ML12341A177

Entergy Pre-filed Evidentiary Hearing Exhibit ENT000596, NL-12-149, Letter from F. Dacimo, Entergy, to NRC Document Control Desk, Clarification of Underground Piping Information Provided in Letter NL-11-032 Regarding the License Renewal App

ML12341A177
Person / Time
Site:	Indian Point
Issue date:	10/18/2012
From:	Dacimo F Entergy Nuclear Northeast
To:	Atomic Safety and Licensing Board Panel, Document Control Desk
SECY RAS
References
RAS 23852, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NL-12-149
Download: ML12341A177 (5)

Text

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 ENT000596 Submitted: December 6 , 2012

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-12-149Page 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-12-149Page 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 boundaryCopper AlloyAir - outdoor (ext)Loss of material Buried Piping and Tanks Inspection

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