ML12233A666

NRC Staff Pre-Filed Hearing Exhibit NRC000152, Indian Point Nuclear Generating Unit 2 - NRC Inspection Report 05000247/2012008, Dated April 19, 2012

ML12233A666
Person / Time
Site:	Indian Point
Issue date:	04/19/2012
From:	Conte R Engineering Region 1 Branch 1
To:	Ventosa J Entergy Nuclear Operations
SECY RAS
References
RAS 23327, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 IR-12-008
Download: ML12233A666 (15)

See also: IR 05000247/2012008

Text

NRC000152

Submitted: August 20, 2012

UNITED STATES

NUCLEAR REGULATORY COTTIM ISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA. PENNSYLVANIA 19406.1415

Apri'l L9, 20L2

Mr. John Ventosa. Site Vice President

Entergy Nuclear Operations, lnc.

Indian Point Energy Center

450 Broadway, GSB

P.O. Box 249

Buchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INSPECTION REPORT

05000247t2012008

Dear Mr. Ventosa:

On March 8,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the lndian Point Nuclear Generating Unit 2. The enclosed report documents the results of the

inspection, which were discussed on March 8,2012, with Mr. John Curry and members of your

staff.

This inspection was an examination of license renewal activities under Temporary Instruction

(Tl) 2516/001, Review of License RenewalActivities. The inspection was directed toward those

activities and facilities accessible during the refueling outage. The inspection also reviewed the

completion of commitments made during the renewed license application process and

compliance with the Commission's rules and regulations and the conditions of your operating

license. Within these areas, the inspection involved examination of selected procedures and

representative records, observations of activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified

during this inspection. The NRC staff identified two instances of commitments which could not

be considered completed at this time. Given the scheduled completion of September 28,2013,

for these commitments, we will incorporate a followup review as a part of our planned team

inspection in this area prior to September 28,2013, to verify completion along with the

completion of other commitments.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from

the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading

Room).

,e"/^Jyffi

Sincerelv,

Richard J. Conte, Chief

Engineering Branchl

Division of Reactor Safety

Mr. John Ventosa

Site Vice President

Entergy Nuclear Operations, Inc.

Indian Point Energy Center

450 Broadway, GSB

Buchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INSPECTION REPORT

0500024712012008

Dear Mr. Ventosa:

On March 8,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

the Indian Point Nuclear Generating Unit 2. The enclosed report documents the results of the

inspection, which were discussed on March 8, 2012, with Mr. John Curry and members of your

staff.

This inspection was an examination of license renewal activities under Temporary Instruction

(Tl) 2516/001, Review of License RenewalActivities. The inspection was directed toward those

activities and facilities accessible during the refueling outage. The inspection also reviewed the

completion of commitments made during the renewed license application process and

compliance with the Commission's rules and regulations and the conditions of your operating

license. Within these areas, the inspection involved examination of selected procedures and

representative records, observations of activities, and interviews with personnel.

On the basis of the samples selected for review, there were no findings of significance identified

during this inspection. The NRC staff identified two instances of commitments which could not

be considered completed at this time. Given the scheduled completion of September 28,2013,

for these commitments, we will incorporale a followup review as a part of our planned team

inspection in this area prior to September 28,2013, to verify completion along with the

completion of other commitments.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRC's document system

Agencyride Document Access and Management System (ADAMS). ADAMS is accessible from

the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading

Room).

Sincerely,

/RN

Richard J. Conte, Chief

Engineering Branchl

Division of Reactor Safety

DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- Meyer\lndian Pt 71003\lR 2012-08 lP Rev 2.docx

ADAMS ACCESSION NUMBER: ML12 104315

g fl Non-Sensitive V Publicly Available

suNst Review

n Sensitive  ! Non-Publicly Available

OFFICE RI/DRS RI/DRP RI/DRS

NAME GMeyer/RJC for MGray RConte

DATE 4t11t12 4t19t12 4t19t12

RECORD COPY

J. Ventosa

Docket No. 50-247

License No. DPR-26

Enclosure:

NRC f nspection Report 05000247 12012008

cc w/enclosure: Distribution via ListServ

J. Ventosa 3

Distribution Mencl: (via E-mail)

W. Dean, RA (R{ORAMATL RESOURCE)

D. Lew. DRA (RIORAMAlL RESOURCE)

J. Clifford, DRP (RlDRPMail Resource)

J. Trapp, DRP (RIDRPMAIL Resource)

C. Miller, DRS (RI DRSMArL RESOURCE)

P. Wilson, DRS (R,lDRSMAIL RESOURCE)

M. McCoppin, Rl OEDO

M. Gray, DRP

B. Bickett, DRP

S. McCarver, DRP

M. Jennerich, DRP

M. Catts, SRI

A. Ayegbusi, Rl

D. Hochmuth, AA

RidsNrrPMlndianPoint Resource

RidsNrrDorlLpll -1 Resource

ROPreport Resource

D. Bearde, DRS

T. Lupold, DRS

R. Conte, DRS

G. Meyer, DRS

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket: 50-247

License: DPR-26

Report: 0500024712012008

Licensee: Entergy Nuclear Northeast (Entergy)

Facility: lndian Point Nuclear Generating Unit 2

Location: Buchanan, NY

Dates: March 5-8,2012

Inspectors: G. Meyer, Senior Reactor Inspector, Division of Reactor Safety

M. Modes, Senior Reactor Inspector, Division of Reactor Safety

Accompanied By: K, Green, Senior Project Manager, Division of License Renewal

W. Holston, Senior Technical Reviewer, Division of License Renewal

Approved By: Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

lR 0500024712012008i 0310512012 - 0310812012; Indian Point Nuclear Generating Unit 2;

Review of License Renewal Activities.

The report covers a one week inspection of the implementation of license renewal activities

during the Indian Point Unit 2 refueling outage, lt was conducted by two region based

engineering inspectors under Temporary Instruction 2516/001. No findings were identified. The

inspectors determined that Entergy actions on four commitments (Commitments 28,29,34, and

36) were complete and met regulatory expectations as reflected in the staff's safety evaluation

report. lnspection of two commitments (Commitments 2 and 3) concluded that additional

inspection was needed.

Enclosure

Report Details

4. oTHER ACTTVTTTES (OA)

4042 Other - License Renewal Activities (Tl 2516/001 )

a. lnspection Scope

This inspection was performed by two NRC Region I based inspectors to evaluate the

license renewal activities at the Indian Point Nuclear Generating Unit 2 in accordance

with Temporary Instruction (Tl) 25161001. As noted in this Tl: "This procedure was

written to allow for timely verification by NRC inspectors that the applicant has made

sufficient progress in implementing its license renewal commitments before entering its

post-4O-year license period and to allow documentation of these inspection activities

while the operating license is being considered for renewal." This phase of the

inspection is "to be completed during the outage preceding the beginning of the period of

extended operations for the purpose of observing or verifying commitments of tests or

other activities that require containment entries or access to rooms that would normally

be posted as a high-radiation area or higher when the reactor is operating." The

inspectors performed in-plant observations of license renewal related activities and

sampled Entergy actions on commitments. The bases for the review was the NRC

staff's safety evaluation report (NUREG'1930) and related licensee letters associated

with licensee renewal regulatory commitments, including Letter NL-11-101, dated

August 22,2011.

b. Findinss and Observations

No findings were identified.

b.1 ln-Plant Observations

The inspectors observed ongoing activities and inspected the general condition of

structures, systems, and components within the scope of license renewal. The

inspectors performed reviews in the following areas, as related to commitments and

aging management programs (AMPs):

. Turbine Building - Flow Accelerated Corrosion AMP

. Turbine Building - One-Time lnspection Program (Commitment 19)

. Station Blackout (SBO)/Appendix R Diesel Generator (Commitment 34)

The inspectors determined the general conditions to be satisfactory and the Entergy

activities to be in accordance with facility programs and procedures.

Enclosure

2

b.2 Commitments - Review Complete

Commitment 28 - Water Chemistrv Control - Closed Coolino Water Prooram

Commitment 28 provides that Entergy will "Enhance the Water Chemistry Control-

Closed Cooling Water Program to maintain water chemistry of the lP2 SBO/Appendix R

diesel generator cooling system per EPRI guidelines" and will "Enhance the Water

Chemistry Control- Closed Cooling Water Program to maintain the lP2 and lP3 security

generator and fire protection diesel cooling water pH and glycolwithin limits specified by

EPRI guidelines" by September 28, 2013. The license renewal team inspection

(Report 0500024712008006 dated August 1, 2008) had noted that some parameters

were not monitored for some diesels in existing procedures.

The inspectors reviewed the implementation plan, EPRI guidelines, revised chemistry

sampling procedures and acceptance criteria, and chemistry results for the SBO/App. R,

fire protection, and security diesels.

The inspectors concluded that Commitment 28 had been completed.

Commitment 29 - Sulfates in the Refuelino Water Storaqe Tank (RWST)

Commitment 29 provides that Entergy will "Enhance the Water Chemistry Control -

Primary and Secondary Program for lP2 to test sulfates monthly in the RWST with a limit

of <150 ppb" by September 28,2013.

The inspectors reviewed the implementation plan, RWST chemistry sampling procedure,

and RWST chemistry results lor 2010 and 2011.

The inspectors concluded that Commitment 29 had been completed.

Commitment 34 - Station Blackout (SBO)/Appendix R Diesel Generator

Commitment 34 provides that "lP2 SBO/Appendix R diesel generator will be installed

and operational by April 30, 2008."

lnspection Report 0500024712008006, dated August 1, 2008, documented the license

renewal team inspection of the lP2 SBO/App. R diesel generator following its installation

and operationaltesting. Inspection Report 0500024712008003, dated August 13, 2008,

documented the inspection of the post-modification testing of this diesel generator.

The inspectors concluded that Commitment 34 had previously been completed.

Commitment 36 - Refuelino Cavitv Concrete

Commitment 36 provides that Entergy will "Perform a one-time inspection and evaluation

of a sample of potentially affected lP2 refueling cavity concrete prior to the period of

extended operation. The sample will be obtained by core boring the refueling cavity wall

in an area that is susceptible to exposure to borated water leakage. The inspection will

Enclosure

3

include an assessment of embedded reinforcing steel. A sample of leakage fluid will be

analyzed to determine the composition of the fluid." These actions are scheduled for

completion by September 28,2013. Commitment 36 also addresses core bores and

leakage fluid analysis in the first ten years of the period of extended operation. During

refueling operations at Unit 2, leakage through the reactor refuel cavity liner plate had

caused the cavity flood-up water to migrate through the concrete walls of the cavity.

NRC was concerned the borated water flowing through the concrete and past the

reinforcement bars could cause an indeterminate degradation.

The inspectors reviewed the test results of concrete cores removed from the lP2 refuel

structure in Engineering Report No. lP-RPT-11-00002, Assessment of Concrete Aging

From Selected Indian Point Structures, Rev 0, January 10,2011. The originally

specified concrete strength, per United Engineers and Constructors Drawing 9321-01-5-

1, Specification for Design, Inspection and Tests of Concrete, High Strength Bolts,

Compaction of Fill and Rock Bearing, was 3000 psi at 28 days. Entergy took seven core

samples from the Unit 2 fuel pool structure; the compression results were 7,213 psi,

3,202 psi, 5,890 psi,6,294 psi, 8,307 psi, 5,497 psi, and 6,448 psi' Using the guidance

of American Concrete Institute, ACI214.4R, the calculated equivalent in-structure

compressive strength was 4,341 psi.

Reinforcing bars were part of three of the concrete samples taken from the Unit 2 fuel

pool structure. The above referenced report noted there was no visible degradation of

the reinforcing bars. This observation compared favorably with concrete core samples

taken from the Unit 1 fuel pool structure, which was wetted by a boric acid solution

equivalent to Unit 2 for approximately 30 years.

Nine samples were taken from the core bores for further interrogation by Petrography

with a Stereo-microscope. These samples were examined in general accordance with

ASTM C-856-04, Standard Practice for Petrographic Examination of Hardened

Concrete. There were observations of concrete paste discoloration and cracks noted in

the Petrographic samples taken from the core samples extracted from the west and

south walls of the fuel pool. The discoloration was attributed to the differences in the

hydration of the paste most likely due to exposure to the water through the cracks, and

the report concluded the examined material was of "relatively good quality."

The inspectors concluded that Commitment 36 is on track to be completed,

b.3 Commitments - Needino Additional NRC Review

Commitment 2 - Boltino Inteqritv Proqram

Commitment 2 provides that Entergy will "Enhance the Bolting lntegrity Program tor lP2

and lP3 to clarify that actual yield strength is used in selecting materials for low

susceptibility to SCC and clarify that prohibition on use of lubricants containing MoSz for

bolting" by September 28, 2013. Commitment 2 also states that "The Bolting Integrity

Program manages loss of preload and loss of material for all external bolting,"

Enclosure

4

The inspectors reviewed the implementation plan and the revised mechanicalfastener

procedure, which had specific instructions on bolting regarding the use of actual yield

strength and the prohibition against molybdenum disulfide as a lubricant. Nonetheless,

there was no planned action regarding the second commitment statement regarding loss

of preload and loss of material, despite Commitment 2 being considered completed by

Entergy. Entergy entered this concern into the license renewal corrective action system

as item LO-LAR-2011-00174, CA-66.

The inspectors concluded that the specific procedural instructions of Commitment 2 had

been completed, but that review of any action on the general statement needed to be

reviewed during a subsequent NRC inspection.

Commitment 3 - Buried Pipinq and Tanks lnspection Proqram

Commitment 3 provides that Entergy will "lmplement the Buried Piping and Tanks

Inspection Program for lP2 land lP3] as described in LRA Section 8.1.6" and perform

the following:

o "lnclude in the Buried Piping and Tanks lnspection Program described in LRA

Section 8.1.6 a risk assessment of the in-scope buried piping and tanks that

includes consideration of the impacts of buried piping or tank leakage and of

conditions affecting the risk for corrosion."

. "Classify pipe segments and tanks as having a high, medium or low impact of

leakage based on the safety class, the hazard posed by fluid contained in the

piping and the impact of leakage on reliable plant operation."

. "Determine corrosion risk through consideration of piping or tank material, soil

resistivity, drainage, the presence of cathodic protection and the type of coating."

o "Establish inspection priority and frequency for periodic inspections of the in-

scope piping and tanks based on the results of the risk assessment."

o "Perform inspection using inspection techniques with demonstrated

effectiveness."

The inspectors reviewed the implementation plan and Entergy fleet, corporate

engineering and site engineering procedures. The inspectors also reviewed a summary

report of inspection results, cathodic protection records, and area potential earth current

(APEC) survey results.

The inspectors reviewed the risk assessment, classifications of leakage impacts, and

corrosion risk categorizations addressed in the first three bulleted items above, and

found the evaluation approaches to be sound and generally credible. The inspectors

reviewed the inspection plan based on these evaluations to be reasonable and

appropriate. The inspectors reviewed a sample of inspection records, which showed

that inspections had involved direct visual inspection, followed by external ultrasonic test

(UT) inspections in some cases, and were thorough and appropriate.

The inspectors noted two concerns. First, site engineering procedure SEP-UlP-IPEC

stated that guided wave inspection was an acceptable indirect inspection technique.

Enclosure

5

The inspectors noted that while guided wave inspection was a credible method to inform

other inspections, it did not meet the "demonstrated effectiveness" standard and was not

suitable for inspection by itself. There was no evidence that guided wave inspection had

been solely used to accept inspected piping or tanks, but the procedure merited

clarification on the use of guided wave inspection. Second, Entergy fleet procedure

EN-DC-343 listed the affected Unit 2 underground systems in Attachment 9.2, but

omitted the river water, circulating water, and containment isolation support systems.

There was no immediate impact on the inspection plan given that these actions were not

in effect without a renewed license. However, Entergy will review this matter and they

entered these two concerns into the license renewal corrective action system as item

LO-LAR-201 1 -001 7 4, CA-67 .

Given the preliminary progress on Commitment 3, the inspectors determined that

additional inspection was merited on the clarification of the use of guided wave

inspection, coverage of omitted underground systems, and subsequently completed

inspections.

b.4 Annual Updates

10 CFR 54.21(b) requires each year following submittal of the license renewal

application and at least three months before scheduled completion of the NRC review,

an amendment to the renewal application be submitted that identifies any change to

the current licensing basis (CLB) of the facility that materially affects the contents of the

license renewal application, including the Updated Final Safety Analysis Report

(UFSAR) supplement. The inspectors selected a sample from annual update submittals

for review.

Amendment 8 to the application transmitted by a letter (NL-09-060) dated May 15, 2009.

This amendment was a result of a review of documents affecting the current license

basis during the period May 1, 2008 through March 1, 2009, since the prior annual

update amendment. The review concluded that sections of the application were affected

by changes to the current licensing basis. For example, during this period, the Indian

Point 3 Security Dieselwas replaced, affecting Section 3.3.2.1.15 and Table 3.3.3-15-

lP3 of the application.

This example illustrated Entergy Nuclear Operations, Inc. compliance with 10 CFR

54.21(b).

Summarv

No findings were identified and general conditions in the plant areas observed were

satisfactory. The inspectors determined that Entergy actions on four commitments

(Commitments 28, 29,34, and 36) were complete and met regulatory expectations as

reflected in the staff's safety evaluation report. Inspection of two commitments

(Commitments 2 and 3) concluded that additional inspection was needed. Further NRC

inspection of Unit 2 commitments, including Commitments 2 and 3, is planned prior to

the scheduled completion date of September 28,2013.

Enclosure

6

4OAO Exit Meetino

The inspectors presented the inspection results to Mr. John Curry, License Renewal

Project Manager, and other members of the staff on March 8, 2012. The inspectors

confirmed that no proprietary materialwas examined during the inspection.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Curry, License RenewalTeam Project Manager

N. Azevedo, Supervisor, Supervisor Engineering Programs

C. Caputo, License RenewalTeam

G. Dahl, Licensing Engineer

R. Drake, System Engineer

J. Flagg, License Renewal Team

D. Lach, License Renewal Team

LIST OF DOCUMENTS REVIEWED

General

NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point

Nuclear Generating Unit Nos. 2 and 3, November 2009

NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point

Nuclear Generating Unit Nos. 2 and 3, Supplement 1, August 30, 2011

Entergy Letter NL-1 1-101 , Clarification for Request for Additional Information (RAl), dated

August 22,2011

In-plant Observations

One-Time Inspection Matrix (draft)

One-Time Inspection Form 169473-01

One-Time lnspection Form 51 282477 -01

WO 00255920, FAC UT of heater drain piping

WO 00255936, FAC UT of reheater drain piping

Commitment 2 (Boltinq Inteqritv)

lP-RPT-11-LRD03, Review of the Bolting Integrity AMP for lmplementation, Rev 0 (draft)

O-MS-411, Torquing of Mechanical Fasteners, Rev 3

Enclosure

A-2

Commitment 3 (Buried Pipinq and Tanks lnspection)

lP-RPT-11-LRD07, Review of the Buried Pipe and Tanks Inspection AMP for lmplementation,

Rev 0 (draft)

EN-DC-343, Underground Piping and Tanks Inspection and Monitoring Program, Rev 4

CEP-UPT-0100, Underground Piping and Tanks lnspection and Monitoring, Rev 0

SEP-UlP-lPEC, Underground Components Inspection Plan, Rev 0

PCA Engineering Inc, Cathodic Protection System Maintenance Record Sheet,

AFW Pump Room Annex - Unit 2, PCA Job No. 30493, 2128112

lP-RPT-11-0045, Indian Point Energy Center APEC Survey, 11117111

IPEC Underground Piping and Tank Program Completed Buried Pipe lnspections, 1111112

Thielsch Engineering, Laboratory Testing Data Sheet, 12112111

Photographs of Nov/Dec 2011 inspections of lP2 24" SRW lines 409

(16 pictures dated 11123111) and 408 (24 pictures dated 11123111)

lP2-lJT-11-050, UT Erosion Corrosion Exam - 24 SRW line 409, 12128111

f P2-UT,11-048, UT Erosion Corrosion Exam - 24 SRW line 408, 1212811, 2

pictures

lnspection Report, lP3 AFWCond Return to CST (8" line 1080), WO 279578-03, 1219111,

4 pictures

lnspection Report, lP3 CST Supply to AFW Pumps (12" line 1070), WO 279578-03, 1219111,

4 pictures

lP3-UT-11-076. UT E/C Examination lP3 8" line 1080, 12115111

lP3-UT-1 1-077, UT E/C Examination lP3 12" line 1070, 12115111

Commitment 28 (Water Chemistrv - Closed Coolinq)

EPRI TR-107396, Closed Cooling Water Chemistry Guideline, Rev 1

lP-RPT-11-LRD41, Review of the Water Chemistry- Closed Cooling Water AMP for

lmplementation, Rev 0 (draft)

}-CY-2510, Closed Cooling Water Chemistry Specifications and Frequencies, Rev 13

f P2 SBP/App R diesel quarterly chemistry results, March 2008 to January 2012

tP2 Fire pump diesel quarterly chemistry results, January 2007 to December 201 1

lP2 Security diesel quarterly chemistry results, January 2007 to December 2011

Commitment 29 (RWST Sulfates)

IP-RPT-11-LRD42, Review of the Water Chemistry - Primary and Secondary AMP for

lmplementation, Rev 0 (draft)

2-CY-2625, General Plant Systems Specifications and Frequencies, Rev 16

lP2 RWST monthly chemistry results, January 2010 to February 2012

Commitment 36 (Refuelinq Cavitv Concrete)

ER No. lP-RPT-11-00002, Assessment of Concrete Aging From Selected lndian Point

Structures, Rev 0

United Engineers and Constructors Drawing 9321-01-5-1, Specification for Design, Inspection

and Tests of Concrete, High Strength Bolts, Compaction of Fill and Rock Bearing

ASTM C-856-04, Standard Practice for Petrographic Examination of Hardened Concrete

Enclosure

A-3

LIST OF ACRONYMS

ADAMS Agencyruide Documents Access and Management System

AMP Aging Management Program

CLB Current Licensing Basis

EPRI Electric Power Research Institute

LRA License RenewalApplication

NRC U. S. Nuclear Regulatory Commission

RFO Refueling Outage

RWST Refueling Water Storage Tank

SBO Station Blackout

Tl Temporary lnstruction

UFSAR Updated Final Safety Analysis Report

UT Ultrasonic Test

Enclosure