ML081230347
| ML081230347 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/12/2008 |
| From: | Kimberly Green NRC/NRR/ADRO/DLR |
| To: | Entergy Nuclear Operations |
| Green, Kimberly NRR/DLR/RLRB 415-1627 | |
| References | |
| Download: ML081230347 (8) | |
Text
May 12, 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 - STRUCTURES
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
ML081230347 OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR NAME KGreen YEdmonds RFranovich (BPham for)
DATE 05/7/08 05/7/08 05/12/08 Letter to Entergy from K. Green, dated May 12, 2008 DISTRIBUTION:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - STRUCTURES HARD COPY:
DLR RF E-MAIL:
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Indian Point Nuclear Generating Units 2 and 3 cc:
Senior Vice President Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Vice President Oversight Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety &
Licensing Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 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 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858 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
Indian Point Nuclear Generating Units 2 and 3 cc:
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 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 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 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 Joan Leary Matthews Senior Counsel for Special Projects Office of General Counsel NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-5500
ENCLOSURE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION (RAI)
STRUCTURESCLARIFICATION ON RESPONSES Based on the staffs review of Entergys responses dated February 27, 2008, and as discussed in a telephone conferences held on April 16, 2008, and April 28, 2008, please provide responses to the following:
RAI 2.4-1 (Follow Up)
With regard to Switchgear Structures and Foundation (IP3), clarify which structural components in Table 2.4-3 cover the switchgear structures and foundation. (Note that the structures listed in parentheses under line item foundations do not include switchgear structures).
RAI 2.4.1-2 (Follow Up)
(i)
The response states that the Primary Shield Wall is included as part of line item Beams, columns, interior walls, slabs in LRA 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 that the primary shield wall is subjected to a more severe environment (high temperature and radiation exposure) and has a much higher safety-significance than the general interior wall, it is prudent to include the primary shield wall as a separate line item in LRA Table 2.4-1 to make its inclusion as within the scope of license renewal and subject to AMR explicitly clear.
(iii) The 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 and is subjected to a different environment than the interior 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 a separate table line item should be provided.
(v) The response states that liner plate insulation is included with line item Insulation Jacket in LRA 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 polyvinyl chloride (PVC) for Unit 2, and Urethane foam covered with gypsum board for Unit 3 (See UFSAR Section 5.1). The insulation itself is not included in LRA Table 2.4-1 or Table 2.4-4, nor are these materials identified in LRA Sections 3.5.2.1.1 or 3.5.2.1.4. These items are also not addressed in the response to RAI 2.4.4-2. Clarify/address the scoping, screening and AMR of these in-scope insulation materials.
(vi) The response states that protective coatings for the containment liner are not in scope because they do not perform an intended function. The staff believes that although protective coatings on the containment liner do not directly perform a license renewal function, they, however, prevent degradation of the liner if maintained. GALL AMP XI.S8 of NUREG-1801, Vol. 2 (the GALL Report), which is the AMP for protective coatings, recommends coating maintenance to avoid clogging of the sumps. The GALL Report states that if protective coatings are relied upon to manage the effects of aging, the
structures monitoring program should include provisions to address protective coating monitoring and maintenance (See Item 25 in Table 5 of NUREG-1801, Vol. 1).
Considering the above, justify the exclusion of the protective coating on the containment liner from the scope of license renewal and from being subject to an AMR.
(ix) The 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 through 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 as well as cause degradation of the primary shield wall concrete. Considering the above, justify the exclusion of the reactor cavity seal from the scope of license-renewal and from being subject to an AMR.
RAI 2.4.1-3 (Follow Up)
The 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 piping penetration bellows in each unit. Further, clarify if there are transfer canal bellows (with the number in each unit) at Indian Point, and if they are within the scope of license renewal. If not, please justify their exclusion.
RAI 2.4.1-5 (Follow Up)
The response states that the hatch locks, hinges and closure mechanisms are active components and, therefore, are not subject to AMR as discussed in LRA Table 3.5.1, Line Item 3.5.1-17. The staff has determined that these components are passive during plant operation, during which time they are (and need 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 NUREG-1801, Vol. 1, Rev. 1, Table 5, Item 17). The AMPs listed are 10 CFR Part 50, Appendix J and Plant Technical Specifications that ensure that the containment is operable and access airlocks maintain leak tightness in the closed position. Considering the above, justify the exclusion of the hatch locks, hinges and closure mechanisms from the scope of license renewal and from being subject to an AMR.
RAI 2.4.2-1 (Follow Up)
The response states that in-scope grating, decking and ladders are bulk commodities addressed in LRA Table 2.4-4. Since this is a generic statement, clarify if the specific components in question that were identified in the RAI (i.e. metal decking and grating of the intake structure enclosure and ladder of the service water valve pit) are included in-scope and subject to AMR as bulk-commodities addressed in LRA Table 2.4-4.
RAI 2.4.3-4 (Follow Up)
The response states 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, correct the typo in the line item crane rails and girders in LRA Table 2.4-3.
RAI 2.4.2-2 (a) LRA Table 2.2-3 and LRA Section 2.4.2 include Discharge Canal and Outfall Structure as being within the scope of license renewal. The description in LRA 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, explain why Outfall Structure is included in LRA Table 2.2-3 and LRA Section 2.4.2.
(b) Based on the description in LRA Section 2.4.2 with regard to the Discharge Canal, confirm/clarify if (i) the entire Discharge Canal is considered within the scope of license renewal and subject to AMR, or if (ii) only the portion adjacent to/supporting the service water pipe chase and the portion supporting and including the slab on which the Unit 3 service water backup pumps are mounted is within the scope of license renewal and subject to AMR.