ML15169A758
| ML15169A758 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/18/2015 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| Download: ML15169A758 (8) | |
Text
IPRenewal NPEmails From: Wentzel, Michael Sent: Thursday, June 18, 2015 1:13 PM To: Louie, Richard (rlouie@entergy.com)
Subject:
Draft RAI Set 2015-02 Attachments: IP RAI Set 2015-02.docx
- Rich, Attached is a draft of RAI set 2015-02, which are follow-up RAIs to Entergys March 10, 2015 responses to the LR-ISG-2013-01 RAIs. Once you and your staff have a chance to review the RAIs, please let me know if you would like to have a phone call to clarify.
- Thanks, Mike Michael Wentzel Project Manager NRR/DLR/RPB2 (301) 415-6459 michael.wentzel@nrc.gov 1
Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 5199 Mail Envelope Properties (f3f859cb89b84e9ebdc6073b6be6b933)
Subject:
Draft RAI Set 2015-02 Sent Date: 6/18/2015 1:12:59 PM Received Date: 6/18/2015 1:13:00 PM From: Wentzel, Michael Created By: Michael.Wentzel@nrc.gov Recipients:
"Louie, Richard (rlouie@entergy.com)" <rlouie@entergy.com>
Tracking Status: None Post Office: HQPWMSMRS02.nrc.gov Files Size Date & Time MESSAGE 450 6/18/2015 1:13:00 PM IP RAI Set 2015-02.docx 87938 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
UNITTED STATES S NUCL LEARREGU ULATORY COMMISSIO C ON WASHINGTTON, D.C. 20555 5-0001 Vice Pressident, Operrations Entergy Nuclear N Opeerations, Inc.
Indian Po oint Energy Center 450 Broa adway, GSB P.O. Boxx 249 Buchana an, NY 10511-0249 SUBJEC CT: REQU UEST FOR ADDITIONA A AL INFORMA ATION FOR THE REVIE EW OF THE INDIA AN POINT NUCLEAR GENERATING G UNIT NOS S. 2 AND 3, LICENSE RENE EWAL APPL LICATION, SETS 2015-02 2 (TAC NOS S. MD5407 ANDA MD54008)
Dear Sir or Madam:
By letter dated April 23, 2 2007, ass supplemen nted by letterrs dated May 3, 2007, and June 21, 2007, Enterrgy Nuclear Operations, Inc. (Enterg gy) submitted an applica ation pursuant to Title 10 of o theCode of o Federal RegulationsPart 54 to ren new the operrating licensses for Indian n Point Nuclear Generrating Unit Nos. 2 and 3 to the U.S. NuclearN Reg gulatory Com mmission (NRC).
The NRC C staff docum mented its findings in the e Safety Eva aluation Rep port (SER) reelated to the e
license reenewal of In ndian Point Nuclear N Generating Unit Nos. 2 and 3, which wa as issued Auugust 11, 20099 and supplemented Aug gust 30, 2011 (SER Supplement 1), and November 6, 2014 (SER Supplement 2)).
Subsequ uent the issuance of SER R Supplement 1, the staff identified additional a opperating experience at severa al nuclear poower plants regarding r losss of coating g integrity off internal coatings.. To address this operating experience, on Novvember 14, 2014, 2 the NRRC staff issu ued interim sttaff guidance e document LR-ISG-201 13-01, "Aging Managem ment of Loss of Coating oro Lining Inttegrity for Internal Coatinngs/Linings on In-Scope e Piping, Pipping Compon nents, Heat Exchangers, and Tan nks.
By letterss dated April 1, 2014 and Decemberr 2, 2014, the NRC stafff requested additionala information as to how w Entergy planned to ma anage the efffects of agin ng as described in LR-ISSG-2013-01.. By letter da ated March 10, 2015, Entergy respo onded to the e NRC staffss request forr additionaal information n. Based on n its review of o the inform mation contaiined in Entergys letter, the t
NRC stafff requests additional a infformation ass described in the enclossure.
This RAI was discuss sed with Mr.. Richard Loouie, and a mutually m agreeeable date for Entergys response e is within 300 days from the date of this t letter.
If you have any questions, please contact me at 301-415-6459, or by email at michael.wentzel@nrc.gov.
Sincerely, Michael Wentzel, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
As stated cc w/encl: Listserv
- concurred via email OFFICE LA:DLR PM: DLR/RPB2 BC:DLR/RPB1 PM: DLR/RPB2 NAME MWentzel YDiaz-Sanabria MWentzel DATE
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 2015-01 (TAC NOS. MD5407 AND MD5408)
DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRsrg Resource RidsNrrDraAfpb Resource RidsNrrDeEvib Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsNrrPMIndianPoint Resource YDiaz MGray, RI MWentzel ABurritt, RI WHolston DonaldJackson, RI DPickett MModes, RI STurk, OGC NSheehan, RI OPA BMizuno, OGC DScrenci, RI OPA DRoth, OGC DTifft, RI BHarris, OGC NMcNamara, RI SBurnell, OPA GNewman, RI DMcIntyre, OPA JSStewart, RI JWeil, OCA AmiPatel, RI
REQUEST FOR ADDITIONAL INFORMATION (RAI), SET 2015-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 (IP2 and IP3)
LICENSE RENEWAL APPLICATION DOCKET NOS. 50-247 AND 50-286 REGARDING LR-ISG-2013-01 RAI 3.0.3-16
Background
As amended by letter dated March 10, 2015, LRA Table 3.3.2-19-43-IP3, Pressurizer System, states that loss of coating integrity is managed for metal components with internal coating in a treated borated water > 140°F environment by the Coating Integrity Program.
Issue Environments with high temperatures are not evaluated to be bounding within the assumptions of GALL AMP XI.M42, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.The changes to the LRA do not state the specific coating material used in systems with temperatures exceeding 140°F. Therefore, the staff lacks sufficient information to conclude that the recommendations in AMP XI.M42 (e.g., inspection intervals, acceptance criteria) are sufficient for the materials exposed to temperatures greater than 140°F.
Request State the coating materials exposed to temperatures greater than 140°F. Provide the basis for concluding that loss of coating integrity is adequately managed in the subject environment.
RAI 3.0.3-17
Background
As amended by letter dated March 10, 2015, LRA Sections A.2.1.42, A.3.1.42, and B.1.43,Coating Integrity, state that the Coating Integrity Program will be implemented by December 31, 2024. In addition, Commitment 8, as revised, states that LRA Sections A.2.1.13, A.3.1.13 and B.1.14, Fire Water System, will be implemented by December 31, 2019.
Issue The implementation schedule for LRA Section B.1.43 ranges up to nine years, from 2015 to 2024. In addition, implementation of Commitment 8, as revised,ranges from 2015 to 2019.
SRP-LR Table 3.0-1 for AMP XI.M42 states that the first inspections of internal coatings should be completed no later than the last refueling outage prior to the period of extended operation.
The staff recognizes that Indian Point Unit 2 has entered timely renewal and Indian Point Unit 3 may shortly enter timely renewal. As such, it does not appear that the inspection section schedule recommended in Table 3.0-1 will be met. Further, it is not clear to the staff how loss of coating integrity will be managed in the time frame prior to the programs being implemented.
Request State how loss of coating integrity will be managed between now and the proposed implementation dates and the basis for concluding that coating integrity will be adequately managed in this time period.
RAI 3.0.3-18
Background
ENCLOSURE
As amended by letter dated March 10, 2015, LRA Section B.1.14,Fire Water System, provides an enhancement to the corrective actions program element associated with returning degraded coatings (i.e., peeling, delaminated, or blistered) coatings to service without repair, replacement or removal. No exceptions related to conducting adhesion testing are stated in LRA Section B.1.43, Coating Integrity.
Issue GALL Report AMP XI.M42, element 7, corrective actions,recommendsthat the coatings/linings for in-scope components that do not meet acceptance criteria arerepaired, replaced, or removed. GALL Report AMP XI.M42 allows an alternative, which recommends, among other things, that adhesion testing be performed before returning degraded (i.e., peeling, delaminated, or blistered) coatings to service. For the alternative for returning a coating exhibiting peeling and delamination to service without repair, the Fire Water System program does not include adhesion testing as part of the alternative. In addition, the enhancement states that for coatings exhibiting blistering, light tapping of the coating will be performed to determine the extent of blistering. AMP XI.M42 only recommends the use of light tapping when it is physically impossible to perform adhesion testing.
LRA Section B.1.14 did not state an exception to adhesion testing even though the proposed changes to the Fire Water System program were not consistent with GALL Report AMP XI.M42.
LRA Section B.1.43 does not state an exception to adhesion testing. It is not clear to the staff whether adhesion testing will be conducted prior to returning degraded coatings/linings within the scope of the Coating Integrity Program to service.
Request
- 1. State whether the Coating Integrity Program will include adhesion testing prior to returning degraded coatings/linings to service.
- 2. If the Coating Integrity Program does not include adhesion testing for returning degraded coatings/linings to service, explain why adhesion testing is not needed as part of the alternative for returning degraded coatings to service for in-scope fire water system components.