ML081190059

Summary of Telephone Conference Call Held on 04/03/08, Between NRC and Entergy Nuclear Operations, Inc., Concerning Responses to Request for Additional Information Related to the Indian Point, Units 2 & 3, License Renewal Application Metal

ML081190059
Person / Time
Site:	Indian Point
Issue date:	05/08/2008
From:	Kimberly Green NRC/NRR/ADRO/DLR
To:	Entergy Nuclear Operations
Green, Kimberly NRR/DLR/RLRB 415-1627
References
Download: ML081190059 (9)

Text

May 8, 2008 LICENSEE: Entergy Nuclear Operations, Inc.

FACILITY: Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 3, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION -METAL FATIGUE, BOLTED CONNECTIONS, AND BORAFLEX The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on April 3, 2008, to discuss and clarify the staff's draft request for additional information (D-RAI) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staff's D-RAI.

provides a listing of the participants and Enclosure 2 contains a listing of the D-RAI items discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

/RA/ Kimberly Green, Safety Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosures:

1. List of Participants 2. Summary of Discussion cc w/encls: See next page

ML081190059 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME YEdmonds KGreen RFranovich DATE 05/05/08 05/06/08 05/08/08 Letter to Entergy from K. Green, dated May 08, 2008 DISTRIBUTION

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 3, 2008, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION -

METAL FATIGUE, BOLTED CONNECTIONS, AND BORAFLEX

HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr RidsNrrDlrRpb1 RidsNrrDlrRpb2 RidsNrrDlrRer1 RidsNrrDlrRer2 RidsNrrDlrRerb RidsNrrDlrRpob RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDraAplb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter ------------- RFranovich EDacus, OCA BPham GMeyer, RI KGreen MMcLaughlin, RI JCaverly NMcNamara, RI RAuluck DScrenci, RI OPA KChang NSheehan, RI OPA MKowal PCataldo, RI JBoska CHott, RI STurk, OGC DJackson, RI LSubin, OGC BWelling, RI BMizuno, OGC RConte, RI SBurnell, OPA ECobey, RI DMcIntyre, OPA MCox, RI TMensah, OEDO

Indian Point Nuclear Generating Units 2 and 3 cc:

Senior Vice President Entergy Nuclear Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995

Vice President Oversight Entergy Nuclear Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety &

Licensing Entergy Nuclear Operations, Inc. P.O. Box 31995 Jackson, MS 39286-1995

Senior Vice President and COO Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

Assistant General Counsel Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, NY 10601

Manager, Licensing Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

Mr. Paul D. Tonko President and CEO New York State Energy Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399

Mr. John P. Spath New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350

Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Senior Resident Inspector's Office Indian Point 2 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Senior Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Indian Point Nuclear Generating Units 2 and 3 cc:

Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858

Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001

Mr. Phillip Musegaas Riverkeeper, Inc. 828 South Broadway Tarrytown, NY 10591

Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Mr. R. M. Waters Technical Specialist Licensing 450 Broadway P.O. Box 0249 Buchanan, NY 10511-0249 Mr. Sherwood Martinelli 351 Dyckman Peekskill, NY 10566 Ms. Susan Shapiro, Esq. 21 Perlman Drive Spring Valley, NY 10977 John Sipos Assistant Attorney General New York State Department of Law Environmental Protection Bureau The Capitol Albany, NY 12224 Robert Snook Assistant Attorney General Office of the Attorney General State of Connecticut 55 Elm Street P.O. Box 120 Hartford, CT 06141-0120 Ms. Kathryn M. Sutton, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Paul M. Bessette, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Mr. Martin J. O'Neill, Esq.

Morgan, Lewis & Bockius, LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 The Honorable Nita Lowey 222 Mamaroneck Avenue, Suite 310 White Plains, NY 10605

Joan Leary Matthews Senior Counsel for Special Projects Office of General Counsel NYS Department of Environmental Conservation 625 Broadway Albany, NY 12233-5500

ENCLOSURE 1 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 3, 2008

PARTICIPANTS AFFILIATIONSKim Green U.S. Nuclear Re gulator y Commission (NRC)On Yee NRCPeter Wen NRC Jim Davis NRC Bo Pham NRC Jim Medhoff NRC Mike Stroud Enter gy Nuclear O perations, Inc.

(Entergy)Garr y Youn g Enter gy Alan Co x Enter gyTed Iv y Enter gyDon Fronabar ger Enter gyCharlie Ca puto Enter gyJohn Curr y Enter gyNelson Azevedo Enter gyCharlie Jackson Enter gy

ENCLOSURE 2 DRAFT REQUEST FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION METAL FATIGUE April 3, 2008

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on April 3, 2008, to discuss and clarify the following draft requests for additional information (D-RAIs) concerning the Indian Point Nuclear Generating Unit Nos. 2 and 3 license renewal application (LRA).

D-RAI 4.3.1.8-1

License Renewal Application Section 4.3.1 states "Current design basis fatigue evaluations calculate cumulative usage factors (CUFs) for components or sub-components based on design transient cycles." For CUF values listed in LRA Tables 4.3-13 and 4.3-14, please provide the methodology used with sufficient results of the fatigue analysis such that the staff can make a determination based on the guidance described in Standard Review Plan-License Renewal (SRP-LR) (NUREG-1800). Specifically, please describe the details of how environmentally assisted fatigue (EAF) is factored into the calculation of the CUF using F en values. Discussion: The applicant was uncertain as to whether the staff was requesting that they provide the evaluations or a description of evaluations. Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.

License renewal application (LRA) Section 4.3.1 states "Current design basis fatigue evaluations calculate cumulative usage factors (CUFs) for components or sub-components based on design transient cycles." For CUF values listed in LRA Tables 4.3-13 and 4.3-14, please describe the details of how various environmental effects are factored into the calculation of the CUF using F en values. D-RAI 4.3.1.8-2 From the review of EAF analysis of other plants, it was found that the transfer function methodology used in the EAF analysis may not provide valid results, as it is dependent on the inputs. To assist the staff in its review, please provide the EAF analysis for all the NUREG/

CR-6260 locations (components) at Indian Point unless it can be demonstrated that the CUF value is within the ASME Code limit of 1.0 by using the original 40-year analysis value adjusted for 60 years and multiplied by F en, which is consistent with SRP-LR and ASME Code. This analysis should be completed by using NRC-approved fatigue software and the ASME Code,Section III, Subsection NB-3200 methodology (which defines the use of six stress components to determine the stress state and thereby calculates the principal stresses and stress intensities). Justify the analysis method, the load (stress) combination, and the results of the ASME Code analysis if 2-D axis-symmetric modeling is used. In addition, the analysis should apply ASME code rules such as elastic-plastic correction factor, K e, and stress intensities correction factor for modulus of elasticity. This analysis should be performed without the use of the transfer function method.

Discussion: The applicant wanted clarification on the staff's request. The applicant pointed out that the request is a new staff position and that for previous plants, the staff has not requested the analyses to be provided and has accepted a commitment to perform the analyses two years prior to entering the period of extended operation as part of the Fatigue Monitoring Program in accordance with 10 CFR 54.21(c)(1)(iii). Subsequent to the telephone conference, the staff determined that no additional information is needed at this time. Therefore, a formal RAI will not be issued at this time.

D-RAI 4.3.1.8-3 SRP-LR Section 4.3.2.1.1.3 provides the basis for the staff acceptance of an aging management program to address environmental fatigue. It states, "[T]he staff has evaluated a program for monitoring and tracking the number of critical thermal and pressure transients for the selected reactor coolant system components. The staff has determined that this program is an acceptable aging management program to address metal fatigue of the reactor coolant system components according to 10 CFR 54.21(c)(1)(iii)." The staff is unable to determine if the Fatigue Monitoring Program of IP2 and IP3 contain sufficient details to satisfy this criterion, based on the NA items listed in LRA Tables 4.3-13 and 4.3-14. Please provide adequate details of the Fatigue Monitoring Program, specifically the fatigue analysis used in determining the CUF values for the NA locations and how IPEC plans to proceed in monitoring the locations of Tables 4.3-13 and 4.3-14 during the period of extended operation.

Discussion: The applicant wanted clarification on what the staff is requesting. Based on the discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.

Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR) Section 4.3.2.1.1.3 provides the basis for the staff acceptance of an aging management program to address environmental fatigue. It states, "[t]he staff has evaluated a program for monitoring and tracking the number of critical thermal and pressure transients for the selected reactor coolant system components. The staff has determined that this program is an acceptable aging management program to address metal fatigue of the reactor coolant system components according to 10 CFR 54.21(c)(1)(iii)." The staff is unable to determine if the Fatigue Monitoring Program for Indian Point 2 and Indian Point 3 contains sufficient details to satisfy this criterion. Please provide adequate details of the Fatigue Monitoring Program such that the staff can make a determination based on the criterion set forth in SRP-LR Section 4.3.2.1.1.3. Also, please explain in detail the corrective actions and the frequency that such actions will be taken so that the acceptance criteria will not be exceeded in the period of extended operation. (This RAI will be renumbered as RAI 4.3.1.8-2.)

D-RAI 4.3.1.8-4 Section B.1.12 of the LRA amendment, dated January 22, 2008, states, "If ongoing monitoring indicates the potential for a condition outside that analyzed above, IPEC may perform further reanalysis of the identified configuration using established configuration management processes as described above." Please explain in detail what is meant by the phrase "using established configuration management processes." Also, please explain in detail the corrective actions and the frequency that such actions will be taken so the acceptance criteria will not be exceeded in the period of extended operation. Discussion: The applicant stated that it was unclear about the staff's request regarding "configuration management processes." In a subsequent call, the applicant explained that the configuration management processes referred to are those governed by its 10 CFR Part 50, Appendix B Quality Assurance program, and include design input verification and independent reviews which ensure that valid assumptions, transients, cycles, external loadings, analysis methods, and environmental fatigue life correction factors will be used in the fatigue analyses.

Therefore, this portion of question is withdrawn and will not be sent as a formal RAI. The portion of the request that deals with corrective actions will be added to RAI 4.3.1.8-2 (as renumbered).

Non-EQ Bolted Cable Connection AMP D-RAI 3.0.3.3.6-1

With regard to Indian Point Aging Management Program (AMP) B.1.22, "Non-EQ Bolted Cable Connection Program," the license renewal application states that inspection methods may include thermography, contact resistance testing, or other appropriate methods including visual, based on plant configuration and industry guidance. In Generic Aging Lessons Learned (GALL)

AMP XI.E6, the staff recommends thermography, contact resistance testing, or other appropriate methods based on plant configuration and industry guidance for detecting loss of preload or bolt loosening. In the case where visual inspection will be the only method used, provide a technical basis of how this will be sufficient to detect loss of preload or loosening of bolted connections.

Discussion: The applicant stated that this question is similar to an audit question that has been answered and subsequently discussed during two telephone conferences. This issue is being reviewed by the Division of Engineering and, therefore, is withdrawn at this time. However, when the staff has reached a determination, a formal RAI may be issued at such time.

Boraflex AMP

D-RAI 3.0.3.2.3-1 Indian Point 2 Updated Final Safety Analysis Report, Revision 20, dated 2006, Section 14.2.1 on page 55 of 218, states in part that:

"Northeast Technology Corporation report NET-173-01 and NET-171-02 are based on conservative projections of amount of boraflex absorber panel degradation assumed in each sub-region. These projections are valid through the end of the year 2006."

Please confirm that the Boraflex neutron absorber panels in the Indian Point Unit 2 spent fuel pool have been re-evaluated for service through the end of the current licensing period. Also, please discuss the plans for updating the Boraflex analysis during the period of extended operation.

Discussion: The applicant indicated that the question is clear. This D-RAI will be sent as a formal RAI.