NL-17-069, Reply to Requests for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application RAI Set 2017-05 (CAC Nos. MD5407 and MD5408)

Reply to Requests for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application RAI Set 2017-05 (CAC Nos. MD5407 and MD5408)

ML17166A380
Person / Time
Site:	Indian Point
Issue date:	06/08/2017
From:	Vitale A Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MD5407, CAC MD5408, NL-17-069
Download: ML17166A380 (11)

Text

• .--.Entergx Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254 6700 Anthony J Vitale Site Vice President NL-17-069 June 8, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

. Reply to Requests for Additional Information for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application RAI SET 2017-05 (CAC Nos. MD5407 and MD5408)

Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

REFERENCES:

1) NRC letter dated April 28, 2017, "Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI SET 2017-04 (CAC Nos. MD5407 and MD5408)," (ML17110A133)

Dear Sir or Madam:

Entergy Nuclear Operations, Inc. (Entergy) is providing in Attachment 1, the additional information requested by the U.S. Nuclear Regulatory Commission (NRC) pertaining to the review of the License Renewal Application (LRA) for Indian Point Energy Center (IPEC) Unit Nos. 2 and 3 (Reference 1).

Revised LRA Table 3.3.2-17-IP3 is provided in Attachment 2. Revised LRA Table 3.3.2-19 IP2 is provided in Attachment 3.

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 Jurie 5 , 2017.

Sincerely, AJV/gd

NL-17-069 Docket Nos. 50-247 and 50-286 Page 2of2 Attachments:

1. Reply to NRC Request for Additional Information Regarding the License Renewal Application

2. Revised LRA Table 3.3.2-17-IP3

3. Revised LRA Table 3.3.2-19-44-IP2 cc: Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. William Burton, NRC Senior Project Manager, Division of License Renewal Mr. Richard V. Guzman, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service Mr. John B. Rhodes, President and CEO NYSERDA NRC Resident Inspector's Office

ATTACHMENT 1 to NL-17-069 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

NL-17-069 Attachment 1 Page 1 of 4 RAI 3.3.2-17-IP3-1

Background

Section 54.21 (a)(3) of Title 10 of the Code of Federal Regulations (10 CFR) requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

As amended by letter dated December 15, 2016, LRA Table 3.3.2-17-IP3 states that fiberglass city water piping exposed to soil has no aging effect and no recommended aging management program.

The subject letter also describes the change to Table 3.3.2-17-IP3 as: "[p]ermanently repaired pipe (line #1033) with a pressure retaining clamp and using CSI Pipe Wrap-Ply material (carbon fiber) applied on the exterior circumference of the pipe and clamp."

1. It is unclear to the staff, based on conflicting information provided above, if the line item represented in LRA Table 3.3.2-17-IP3 is fiberglass piping or is carbon fiber applied on the exterior circumference of the pipe.

2. The "parameters monitored or inspected" program element of GALL Report AMP Xl.M41, "Buried and Underground Piping and Tanks," as modified by LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations,"

recommends visual inspections of the external surface condition of polymeric materials to detect (a) loss of material due to wear; and (b) cracking, blistering, and change in color due to water absorption.

• Request

1. Clarify if the line item represented in LRA Table 3.3.2-17-IP3 is fiberglass piping or is carbon fiber applied on the exterior circumference of the pipe.

2. State the basis for why (a) loss of material due to wear; and (b) cracking, blistering, and change in color due to water absorption are not aging effects requiring management for polymeric materials exposed to soil.

Response

1. The line item included in LRA Table 3.3.2-17-IP3 as fiberglass piping by Letter NL 138, dated December 15, 2016, is carbon fiber reinforced epoxy applied on the exterior circumference of a pressure retaining clamp and the pipe encapsulating both the clamp and a short section of the pipe. Conservatively, the carbon fiber wrap is designed to carry full structural load around the repaired area of the underlying pipe.

NL-17-069 Attachment 1 Page 2of4

2. The pressure retaining clamp discussed in response to Request 1 restricts exposure of the interior surface of the carbon fiber reinforced epoxy from process fluid. Thus, only the external surface of the carbon fiber reinforced epoxy is exposed to an environment that could produce potential aging effects.

As indicated in LR-ISG-2015-01, loss of material due to wear can occur in polymeric components buried in soil containing deleterious materials; however, the backfill placed around the carbon fiber wrap repair consists of clean sand without deleterious material that could cause wear. In addition, LR-ISG-2015-01 describes that there is reasonable assurance that changes in material properties of polymeric materials will not occur as a result of contact with typical soil environments. The Parameters Monitored or Inspected element of the Buried and Underground Piping and Tanks program described in LR-ISG-2015-01 discusses cracking, blistering, and change in color due to water absorption, but these effects are limited to high-density polyethylene (HDPE) and fiberglass components and are not expected in the carbon fiber wrap.

As a result, no aging effects on the carbon fiber reinforced epoxy are expected*

through the period of extended operation.

LRA Table 3.3.2-17-IP3 is revised to indicate the subject piping is carbon fiber reinforced epoxy. See Attachment 2.

RAI 3.3.2-19-44-IP2-1

Background

Section 54.21 (a)(3) of 10 CFR requires the applicant to demonstrate that the effects of aging for structures and components will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation. As described in SRP-LR, an applicant may demonstrate compliance with 10 CFR 54.21 (a)(3) by referencing the GALL Report and when evaluation of the matter in the GALL Report applies to the plant.

As amended by letter dated December 15, 2016, LRA Table 3.3.2-19-44-IP2 states that plastic chlorination system piping and valves exposed externally to indoor air and internally to treated water have no aging effects and no recommended aging management programs.

NUREG-1801, "Generic Aging Lessons Learned (GALL) Report," is referenced as a technical basis document in NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants" (SRP-LR). The GALL Report lists generic aging

. management reviews (AM Rs) of systems, structures, and components (SSCs) that may be in the scope of license renewal applications (LRAs). The GALL Report provides little differentiation among generic terms such as plastic for mechanical systems. Therefore, NRC issued the Regulatory Issue Summary (RiS) 2012-02 dated January 24, 2012, "Insights into Recent License Renewal Application Consistency with the Generic Aging Lessons Learned Report."

This document provides guidance to the industry in regard to further information recommended*

in license renewbl applications. In regard to plastic materials, the RIS recommends that

NL-17-069 Attachment 1 Page 3 of 4 applicants provide further information in a plant-specific note because the term "plastic" is not sufficient to evaluate potential aging effects. The RIS states:

"The plant-specific note should state the actual material type or grade (e.g.,

polyvinyl chloride (PVC), fiberglass-reinforced vinyl ester) and identify environmental considerations that are not obvious from the LRA, FSAR, or license renewal drawings, such as exposure to ultraviolet light, ozone, high temperatures, chemicals, or radiation. The staff requires this information because susceptibility to aging varies widely with the specific material type and environment."

An applicant should ensure that the appropriate material type details are included in the LRA when it states that no Aging Effects Requiring Management or AMP is applicable for plastic components.

For the plastic piping and valves in the chlorination system, the staff does not have sufficient information on the specific type of plastic and the indoor air and treated water environments to evaluate whether the appropriate aging effects have been identified.

Request

1. State the specific type of plastic material used for the chlorination system piping and valves.

2. State the degree to which the external surfaces of the subject piping might be exposed to ultraviolet light, ozone, high temperatures, chemicals, and radiation.

3. State the chlorine concentration and type of chlorine to which the piping will be exposed.

4. If the above environmental factors are present, state the basis for why the piping is not subject to aging effects requiring management.

Response

1. The specific type of plastic pipe used' is chlorinated polyvinyl chloride (CPVC).

2. Much of the CPVC piping is installed beneath floor grating and along walls of the intake structure shielding it from significant sources of ultraviolet light such as sunlight or fluorescent lighting. However, sections of the piping are exposed to sunlight at times during the day.

No abnormal levels of ozone are expected beyond normal atmospheric levels.

The highest temperature expected for the CPVC piping is normal outdoor temperature. The piping is not in close proximity to any heat source.

The CPVC piping carries sodium hypochlorite., The piping is not exposed to other chemicals.

The CPVC piping is not exposed to radiation above normal background levels.

NL-17-069 Attachment 1 Page 4 of 4 I

3. A solution of 15% commercial grade sodium hypochlorite is used in the chlorination system.

4. Although no significant source of ultraviolet light such as sunlight or fluorescent lightir;ig are present, aging effects are conservatively applied as a result of the sections of CPVC piping exposed to sunlight for periods of time during the day.

The subject CPVC piping is designed for 100°F and outside design temperature is 93°F dry bulb . Consequently, there are no aging effects requiring management due to elevated temperatures.

CPVC is an acceptable piping material for exposure to sodium hypochlorite There are no aging effects requiring management due to chemicals.

The CPVC piping is not exposed to a radiation source that could contribute to aging effects requiring management.

,

CPVC is not affected by ozone. Consequently, there are no aging effects requiring management due to ozone.

LRA Table 3.3.2-19-44-IP2 is revised. See Attachment 3.

ATTACHMENT 2 to NL-17-069 REVISED LRA TABLE 3.3.2-17-IP3 Changes are shown as strikethroughs for deletions and underlines for additions

. ENTERGYNUCLEAR OPERATIONS, INC.

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

NL-17-069 Attachment 2 Page 1 of 1 Table 3.3.2-17-IP3 City Water Summary of Aging Management Review Table 3.3.2-17-IP3: City Water Aging Effect NU REG-Component Intended Aging Management Table 1 Material Environment Requiring 1801 Vol. 2 Notes Type Function Programs Item Management Item Piping Pressure FieeF§lass Soil (ext) None None -- -- F boundary Carbon fiber reinforced epoxy

ATTACHMENT 3 to NL-17-069 REVISED LRA TABLE 3.3.2-19-44-IP2

,_,

Changes are shown as strikethroughs for deletions and underlines for additions ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-17-069 Attachment 3 Page 1 of 1 Table 3.3.2-19-44-IP2 Chlorination System Nonsafety-Related Components Potentially Affecting Safety Functions Summary of Aging Management Review Table 3.3.2-19-44-IP2: Chlorination System u

Aging Effect Component Intended Aging Management NUREG-1801 Table 1 Material Environment Requiring Notes Type Function Programs Vol. 2 Item Item Management Pressure A"1r indoor (ext)

• • Nooe Nooe'

- - -

Piping Plastic Air - outdoor Change in External Surfaces F. 321 boundary material (ext) Monitoring grogerties Piping Pressure Plastic Treated water None None

- - -

boundary (int) F, 321

/\.

nlr indoor (ext) Nooe - - -

Pressure Nooe Valve body Plastic Air - outdoor Change in External Surfaces F, 321 boundary material (ext) Monitoring grogerties Valve body Pressure Plastic Treated water None None

- - -

boundary (int) F, 321 Plant-Specific Notes 321. Component is located in the intake structure and manufactured from chlorinated polyvinyl chloride (CPVC).