.

RAI 2.3B.3.3-1 Component Cooling Water System (Unit 3)

Drawing LRA-9321-27303 - lines surrounding component cooling supply to #31 and #32 waste gas compressors.

RAI 2.3A.3.5-1 Gas System (Unit 2)

Drawing LRA-9321-2723 line 1-CH-151R-LINE#115 that is directly connected to the volume control tank.

RAI 2.3A.3.18-1 Plant Drains System - Waste Disposal System (Unit 2)

Drawing LRA-9321-2719 - containment penetrations Y and Z outside of the safety-related boundary that is structurally attached to the containment penetration piping both inside and outside containment at locations C1 and C2, respectively.

RAI 2.3B.3.18-1 Plant Drains System - Liquid Waste Disposal System (Unit 3)

Drawing LRA-9321-27193 (sheet 1) - containment penetrations Y and Z outside of the safety-related boundary that is structurally attached to the containment penetration piping both inside and outside containment (at locations C3 and D3, respectively).

RAI 2.3A.3.13-1 Fuel Oil System (Unit 2)

1. Drawing LRA-9321-2030 - 3/4-inch line from 21 diesel generator fuel oil drip tank drain pump 21 and associated valves structurally attached to fuel oil day tank No. 21 between locations G2 and G4.
2. Drawing LRA-9321-2030 - 3/4-inch line from 22 diesel generator fuel oil drip tank drain pump 22 and associated valves structurally attached to fuel oil day tank no. 22 between locations D2 and D4.
3. Drawing LRA-9321-2030 - 3/4-inch line from 23 diesel generator fuel oil drip tank drain pump 23 and associated valves structurally attached to fuel oil day tank no. 23 between locations B2 and B4.

RAI 2.3B.3.13-1 Fuel Oil System (Unit 3)

1. Drawing LRA-9321-20303 - 3/4-inch line # 1103 near 31 diesel generator fuel oil drip tank drain pump 31 discharge and associated valves structurally attached to fuel oil day tank no.

31 between locations B4 and E3.

2. Drawing LRA-9321-20303 - 3/4-inch line # 1106 near diesel generator fuel oil drip tank drain pump 32 discharge and associated valves structurally attached to fuel oil day tank no. 32 between locations B6 and E5.
3. Drawing LRA-9321-20303 - 3/4-inch line # 1106 near diesel generator fuel oil drip tank drain pump 33 discharge and associated valves structurally attached to fuel oil day tank no. 33 between locations B7 and E7.

RAI 2.3A.3.14-2 Emergency Diesel Generators (Unit 2)

Drawing LRA-9321-2028 - 3/4-inch line from city water system (for makeup) structurally attached to 21, 22, and 23 jacket water expansion tanks, including valves and LCV-5004, LCV-5005, and LCV-5006, located between B5/6 and H5/6 and in the EDG room.

RAI 2.3B.3.14-2 Emergency Diesel Generators (Unit 3)

Drawing LRA-9321-20283 - 3/4-inch line #1033 from city water system (for makeup) structurally attached to 31 (3/4-inch line #1033), 32 (3/4-inch line #1034), and 33 (3/4-inch line #1035) jacket water expansion tanks, including valves and associated level control valves located between D2 and D7 and in the EDG room.

Fire Protection RAI 3.0.3.2.7-1 LRA Table 2.4-4 lists fire stops and fire wrap as bulk commodities that perform an intended function of fire barrier. LRA Table 3.5.2-4, Bulk Commodities, identifies the material,

environment and aging effect requiring aging management for these two commodities. The Fire Protection Program is identified as the aging management program along with Note J which indicates that neither the component nor the material and environment combination is evaluated in NUREG-1801. However, in LRA Section B.1.13, Fire Protection, there is no indication that fire stops and fire wrap are included as commodities whose aging effects will be managed by the AMP. Describe how the aging effects of cracking/delamination, separation (for fire stops), and loss of material (for fire wrap) will be managed under the Fire Protection AMP.

Nickel Alloy RAI 3.0.3.3.5-1 The Nickel Alloy Inspection Program for the monitoring and trending program element states that records of the inspection program, examination and test procedures, examination/test data, and corrective actions taken or recommended are maintained in accordance with the requirements of ASME Section XI, Subsection IWA.

The Standard Review Plan for License Renewal (SRP-LR) Section A.1.2.3.5, and SRP-LR Table A.1-1 state that:

Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions. Plant-specific and/or industry-wide operating experience may be considered in evaluating the appropriateness of the technique and frequency. This program element describes how the data collected are evaluated and may also include trending for a forward look. This includes an evaluation of the results against the acceptance criteria and a prediction regarding the rate of degradation in order to confirm that timing of the next scheduled inspection will occur before a loss of SC intended function. Although aging indicators may be quantitative or qualitative, aging indicators should be quantified, to the extent possible, to allow trending. The parameter or indicator trended should be described. The methodology for analyzing the inspection or test results against the acceptance criteria should be described. Trending is a comparison of the current monitoring results with previous monitoring results in order to make predictions for the future.

Please describe how the monitoring and trending program elements will be addressed in the Nickel Alloy Inspection Program.

RAI 3.0.3.3.5-2 LRA Table 3.1.1, Item 3.1.1-31 is applicable to NUREG-1801, Rev. 1, Items IV.A2-12, IV.A2-19, and IV.C2-13, which specify that an acceptable aging management program is to comply with applicable NRC Orders and provide a commitment in the FSAR supplement to implement applicable (1) Bulletins and Generic Letters and (2) staff-accepted industry guidelines.

The statement in the Nickel Alloy Inspection Program states that Indian Point will continue to implement commitments associated with (1) NRC Orders, Bulletins and Generic Letters associated with nickel alloys and (2) staff accepted industry guidelines.

The intent of this statement is unclear. Please clarify that the applicant commits to comply with applicable Bulletins, Generic Letters and staff-accepted industry guidelines.

Letter to M. Balduzzi from K. Green, dated February 13, 2008 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - BALANCE OF PLANT, FIRE PROTECTION AND NICKEL ALLOY HARD COPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr RidsNrrDlrRpb1 RidsNrrDlrRpb2 RidsNrrDlrRer1 RidsNrrDlrRer2 RidsNrrDlrRerb RidsNrrDlrRpob RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDraAplb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter

RFranovich EDacus, OCA BPham GMeyer, RI KGreen MMcLaughlin, RI JCaverly NMcNamara, RI RAuluck DScrenci, RI OPA KChang NSheehan, RI OPA MKowal PCataldo, RI JBoska CHott, RI STurk, OGC DJackson, RI LSubin, OGC BWelling, RI BMizuno, OGC RConte, RI SBurnell, OPA ECobey, RI DMcIntyre, OPA MCox, RI TMensah, OEDO

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Michael R. Kansler Mr. Joseph P. DeRoy President & CEO/CNO Vice President, Operations Support Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 1340 Echelon Parkway Jackson, MS 39213 Jackson, MS 39213 Mr. John T. Herron Mr. John A. Ventosa Senior Vice President GM, Engineering Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Sr. Vice President Mr. John F. McCann Engineering & Technical Services Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Fred R. Dacimo Ms. Charlene D. Faison Site Vice President Manager, Licensing Entergy Nuclear Operations, Inc. Entergy Nuclear Operations, Inc.

Indian Point Energy Center 440 Hamilton Avenue 450 Broadway, GSB White Plains, NY 10601 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Ernest J. Harkness Director, Oversight Mr. Anthony Vitale - Acting Entergy Nuclear Operations, Inc.

General Manager, Plant Operations 1340 Echelon Parkway Entergy Nuclear Operations, Inc. Jackson, MS 39213 Indian Point Energy Center 450 Broadway, GSB Mr. Patric W. Conroy P.O. Box 249 Director, Nuclear Safety Assurance Buchanan, NY 10511-0249 Entergy Nuclear Operations, Inc.

Indian Point Energy Center Mr. Oscar Limpias 450 Broadway, GSB Vice President Engineering P.O. Box 249 Entergy Nuclear Operations, Inc. Buchanan, NY 10511-0249 1340 Echelon Parkway Jackson, MS 39213

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. T.R. Jones - Acting Senior Resident Inspectors Office Manager, Licensing Indian Point 3 Entergy Nuclear Operations, Inc. U.S. Nuclear Regulatory Commission Indian Point Energy Center P.O. Box 59 450 Broadway, GSB Buchanan, NY 10511 P.O. Box 249 Buchanan, NY 10511-0249 Mr. Charles Donaldson, Esquire Assistant Attorney General Mr. William C. Dennis New York Department of Law Assistant General Counsel 120 Broadway Entergy Nuclear Operations, Inc. New York, NY 10271 440 Hamilton Avenue White Plains, NY 10601 Mayor, Village of Buchanan 236 Tate Avenue Mr. Paul D. Tonko Buchanan, NY 10511 President and CEO New York State Energy Research and Mr. Raymond L. Albanese Development Authority Four County Coordinator 17 Columbia Circle 200 Bradhurst Avenue Albany, NY 12203-6399 Unit 4 Westchester County Hawthorne, NY 10532 Mr. John P. Spath New York State Energy, Research and Mr. William DiProfio Development Authority PWR SRC Consultant 17 Columbia Circle 48 Bear Hill Road Albany, NY 12203-6399 Newton, NH 03858 Mr. Paul Eddy Mr. Garry Randolph New York State Department PWR SRC Consultant of Public Service 1750 Ben Franklin Drive, 7E 3 Empire State Plaza Sarasota, FL 34236 Albany, NY 12223-1350 Mr. William T. Russell Regional Administrator, Region I PWR SRC Consultant U.S. Nuclear Regulatory Commission 400 Plantation Lane 475 Allendale Road Stevensville, MD 21666-3232 King of Prussia, PA 19406 Mr. Jim Riccio Senior Resident Inspectors Office Greenpeace Indian Point 2 702 H Street, NW U.S. Nuclear Regulatory Commission Suite 300 P.O. Box 59 Washington, DC 20001 Buchanan, NY 10511

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Phillip Musegaas Mr. Paul M. Bessette, Esq.

Riverkeeper, Inc. Morgan, Lewis & Bockius, LLP 828 South Broadway 1111 Pennsylvania Avenue, NW Tarrytown, NY 10591 Washington, DC 20004 Mr. Mark Jacobs Mr. Martin J. ONeill, Esq.

IPSEC Morgan, Lewis & Bockius, LLP 46 Highland Drive 1111 Pennsylvania Avenue, NW Garrison, NY 10524 Washington, DC 20004 Mr. R. M. Waters The Honorable Nita Lowey Technical Specialist Licensing 222 Mamaroneck Avenue, Suite 310 450 Broadway White Plains, NY 10605 P.O. Box 0249 Buchanan, NY 10511-0249 Joan Leary Matthews Senior Counsel for Special Projects Mr. Sherwood Martinelli Office of General Counsel 351 Dyckman NYS Department of Environmental Peekskill, NY 10566 Conservation 625 Broadway Ms. Susan Shapiro, Esq. Albany, NY 12233-5500 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

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