ML12292A932
| ML12292A932 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/18/2012 |
| From: | - No Known Affiliation |
| To: | Division of License Renewal |
| References | |
| Download: ML12292A932 (7) | |
Text
1 IPRenewal NPEmails From:
Waters, Roger M. [rwater1@entergy.com]
Sent:
Thursday, October 18, 2012 7:00 PM To:
Wentzel, Michael Cc:
Daily, John; Pickett, Douglas
Subject:
IPEC License Renewal - Clarification of Underground Piping Information Attachments:
NL-12-149.pdf
- Mike, Attached is a pdf version of the subject submittal. The hardcopies will be sent out shortly.
Roger Waters IPEC Licensing 914-254-7714
Hearing Identifier:
IndianPointUnits2and3NonPublic_EX Email Number:
3878 Mail Envelope Properties (A121135CD9246F4082BF946E6F9FB039258020F4)
Subject:
IPEC License Renewal - Clarification of Underground Piping Information Sent Date:
10/18/2012 7:00:16 PM Received Date:
10/18/2012 7:00:21 PM From:
Waters, Roger M.
Created By:
rwater1@entergy.com Recipients:
"Daily, John" <John.Daily@nrc.gov>
Tracking Status: None "Pickett, Douglas" <Douglas.Pickett@nrc.gov>
Tracking Status: None "Wentzel, Michael" <Michael.Wentzel@nrc.gov>
Tracking Status: None Post Office:
jdcxmetsp004.etrsouth.corp.entergy.com Files Size Date & Time MESSAGE 163 10/18/2012 7:00:21 PM NL-12-149.pdf 235177 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
Fred Dacimo Vice President Operations License Renewal Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 NL-12-149 October 18, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Clarification of Underground Piping Information Provided in Letter NL-11-032 Regarding the License Renewal Application Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64
REFERENCE:
(1) Entergy letter (NL-11-032), Response to Request for Additional Information (RAI) Aging Management Programs, dated March 28, 2011
Dear Sir or Madam:
Reference (1) stated in the response to RAI 3.0.3.1.2-1 Part 5a that Underground piping and tanks are below grade, but are contained within a tunnel or vault such that they are in contact with air and are located where access for inspection is restricted. In-scope SSCs that are subject to aging management review at IPEC include no underground piping or tanks. Indian Point made this statement because piping located in underground vaults is periodically accessed for visual inspections during pressure tests. However, during a recent review of the NRC Interim Staff Guidance (ISG) for Buried Piping, LR-ISG-2011-03, a question was raised relative to the definition of restricted and whether the Indian Point definition was consistent with the intent of the ISG. As a result of this question, Entergy Nuclear Operations, Inc held a conference call with the NRC staff to clarify the definition of restricted as used in the ISG.
Although definition of the term restricted as related to underground piping was not found in NRC guidance documents related to license renewal, during the conference call on October 11, 2012, the NRC Staff indicated that it was intended that piping located in vaults for which access requires more than simply opening a locked access cover should be classified as underground piping.
As a result of this change in understanding of the definition of underground piping, Indian Point has identified portions of the service water, city water and fuel oil systems that are located in vaults that require more than unlocking a hatch or cover for access. This piping will now be considered underground piping as defined in LR-ISG-2011-03. Specifically, this includes
ATTACHMENT 1 TO NL-12-149 CHANGES TO THE INDIAN POINT LRA SERVICE WATER, CITY WATER, AND FUEL OIL SYSTEMS AGING MANAGEMENT REVIEW TABLES ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 NL-12-149 Page 1 of 2 The following identifies changes to the service water system and fuel oil system aging management review tables as a result of the clarification identified in this letter.
Changes are shown with underlines for additions.
Table 3.3.2-2-IP3: Service Water System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Vol. 2 Item Table 1 Item Notes Piping Pressure boundary Carbon steel Condensation (ext)
Loss of material Buried Piping and Tanks Inspection VII.I-11 (A-81) 3.3.1-58 E
Table 3.3.2-13-IP2: Fuel Oil Systems Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Vol. 2 Item Table 1 Item Notes Piping Pressure boundary Carbon steel Air - outdoor (ext)
Loss of material Buried Piping and Tanks Inspection VII.H1-8 (A-24) 3.3.1-60 E
Table 3.3.2-13-IP3: Fuel Oil Systems Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Vol. 2 Item Table 1 Item Notes Piping Pressure boundary Carbon steel Air - outdoor (ext)
Loss of material Buried Piping and Tanks Inspection VII.H1-8 (A-24) 3.3.1-60 E
NL-12-149 Page 2 of 2 Table 3.3.2-17-IP3: City Water Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Vol. 2 Item Table 1 Item Notes Piping Pressure boundary Copper Alloy Air - outdoor (ext)
Loss of material Buried Piping and Tanks Inspection G