ML12340A681
| ML12340A681 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 04/19/2012 |
| From: | Conte R Engineering Region 1 Branch 1 |
| To: | Ventosa J Entergy Nuclear Operations |
| SECY RAS | |
| References | |
| RAS 23327, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 IR-12-008 | |
| Download: ML12340A681 (15) | |
See also: IR 05000247/2012008
Text
United States Nuclear Regulatory Commission Official Hearing Exhibit
Entergy Nuclear Operations, Inc.
In the Matter of:
(Indian Point Nuclear Generating Units 2 and 3)
ASLBP #: 07-858-03-LR-BD01
Docket #: 05000247 l 05000286
Exhibit #: NRC000152-00-BD01 Identified: 10/15/2012
Admitted: 10/15/2012 Withdrawn: NRC000152
Rejected: Stricken:
Other: Submitted: August 20, 2012
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PENNSYLVANIA 19406-1415
April 19, 2012
Mr. John Ventosa, 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 UNIT 2 - NRC INSPECTION REPORT
Dear Mr. Ventosa:
On March 8, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
the Indian Point Nuclear Generating Unit 2. The enclosed report documents the results of the
inspection, which were discussed on March 8, 2012, with Mr. John Curry and members of your
staff.
This inspection was an examination of license renewal activities under Temporary Instruction
(TI) 2516/001 , Review of License Renewal Activities. The inspection was directed toward those
activities and facilities accessible during the refueling outage. The inspection also reviewed the
completion of commitments made during the renewed license application process and
compliance with the Commission's rules and regulations and the conditions of your operating
license. Within these areas, the inspection involved examination of selected procedures and
representative records, observations of activities, and interviews with personnel.
On the basis of the samples selected for review, there were no findings of significance identified
during this inspection. The NRC staff identified two instances of commitments which could not
be considered completed at this time. Given the scheduled completion of September 28, 2013,
for these commitments, we will incorporate a followup review as a part of our planned team
inspection in this area prior to September 28, 2013, to verify completion along with the
completion of other commitments.
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
Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html(the Public Electronic Reading
Room).
Sincere~y,
flJ~ } ,G;;;tp
Richard J. Conte, Chief
Engineering Branch1
Division of Reactor Safety
0 Non-Sensitive 0 Publicly Available
0 SUNSI Review
0 Sensitive 0 Non-Publicly Available
OFFICE RIIDRS RIIDRP RIIDRS
NAME GMeyerlRJC for MGray RConte
DATE 4/11/12 4/19/12 4/19/12
J. Ventosa 2
Docket No. 50-247
License No. DPR-26
Enclosure:
NRC Inspection Report 05000247/2012008
cc w/enclosure: Distribution via ListServ
J. Ventosa 3
Distribution w/encl: (via E-mail)
W. Dean, RA (R10RAMAIL RESOURCE)
D. Lew, DRA (R10RAMAIL RESOURCE)
J. Clifford, DRP (R1DRPMail Resource)
J. Trapp, DRP (R1DRPMAIL Resource)
C. Miller, DRS (R1DRSMAIL RESOURCE)
P. Wilson, DRS (R1DRSMAIL RESOURCE)
M. McCoppin, RI OEDO
M. Gray, DRP
B. Bickett, DRP
S. McCarver, DRP
M. Jennerich, DRP
M. Catts, SRI
A. Ayegbusi, RI
D. Hochmuth, AA
RidsNrrPMlndianPoint Resource
RidsNrrDorlLpl1-1 Resource
ROPreport Resource
D. Bearde, DRS
T. Lupoid, DRS
R. Conte, DRS
G. Meyer, DRS
u.s. NUCLEAR REGULATORY COMMISSION
REGION I
Docket: 50-247
License: DPR-26
Report: 05000247/2012008
Licensee: Entergy Nuclear Northeast (Entergy)
Facility: Indian Point Nuclear Generating Unit 2
Location: Buchanan, NY
Dates: March 5 - 8, 2012
Inspectors: G. Meyer, Senior Reactor Inspector, Division of Reactor Safety
M. Modes, Senior Reactor Inspector, Division of Reactor Safety
Accompanied By: K. Green, Senior Project Manager, Division of License Renewal
W. Holston, Senior Technical Reviewer, Division of License Renewal
Approved By: Richard J . Conte, Chief
Engineering Branch 1
Division of Reactor Safety
Enclosure
SUMMARY OF FINDINGS
IR 05000247/2012008; 03/05/2012 - 03/08/2012; Indian Point Nuclear Generating Unit 2;
Review of License Renewal Activities.
The report covers a one week inspection of the implementation of license renewal activities
during the Indian Point Unit 2 refueling outage. It was conducted by two region based
engineering inspectors under Temporary Instruction 25161001. No findings were identified. The
inspectors determined that Entergy actions on four commitments (Commitments 28,29,34, and
36) were complete and met regulatory expectations as reflected in the staff's safety evaluation
report. Inspection of two commitments (Commitments 2 and 3) concluded that additional
inspection was needed.
ii Enclosure
Report Details
4. OTHER ACTIVITIES (OA)
40A2 Other - License Renewal Activities (TI 2516/001)
a. Inspection Scope
This inspection was performed by two NRC Region I based inspectors to evaluate the
license renewal activities at the Indian Point Nuclear Generating Unit 2 in accordance
with Temporary Instruction (TI) 2516/001. As noted in this TI: This procedure was
written to allow for timely verification by NRC inspectors that the applicant has made
sufficient progress in implementing its license renewal commitments before entering its
post-40-year license period and to allow documentation of these inspection activities
while the operating license is being considered for renewal." This phase of the
inspection is "to be completed during the outage preceding the beginning of the period of
extended operations for the purpose of observing or verifying commitments of tests or
other activities that require containment entries or access to rooms that would normally
be posted as a high-radiation area or higher when the reactor is operating." The
inspectors performed in-plant observations of license renewal related activities and
sampled Entergy actions on commitments. The bases for the review was the NRC
staff's safety evaluation report (NUREG-1930) and related licensee letters associated
with licensee renewal regulatory commitments, including Letter NL-11-1 01, dated
August 22,2011.
b. Findings and Observations
No findings were identified.
b.1 In-Plant Observations
The inspectors observed ongoing activities and inspected the general condition of
structures, systems, and components within the scope of license renewal. The
inspectors performed reviews in the following areas, as related to commitments and
aging management programs (AMPs):
- Turbine Building - Flow Accelerated Corrosion AMP
- Turbine Building - One-Time Inspection Program (Commitment 19)
- Station Blackout (SBO)/Appendix R Diesel Generator (Commitment 34)
The inspectors determined the general conditions to be satisfactory and the Entergy
activities to be in accordance with facility programs and procedures.
Enclosure
2
b.2 Commitments - Review Complete
Commitment 28 - Water Chemistry Control- Closed Cooling Water Program
Commitment 28 provides that Entergy will "Enhance the Water Chemistry Control -
Closed Cooling Water Program to maintain water chemistry of the IP2 SBO/Appendix R
diesel generator cooling system per EPRI guidelines" and will "Enhance the Water
Chemistry Control- Closed Cooling Water Program to maintain the IP2 and IP3 security
generator and fire protection diesel cooling water pH and glycol within limits specified by
EPRI guidelines" by September 28, 2013. The license renewal team inspection
(Report 05000247/2008006 dated August 1, 2008) had noted that some parameters
were not monitored for some diesels in existing procedures.
The inspectors reviewed the implementation plan, EPRI guidelines, revised chemistry
sampling procedures and acceptance criteria, and chemistry results for the SBO/App. R,
fire protection, and security diesels.
The inspectors concluded that Commitment 28 had been completed.
Commitment 29 - Sulfates in the Refueling Water Storage Tank (RWST)
Commitment 29 provides that Entergy will "Enhance the Water Chemistry Control -
Primary and Secondary Program for IP2 to test sulfates monthly in the RWST with a limit
of <150 ppb" by September 28, 2013.
The inspectors reviewed the implementation plan, RWST chemistry sampling procedure,
and RWST chemistry results for 2010 and 2011 .
The inspectors concluded that Commitment 29 had been completed .
Commitment 34 - Station Blackout (SBO)/Appendix R Diesel Generator
Commitment 34 provides that "IP2 SBO/Appendix R diesel generator will be installed
and operational by April 30, 2008."
Inspection Report 05000247/2008006, dated August 1, 2008, documented the license
renewal team inspection of the IP2 SBO/App. R diesel generator following its installation
and operational testing . Inspection Report 05000247/2008003, dated August 13, 2008,
documented the inspection of the post-modification testing of this diesel generator.
The inspectors concluded that Commitment 34 had previously been completed.
Commitment 36 - Refueling Cavity Concrete
Commitment 36 provides that Entergy will "Perform a one-time inspection and evaluation
of a sample of potentially affected IP2 refueling cavity concrete prior to the period of
extended operation. The sample will be obtained by core boring the refueling cavity wall
in an area that is susceptible to exposure to borated water leakage. The inspection will
Enclosure
3
include an assessment of embedded reinforcing steel. A sample of leakage fluid will be
analyzed to determine the composition of the fluid." These actions are scheduled for
completion by September 28, 2013. Commitment 36 also addresses core bores and
leakage fluid analysis in the first ten years of the period of extended operation. During
refueling operations at Unit 2, leakage through the reactor refuel cavity liner plate had
caused the cavity flood-up water to migrate through the concrete walls of the cavity.
NRC was concerned the borated water flowing through the concrete and past the
reinforcement bars could cause an indeterminate degradation.
The inspectors reviewed the test results of concrete cores removed from the IP2 refuel
structure in Engineering Report No. IP-RPT-11-00002, Assessment of Concrete Aging
From Selected Indian Point Structures, Rev 0, January 10, 2011. The originally
specified concrete strength, per United Engineers and Constructors Drawing 9321-01-5-
1, Specification for Design, Inspection and Tests of Concrete, High Strength Bolts,
Compaction of Fill and Rock Bearing, was 3000 psi at 28 days. Entergy took seven core
samples from the Unit 2 fuel pool structure; the compression results were 7,213 psi,
3,202 psi, 5,890 psi, 6,294 psi, 8,307 psi, 5,497 psi, and 6,448 psi. Using the guidance
of American Concrete Institute, ACI 214.4R, the calculated equivalent in-structure
compressive strength was 4,341 psi.
Reinforcing bars were part of three of the concrete samples taken from the Unit 2 fuel
pool structure. The above referenced report noted there was no visible degradation of
the reinforcing bars. This observation compared favorably with concrete core samples
taken from the Unit 1 fuel pool structure, which was wetted by a boric acid solution
equivalent to Unit 2 for approximately 30 years.
Nine samples were taken from the core bores for further interrogation by Petrography
with a Stereo-microscope. These samples were examined in general accordance with
ASTM C-856-04, Standard Practice for Petrographic Examination of Hardened
Concrete. There were observations of concrete paste discoloration and cracks noted in
the Petrographic samples taken from the core samples extracted from the west and
south walls of the fuel pool. The discoloration was attributed to the differences in the
hydration of the paste most likely due to exposure to the water through the cracks, and
the report concluded the examined material was of "relatively good quality."
The inspectors concluded that Commitment 36 is on track to be completed.
b.3 Commitments - Needing Additional NRC Review
Commitment 2 - Bolting Integrity Program
Commitment 2 provides that Entergy will "Enhance the Bolting Integrity Program for IP2
and IP3 to clarify that actual yield strength is used in selecting materials for low
susceptibility to SCC and clarify that prohibition on use of lubricants containing MoS2 for
bolting" by September 28, 2013. Commitment 2 also states that "The Bolting Integrity
Program manages loss of preload and loss of material for all external bolting."
Enclosure
4
The inspectors reviewed the implementation plan and the revised mechanical fastener
procedure, which had specific instructions on bolting regarding the use of actual yield
strength and the prohibition against molybdenum disulfide as a lubricant. Nonetheless,
there was no planned action regarding the second commitment statement regarding loss
of preload and loss of material, despite Commitment 2 being considered completed by
Entergy. Entergy entered this concern into the license renewal corrective action system
as item LO-LAR-2011-00174, CA-66.
The inspectors concluded that the specific procedural instructions of Commitment 2 had
been completed, but that review of any action on the general statement needed to be
reviewed during a subsequent NRC inspection.
Commitment 3 - Buried Piping and Tanks Inspection Program
Commitment 3 provides that Entergy will "Implement the Buried Piping and Tanks
Inspection Program for IP2 [and IP3] as described in LRA Section B.1.6" and perform
the following:
- "Include in the Buried Piping and Tanks Inspection Program described in LRA Section B.1.6 a risk assessment of the in-scope buried piping and tanks that
includes consideration of the impacts of buried piping or tank leakage and of
conditions affecting the risk for corrosion ."
- "Classify pipe segments and tanks as having a high, medium or low impact of
leakage based on the safety class, the hazard posed by fluid contained in the
piping and the impact of leakage on reliable plant operation."
- "Determine corrosion risk through consideration of piping or tank material, soil
resistivity, drainage, the presence of cathodic protection and the type of coating ."
- "Establish inspection priority and frequency for periodic inspections of the in-
scope piping and tanks based on the results of the risk assessment."
- "Perform inspection using inspection techniques with demonstrated
effectiveness. "
The inspectors reviewed the implementation plan and Entergy fleet, corporate
engineering and site engineering procedures. The inspectors also reviewed a summary
report of inspection results, cathodic protection records, and area potential earth current
(APEC) survey results.
The inspectors reviewed the risk assessment, classifications of leakage impacts, and
corrosion risk categorizations addressed in the first three bulleted items above, and
found the evaluation approaches to be sound and generally credible. The inspectors
reviewed the inspection plan based on these evaluations to be reasonable and
appropriate. The inspectors reviewed a sample of inspection records, which showed
that inspections had involved direct visual inspection, followed by external ultrasonic test
(UT) inspections in some cases, and were thorough and appropriate.
The inspectors noted two concerns. First, site engineering procedure SEP-UIP-IPEC
stated that guided wave inspection was an acceptable indirect inspection technique.
Enclosure
5
The inspectors noted that while guided wave inspection was a credible method to inform
other inspections, it did not meet the "demonstrated effectiveness" standard and was not
suitable for inspection by itself. There was no evidence that guided wave inspection had
been solely used to accept inspected piping or tanks, but the procedure merited
clarification on the use of guided wave inspection. Second, Entergy fleet procedure
EN-DC-343 listed the affected Unit 2 underground systems in Attachment 9.2, but
omitted the river water, circulating water, and containment isolation support systems.
There was no immediate impact on the inspection plan given that these actions were not
in effect without a renewed license. However, Entergy will review this matter and they
entered these two concerns into the license renewal corrective action system as item
Given the preliminary progress on Commitment 3, the inspectors determined that
additional inspection was merited on the clarification of the use of guided wave
inspection, coverage of omitted underground systems, and subsequently completed
inspections.
b.4 Annual Updates
10 CFR 54.21 (b) requires each year following submittal of the license renewal
application and at least three months before scheduled completion of the NRC review,
an amendment to the renewal application be submitted that identifies any change to
the current licensing basis (CLB) of the facility that materially affects the contents of the
license renewal application, including the Updated Final Safety Analysis Report
(UFSAR) supplement. The inspectors selected a sample from annual update submittals
for review.
Amendment 8 to the application transmitted by a letter (NL-09-060) dated May 15, 2009.
This amendment was a result of a review of documents affecting the current license
basis during the period May 1, 2008 through March 1, 2009, since the prior annual
update amendment. The review concluded that sections of the application were affected
by changes to the current licensing basis. For example, during this period, the Indian
Point 3 Security Diesel was replaced, affecting Section 3.3.2.1 .15 and Table 3.3.3-15-
IP3 of the application.
This example illustrated Entergy Nuclear Operations, Inc. compliance with 10 CFR
54.21(b).
Summary
No findings were identified and general conditions in the plant areas observed were
satisfactory. The inspectors determined that Entergy actions on four commitments
(Commitments 28,29,34, and 36) were complete and met regulatory expectations as
reflected in the staff's safety evaluation report. Inspection of two commitments
(Commitments 2 and 3) concluded that additional inspection was needed. Further NRC
inspection of Unit 2 commitments, including Commitments 2 and 3, is planned prior to
the scheduled completion date of September 28, 2013.
Enclosure
6
40A6 Exit Meeting
The inspectors presented the inspection results to Mr. John Curry, License Renewal
Project Manager, and other members of the staff on March 8, 2012. The inspectors
confirmed that no proprietary material was examined during the inspection.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
ATTACHMENT
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
J. Curry, License Renewal Team Project Manager
N. Azevedo, Supervisor, Supervisor Engineering Programs
C. Caputo, License Renewal Team
G. Dahl, Licensing Engineer
R. Drake, System Engineer
J. Flagg, License Renewal Team
D. Lach, License Renewal Team
LIST OF DOCUMENTS REVIEWED
General
NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point
Nuclear Generating Unit Nos. 2 and 3, November 2009
NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point
Nuclear Generating Unit Nos. 2 and 3, Supplement 1, August 30, 2011
Entergy Letter NL-11-1 01, Clarification for Request for Additional Information (RAI), dated
August 22, 2011
In-plant Observations
One-Time Inspection Matrix (draft)
One-Time Inspection Form 169473-01
One-Time Inspection Form 51282477-01
WO 00255920, FAC UT of heater drain piping
WO 00255936, FAC UT of reheater drain piping
Commitment 2 (Bolting Integrity)
IP-RPT-11-LRD03, Review of the Bolting Integrity AMP for Implementation, Rev 0 (draft)
O-MS-411, Torquing of Mechanical Fasteners, Rev 3
Enclosure
A-2
Commitment 3 (Buried Piping and Tanks Inspection)
IP-RPT-11-LRD07, Review of the Buried Pipe and Tanks Inspection AMP for Implementation,
Rev 0 (draft)
EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, Rev 4
CEP-UPT -0100, Underground Piping and Tanks Inspection and Monitoring, Rev 0
SEP-UIP-IPEC, Underground Components Inspection Plan, Rev 0
PCA Engineering Inc, Cathodic Protection System Maintenance Record Sheet,
AFW Pump Room Annex - Unit 2, PCA Job No. 30493, 2/28/12
IP-RPT-11-0045, Indian Point Energy Center APEC Survey, 11/17/11
IPEC Underground Piping and Tank Program Completed Buried Pipe Inspections, 1/11112
Thielsch Engineering, Laboratory Testing Data Sheet, 12/12/11
Photographs of NovlDec 2011 inspections of IP2 24" SRW lines 409
(16 pictures dated 11/23/11) and 408 (24 pictures dated 11/23/11)
IP2-UT-11-050, UT Erosion Corrosion Exam - 24 SRW line 409, 12/28/11
IP2-UT-11-048, UT Erosion Corrosion Exam - 24 SRW line 408, 12/28/1, 2 pictures
Inspection Report, IP3 AFWICond Return to CST (8" line 1080), WO 279578-03, 12/9/11,
4 pictures
Inspection Report, IP3 CST Supply to AFW Pumps (12" line 1070), WO 279578-03, 12/9/11,
4 pictures
IP3-UT-11-076, UT EIC Examination IP3 8" line 1080, 12/15/11
IP3-UT-11-077, UT EIC Examination IP3 12"line 1070, 12/15/11
Commitment 28 (Water Chemistry - Closed Cooling)
EPRI TR-107396, Closed Cooling Water Chemistry Guideline, Rev 1
IP-RPT-11-LRD41, Review of the Water Chemistry- Closed Cooling Water AMP for
Implementation, Rev 0 (draft)
0-CY-2510, Closed Cooling Water Chemistry Specifications and Frequencies, Rev 13
IP2 SBP/App R diesel quarterly chemistry results, March 2008 to January 2012
IP2 Fire pump diesel quarterly chemistry results, January 2007 to December 2011
IP2 Security diesel quarterly chemistry results, January 2007 to December 2011
Commitment 29 (RWST Sulfates)
IP-RPT-11-LRD42, Review of the Water Chemistry - Primary and Secondary AMP for
Implementation, Rev 0 (draft)
2-CY-2625, General Plant Systems Specifications and Frequencies, Rev 16
IP2 RWST monthly chemistry results, January 2010 to February 2012
Commitment 36 (Refueling Cavity Concrete)
ER No. IP-RPT-11-00002, Assessment of Concrete Aging From Selected Indian Point
Structures, Rev 0
United Engineers and Constructors Drawing 9321-01-5-1, Specification for Design, Inspection
and Tests of Concrete, High Strength Bolts, Compaction of Fill and Rock Bearing
ASTM C-856-04, Standard Practice for Petrographic Examination of Hardened Concrete
Enclosure
A-3
LIST OF ACRONYMS
ADAMS Agencywide Documents Access and Management System
AMP Aging Management Program
CLB Current licensing Basis
EPRI Electric Power Research Institute
LRA License Renewal Application
NRC U. S. Nuclear Regulatory Commission
RFO Refueling Outage
RWST Refueling Water Storage Tank
SBO Station Blackout
TI Temporary Instruction
UFSAR Updated Final Safety Analysis Report
UT Ultrasonic Test
Enclosure