ML12310A061

Clarification of Underground Piping Information Provided in Letter NL-11-032 Regarding the License Renewal Application

ML12310A061
Person / Time
Site:	Indian Point
Issue date:	10/18/2012
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-149
Download: ML12310A061 (5)

Text

Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal 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-1 1-032 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-1 1-032), "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 NL-1 2-149 Page 2 of 2 portions of two 24" diameter Indian Point 3 service water inlet headers (approximate total length of 70 feet) that run over the discharge canal, portions of the Indian Point 2 and 3 fuel oil piping (1 1/", 3" and 4" in diameter) that supply and run between the fuel oil storage tanks and from the storage tanks to each of the emergency diesel generator (EDG) rooms (approximate total length of 160 feet) and a portion of the %" diameter Indian Point 3 city water piping (approximate total length of 40 feet) that runs in the EDG pipe trench.The above piping will be periodically inspected under the Buried Piping and Tanks Inspection Program at a frequency that meets or exceeds NUREG-1801 Section XI.M41 guidance for underground piping which will ensure the effects of aging are adequately managed. Attachment 1 identifies changes to the service water, city water and fuel oil systems aging management review tables that result from the clarification identified in this letter.If you have any questions, or require additional information, please contact Mr. Robert Walpole at 914-254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on lot 1;- rz-~Sincer FRD/rw

Attachment:

1. Changes to the Indian Point LRA Service Water, City Water, and Fuel Oil Systems Aging Management Review Tables cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Mr. John Daily, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, Jr., President and CEO NYSERDA ATTACHMENT I 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 Attachment 1 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 3.3.2-2-1P3:

Service Water System AgngEfetNUREG-Tal Component Intended Aging Management 1801 Table I Type Function Material Environment Requiring Programs 1801 Vol.2 Item Notes Management Item Pipinq Pressure Carbon steel Condensation Loss of material Buried Pipinq and VI1.1-11 3.3.1-58 E boundary (ext) Tanks Inspection Table 3.3.2-13-1P2:

Fuel Oil Systems Aging ffectNUREG-Component Intended Aging Management 1801 Table I Type Inten Material Environment Requiring 1801 Vol. 2 Notes Type Function Management Programs Item Item Ppi Pressure Carbon steel Air- outdoor Loss of material Buried Piping and VII.H1-8 3.3.1-60 E boundary (ext) Tanks Inspection (A-24)Table 3.3.2-13-1P3:

Fuel Oil Systems Component Intended Aging Effect ANUREG- Table I TypAMaterial Environment Requiring Aging Management 1801 Vol. 2 Notes Type Function Management Programs Item Item a!piM Pressure Carbon steel Air- outdoor Loss of material Buried Piping and VII.H1-8 3.3.1-60 E boundary (ext) Tanks Inspection (A-24)

Attachment 1 NL-12-149 Page 2 of 2 Table 3.3.2-17-1P3:

City Water Component Intended Aging Effect Aging Management NUREG- Table I Type Inten Material Environment Requiring Programs Vol 2 Item Notes Type Function Management Item"in Pressure Cogper Alloy Air- outdoor (ext) Loss of material Buried Piping and -- -- G boundary Tanks Inspection