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=Text=
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{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2015 Vice President, Operations Entergy Nuclear Operations, Inc.
-0001 July 7, 2015 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249
 
Buchanan, NY 10511
-0249


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 201 5-0 2 (TAC NOS. MD5407 AND MD5408)
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 2015-02 (TAC NOS. MD5407 AND MD5408)


==Dear Sir or Madam:==
==Dear Sir or Madam:==


By letter dated April 23, 2007, as supplemented by letters dated May 3, 2007, and June 21, 2007, Entergy Nuclear Operations, Inc. (Entergy) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 to the U.S. Nuclear Regulatory Commission (NRC). The NRC staff documented its findings in t he Safety Evaluation Report (SER) related to the license renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, which was issued August 11, 2009 and supplemented August 30, 2011 (SER Supplement 1), and November 6, 2014 (SER Supplement 2)
By letter dated April 23, 2007, as supplemented by letters dated May 3, 2007, and June 21, 2007, Entergy Nuclear Operations, Inc. (Entergy) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 to the U.S. Nuclear Regulatory Commission (NRC).
. Subsequen t to the issuance of SER Supplement 1, the staff identified additional operating experience at several nuclear power plants regarding loss of coating integrity of internal coatings. To address this operating experience , on November 14, 201 4 , the NRC staff issued interim staff guidance document LR-ISG-201 3-0 1 , "Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In
The NRC staff documented its findings in the Safety Evaluation Report (SER) related to the license renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, which was issued August 11, 2009 and supplemented August 30, 2011 (SER Supplement 1), and November 6, 2014 (SER Supplement 2).
-Scope Piping, Piping Components, Heat Exchangers, and Tanks
Subsequent to the issuance of SER Supplement 1, the staff identified additional operating experience at several nuclear power plants regarding loss of coating integrity of internal coatings. To address this operating experience, on November 14, 2014, the NRC staff issued interim staff guidance document LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.
."  By letter s dated April 1, 2014 and December 2, 2014, the NRC staff requested additional information as to how Entergy planned to manage the effects of aging as described in LR
By letters dated April 1, 2014 and December 2, 2014, the NRC staff requested additional information as to how Entergy planned to manage the effects of aging as described in LR-ISG-2013-01. By letter dated March 10, 2015, Entergy responded to the NRC staffs request for additional information (RAI). Based on its review of the information contained in Entergys letter, the NRC staff RAIs are as described in the enclosure.
-ISG-201 3-0 1. By letter dated March 10, 2015, Entergy responded to the NRC staff's request for additional information (RAI). Based on its review of the information contained in Entergy's letter, the NRC staff RAIs are as described in the enclosure.
This RAI was discussed with Mr. Richard Louie, and a mutually agreeable date for Entergys response is within 60 days from the date of this letter.
This RAI was discussed with Mr.
 
Richard Loui e, and a mutually agreeable date for Entergy's response is within 60 days from the date of this letter
If you have any questions, please contact me at 301-415-6459, or by e-mail at michael.wentzel@nrc.gov.
.
Sincerely,
If you have any questions, please contact me at 301
                                            /RA/
-415-6459, or by e-mail at michael.wentzel@nrc.gov
Michael Wentzel, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
. Sincerely,
/RA/
Michael Wentzel , Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50
-247 and 50
-286


==Enclosure:==
==Enclosure:==


As stated cc w/encl: Listserv
As stated cc w/encl: Listserv


ML15170A456
ML15170A456                                 *concurred via email OFFICE     LA:DLR             PM: DLR/RPB2           BC:DLR/RPB1       PM: DLR/RPB2 NAME       IBetts             MWentzel               YDiaz-Sanabria   MWentzel DATE       6/22/15           7/6/15                 7/6/15           7/7/15
    *concurred via email OFFICE LA:DLR PM: DLR/RPB2 BC:DLR/RPB1 PM: DLR/RPB2 NAME IBetts MWentzel YDiaz-Sanabria MWentzel DATE 6/22/15 7/6/15 7/6/15 7/7/15


==SUBJECT:==
==SUBJECT:==
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 201 5-0 2 (TAC NOS. MD5407 AND MD5408)
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 2015-02 (TAC NOS. MD5407 AND MD5408)
DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRsrg Resource RidsNrrDraAfpb Resource RidsNrrDeEvib Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsNrrPMIndianPoint Resource
-------------
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


DISTRIBUTION
REQUEST FOR ADDITIONAL INFORMATION, SET 2015-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION DOCKET NOS. 50-247 AND 50-286 REGARDING LR-ISG-2013-01 RAI 3.0.3-16
:
HARD COPY: DLR RF  E-MAIL: PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRsrg Resource RidsNrrDraAfpb Resource RidsNrrDeE vib Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource


RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsNrrPMIndianPoint Resource
===Background===
-------------
As amended by letter dated March 10, 2015, license renewal application (LRA)
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
Table 3.3.2-19-43-IP3, Pressurizer System, states that loss of coating integrity is managed for metal components with internal coating in a treated borated water > 140°F environment by the Coating Integrity Program.
Issue Environments with high temperatures are not evaluated to be bounding within the assumptions of Generic Aging Lessons Learned (GALL) aging management program (AMP) XI.M42, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. The changes to the LRA do not state the specific coating material used in systems with temperatures exceeding 140°F.
Therefore, the staff lacks sufficient information to conclude that the guidance in AMP XI.M42 (e.g., inspection intervals, acceptance criteria) is sufficient for the materials exposed to temperatures greater than 140°F.
Request State the coating materials exposed to temperatures greater than 140°F. Provide the basis for concluding that loss of coating integrity is adequately managed in the subject environment.
RAI 3.0.3-17


ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION, SET 201 5-0 2 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION DOCKET NOS. 50
===Background===
-247 AND 50
As amended by letter dated March 10, 2015, LRA Sections A.2.1.42, A.3.1.42, and B.1.43, Coating Integrity, state that the Coating Integrity Program will be implemented by December 31, 2024. In addition, Commitment 8, as revised, states that LRA Sections A.2.1.13, A.3.1.13 and B.1.14, Fire Water System, will be implemented by December 31, 2019.
-286 REGARDING LR
-ISG-201 3-0 1  RAI 3.0.3-16 Background As amended by letter dated March 10, 2015, license renewal application (LRA)  Table 3.3.2 43-IP3, "Pressurizer System," states that loss of coating integrity is managed for metal components with internal coating in a "treated borated water
> 140°F" environment by the Coating Integrity Program.
Issue Environments with high temperatures are not evaluated to be bounding within the assumptions of Generic Aging Lessons Learned (GALL) aging management program (AMP) XI.M42, "Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In
-Scope Piping, Piping Components, Heat Exchangers, and Tanks."  The changes to the LRA do not state the specific coating material used in systems with temperatures exceeding 140°F. Therefore, the staff lacks sufficient information to conclude that the guidance in AMP XI.M42 (e.g., inspection i ntervals, acceptance criteria) is sufficient for the materials exposed to temperatures greater than 140°F.
Request State the coating materials exposed to temperatures greater than 140°F. Provide the basis for concluding that loss of coating integrity is adequately managed in the subject environment.
RAI 3.0.3-17 Background As amended by letter dated March 10, 2015, LRA Sections A.2.1.42, A.3.1.42, and B.1.43, "Coating Integrity," state that the Coating Integrity Program will be implemented by December 31, 2024. In addition, Commitment 8, as revised, states that LRA Sections A.2.1.13, A.3.1.13 and B.1.14, "Fire Water System," will be implemented by December 31, 2019.
Issue The implementation schedule for LRA Section B.1.43 ranges up to nine years, from 2015 to 2024. In addition, implementation of Commitment 8, as revised, ranges from 2015 to 2019.
Issue The implementation schedule for LRA Section B.1.43 ranges up to nine years, from 2015 to 2024. In addition, implementation of Commitment 8, as revised, ranges from 2015 to 2019.
Standard Review Plan for License Renewal (SRP-LR) Table 3.0-1 for AMP XI.M42 states that the first inspections of internal coatings should be completed no later than the last refueling outage prior to the period of extended operation. The staff recognizes that Indian Point Generating Unit No. 2 has entered timely renewal and Indian Point Generating Unit No. 3 may shortly enter timely renewal. As such, it does not appear that the inspection section schedule recommended in Table 3.0
Standard Review Plan for License Renewal (SRP-LR) Table 3.0-1 for AMP XI.M42 states that the first inspections of internal coatings should be completed no later than the last refueling outage prior to the period of extended operation. The staff recognizes that Indian Point Generating Unit No. 2 has entered timely renewal and Indian Point Generating Unit No. 3 may shortly enter timely renewal. As such, it does not appear that the inspection section schedule recommended in Table 3.0-1 will be met. Further, it is not clear to the staff how loss of coating integrity will be managed in the time frame prior to the programs being implemented.
-1 will be met. Further , it is not clear to the staff how loss of coating integrity will be managed in the time frame prior to the programs being implemented.
ENCLOSURE
Request State how loss of coating integrity will be managed between now and the proposed implementation dates and the basis for concluding that coating integrity will be adequately managed in this time period
 
.}}
Request State how loss of coating integrity will be managed between now and the proposed implementation dates and the basis for concluding that coating integrity will be adequately managed in this time period.}}

Latest revision as of 09:59, 31 October 2019

RAI for the Review of the Indian Point Nuclear Generating Unit Nos. 2 and 3, License Renewal Application, Set 2015-02
ML15170A456
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 07/07/2015
From: Michael Wentzel
License Renewal Projects Branch 2
To:
Entergy Nuclear Operations
Wentzel M, 415-6459
References
TAC MD5407, TAC MD5408
Download: ML15170A456 (6)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 7, 2015 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 2015-02 (TAC NOS. MD5407 AND MD5408)

Dear Sir or Madam:

By letter dated April 23, 2007, as supplemented by letters dated May 3, 2007, and June 21, 2007, Entergy Nuclear Operations, Inc. (Entergy) submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 to renew the operating licenses for Indian Point Nuclear Generating Unit Nos. 2 and 3 to the U.S. Nuclear Regulatory Commission (NRC).

The NRC staff documented its findings in the Safety Evaluation Report (SER) related to the license renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, which was issued August 11, 2009 and supplemented August 30, 2011 (SER Supplement 1), and November 6, 2014 (SER Supplement 2).

Subsequent to the issuance of SER Supplement 1, the staff identified additional operating experience at several nuclear power plants regarding loss of coating integrity of internal coatings. To address this operating experience, on November 14, 2014, the NRC staff issued interim staff guidance document LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.

By letters dated April 1, 2014 and December 2, 2014, the NRC staff requested additional information as to how Entergy planned to manage the effects of aging as described in LR-ISG-2013-01. By letter dated March 10, 2015, Entergy responded to the NRC staffs request for additional information (RAI). Based on its review of the information contained in Entergys letter, the NRC staff RAIs are as described in the enclosure.

This RAI was discussed with Mr. Richard Louie, and a mutually agreeable date for Entergys response is within 60 days from the date of this letter.

If you have any questions, please contact me at 301-415-6459, or by e-mail at michael.wentzel@nrc.gov.

Sincerely,

/RA/

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

ML15170A456 *concurred via email OFFICE LA:DLR PM: DLR/RPB2 BC:DLR/RPB1 PM: DLR/RPB2 NAME IBetts MWentzel YDiaz-Sanabria MWentzel DATE 6/22/15 7/6/15 7/6/15 7/7/15

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION, SET 2015-02 (TAC NOS. MD5407 AND MD5408)

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRerb Resource RidsNrrDlrRsrg Resource RidsNrrDraAfpb Resource RidsNrrDeEvib Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource RidsNrrPMIndianPoint Resource


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, SET 2015-02 RELATED TO INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION DOCKET NOS. 50-247 AND 50-286 REGARDING LR-ISG-2013-01 RAI 3.0.3-16

Background

As amended by letter dated March 10, 2015, license renewal application (LRA)

Table 3.3.2-19-43-IP3, Pressurizer System, states that loss of coating integrity is managed for metal components with internal coating in a treated borated water > 140°F environment by the Coating Integrity Program.

Issue Environments with high temperatures are not evaluated to be bounding within the assumptions of Generic Aging Lessons Learned (GALL) aging management program (AMP) XI.M42, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks. The changes to the LRA do not state the specific coating material used in systems with temperatures exceeding 140°F.

Therefore, the staff lacks sufficient information to conclude that the guidance in AMP XI.M42 (e.g., inspection intervals, acceptance criteria) is sufficient for the materials exposed to temperatures greater than 140°F.

Request State the coating materials exposed to temperatures greater than 140°F. Provide the basis for concluding that loss of coating integrity is adequately managed in the subject environment.

RAI 3.0.3-17

Background

As amended by letter dated March 10, 2015, LRA Sections A.2.1.42, A.3.1.42, and B.1.43, Coating Integrity, state that the Coating Integrity Program will be implemented by December 31, 2024. In addition, Commitment 8, as revised, states that LRA Sections A.2.1.13, A.3.1.13 and B.1.14, Fire Water System, will be implemented by December 31, 2019.

Issue The implementation schedule for LRA Section B.1.43 ranges up to nine years, from 2015 to 2024. In addition, implementation of Commitment 8, as revised, ranges from 2015 to 2019.

Standard Review Plan for License Renewal (SRP-LR) Table 3.0-1 for AMP XI.M42 states that the first inspections of internal coatings should be completed no later than the last refueling outage prior to the period of extended operation. The staff recognizes that Indian Point Generating Unit No. 2 has entered timely renewal and Indian Point Generating Unit No. 3 may shortly enter timely renewal. As such, it does not appear that the inspection section schedule recommended in Table 3.0-1 will be met. Further, it is not clear to the staff how loss of coating integrity will be managed in the time frame prior to the programs being implemented.

ENCLOSURE

Request State how loss of coating integrity will be managed between now and the proposed implementation dates and the basis for concluding that coating integrity will be adequately managed in this time period.