NL-08-031, Reply to Request for Additional Information Regarding License Renewal Application - Scoping and Screening Methodology
| ML080510579 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/13/2008 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-031 | |
| Download: ML080510579 (9) | |
Text
Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB Entergy, P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 788 2055 Fred Dacimno Vice President License Renewal February 13, 2008 Re: Indian Point Units 2 & 3 Docket Nos. 50-247 & 50-286 NL-08-03 1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Reply to Request for Additionar Information Regarding License Renewal Application -
ScoDing and Screening Methodology
Reference:
NRC letter dated January 14, 2008; "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 License Renewal - Scoping and Screening Methodology
Dear Sir or Madam:
Entergy Nuclear Operations, Inc is providing, in Attachment I, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application for Indian Point 2 and Indian Point 3. The additional information provided in this transmittal addresses staff questions regarding Scoping and Screening Methodology.
There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr. R. Walpole, Manager, Licensing at (914) 734-6710.
I declare under penalty of perjury that the foregoing is true and correct. Executed on , Ii3O'.
F'TLdR. Dacimo Vice President License Renewal
NL-08-031 Docket Nos. 50-247 & 50-286 Page 2 of 2
Attachment:
Reply to NRC Request for Additional Information Regarding License Renewal Application - Scoping and Screening Methodology cc: Mr. Bo M. Pham, NRC Environmental Project Manager Ms. Kimberly Green, NRC Safety Project Manager Mr. John P. Boska, NRC NRR Senior Project Manager Mr. Samuel J. Collins, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel IPEC NRC Senior Resident Inspectors Office Mr. Paul D. Tonko, President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service
ATTACHMENT I TO NL-08-031 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE RENEWAL APPLICATION Scoping and Screening Methodology ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 and 3 DOCKETS 50-247 and 50-286
NL-08-031 Attachment I Docket Nos. 50-247 & 50-286 Page 1 of 6 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)
REQUESTS FOR ADDITIONAL INFORMATION (RAI)
SCOPING AND SCREENING METHODOLOGY The U.S. Nuclear Regulatory Commission (NRC or staff) has reviewed the information related to Scoping and Screening Methodology provided by the applicant in the Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3) LRA. The staff has identified that additional information is needed to complete the review as addressed below.
RAI 2.1-1 10 CFR 54.4(a)(2) Scopinq Criteria for Nonsafety-related SSCs 10 CFR 54.4 (a)(2) requires, in part, that all nonsafety-related systems, structures and components (SSCs) whose failure could prevent the satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1) are to be included within the scope of license renewal.
(a) The staff noted during the audit that the applicant had included fluid-filled, nonsafety-related pipes located within a safety-related space within the scope of license renewal based on the spaces' approach and had also included portions of nonsafety-related piping attached to safety-related SSCs within the scope of license renewal. However, the applicant did not provide sufficient information in the license renewal application nor the implementing procedures to demonstrate that when the fluid-filled pipe was also attached to a safety-related SSC, an additional portion of the pipe, beyond the safety-related space, up to and including an appropriate seismic anchor, equivalent anchor or bounding condition, was also included within the scope of license renewal.
The staff requests that the applicant provide a description of the process used to ensure that fluid-filled, nonsafety-related pipe, attached to safety-related SSCs which exit the safety-related space, was included within the scope of license renewal up to and including an appropriate seismic anchor, equivalent anchor or bounding condition.
(b) During the NRC audit, the staff reviewed the applicant's technical evaluation and on-site documentation for nonsafety-related affecting safety-related SSCs which indicated that certain nonsafety-related SSCs potentially affecting safety-related SSCs were not included within the scope of license renewal based on the proximity of the nonsafety-related SSCs to the safety-related SSCs.
The staff requests that the applicant provide the rationale and basis for not including nonsafety-related SSCs in the vicinity of safety-related SSCs within the scope of license renewal based on their proximity to safety-related SSCs. Indicate the extent of condition by providing a description of the nonsafety-related SSCs which were not included within the scope of license renewal based on their proximity to safety-related SSCs and a description of the corresponding safety-related SSCs.
-Attachment I Docket Nos. 50-247 & 50-286 Page 2 of 6 (c) During the NRC audit, the staff reviewed the applicant's technical evaluation and on-site documentation for nonsafety-related affecting safety-related SSCs which indicated that certain similar SSCs were included within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1) for one unit and 10 CFR 54.4(a)(2) for the other unit.
The staff requests that the applicant provide the rationale and basis for including similar SSCs within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1) for one unit and 10 CFR 54.4(a)(2) for the other unit and how the corresponding review of the adjacent or attached nonsafety-related SSCs (for inclusion within the scope of license renewal) was performed for similar systems in the two units. Indicate the extent of condition by providing a description of the SSCs which were included within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) for one unit and 10 CFR 54.4(a)(2) for the other unit and corresponding descriptions of any differences in the review of adjacent or attached nonsafety-related SSCs.
In addressing these issues, indicate if your review concludes that use of the scoping methodology precluded the identification of nonsafety-related SSCs that could interact with safety-related SSCs, and which were not specifically exempted by your current licensing' basis, and, therefore, should have been considered within the scope of license renewal. Describe any additional scoping evaluations to be performed to address the 10 CFR 54.4(a)(2) criteria.
As part of your response, list any additional SSCs included within the scope as a result of your efforts related to this RAI; and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.
Response for RAI 2.1-1 Part (a):
The process for determining the components to be included for 10 CFR 54.4(a)(2) included a review of all passive mechanical components at IPEC that were not already included in an aging management review report under 10 CFR 54.4(a)(1) or (a)(3).
The review began with a determination of which components needed to be in scope due to their potential for spatial interaction with components with a safety function. If piping and components for fluid-filled systems exit areas containing components with safety functions, further review was performed. This occurred in only limited locations. For those few locations, IPEC reviewed the component database and associated drawings and confirmed that those components required for structural support are within the safety-related space.
NL-08-031 Attachment I Docket Nos. 50-247 & 50-286 Page 3 of 6 Response for RAI 2.1-1 Part (b):
Within a structure that contains components with safety functions, the proximity of components to components with a safety function is not used as a criterion for exclusion of a system or component from (a)(2) scope due to spatial interaction. The wording in the original version of the aging management review report reviewed during the license renewal scoping and screening audit did not clarify why fluid-filled components in locations with safety-related equipment were excluded. Some systems have fluid-filled nonsafety-related components located in structures that contain components with safety functions but cannot spatially affect components with safety functions due to physical barriers such as room separation within the structure. During the license renewal scoping and screening audit, a portion of the IP2 chlorination (CL) system was determined to be in proximity to service water system components which perform a safety function. The CL system had been excluded from 10 CFR 54.4(a)(2) scope. The CL system is added to the scope of license renewal for 10 CFR 54.4(a)(2) with components to be managed by the Periodic Surveillance and Preventive Maintenance, External Surfaces Monitoring, and Bolting Integrity Programs.
Response for RAI 2.1-1 Part (c):
Because IP2 and IP3 were operated independently for an extended period of time, there are differences between IP2 and IP3 in terms of the number of systems, as well as system boundaries and intended functions for similarly named systems. The site component database along with system flow diagrams were used to define system boundaries and identify system intended functions. Consequently, certain similarly named SSCs were included within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(1) only for one unit and 10 CFR 54.4(a)(2) only for the other unit because the system boundaries were different.
The IP2 city water system (CYW) is in scope for 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2) while the IP3 city water system (CWM) is in scope only for 10 CFR 54.4(a)(2). IP2 piping assigned to the city water system provides containment isolation, a 10 CFR 54.4(a)(1) intended function, for supply to fire water hose reels inside the containment building. The IP3 city water system does not provide a similar intended function or any other (a)(1) functions and therefore is not in scope for 10 CFR 54.4(a)(1). Since the city water systems are fluid-filled, all components not included for 54.4 (a)(1) or (a)(3) in structures containing components with safety functions were reviewed for potential spatial impact. Appropriate LRA drawings were also reviewed to verify that no components required for structural support of components with safety functions were excluded.
This review was performed for both systems regardless of system functions to ensure all in-scope components were identified.
The IP2 instrument air closed cooling water system (IACC) system is in scope only for 10 CFR 54.4(a)(2) while the IP3 IACC system is in scope for 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).
IP3 IACC heat exchangers SWN CLC 31 HTX, SWN CLC 32 HTX perform an intended function of providing service water system pressure boundary and are in scope for 10 CFR 54.4(a)(1).
The corresponding IP2 IACC heat exchangers 21 CWHX, 22CWHX are assigned to the service water (SW) system and not IACC, so the IP2 IACC system has no components with a 10 CFR 54.4(a)(1) intended function. Since the IACC systems are fluid-filled, all components in structures containing components with safety functions were reviewed for potential spatial impact. Appropriate LRA drawings were also reviewed to verify that no components required for
NL-08-031 Attachment I Docket Nos. 50-247 & 50-286 Page 4 of 6 structural support of components with safety functions were excluded. This review was performed for both systems regardless of system functions to ensure all in-scope components were identified.
The IP2 river water service system (RW) is in scope for 10 CFR 54.4(a)(1) to support the service water system pressure boundary. Both IP2 and IP3 RW systems are in scope for 10 CFR 54.4(a)(2). The IP3 RW system has no components within its boundary that support the service water system pressure boundary or any other (a)(1) functions. Since the RW systems are fluid-filled, all system components in structures containing components with safety functions were included for potential spatial impact. Appropriate LRA drawings were also reviewed to verify that no components required for structural support of components with safety functions were excluded. This review was performed for both systems regardless of system functions to ensure all in-scope components were included.
Summary In addressing these issues, the review concluded that the scoping method was appropriate to identify nonsafety-related SSCs that could interact with safety-related SSCs in a manner that could prevent satisfactory accomplishment of a safety function.
As a result of a plant walkdown during the scoping and screening audit, however, one additional, system requires addition to the scope of license renewal per 10 CFR 54.4(a)(2) as described in part (b) above. The LRA is revised as follows to include the IP2 chlorination system (CL).
LRA Revisions (added text underlined, strikeouts deleted)
LRA Table 2.2.la-IP2, Mechanical Systems within the Scope of License Renewal, is revised to add the following line item.
System Unit 2 System Name LRA Section Describing System Code CL Chlorination Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2)
LRA Table 2.2-2-1P2, Mechanical Systems Not within the Scope of License Renewal, is revised to remove the following line item.
System USystem ystem Name UFSAR Reference I I GL- GheChioatlei-i Sections 9.6. 1.2 and 10.2.4
NL-08-031 Attachment I Docket Nos. 50-247 & 50-286 Page 5 of 6 LRA Table 2.3.3-19-A-1P2, Miscellaneous Systems within the Scope of License Renewal for 10 CFR 54.4(a)(2), is revised to add the following line item.
System System Name LRA Section Describing System Number CL Chlorination Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2)
LRA Section 2.3.3.19, Miscellaneous Systems in Scope for (a)(2), System Description, is revised to add the following IP2 system description for the IP2 chlorination system.
Unit 2 Chlorination The purpose of the CL system is to provide sodium hypochlorite to the intake bays to limit microorganism fouling in these bays and in the associated water systems that use raw water (service water, circulating water, etc). The system includes the sodium hvDochlorite tanks, oumos. distribution oioina and valves, instruments and controls.
LRA Table 2.3.3-19-B-1P2, 10 CFR 54.4(a)(2) Aging Management Review Tables, is revised to add the following line item.
Table 2.3.3-19-B-IP2 10 CFR 54.4(a)(2) Aging Management Review Tables System Name Series 2.3.3-19-xx-IP2 Table Series 3.3.2-19-xx-IP2 Table Chlorination Table 2.3.3-19-45-IP2 Table 3.3.2-19-45-1P2
NL-08-031 Attachment I Docket Nos. 50-247 & 50-286 Page 6 of 6 The following table is added to Section 2.3.3-19 for IP2.
Table 2.3.3-19-44-1P2 Chlorination System Nonsafety-Related Components Potentially Affecting Safety Functions Subject to Agina Management Review Component Type Intended Function Bolting Pressure boundary PPressure boundary Valve body Pressure boundary LRA Section 3.3, Conclusion, is revised to add the following table.
Table 3.3.2-19-44-1P2: Chlorination System NUREG-1801 Table Intended Aging Effect Aing Comp Type Functin Material Environment Requiring Management 18012 Function Programs Vol.
Item 1Talem Notes ItemNoe Management Loss of material Bolting inter (S-4 22 A Bolting Pressure Carbon Air - indoor boundar steel (ext) irity 22 External VIII.H-7 3.4.1- A in Pressure Carbon Air - indoor Loss of material surfaces (S-29) 28 boundary steel (ext) monitoring Periodic G,305 Pressure Carbon Treated water surveillance and boundary steel (int) material reventive maintenance External VIII.H-7 3.4.1- A Valve body Peure Carbo Air Loss of material surfaces (S-29) 288 boundary steel (ext) monitoring Periodic G,305 Valve body Pressure Carbon Treated water Loss of material surveillance and boundarv steel (int) preventive maintenance