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 J 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

UNITED STATESNUCLEAR REGULATORY COTTIM ISSIONREGION I475 ALLENDALE ROADKING OF PRUSSIA. PENNSYLVANIA 19406.1415Apri'l L9, 20L2Mr. John Ventosa. Site Vice PresidentEntergy Nuclear Operations, lnc.Indian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INSPECTION REPORT05000247t2012008

Dear Mr. Ventosa:

On March 8,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atthe lndian Point Nuclear Generating Unit 2. The enclosed report documents the results of theinspection, which were discussed on March 8,2012, with Mr. John Curry and members of yourstaff.This inspection was an examination of license renewal activities under Temporary Instruction(Tl) 2516/001, Review of License RenewalActivities. The inspection was directed toward thoseactivities and facilities accessible during the refueling outage. The inspection also reviewed thecompletion of commitments made during the renewed license application process andcompliance with the Commission's rules and regulations and the conditions of your operatinglicense. Within these areas, the inspection involved examination of selected procedures andrepresentative records, observations of activities, and interviews with personnel.On the basis of the samples selected for review, there were no findings of significance identifiedduring this inspection. The NRC staff identified two instances of commitments which could notbe 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 teaminspection in this area prior to September 28,2013, to verify completion along with thecompletion of other commitments.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document systemAgencywide Document Access and Management System (ADAMS). ADAMS is accessible fromthe NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic ReadingRoom).Sincerelv,,e"/^JyffiRichard J. Conte, ChiefEngineering BranchlDivision of Reactor Safety Mr. John VentosaSite Vice PresidentEntergy Nuclear Operations, Inc.Indian Point Energy Center450 Broadway, GSBBuchanan, NY 1051 1-0249

SUBJECT: INDIAN POINT NUCLEAR GENERATING UNIT 2 - NRC INSPECTION REPORT0500024712012008

Dear Mr. Ventosa:

On March 8,2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection atthe Indian Point Nuclear Generating Unit 2. The enclosed report documents the results of theinspection, which were discussed on March 8, 2012, with Mr. John Curry and members of yourstaff.This inspection was an examination of license renewal activities under Temporary Instruction(Tl) 2516/001, Review of License RenewalActivities. The inspection was directed toward thoseactivities and facilities accessible during the refueling outage. The inspection also reviewed thecompletion of commitments made during the renewed license application process andcompliance with the Commission's rules and regulations and the conditions of your operatinglicense. Within these areas, the inspection involved examination of selected procedures andrepresentative records, observations of activities, and interviews with personnel.On the basis of the samples selected for review, there were no findings of significance identifiedduring this inspection. The NRC staff identified two instances of commitments which could notbe 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 teaminspection in this area prior to September 28,2013, to verify completion along with thecompletion of other commitments.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document systemAgencyride Document Access and Management System (ADAMS). ADAMS is accessible fromthe NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic ReadingRoom).

Sincerely,/RNRichard J. Conte, ChiefEngineering BranchlDivision of Reactor SafetyDOCUMENT NAME: G:\DRS\Engineering Branch 1\-- Meyer\lndian Pt 71003\lR 2012-08 lP Rev 2.docx104315ADAMS ACCESSION NUMBER: ML12g suNst Reviewfl Non-Sensitiven SensitiveV!Publicly AvailableNon-Publicly AvailableOFFICERI/DRSRI/DRPRI/DRSNAMEGMeyer/RJC forMGrayRConteDATE4t11t124t19t124t19t12RECORD COPY J. VentosaDocket No. 50-247License No. DPR-26

Enclosure:

NRC f nspection Report 05000247 12012008cc w/enclosure: Distribution via ListServ Distribution Mencl: (via E-mail)W. Dean, RAD. Lew. DRAJ. Trapp, DRPC. Miller, DRS(R{ORAMATL RESOURCE)(RIORAMAlL RESOURCE)(RIDRPMAIL Resource)(RI DRSMArL RESOURCE)J. Clifford, DRP (RlDRPMail Resource)P. Wilson, DRS (R,lDRSMAIL RESOURCE)M. McCoppin, Rl OEDOM. Gray, DRPB. Bickett, DRPS. McCarver, DRPM. Jennerich, DRPM. Catts, SRIA. Ayegbusi, RlD. Hochmuth, AARidsNrrPMlndianPoint ResourceRidsNrrDorlLpll -1 ResourceROPreport ResourceD. Bearde, DRST. Lupold, DRSR. Conte, DRSG. Meyer, DRS U.S. NUCLEAR REGULATORY COMMISSIONREGION IDocket: 50-247License: DPR-26Report: 0500024712012008Licensee: Entergy Nuclear Northeast (Entergy)Facility: lndian Point Nuclear Generating Unit 2Location: Buchanan, NYDates: March 5-8,2012Inspectors: G. Meyer, Senior Reactor Inspector, Division of Reactor SafetyM. Modes, Senior Reactor Inspector, Division of Reactor SafetyAccompanied By: K, Green, Senior Project Manager, Division of License RenewalW. Holston, Senior Technical Reviewer, Division of License RenewalApproved By: Richard J. Conte, ChiefEngineering Branch 1Division of Reactor SafetyEnclosure SUMMARY OF FINDINGSlR 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 activitiesduring the Indian Point Unit 2 refueling outage, lt was conducted by two region basedengineering inspectors under Temporary Instruction 2516/001. No findings were identified. Theinspectors determined that Entergy actions on four commitments (Commitments 28,29,34, and36) were complete and met regulatory expectations as reflected in the staff's safety evaluationreport. lnspection of two commitments (Commitments 2 and 3) concluded that additionalinspection was needed.Enclosure 4.a.4042Report DetailsoTHER ACTTVTTTES (OA)Other - License Renewal Activities (Tl 2516/001 )lnspection ScopeThis inspection was performed by two NRC Region I based inspectors to evaluate thelicense renewal activities at the Indian Point Nuclear Generating Unit 2 in accordancewith Temporary Instruction (Tl) 25161001. As noted in this Tl: "This procedure waswritten to allow for timely verification by NRC inspectors that the applicant has madesufficient progress in implementing its license renewal commitments before entering itspost-4O-year license period and to allow documentation of these inspection activitieswhile the operating license is being considered for renewal." This phase of theinspection is "to be completed during the outage preceding the beginning of the period ofextended operations for the purpose of observing or verifying commitments of tests orother activities that require containment entries or access to rooms that would normallybe posted as a high-radiation area or higher when the reactor is operating." Theinspectors performed in-plant observations of license renewal related activities andsampled Entergy actions on commitments. The bases for the review was the NRCstaff's safety evaluation report (NUREG'1930) and related licensee letters associatedwith licensee renewal regulatory commitments, including Letter NL-11-101, datedAugust 22,2011.Findinss and ObservationsNo findings were identified.ln-Plant ObservationsThe inspectors observed ongoing activities and inspected the general condition ofstructures, systems, and components within the scope of license renewal. Theinspectors performed reviews in the following areas, as related to commitments andaging 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 Entergyactivities to be in accordance with facility programs and procedures.b.b.1Enclosure 2b.2 Commitments - Review CompleteCommitment 28 - Water Chemistrv Control - Closed Coolino Water ProoramCommitment 28 provides that Entergy will "Enhance the Water Chemistry Control-Closed Cooling Water Program to maintain water chemistry of the lP2 SBO/Appendix Rdiesel generator cooling system per EPRI guidelines" and will "Enhance the WaterChemistry Control- Closed Cooling Water Program to maintain the lP2 and lP3 securitygenerator and fire protection diesel cooling water pH and glycolwithin limits specified byEPRI guidelines" by September 28, 2013. The license renewal team inspection(Report 0500024712008006 dated August 1, 2008) had noted that some parameterswere not monitored for some diesels in existing procedures.The inspectors reviewed the implementation plan, EPRI guidelines, revised chemistrysampling 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 limitof <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 GeneratorCommitment 34 provides that "lP2 SBO/Appendix R diesel generator will be installedand operational by April 30, 2008."lnspection Report 0500024712008006, dated August 1, 2008, documented the licenserenewal team inspection of the lP2 SBO/App. R diesel generator following its installationand 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 ConcreteCommitment 36 provides that Entergy will "Perform a one-time inspection and evaluationof a sample of potentially affected lP2 refueling cavity concrete prior to the period ofextended operation. The sample will be obtained by core boring the refueling cavity wallin an area that is susceptible to exposure to borated water leakage. The inspection willEnclosure 3include an assessment of embedded reinforcing steel. A sample of leakage fluid will beanalyzed to determine the composition of the fluid." These actions are scheduled forcompletion by September 28,2013. Commitment 36 also addresses core bores andleakage fluid analysis in the first ten years of the period of extended operation. Duringrefueling operations at Unit 2, leakage through the reactor refuel cavity liner plate hadcaused 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 thereinforcement bars could cause an indeterminate degradation.The inspectors reviewed the test results of concrete cores removed from the lP2 refuelstructure in Engineering Report No. lP-RPT-11-00002, Assessment of Concrete AgingFrom Selected Indian Point Structures, Rev 0, January 10,2011. The originallyspecified 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 coresamples 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 guidanceof American Concrete Institute, ACI214.4R, the calculated equivalent in-structurecompressive strength was 4,341 psi.Reinforcing bars were part of three of the concrete samples taken from the Unit 2 fuelpool structure. The above referenced report noted there was no visible degradation ofthe reinforcing bars. This observation compared favorably with concrete core samplestaken from the Unit 1 fuel pool structure, which was wetted by a boric acid solutionequivalent to Unit 2 for approximately 30 years.Nine samples were taken from the core bores for further interrogation by Petrographywith a Stereo-microscope. These samples were examined in general accordance withASTM C-856-04, Standard Practice for Petrographic Examination of HardenedConcrete. There were observations of concrete paste discoloration and cracks noted inthe Petrographic samples taken from the core samples extracted from the west andsouth walls of the fuel pool. The discoloration was attributed to the differences in thehydration of the paste most likely due to exposure to the water through the cracks, andthe 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 ReviewCommitment 2 - Boltino Inteqritv ProqramCommitment 2 provides that Entergy will "Enhance the Bolting lntegrity Program tor lP2and lP3 to clarify that actual yield strength is used in selecting materials for lowsusceptibility to SCC and clarify that prohibition on use of lubricants containing MoSz forbolting" by September 28, 2013. Commitment 2 also states that "The Bolting IntegrityProgram manages loss of preload and loss of material for all external bolting,"Enclosure 4The inspectors reviewed the implementation plan and the revised mechanicalfastenerprocedure, which had specific instructions on bolting regarding the use of actual yieldstrength and the prohibition against molybdenum disulfide as a lubricant. Nonetheless,there was no planned action regarding the second commitment statement regarding lossof preload and loss of material, despite Commitment 2 being considered completed byEntergy. Entergy entered this concern into the license renewal corrective action systemas item LO-LAR-2011-00174, CA-66.The inspectors concluded that the specific procedural instructions of Commitment 2 hadbeen completed, but that review of any action on the general statement needed to bereviewed during a subsequent NRC inspection.Commitment 3 - Buried Pipinq and Tanks lnspection ProqramCommitment 3 provides that Entergy will "lmplement the Buried Piping and TanksInspection Program for lP2 land lP3] as described in LRA Section 8.1.6" and performthe following:o "lnclude in the Buried Piping and Tanks lnspection Program described in LRASection 8.1.6 a risk assessment of the in-scope buried piping and tanks thatincludes consideration of the impacts of buried piping or tank leakage and ofconditions affecting the risk for corrosion.". "Classify pipe segments and tanks as having a high, medium or low impact ofleakage based on the safety class, the hazard posed by fluid contained in thepiping and the impact of leakage on reliable plant operation.". "Determine corrosion risk through consideration of piping or tank material, soilresistivity, 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 demonstratedeffectiveness."The inspectors reviewed the implementation plan and Entergy fleet, corporateengineering and site engineering procedures. The inspectors also reviewed a summaryreport of inspection results, cathodic protection records, and area potential earth current(APEC) survey results.The inspectors reviewed the risk assessment, classifications of leakage impacts, andcorrosion risk categorizations addressed in the first three bulleted items above, andfound the evaluation approaches to be sound and generally credible. The inspectorsreviewed the inspection plan based on these evaluations to be reasonable andappropriate. The inspectors reviewed a sample of inspection records, which showedthat 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-IPECstated that guided wave inspection was an acceptable indirect inspection technique.Enclosure 5The inspectors noted that while guided wave inspection was a credible method to informother inspections, it did not meet the "demonstrated effectiveness" standard and was notsuitable for inspection by itself. There was no evidence that guided wave inspection hadbeen solely used to accept inspected piping or tanks, but the procedure meritedclarification on the use of guided wave inspection. Second, Entergy fleet procedureEN-DC-343 listed the affected Unit 2 underground systems in Attachment 9.2, butomitted the river water, circulating water, and containment isolation support systems.There was no immediate impact on the inspection plan given that these actions were notin effect without a renewed license. However, Entergy will review this matter and theyentered these two concerns into the license renewal corrective action system as itemLO-LAR-201 1 -001 7 4, CA-67 .Given the preliminary progress on Commitment 3, the inspectors determined thatadditional inspection was merited on the clarification of the use of guided waveinspection, coverage of omitted underground systems, and subsequently completedinspections.b.4 Annual Updates10 CFR 54.21(b) requires each year following submittal of the license renewalapplication and at least three months before scheduled completion of the NRC review,an amendment to the renewal application be submitted that identifies any change tothe current licensing basis (CLB) of the facility that materially affects the contents of thelicense renewal application, including the Updated Final Safety Analysis Report(UFSAR) supplement. The inspectors selected a sample from annual update submittalsfor 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 licensebasis during the period May 1, 2008 through March 1, 2009, since the prior annualupdate amendment. The review concluded that sections of the application were affectedby changes to the current licensing basis. For example, during this period, the IndianPoint 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 CFR54.21(b).SummarvNo findings were identified and general conditions in the plant areas observed weresatisfactory. The inspectors determined that Entergy actions on four commitments(Commitments 28, 29,34, and 36) were complete and met regulatory expectations asreflected in the staff's safety evaluation report. Inspection of two commitments(Commitments 2 and 3) concluded that additional inspection was needed. Further NRCinspection of Unit 2 commitments, including Commitments 2 and 3, is planned prior tothe scheduled completion date of September 28,2013.Enclosure 64OAO Exit MeetinoThe inspectors presented the inspection results to Mr. John Curry, License RenewalProject Manager, and other members of the staff on March 8, 2012. The inspectorsconfirmed that no proprietary materialwas examined during the inspection.ATTACHMENT: SUPPLEMENTAL INFORMATIONEnclosure A-1ATTACHMENTSUPPLEMENTAL INFORMATIONKEY POINTS OF CONTACTLicensee PersonnelJ. Curry, License RenewalTeam Project ManagerN. Azevedo, Supervisor, Supervisor Engineering ProgramsC. Caputo, License RenewalTeamG. Dahl, Licensing EngineerR. Drake, System EngineerJ. Flagg, License Renewal TeamD. Lach, License Renewal TeamLIST OF DOCUMENTS REVIEWEDGeneralNUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian PointNuclear Generating Unit Nos. 2 and 3, November 2009NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian PointNuclear Generating Unit Nos. 2 and 3, Supplement 1, August 30, 2011Entergy Letter NL-1 1-101 , Clarification for Request for Additional Information (RAl), datedAugust 22,2011In-plant ObservationsOne-Time Inspection Matrix (draft)One-Time Inspection Form 169473-01One-Time lnspection Form 51 282477 -01WO 00255920, FAC UT of heater drain pipingWO 00255936, FAC UT of reheater drain pipingCommitment 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 3Enclosure A-2Commitment 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 4CEP-UPT-0100, Underground Piping and Tanks lnspection and Monitoring, Rev 0SEP-UlP-lPEC, Underground Components Inspection Plan, Rev 0PCA Engineering Inc, Cathodic Protection System Maintenance Record Sheet,AFW Pump Room Annex - Unit 2, PCA Job No. 30493, 2128112lP-RPT-11-0045, Indian Point Energy Center APEC Survey, 11117111IPEC Underground Piping and Tank Program Completed Buried Pipe lnspections, 1111112Thielsch Engineering, Laboratory Testing Data Sheet, 12112111Photographs 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, 12128111f P2-UT,11-048, UT Erosion Corrosion Exam - 24 SRW line 408, 1212811, 2 pictureslnspection Report, lP3 AFWCond Return to CST (8" line 1080), WO 279578-03, 1219111,4 pictureslnspection Report, lP3 CST Supply to AFW Pumps (12" line 1070), WO 279578-03, 1219111,4 pictureslP3-UT-11-076. UT E/C Examination lP3 8" line 1080, 12115111lP3-UT-1 1-077, UT E/C Examination lP3 12" line 1070, 12115111Commitment 28 (Water Chemistrv - Closed Coolinq)EPRI TR-107396, Closed Cooling Water Chemistry Guideline, Rev 1lP-RPT-11-LRD41, Review of the Water Chemistry- Closed Cooling Water AMP forlmplementation, Rev 0 (draft)}-CY-2510, Closed Cooling Water Chemistry Specifications and Frequencies, Rev 13f P2 SBP/App R diesel quarterly chemistry results, March 2008 to January 2012tP2 Fire pump diesel quarterly chemistry results, January 2007 to December 201 1lP2 Security diesel quarterly chemistry results, January 2007 to December 2011Commitment 29 (RWST Sulfates)IP-RPT-11-LRD42, Review of the Water Chemistry - Primary and Secondary AMP forlmplementation, Rev 0 (draft)2-CY-2625, General Plant Systems Specifications and Frequencies, Rev 16lP2 RWST monthly chemistry results, January 2010 to February 2012Commitment 36 (Refuelinq Cavitv Concrete)ER No. lP-RPT-11-00002, Assessment of Concrete Aging From Selected lndian PointStructures, Rev 0United Engineers and Constructors Drawing 9321-01-5-1, Specification for Design, Inspectionand Tests of Concrete, High Strength Bolts, Compaction of Fill and Rock BearingASTM C-856-04, Standard Practice for Petrographic Examination of Hardened ConcreteEnclosure A-3LIST OF ACRONYMSADAMS Agencyruide Documents Access and Management SystemAMP Aging Management ProgramCLB Current Licensing BasisEPRI Electric Power Research InstituteLRA License RenewalApplicationNRC U. S. Nuclear Regulatory CommissionRFO Refueling OutageRWST Refueling Water Storage TankSBO Station BlackoutTl Temporary lnstructionUFSAR Updated Final Safety Analysis ReportUT Ultrasonic TestEnclosure