NL-13-037, Indian Point, Units 2 & 3 - Revision to the Response to Request for Additional Information (RAI) Aging Management Programs

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Indian Point, Units 2 & 3 - Revision to the Response to Request for Additional Information (RAI) Aging Management Programs
ML13074A020
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/05/2013
From: Dacimo F R
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-037
Download: ML13074A020 (5)


Text

vEntergy Enterpy 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 License Renewal NL-13-037 March 5, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

REFERENCE:

Revision to the Response to Request for Additional Information (RAI)Aging Management Programs Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 1. Entergy Letter NL-1 1-032, "Response to Request for Additional Information (RAI) Aging Management Programs," dated March 28, 2011.2. Draft License Renewal Interim Staff Guidance, LR-ISG-2011-03,"Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2, Aging Management Program XI.M41, "Buried and Underground Piping and Tanks".3. Final License Renewal Interim Staff Guidance, LR-ISG-2011-03,"Changes to the Generic Aging Lessons Learned (GALL) Report Revision 2, Aging Management Program XI.M41, "Buried and Underground Piping and Tanks", published on August 2, 2012.

Dear Sir or Madam:

In Reference 1, Entergy responded to RAI 3.0.3.1.2-1 which requested additional information related to the number of total and direct visual inspections of license renewal in-scope piping during the 10 years prior to entering the period of extended operation (PEO) and during each 10 year period during the PEO. The response provided in Reference 1 was based on draft Interim Staff Guidance (ISG) LR-ISG-2011-03 (Reference

2) which classified buried piping as either safety-related or containing hazardous material.

When the final version of the ISG was issued (Reference 3), the safety-related and the hazardous material categories were combined into one category.

This change was implemented to allow licensees to select inspection locations based on plant-specific risk ranking rather than piping categories.

fooi Docket Nos. 50-247 & 50-286 NL-13-037 Page 2 of 2 The purpose of this letter is to revise the response to parts la, lb and ic of RAI 3.0.3.1.2-1 to be consistent with the recommendations provided in Reference

3. Since IPEC has limited amounts of buried piping containing hazardous material, this change will allow inspections of more buried piping in safety-related systems in lieu of performing multiple inspections of piping in the same system containing hazardous materials.

The revised response does not impact the Buried Piping and Tanks Inspection Program descriptions provided in the LRA UFSAR Supplement.

Attachment 1 provides the revised responses to parts la, lb and 1c of RAI 3.0.3.1.2-1.

There are no new regulatory commitments in this submittal.

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 Sin FRD/rw

Attachment:

1. Revised Response to Request for Additional Information (RAI), Aging Management Programs 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. Nathaniel Ferrer, NRC Project Manager, Division of License Renewal 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 1 TO NL-13-037 LICENSE RENEWAL APPLICATION REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)AGING MANAGEMENT PROGRAMS ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286 Docket Nos. 50-247 and 50-286 NL-13-037 Attachment 1 Page 1 of 2 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION REVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION (RAI)AGING MANAGEMENT PROGRAMS Changes are shown as strikethroughs for deetieins and underlines for additions.

NRC Request RAI 3.0.3.1.2-1 Part la 1. Respond to the following:

a. Describe how many in-scope buried piping segments for each material, code/safety-related piping, and potential to release materials detrimental to the environment category will be inspected.

Revised Response for RAI 3.0.3.1.2-1 Part la For the 10-year period prior to the PEO, the following table presents the planned inspections for buried piping subject to aging management review that is code/safety-related or has the potential to release materials detrimental to the environment (Code/SR/Hazmat) (ha.mat..

Inspections by material a44d Gateg.ey are indicated.

Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR/Hazmat 43 26 4-4 19 GaCben steel Haizmat 4-3 6 Stainless steel Code/SR/Hazmat N/A 6 NRC Request RAI 3.0.3.1.2-1 Part lb b. For the 45 planned inspections prior to the period of extended operation:

i. How many will consist of an excavated direct visual inspection of the external surfaces of the buried pipe?ii. What length of piping will be excavated and have a direct visual inspection conducted?

Revised Response for RAI 3.0.3.1.2-1 Part lb The following table provides the number of planned direct visual inspections prior to the PEO. For planned direct visual inspections, future excavations will expose a minimum of 10 linear feet of pipe, for full circumferential inspections.

Ten completed inspections have ranged from approximately five feet to more than ten feet averaging approximately eight linear feet.Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR/Hazmat 9 20 8 11 Gazbem stee4 Haz4at 4 3 Stainless steel Code/SR/Hazmat N/A 3 Docket Nos. 50-247 and 50-286 NL-13-037 Attachment 1 Page 2 of 2 NRC Request RAI 3.0.3.1.2-1 Part lc c. Understanding that the total number of inspections performed will be informed by plant-specific and industry operating experience, what minimum number of inspections of buried in-scope piping is planned during the 40 -50 and 50 -60 year operating periods? When describing the minimum number of planned inspections, differentiate between material, code/safety-related piping, and potential to release materials detrimental to the environment category piping inspection quantities of buried in-scope piping.Revised Response for RAI 3.0.3.1.2-1 Part lc IPEC will perform direct visual inspections during each 10-year period of the PEO in accordance with the following table. The table lists inspections for different materials, for code/safety-related piping, and for piping with the potential to release materials detrimental to the environment (indicatd as hazmat.)Material Category IP2 Inspections IP3 Inspections Carbon steel Code/SR/Hazmat 6 14 6 14 H_____ steelHzmt a 8 Stainless steel Code/SR/Hazmat N/A 2 If sample results indicate the soil is corrosive as described in the response to 2.c belew in Reference 1, then the number of inspections for the carbon steel code/safety-related/hazmat piping will be increased to eight and the numb.. of inspOction.

for the carbon hazmat piping will be ...rcascd t4 1-2 20.