ML081160391
| ML081160391 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/08/2008 |
| From: | Kimberly Green NRC/NRR/ADRO/DLR |
| To: | |
| Green, Kimberly NRR/DLR/RLRB 415-1627 | |
| References | |
| Download: ML081160391 (11) | |
Text
May 8, 2008 LICENSEE: Entergy Nuclear Operations, Inc.
FACILITY: Indian Point Nuclear Generating Unit Nos. 2 and 3
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALLS HELD ON APRIL 16, 2008, AND APRIL 28, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATIONSTRUCTURES The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held telephone conference calls on April 16, 2008, and April 28, 2008, to obtain clarification on Entergys response to a request for additional information (RAI) regarding the Indian Point license renewal application (LRA). By letter dated February 27, 2008, Entergy submitted its response to an RAI regarding structures. The staff reviewed the information contained therein, and requested additional information/clarification on a few items. provides a listing of the participants, and Enclosure 2 contains a listing of the items discussed with the applicant, including a brief description of the resolution of the items.
The applicant had an opportunity to comment on this summary.
/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
Enclosures:
- 1. List of Participants
- 2. Summary of Discussion cc w/encls: See next page
ML081160391 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME YEdmonds KGreen RFranovich DATE 05/05/08 05/06/08 05/08/08 Letter to Entergy from K. Green, dated May 8, 2008 DISTRIBUTION:
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALLS HELD ON APRIL 16, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION STRUCTURES 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:
Senior Vice President Mr. John P. Spath Entergy Nuclear Operations, Inc. New York State Energy, Research and P.O. Box 31995 Development Authority Jackson, MS 39286-1995 17 Columbia Circle Albany, NY 12203-6399 Vice President Oversight Entergy Nuclear Operations, Inc. Mr. Paul Eddy P.O. Box 31995 New York State Department Jackson, MS 39286-1995 of Public Service 3 Empire State Plaza Senior Manager, Nuclear Safety & Albany, NY 12223-1350 Licensing Entergy Nuclear Operations, Inc. Regional Administrator, Region I P.O. Box 31995 U.S. Nuclear Regulatory Commission Jackson, MS 39286-1995 475 Allendale Road King of Prussia, PA 19406 Senior Vice President and COO Entergy Nuclear Operations, Inc. Senior Resident Inspectors Office 440 Hamilton Avenue Indian Point 2 White Plains, NY 10601 U.S. Nuclear Regulatory Commission P.O. Box 59 Assistant General Counsel Buchanan, NY 10511 Entergy Nuclear Operations, Inc.
440 Hamilton Avenue Senior Resident Inspectors Office White Plains, NY 10601 Indian Point 3 U.S. Nuclear Regulatory Commission Manager, Licensing P.O. Box 59 Entergy Nuclear Operations, Inc. Buchanan, NY 10511 Indian Point Energy Center 450 Broadway, GSB Mr. Charles Donaldson, Esquire P.O. Box 249 Assistant Attorney General Buchanan, NY 10511-0249 New York Department of Law 120 Broadway Mr. Paul D. Tonko New York, NY 10271 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
Indian Point Nuclear Generating Units 2 and 3 cc:
Mayor, Village of Buchanan Ms. Susan Shapiro, Esq.
236 Tate Avenue 21 Perlman Drive Buchanan, NY 10511 Spring Valley, NY 10977 Mr. William DiProfio John Sipos PWR SRC Consultant Assistant Attorney General 48 Bear Hill Road New York State Department of Law Newton, NH 03858 Environmental Protection Bureau The Capitol Mr. Garry Randolph Albany, NY 12224 PWR SRC Consultant 1750 Ben Franklin Drive, 7E Robert Snook Sarasota, FL 34236 Assistant Attorney General Office of the Attorney General Mr. William T. Russell State of Connecticut PWR SRC Consultant 55 Elm Street, P.O. Box 120 400 Plantation Lane Hartford, CT 06141-0120 Stevensville, MD 21666-3232 Ms. Kathryn M. Sutton, Esq.
Mr. Jim Riccio Morgan, Lewis & Bockius, LLP Greenpeace 1111 Pennsylvania Avenue, NW 702 H Street, NW, Suite 300 Washington, DC 20004 Washington, DC 20001 Mr. Paul M. Bessette, Esq.
Mr. Phillip Musegaas Morgan, Lewis & Bockius, LLP Riverkeeper, Inc. 1111 Pennsylvania Avenue, NW 828 South Broadway Washington, DC 20004 Tarrytown, NY 10591 Mr. Martin J. ONeill, Esq.
Mr. Mark Jacobs Morgan, Lewis & Bockius, LLP IPSEC 1111 Pennsylvania Avenue, NW 46 Highland Drive Washington, DC 20004 Garrison, NY 10524 The Honorable Nita Lowey Mr. R. M. Waters 222 Mamaroneck Avenue, Suite 310 Technical Specialist Licensing White Plains, NY 10605 450 Broadway P.O. Box 0249 Joan Leary Matthews Buchanan, NY 10511-0249 Senior Counsel for Special Projects Office of General Counsel Mr. Sherwood Martinelli NYS Department of Environmental 351 Dyckman Conservation Peekskill, NY 10566 625 Broadway Albany, NY 12233-5500
TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 16, 2008, AND APRIL 28, 2008 PARTICIPANTS AFFILIATIONS Kim Green U.S. Nuclear Regulatory Commission (NRC)
George Thomas NRC Hans Ashar NRC Mike Stroud Entergy Nuclear Operations, Inc. (Entergy)
Alan Cox Entergy Reza Ahrabli Entergy John Curry (4/28/08) Entergy Charlie Caputo (4/28/08) Entergy ENCLOSURE 1
CLARIFICATION ON RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION April 16, 2008, and April 28, 2008 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference calls on April 16, 2008, and April 28, 2008, to discuss and clarify the following responses to a request for additional information (RAI) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 license renewal application (LRA).
By letter dated January 28, 2008, the staff requested additional information regarding certain structures, among other items. By letter dated February 27, 2008, Entergy responded to the staffs RAI.
Upon review of the information contained in Entergys response letter, the staff determined that additional clarification was warranted. The items requiring clarification are discussed below.
RAI 2.4-1 (a) The response states that the liquid waste storage building (located within the administration building) does not perform a license renewal function and therefore not in scope. To help staff arrive at this conclusion, please indicate the function performed by the liquid waste storage building.
Applicants clarification:
The applicant stated that the function of the liquid waste storage building is to house the liquid radwaste facility, which does not have any license renewal intended functions. The staff was satisfied with this clarification.
(b) With regard to switchgear structures and foundation, clarify which structural components in Table 2.4-3 cover the switchgear structures and foundation? (Note that the structures listed in parenthesis under line item foundations do not include switchgear structures - needs to be included?)
Applicants clarification:
The applicant stated that the foundation is listed in LRA Table 2.4-4 as equipment pads/foundations. The staff will ask the applicant for this formal clarification.
RAI 2.4.1-2 (i) Response states that Primary Shield Wall is included as part of line item Beams, columns, interior walls, slabs in Table 2.4-1. Note that walls with lesser safety-significance such as pressurizer shield, ring wall and cylinder walls have been listed as separate items in Table 2.4-1. Considering the higher safety-significance of the primary shield wall, suggest including the primary shield wall as a separate line item.
ENCLOSURE 2
Applicants clarification:
The applicant stated that it could list the Primary Shield Wall as a separate line item in the LRA Table. The staff will ask the applicant for this formal clarification.
(iii) Response states that the retaining wall is included as part of line item Beams, columns, interior walls, slabs in Table 2.4-1. The retaining wall at the equipment hatch entrance is an exterior wall. Therefore, the applicant should explicitly call out in the LRA Table 2.4-1 that the line item includes the retaining wall at the equipment hatch entrance or provide separate line item.
Applicants clarification:
The applicant stated that it can revise the response. The staff will ask the applicant for this formal clarification.
(v) Response states that liner plate insulation is included with line item Insulation Jacket in Table 2.4-1. The materials for the insulation jacket and the insulation itself are not the same. The jacket is stainless steel but the insulation is PVC for U2 and Urethane foam covered with gypsum board for U3 (See UFSAR Section 5.1). The insulation itself is not included in Table 2.4-1 nor Table 2.4-4 nor are these materials identified in LRA Sections 3.5.2.1.1 or 3.5.2.1.4. The applicant should appropriately address the scoping, screening and AMR of these in-scope insulation materials in the LRA.
Applicants clarification:
The applicant stated that it can provide written clarification. The staff will ask the applicant for this formal clarification.
(vi) Response states that protective coatings are not in scope because they do not perform an intended function. Athough protective coatings on liner does not directly perform a license renewal function, it however prevents degradation of the liner if maintained. Also, AMP XI.S8 of NUREG-1801 (GALL) recommends its maintenance to avoid clogging of the sumps. The GALL Report requires that if protective coatings are relied upon to manage the effects of aging, the structures monitoring program is to include provisions to address protective coating monitoring and maintenance (See Item 25 in Table 5 of NUREG-1801, Vol. 1). The AMP for protective coatings in the GALL is XI.S8. Therefore, all protective coatings in the plant that are relied upon to manage the effects of aging of steel components in the plant should be in-scope and subject to AMR and AMP.
Applicants clarification:
The applicant stated that it does not credit coatings for managing the effects of aging. However, it will provide written clarification only for the containment liner. The staff will ask the applicant for this formal clarification.
(ix) Response states that the reactor cavity seal ring has no license renewal intended function.
The staff has determined that the reactor cavity seal ring performs as a flood barrier (FLB) to preclude borated water leaks thru the seal and accumulation in the gap between the reactor vessel and the primary shield wall, that could induce corrosion in the reactor vessel and its supports. The applicant should address this in the LRA.
Applicants clarification:
The applicant stated that the reactor cavity seal ring is only used during refueling, and does not have a license renewal intended function for normal operation. The staff stated that it will review the issue further, and if necessary, ask a follow up RAI.
RAI 2.4.1-3 Response states that bellows penetrations in LRA Table 2.4-1 are associated with containment piping penetrations and that refueling bellows is not a feature of the IP2/3 design. Please describe the types of such piping penetration bellows in each unit. Further, clarify if there are transfer canal bellows and if they are within the scope of license renewal.
Applicants clarification:
The applicant stated that it can provide the requested information. The staff will formally ask the applicant for this information and clarification.
RAI 2.4.1-5 The staff does not agree with the applicants statement that the hatch locks, hinges and closure mechanisms are active components and, therefore, not subject to AMR as discussed in LRA Table 3.5.1, Line Item 3.5.1-17. These components are passive during plant operation during which time they are (and needs to remain) in a closed position and are an integral part of the pressure boundary. The aging effect on these components is loss of leak tightness in closed position due to mechanical wear of locks, hinges and closure mechanisms (see Table 5, ID 17 in NUREG-1801, Vol. 1, Rev. 1). The AMPs are 10 CFR Part 50, Appendix J and Plant Technical Specifications that ensures that the containment is operable and access airlock maintain leak tightness in closed position. The applicant needs to screen-in these components as subject to AMR and include the AMP in the LRA.
Applicants clarification:
The applicant stated that it can clarify what it is doing to determine function/operability even though the components about which the staff is inquiring are not subject to an AMR. The staff will ask the applicant for this formal clarification.
RAI 2.4.2-1 In the response, the applicant stated that in-scope grating, decking and ladders are bulk commodities addressed in LRA Table 2.4-4. Clarify if this means that these specific components in question that were identified in the RAI are included in-scope as bulk-commodities addressed in LRA Table 2.4-4.
Applicants clarification:
The applicant stated that the bulk commodities in question are in scope, and that it can clarify the response. The staff will ask the applicant for this formal clarification.
RAI 2.4.3-2 Response states that applicant concurs that the spent fuel pit wall below grade also performs the pressure boundary intended function and LRA Table 2.4-3 and Table 3.5.2-3 are hereby revised to include pressure boundary (PB) intended function for the spent fuel pit wall that is below grade. Where are these revised Tables included?
Applicants clarification:
The applicant referred the staff to LRA Amendment 3, dated March 24, 2008. The staff was satisfied with this clarification.
RAI 2.4.3-4 In its response, the applicant stated that the component type "crane rails and girders" in LRA Table 2.4-3 includes bridge and trolley and also refers to the cranes themselves. Since the language of this line item as currently written is misleading, the applicant needs to correct the typo in the line item crane rails and girders" in Table 2.4-3 to read cranes, rails and girders.
Applicants clarification:
The applicant stated that there is a typo, and it will fix the typo. The staff will ask the applicant for this formal clarification.
RAI 2.4.4-2 The applicant did not respond to the question in the first sentence of the RAI. In short, applicant should clarify if the phrase (insulation or Insulation - there is something missing here!!)
referenced should be (insulation and insulation jacket??).
Applicants clarification:
The applicant stated that there is a typo, and it will fix the typo. The staff will ask the applicant for this formal clarification.
Also, the staff notes that the containment liner plate insulation is PVC for IP2 and Urethane foam covered with gypsum board for IP3 (See UFSAR Section 5.1). The insulation itself is not included in Table 2.4-1 nor Table 2.4-4 nor are these materials identified in LRA Sections 3.5.2.1.1 or 3.5.2.1.4 nor addressed in the above RAI response. The applicant should address scoping and screening of these insulation materials in the appropriate sections of the LRA. This was also indicated against the response to Item (v) of RAI 2.4.1-2.
Applicants clarification:
This is being handled in RAI 2.4.1-2, Item (v).
New Question:
Table 2.2-3 and Section 2.4.2 includes Discharge Canal and Outfall Structure as being within the scope of license renewal. The description in Section 2.4.2 in the second paragraph under the subtitle Discharge Canal and Outfall Structure states that the outfall structure does not
support a license renewal function and therefore is not in scope. If this is the case, why is the Outfall Structure included in Table 2.2-3 and Section 2.4.2? It should have been scoped out in Section 2.2 and included under Table 2.2-4.
Discussion:
The applicant agreed with the staffs assessment. The staff will issue this question as a formal RAI (number RAI 2.4.2-2).