ML081480201
| ML081480201 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/28/2008 |
| From: | Kimberly Green NRC/NRR/ADRO/DLR |
| To: | Entergy Nuclear Operations |
| Green, Kimberly NRR/DLR/RLRB 415-1627 | |
| References | |
| Download: ML081480201 (7) | |
Text
May 28, 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 - INACCESSIBLE OR UNDERGROUND CABLES
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 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
OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR NAME KGreen SFigueroa RFranovich DATE 05/28/08 05/28/08 05/28/08
ENCLOSURE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION INACCESSIBLE OR UNDERGROUND POWER CABLES RAI 3.6.2.3-2 In LRA Table 3.6.2-1, the applicant states that 138kV direct burial insulated transmission cables (passive electrical for station blackout (SBO) recovery) have no aging effects requiring management and indicates (by Note J) for material, environment, aging effect, and aging management program (AMP) that neither the component nor the material and environment combination is evaluated in the GALL Report for meeting the components electrical intended function. The plant-specific Note 602 for this item in LRA Table 3.6.2-1 states that it is not subject to water treeing, since it is designed for continuously wet conditions. Industry and plant operating experience has not provided any information on failures of this type of cable. In addition, in response to the audit team's question concerning the qualification of this cable for continuous submerged condition, the applicant stated that the aging effects caused by moisture and voltage stress are not applicable to this cable because the lead sheath prevents moisture intrusion.
Based on an initial review of the licensee's responses to Generic Letter 2007-01, "Inaccessible or Underground Power Cable Failures that Disable Accident Mitigation Systems or Cause Plant Transients," the staff notes that several licensees have identified failures of XLPE cables in low and medium voltage applications. The high voltage cables could have the same failure mechanisms if the underground cables are susceptible to moisture, water, and condensation environment or have manufacturing defects or damage caused by shipping and installation, or exposure to electrical transients and abnormal operating conditions. The likelihood of failure from any of these causes increases over time as the cable insulation degrades.
10 CFR 54.21(a)(3) requires that components within the scope of license renewal and subject to an AMR must be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation. Therefore, the staff requests the applicant to provide technical justification of why an aging management program is not required to manage the potential loss of dielectric strength leading to reduced insulation resistance and electrical failure due to aging mechanisms such as moisture intrusion, water treeing, elevated operating temperature, voltage stress, and galvanic corrosion. In order to complete its review, the staff requires responses to the following requests for additional information.
- 1.
Explain why an AMP is not required to manage the potential loss of dielectric strength leading to reduced insulation resistance and electrical failure due to aging mechanisms such as moisture and water intrusion, water treeing, elevated operating temperature, voltage stress, and galvanic corrosion. The operating experience has shown that manufacturing defects, and damage caused by shipping and installation are contributing causes resulting in water treeing and insulation breakdown.
- 2.
State whether if any testing was performed on the cable during receipt and post-installation (include the type of testing that was performed on the cable). If so, describe the capabilities of the testing method performed on the cable, the testing results, and state if the testing identified any problems. State whether a current testing or maintenance program exists for this cable system, and if so, describe that program.
- 3.
Provide details of the original cable specifications including procurement specification (include all applicable references) to support that the subject cable is comparable to submarine cable and/or that the cable is supplied with a moisture barrier or water sealant swelling material applied under the lead sheath as specified in your letter dated October 11, 2007, in response to the LRA audit team's question. Also, describe in detail the differences between the subject cable and a submarine cable.
- 4.
Provide documentation showing that the cable can operate for the duration of the period of extended operation in submerged and wet conditions. If no periodic testing is proposed for this cable, explain how you plan to monitor the degradation of the cable or the condition of the conductor insulation (loss of dielectric strength) to preclude any potential cable failure such that the cable will perform its intended function for the period of extended operation as required by 10 CFR 54.21(a)(3).
- 5.
Describe the AEIC or other specification that is applicable to the IP2/IP3 lead sheath power cables that are designed to be installed in wet environments for extended periods.
Also, describe the conditions for which the cable was tested in accordance with specification AEIC CS7 with respect to operability in wet/submerged/humid conditions.
- 6.
Identify the material, environment, aging mechanism, and aging effect for the pot assembly (termination ends) for this cable. Identify details of periodic visual inspections and walkdowns performed to date or planned for the period of extended operation to monitor for oil leakage, oil testing performed or any indications or alarms provided in the control room to indicate the potential loss of oil. Explain how effects of aging will be managed during the period of extended operation.
Letter to Entergy Nuclear Operating from K.Green, dated May 28, 2008 DISTRIBUTION:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - INACCESSIBLE OR UNDERGROUND CABLES 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
Indian Point Nuclear Generating Units 2 and 3 cc:
Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 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 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 Street Peekskill, NY 10566 Ms. Susan Shapiro, Esq.
21 Perlman Drive Spring Valley, NY 10977 Mr. John Sipos Assistant Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 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 Ms. Joan Leary Matthews Senior Counsel for Special Projects Office of General Counsel NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-5500