ML12091A049
| ML12091A049 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/31/2012 |
| From: | Conte R Engineering Region 1 Branch 1 |
| To: | Joseph E Pollock Entergy Nuclear Operations, Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| Shared Package | |
| ML12091A044 | List: |
| References | |
| RAS 22176, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 IR-08-006 | |
| Download: ML12091A049 (43) | |
See also: IR 05000247/2008006
Text
NRC000107
Submitted: March 31, 2012
August 1, 2008
Mr. Joseph Pollock
Site Vice President
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
450 Broadway, GSB
P.O. Box 249
Buchanan, NY 10511-0249
SUBJECT: INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - NRC LICENSE
RENEWAL INSPECTION REPORT 05000247/2008006 & 05000286/2008006
Dear Mr. Pollock:
On February 14, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed the major
onsite portion of the Region I team inspection of your application for license renewal of your
Indian Point Nuclear Generating Unit Nos. 2 and 3, with additional followup inspections through
June 6, 2008. The enclosed report documents the results of the inspection, which were
discussed on June 18, 2008, with you, Fred Dacimo, and members of your staff in an exit
meeting open for public observation in Cortlandt Manor, NY.
The purpose of this inspection was to examine, on a sampling basis, the plant activities and
documents that support the application for a renewed license of the Indian Point Nuclear
Generating Unit Nos. 2 and 3. The inspection team reviewed the scoping of nonsafety-related
systems, structures, and components, as required in 10 CFR 54.4(a)(2). Further, the team
determined whether the proposed aging management programs are capable of reasonably
managing the effects of aging. These NRC inspection activities constitute one of several inputs
into the NRC review process for license renewal applications.
The team concluded that the scoping of nonsafety-related systems, structures, and components
was implemented as required in 10 CFR 54.4(a)(2). Further, the team concluded that the aging
management portion of the license renewal activities was conducted as described in the
License Renewal Application. The team concluded that the documentation supporting the
application was in an auditable and retrievable form. The team identified a number of areas that
resulted in changes to the application.
Overall, the inspection results support a conclusion of reasonable assurance that actions have
been identified and have been taken or will be taken to manage the effects of aging in the
systems, structures, and components identified in your application and that the intended
functions of these systems, structures, and components will be maintained in the period of
extended operation.
J. Pollock 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC=s document system
(ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos. 50-247 and 50-286
License Nos. DPR-26 and DPR-64
Enclosure: Inspection Report 05000247/2008006 and 05000286/2008006
J. Pollock 2
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC=s document system
(ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Docket Nos. 50-247 and 50-286
License Nos. DPR-26 and DPR-64
Enclosure: Inspection Report 05000247/2008006 and 05000286/2008006
SUNSI Review Complete: RJC (Reviewer=s Initials) ADAMS ACCESSION NO. ML082140149
DOCUMENT NAME: G:\DRS\Engineering Branch 1\Meyer\Indian Pt Insp Report\IP LR report FINAL -July 31-2008.doc
After declaring this document AAn Official Agency Record@ it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosu
"N" = No copy
OFFICE RI/DRS RI/DRS RI/DRP RI/DRS
NAME GWMeyer/cmm/RJC RJConte/RJC* MGray/MG* MKGamberoni/DJR
for* for
DATE 07/22/08 07/31/08 07/25/08 08/01/08
OFFICIAL RECORD COPY
- See Previous Concurrence Page
J. Pollock 3
cc w/encl:
Senior Vice President, Entergy Nuclear Operations
Vice President, Operations, Entergy Nuclear Operations
Vice President, Oversight, Entergy Nuclear Operations
Senior Manager, Nuclear Safety and Licensing, Entergy Nuclear Operations
Senior Vice President and COO, Entergy Nuclear Operations
Assistant General Counsel, Entergy Nuclear Operations
Manager, Licensing, Entergy Nuclear Operations
P. Tonko, President and CEO, New York State Energy Research and Development Authority
C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law
A. Donahue, Mayor, Village of Buchanan
J. G. Testa, Mayor, City of Peekskill
R. Albanese, Four County Coordinator
S. Lousteau, Treasury Department, Entergy Services, Inc.
Chairman, Standing Committee on Energy, NYS Assembly
Chairman, Standing Committee on Environmental Conservation, NYS Assembly
Chairman, Committee on Corporations, Authorities, and Commissions
M. Slobodien, Director, Emergency Planning
P. Eddy, NYS Department of Public Service
Assemblywoman Sandra Galef, NYS Assembly
T. Seckerson, County Clerk, Westchester County Board of Legislators
A. Spano, Westchester County Executive
R. Bondi, Putnam County Executive
C. Vanderhoef, Rockland County Executive
E. A. Diana, Orange County Executive
T. Judson, Central NY Citizens Awareness Network
M. Elie, Citizens Awareness Network
D. Lochbaum, Nuclear Safety Engineer, Union of Concerned Scientists
Public Citizen's Critical Mass Energy Project
M. Mariotte, Nuclear Information & Resources Service
F. Zalcman, Pace Law School, Energy Project
L. Puglisi, Supervisor, Town of Cortlandt
Congressman John Hall
Congresswoman Nita Lowey
Senator Hillary Rodham Clinton
Senator Charles Schumer
G. Shapiro, Senator Clinton's Staff
J. Riccio, Greenpeace
P. Musegaas, Riverkeeper, Inc.
M. Kaplowitz, Chairman of County Environment & Health Committee
A. Reynolds, Environmental Advocates
D. Katz, Executive Director, Citizens Awareness Network
K. Coplan, Pace Environmental Litigation Clinic
M. Jacobs, IPSEC
W. Little, Associate Attorney, NYSDEC
M. J. Greene, Clearwater, Inc.
R. Christman, Manager Training and Development
J. Spath, New York State Energy Research, SLO Designee
A. J. Kremer, New York Affordable Reliable Electricity Alliance (NY AREA)
J. Pollock 4
Distribution w/encl: (VIA E-MAIL)
S. Collins, RA
M. Dapas, DRA
S. Williams, RI OEDO
R. Nelson, NRR
M. Kowal, NRR
J. Hughey, NRR
M. Gray, DRP
B. Bickett, DRP
T. Wingfield, DRP
G. Malone, SRI - Indian Point 2
P. Cataldo, SRI - Indian Point 3
C. Hott, RI - Indian Point 2
T. Koonce, RI - Indian Point 3
Region I Docket Room (w/concurrences)
ROPreport Resources
M. Gamberoni, DRS
D. Roberts, DRS
R. Conte, DRS
G. Meyer, DRS
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos: 50-247, 50-286
Report Nos: 05000247/2008006 and 05000286/2008006
Licensee: Entergy Nuclear Operations, Inc (Entergy)
Facility: Indian Point Nuclear Generating Unit Nos. 2 and 3
Location: 450 Broadway, GSB
Buchanan, NY 10511-0249
Dates: January 28 - February 1, 2008
February 11 - 14, 2008
March 31 - April 2, 2008
June 2 - 6, 2008, and June 18, 2008
Inspectors: G. Meyer, Team Leader, Division of Reactor Safety (DRS)
M. Modes, Sr. Reactor Inspector, DRS
J. Richmond, Sr. Reactor Inspector, DRS
S. Chaudhary, Reactor Inspector, DRS
H. Jones, Reactor Inspector, DRS
B. Jose, Reactor Inspector, DRS, Region III
J. Lilliendahl, Reactor Inspector, DRS
D. Tifft, Reactor Inspector, DRS
H. Gray, Sr. Reactor Inspector, DRS
Accompanied by: B. Pham, NRR
Approved By: Richard J. Conte, Chief
Engineering Branch 1
Division of Reactor Safety
SUMMARY OF FINDINGS
05000247/2008006 and 05000286/2008006; January 28 - June 18, 2008; Indian Point
Nuclear Generating Unit Nos. 2 and 3; Scoping of Non-Safety Systems and the
Proposed Aging Management Programs for the Indian Point Application for Renewed
License.
This inspection of license renewal activities was performed by nine regional office
inspectors. The inspection was performed in accordance with NRC Manual Chapter 2516 and NRC Inspection Procedure 71002. This inspection did not identify any findings
as defined in NRC Manual Chapter 0612. The inspection team concluded scoping of
nonsafety-related systems, structures, and components was implemented as required in
10 CFR 54.4(a)(2). Further, the team concluded the aging management program
portions of the license renewal activities were conducted as described in the License
Renewal Application. The team concluded the documentation supporting the application
was in an auditable and retrievable form. The team identified a number of areas that
resulted in changes to the application.
Overall, the inspection results support a conclusion of reasonable assurance that actions
have been identified and have been taken or will be taken to manage the effects of aging
in the systems, structures, and components identified in your application and that the
intended functions of these systems, structures, and components will be maintained in
the period of extended operation.
ii
.
TABLE OF CONTENTS
Page
SUMMARY OF FINDINGS...ii
TABLE OF CONTENTS...iii
4. OTHER ACTIVITIES (OA).1
4OA2 Other - License Renewal1
a. Inspection Scope (IP 71002)...1
b.1 Scoping of Nonsafety-Related Systems, Structures,
and Components...1
b.2 Aging Management Programs.3
Containment Inservice Inspection Program...3
Fatigue Monitoring Program.4
Fire Protection Program4
Fire Water System Program.5
Nickel Alloy Inspection Program..5
One-Time Inspection Small Bore Piping Program6
Steam Generator Integrity Program7
Non-Environmentally Qualified Inaccessible Medium-Voltage
Cable Program...8
Environmental Qualification of Electric Components Program......8
Aboveground Steel Tanks Program9
Metal-Enclosed Bus Inspection Program...9
Non-EQ Bolted Cable Connections Program..10
Non-EQ Instrumentation Circuits Test Review Program...11
Non-EQ Insulated Cables and Connections Program...11
Buried Piping and Tanks Inspection Program.12
Service Water Integrity Program...13
Heat Exchanger Monitoring Program...13
Water Chemistry Control-Closed Cooling Water Program14
Diesel Fuel Monitoring Program15
Boric Acid Corrosion Prevention Program...16
External Surfaces Monitoring Program16
Flow-Accelerated Corrosion Program..17
Reactor Vessel Head Penetration Inspection Program.17
One-Time Inspection Program..18
Selective Leaching Program..18
Bolting Integrity Program19
Structural Monitoring Program..19
Masonry Wall Program...20
b.3 System Review.21
Auxiliary Feedwater System Review21
Unit 2 Station Blackout/Appendix-R Diesel Generator
(SBO/App-R DG) System Review...22
c. Overall Conclusions22
4OA6 Meetings, including Exit23
ATTACHMENT: SUPPLEMENTAL INFORMATION..A-1
iii
Report Details
4. OTHER ACTIVITIES (OA)
4OA2 Other - License Renewal
a. Inspection Scope (IP 71002)
This inspection was performed by NRC regional inspectors to evaluate the thoroughness
and accuracy of the scoping of nonsafety-related systems, structures, and components,
as required in 10 CFR 54.4(a)(2) and to evaluate whether aging management programs
will be capable of managing identified aging effects in an appropriate manner.
The inspectors selected a number of systems, components, and structures for review to
determine if the methodology applied by Entergy appropriately addressed the non-safety
systems affecting the safety functions of a system, structure, or component within the
scope of license renewal.
The inspectors selected a sample of aging management programs to verify the
adequacy of Entergy guidance, implementation activities, and documentation. The
selected aging management programs were reviewed to determine whether the
proposed aging management implementing processes would adequately manage the
effects of aging.
The inspectors reviewed supporting documentation and interviewed Entergy personnel
to confirm the accuracy of the license renewal application conclusions. For a sample of
plant systems and structures, the inspectors performed visual examinations of
accessible portions of the systems to observe aging effects.
b.1. Scoping of Nonsafety-Related Systems, Structures, and Components
For scoping, the inspectors reviewed Entergy program guidance procedures and
summaries of scoping results for Indian Point to assess the thoroughness and accuracy
of the methods used to bring systems, structures, and components within the scope of
license renewal into the application, including nonsafety-related systems, structures, and
components, as required in 10 CFR 54.4 (a)(2). The inspectors determined Entergy
procedures to be consistent with the NRC-accepted guidance in Sections 3, 4, and 5 of
Appendix F to NEI 95-10, Industry Guideline For Implementing The Requirements of
10 CFR Part 54 - The License Renewal Rule, Revision 6 (3: nonsafety-related systems,
structures, and components within scope of the current licensing basis, 4: nonsafety-
related systems, structures, and components directly connected to safety-related
systems, structures, and components, and 5: nonsafety-related systems, structures, and
components not directly connected to safety-related systems, structures, and
components).
The inspectors reviewed the set of license renewal drawings, which had been color-
coded to indicate systems and components in scope for 10 CFR 54.4 (a)(1), in order to
evaluate the effects of (a)(2) systems on the (a)(1) systems, structures, and
2
components. The inspectors interviewed personnel, reviewed license renewal program
documents, and independently inspected numerous areas within Units 1, 2, and 3 to
confirm that appropriate systems, structures, and components had been included within
the license renewal scope, that systems, structures, and components excluded from the
license renewal scope had an acceptable basis, and that the boundary for determining
license renewal scope within the systems, including seismic supports and anchors, was
appropriate.
The in-plant areas and systems reviewed included the following:
$ Units 1, 2 & 3 Turbine Buildings*
$ Unit 1 Nuclear Service Building*
$ Unit 1 Fuel Handling Building*
$ Unit 1 Chemical Systems Building*
$ Unit 2 Primary Auxiliary Building
$ Unit 2 Fuel Storage Building
$ Unit 2 Reactor Building
$ Unit 2 & 3 Control Buildings
$ Units 2 & 3 Intake Structures
$ Units 2 & 3 Security Generators
$ Units 2 & 3 Diesel Generator Rooms
$ Unit 3 Auxiliary Feedwater Pump Room
$ Unit 3 480 V Switchgear Room
$ Unit 3 Cable Spreading Room
$ Unit 2 Station Blackout Diesel Generator
$ Unit 3 Instrument Air System
$ Units 2 & 3 Service Water Systems
- The License Renewal Application (LRA) applies to Units 2 and 3; Unit 1 structures
and systems are addressed due to the potential effect on Units 2 and 3.
For systems, structures, and components selected regarding spatial interaction (failure
of nonsafety-related components adversely affecting adjacent safety-related
components), the inspectors determined that the in-plant configuration had been
accurately and acceptably categorized within the license renewal program documents.
The inspectors determined the personnel involved in the process were knowledgeable
and appropriately trained.
For systems, structures, and components selected regarding structural interaction
(seismic design of safety-related components dependent upon nonsafety-related
components), the inspectors determined that structural boundaries had been accurately
determined and categorized within the license renewal program documents. The
inspectors determined that Entergy had reviewed applicable isometric drawings to
determine the seismic design boundaries and had correctly included the applicable
components in the license renewal application, based on the inspectors= independent
review of a sample of the isometric drawings and the seismic boundary determinations.
3
In summary, the inspectors concluded that Entergy had implemented an acceptable
method of scoping of nonsafety-related systems, structures, and components and that
this method resulted in accurate scoping determinations.
b.2. Aging Management Programs
Containment Inservice Inspection Program
The Containment Inservice Inspection program is an existing program that manages the
aging affects on the containment, which is a reinforced concrete structure without post
tensioning. In the application, Entergy takes exception to NUREG 1801, Revision 1,
because containment seals and gaskets are in the Containment Leak Rate Program and
not in the Containment Inservice Inspection program. This conforms with the American
Society of Mechanical Engineers (ASME) Code applicable to Indian Point, which is an
edition later than that referenced in NUREG 1801, Revision 1.
The program specifies that all accessible surfaces receive a visual examination. The
procedure for visual containment inspection also requires that inaccessible areas
requiring inspection be separately identified. Painted surfaces are examined for
evidence of flaking, blistering, peeling, discoloration, and other signs of distress. Non-
coated areas are examined for evidence of cracking, discoloration, wear, pitting,
excessive corrosion, gouges, surface discontinuities, dents and other signs of surface
irregularities.
The inspectors reviewed the evaluation of concrete visual indications on the exterior of
the Unit 2 containment. Following an inspection during the March - June 2000 outage,
Entergy documented 22 indications of concrete pop-out, i.e., exposed rebar. The
exposed rebar and Cadweld had rusted, and in some cases rust stains had progressed
down the outside of containment. Entergy performed an analysis which compared the
indications against a structural analysis that divided containment into three zones of
importance, each indicating the amount of rebar margins that existed in each zone. The
analysis determined that no repairs were required and remediation would be ineffective
at arresting further aging effects. The NRC inspectors reviewed the analysis and did not
disagree with its determinations.
Entergys monitoring of the concrete pop-outs has consisted of periodic evaluation of
some pop-outs and making a qualitative determination of the amount of aging by
reviewing prior photographs of the pop-out. There were no measurements or
quantitative standards of acceptance applied. Without a method of consistent
measurement, the inspectors questioned the effectiveness of monitoring or trending.
Entergy agreed to correct this and issued CR-IP3-2008-00458 to establish baseline
measurements of the indications and compare them against future measurements.
During the spring 2008 outage, the NRC inspectors entered the Unit 2 containment and
reviewed some accessible areas of the containment liner to determine the visual
condition of the liner. The inspectors also visually inspected some accessible areas of
the liner-to-inside-sill seal and the areas previously ultrasonically thickness gauged.
4
For the Containment Inservice Inspection Program, the inspectors concluded that
Entergy had performed adequate evaluations, including reviews of industry experience
and plant history, to determine appropriate aging effects. Entergy provided adequate
guidance to ensure the aging effects are appropriately identified and addressed.
Fatigue Monitoring Program
The Fatigue Monitoring Program is an existing program that tracks the relevant
transients for selected reactor coolant system components. The components
considered include the reactor vessel, reactor vessel internals, pressurizer, steam
generators, and Class 1 piping and components. The program compares the transient
data with the analyzed fatigue transients in order to assure the actual effective number
of transients does not exceed the analyzed number of transients. The ratio of the
counted transients to the analyzed transients is the usage factor.
The inspectors noted the following site-specific program enhancements in IP-RPT-06-
LRD02, Section 4.2, Fatigue Monitoring:
Unit 2 Enhancements: Revise appropriate procedures to monitor steady state
cycles and feedwater cycles or perform an evaluation to determine monitoring is
not required. Review the number of allowed events and resolve discrepancies
between reference documents and monitoring procedures.
Unit 3 Enhancements: Revise appropriate procedures to include all the transients
identified. Assure all fatigue analysis transients are included with the lowest
limiting numbers. Update the number of design transients accumulated to date.
The inspectors reviewed the program elements and implementation. The inspectors
reviewed selected components and determined the adequacy of the process used to
maintain the transient count for the component.
For the Fatigue Monitoring Program, the inspectors concluded that Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance to
ensure the aging effects are appropriately identified and addressed.
The Fire Protection Program is an existing program modified for the purpose of aging
management and is credited with managing the aging effects in the fire barrier system
and the diesel-driven fire pumps. The aging effects are managed by periodic inspection
of fire barrier penetration seals, fire barrier walls, ceilings, and floors; and periodic
inspection and testing of fire rated doors. Aging effects are also managed by the
periodic inspection and testing of the diesel-driven fire pumps to ensure that the fuel
supply line can perform its intended function.
5
The inspectors reviewed the existing fire protection program and supporting documents
to verify the effectiveness of the program. The inspectors conducted interviews and
performed walkdown inspections of various fire barriers throughout the plant to evaluate
the effectiveness of the existing program. The inspectors also performed a walkdown
inspection of the diesel-driven fire pumps and accessible portions of the associated fuel
supply line. Surveillance procedures were reviewed for completeness and compliance
with applicable codes. Also, program enhancements were reviewed for adequacy and
completeness.
For the Fire Protection Program, the inspectors concluded that Entergy had performed
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. Entergy provided adequate guidance to ensure the
aging effects are appropriately identified and addressed.
Fire Water System Program
The Fire Water System Program is an existing program and is credited with managing
the aging effects in water-based fire protection systems. The aging effects are managed
by periodic testing and inspection of systems and components exposed to water,
including sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, and
above ground and underground piping and components.
The inspectors reviewed program basis documents and implementing procedures to
assess the effectiveness of the existing program. The inspectors reviewed the
implementing procedures and results of periodic flow testing. The inspectors also
conducted interviews and performed walkdown inspections of portions of the fire water
system to evaluate the effectiveness of the existing program. Program enhancements
were reviewed for adequacy and completeness.
For the Fire Water System Program, the inspectors concluded that Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance to
ensure the aging effects are appropriately identified and addressed.
Nickel Alloy Inspection Program
The Nickel Alloy Inspection Program is an existing program that manages aging effects
of alloy 600 components and alloy 82/182 welds in the reactor coolant system that are
not addressed by the Reactor Vessel Head Penetration Inspection Program or the
Steam Generator Integrity Program. The aging effect managed by this program, for
nickel alloys exposed to borated water at an elevated temperature, is primary water
stress corrosion cracking. The Nickel Alloy Inspection Program is a hybrid program
containing elements of the Inservice Inspection Program, the Boric Acid Corrosion
Control Program, and the Water Chemistry Control - Primary and Secondary Program.
Nickel alloy degradation also is currently the subject of NRC Orders, Bulletins and
Generic Letters and NRC-accepted industry guidelines, which form an integral part of
the program implementation at Indian Point.
6
The inspectors reviewed Entergys implementation of NRC Orders, Bulletins, and
Generic Letters that form the basis for the Nickel Alloy Inspection Program. Entergy
credits the Water Chemistry Control - Primary and Secondary Program for minimizing
the potential for primary water stress corrosion cracking in susceptible materials by
maintaining an environment that is less conducive to initiating primary water stress
corrosion cracking. The Nickel Alloy Inspection Program detects degradation by using
the examination and inspection requirements of ASME Section XI, augmented in
response to NRC Orders, Bulletins and Generic Letters, or by the use of NRC-accepted
industry guidelines. The Nickel Alloy Inspection Program detects cracking due to
primary water stress corrosion cracking prior to loss of intended function.
The inspectors reviewed the current Electric Power Research Institute (EPRI) Materials
Reliability Program being developed to manage and mitigate primary water stress
corrosion cracking of nickel based alloy components. The main goal of this program will
be to provide short and long term guidance for inspection, evaluation, and management
of nickel alloy material and weld metal locations in pressurized water reactor primary
systems. Guidance developed by the Materials Reliability Program will be used by
Entergy to identify critical locations for inspection and augment existing inservice
inspections. This program and the implementation of NRC Orders, Bulletins and
Generic Letters are the subject of a separate inspection by the NRC: Temporary
Instruction 2515/172, Reactor Coolant System Dissimilar Metal Butt Welds.
For the Nickel Alloy Inspection Program, the inspectors concluded that Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance to
ensure the aging effects are appropriately identified and addressed.
One-Time Inspection Small Bore Piping Program
The One-Time Inspection Small Bore Piping Program is a new program credited with
managing the aging effects of cracking in small bore ASME Code Class 1 piping less
than 4 inches nominal pipe size (NPS 4), which includes pipe, fittings, and branch
connections. The ASME Code does not require volumetric examination of Class 1 small
bore piping.
The program will include a sample selected based on susceptibility, ability to inspect,
dose considerations, operating experience, and limiting locations of the total population
of ASME Code Class 1 small bore piping locations. When evidence of an aging effect is
revealed by a one-time inspection, evaluation of the inspection results will identify
appropriate corrective actions. Entergy states in its application that the inspections will
be performed prior to the period of extended operation.
This new program will be implemented consistent with the corresponding program
described in NUREG-1801,Section XI.M35, One-Time Inspection of American Society
of Mechanical Engineers Code Class I Small-Bore Piping, which is based on industry
operating experience. The program will use EPRI Report 1000701, Interim Thermal
Fatigue Management Guideline (MRP-24), January 2001, to determine which piping
7
less than 4" nominal pipe size is susceptible to potential effects of thermal stratification
or turbulent penetration.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
programs implementation.
For the One-Time Inspection Small Bore Piping Program, the inspectors concluded that
Entergy had performed adequate evaluations, including reviews of industry experience
and plant history, to determine appropriate aging effects. In program-level documents,
Entergy provided adequate guidance to ensure the aging effects are appropriately
identified and addressed.
Steam Generator Integrity Program
The Steam Generator Integrity Program is an existing program and includes processes
for monitoring and maintaining secondary side component integrity, including steam
generator tubes. Steam generator tubes, in general, have experienced aging caused by
corrosion, including primary water stress corrosion cracking, outside diameter stress
corrosion cracking, intergranular attack, pitting, and wastage. Steam generator tubes
have also experienced mechanically-induced aging, such as denting, wear, impingement
damage, and fatigue. Nondestructive examination techniques, such as eddy current
testing, are used to identify tubes that are defective and need to be removed from
service or repaired.
The Steam Generator Integrity Program is implemented in accordance with NRC-
approved guidance in NEI 97-06, Steam Generator Program Guidelines, and is
monitored by the NRC during every outage of each unit, using Inspection Procedure 71111.08, ISI Inspection. The inspectors had previously reviewed the eddy current
evaluations of tubes, the criteria used to determine if plugging was required, and
assessed the effectiveness of measures to mitigate degradation. The inspectors have
reviewed implementation regarding leakage monitoring, tube inspection scope and
frequency, plugging and repair criteria, and steam generator degradation management.
The inspectors reviewed the most recent Condition Monitoring and Operational
Assessment Reports for each unit to ascertain the current state of the generators. The
inspectors noted Unit 2 generators were replaced in December of 2000 with a W Model
44F Westinghouse design and the unit was uprated in November 2004. The inspectors
also noted the original Unit 3 generators were replaced in 1989 and underwent an uprate
in April of 2005.
For the Steam Generator Integrity Program, the inspectors concluded that Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance to
ensure the aging effects are appropriately identified and addressed.
8
Non-Environmentally Qualified Inaccessible Medium-Voltage Cable Program
The Non-Environmentally Qualified (non-EQ) Inaccessible Medium-Voltage Cable
Program is a new program that Entergy will implement prior to the period of extended
operation. The program will be comparable to that described in NUREG-1801, Section
XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49
Environmental Qualification Requirements. This program applies to inaccessible (e.g.,
in conduit or direct-buried) medium-voltage cables within the scope of license renewal
that are exposed to significant moisture simultaneously with applied voltage. This
program includes a commitment to test these cables at least once every 10 years to
provide an indication of the condition of the conductor insulation. The specific type of
test performed will be determined and implemented prior to the expiration of the current
license. The program also includes inspections for water accumulation in manholes at
least once every two years.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. The inspectors reviewed program documentation,
condition reports, aging management review documents, and existing procedures, and
confirmed that Entergy had a commitment in place to enhance the program prior to the
period of extended operation. The inspectors also interviewed the engineer responsible
for the non-EQ inaccessible medium-voltage cable program regarding implementation of
particular test procedures to be developed under the program. The inspectors verified
that Entergy had performed adequate historical reviews of plant specific and industry
experience to determine aging effects.
Due to work control and planning constraints, Entergy was unable to open a manhole for
inspection during the inspection period. On June 2, 2008, the inspectors returned and
observed a scheduled quarterly preventive maintenance (PM) activity to open and
inspect Unit 3 manhole 36. The inspectors observed standing water with several cable
splices submerged. There were two 6.9 kV cables in the manhole, both associated with
the station blackout/fire protection diesel generator. Entergy pumped the water out of
the manhole, and assessed the condition of the cable jackets and splices as acceptable.
In addition, the inspectors reviewed the results of previous quarterly PMs, and noted that
water was typically found at a depth sufficient to submerge at least the lower cable
splices. These inspection results regarding manhole environmental conditions are under
evaluation by the NRC Office of Nuclear Reactor Regulation (NRR).
For the Non-EQ Inaccessible Medium-Voltage Cable Program, the inspectors concluded
that Entergy had performed adequate evaluations, including reviews of industry
experience and plant history, to determine appropriate aging effects. In program-level
documents, Entergy provided adequate guidance to ensure the aging effects are
appropriately identified and addressed.
Environmental Qualification of Electric Components Program
The Environmental Qualification of Electric Components Program is an existing program,
which is based on the program described in NUREG-1801,Section X.E1,
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Environmental Qualification (EQ) of Electric Components. This program manages
component thermal, radiation, and cyclical aging through the use of aging evaluations
based on 10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ
components not qualified for the current license term are to be refurbished or replaced,
or have their qualification extended prior to reaching the aging limits established in the
evaluation. Aging evaluations for EQ components that specify a qualification of at least
40 years are considered time-limited aging analyses for license renewal.
The inspectors reviewed program documentation, condition reports, aging management
review documents and existing procedures to evaluate the capability of the program to
manage aging effects of EQ electric components. The inspectors also interviewed the
engineer responsible for the EQ program, and reviewed internal and external
assessments of the EQ program. The inspectors verified that Entergy had performed
adequate historical reviews of plant specific and industry experience to determine aging
effects.
For the Environmental Qualification of Electric Components Program, the inspectors
concluded Entergy had performed adequate evaluations, including reviews of industry
experience and plant history, to determine appropriate aging effects. Entergy provided
adequate guidance to ensure aging effects will be appropriately identified and
addressed.
Aboveground Steel Tanks Program
The Aboveground Steel Tanks Program is an existing program credited with managing
the loss of material from external surfaces of aboveground carbon steel tanks. The
aging effects are managed by periodic visual inspections of external surfaces and
thickness measurements of locations that are inaccessible for external visual inspection.
The inspectors reviewed program basis documents, plant procedures, and recent
aboveground tank inspection results, and interviewed personnel. The inspectors also
performed walkdown inspections of the Unit 2 and 3 condensate storage tanks, Unit 2
diesel fire pump water storage tank, and Unit 3 fire water storage tanks.
For the Aboveground Steel Tanks Program, the inspectors concluded Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance to
ensure aging effects will be appropriately identified and addressed.
Metal-Enclosed Bus Inspection Program
The Metal-Enclosed Bus Inspection Program is an existing program credited with
managing the aging effects on non-segregated phase bus. The aging effects are
managed by visually inspecting the enclosure assemblies and interior portions of the bus
for structural integrity, signs of cracking, corrosion, water intrusion, excessive dust
buildup, or foreign debris.
10
The inspectors reviewed drawings, reviewed completed maintenance documents, and
performed walkdown inspections to evaluate the capability of the program to manage
aging effects. The inspectors also had discussions with plant personnel regarding the
program and the current conditions of the non-segregated bus.
The inspectors questioned the completeness of acceptance criteria for the internal
inspection portion of the program. Entergy stated that the inspection procedures would
be revised to include more complete acceptance criteria and the License Renewal
Application (LRA) would be amended. The LRA was subsequently amended in LRA
Amendment 3 dated March 24, 2008.
The inspectors also noted that the program operating experience review did not identify
a 2004 example in which a bus connection was found less than hand tight and declared
inoperable. Entergy agreed to revise the operating experience review report to include
this example.
For the Metal Enclosed Bus Inspection Program, the inspectors concluded that Entergy
had performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance, as
amended, to ensure aging effects are appropriately identified and addressed.
Non-EQ Bolted Cable Connections Program
The Non-EQ Bolted Cable Connections Program is a new program credited with
managing the aging effects in bolted cable connections. The purpose of the program is
to inspect bolted cable connections for loosening of the connections due to thermal
cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion,
or oxidation. The aging effects are managed by a one-time inspection of a
representative sample of in-scope connections.
The inspectors reviewed program documents, and had discussions with plant personnel
to assess the proposed program and its capability to manage aging effects. The
inspectors noted that the existing program document allowed visual inspection of the
connections, an approach which is not endorsed in the draft interim staff guidance, LR-
ISG-2007-02 (Changes to Generic Aging Lesson Learned Report Aging Management
Program XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49
Environmental Qualification Requirements). Entergy stated that the inspection method
would be revised to comply with the final interim staff guidance, when issued, and the
LRA would be amended. The LRA was subsequently amended in LRA Amendment 3
dated March 24, 2008.
For the Non-EQ Insulated Cables and Connections Program, the inspectors concluded
that Entergy performed adequate evaluations, including reviews of industry experience
and plant history, to determine appropriate aging effects. In program-level documents,
Entergy provided adequate guidance, as amended, to ensure aging effects are
appropriately identified and addressed.
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Non-EQ Instrumentation Circuits Test Review Program
The Non-EQ Instrumentation Circuits Test Review Program is a new program credited
with managing the aging effects in instrument cables exposed to adverse localized
equipment environments. The aging effects are managed by a periodic review of
instrumentation circuit calibration or surveillance results for in-scope components. Also,
cable testing on in-scope cables will be performed for cables that are disconnected
during the associated instrument calibration.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. However, the inspectors interviewed plant personnel,
reviewed completed calibration results, and reviewed program documentation to assess
the capability of the proposed program to manage aging effects.
For the Non-EQ Instrumentation Circuits Test Review Program, the inspectors
concluded that Entergy had performed adequate evaluations, including reviews of
industry experience and plant history, to determine appropriate aging effects. In
program-level documents, Entergy provided adequate guidance to ensure aging effects
are appropriately identified and addressed.
Non-EQ Insulated Cables and Connections Program
The Non-EQ Insulated Cables and Connections Program is a new program credited with
managing the aging effects in insulated cables and connections exposed to adverse
localized environments caused by heat, radiation, and moisture. The aging effects are
managed by periodic visual inspections of a representative sample of in-scope cables
and connections for jacket surface anomalies.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. The inspectors performed walkdown inspections, and
had discussions with plant personnel to assess the proposed program and its capability
to manage aging effects. The inspectors reviewed EPRI TR-109619, Guideline for the
Management of Adverse Localized Equipment Environments, the guidance document
that will be used to develop the program procedures. The inspectors noted that the
aging management review for electrical cables did not include the transite (fibrous
cement board) material used between cable trays for cable separation purposes.
Entergy agreed to revise the aging management review to address transite.
For the Non-EQ Insulated Cables and Connections Program, the inspectors concluded
that Entergy had performed adequate evaluations, including reviews of industry
experience and plant history, to determine appropriate aging effects. In program-level
documents, Entergy provided adequate guidance to ensure aging effects are
appropriately identified and addressed.
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Buried Piping and Tanks Inspection Program
The Buried Piping and Tanks Inspection Program is a new program credited with
managing the effects of external corrosion on the pressure-retaining capability of buried
carbon steel, gray cast iron, and stainless steel piping components and tanks in a soil
environment. The aging effects will be managed by preventive measures (i.e., coatings
and wrappings) to mitigate corrosion and by visual inspections during planned
excavations. The program will be implemented by performing at least one inspection
within the 10 year period prior to the period of extended operation, either during an
excavation for other purposes or during an excavation planned for this inspection. An
additional inspection will also be performed during the first 10 years of extended
operation. The program will provide inspection and acceptance criteria, and will require
evaluation of the inspection results. Inspections will be performed in accordance with
approved station procedures.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. The inspectors reviewed the program basis document,
including proposed scope, parameters to be monitored, method of monitoring, and
acceptance criteria, and system drawings, and interviewed the responsible plant
personnel regarding these documents and inspection criteria to be used. In addition, the
inspectors reviewed EN-DC-343, Entergy Buried Piping and Tanks Inspection and
Monitoring Program, which was an existing Entergy corporate level program not yet
approved for implementation at Indian Point. The inspectors also performed field
walkdown inspections of portions of the service water, auxiliary feedwater, and diesel
fuel oil systems in the vicinity of buried piping to independently assess the material
conditions and identify inconsistencies between the as-built plant configuration, and the
aging management evaluations and programs.
Entergy reviewed condition reports written in the last 5 years to identify whether any in-
scope buried piping component or tank inspections had been performed during
excavations performed for other reasons. The review did not identify any issues (i.e.,
surface corrosion, damaged coating) associated with in-scope buried components.
Entergy did identify several recent instances where buried piping had been excavated to
perform internal piping inspections, or to fix through-wall leaks due to internal corrosion.
In those instances, no formal inspection had been performed or documented, but
engineering and maintenance personnel involved with the excavations stated that the
external pipe coatings appeared to be in good condition. Therefore, Entergy concluded
there had been no significant degradation or failures of the existing protective coatings
on buried piping or tanks.
For the Buried Piping and Tanks Inspection Program, the inspectors concluded Entergy
had performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. In program-level documents, Entergy
provided adequate guidance to ensure the aging effects are appropriately identified and
addressed.
13
Service Water Integrity Program
The Service Water Integrity Program is an existing program credited with managing the
maintenance of internal protective coatings and piping, as well as the prevention of
excessive macro-fouling and biofouling, associated with the open cycle service water
system. The aging effects of material loss (corrosion) and fouling are managed by a
condition and performance monitoring program (e.g., visual inspections and/or non-
destructive examinations), and control techniques (e.g., chemical treatment), as
recommended by NRC Generic Letter 89-13. The program includes piping and
components in the service water system, emergency diesel generator system,
component cooling water system, containment cooling and filtration systems, various in-
scope nonsafety-related systems (i.e., instrument air), and the main control room
heating, ventilation and air conditioning system.
The inspectors reviewed the existing program, associated procedures, trending reports,
heat exchanger inspection records, eddy current examination results and trending
reports, heat exchanger tube plugging trends, buried piping internal inspection records,
intake structure inspection records, service water piping through-wall leakage logs, and
service water system health reports to evaluate the effectiveness of the existing
program. The inspectors interviewed the service water system engineer and the
engineer responsible for the service water program, and performed field walkdown
inspections to independently assess the material condition of the service water system,
and identify inconsistencies between the as-built plant configuration and the aging
management evaluations and programs.
The inspectors identified baffle racks in the Unit 3 intake structure, located immediately
below the service water pump suctions, which had not been included in Entergy's aging
management reviews. Entergy determined these components should have been within
the scope of license renewal and committed to perform an aging management review,
as required. Entergy preliminarily concluded these components would be managed by
the Structures Monitoring Program and stated that the LRA would be amended. The
LRA was subsequently amended in LRA Amendment 3 dated March 24, 2008.
For the Service Water Integrity Program, the inspectors concluded Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance, as
amended, to ensure aging effects are appropriately identified and addressed.
Heat Exchanger Monitoring Program
The Heat Exchanger Monitoring Program is an existing program, which will be enhanced
to manage the aging effects of material loss (corrosion) for heat exchanger tubes, for
those heat exchangers within the scope of license renewal that are not covered by other
existing periodic monitoring programs. The aging effects will be managed by periodic
visual inspections and non-destructive examinations. The enhancements will add
additional heat exchangers, within the scope of license renewal, to the existing program
and revise program procedures to (1) perform visual inspections when non-destructive
examinations cannot be performed, (2) consider material environment combinations
14
when determining sample selections, and (3) specify acceptance criteria for visual
inspections and minimum tube wall thickness.
The inspectors reviewed the existing program, heat exchanger inspection records, eddy
current examination results and trending reports, and heat exchanger tube plugging
trends to determine the effectiveness of the existing program. The inspectors
interviewed the heat exchanger program engineer and selected maintenance personnel,
performed field walkdown inspections, and observed portions of an on-going instrument
air closed cooling water heat exchanger inspection to independently assess the material
condition of selected heat exchangers, and identify inconsistencies between the as-built
plant configuration and the aging management evaluations and programs.
The inspectors identified that the Unit 2 instrument air closed cooling water heat
exchangers were included in an aging management review, but had been omitted from
an implementing procedure with heat exchangers to be added into the heat exchanger
monitoring program. Entergy agreed to add these heat exchangers to the program
implementing procedures, which already included the similar heat exchangers from
Unit 3.
For the Heat Exchanger Monitoring Program, the inspectors concluded Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance, as
revised, to ensure the aging effects are appropriately identified and addressed.
Water Chemistry Control - Closed Cooling Water Program
The Water Chemistry Control - Closed Cooling Water Program is an existing program,
which will be enhanced to manage the aging effects of material loss (corrosion),
cracking, and fouling for piping components and heat exchangers in closed cooling
water systems. The aging effects are managed by monitoring and controlling water
chemistry to minimize contaminant concentration and mitigate loss of material. The
enhancements will add additional closed cooling water systems into the existing water
chemistry program and revise the program procedures to monitor the appropriate
chemistry parameters. The added systems include the Unit 2 station blackout diesel,
and the Unit 2 and Unit 3 security generators.
The inspectors reviewed the existing water chemistry program and the associated
chemistry procedures, and interviewed water chemistry specialists to evaluate the
effectiveness of the existing program. In addition, the inspectors performed field
walkdown inspections and observed portions of an on-going instrument air closed
cooling water heat exchanger inspection to independently assess the material condition
of selected closed cooling water systems, and identify inconsistencies between the as-
built plant configuration and the aging management evaluations and programs.
The inspectors identified that (1) neither the existing procedures nor the specified
enhancements included monitoring glycol within specified limits for the Unit 2 and Unit 3
security generators, and (2) the Unit 2 and Unit 3 fire protection diesels had not been
included in the closed cooling water systems to be added to the existing program.
15
Entergy stated that the proposed enhancements would be revised to include these items
and the LRA would be amended. The LRA was subsequently amended in LRA
Amendment 3 dated March 24, 2008.
The inspectors identified that the reactor coolant pump motor lube oil coolers (i.e., heat
exchangers) had been incorrectly identified as short-lived components and screened out
of license renewal scope without an aging management review. Entergy committed to
perform an aging management review for these components. Entergy preliminarily
concluded these components would be managed by the Water Chemistry Control -
Closed Cooling Water Program and the Oil Analysis Program. This change was
subsequently addressed in Entergys response to NRC request for additional information
(RAI) 2.3.0-2 dated March 24, 2008.
For the Water Chemistry Control - Closed Cooling Water Program, the inspectors
concluded Entergy had performed adequate evaluations, including reviews of industry
experience and plant history, to determine appropriate aging effects. Entergy provided
adequate guidance, as amended, to ensure the aging effects will be appropriately
identified and addressed.
Diesel Fuel Monitoring Program
The Diesel Fuel Monitoring Program is an existing program, which will be enhanced to
manage the aging affects of material loss (corrosion) and fouling in fuel oil systems. The
aging effects are managed by a combination of periodic chemistry sampling and
analysis, and periodic fuel oil tank cleaning and inspection. The enhancements will
(1) add selected systems within the scope of license renewal that were not previously
included in the existing monitoring program, (2) add periodic cleaning and inspection of
fuel oil tanks, including thickness measurements of tank bottoms, and (3) revise fuel oil
chemistry sampling frequency, sample location, and monitored parameters, in
accordance with appropriate industry standards.
The inspectors reviewed the existing fuel oil monitoring program, associated chemistry
procedures, and recent fuel oil analysis results to evaluate the effectiveness of the
existing program. The inspectors reviewed tank inspection records to verify the results
were within the acceptable range. In addition, the inspectors interviewed engineering
and chemistry personnel, and performed field walkdown inspections of the diesel fuel oil
storage tanks, emergency diesel generators, station blackout diesels, and the
emergency fuel oil transfer trailer to independently assess the material condition of the
fuel oil systems and identify inconsistencies between the as-built plant configuration, and
the aging management evaluations and programs.
The inspectors identified that the Unit 2 security diesel fuel oil storage tank was not
included in the program enhancement to perform fuel oil chemistry sampling. Entergy
stated that the proposed enhancements would be revised to include this item and the
LRA would be amended. The LRA was subsequently amended in LRA Amendment 3
dated March 24, 2008.
16
The inspectors identified that the existing procedure for fuel oil transfer using the
emergency fuel oil transfer trailer did not specify a chemistry oil sample be taken at the
tank bottom, and did not provide specific acceptance criteria as to when tank flushing
would be required. Entergy stated that the transfer trailer procedure would be revised to
sample and flush in accordance with the existing requirements for fuel oil receipt
inspections and the LRA would be amended. The LRA was subsequently amended in
LRA Amendment 3 dated March 24, 2008.
The inspectors identified that for the Unit 3 emergency diesel fuel oil storage tanks, the
existing procedure for tank bottom verification relied on techniques which would not be
capable of determining bottom thickness, and did not specify appropriate acceptance
criteria. Entergy stated that the existing procedure would be revised to specify wall
thickness measurement using appropriate techniques and include appropriate
acceptance criteria, and the LRA would be amended. The LRA was subsequently
amended in LRA Amendment 3 dated March 24, 2008.
For the Diesel Fuel Monitoring Program, the inspectors concluded Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine appropriate aging effects. Entergy provided adequate guidance, as
amended, to ensure the aging effects will be appropriately identified and addressed.
Boric Acid Corrosion Prevention Program
The Boric Acid Corrosion Prevention Program is an existing program credited with
managing the aging effects of structures and components that are susceptible to boric
acid corrosion. The aging effects are managed by performing periodic visual inspections
of systems containing borated water and adjacent structures, components, and supports
for leakage, and implementing appropriate corrective actions.
The inspectors reviewed relevant license renewal program documents, implementing
procedures, the boric acid leakage database, and corrective action program documents,
and interviewed the boric acid coordinator. Additionally, the inspectors performed a
walkdown inspection of the Unit 2 and Unit 3 safety injection pump rooms and
containment spray pump rooms.
For the Boric Acid Corrosion Prevention Program, the inspectors concluded that Entergy
had performed adequate evaluations, including reviews of industry experience and plant
history, to determine the appropriate aging effects. Entergy provided adequate guidance
to ensure aging effects are appropriately identified and addressed.
External Surfaces Monitoring Program
The External Surfaces Monitoring Program is an existing program that will be enhanced
for the purpose of aging management. The aging effects are managed by performing
periodic visual inspections by system engineers of components subject to aging
management. The program is also credited with managing loss of material from internal
17
surfaces for situations in which internal and external material and environment
combinations are the same, such that external surface condition is representative of
internal surface condition.
The inspectors reviewed relevant license renewal program documents, implementing
procedures, system walkdown reports, and condition reports, and performed a walkdown
inspection of the Unit 2 and Unit 3 safety injection pump rooms and residual heat
removal pump rooms with the system engineer.
For the External Surfaces Monitoring Program, the inspectors concluded that Entergy
had performed adequate evaluations, including reviews of industry experience and plant
history, to determine the appropriate aging effects. Entergy provided adequate guidance
to ensure aging effects are appropriately identified and addressed.
Flow-Accelerated Corrosion Program
The Flow-Accelerated Corrosion Program is an existing program credited with managing
the corrosion aging effects in all carbon steel and low alloy steel components in systems
containing high-energy fluids carrying two-phase or single-phase high energy fluid
greater than 2% of plant operating time. The aging effects are managed by performing
non-destructive examinations (e.g., ultrasonic testing) to detect wall thinning and by
predicting wear rates to support the proactive replacement of system piping. In addition,
the program provides for the performance of follow-up inspections to confirm predictions
and to determine the need for repairs or replacements, as necessary.
The inspectors reviewed relevant license renewal program documents, implementing
procedures, calculations, past flow-accelerated corrosion reports, and condition reports
generated during previous inspections. In addition, with the engineer responsible for the
flow-accelerated corrosion program, the inspectors performed a walkdown inspection of
past inspection points and scheduled inspection points to confirm the configuration
matched the plant drawings.
For the Flow-Accelerated Corrosion Program, the inspectors concluded that Entergy had
performed adequate evaluations, including reviews of industry experience and plant
history, to determine the appropriate aging effects. Entergy provided adequate guidance
to ensure aging effects are appropriately identified and addressed.
Reactor Vessel Head Penetration Inspection Program
The Reactor Vessel Head Penetration Inspection Program is an existing program
credited with managing the aging effect of primary water stress corrosion cracking
(PWSCC) of nickel-based alloy reactor vessel head penetrations exposed to borated
water. Entergy developed this program in response to NRC Order EA-03-009. The
aging effects are managed by performing bare metal visual examinations of the external
surfaces of the reactor vessel head and non-visual examinations on the underside of the
head.
18
The inspectors reviewed relevant license renewal program documents, implementing
procedures, calculations of effective degradation years, videos of past reactor vessel
head inspections, and reports documenting the results of past reactor vessel head
inspections. The inspectors also reviewed Entergys written responses to NRC Bulletins
and NRC Order EA-03-009, and interviewed the assistant outage manager regarding the
reactor vessel head penetration program.
For the Reactor Vessel Head Penetration Inspection Program, the inspectors concluded
that Entergy had performed adequate evaluations, including reviews of industry
experience and plant history, to determine the appropriate aging effects. Entergy
provided adequate guidance to ensure aging effects are appropriately identified and
addressed.
One-Time Inspection Program
The One-Time Inspection Program is a new aging management program intended to
verify the effectiveness of other aging management programs, including Water
Chemistry, Oil Analysis, and Diesel Fuel Monitoring Programs, by reviewing various
aging effects for impact. Where corrosion resistant materials and/or non-corrosive
environments exist, the One-Time Inspection Program is intended to verify that an aging
management program is not needed during extended operations by confirming that
aging effects are not occurring or are occurring in a manner that does not affect the
safety function of systems, structures, and components. These verifications will be
accomplished by non-destructive evaluation performed by qualified personnel using
procedures and processes consistent with the ASME Boiler and Pressure Vessel Code
and 10 CFR 50, Appendix B. The One-Time Inspection Program will be implemented
prior to the period of extended operation.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. The inspectors reviewed the program description and
implementing procedures, and discussed the planned activities with the responsible
staff.
For the One-Time Inspection Program, the inspectors concluded Entergy had performed
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. In program-level documents, Entergy provided
adequate guidance to ensure aging effects are appropriately identified and addressed.
Selective Leaching Program
The Selective Leaching Program is a new program that is credited with managing the
aging of components made of cast iron, bronze, brass, and other alloys exposed to raw
water, treated water, soil or other environments that may lead to selective leaching of
material constituents. The program will include a one-time visual inspection and
hardness measurement of selected components that may be susceptible to selective
leaching to determine whether loss of material due to selective leaching is occurring, and
whether the process will affect the ability of the components to perform their intended
19
function for the period of extended operation. The Selective Leaching Program will be
implemented prior to the period of extended operation.
At the time of the inspection, Entergy had not completed many of the actions identified in
the program. Therefore, the inspectors were unable to assess the effectiveness of the
implementation of this program. The inspectors reviewed the program description and a
listing of components covered by the program, and discussed the planned activities with
the responsible staff. Also, the inspectors reviewed condition reports for some
applicable components and visually examined the condition of these components.
The inspectors noted that the program description specified a selected set of
components to be inspected but provided no details as to how the set would be
determined. Subsequently, Entergy stated that the program description would be
revised to base the sample selection on a 90% confidence that 90% of the component
population has not experienced degradation, and the LRA would be amended. The LRA
was subsequently amended in LRA Amendment 3 dated March 24, 2008.
For the Selective Leaching Program, the inspectors concluded Entergy had performed
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. In program-level documents, Entergy provided
adequate guidance, as amended, to ensure aging effects are appropriately identified and
addressed.
Bolting Integrity Program
The Bolting Integrity Program is an existing program which applies to the bolting and
torquing practices for bolting on pressure retaining components, component supports,
and structural joints. The program includes periodic inspections for signs of leakage due
to cracking, loss of material, and loss of preload. The program has preventive measures
to preclude or minimize loss of preload and cracking.
The inspectors reviewed program basis documents and plant procedures, and
interviewed applicable personnel. The inspectors also performed walkdown inspections
of various systems to evaluate the effectiveness of the existing program.
For the Bolting Integrity Program, the inspectors concluded Entergy had performed
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. Entergy provided adequate guidance to ensure
aging effects are appropriately identified and addressed.
Structural Monitoring Program
The Structural Monitoring Program is an existing program that will be enhanced for the
purpose of aging management of structures and structural components. The program
had been developed based on guidance in Regulatory Guide 1.160 Revision 2,
Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and NUMARC 93-01 Revision 2, Industry Guidelines for Monitoring the Effectiveness of Maintenance
at Nuclear Power Plants, to satisfy the requirements of the Maintenance Rule. The
20
scope of the program also includes condition monitoring of masonry walls and water-
control structures. The program enhancements will expand the program to include
additional structures and components (such as diesel generator foundations, fire
pumphouses, water and oil storage tanks, manholes and duct banks, cable trays and
supports, cranes, crane rails, gaskets, seismic joint filler, and roof elastomers) that are
not monitored under the existing program but require monitoring during the period of
extended operations. Also, guidance will be added to the program to perform an
engineering evaluation of groundwater samples to assess the aggressiveness of
groundwater to concrete on a periodic basis (at least once every five years).
Aging effects are managed by periodic visual inspections by qualified personnel to
monitor structures and components for applicable aging effects. Specifically, concrete
structures are inspected for loss of material, cracking, and changes in material
properties. Steel components are inspected for loss of material due to corrosion.
Masonry walls are inspected for cracking, and elastomers will be monitored for a change
in material properties. Earthen structures associated with water-control structures will be
inspected for loss of material and loss of form (such as subsidence, settlement, leaks,
and bowing). Component supports will be inspected for loss of material, reduction or
loss of isolation function, and reduction in anchor capacity due to local concrete
degradation. Exposed surfaces of bolting are monitored for loss of material due to
corrosion, loose nuts, missing bolts, or other indications of loss of pre-load.
The inspectors reviewed the program description, program basis documents, station
procedures, and results of prior inspections, interviewed cognizant personnel, and
visually examined accessible structural items, including reinforced concrete and
structural steel members, components, and systems to assess the effectiveness of the
current program.
The inspectors also reviewed station procedures, maintenance history, inspection
findings and followup of inspection findings, and inspection schedules. Planned
inspection frequency was every five (5) years for accessible areas. The program
contained provisions for more frequent inspections to ensure that observed conditions
that have the potential for impacting an intended function are evaluated or corrected in
accordance with the corrective action process.
For the Structural Monitoring Program, the inspectors concluded Entergy had conducted
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. Entergy provided adequate guidance to ensure
aging effects are appropriately identified and addressed.
Masonry Wall Program
The Masonry Wall Program is an existing program which will be enhanced to include the
Unit 1 intake structure within the scope of the program due to potential effects on Unit 2
electrical equipment. The scope of the program includes all masonry walls that perform
intended functions in accordance with 10 CFR 54.4 and were covered by IE Bulletin 80-
11. Additionally, the program includes masonry walls covered by 10 CFR 50.48 (Fire
Protection), radiation shielding, and walls with potential to affect safety-related
21
components. The program is credited with managing the aging effects in masonry walls
by a program of inspection for deterioration on a frequency of 5 years to assure that the
established evaluation basis for each masonry wall remains valid during the period of
extended operation. If any crack or deterioration is found, the inspection frequency is to
be increased to monitor and assess the cause and effect of the degradation.
The inspectors reviewed the program description, program basis documents, station
procedures, and results of prior inspections. The inspectors also interviewed cognizant
personnel and performed a visual examination of accessible masonry walls to assess
the effectiveness of the current program. The inspections are implemented through
station procedures. A review of maintenance history indicated that any degradation
(such as cracks) of masonry block walls was identified and addressed, providing
evidence that the inspection program is effective in identifying and correcting
deficiencies, so that walls continue to perform their intended function.
In response to IE Bulletin 80-11, Masonry Wall Design," and Information Notice 87-67,
Lessons Learned from Regional Inspections of Licensee Actions in Response to IE
Bulletin 80-11," various actions have been taken. Actions have included program
enhancements, follow-up inspections to substantiate masonry wall analyses and
classifications, and the development of procedures for tracking and recording changes to
the walls. These actions have addressed all concerns raised by IE Bulletin 80-11 and
Information Notice 87-67, namely unanalyzed conditions, improper assumptions,
improper classification, and lack of procedural controls. The inspectors review of Indian
Point operating experience demonstrated that the program has been effective in
managing aging effects of masonry walls.
For the Masonry Wall Program, the inspectors concluded Entergy had performed
adequate evaluations, including reviews of industry experience and plant history, to
determine appropriate aging effects. Entergy provided adequate guidance to ensure
aging effects are appropriately identified and addressed.
b.3 System Review
Auxiliary Feedwater System Review
The inspectors selected the auxiliary feedwater system for a focused review to
determine whether the aging management programs were adequate to effectively
manage aging effects related to this system. The aging effects requiring management
for the auxiliary feedwater system are loss of material, cracking-fatigue, fouling,
cracking, and loss of material due to wear. The following aging management programs
are credited with managing aging effects of the auxiliary feedwater system:
Aboveground Steel Tanks; Bolting Integrity; Buried Piping and Tanks Inspection,
External Surfaces Monitoring; Flow-Accelerated Corrosion; Water Chemistry Control -
Auxiliary Systems; and Water Chemistry Control - Primary and Secondary.
The inspectors interviewed the auxiliary feedwater system engineer, performed
walkdown inspections, and reviewed various aging management program documents to
verify that the existing programs credited with managing the effects of aging in the
auxiliary feedwater system have been comprehensive and effective. (All programs
22
except Buried Piping and Tanks Inspection are existing programs.) Specifically, the
inspectors evaluated the existing aging management programs by reviewing system
health reports, condition reports, plant procedures, and NDE inspection reports.
For the auxiliary feedwater system, the inspectors concluded that the physical condition
of the system and the results of tests and inspections of the various existing aging
management programs demonstrated that aging effects on the auxiliary feedwater
system have been appropriately identified and addressed. Also, the inspectors
concluded that the auxiliary feedwater system was appropriately addressed within the
applicable aging management programs.
Unit 2 Station Blackout/Appendix-R Diesel Generator (SBO/App-R DG) System Review
Entergy modified the facility, and placed the new Unit 2 SBO/App-R DG in-service on
April 30, 2008. (See LRA Amendment 4 dated April 30, 2008, for additional information.)
The inspectors performed a focused review to determine whether the scoping and
proposed aging management programs were adequate to effectively manage aging
effects of this system. The aging effects requiring management for the SBO/App-R DG
system are loss of material, cracking-fatigue, fouling, cracking, and loss of material due
to wear. The following aging management programs are credited with managing aging
effects: Bolting Integrity; External Surfaces Monitoring; Oil Analysis; Periodic
Surveillance and Preventive Maintenance; Water Chemistry Control - Closed Cooling
Water; Heat Exchanger Monitoring; and Selective Leaching.
The inspectors interviewed the SBO/App-R DG system engineer, performed walkdown
inspections, and reviewed various aging management program documents to verify that
the programs credited with managing the effects of aging in the SBO/App-R DG system
will be comprehensive and effective. Because the SBO/App-R DG system is new, with
no operating experience, the inspectors evaluated the existing aging management
programs by reviewing similar system and component health reports, condition reports,
and NDE inspection reports.
For the SBO/App-R DG system, the inspectors concluded that for license renewal
purposes Entergy had accurate scoping determinations for the system and its
components. Also, the inspectors concluded that the SBO/App-R DG system was
appropriately addressed within the applicable aging management programs and that
these programs were capable of managing SBO/App-R DG system aging effects.
c. Overall Conclusions
Overall, the inspection results support a conclusion that the proposed activities will
reasonably manage the effects of aging in the systems, structures, and components
identified in the application and that the intended functions of these systems, structures,
and components will be maintained in the period of extended operation. The inspection
concluded that the documentation supporting the application was in an auditable and
retrievable form.
23
40A6 Meetings, Including Exit Meeting
The inspectors presented the inspection results to Joe Pollock, Site Vice President; Fred
Dacimo, Vice President, License Renewal; and members of their staffs in an exit
meeting that was open for public observation on June 18, 2008, in Cortlandt Manor, NY.
Entergy had no objections to the NRC observations and presented the status of Entergy
actions to address the NRC observations. Slides from the exit meeting are located in
ADAMS within package ML081850595, which addresses inspection-related documents,
including NRC slides under ML081840487 and Entergy slides under ML082130530.
No proprietary information was provided to the inspectors during this inspection.
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
F. Dacimo Vice President, License Renewal
J. Pollock Site Vice President
R. Ahrabli Structural engineer
T. Beasly System engineer
A. Bokhari Design engineer
C. Caputo License renewal team
J. Cottam Fire protection programs engineer
A. Cox License renewal team
J. Curry License renewal project manager
R. Dolansky Program engineer
D. Fronabarger License renewal team
J. Goebel Assistant outage manager
R. Herrmann Program engineer
J. Hill Design engineering, I&C supervisor
T. Ivy License renewal team
L. Loubrano Component engineer
W. Mahlmeister Design engineer
I. Mew Program engineer
D. Pennino, Program engineer
J. Pinada System engineer
C. Pistol Program engineer
H. Robinson System engineer
R. Rucker License renewal team
D. Shah System engineer
M. Stewart Electrical maintenance
A. Taylor License renewal team
M. Tesorioro NSSS supervisor
J. Timone Component engineer
J. Whitney System engineer
LIST OF DOCUMENTS REVIEWED
License Renewal Application Drawings
Complete set, including four Unit 1, 73 Unit 2, and 60 Unit 3 drawings
Other Drawings
A202382, Conduit Details for Manholes 35 & 36, Rev 8
A-2
617F645, IP3 Main One Line Diagram, Rev 18
A208377-09, IP2 Main One Line Diagram, Rev 9
A250907-21, IP2 Electrical Distribution and Transmission System, Rev 21
9321-2018, Flow Diagram - Condensate & Boiler Feed Pump Suction
9321-2019, Flow Diagram - Boiler Feedwater
9321-F-2012, IP2 Intake Structure General Arrangement, Rev 5
9321-F-40573, IP3 Flow Diagram for Auxiliary Steam Supply and Condensate Return
System, Rev 27
9321-F-51773, Pipe Trench Area - Restraint and Support Design, Rev 7
9321-L-60129, Sht 6, Restraint SA-H&R-505-U
License Renewal Program Basis Documents
IP-RPT-06-LRD01, System and Structure Scoping Results, Rev 0
IP-RPT-06-LRD02, Aging Management Program Evaluation Report, Rev 3:
Section 3.1, One-time Inspection - Small Bore Piping Program
Section 4.1, Nickel Alloy Inspection Program
Section 4.2, Fatigue Monitoring Program
Section 4.6, Reactor Vessel Head Penetration Inspection Program
Section 4.8, Steam Generator Integrity Program
IP-RPT-06-LRD05, Operating Experience Review Report, Rev 1
IP-RPT-06-LRD07, Aging Management Program Evaluation Report, Rev 3:
Section 3.1, Buried Piping and Tanks Inspection Program
Section 3.2, One-Time Inspection Program
Section 3.3, Selective Leaching Program
Section 4.1, Aboveground Steel Tanks Program
Section 4.2, Bolting Integrity Program
Section 4.4, Boric Acid Corrosion Prevention Program
Section 4.5, Diesel Fuel Monitoring Program
Section 4.6, External Surface Monitoring Program
Section 4.7, Fire Protection Program
Section 4.8, Fire Water System Program
Section 4.9, Flow Accelerated Corrosion Program
Section 4.12, Service Water Integrity Program
Section 4.15, Water Chemistry Control - Closed Cooling Water Program
Section 4.17, Heat Exchanger Monitoring Program
IP-RPT-06-LRD08, Aging Management Program Evaluation Report, Rev 3:
Section 3.2, Containment Inservice Inspection Program
Section 3.3, Structures Monitoring Program
Section 3.4, Masonry Wall Program
IP-RPT-06-LRD09, Aging Management Program Evaluation Report, Rev 3:
Section 3.1, Non-EQ Bolted Cable Connections Program
Section 3.2, Non-EQ Inaccessible Medium-Voltage Cable Program
A-3
Section 3.3, Non-EQ Instrumentation Circuits Test Review Program
Section 3.4, Non-EQ Insulated Cables and Connections Program
Section 4.1, Environmental Qualification (EQ) of Electric Components Program
Section 4.2, Metal Enclosed Bus Inspection Program
Aging Management Review Technical Basis Documents (all preceded by IP-RPT-06-)
AMC04, Aging Management Review of Bulk Commodities, Rev 1
AME01, Attachment 4, Inaccessible Medium-Voltage Cable Screening, Rev 0
AMM14, Aging Management Review of the Compressed Air Systems, Rev 0
AMM16, Aging Management Review of Fire Protection Water System, Rev 0
AMM20, Aging Management Review of IP2 SBO and Appendix R Diesel Generator
System, Rev 0
AMM24, Aging Management Review of the Auxiliary Feedwater Systems
AMM30, Aging Management Review of the Nonsafety-related Systems and Components
Affecting Safety-Related Systems, Rev 2 & Rev 3
Plant Procedures
EN-DC-147, Alloy 600 Program Plan, Rev 3
EN-DC-159, System Monitoring Program, Rev 2
EN-DC-178, System Walkdowns, Rev 1
EN-DC-315, Flow Accelerated Corrosion Program, Rev 0
EN-DC-317, Entergy Steam Generator Administrative Procedure, Rev 2
EN-DC-319, Inspection and Evaluation of Boric Acid Leaks, Rev 2
EN-DC-343, Entergy Buried Piping and Tanks Inspection & Monitoring Program, Rev 0
EN-LI-102, Corrective Action Process, Rev 8
EN-LI-102, Corrective Action Process, Rev 9
EN-MS-S-011-MULTI, Conduct of System Engineering, Rev 2
ENN-CS-S-008, Pipe Wall Thinning Structural Evaluation, Rev 1
ENN-DC-150, Condition Monitoring of Maintenance Rule Maintenance, Rev 2
ENN-EP-S-001, IWE General Visual Containment Inspection, Rev 0
ENN-EP-S-003, IWL Visual Containment Inspection, Rev 0
ENN-NDE-2.12, Certification of Visual Testing (VT) Personnel, Rev 2
ENN-NDE-9.05, Ultrasonic Thickness Examination, Rev 1
ENN-NDE-10.1, VT-1 Examination, Rev 3
0-MS-411, Rev 1 Torquing of Mechanical Fasteners
2-PT-R075, Rev 13 RCS Integrity Inspection
3-PT-R131, Rev 11 RCS Integrity Leak Test
Engineering Report IP-RPT-07-00093, Boric Acid Corrosion Control Program, Rev 0
HTX-006-IAC, Instrument Air Compressor Closed Cooling Water HX Maint., Rev 1
IP-SMM EV-103, Petroleum Bulk Storage Tank Program, Rev 0
PFM-116, Motor Monitoring Program Procedure, Rev 0
PT-EM19, Procedure for Testing Cable Spreading Room Halon System, Rev 10
SAO-703, Fire Protection Impairment Criteria and Surveillance, Rev 24
SEP-SW-001, Generic Letter 89-13 Service Water Program, Rev 1
0-CY-1500, Chemistry Sampling Locations, Rev 6
0-CY-1810, Diesel Fuel Oil Monitoring, Rev 5
A-4
0-CY-2510, Closed Cooling Water Chemistry Specifications and Frequencies, Rev 4
0-CY-2515, Adding Chemicals to Closed Cooling Systems, Rev 6
0-CY-3318, Water and Sediment in Fuel Oil, Rev 3
2-PI-Q001, Inspection Procedure for Fire Separation Barriers (Unit 2), Rev 8
2-PT-2Y015, Revision 1, Thermal Cycle Monitoring Program, Rev 0
2-PT-2Y017, Procedure for Penetration Fire Barrier Seal Inspections (Unit 2), Rev 0
2-PT-W005, Weekly Surveillance Procedure for Diesel Fire Pump (Unit 2), Rev 18
2-PT-M040, Procedure for Testing Diesel Fire Pump (Unit 2), Rev 23
2-PT-Q092, Containment Building Inspection, Rev 3
2-PT-R156, RCS Boric Acid Leakage and Corrosion Inspection, Rev 1
2-PT-R203, Visual Examination of Reactor Vessel Head Penetrations and Head Surface
for Leakage, Rev 2
2-PT-R204, Visual Examination of Reactor Vessel Bottom Mounted Instrument
Penetrations for Leakage, Rev 1
2-SOP 29.20, Emergency Fuel Oil Transfer Using the Trailer, Rev 0
3-CY-2615, Adding Chemicals to Auxiliary Systems, Rev 0
3-PT-M042B, Procedure for Testing Unit 3 Diesel Fire Pump, Rev 3
3-PT-M051, Revision 9, Plant Operation Information, Rev 2
3-PT-R100A, Procedure for Unit 3 Controlled Barrier Inspection, Rev 1
3-PT-R102, Procedure for Fire Barrier Wrap/Radiant Energy Shield Inspection, Rev 4
3-PT-2Y004, Unit 3 CO2 System Test for Cable Spreading & Switchgear Rooms, Rev 2
3-PT-Q137, Containment Building Inspection, Rev 4
3-PT-R203, Visual Examination of Reactor Vessel Head Penetrations and Head Surface
for Leakage, Rev 2
3-PT-R204, Visual Examination of Reactor Vessel Bottom Mounted Instrument
Penetrations for Leakage, Rev 1
3-PT-CS032B, Flow Test of SW Header Check Valve and Underground Portions of Line 408,
Rev 9
2-RPT-00003, Containment Inservice Inspection Program First Containment Inspection
Interval (09/09/96 - 05/09/08), Rev 1
3-RPT-UNSPEC-03499, IP 2&3 Eddy Current Program, Rev 1
IP-RPT-04-00206, Indian Point 2 Steam Generator Program, Rev 1
IP-RPT-04-01796, Indian Point 3 Steam Generator Program, Rev 7
IP-RPT-06-00055, Condition Monitoring and Operational Assessment of
Indian Point 2 Steam Generator Tubing for Cycles 18 and 19, Rev 0
IP-RPT-07-00031, 3R14 Condition Monitoring and Operational Assessment of Indian
Point 3 Steam Generators, Rev 0
IP3-RPT-VC-03071, Containment Inservice Inspection, First Ten Year Class MC and CC
Program, 09/10/99-07/20/09, Rev 5
System Health Reports
IP3 Heat Exchangers, 2nd Quarter 2007
IP3 Service Water, 1st Quarter 2007
IP2 Auxiliary Feedwater, 1st Quarter 2007
IP2 Auxiliary Feedwater, 3rd Quarter 2007
IP3 Auxiliary Feedwater, 1st Quarter 2007
IP3 Auxiliary Feedwater, 3rd Quarter 2007
IP2 Cycle 18 Generic Letter 89-13 Leakage Logs
A-5
IP2&3 Service Water System Leakage History 1991 to Present, Dated Jan 2008
IP3 Cycle 15 Generic Letter 89-13 Leakage Logs
Condition Reports (CRs)
IP2-2000-07403
IP2-2002-03598
IP2-2004-05296
IP2-2005-02690
IP2-2006-01798
IP2-2006-01965
IP2-2006-02161
IP2-2006-02553
IP2-2006-02712
IP2-2007-03749
IP2-2008-00517*
IP3-2000-01898
IP3-2001-04270
IP3-2005-03202
iP3-2006-00583
IP3-2007-01388
IP3-2007-00309
IP3-2007-02984
IP3-2008-00285*
IP3-2008-00442*
IP3-2008-00444*
IP3-2008-00457*
IP3-2008-00517*
A-6
IP3-LO-2005-00117
- CRs written as a result of the NRC inspection
Maintenance Requests & Work Orders
WO IP3-98-484002
WO 51434864
I3-000261300
I3-000277700
I3-010166600
I3-980309200
I3-980309300
I3-990116600
IP2-02-31080
IP2-02-31084
IP2-02-33308
IP2-98-97215
A-7
IP3-02-21958
IP3-02-22487
NP-92-58250
NP-93-66966
NP-95-81537
NP-98-97215
Completed Surveillance Tests
2-PC-2Y72A, Source Range Neutron Flux N-31 Channel Calibration, performed 4/19/06
2-PC-2Y72B, Source Range Neutron Flux N-32 Channel Calibration, performed 4/20/06
2-PC-2Y73A, Intermediate Range Neutron Flux N-35 Channel Calibration, performed 5/9/06
2-PC-2Y73B, Intermediate Range Neutron Flux N-36 Channel Calibration, performed 4/25/06
2-PC-4Y74B, Nuclear Instruments Power Range N-42 Channel Calibration, performed 5/5/06
2-PC-4Y74D, Nuclear Instruments Power Range N-44 Channel Calibration, performed 5/4/06
2-PC-R38-2, High Range Containment Area Radiation Monitor R25, performed 4/14/06, 5/16/06
2-PC-R38-4, High Range Containment Area Radiation Monitor R26, performed 5/6/06
2-PI-M009, Aboveground Petroleum Storage Tanks, Performed 1/16/08
3-PC-Q109A, Nuclear Power Range Channel N-41 Axial Offset Calibration, performed 5/31/07
3-PC-Q109B, Nuclear Power Range Channel N-42 Axial Offset Calibration, performed 5/31/07
3-PC-Q109C, Nuclear Power Range Channel N-43 Axial Offset Calibration, performed 6/1/07
3-PC-Q109D, Nuclear Power Range Channel N-44 Axial Offset Calibration, performed 6/1/07
3-PC-R45, Calibration Procedure for the Gamma-Metrics Excore Nuclear Instrumentation
System, performed 3/25/05
3-PC-R46A, Containment High Range Radiation Monitor Calibration (R-25), performed 3/13/07
3-PC-R46B, Containment High Range Radiation Monitor Calibration (R-26), performed 3/13/07
3-PC-R72A, Nuclear Instruments Source Range N-31 Channel Calibration, performed 3/8/07
3-PC-R72B, Nuclear Instruments Source Range N-32 Channel Calibration, performed 3/8/07
3-PC-R73A, Nuclear Instruments Intermediate Range N-35 Channel Calibration, performed
3/10/07
3-PC-R73B, Nuclear Instruments Intermediate Range N-36 Channel Calibration, performed
3/10/07
EBD-B-002-N, Westinghouse 6.9KV Cubicle and Bus Cleaning and Inspections, performed
2/25/93, 7/14/94, 5/15/97, 11/2/04
EBD-P-004-A, Westinghouse Station Service Transformers and Buses (480VAC), performed
4/24/00, 11/8/02
ELC-013-BUS, Inspection, Cleaning, and Testing of Medium Voltage Switchgear, performed
9/17/99, 5/7/01, 4/9/03, 3/18/07, 3/21/07
ELC-014-BUS, Inspection, Cleaning, and Testing of 480V Load Center, performed 9/17/99,
4/8/03, 3/17/07
IP2-04-30541, High Range Containment Area Radiation Monitor 26, performed 3/24/06
PC-M-1, Nuclear Power Range Channels Axial Offset, performed 9/13/04
PI-SA-2, Atmospheric Tanks, Performed 9/7/07
2-PT-3Y009, Flow Test for underground SE Line 409, Completed 08-09-2005
2-PT-3Y010, Flow Test for underground SE Line 409, Completed 09-10-2005
A-8
3-PT-CS032A, Flow Test of SW Header Check Valve and Underground Portions of Line 408,
Completed 03-28-2007
WR 51478836-01, Perform 3-PT-Q137, Rev 4, Containment Building Inspection
WR 51550475, Perform 2-PT-Q092, Rev 3, Containment Building Inspection
WR IP2-02-17652, Perform 2-PT-R203, Rev 0, Visual Examination of Reactor Vessel Head
Penetrations and Head Surface for Leakage
WR IP3-06-10035, Perform 3-PT-R203, Rev 1, Visual Examination of Reactor Vessel Head
Penetrations and Head Surface for Leakage
WR IP3-06-12801, Perform 3-PT-R204, Rev 0, Visual Examination of Reactor Vessel Bottom
Mounted Penetrations for Leakage
Inspection Reports
IP3-UT-07-096
IP2-UT-07-053
IP2-UT-07-047
IP2-UT-07-043
IP2-UT-07-037
Maintenance Rule Inspections (Structural):
- Reactor Building: Twenty-three reports
- Turbine Building: Eight reports
- Emergency Diesel Generator and Associated Structures: Nine reports
- Radwaste Building: Four reports
- Miscellaneous Structures: Sixty reports
Visual Inspection Photographs
IP2 408 SWP:
408 header exc Nov 04, 021 - 10 photographs
IP2 buried flng to header by river - 3 photographs
IP2 SWP 408 buried flng to PAB Bldg - 4 photographs
IP2 SWP 24/25/26 408 - 5 photographs
1st tee @ 30' - 4 photographs
Upper 90 vert elbow - 1 photographs
IP2 414 HDR:
Debris @10' east of access - 1 photograph
Debris @15' east of access - 1 photograph
IP2 840 Vlv:
840 flng - 1 photograph
1103 pipe connection to main from swn 46 - 1 photograph
1105 left side close up - 1 photograph
1105 right side close up - 1 photograph
1105 upstream - 4 photographs
Flow restrictor - 1 photographs
A-9
Main Pipe to 1103 (SWN45) connection - 1 photograph
Tee crotch near 840 - 1 photograph
Weld @ tee down stream of 1105 (2) - 1 photograph
Weld @ tee down stream of 1105 left side - 1 photograph
Weld @ tee down stream of 1105 right side - 1 photograph
Weld @ tee downstream (4) - 1 photograph
Weld @ tee downstream of 1105 (3) - 1 photograph
Excavation of flange 408 - 12 pictures
SWN 40:
2nd Reducer from access - 1 photograph
Debris @ Vert 90 elbow - 3 photographs
Photos of Reactor Vessel Head Cleaning from 2R16
Photos of Reactor Vessel Head Cleaning from 2R17
Miscellaneous Documents
IP2-DBD-222, Electrical Separation Design Basis Document, Rev 2
Letter No. 20407.002, from Normandeau Associates, to IP3, Zebra Mussel Monitoring Program
June Results, dated 06-22-2007
Letter from Hunting Pipeline Services, to IP3, Evaluation of As-found Condition of SW
Mechanical Seals, dated 03-17-2005
2R17 Flow Accelerated Corrosion Monitoring Program, Spring 2006
3R14 FAC Examination Report for Indian Point Unit 2 for Entergy Nuclear, March 2007
IP-RPT-05-00407, IPEC 3R14 FAC Scope Review, Rev 0
IP-RPT-06-00070, Alloy 600 Program Plan, Rev 0
IP-RPT-MULT-03162, Unit 3 Flow-Accelerated Corrosion Susceptibility Review and Small-Bore
and Augmented Monitoring Program, Rev 2
IP2 Boric Acid Database
IP2 Flow Accelerated Corrosion Program Plan Supplement, April 28, 2003
IP2 Reactor Vessel Examination, Examination Summary dated May 5, 2006
IP3 Boric Acid Database
ER IP2-06-26282, Flow Accelerated Corrosion Inspection Points for 2R18, Rev 0
ER IP3-05-24045, Flow Accelerated Corrosion Inspection Points for 3R14, Rev 1
IP2-02-50626, Reactor Vessel Head Penetration Contingency Repair
Maintenance Rule Basis Document for Structures
Monitoring Reports for 10CFR50.65 Maintenance Rule Structures
A02-07I, 12/23/2003, QA Audit Report on EQ Program.
A03-12-I, 10/21/2003, Fire Protection Program Audit
GT-1 North & South Fuel Oil Storage Tanks Inspection Report, Dated June 2001
GT-2/3 Fuel Oil Storage Tank Inspection Report, Dated April 2002
IP-2 Service Water Intake Pump Bay Silt Mapping Report, Dated 05-04-2007
IP-2 Service Water Intake Pump Bay Silt Mapping Report, Dated 11-28-2007
IP-2 Remote Visual Inspection of Service Water Piping Report, Dated 11-10-2004
QA-09-2005-IP-1, 12/12/2005, IPEC Fire Protection Program Audit.
QA-09-2006-IP-1, 01/19/2006, IPEC Fire Protection Program Audit.
IPEC Self Assessment Report - Leak Management Program Implementation
A-10
Listing of Components Covered by Selective Leaching Program
Email from Charles Caputo on August 14, 2006; Results from site walkdown of the
chlorination system for IP2 and IP3
WCAP-12191, Transient and Fatigue Cycle Monitoring Program Transient History
Evaluation Final Report for Indian Point Unit 2, July 1999, Rev 2
WCAP-12937, Structural Evaluation of Indian Point Units 2 and 3 Pressurizer Surge
Lines, Considering the Effects of Thermal Stratification, May 1991
Calculations
FCX-00538, Estimation of EDYs for IP2 Reactor Vessel Head by 2R17 and 2R18
IP-CALC-04-01634, Assessment of the Impact of Power Uprate on the EOL Degradation
Years (EDY's) for the IP3 Vessel Head, Rev 0
IP-CALC-06-00100, Wall Thinning Evaluation for Flow Accelerated Corrosion at 2R17
Locations, Rev 0
IP-CALC-06-00175, Evaluation of FAC Inspection Point LPFW22B-1N for Local Wall
Thinning, Rev 0
IP-CALC-06-00297, Wall Thinning Evaluation and R.S.L. for Flow Accelerated Corrosion at
2R17 Locations, Rev 0
IP3-CALC-RV-03720, Estimation of Effective Degradation Years (EDY) for IP3 Reactor Vessel
Head, Rev 2
Entergy Letters/Correspondence
Indian Point 2 Response to NRC Generic Letter 89-08 Erosion/Corrosion - Induced Pipe
Wall Thinning, July 20, 1989
Indian Point Unit 2, Response to NRC Bulletin No. 87-01, Thinning of Pipe Walls in
Nuclear Power Plants, September 11, 1987
IP3-87-055Z, Indian Point 3. NRC Bulletin No. 87-01 Thinning of Pipe Walls in
Nuclear Power Plants, September 15, 1987
IPN-89-044, Indian Point 3 Nuclear Power Plant Response to NRC Generic Letter 89-08,
Erosion/Corrosion - Induced Pipe Wall Thinning, July 21, 1989
Letter from Entergy to NRC dated March 11, 2004, Indian Point 2 and 3 Answer to
2/20/04 Revised NRC Order Regarding Interim Inspection Requirements for
Reactor Pressure Vessel Heads
Letter from Entergy to NRC dated March 27, 2003, IP3 NRC Order EA-03-009
Relaxation Request Regarding Inspection of Reactor Pressure Vessel Head
Nozzles
Letter from NRC to Entergy dated October 15, 2004, Relaxation of First Revised Order
on Reactor Vessel Nozzles, Indian Point Unit Number 2
NL-05-001, Letter from Entergy to NRC dated January 17, 2005, Reactor Vessel Head
Inspection Results: IP2, Fall 2004 Refueling Outage (2R16)
NL-05-044, Letter from Entergy to NRC dated May 31, 2005, Reactor Vessel Head
Inspection Results: IP3, Spring 2005 Refueling Outage (3R13)
NL-06-028, Letter from Entergy to NRC dated May 31, 2006, License Amendment
Request for Adoption of TSTF-449, Regarding Steam Generator Tube Integrity
NRC Letter to Entergy Nuclear Operations, Inc. August 18, 2005
Entergy Nuclear Northeast Letter to NRC, NL-05-002, January 17, 2005
Entergy Nuclear Northeast Letter to NRC, NL-05-063, May 31, 2005
A-11
NRC Documents
BL 2002-01, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure
Boundary Integrity
BL 2002-02, Reactor Pressure Vessel Head And Vessel Head Penetration Nozzle
Inspection Programs, August 9, 2002
BL 2003-02, Leakage From Reactor Pressure Vessel Lower Head Penetrations And
Reactor Coolant Pressure Boundary Integrity, August 21, 2003
EA-03-009, Issuance Of Order Establishing Interim Inspection Requirements For
Reactor Pressure Vessel Heads At Pressurized Water Reactors, February 11,
2003
EA-03-009, Issuance Of First Revised NRC Order (EA-03-009) Establishing Interim
Inspection Requirements For Reactor Pressure Vessel Heads At Pressurized
Water Reactors, February 20, 2004
GL 88-05, Boric Acid Corrosion Of Carbon Steel Reactor Pressure Boundary
Components In Pwr Plants (Generic Letter 88-05), March 17, 1988
GL 89-13, Service Water System Problems Affecting Safety-related Equipment
IN 2002-11, Recent Experience With Degradation Of Reactor Pressure Vessel Head,
March 12, 2002
IN 2002-13, Possible Indicators Of Ongoing Reactor Pressure Vessel Head
Degradation, April 4, 2002
IN 2003-02, Recent Experience With Reactor Coolant System Leakage And Boric Acid
Corrosion, January 16, 2003
IN 86-108, Degradation Of Reactor Coolant System Pressure Boundary Resulting From
Boric Acid Corrosion, December 29, 1986
NUREG-1801, Generic Aging Lessons Learned (GALL) Report, Rev 1
RIS 2003-13, NRC Review Of Responses To Bulletin 2002-01, Reactor Pressure
Vessel Head Degradation And Reactor Coolant Pressure Boundary Integrity
Industry Documents
EPRI TR 1042135 Bolted Joint Maintenance & Applications Guide
EPRI TR-107396, Closed Cooling Water Chemistry Guideline, Rev 1
EPRI TR-107514, Age-Related Degradation Inspection Method and Demonstration
EPRI Report 10000701, Interim Thermal Fatigue Management Guideline (MRP-24),
January 2001
NEI 95-10, Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 -
The License Renewal Rule, Rev 6
NSAC-202L-R3, Recommendations for an Effective Flow-Accelerated Corrosion
Program, May 2006
United Engineers & Constructions Inc. Specification No. 9321-01-248-18
A-12
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
ASME American Society of Mechanical Engineers
CR Condition Report
DRS Division of Reactor Safety
EPRI Electric Power Research Institute
EQ Environmental qualification, i.e., 10 CFR 50.49
IE Office of Inspection & Enforcement, NRC
ISG Interim Staff Guidance
ISI Inservice Inspection
LRA License Renewal Application
NEI Nuclear Energy Institute
NPS normal pipe size
NRC U.S. Nuclear Regulatory Commission
NRR Office of Nuclear Reactor Regulation, NRC
PARS Publicly Available Records
PM preventive maintenance
PWSCC primary water stress corrosion cracking