ML081260345

Summary of Telephone Conference Call Held on April 28, 2008, Between the U.S. NRC and Entergy Nuclear Operations, Inc., Concerning Responses to Request for Additional Information Related to the Indian Point Nuclear Generating Units 2 and 3,

ML081260345
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: ML081260345 (10)

Text

May 12, 2008 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON 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 APPLICATION -

OPERATING EXPERIENCE The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on April 28, 2008, to discuss and clarify the staffs draft request for additional information (D-RAI) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs D-RAI. provides a listing of the participants and Enclosure 2 contains a listing of the D-RAI items discussed with the applicant, including a brief description on the status 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:

As stated cc w/encls: See next page

ML081260345 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME YEdmonds KGreen RFranovich (BPham for)

DATE 05/8/08 05/9/08 05/12/08 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 28, 2008 PARTICIPANTS AFFILIATIONS Kim Green U.S. Nuclear Regulatory Commission (NRC)

Ken Chang NRC Jim Davis NRC On Yee NRC Raj Auluck NRC Rich Morante Brookhaven National Laboratory (BNL)

Ken Sullivan BNL Mano Subudhi BNL Mike Stroud Entergy Nuclear Operations, Inc. (Entergy)

Alan Cox Entergy Andy Taylor Entergy Charlie Caputo Entergy John Curry Entergy Enclosure 1

DRAFT REQUESTS FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION OPERATING EXPERIENCE April 28, 2008 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on April 28, 2008, to discuss and clarify the following draft requests for additional information (D-RAIs) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 license renewal application (LRA).

D-RAI RCS-1 Review of the condition report (CR) summaries 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 LRA Section 3.2 to 3.4.

Discussion: The applicant wanted to understand what the staff is requesting. It appears that the staff is questioning the corrective action program for which there are ongoing inspections that are performed by the Region. The staff stated that the question is parallel to a question on operating experience for structures that was asked during an audit, and that the goal is to show the effectiveness of the applicable aging management programs. Upon this clarification, the applicant stated that it will answer the staffs RAI. This D-RAI will be sent as a formal RAI.

Enclosure 2

D-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.

(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.

Discussion: The applicant stated that for part (i) of the question, the review of operating experience was not limited to a CR review, and that a description of the process would be provided. For part (ii) of the question, the applicant stated that the programs that are referenced are new programs, and therefore, the plant does not yet have operating experience. The staff asked the applicant if it had reviewed any industry operating experience, and that a description of what it had reviewed and identified as part of that review is what can be provided in its response. The applicant stated that the industry operating experience cited in NUREG-1801 for these programs may be referenced in its response. This D-RAI will be sent as a formal RAI.

D-RAI AUX-1 In reviewing plant basis documents and CR summaries related to operating experience applicable to non-Class 1 mechanical systems in the areas of Diesel Fuel Monitoring, Oil Analysis, Service Water Integrity, Water Chemistry Control Auxiliary Systems and Water Chemistry Control Closed Cooling Water Systems, the staff identified conditions of aging degradation in LRA Section 3.3 that are not described in detail in LRA or plant basis documents.

The areas of aging degradation identified by the staff were in the following areas: (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; (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 in LRA Sections 3.2 and 3.4, specifically addressed in this RAI.

Discussion: The applicant wanted clarification on the staffs request, particularly part (a). The applicant stated several CRs can comprise one aging degradation category as delineated in the staffs question, and that to provide a history on each CR for each type of degradation would be quite cumbersome. The staff clarified that a summary of the general history for each type of degradation would be sufficient, and that the goal is to show the effectiveness of the applicable aging management programs. Upon this clarification, the applicant stated that it will answer the staffs question. This D-RAI will be sent as a formal RAI.

D-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 have been or will be effective for managing aging during the period of extended operation.

Discussion: The applicant pointed out what appears to be a typo. The staff will fix the typo and the revised question will be sent as a formal RAI.

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 12, 2008 DISTRIBUTION:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON 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 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 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 Street 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