ML081260345

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Summary of Telephone Conference Call Held on April 28, 2008, Between the U.S. NRC and Entergy Nuclear Operations, Inc., Concerning Responses to Request for Additional Information Related to the Indian Point Nuclear Generating Units 2 and 3,
ML081260345
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 05/12/2008
From: Kimberly Green
NRC/NRR/ADRO/DLR
To:
Entergy Nuclear Operations
Green, Kimberly NRR/DLR/RLRB 415-1627
References
Download: ML081260345 (10)


Text

May 12, 2008 LICENSEE: Entergy Nuclear Operations, Inc.

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

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 28, 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 -OPERATING EXPERIENCE The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on April 28, 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.

Enclosure 1 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:

As stated cc w/encls: See next page

ML081260345 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME YEdmonds KGreen RFranovich (BPham for) DATE 05/8/08 05/9/08 05/12/08 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS APRIL 28, 2008

PARTICIPANTS AFFILIATIONSKim Green U.S. Nuclear Re gulator y Commission (NRC)Ken Chan g NRCJim Davis NRC On Yee NRC

Ra j Auluck NRCRich Morante Brookhaven National Laborator y (BNL) Ken Sullivan BNL Mano Subudhi BNL Mike Stroud Enter gy Nuclear O perations, Inc.

(Entergy)Alan Co x Enter gy And y Ta ylor Enter gyCharlie Ca puto Enter gyJohn Curr y Enter gy

Enclosure 1

DRAFT REQUESTS FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION OPERATING EXPERIENCE April 28, 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 28, 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 RCS-1 Review of the condition report (CR) summaries related to Class 1 mechanical systems identified four areas of degraded conditions. Those areas are as follows: (1) borated water leakage/boric acid deposits associated with control rod drive, control rod drive mechanism, resistance temperature device, reactor pressure vessel (RPV) bottom head, seal tables, penetrations, fittings and thimble tubes; (2) seal housing bolt cracks; (3) steam generator tube indications; and (4) RPV head weld indications.

Please provide the following information for each type of degraded condition identified above, in sufficient detail for the staff to make a determination about the adequacy of corrective actions for the extended period of operation:

(a) history of the degradation; (b) evaluation of the extent of degradation; (c) corrective actions already taken or planned; (d) the current status of the degraded condition; (e) special or augmented aging management requirements during the period of extended operation; (f) license renewal commitments.

Based on the staff's review of the CR list, it is not clear to the staff if this list contains all significant plant-specific reactor coolant system (RCS) component degradation experienced at Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3). Please identify and provide the same information (items a-f) for any other significant existing conditions of aging for the RCS not specifically identified in this RAI.

In addition, please identify and provide the same information (items a-f) for other significant existing conditions of aging, if applicable, in any Class 1 mechanical components for LRA Section 3.2 to 3.4.

Discussion: The applicant wanted to understand what the staff is requesting. It appears that the staff is questioning the corrective action program for which there are ongoing inspections that are performed by the Region. The staff stated that the question is parallel to a question on operating experience for structures that was asked during an audit, and that the goal is to show the effectiveness of the applicable aging management programs. Upon this clarification, the applicant stated that it will answer the staff's RAI. This D-RAI will be sent as a formal RAI.

Enclosure 2

D-RAI RCS-2 Based on the review of the plant basis documents associated with operating experience discussions for aging management programs (AMPs) B.1.16, B.1.18, B.1.30, and B.1.31, the staff found that additional information is needed to complete its operating experience review. Therefore, please provide the following additional information to assist the staff in its review:

(i) For AMPs B.1.16, B.1.18, B.1.30, and B.1.31, please describe in sufficient detail the plant-specific CR review that forms the basis to conclude that each of these existing programs will be effective in managing applicable aging effects, as identified in the LRA.

(ii) For new AMPs B.1.37 and B.1.38, which are currently being developed, the AMP description of each program identifies that RCS components will be managed for thermal and/or irradiation embrittlement. Please describe in sufficient detail any operating experience for these AMPs, and the review of plant-specific and industry-wide operating experience for those RCS components that have been identified as potentially susceptible to thermal and/or irradiation embrittlement at IP2 and IP3.

Discussion: The applicant stated that for part (i) of the question, the review of operating experience was not limited to a CR review, and that a description of the process would be provided. For part (ii) of the question, the applicant stated that the programs that are referenced are new programs, and therefore, the plant does not yet have operating experience. The staff asked the applicant if it had reviewed any industry operating experience, and that a description of what it had reviewed and identified as part of that review is what can be provided in its response. The applicant stated that the industry operating experience cited in NUREG-1801 for these programs may be referenced in its response. This D-RAI will be sent as a formal RAI.

D-RAI AUX-1 In reviewing plant basis documents and CR summaries related to operating experience applicable to non-Class 1 mechanical systems in the areas of Diesel Fuel Monitoring, Oil Analysis, Service Water Integrity, Water Chemistry Control Auxiliary Systems and Water Chemistry Control Closed Cooling Water Systems, the staff identified conditions of aging degradation in LRA Section 3.3 that are not described in detail in LRA or plant basis documents. The areas of aging degradation identified by the staff were in the following areas: (1) degraded IP2 traveling screens; (2) eroded fuel line in IP2 utility tunnel caused by in-leakage; (3) erosion/corrosion of IP2 components and thru-wall leaks; (4) IP3 feedwater outer-diameter thinning; and (5) IP3 service water degradation.

The applicant is requested to provide the following information for each type of degraded condition identified above, in sufficient detail for the staff to make a determination about the adequacy of corrective actions for the extended period of operation:

(a) history of the degradation; (b) evaluation of the extent of degradation; (c) corrective actions already taken or planned; (d) the current status of the degraded condition; (e) special or augmented aging management requirements during the period of extended operation; (f) license renewal commitments.

In addition, the applicant is requested to identify and provide the same information (items a-f) for other significant existing conditions of aging in non-Class 1 mechanical components in LRA Sections 3.2 and 3.4, specifically addressed in this RAI.

Discussion: The applicant wanted clarification on the staff's request, particularly part (a). The applicant stated several CRs can comprise one aging degradation category as delineated in the staff's question, and that to provide a history on each CR for each type of degradation would be quite cumbersome. The staff clarified that a summary of the general history for each type of degradation would be sufficient, and that the goal is to show the effectiveness of the applicable aging management programs. Upon this clarification, the applicant stated that it will answer the staff's question. This D-RAI will be sent as a formal RAI.

D-RAI AUX-2 Appendix B of the LRA concluded that the Service Water Integrity Program has been effective in managing those aging effects for which it is credited based on the results of one peer assessment, one self assessment and five NRC inspections of the Generic Letter (GL) 89-13 program. NRC GL 89-13 guidelines are directed to ensure the performance of safety-related systems and components exposed to service water. It is not clear to the staff how the results of these inspections are used to confirm the effectiveness of managing aging effects in nonsafety-related components of the service water system (SWS) that are within scope for license renewal.

The staff requests the applicant to clarify whether the Service Water Integrity Program is credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. If so, please provide evidence for the conclusion presented in the LRA, that this AMP is effective in managing age-related degradation of the SWS. If not, identify the AMP(s) that are credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. Provide the basis for concluding that these programs have been or will be effective for managing aging during the period of extended operation.

Discussion: The applicant pointed out what appears to be a typo. The staff will fix the typo and the revised question will be sent as a formal RAI.

Appendix B of the LRA concluded that the Service Water Integrity Program has been effective in managing those aging effects for which it is credited based on the results of one peer assessment, one self assessment and five NRC inspections of the Generic Letter (GL) 89-13 program. NRC GL 89-13 guidelines are directed to ensure the performance of safety-related systems and components exposed to service water. It is not clear to the staff how the results of these inspections are used to confirm the effectiveness of managing aging

effects in nonsafety-related components of the service water system (SWS) that are within scope for license renewal.

The staff requests the applicant to clarify whether the Service Water Integrity Program is credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. If so, please provide evidence for the conclusion presented in the LRA, that this AMP is effective in managing age-related degradation of the SWS. If not, identify the AMP(s) that are credited for aging management of the nonsafety-related components of the SWS that are within scope for license renewal. Provide the basis for concluding that these programs will be effective for managing aging during the period of extended operation.

Letter to Entergy from K. Green, dated May 12, 2008 DISTRIBUTION

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON APRIL 28, 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-OPERATING EXPERIENCE 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 JBoska NMcNamara, RI RAuluck DScrenci, RI OPA KChang NSheehan, RI OPA MKowal PCataldo, RI STurk, OGC CHott, RI LSubin, OGC DJackson, RI BMizuno, OGC BWelling, RI SBurnell, OPA ECobey, RI DMcIntyre, OPA MCox, RI TMensah, OEDO RConte, RI

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

Indian Point Nuclear Generating Units 2 and 3 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 Street 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