NL-13-132, Reply to Request for Additional Information Regarding the License Renewal Application

Reply to Request for Additional Information Regarding the License Renewal Application

ML13282A140
Person / Time
Site:	Indian Point
Issue date:	10/03/2013
From:	Dacimo F Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-132
Download: ML13282A140 (10)

Text

Enterav Nuclear Northeast Indian Point Energy Center EnterWy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimno Vice President Operations License Renewal NL-13-132 October 3, 2013 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Reply to Request for Additional Information 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:

NRC letter, "Request for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, SET 2013-05" dated September 3, 2013

Dear Sir or Madam:

Entergy Nuclear Operations, Inc is providing, in the attachment, the additional information requested in the referenced letter pertaining to NRC review of the License Renewal Application (LRA) for Indian Point 2 and Indian Point 3.

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 Jnd r penalty of perjury that the foregoing is true and correct. Executed on S7, 2013.

FRD/rw

Docket Nos. 50-247 & 50-286 NL-13-132 Page 2 of 2

Attachment:

Reply to NRC Request for Additional Information Regarding the License Renewal Application 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 Ms. Kimberly Green, 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 TO NL-13-132 REPLY TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE LICENSE RENEWAL APPLICATION ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NOS. 50-247 AND 50-286

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 1 of 7 INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION (LRA)

REQUESTS FOR ADDITIONAL INFORMATION (RAI)

RAI 3.0.3.1.2-4a

Background:

The response to RAI 3.0.3.1.2-4 dated July 24, 2013 stated the following in relation to crediting the cathodic protection (CP) system:

" "[t]he IPEC CP systems will not be credited as preventive measures for the in-scope buried piping."

" "[t]o the extent they are proven effective, the CP systems at IPEC will be considered in risk ranking to ensure that the in-scope buried piping systems that are more susceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority."

" "[t]herefore, no revision to License Renewal Application Sections A.2.1.5 and A.3.1.5 is necessary because Entergy is not crediting the CP system as a preventive measure for in-scope buried piping."

The response to RAI 3.0.3.1.2-4 further stated the following in regard to using the 1OOmV polarization criterion to demonstrate effectiveness of CP system performance:

• "[f]or existing CP systems, corrosion monitoring probes may be installed near pipe depth to ensure that the pipe of concern is being adequately protected given the possible presence of mixed metal potentials."

" "[t]he failure to meet the 100 mV polarization criterion (which is not uncommon in dry, high-resistance soils) during a new CP system commissioning would prompt further investigation. For example, in that circumstance, corrosion coupons or corrosion probes can be used to confirm the low corrosivity of the in situ soils, such that CP and compliance with the NACE SP0169 CP system effectiveness criteria are not necessary."

Issue:

The staff understands that the CP system will not be credited as a preventive measure for in-scope buried piping. The staffs evaluation of the acceptability of the Buried Piping and Tanks Inspection Program without crediting CP is documented in Safety Evaluation Report Section 3.0.3.1.2. However, the CP system is being credited in regard to risk ranking inspection locations. As such, the program should reflect the purpose of the CP system and its acceptance criteria (e.g., annual testing to confirm 85 percent availability, 80 percent effectiveness, a polarization potential of at least 850 mV instant-off, and upper voltage acceptance criterion of 1200 mV instant-off) that will be used when risk ranking inspection locations. Also, the updated Final Safety Analysis Report (UFSAR)

Supplement should reflect the purpose of the CP system.

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 2 of 7 While the staff recognizes that buried coupons, electrical resistance probes, or placement of reference cells can be used as effective means to detect corrosion rates or localized effectiveness of CP when using the 100 mV polarization criterion in a mixed metal environment, the program does not state details such as what industry consensus document(s) will be used to install the devices, device placement, coupon characteristics, analysis of device results (e.g., how pitting rates versus general corrosion rates will be differentiated), how acceptance criteria will be established, and how many inspections of buried pipe will occur during the time period when the CP effectiveness is indeterminate.

Request:

1. Revise the Buried Piping and Tanks Inspection Program to include the purpose of the CP system and acceptance criteria that will be used when risk ranking inspection locations.

2. Revise the Buried Piping and Tanks Inspection Program UFSAR Supplement to reflect the purpose of the CP system.

3. If the 100 mV polarization criterion will be used in a mixed metal environment, respond to the following:

a. State which industry consensus documents will be used to install and use the corrosion rate monitoring devices or reference electrodes.

b. State the acceptance criteria for general and pitting corrosion rates when using electrical resistance probes or coupons.

c. State how many inspections of buried pipe will occur during the time period when the CP effectiveness is indeterminate.

d. If coupons will be used, respond to questions i through iii.

i. Des cribe the corrosion coupon characteristics, including:

• the type of coupon to be used (e.g., free-corrosion coupon, polarized and native coupon pair, gravimetric, electrical resistance probe);

• whether the coupons will be coated with an intentionally embedded holiday;

• the surface condition (e.g., presence of scale and corrosion products, surface finish) of coupons; and

• the composition of the coupon compared to the pipe (e.g., chemical composition and microstructure).

ii. Des cribe the coupon placement, including:

• how coupon locations will be selected so that they will be representative of the CP conditions at the point of interest;

" the number of coupons that will be buried for each linear length of buried pipe;

• coupon size and orientation with respect to the pipe, for example, how close both in distance and elevation the coupons will be installed to the pipe; and whether coupon will be perpendicular or parallel with the pipe;

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 3 of 7

• the length of time coupons will be allowed to be buried;

• how many years the coupons will be buried prior to accepting results;

• for a given portion of pipe, how will the impact of localized soil parameters, such as soil resistivity, soil chemistry, moisture content, temperature and microbiological activity, be considered;

• how voids in the backfill will be avoided when installing coupons; and

• how seasonal variability will be accounted for on soil characteristics.

iii. Describe the analysis of coupon results, including:

" what guidance will be used regarding coupon cleaning, corrosion rate calculations, and data reporting; and

• how pitting rates versus general corrosion rates will be differentiated.

Response to RAI 3.0.3.1.2-4a

1. The following changes are made to Appendix B.1.6 to include the purpose of the CP system and acceptance criteria that will be used when risk ranking inspection locations.

Changes are shown with underline for additions.

B.1.6 BURIED PIPING AND TANKS INSPECTION PErogram Description The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried and underground carbon steel, gray cast iron, copper alloy and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement. The program applies to buried components in the following systems.

" Safety injection

" Service water

" Fire protection

• Fuel oil

" Security generator

• City water

" Plant drains

" Auxiliary feedwater

" Containment isolation support

• River water service (IP1)

• Circulating Water System (IP2)

• Instrument Air (IP2)

Docket Nos. 50-247 & 50-286 NL-1 3-132 Attachment Page 4 of 7 Of these systems, only the safety injection system contains radioactive fluids during normal operations. The safety injection system buried components are stainless steel. Stainless steel is used in the safety injection system for its corrosion resistance. This program also applies to underground components in the IP3 service water and city water systems and the IP2 and IP3 fuel oil systems.

Cathodic protection systems installed at IPEC provide additional protection of license renewal in-scope buried piping and minimize corrosion in areas that have been found susceptible to corrosion based on indirect inspections (i.e., guided wave inspections) or testing (e.g., AP-EC surveys). To the extent they are proven effective, the CP systems at IPEC will be considered in risk ranking to ensure that the in-scope buried piping systems more susceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority.

The CP systems will be monitored with the following acceptance criteria.

• Minimum -850 mV instant-off soil-to-pipe potential relative to a copper/copper sulfate reference electrode

• Maximum -1200 mV instant-off soil-to-pipe potential relative to a copper/copper sulfate reference electrode

• Minimum availability of 85%. The percent of system availability is calculated by determining the percent of the time the rectifiers are in service providing cathodic protection. "In service" is defined as rectifier current output values greater than zero amps or zero volts. The time the system is out of service for testing is not included in the calculation of system availability.

• Minimum of 80% CP system effectiveness. Test locations must meet a soil-to-pipe potential of instant-off -850 mV to -1200 mV relative to a copper/copper sulfate reference electrode. The percent of CP effectiveness is calculated by using the last measured values at each test station and dividing the total number of CP survey points that meet the required acceptance criteria by the total number of points surveyed during the monitoring period.

Failure to meet these acceptance criteria will result in no credit being taken for the CP system in the risk ranking process.

The Buried Piping and Tanks Inspection Program will be modified based on operating experience to include a risk assessment of in-scope buried piping and tanks that includes consideration of the impacts of buried piping tank or tank leakage and of conditions affecting the risk for corrosion. The program will classify pipe segments and tanks as having a high, medium or low impact of leakage based on the safety class, the hazard dosed by fluid contained in the piping and the impact of leakage on reliable plant operation.

Corrosion risk will be determined through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment.

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 5 of 7 Inspections will be performed using qualified inspection techniques with demonstrated effectiveness. Inspections will begin prior to the period of extended operation.

Prior to entering the period of extended operation, plant operating experience will be reviewed and multiple inspections will be completed within the past ten years. Additional periodic inspections will be performed within the first ten years of the period of extended operation.

Underground piping within the scope of license renewal and subject to aging management review will be visually inspected prior to the period of extended operation and then on a frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed.

Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

The program will be implemented prior to the period of extended operation.

NUREG-1801 Consistency The Buried Piping and Tanks Inspection Program will be consistent with program attributes described in NUREG-1801,Section XI.M34, Buried Piping and Tanks Inspection.

2. The following changes are made to Appendix A of the LRA to reflect the purpose of the CP system. Additions are shown with underline.

A.2.1.5 Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried and underground carbon steel, copper alloy, gray cast iron, and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement. Cathodic protection (CP) systems installed at IPEC provide additional protection of license renewal in-scope buried piping and minimize corrosion in areas that have been found susceptible to corrosion based on indirect inspections or testing. To the extent they are proven effective, the CP systems at IPEC will be considered in risk ranking to ensure that the in-scope buried piping systems that are more susceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority.

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 6 of 7 1P2 will perform 20 direct visual inspections of buried piping during the 10 year period prior the PEO. IP2 will perform 14 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years in the PEO. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 20 during each 10-year period of the PEO.

The Buried Piping and Tanks Inspection Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection with the following modification.

The Buried Piping and Tanks Inspection Program will be modified based on operating experience to include a risk assessment of 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. The program will 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. Corrosion risk will be determined through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment. Inspections will be performed using qualified inspection techniques with demonstrated effectiveness, Inspections will begin prior to the period of extended operation. Underground piping within the scope of license renewal and subject to aging management review will be visually inspected prior to the period of extended operation and then on a frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

A.3.1.5 Buried Piping and Tanks Inspection Program The Buried Piping and Tanks Inspection Program is a new program that includes (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried and underground carbon steel, gray cast iron, copper alloy and stainless steel components. Preventive measures are in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components are inspected when excavated during maintenance. If trending within the corrective action program identifies susceptible locations, the areas with a history of corrosion problems are evaluated for the need for additional inspection, alternate coating, or replacement. Cathodic protection (CP) systems installed at IPEC provide additional protection of license renewal in-scope buried piping and minimize corrosion in areas that have been found susceptible to corrosion based on indirect

Docket Nos. 50-247 & 50-286 NL-13-132 Attachment Page 7 of 7 inspections or testing. To the extent they are proven effective, the CP systems at IPEC will be considered in risk rankinq to ensure that the in-scope buried piping systems that are more susceptible to external corrosion continue to receive a higher risk ranking when determining inspection priority.

IP3 will perform 14 direct visual inspections of buried piping during the 10 year period prior the PEO. IP3 will perform 16 direct visual inspections during each 10-year period of the PEO. Soil samples will be taken prior to the PEO and at least once every 10 years into the PEO. Soil will be tested at a minimum of two locations at least three feet below the surface near in-scope piping to determine representative soil conditions for each system. If test results indicate the soil is corrosive then the number of piping inspections will be increased to 22 during each 10-year period of the PEO.

The Buried Piping and Tanks Inspection Program will be implemented prior to the period of extended operation. This new program will be implemented consistent with the corresponding program described in NUREG-1801 Section XI.M34, Buried Piping and Tanks Inspection with the following modification.

The Buried Piping and Tanks Inspection Program will be modified based on operating experience to include a risk assessment of 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. The program will 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. Corrosion risk will be determined through consideration of piping or tank material, soil resistivity, drainage, the presence of cathodic protection and the type of coating. Inspection priority and frequency for periodic inspections of the in-scope piping and tanks will be based on the results of the risk assessment. Inspections will be performed using qualified inspection techniques with demonstrated effectiveness, Inspections will begin prior to the period of extended operation. Underground piping within the scope of license renewal and subject to aging management review will be visually inspected prior to the period of extended operation and then on a frequency of at least once every two years during the period of extended operation. This inspection frequency will be maintained unless the piping is subsequently coated in accordance with the preventive actions specified in NUREG-1801 Section XI.M41 as modified by LR-ISG-2011-03. Visual inspections will be supplemented with surface or volumetric non-destructive testing if indications of significant loss of material are observed. Consistent with revised NUREG-1801 Section XI.M41, such adverse indications will be entered into the plant corrective action program for evaluation of extent of condition and for determination of appropriate corrective actions (e.g., increased inspection frequency, repair, replacement).

3. For the purpose of crediting the cathodic protection system in regard to risk ranking inspection locations, IPEC will utilize the polarization potential of at least (i.e. more negative than) -850 mV instant-off as the acceptance criteria. Test locations which do not meet this soil-to-pipe potential of instant-off -850 mV to -1200 mV relative to a copper/copper sulfate reference electrode will be considered as not meeting the acceptance criteria when calculating the system effectiveness.