ML081230082

RAI for Review of Indian Point Units 2 and 3, LRA - Operating Experience

ML081230082
Person / Time
Site:	Indian Point
Issue date:	05/07/2008
From:	Kimberly Green NRC/NRR/ADRO/DLR
To:	Entergy Nuclear Operations
Green, Kimberly NRR/DLR/RLRB 415-1627
References
Download: ML081230082 (7)

Text

May 7, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - OPERATING EXPERIENCE

Dear Sir or Madam:

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 Kimberly.green@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

ML081230082 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR BC:RER1:DLR NAME YEdmonds KGreen RFranovich KChang DATE 05/05/08 05/06/08 05/07/08 05/07/08 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION OPERATING EXPERIENCE RAI RCS-1 The staffs review of the condition report (CR) summaries of operating experience related to Class 1 mechanical systems identified four areas of degraded conditions. Those areas are as follows: (1) borated water leakage/boric acid deposits associated with control rod drive, control rod drive mechanism, resistance temperature device, reactor pressure vessel (RPV) bottom head, seal tables, penetrations, fittings and thimble tubes; (2) seal housing bolt cracks; (3) steam generator tube indications; and (4) RPV head weld indications.

Please provide the following information for each type of degraded condition identified above, in sufficient detail for the staff to make a determination about the adequacy of corrective actions for the extended period of operation:

(a) history of the degradation; (b) evaluation of the extent of degradation; (c) corrective actions already taken or planned; (d) the current status of the degraded condition; (e) special or augmented aging management requirements during the period of extended operation; (f) license renewal commitments.

Based on the staffs review of the CR list, it is not clear to the staff if this list contains all significant plant-specific reactor coolant system (RCS) component degradation experienced at Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3). Please identify and provide the same information (items a-f) for any other significant existing conditions of aging for the RCS not specifically identified in this RAI.

In addition, please identify and provide the same information (items a-f) for other significant existing conditions of aging, if applicable, in any Class 1 mechanical components for included in LRA Section 3.2 through 3.4.

RAI RCS-2 Based on the review of the plant basis documents associated with operating experience discussions for aging management programs (AMPs) B.1.16, B.1.18, B.1.30, and B.1.31, the staff found that additional information is needed to complete its operating experience review.

Therefore, please provide the following additional information to assist the staff in its review:

(i) For AMPs B.1.16, B.1.18, B.1.30, and B.1.31, please describe in sufficient detail the plant-specific CR review that forms the basis to conclude that each of these existing programs will be effective in managing applicable aging effects, as identified in the LRA.

ENCLOSURE

(ii) For new AMPs B.1.37 and B.1.38, which are currently being developed, the AMP description of each program identifies that RCS components will be managed for thermal and/or irradiation embrittlement. Please describe in sufficient detail any operating experience for these AMPs, and the review of plant-specific and industry-wide operating experience for those RCS components that have been identified as potentially susceptible to thermal and/or irradiation embrittlement at IP2 and IP3.

RAI AUX-1 In reviewing IP2 and IP3 CR summaries related to operating experience applicable to non-Class 1 mechanical systems, and operating experience summaries for the Diesel Fuel Monitoring, Oil Analysis, Service Water Integrity, Water Chemistry Control -- Auxiliary Systems, and Water Chemistry Control -- Closed Cooling Water Systems AMPs, the staff identified conditions of aging degradation that are not described in detail in the LRA or plant basis documents. The following areas of aging degradation were identified by the staff: (1) degraded IP2 traveling screens; (2) eroded fuel line in IP2 utility tunnel caused by in-leakage; (3) erosion/corrosion of IP2 components and thru-wall leaks; (4) IP3 feedwater outer-diameter thinning; and (5) IP3 service water degradation.

The applicant is requested to provide the following information for each type of degraded condition identified above, in sufficient detail for the staff to make a determination about the adequacy of corrective actions for the extended period of operation:

(a) history of the degradation; (b) evaluation of the extent of degradation; (c) corrective actions already taken or planned; (d) the current status of the degraded condition; (e) special or augmented aging management requirements during the period of extended operation; and (f) license renewal commitments.

In addition, the applicant is requested to identify and provide the same information (items a-f) for other significant existing conditions of aging in non-Class 1 mechanical components included in LRA Sections 3.2 and 3.4, which are not specifically addressed in this RAI.

RAI AUX-2 Appendix B of the LRA concluded that the Service Water Integrity Program has been effective in managing those aging effects for which it is credited based on the results of one peer assessment, one self assessment and five NRC inspections of the Generic Letter (GL) 89-13 program. NRC GL 89-13 guidelines are directed to ensure the performance of safety-related systems and components exposed to service water. It is not clear to the staff how the results of these inspections are used to confirm the effectiveness of managing aging effects in nonsafety-related components of the service water system (SWS) that are within scope for license renewal.

The staff requests the applicant to clarify whether the Service Water Integrity Program is credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. If so, please provide evidence for the conclusion presented in the LRA, that this AMP is effective in managing age-related degradation of the SWS. If not, identify the AMP(s) that are credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. Provide the basis for concluding that these programs will be effective for managing aging during the period of extended operation.

Letter to Entergy from K. Green, dated May 7, 2008 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - OPERATING EXPERIENCE HARD COPY:

DLR RF E-MAIL:

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Indian Point Nuclear Generating Units 2 and 3 cc:

Senior Vice President Mr. Paul Eddy Entergy Nuclear Operations, Inc. New York State Department P.O. Box 31995 of Public Service Jackson, MS 39286-1995 3 Empire State Plaza Albany, NY 12223-1350 Vice President Oversight 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 Manager, Nuclear Safety &

Licensing Senior Resident Inspectors Office Entergy Nuclear Operations, Inc. Indian Point 2 P.O. Box 31995 U.S. Nuclear Regulatory Commission Jackson, MS 39286-1995 P.O. Box 59 Buchanan, NY 10511 Senior Vice President and COO Entergy Nuclear Operations, Inc. Senior Resident Inspectors Office 440 Hamilton Avenue Indian Point 3 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 Mr. Charles Donaldson, Esquire White Plains, NY 10601 Assistant Attorney General New York Department of Law Manager, Licensing 120 Broadway Entergy Nuclear Operations, Inc. New York, NY 10271 Indian Point Energy Center 450 Broadway, GSB Mr. Raymond L. Albanese P.O. Box 249 Four County Coordinator Buchanan, NY 10511-0249 200 Bradhurst Avenue Unit 4 Westchester County Mr. Paul D. Tonko Hawthorne, NY 10532 President and CEO New York State Energy, Research, and Mayor, Village of Buchanan Development Authority 236 Tate Avenue 17 Columbia Circle Buchanan, NY 10511 Albany, NY 12203-6399 Mr. William DiProfio Mr. John P. Spath PWR SRC Consultant New York State Energy, Research, and 48 Bear Hill Road Development Authority Newton, NH 03858 17 Columbia Circle Albany, NY 12203-6399

Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. Garry Randolph Robert Snook PWR SRC Consultant Assistant Attorney General 1750 Ben Franklin Drive, 7E Office of the Attorney General Sarasota, FL 34236 State of Connecticut 55 Elm Street Mr. William T. Russell P.O. Box 120 PWR SRC Consultant Hartford, CT 06141-0120 400 Plantation Lane Stevensville, MD 21666-3232 Ms. Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius, LLP Mr. Jim Riccio 1111 Pennsylvania Avenue, NW Greenpeace Washington, DC 20004 702 H Street, NW Suite 300 Mr. Paul M. Bessette, Esq.

Washington, DC 20001 Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Mr. Phillip Musegaas Washington, DC 20004 Riverkeeper, Inc.

828 South Broadway Mr. Martin J. ONeill, Esq.

Tarrytown, NY 10591 Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Mr. Mark Jacobs Washington, DC 20004 IPSEC 46 Highland Drive The Honorable Nita Lowey Garrison, NY 10524 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605 Mr. R. M. Waters Technical Specialist Licensing Joan Leary Matthews 450 Broadway Senior Counsel for Special Projects P.O. Box 0249 Office of General Counsel Buchanan, NY 10511-0249 NYS Department of Environmental Conservation Mr. Sherwood Martinelli 625 Broadway 351 Dyckman Albany, NY 12233-5500 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