ML15071A355

2015/03/12 Indian Point Lr Hearing - Draft Follow-up RAIs for LR-ISG-2012-002

ML15071A355
Person / Time
Site:	Indian Point
Issue date:	03/12/2015
From:	Office of Nuclear Reactor Regulation
To:
References
Download: ML15071A355 (11)

Text

IPRenewal NPEmails From: Wentzel, Michael Sent: Thursday, March 12, 2015 2:33 PM To: Louie, Richard (rlouie@entergy.com)

Subject:

Draft Follow-up RAIs for LR-ISG-2012-002 Attachments: Draft IP RAI Set 2015-01.docx

Rich, Attached are the draft RAIs resulting from the staffs review of Entergys December 16, 2014 letter addressing LR-ISG-2012-002. After youve had a chance to review, if you feel a phone call to clarify the questions would be helpful, please let me know.

Thanks, Mike Michael Wentzel Project Manager NRR/DLR/RPB2 (301) 415-6459 michael.wentzel@nrc.gov 1

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 4947 Mail Envelope Properties (C0A338EE37A11447B136119705BF9A3F0288112C48D7)

Subject:

Draft Follow-up RAIs for LR-ISG-2012-002 Sent Date: 3/12/2015 2:32:32 PM Received Date: 3/12/2015 2:32:34 PM From: Wentzel, Michael Created By: Michael.Wentzel@nrc.gov Recipients:

"Louie, Richard (rlouie@entergy.com)" <rlouie@entergy.com>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 444 3/12/2015 2:32:34 PM Draft IP RAI Set 2015-01.docx 96738 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 Pooint 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 INDIAAN POINT NUCLEAR GENERATING G UNIT NOS S. 2 AND 3, LICENSE RENE EWAL APPL LICATION, SET S 2015-01 1 (TAC NOS S. MD5407 ANDA MD540 08)

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), submitteed an applica ation pursuaant to Title 10 of o theCode of o Federal RegulationsPart 54, to ren new the ope erating licensses for India an Point Nuclear Generrating Unit Nos. 2 and 3, for review by b the U.S. Nuclear N Reggulatory Commisssion (NRC). The NRC staff s documeented its finddings in the Safety S Evaluuation Reporrt (SER) related to the license rene ewal of India an Point Nucclear Genera ating Unit Noos. 2 and 3, which wa as issued Au ugust 11, 2009 and supp plemented August A 30, 20011 (SER Supplement 1), 1 and Nove ember 6, 2014 (SER Su upplement 2)).

Subsequ uent the issuance of SER R Supplement 1, the staff identified additional a opperating experience at severa al nuclear po ower plants regarding r re ecurring interrnal corrosioon, corrosionn occurringg under insulation, and managing m agging effects for f fire water system com mponents. To T address this operatin ng experiencce, on Novem mber 22, 2013, the NRC C staff issuedd interim sta aff guidance e document LR-ISG-2012-02, "Aging g Manageme ent of Internal Surfaces,, Fire Water Systems, Atmospherric Storage Tanks, T and Corrosion C Unnder Insulation.

By letter dated April 1, 2014, the NRC staff requested r ad ormation as to how Ente dditional info ergy planned to manage the t effects ofo aging as described in LR-ISG-2012-02. By lettter dated Decembe er 16, 2014, Entergy ressponded to thet NRC stafffs request for f additiona al information.

Based on n its review of o the inform mation contained in Entergys letter, the NRC sta aff requests additionaal informationn as describ bed in the en nclosure.

This RAI was discuss sed with Mr.. Richard Lo ouie, and a mutually m agreeeable date for Entergys response e is within 30 0 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)

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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 2015-01 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-2012-02 RAI 3.0.3-3

Background

Entergy Nuclear Operations Inc. (Entergy), in a letter dated December 16, 2014, responds to RAI 3.0.3-1 and addresses the issues contained in LR-ISG-2012-02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation. Regarding LR-ISG-2012-02, Section A, Recurring Internal Corrosion, the response states that reviews of past plant-specific operating experience identified recurring internal corrosion due to general, pitting, and crevice corrosion that resulted in through-wall leaks at least once in each of three refueling cycles in the last 10 years for both units. For the service water system, the response states that minor corrosion issues still occur, but these do not compromise the intended functions of the service water system. In discussing through-wall leaks for cement-line carbon steel piping or stainless steel and copper alloy piping, the response also states that based on operating experience, such leaks have no impact on system performance and have not threatened the structural integrity of the piping or the safety function of nearby equipment.

Issue During its review, the staff identified plant-specific operating experience that appears to contradict statements in the RAI response regarding the significance of the corrosion issues associated with the service water system. In this regard, Licensee Event Report (LER) 286/2011-003, Technical Specification Required Shutdown and a Safety System Functional Failure for a Leaking Service Water Pipe Causing Flooding in the SW [service water] Valve Pit Preventing Access for Accident Mitigation, dated April 25, 2011, states: After further evaluation, it was concluded there was a loss of safety function, and It was concluded that this condition was a safety system functional failure. The LER statements appear to be inconsistent with the statement in the December 2014 response, regarding no impact of system performance.

In addition, LER 286/2002-001, Operation in a Condition Prohibited by Technical Specifications Due to an Inoperable Service Water Pipe Caused by a Leak that Exceeded the Allowable Outage Time,dated July 5, 2002,states, Engineering evaluation of data collected concluded that the leaking pipe did not provide sufficient structural integrity for the piping to meet code allowables for pipe thinning and through wall leaks and therefore was inoperable. Although this LER is beyond the 10-year operating experience review window conducted for RAI 3.0.3-1, the staff notes that this operating experience was not included in the license renewal application in the discussion for the operating experience of the Service Water Integrity Program. Also, the staff notes that by letter dated June 5, 2008, Entergy responded to RAI AUX-1, which relates to the staffs questions on the operating experience summaries for several aging management programs, including the Service Water Integrity Program. For IP3 service water degradation, the 2008 response discusses the detection of loss of material during inspections from 2001 to 2004 and states that these conditions did not result in a loss of system intended function.

Engineering review of external corrosion and a pinhole leak did not result in any operability ENCLOSURE

concerns. Based on LER 286/2002-001, the significance of past operating experience, regarding structural integrity and operability, may not have been adequately characterized by the statements made in the 2008 RAI response.

Request Explain and reconcile the information related to loss of safety function contained in the December 2014 response to RAI 3.0.3-1 and LER 286/2011-003. In addition, explain and reconcile the information related to the structural integrity and operability in the 2008 response to RAI AUX-1 and LER 286/2002-001.

RAI 3.0.3-4

Background

Entergy letter dated December 16, 2014, responds to RAI 3.0.3-1 and addresses the issues contained in LR-ISG-2012-02. Regarding LR-ISG-2012-02, Section A, Recurring Internal Corrosion, the response states that reviews of past plant-specific operating experience identified at least one through-wall leak in each of three refueling cycles in the last 10 years for both units due to general, pitting, and crevice corrosion. For the service water system, the response states that minor corrosion issues still occur, but these do not compromise the intended functions of the service water system. In discussing through-wall leaks for cement-line carbon steel piping or stainless steel and copper alloy piping, the response also states that based on operating experience, such leaks have no impact on system performance and have not threatened the structural integrity of the piping or the safety function of nearby equipment.

The response subsequently includes an enhancement to the Service Water Integrity Program to incorporate the actions used to manage the minor corrosion issues in the service water system. The enhancement, to be implemented by 2019, consists of revising procedures to evaluate through-wall leaks under the corrective action program and to inspect portions of the buried service water by robotic crawler or manual crawl-through.

Recent LERs (286/2014-002, 247/2013-004, and 286/2011-003) discuss additional leaks in the service water system piping. The first LER (286/2014-002) states that Procedure 3-PT-R185B (Primary Auxiliary Building SW Piping and Valve Flush) was developed specifically to address recurring problems with leaks in stagnant vent and drain piping and that the procedure is the main line of defense for preventing future leaks in small bore carbon steel piping socket welds. The staff notes that the initial Service Water Integrity Program previously included periodic flushing of infrequently used loops to manage loss of material in service water components. The second LER (247/2013-004) discusses replacement of certain portions of Series 300 stainless steel piping (which replaced the original carbon steel piping) in the service water system with highly corrosion resistant material. The replacement plan was developed after deficiencies were identified in 2008. The third LER (286/2011-003) discusses the loss of safety function for a portion of the service water system and states that the Generic Letter (GL) 89-13 program (the basis for the Service Water Integrity Program) will be revised to prioritize inspection frequencies of service water welds.

The significance of the degradation identified in the third LER (286/2011-003) prompted the staff to review the responses to Generic Letter 89-13 for IP2 and IP3. The staff noted a difference between the current licensing basis for the two responses. The February 2, 1990, response for IP2 discussed an in-place QA radiographic program that randomly inspects 10 percent of the service water piping welds annually, whereas the September 9, 1992, response

for IP3 includes ultrasonic inspections of non-cement lined portions and visual inspections using a robotic crawler with a high resolution camera. The staff notes that a 1991 status update for IP2 on various Action Items for GL 89-13 states: We have initiated an internal visual inspection program for underground service water piping. This program utilizes pipe crawling video equipment to inspect and record the condition of the cement-lined underground pipe.

Issue Given the enhancements to the Service Water Integrity Program proposed in the December 16, 2014 letter, the current details of the program implementation are unclear to the staff. Since the IP2 and IP3 responses to GL 89-13 both refer to using remote crawlers and one response specifically addresses underground service water piping, it is not clear to the staff how the current enhancement for internally inspecting buried service water piping (to be implemented prior to 2019) differs from the program that (based on the current licensing basis) was previously in place. In addition, regarding the other currently proposed enhancement to the Service Water Integrity Program (evaluatingleakage under the corrective action program), the need for revised procedures to evaluate through-wall leaks under the corrective action program implies that leakage currently may not be evaluated under the corrective action program. In this regard, too, it is not clear to the staff how the proposed enhancement differs from the program that was previously in place, given that LRA Section B.0.3 states the corrective action controls of the Entergy (10 CFR Part 50, Appendix B) Quality Assurance Program are applicable to all aging management programs and activities.

Based on the operating experience discussed in the above LERs, enhancements to the Service Water Integrity Program have been implemented beyond the version of the program that was evaluated by the staff in NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3. For LER 286/2011-003, the program apparently did not adequately manage the effects of aging because an intended function of the system was not maintained consistent with the current licensing basis. SRP-LR Section A.1.2.3.10 states that a past failure would not necessarily invalidate an aging management program because the feedback from operating experience should have resulted in appropriate program enhancements or new programs. In that regard, it is not clear to the staff what changes have been made to the program over the years as a result of past operating experiences or what changes have been made to the prior commitments for GL 89-13.

Request

1) Provide a description and chronological history of any enhancements that have been made to the Service Water Integrity Program, from the version of the program reviewed by the staff as documented in NUREG-1930, as a result of Indian Point site-specific operating experience. If no enhancements have been made, then discuss the meaning of the statement in LER 286/2011-003 regarding changes that will be made to the GL 89-13 program. In addition, clarify whether Procedure 3-PT-R185B was revised as a result of the extent of condition review discussed in LER 286/2014-002, and if it was not revised, discuss how the recurring problems with leaks developing in stagnant vent and drain connection piping and valves (identified in the extent of condition review) are being addressed.

2) Clarify whether (and if so, when) any changes have been made to previously docketed licensing commitments for the IP2 and IP3 responses to GL 89-13, and provide information as to whether (and if so, when) that the NRC has been informed of any changes.

3) For the two proposed enhancements in the response to RAI 3.0.3-1, clarify the differences between the new enhancement activities and the activities in the previously implemented program.

4) Provide the following details for the current Service Water Integrity Program:

a) the amount and timing of any past (and if they are to be credited, any planned) service water system piping replacements; b) trend data from the past 10 years for the number of leaks caused by age-related degradation; c) the number and frequency of volumetric inspections being performed to both track known degradation locations and identify additional degradation locations; d) the type (internal or external), amount, and frequency of visual inspections being performed; e) the criteria used to determine locations for and adjustments to the number and frequency of volumetric and visual inspections, including any predictive methodology.

In responding to Request No. 1 and Request No. 4, parts c, d, and e, state whether these actions will continue during the timely renewal period and period of extended operation; and revise the Service Water Integrity Program and corresponding Updated Final Safety Analysis Reportsupplement accordingly.

RAI 3.0.3-5

Background

The response to RAI 3.0.3 1 dated December 16, 2014, states that the fire protection water and city water systems have experienced recurring internal corrosion (RIC), as defined in LR-ISG-2012-02. With regard to the fire protection water system, the response states, [l]ocalized corrosion has resulted in minor through-wall leaks that have no impact on system performance and do not threaten the structural integrity of the piping or the safety function of nearby equipment. No changes were proposed to the Fire Water System Program to address RIC.

With regard to the city water system, the response states, [h]owever, based on past operating experience, they [through wall leaks] do not compromise the intended functions of these or any other system, and do not warrant aging management program activities beyond those provided by established aging management programs and the corrective action program.

Issue Past performance does not provide reasonable assurance that throughout the period of extended operation, internal general corrosion will be revealed by a through-wall leak prior to the general corrosion potentially impacting the structural integrity of the system. Nor does it provide reasonable assurance that larger through-wall flaws sufficient to challenge the pressure boundary function will not occur. It is also unclear to the staff that a sufficient representative sample exists for the carbon steel piping to demonstrate that general corrosion is progressing slowly enough that it will not prevent an in-scope component from performing its current licensing basis intended function during the period of extended operation.

Although to date through-wall leaks have not affected the safety function of nearby equipment, the staff lacks sufficient information to conclude with reasonable assurance that this will be the case throughout the period of extended operation.

Request

1) State the basis and justification for concluding that existing inspection data are sufficient to demonstrate that general corrosion is progressing slowly enough that it will not prevent an in-scope component from performing its current licensing basis intended function during the period of extended operation.

2) State the basis and justification for concluding that through-wall leaks will not impact the safety function of nearby equipment throughout the period of extended operation.

3) Provide the staff with sufficient quantitative data for it to reach the same conclusions.

Alternatively, propose periodic inspections in response to SRP-LR Section 3.3.2.2.8, Loss of Material due to Recurring Internal Corrosion.