NL-17-092, Amended Response to Request for Additional Information Question RAI 3.3.2-17-IP3-1 Re License Renewal Application RAI Set 2017-05

Amended Response to Request for Additional Information Question RAI 3.3.2-17-IP3-1 Re License Renewal Application RAI Set 2017-05

ML17216A031
Person / Time
Site:	Indian Point
Issue date:	07/27/2017
From:	Vitale A Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MD5407, CAC MD5408, NL-17-092
Download: ML17216A031 (7)

Text

• • =-=* Entergx Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249 Tel (914) 254 6700 Anthony J Vitale Site Vice President

• NL-17-092 July 27, 2017 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Amended Response to Request for Additional Information Question RAI 3.3.2-17-IP3-1 Regarding License Renewal Application RAI SET 2017-05 for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3 (CAC Nos. MD5407 and MD5408)

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

REFERENCES:

1) Entergy letter dated June 8, 2017, "Reply to Requests of 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) (NL-17-069)

2) NRC letter dated April 28, 2017, "Requests for Additional Information for the Review of the Indian Point License Renewal Application RAI SET 2017-05 (CAC Nos. MD5407 and MD5408)," (ML17110A133)

3) Entergy letter dated December 15, 2016, "Amendment 18 to License Renewal Application (LRA) Indian Point Nuclear Generating Unit Nos.

2 and 3," (NL-16-138) (ML16358A526)

Dear Sir or Madam:

By Reference 1, Entergy Nuclear Operations, Inc. (Entergy) provided responses to additional information requested by the U.S. Nuclear Regulatory Commission (NRC), identified in Reference 2 pertaining to the review of the License Renewal Application (LRA) for Indian Po.int Energy Center (IPEC) Unit Nos. 2 and 3.

During its review of the response to RAI 3.3.2-17-IP3-1, the NRC staff noted an apparent inconsistency between the response and the revised LRA Table 3.3.2-17-IP3. The response stated that the carbon fiber-reinforced epoxy was applied on the exterior circumference of a pressure-retaining clamp, while the revised LRA Table 3.3.2-17-IP3 indicated that the piping was made of carbon fiber-reinforced epoxy. In this situation, the pressure-retaining clamp acts as the piping and the carbon fiber-reinforced epoxy acts as an exterior coating. For clarification, Entergy is providing an amended response to RAI 3.3.2-17-IP3-1 in Attachment 1.

NL-17-092 Docket Nos. 50-247 and 50-286 Page 2 of 2 As a result of this amended response, a revised LRA Table 3.3.2-17-IP3 is provided in .

The response provided in this submittal supersedes in its entirety the response previously provided by Reference 1.

There are no new commitments being made 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 7 (/-;;..7 I 2017.

Sincerely, AJV/rl Attachments:

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

2. Revised LRA Table 3.3.2-17-IP3 cc: Mr. Daniel H. Dorman, Regional Administrator, NRG Region I Mr. Sherwin E. Turk, NRG Office of General Counsel, Special Counsel Mr. William Burton, NRG 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 Ms. Alicia Barton, President and CEO NYSERDA NRG Resident Inspector's Office

ATTACHMENT 1 to NL-17-092 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-17-092 Attachment 1 Page 1 of 2 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 agirig effect and no recommended aging management program.

The subject letter also describe~r 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 forwhy (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 in Letter NL 138, dated December 15, 2016 (Reference 3), is carbon fiber-reinforced epoxy overlaid onto the exterior circumference of a carbon steel pressure-retaining clamp on carbon steel piping.

NL-17-092 Attachment 1 Page 2 of 2

2. In clarification of the line item included in LRA Table 3.3.2-17-IP3 as fiberglass piping by Reference 3, the pressure-retaining clamp provides,the pressure boundary and serves as a continuation of the piping. The effects of aging for the clamp are the same as those for other carbon steel piping in the Buried Piping and Tanks Inspection Program. Because the clamp is not a polymeric material, the effects of aging for polymeric materials exposed to soil do not apply. The line item added for fiberglass piping by Reference 3 is unnecessary in LRA Table 3.3.2-17-IP3. Removal of this line item from the table is shown in Attachment 2. Deletions are lined through.

ATTACHMENT 2 to NL-17-092 REVISED LRA TABLE 3.3.2-17-IP3 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-17-092 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

~ PFessw=e Fiberglass Soil (ext) Nooe Nooe - - F-bo1rnElaFy