ML081770331
| ML081770331 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/27/2008 |
| From: | Kimberly Green NRC/NRR/ADRO/DLR |
| To: | Entergy Nuclear Generation Co |
| Green, Kimberly NRR/DLR/RPB2 415-1627 | |
| References | |
| Download: ML081770331 (10) | |
Text
June 27, 2008 LICENSEE:
Entergy Nuclear Operations, Inc.
FACILITY:
Indian Point Nuclear Generating Unit Nos. 2 and 3
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 19, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATIONSUBMERGED CABLES The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations Inc. (Entergy) held a telephone conference call on May 19, 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
Enclosure:
As stated cc w/encl: See next page
ML081770331 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME SFigueroa KGreen RFranovich (AStuyvenberg for)
DATE 06/26/08 06/27/08 06/27/08
ENCLOSURE 1 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS MAY 19, 2008 PARTICIPANTS AFFILIATIONS Kim Green U.S. Nuclear Regulatory Commission (NRC)
Duc Nguyen NRC Raj Auluck NRC Roy Mathew NRC Mike Stroud Entergy Nuclear Operations, Inc. (Entergy)
Roger Rucker Entergy Alan Cox Entergy John Curry Entergy Charlie Caputo Entergy Herb Robinson Entergy
ENCLOSURE 2 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION INACCESSIBLE OR UNDERGROUND POWER CABLES MAY 19, 2008 D-RAI 3.6.2.3-1 In LRA Table 3.6.2-1, the applicant states that 138kV direct burial insulated transmission cables (passive electrical for SBO recovery) have no aging effects requiring management and indicates (by Note J) for material, environment, aging effect, and AMP that neither the component nor the material and environment combination is evaluated in 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 submerge 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 without providing any technical justifications.
Based on the 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 also have the same failure mechanisms if the underground cables are susceptible to moisture, water, and condensation environment or have manufacturing defects or damages 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. Therefore, in order to complete our review, the staff requires responses to the following additional information.
- 1. Explain 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 and water intrusion, water treeing, elevated operating temperature, voltage stress, galvanic corrosion, manufacturing defects, and potential damages caused by shipping and installation.
Discussion: Based on the discussion with the applicant, the staff agreed to revise this question to remove references to mechanisms that are not age-related. The revised question will be sent as a formal RAI.
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. Describe any testing that was performed on the cable during receipt and post-installation (include the type of testing that was performed on the cable). Describe the capabilities of the testing method performed on the cable. Describe the testing results, and state if the testing identified any problems. Describe if a current testing or maintenance program exists for this cable system.
Discussion: Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.
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 specification including procurement specification (include all applicable references) to support that the subject cable is comparable to submarine cable and/or 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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.
- 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).
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.
- 5. Describe 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.
Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.
- 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 and
check pothead bolt torque, oil testing performed or any indications or alarms provided in the control room to indicate the potential loss of oil. Explain how you manage the aging effect (loss of dielectric strength) during the period of extended operation.
Discussion: Based on the discussion with the applicant, the staff agreed to revise this question regarding checking pothead bolt torque since the activity is covered under normal preventive maintenance. The revised question will be sent as a formal RAI.
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 Operations, Inc. from K. Green dated June 27, 2008 DISTRIBUTION:
SUBJECT:
SUMMARY
OF TELEPHONE CONFERENCE CALL HELD ON MAY 19, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATIONSUBMERGED CABLES 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 JBoska NMcNamara, RI RAuluck DScrenci, RI OPA KChang NSheehan, RI OPA MKowal PCataldo, RI STurk, OGC CHott, RI LSubin, OGC DJackson, RI BMizuno, OGC BWelling, RI SBurnell, OPA ECobey, RI DMcIntyre, OPA MCox, RI TMensah, OEDO RConte, RI
Indian Point Nuclear Generating Unit Nos. 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 and 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. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236
Indian Point Nuclear Generating Unit Nos. 2 and 3 cc:
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