ML090920150
| ML090920150 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/03/2009 |
| From: | Kimberly Green License Renewal Projects Branch 2 |
| To: | Entergy Nuclear Operations |
| Green Kimbrly NRR/DLR/RPB2 415-1627 | |
| References | |
| Download: ML090920150 (9) | |
Text
April 3, 2009 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 - OPEN ITEMS
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. (Entergy), 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 completing its review of the application. The initial findings are documented in the Safety Evaluation Report with Open Items Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, issued in January 2009. Entergy has previously provided information for many of the open items which are identified in this report. In order for the staff to complete its review of the remaining open items, the staff requests additional information as described in the enclosure.
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 by 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
ML090920150 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME KGreen DWrona DATE 04/03/09 04/03/09 04/03/09
Letter to Entergy Nuclear Operations from K. Green, dated April 03, 2008 DISTRIBUTION:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - OPEN ITEMS HARD COPY:
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Indian Point Nuclear Generating Unit Nos. 2 and 3 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. Francis J. Murray President and CEO New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Ms. Alyce Peterson 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 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232
Indian Point Nuclear Generating Unit Nos. 2 and 3 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 Ms. Jessica Steinberg, J.D.
Sive, Paget & Riesel, P.C.
460 Park Avenue New York, NY 10022 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
ENCLOSURE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION - OPEN ITEMS Follow-up RAI 1: Open Item 3.0.3.2.15-1 (Audit Question 359)
In Entergy Nuclear Operations, Inc. (Entergy) letter NL-08-169, dated November 6, 2008, Additional Information Regarding License Renewal Application-Operating Experience Clarification, the applicant submitted a supplemental clarification describing its plan for implementing a permanent remediation of the Indian Point Nuclear Generating Unit No. 2 (IP2) refueling cavity leakage over the next three scheduled IP2 re-fueling outages (2010, 2012, 2014). In order to complete its review, the staff requests the following information:
- a.
In order for the staff to address the adequacy of the applicants proposed monitoring method, the applicant is requested to provide additional information on the leakage path from the refueling cavity to the collection point lower in containment, as well as the leak flow-rate. In this regard, describe the leakage path and chemical composition of the leaking fluid, provide historical flow-rate values, and confirm whether or not any leakage enters the reactor cavity inside the primary shield wall. Provide the technical basis as to how the leakage path was determined, with a focus on water entering the reactor cavity.
Provide a sketch of containment and the refueling cavity which highlights the leakage path.
- b.
The transmittal letter NL-08-169, dated November 6, 2008, states: There are no new commitments identified in this submittal. The applicant has previously taken a bore sample in the region of the leak, and has committed to take another sample prior to entering the period of extended operation. In absence of a formal commitment to remedy the source of leakage, the applicants aging management program (AMP) should include a method to monitor for a degrading condition in the refueling cavity, and other structures and components that would be affected by the leakage, during the period of extended operation, or the applicant should explain how the structures monitoring program will adequately manage potential aging of this region during the period of extended operation.
Follow-up RAI 2: Open Item 3.0.3.2.15-2 (Audit Question 360)
In Entergy letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental clarification for the IP2 spent fuel pool pit walls, which provides a detailed description of (1) the design margins for the spent fuel pool concrete walls; and (2) the results of prior concrete core sample testing and rebar corrosion testing.
- a.
In Commitment 25, the applicant commits to sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least every three months to assess for potential indications of spent fuel pool leakage. This commitment does not describe what actions will be taken if leakage continues. If sampling indicates continued leakage, the applicants AMP should include a method to determine if a degraded condition exists during the period of extended operation, or the applicant should explain how the Structures Monitoring Program will adequately manage potential aging of the inaccessible concrete of the IP2 spent fuel pool due to borated water leakage during the period of extended operation.
- b.
The second paragraph on page 2 of Attachment 1 of the clarification letter dated November 6, 2008, states in part: [l]ittle or no corrosion was observed in the rebar except at a location in the wall where spalling had occurred exposing rebar to the elements. Analysis of the rust particles showed high chloride content and low boron concentration indicating that rainwater was the primary cause of the observed corrosion. The staff requests the applicant to identify any Unit 2 and Unit 3 operating experience related to rebar corrosion, in light of the chloride content in rainwater, and identify the likely source for the high chloride content in the rainwater. Additionally, the applicant is requested to explain whether and how the AMP is adequate to address this environment and the related potential aging effects to ensure there is no loss of intended function during the period of extended operation.
Follow-up RAI 3: Open Item 3.0.3.3.2-1 (Audit Question 361)
In Entergy letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental clarification for Indian Point (IP) containment spalling, describing the design margins for the IP containment structures at the locations of existing concrete degradation. Based on its review of the information, the staff identified areas that need further clarification and/or additional information to complete its review as described below:
- a.
The clarification for the IP containment spalling states: As the surface concrete is not credited for tensile strength of the structure, the spalling has no impact on the available margins. The strength margins identified appear to be based on the nominal rebar dimensions, without any consideration for rebar degradation due to exposure and potential loss of bond between the concrete and the rebar. Explain how the existing degradation and design margin will be considered in performing periodic inspections to monitor degradation that would ensure that there is no loss of containment intended function during the period of extended operation.
- b.
In the spent fuel pool discussion, in the letter dated November 6, 2008, the applicant stated: [l]ittle or no corrosion was observed in the rebar except at a location in the wall where spalling had occurred exposing rebar to the elements. Analysis of the rust particles showed high chloride content and low boron concentration indicating that rainwater was the primary cause of the observed corrosion. The applicant is requested to provide the technical basis for the adequacy of the 5-year IWL frequency of inspection of the degraded areas of the IP containments during the period of extended operation, considering the possibility of an increased site-specific corrosion rate of the exposed rebar on the containments. This should include results of prior inspections, including any available comparative photos showing the progression of degradation.
Follow-up RAI 4: Open Item 3.5-1 In Entergy letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental clarification to license renewal application (LRA) Section 3.5.2.2 related to the concrete mix design method and the durability of concrete used at IP. In the LRA the applicant claimed that concrete meets the specifications of ACI 318-63 and the intent of ACI 201.2R-77, Guide to Durable Concrete. As a result the applicant claimed that several aging effects were not applicable to concrete. Based on its review of the information, the staff identified areas that need further clarification and/or additional information to determine that the applicant meets the cited ACI specifications such that further evaluation is not necessary as recommended by the GALL Report.
- a.
In the clarification to LRA Section 3.5.2.2 (Part 1) on page 6 of Attachment 1 to letter NL-08-169, the applicant stated that it used Method 2 of Section 502 of ACI 318-63 by testing trial mixes to determine the water-cement ratios for the concrete mix design of the IP containments and other structures. In order for the staff to evaluate the quality and durability of concrete in IP structures that may be subject to degradation during the period of extended operation, the staff requests the applicant to define the water-cement ratio that was used at the time of construction. Additionally, to assist the staff in understanding the parameters related to concrete strength and durability during the period of extended operation, the applicant is requested to describe the methodology used to establish the required concrete compressive strength of 3000 psi for the containment and other safety-related concrete structures, in accordance with ACI 318-63, Method 2. The applicant is requested to provide a summary of the results of statistical analyses performed, if any, of the original concrete strength tests, including number of samples, raw strength values from the test, the mean, the standard deviation, and the original criterion (e.g., mean minus 1 standard deviation, coefficient of variation) used to confirm that the required compressive strength was achieved. The applicant is requested to provide this information for the IP containments and other safety-related IP Unit 2 and 3 concrete structures, including the refueling cavities and the spent fuel pools, to support the applicants view that IP concrete meets the requirements of Method 2 in Section 502 of ACI 318-63 and the intent of ACI 201.2R-77.
- b.
If the applicant is unable to provide the information requested in part (a) above, the applicant is requested to explain how the aging effects on concrete will be adequately managed and safety margins will be determined during the period of extended operation.
Follow-up RAI 5: Open Item 3.5-2 In Entergy letter NL-08-169, dated November 6, 2008, Additional Information Regarding License Renewal Application-Operating Experience Clarification, the applicant submitted a supplemental clarification to LRA Section 3.5.2.2 (Part 3) for IP2 containment concrete and its ability to withstand local area temperatures up to 250ºF. The staff has identified areas that need further clarification and/or additional information as discussed below:
- a.
Clearly explain the role of the air-to-air heat exchangers in cooling the concrete around the hot piping penetrations. Include the normal operating temperature of the concrete as well as the maximum concrete temperature assuming failure of the heat exchangers.
- b.
In the clarification to LRA Section 3.5.2.2 (Part 3) on page 7 of Attachment 1 to letter NL-08-169, the applicant stated that a 15% reduction of concrete strength could be expected when reaching temperatures of 250ºF and that concrete compressive strength tests showed an actual strength more than 15% higher than design strength. Please provide the methodology used to arrive at the conclusion that the actual concrete strength is more than 15% greater than 3000 psi, (i.e., greater than 3450 psi). Provide a summary of the results, including number of samples, raw strength values from the test, the mean, the standard deviation, and the original criterion (e.g., mean minus 1 standard deviation) used to confirm that the claimed strength was achieved. Explain how consideration was given to the reduction in modulus of elasticity in the high temperature concrete evaluation.
- c.
If the applicant is unable to provide the information requested above, the applicant is requested to explain how the aging effects on concrete, due to high temperatures, will be adequately managed during the period of extended operation.