NL-13-046, Amendment 13 to License Renewal Application (LRA) Pertaining to One-Time Inspection and Selective Leaching Programs

Amendment 13 to License Renewal Application (LRA) Pertaining to One-Time Inspection and Selective Leaching Programs

ML13094A369
Person / Time
Site:	Indian Point
Issue date:	03/18/2013
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-046
Download: ML13094A369 (9)

Text

Entergy Nuclear Northeast m-ý= Enteagy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal NL-13-046 March 18, 2013 Document Control D~esk U. S. Nuclear Regulatory Commission Mail Stop O-P1-17 Washington, D.C. 20555-0001

SUBJECT:

Amendment 13 to License Renewal Application (LRA) pertaining to One-Time Inspection and Selective Leaching Programs Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 REFERENCE 1 Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application" (NL-07-039)

Dear Sir or Madam:

In the referenced letter, Entergy Nuclear Operations, Inc., applied for renewal of the Indian Point Energy Center operating licenses. Attachment 1 to this letter contains Amendment 13 of the License Renewal Application (LRA), pertaining to the one-time inspection and selective leaching programs. This change is to establish the sample size for these programs consistent with current NRC guidance.

Should you have any questions concerning this report, please contact Mr. Robert W. Walpole, Licensing Manager, at (914) 254-6710.

NL-13-046 Dockets 50-247 and 50-286 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 18, 2013.

Sincerely, FRD/ai

Attachment:

1. License Renewal Application Amendment cc: Mr. William Dean, Regional Administrator, NRC Region 1 Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dennis Morey, NRC Chief, Projects Branch 1 Mr. Dave Wrona, NRC Chief, Projects Branch 2 Mr. Nathaniel Ferrer, Project Manager, NRC NRR DOLR Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL NRC Resident Inspector's Office Ms. Bridget Frymire, NYS Dept. of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA

ATTACHMENT 1 TO NL-13-046 License Renewal Application Amendment Additions Underlined Deletions Lined Out ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 DOCKET NOS. 50-247 & 50-286

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 1 of 6 B.1.27 One-Time Inspection Proaram Descriotion The One-Time Inspection Program is a new program that includes measures to verify effectiveness of an aging management program (AMP) and confirm the absence of an aging effect. For structures and components that rely on an AMP, this program will verify effectiveness of the AMP by confirming that unacceptable degradation is not occurring and the intended function of a component will be maintained during the period of extended operation. One-time inspections may be needed to address concerns for potentially long incubation periods for certain aging effects on structures and components. There are cases where either (a) an aging effect is not expected to occur but there is insufficient data to completely rule it out, or (b) an aging effect is expected to progress very slowly. For these cases, there will be confirmation that either the aging effect is indeed not occurring, or the aging effect is occurring very slowly as not to affect the component or structure intended function. A one-time inspection of the subject component or structure is appropriate for this verification. The inspections will be nondestructive examinations (including visual, ultrasonic, and surface techniques).

The elements of the program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation. The program will include activities to confirm the absence of aging effects as described below.

A one-time inspection activity is used to verify the effectiveness of the water chemistry control programs by confirming that unacceptable cracking, loss of material, and fouling is not occurring on components within systems covered by water chemistry control programs.

A one-time inspection activity is used to verify the effectiveness of the Oil Analysis Program by confirming that unacceptable cracking, loss of material, and fouling is not occurring on components within systems covered by the Oil Analysis Program.

A one-time inspection activity is used to verify the effectiveness of the Diesel Fuel Monitoring Program by confirming that unacceptable loss of material and fouling is not occurring on components within systems covered by the Diesel Fuel Monitoring Program.

One-time inspection activities on the following confirm that loss of material is not occurring or is so insignificant that an aging management program is not warranted.

• Internal surfaces of drain system stainless steel piping, tubing, and valve bodies exposed to raw water (drain water) in EDG buildings, primary auxiliary buildings, and electrical tunnels.

Also included are drains in the IP3 auxiliary feed pump building

• Internal surfaces of stainless steel valve bodies in the station air containment penetration exposed to condensation

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 2 of 6

" Internal surfaces of stainless steel dryer housing, filter housings, piping, tubing, strainers, and valve bodies in the IP1 station air system exposed to condensation

" Internal surfaces of stainless steel piping, tubing, strainers, and valve bodies in the IP1 station air system exposed to condensation

• Internal surfaces of stainless steel piping, strainers, strainer housings, tanks, tubing and valve bodies exposed to condensation in the emergency diesel generator (EDG) starting air subsystem

• Internal surfaces of the carbon steel tanks, piping and valve bodies and stainless steel drain pans and flex hoses in the RCP oil collection system

• Internal surfaces of auxiliary feedwater system stainless steel tubing and valve bodies exposed to treated water (city water)

" Internal surfaces of stainless steel piping and valve bodies in the containment penetration for gas analyzers exposed to condensation

" Internal surfaces of circulating water (CW) system stainless steel or CASS piping, piping elements and components containing raw water IP2

• Internal surfaces of intake structure (DOCK) system stainless steel piping, piping elements and components containing raw water

• Internal surfaces of chemical feed (CF) system stainless steel tanks, pump casings, piping, piping elements and components containing treated water

" Internal surfaces of city water (CYW) system stainless steel and CASS flex hoses, piping, piping elements and components , strainers, strainer housings, tubing and valve bodies containing treated water (city water)

" Internal surfaces of emergency diesel generator (EDG) system stainless steel piping, piping elements and components containing condensation or treated water (city water)

• Internal surfaces of fresh water cooling (FWC) system stainless steel piping, piping elements and components containing treated water (city water)

• Internal surfaces of integrated liquid waste handling (ILWH) system stainless steel tanks, pump casings, piping, piping elements and components containing raw water

• Internal surfaces of the lube oil (LO) system aluminum tanks, piping, piping elements and components containing raw water

• Internal surfaces of the river water service system (RW) stainless steel piping, piping elements and components'containing raw water

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 3 of 6

• Internal surfaces of the waste disposal (WDS) system stainless steel and CASS tanks, pump casings, piping, piping elements and components containing raw water

• Internal surfaces of the water treatment plant (WTP) system stainless steel piping, piping elements and components containing treated water (city water)

" Containment liner affected by the 1973 event behind the insulation to assure liner degradation is not occurring

" Sample of potentially affected refueling cavity concrete obtained by core boring the refueling cavity wall in an area susceptible to exposure to borated water leakage. Include an assessment of embedded reinforcing steel.

IP3

• Internal surfaces of the ammonia/morpholine addition (AMA) system stainless steel piping, piping elements and components containing treated water

" Internal surfaces of the boron and layup chemical addition (BLCA) system stainless steel tanks, pump casings, piping, piping elements and components containing treated water

" Internal surfaces of city water makeup (CWM) system stainless steel and CASS piping, piping elements and components containing treated water (city water)

" Internal surfaces of the gaseous waste disposal (GWD) system CASS piping, piping elements and components containing condensation

• Internal surfaces of the hydrazine addition (HA) system stainless steel tanks, pump casings, piping, piping elements and components containing treated water

• Internal surfaces of the liquid waste disposal (LWD) system stainless steel and CASS tanks, pump casings, piping, piping elements and components containing raw water or treated water (city water)

" Internal surfaces of the nuclear equipment drain (NED) system stainless steel tanks, piping, piping elements and components containing raw water

• Containment steel liner at the juncture with the concrete floor slab to assure liner degradation is not occurring The representative sample size will be based on Chapter 4 of EPRI document 107514, Age Related DogradatiOn InspectinR Method and Domonstration, which out-iner, a mo-thod to determino the1umb. r of inspecti.nst requir*ed for 90,%cnfidemne that 90.. of the

. population

. does Rot e.perience degradation (90/90)-NUREG-1801, Revision 2, where the sample size for the one-time inspection program is at least 20% of the population or a maximum of 25 components.

Each group of components with the same material-environment combination is considered a separate population.

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 4 of 6 When evidence of an aging effect is revealed by a one-time inspection, routine evaluation of the inspection results will identify appropriate corrective actions.

The inspection will be performed prior to the period of extended operation.

NUREG-1801 Consistency The One-Time Inspection Program will be consistent with the program described in NUREG-1 801, Section Xl.M32, One-Time Inspection.

Exceptions to NUREG-1801 None Enhancements None Operatina Experience The One-Time Inspection Program is a new program. Plant and industry operating experience will be considered when implementing this program. The scope of the inspections and inspection techniques are consistent with proven industry practices for managing the effects of aging.

The One-Time Inspection Program is based on the program description in NUREG-1 801, which in turn is based on industry operating experience. As such, operating experience assures that implementation of the One-Time Inspection Program will manage the effects of aging such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.

Conclusion The One-Time Inspection Program provides assurance that the Water Chemistry Control, Diesel Fuel Monitoring, and Oil Analysis programs will be effective in managing the effects of aging to ensure component intended functions can be maintained in accordance with the current licensing basis (CLB) through the period of extended operation. In addition, the One-Time Inspection Program will confirm the absence of significant aging effects on specific system components where significant aging effects are not expected.

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 5 of 6 B.1.33 Selective Leaching Proaram Description The Selective Leaching Program is a new program that will ensure the integrity of components made of gray cast iron, bronze, brass, and other alloys exposed to raw water, treated water, or groundwater that may lead to selective leaching. The program will include a one-time visual inspection, hardness measurement (where feasible based on form and configuration) or other industry-accepted mechanical inspection techniques of selected components that may be susceptible to selective leaching to determine whether loss of material due to selective leaching is occurring, and whether the process will affect the ability of the components to perform their intended function through the period of extended operation. The selected set or representative sample size will be based on Chapter 4 of EPR! docu-met 107514, Age Related Degradation Inspection Method and Domoenstration, which outlines a;Method to determine the num~ber of inepectio* , required for 90-% confidence that 90%oX of the population does not exPeFience degradation (@0W90) NUREG-1 801, Revision 2 where the sample for the selective leaching prog ram is at least 20% of the population or a maximum of 25 components. Each group of components with the same material-environment combination is considered a separate population.

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

NUREG-1801 Consistency The Selective Leaching Program will be consistent with the program described in NUREG-1 801,Section XI.M33 Selective Leaching of Materials.

ExceDtions to NUREG-1 801 None Enhancements None Operatin9 Experience The Selective Leaching Program is a new program. Plant and industry operating experience will be considered when implementing this program. Industry operating experience that forms the basis for the program is described in the operating experience element of the NUREG-1 801 program description. IPEC plant-specific operating experience is not inconsistent with the operating experience in the NUREG-1801 program description.

The IPEC program is based on the program description in NUREG-1801, which in turn is based on industry operating experience. As such, operating experience provides assurance that implementation of the Selective Leaching Program will manage aging effects such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extend operation.

NL-13-046 Docket Nos. 50-247 and 50-286 Attachment 1 Page 6 of 6 The Selective Leaching Program will be effective for managing aging effects since it will incorporate proven monitoring techniques. The Selective Leaching Program assures the effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis through the period of extended operation.