ML090760748

03/02/2009 Summary of Telephone Conference Call Held Between NRC and Entergy Nuclear Operations, Inc., Concerning Draft Request for Additional Information Pertaining to the Indian Point, Units 2 & 3, License Renewal Application - Open Items

ML090760748
Person / Time
Site:	Indian Point
Issue date:	03/25/2009
From:	Green K J License Renewal Projects Branch 2
To:	Entergy Nuclear Operations
Green Kimbrly NRR/DLR/RPB2 415-1627
References
Download: ML090760748 (10)

Text

March 25, 2009 LICENSEE: Entergy Nuclear Operations, Inc.

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

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 2, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - OPEN ITEMS The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., held a telephone conference call on March 2, 2009, to discuss and clarify the staff's draft request for additional information (D-RAI) concerning certain open items identified in the Safety Evaluation Report with Open Items Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3. 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:

1. List of Participants

2. List of Draft Request for Additional Information cc w/encls: See next page

ML090760748 OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR NAME IKing KGreen DWrona DATE / /09 / /09 / /09 Letter to Entergy Nuclear Operations, Inc. from K. Green, dated March 25, 2009 DISTRIBUTION

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON MARCH 2, 2009, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, LICENSE RENEWAL APPLICATION - OPEN ITEMS HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr RidsNrrDlrRpb1 RidsNrrDlrRpb2 RidsNrrDlrRer1 RidsNrrDlrRer2 RidsNrrDlrRerb RidsNrrDlrRpob RidsNrrDciCvib RidsNrrDciCpnb RidsNrrDraAfpb RidsNrrDraAplb RidsNrrDeEmcb RidsNrrDeEeeb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDssScvb RidsOgcMailCenter

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DWrona EDacus, OCA BPham GMeyer, RI KGreen RConte, RI AStuyvenberg ECobey, RI JBoska NMcNamara, RI RAuluck DScrenci, RI OPA JDozier NSheehan, RI OPA MKowal PCataldo, RI STurk, OGC CHott, RI LSubin, OGC DJackson, RI BMizuno, OGC BWelling, RI SBurnell, OPA DMcIntyre, OPA UShoop, OEDO

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

Ms. Jessica Steinberg, J.D. Sive, Paget & Riesel, P.C. 460 Park Avenue New York, NY 10022 Mr. 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

Ms. 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 March 2, 2009

PARTICIPANTS AFFILIATIONSKim Green U.S. Nuclear Re gulator y Commission (NRC)Ra j Auluck NRCHans Ashar NRC Geor ge Thomas NRC Br yce Lehman NRCRich Morante Brookhaven National Laborator y Mike Stroud Enter gy Nuclear O perations, Inc.

(Entergy)Alan Cox Enter gyRich Drake Enter gy

ENCLOSURE 2 DRAFT REQUEST FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION OPEN ITEMS MARCH 2, 2009

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc., (Entergy or the applicant) held a telephone conference call on March 2, 2009, to discuss and clarify the following draft request for additional information (D-RAI) regarding certain open items identified in the Safety Evaluation Report with Open Items Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3).

Follow-up D-RAI 1: Question 359 - Open Item 3.0.3.2.15-1

In Entergy Letter NL-08-169, dated November 6, 2008, "Additional Information Regarding License Renewal Application- Operating Experience Clarification," the applicant submitted a supplemental "clarification," describing its plan for implementing a permanent remediation of the Indian Point Nuclear Generating Unit No. 2 (IP2) refueling cavity leakage over the next three scheduled IP2 re-fueling outages (2010, 2012, 2014).

The transmittal letter NL-08-169, dated November 6, 2008, states: "There are no new commitments identified in this submittal." The applicant has previously taken a bore sample in the region of the leak, and has committed to take another sample prior to entering the period of extended operation. In absence of a formal commitment to remedy the source of leakage, the applicant's aging management program (AMP) should include a method to monitor for a degrading condition in the refueling cavity, and other structures affected by the leakage, during the period of extended operation, or the applicant should explain how the Structural Monitoring Program will adequately manage potential aging of this region 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.

Follow-up D-RAI 2: Question 360 - Open Item 3.0.3.2.15-2

In Entergy Letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental "clarification" for the IP2 spent fuel pool pit walls, which provides a detailed description of (1) the design margins for the spent fuel pool concrete walls; and (2) the results of prior concrete core sample testing and rebar corrosion testing.

a. In Commitment 25, the applicant commits to sample for tritium in groundwater wells in close proximity to the IP2 spent fuel pool at least every three months to assess for potential indications of spent fuel pool leakage. This commitment does not describe what actions will be taken if leakage continues. If sampling indicates continued leakage, the applicant's AMP should include a method to determine if a degraded condition exists during the period of extended operation, or the applicant should explain how the Structural Monitoring Program will adequately manage potential aging of the

inaccessible concrete of the IP2 spent fuel pool due to borated water leakage during the period of extended operation.

b. The second paragraph on page 2 of Attachment 1 of the clarification letter dated November 6, 2008, states in part: "[l]ittle or no corrosion was observed in the rebar except at a location in the wall where spalling had occurred exposing rebar to the elements. Analysis of the rust particles showed high chloride content and low boron concentration indicating that rainwater was the primary cause of the observed corrosion." The staff requests the applicant to identify any Unit 2 and Unit 3 operating experience related to rebar corrosion, in light of the chloride content in rainwater, and identify the likely source for the high chloride content in the rainwater. Further the applicant is requested to explain whether and how the AMP is adequate to address this environment and the related potential aging effects to ensure there is no loss of intended function 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.

Follow-up D-RAI 3: Question 361 - Open Item 3.0.3.3.2-1 In Entergy Letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental "clarification" for IP containment spalling, describing the design margins for the Indian Point (IP) containment structures at the locations of existing concrete degradation on the vertical wall. Based on its review of the information, the staff identified areas that need further clarification and/or additional information to complete its review as described below:

a. The clarification for the IP containment spalling states: "As the surface concrete is not credited for tensile strength of the structure, the spalling has no impact on the available margins." The strength margins identified appear to be based on the nominal rebar dimensions, without any consideration for rebar degradation due to exposure and potential loss of bond between the concrete and the rebar. Explain whether, and if so how, the existing degradation and design margin will be considered in performing periodic inspections to monitor degradation, to ensure there is no loss of containment intended function during the period of extended operation.

b. In the spent fuel pool discussion, in the letter dated November 6, 2008, the applicant stated: "Little or no corrosion was observed in the rebar except at a location in the wall where spalling had occurred exposing rebar to the elements. Analysis of the rust particles showed high chloride content and low boron concentration indicating that rainwater was the primary cause of the observed corrosion." The applicant is requested to explain the adequacy of the 5-year IWL frequency of inspection of the degraded areas of the IP containments during the period of extended operation, considering the possibility of an increased site-specific corrosion rate of the exposed rebar on the containments.

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

Follow-up D-RAI 4: Open Item 3.5-1

In Entergy Letter NL-08-169, dated November 6, 2008, the applicant submitted a supplemental "clarification" to LRA Section 3.5.2.2 related to the concrete mix design method and the durability of concrete used at IP. In the LRA the applicant claimed that concrete meets the specifications of ACI 318-63 and the intent of ACI 201.2R-77, Guide to Durable Concrete. As a result the applicant claimed that several aging effects were not applicable to inaccessible concrete. Based on its review of the information, the staff identified areas that need further clarification and/or additional information to determine that the applicant meets the cited ACI specifications such that further evaluation is not necessary as recommended by the GALL Report. a. In the clarification to LRA Section 3.5.2.2 (Part 1) on page 6 of Attachment 1 to letter NL-08-169, the applicant stated that it used Method 2 of Section 502 of ACI 318-63 by testing trial mixes to determine the water-cement ratios for the concrete mix design of the IP containments and other structures. In order for the staff to evaluate the quality of concrete in IP structures that may be subject to degradation during the period of extended operation, the staff requests the applicant to define the water-cement ratio that was specified at the time of construction. The applicant is requested to provide this information for the IP containments and other safety-related IP Unit 2 and 3 concrete structures, including the refueling cavities and the spent fuel pools.

b. In order for the staff to understand the parameters related to concrete strength and durability during the period of extended operation, the applicant is requested to describe the methodology used to establish the required concrete compressive strength of 3000 psi for the containment and other safety-related concrete structures, in accordance with ACI 318-63, Method 2. The applicant is requested to provide a summary of the results of statistical analyses performed, if any, of the original concrete strength tests, including number of samples, raw strength values from the test, the mean, the standard deviation, and the original criterion (e.g., mean minus 1 standard deviation, coefficient of variation) used to confirm that the required compressive strength was achieved, and can be relied upon during the period of extended operation such that further evaluation is not necessary as recommended by the GALL Report.

c. If the applicant is unable to provide the information requested in parts (a) and (b) above, the applicant is requested to explain how the aging effects on concrete will be adequately managed during the period of extended operation.

Discussion: With regard to part a of the question, during the telephone call, the applicant stated that because it used Method 2 of the ACI 318-63 standard to test the concrete mixtures, there is not one specific water-cement ratio that was "specified" at the time of construction. Therefore, the applicant requested that the word "specified" in the sentence, "-the staff requests the applicant to define the water-cement ratio that was specified at the time of construction," be changed to "used." The staff agreed that this would be a more appropriate term to use given the methodology used to test the concrete. Based on this discussion with the applicant, the staff agreed to revise this question as follows. The revised question will be sent as a formal RAI.

In the clarification to LRA Section 3.5.2.2 (Part 1) on page 6 of Attachment 1 to letter NL-08-169, the applicant stated that it used Method 2 of Section 502 of ACI 318-63 by testing trial mixes to determine the water-cement ratios for the concrete mix design of the IP containments and other structures. In order for the staff to evaluate the quality of concrete in IP structures that may be subject to degradation during the period of extended operation, the staff requests the applicant to define the water-cement ratio that was used at the time of construction. The applicant is requested to provide this information for the IP containments and other safety-related IP Unit 2 and 3 concrete structures, including the refueling cavities and the spent fuel pools.

Follow-up D-RAI 5: Open Item 3.5-2 In Entergy Letter NL-08-169, dated November 6, 2008, "Additional Information Regarding License Renewal Application- Operating Experience Clarification," the applicant submitted a supplemental "clarification" to LRA Section 3.5.2.2 (Part 3) for IP2 containment concrete and its ability to withstand local area temperatures up to 250ºF. The staff has identified areas that need further clarification and/or additional information as discussed below:

a. In the clarification to LRA Section 3.5.2.2 (Part 3) on page 7 of Attachment 1 to letter NL-08-169, the applicant stated that a 15% reduction of concrete strength could be expected when reaching temperatures of 250ºF and that concrete compressive strength tests showed an actual strength more than 15% higher than design strength. Please provide the methodology used to arrive at the conclusion that the actual concrete strength is more than 15% greater than 3000 psi, (i.e., greater than 3450 psi). Provide a summary of the results, including number of samples, raw strength values from the test, the mean, the standard deviation, and the original criterion (e.g., mean minus 1 standard deviation) used to confirm that the claimed strength was achieved.

b. Please explain how consideration was given to the reduction in modulus of elasticity in the high temperature concrete evaluation.

c. If the applicant is unable to provide the information requested in parts (a) and (b) above, the applicant is requested to explain how the aging effects on concrete, due to high temperatures, will be adequately managed 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.

During the telephone call, the staff inquired about the 250ºF local area temperature in the adjoining concrete for penetrations for pipes carrying hot fluid, and whether the air-to-air heat exchangers are needed to maintain the temperature below 250ºF. The applicant stated that it will include information regarding the local area temperature for concrete in near these penetrations when it responds to the RAI.