NL-13-131, Amendment 14 to License Renewal Application (LRA)

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Amendment 14 to License Renewal Application (LRA)
ML13274A238
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 09/26/2013
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-131
Download: ML13274A238 (17)
v • d • e


Text

Enteray Nuclear Northeast Indian Point Energy Center

%--Entergy 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel (914) 254-2055 Fred Dacimo Vice President Operations License Renewal NL-13-131 September 26, 2013 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

SUBJECT:

Amendment 14 to License Renewal Application (LRA)

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26 REFERENCES 1. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application" (NL-07-039)

2. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Boundary Drawings" (NL-07-040)
3. Entergy Letter dated April 23, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application Environmental Report References" (NL-07-041)
4. Entergy Letter dated October 11, 2007, F. R. Dacimo to Document Control Desk, "License Renewal Application (LRA)" (NL-07-124)
5. Entergy Letter dated November 14, 2007, F. R. Dacimo to Document Control Desk, "Supplement to License Renewal Application (LRA)

Environmental Report References" (NL-07-133)

Dear Sir or Madam:

In the referenced letters, Entergy Nuclear Operations, Inc. applied for renewal of the Indian Point Energy Center operating license. This letter contains Amendment 14 of the License Renewal Application (LRA).

Should you have any questions concerning this report, please contact Mr. Robert W. Walpole, Licensing Manager, at (914) 254-6710.

NL-13-131 Dockets 50-247 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on Sincerely, FRD/rw Attachment 1. Partial Annual Update Amendment for Indian Point Unit No. 2 cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Sherwin E. Turk, NRC Office of General Counsel, Special Counsel Mr. Dave Wrona, NRC Branch Chief, Engineering Review Branch I Ms. Kimberly Green, NRC Sr. Project Manager, Division of License Renewal Mr. Douglas Pickett, NRR Senior Project Manager Ms. Bridget Frymire, New York State Department of Public Service NRC Resident Inspector's Office Mr. Francis J. Murray, Jr., President and CEO NYSERDA

ATTACHMENT 1 TO NL-13-131 Partial Annual Update Amendment for Indian Point Unit No. 2 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

NL-13-131 Page 1 of 14 Docket 50-247 Attachment 1 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 LICENSE RENEWAL APPLICATION PARTIAL ANNUAL UPDATE AMENDMENT In accordance with 10 CFR 54.21(b), each year following submittal of the license renewal application and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the CLB of the facility that materially affects the contents of the license renewal application (LRA), including the FSAR supplement.

This amendment is based on a review of IP2 documents potentially affecting the CLB during the period of September 1, 2012 through June 30, 2013. The purpose of this amendment is to provide an LRA that is consistent with the CLB and IP2 UFSAR as of June 30, 2013. The UFSAR will be submitted to the NRC on or before September 28, 2013 in accordance with NRC letter, "Indian Point Nuclear Generating Unit No. 2 - Actions to be Completed Prior to Entering the Period of Timely Renewal", dated August 19, 2013 (ML13197A034).

The last annual update of the LRA included a review of documents through August 31, 2012. The annual update will be submitted in accordance with 10 CFR 54.21 (b) and will include IP2 document reviews for the period 7/1/13 thru 8/31/13 and Indian Point Unit 3 (IP3) document reviews for the entire period 9/1/12 thru 8/31/13. These two submittals will together provide the IPEC 2013 Annual Update for IP2 and IP3. The annual update will be submitted in December 2013.

The review concluded that certain sections of the LRA are affected by changes to CLB documents and other related LRA reviews. The table below summarizes the changes listing the affected system (if applicable), an explanation of the change (including effect on the LRA), and the affected LRA section.

LRA Sections Affected LRA Section Changes Affected Add GT2/3 Fuel Oil Storage Tank as Appendix A Section requiring periodic thickness A.2.1.8 measurements to the tank bottom.

Add listing of PSPMs for the Fuel Oil Appendix A Section System related to inclusion of GT3-BSD ApedASci in the scope of LR. A.2.1.28

NL-13-131 Page 2 of 14 Docket 50-247 Attachment 1 LRA Section Changes Affected Add black start diesel (GT3-BSD) related to Fuel Oil System to listing for requirement to maintain cooling water to EPRI guidelines in the WCC-Closed Cooling Water Program. Appendix A Section Add station air (IP1) cooling and fresh A.2.1.39 water cooling and black start diesel (GT3-BSD) cooling to the listing of systems to which WCC-Closed Cooling Water Program is applied.

Add GT2/3 Fuel Oil Storage Tank as Appendix B Section requiring periodic thickness B.1.9 measurements to the tank bottom.

Add listing of PSPMs for the Fuel Oil System related to inclusion of GT3-BSD Appendix B Section in the scope of LR. 6.1.29 Add station air (IP1) cooling and fresh water cooling and black start diesel (GT3-BSD) cooling to the listing of systems to which WCC-Closed Cooling Water Program is applied. Appendix B Section Add black start diesel (GT3-BSD) related 8.1.40 to Fuel Oil System to listing for requirement to maintain cooling water to EPRI guidelines.

Add component types to Table 2.3.3 IP2 for the Fuel Oil System (IPEC 2012 Table 2.3.3-13-1P2 Annual Update showed these changes as applying to IP3)

NL-13-131 Page 3 of 14 Docket 50-247 Attachment 1 Changes j LRA Section Affected Add component type fine items to Table 3.3.2-13-1P2 for the Fuel Oil System Table 3.3.2-13-1P2 (IPEC 2012 Annual Update showed these changes as applying to IP3)

EC 40495 added component line items for 'piping' to Table 3.3.2-2-1P2, Service Table 3.3.2-2-1P2 Water and material and aging effects to Section 3.3.2.1.2 Section 3.3.2.1.2 LRA Appendix A A.2.1.8 Diesel Fuel Monitoring Program The Diesel Fuel Monitoring Program is an existing program that entails sampling to ensure that adequate diesel fuel quality is maintained to prevent loss of material and fouling in fuel systems.

Exposure to fuel oil contaminants such as water and microbiological organisms is minimized by periodically draining and cleaning tanks and by verifying the quality of new oil before its introduction into the storage tanks. Sampling and analysis activities are in accordance with technical specifications on fuel oil purity and the guidelines of ASTM Standards D4057-95 and D975-95 (or later revisions of these standards).

Thickness measurements of storage tank bottom surface verify that significant degradation is not occurring.

The One-Time Inspection Program describes inspections planned to verify the effectiveness of the Diesel Fuel Monitoring Program.

The Diesel Fuel Monitoring Program will be enhanced to include the following.

e Revise applicable procedures to include cleaning and inspection of the GT1 gas turbine fuel oil storage tanks, EDG fuel oil day tanks, and SBO/Appendix R diesel generator fuel oil day tank once every ten years.

- Revise applicable procedures to include quarterly sampling and analysis of the SBO/Appendix R diesel generator fuel oil day tank, security diesel fuel oil storage tank, and security diesel fuel oil day tank. Particulates (filterable solids), water and sediment checks will be performed on the samples. Filterable solids acceptance criterion will be _ 10mg/l.

Water and sediment acceptance criterion will be _ 0.05%.

e Revise applicable procedures to include thickness measurement of the bottom surface of the EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel oil day tank, GT1 gas turbine fuel oil storage tanks, GT2/3 fuel oil storage tank, and diesel fire pump fuel oil storage tank once every ten years.

NL-13-131 Page 4 of 14 Docket 50-247 Attachment 1 A.2.1.28 Periodic Surveillance and Preventive Maintenance Program Surveillance testing and periodic inspections using visual or other non-destructive examination techniques verify that the following components are capable of performing their intended function.

" reactor building cranes (polar and manipulator), crane rails, and girders, and refueling platform

" recirculation pump motor cooling coils and housing

" city water system strainer housings and valve bodies

  • charging pump casings

" plant drain components and backwater valves

  • station air containment penetration piping

" HVAC duct flexible connections

" HVAC stored portable blowers and flexible trunks

" EDG exhaust components

" EDG duct flexible connections

" EDG air intake and aftercooler components

" EDG air start components

" EDG cooling water makeup supply valves

" security generator exhaust components

" security generator radiator tubes

  • SBO/Appendix R diesel exhaust components
  • SBO/Appendix R diesel cooling water heat exchangers
  • SBO/Appendix R diesel fuel oil cooler
  • diesel fuel oil trailer transfer tank and associated valves
  • containment cooling duct flexible connections
  • containment cooling fan units internals
  • control room HVAC condensers and evaporators
  • control room HVAC ducts and drip pans
  • control room HVAC duct flexible connections

" circulating water, city water, intake structure system, emergency diesel generator, fresh water cooling, instrument air, integrated liquid waste handling, lube oil, miscellaneous, radiation monitoring, river water, station air, waste disposal, wash water, and water treatment plant system piping, piping components, and piping elements

  • pressurizer relief tank

" main steam safety valve tailpipes

  • atmospheric dump valve silencers
  • off-site power feeder, 138 kV underground transmission cable
  • main condenser tube internal surfaces and condensate system expansion joints
  • instrument air aftercooler tube internal surfaces and filters
  • fresh water/river water heat exchanger internal and external surfaces
  • river water system pump casings
  • wash water system pump casings
  • GT3-BSD jacket water cooling heat exchanger

NL-1 3-131 Page 5 of 14 Docket 50-247 Attachment 1

  • emergency fuel oil trailer transfer tank and related components A.2.1.39 Water Chemistry Control - Closed Cooling Water Program The Water Chemistry Control - Closed Cooling Water Program is an existing program that includes preventive measures that manage loss of material, cracking, or fouling for components in closed cooling water systems (component cooling water (CCW), instrument air cooling (IP2 only), fresh water cooling, black start diesel (GT3-BSD) cooling, conventional closed cooling (CCC),

instrument air closed cooling (IACC), emergency diesel generator cooling, security generator cooling, station air (IP1) cooling and SBO/Appendix R diesel generator cooling. These chemistry activities provide for monitoring and controlling closed cooling water chemistry using procedures and processes based on EPRI guidance for closed cooling water chemistry.

The One-Time Inspection Program for Water Chemistry utilizes inspections or non-destructive evaluations of representative samples to verify that the Water Chemistry Control - Closed Cooling Water Program has been effective at managing aging effects.

The Water Chemistry Control - Closed Cooling Water Program will be enhanced to include the following.

  • Revise appropriate procedures to maintain water chemistry of the SBO/Appendix R diesel generator cooling system per EPRI guidelines.

" Revise appropriate procedures to maintain the security generator, black start diesel (GT3-BSD) and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

Enhancements will be implemented prior to the period of extended operation.

NL-13-131 Page 6 of 14 Docket 50-247 Attachment 1 LRA Appendix B B.1.9 DIESEL FUEL MONITORING Attributes Affected Enhancement

4. Detection of Aging Effects IP2: Revise applicable procedures to include thickness measurement of the bottom surface of the EDG fuel oil storage tanks, EDG fuel oil day tanks, SBO/Appendix R diesel generator fuel day tank, GT1 gas turbine fuel oil storage tanks, GT2/3 fuel oil storage tank, and diesel fire pump fuel oil storage tank once every ten years.

IP3: Revise applicable procedures to include thickness measurement of the bottom surface of the EDG fuel oil day tanks, EDG fuel oil storage tanks, Appendix R fuel oil storage tank, and diesel fire pump fuel oil storage tank once every ten years.

B.1.29 PERIODIC SURVEILLANCE AND PREVENTIVE MAINTENANCE Fuel oil system IP2: Use visual or other NDE techniques to internally inspect the fuel oil cooler for the SBO/Appendix R diesel generator to manage fouling.

Use visual or other NDE techniques to inspect internal and external surfaces of the emergency fuel oil trailer transfer tank and associated valves for loss of material.

IP2 Black Start Diesel (GT3-BSD):

Use visual or other NDE techniques to inspect external surfaces for iacket water cooling heat exchanger (tubes) to manage fouling.

Use visual or other NDE techniques to internally inspect surfaces for stainless steel flexible bellows, carbon steel piping and silencer, and aluminum turbocharger exposed to exhaust gas to manage loss of material and cracking.

NL-13-131 Page 7 of 14 Docket 50-247 Attachment 1 B.1.40 WATER CHEMISTRY CONTROL - CLOSED COOLING WATER Program Description The Water Chemistry Control - Closed Cooling Water Program is an existing program that includes preventive measures that manage loss of material, cracking, or fouling for components in closed cooling water systems: component cooling water (CCW), instrument air closed cooling (IACC),

fresh water cooling, black start diesel (GT3-BSD) cooling, emergency diesel generator cooling, SBO/Appendix R diesel generator cooling (IP2), Appendix R diesel generator cooling (IP3),

security generator cooling, station air cooling (IP1), conventional closed cooling (CCC) (IP2 only),

and turbine hall closed cooling (THCC) (IP3 only). These chemistry activities provide for monitoring and controlling closed cooling water chemistry using IPEC procedures and processes based on EPRI guidelines for closed cooling water issued as EPRI TR-1007820, Closed Cycle Cooling Water Chemistry, Rev. 1, dated April 2004. This guideline supersedes EPRI TR-107396, Closed Cycle Cooling Water Chemistry Guideline, Revision 0, issued November 1997, referenced in NUREG-1 801. Differences in Revision 0 and Revision 1 are described below.

Enhancements Attributes Affected Enhancement

2. Preventive Actions IP2: Revise appropriate procedures to
3. Parameters Monitored or maintain water chemistry of the Inspected SBO/Appendix R diesel generator cooling
5. Monitoring and Trending system per EPRI guidelines.
6. Acceptance Criteria IP2: Revise appropriate procedures to maintain the security generator, black start diesel (GT3-BSD) and fire protection diesel cooling water pH and glycol within limits specified by EPRI guidelines.

NL-13-131 Page 8 of 14 Docket 50-247 Attachment 1 TABLE 2.3.3-13-1P2 FUEL OIL COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW Component Type Intended Function Filter housing Pressure boundary Flexible bellows Pressure boundary Heat exchanger (bonnet) Pressure boundary Heat exchanger (tubes) Heat transfer Heat exchanger (tubes) Pressure boundary Silencer Pressure boundary Turbocharger Pressure boundary

NL-1 3-131 Page 9 of 14 Docket 50-247 Attachment 1 3.3.2-13-1P2 Fuel Oil Systems Summary of Aging Management Review Table 3.3.2-13-1P2: Fuel Oil Systems Component Intended Aging Effect Aging NUREG- Table 1 Typet Fnctone Material Environment Requiring Management 1801 Vol. te Notes Type Function Management Programs 2 Item Item Filter housin Pressure Carbon Air - indoor Loss of External Surfaces VII.l-8 3.3.1-58 A F boundary steel (ext) material Monitoring (A-77)

F Pressure Carbon Loss of Diesel Fuel VII.HI-10 B F boundary steel material Monitoring (A-30) 316 Filter housin Pressure Carbon Air-indoor (int) Loss of External Surfaces V.B-1 boundary steel material Monitoring (E-25) 3.2.1-32 E Flexible Pressure Stainless Air - indoor (ext) None None 31 AAP-1 bellows boundary steel (AP-17)

Periodic -- -- H Flexible Pressure Stainless Exhaust gas Cracking- surveillance and bellows boundary steel (int) fatigue preventive maintenance Periodic VII.H2-2 3.3.1-18 E Flexible Pressure Stainless Exhaust gas Loss of surveillance and (-7 bellows boundary steel (int) material preventive maintenance

NL-13-131 Page 10 of 14 Docket 50-247 Attachment 1 Table 3.3.2-13-1P2: Fuel Oil Systems Component Intended Aging Effect Aging NUREG- Table 1 Function Material Environment Requiring Management 1801 Vol. Item Notes Type Management Programs 2 Item Heat Carbon Air - indoor Loss of External Surfaces VII.l-8 (A3.8 3.3.1-58 A Heat Pressure (bonnet) boundary steel (ext) material Monitoring Heat Pressure Carbon Treated water Loss of Water chemistry VII.C2-1 3.3.1-48 D exchan-qer Peure Carbo Treated control - closed (A-63)

(bonnet) boundary steel (int) material cooling water Copper Periodic .... G Heat eat Heat Coy surveillance and exchan)er transfer alloy >15% Air- indoor (ext) Foulina preventive (tubes) Zn maintenance Heat Heat Copper Treated water Water chemistry VII.C2-2 3.3.1-52 D exchanger alloy >15% Tted Fouling control - closed (AP-80)

(tubes) Zn cooling water Heat Pressure Copper V.F-3 3.2.1-53 C exchangqer alloy >15% Air - indoor (ext) None None (EP-10)

(tubes) boundary Zn Heat Pressure Copper Treated water Loss of VII.H1-4 exchanger boundar alloy >15% (int) material Selective leachingq (AP43) 3.3.1-84 C (tubes) Zn Heat Pressure Copper Treated water Loss of Water chemistry VII.E1-2 exchangqer bounda alloy >15% control - closed (AP-34) 3.3.1-51 Q (tubes)n int) material coolingq water

NL-13-131 Page 11 of 14 Docket 50-247 Attachment 1 Table 3.3.2-13-1P2: Fuel Oil Systems Component Intended Aging Effect Aging NUREG- Table 1 Material Environment Requiring Management 1801 Vol. Item Notes Type Function Management Programs 2 Item Water chemistry VII.H2-23 3.3.1-47 D Loss of control - closed (A-253 Pressure Carbon Treated water Piping steel (int) material coolin-q water boundary Periodic VII.H2-2 3.3.1-18 E Pressure Carbon Exhaust gas Loss of surveillance and (A-27) boundary steel (int) material preventive maintenance V.A-19 (E-29) 3.2.1-32 E Carbon Air indLoss of External Surfaces PiingPressure Monitoring(

Presboundary sl Air- indoor (int) material None V.F-2 (EP-3) 3.2.1-50 C PiigPressure Air - indoor None boundary Aluminum (ext)

V.F-2 3.2.1-50 C Piping boundary Aluminum Air - indoor (int) None None (EP-3)

External surfaces VII.I-8 3.3.1-58 A Silencer Pressure Carbon Air - indoor (ext) Loss of boundary steel material monitoring (A-77)

Periodic .... H Pressure Carbon Exhaust gas Cracking- surveillance and boundary steel (int) fatigue preventive maintenance

NL-1 3-131 Page 12 of 14 Docket 50-247 Attachment 1 Table 3.3.2-13-1P2: Fuel Oil Systems Component Typoen Intended Incten Material Environment Aging Effect Requiring Aging Management NUREG-1801 Vol Table te 1 Notes Type Function Management Programs 2 Item Item Periodic VII.H2-2 3.3.1-18 E Silencer Pressure Carbon Exhaust gas Loss of surveillance and (A-27) boundary steel (int) material preventive maintenance Loss of External surfaces VII.I-8 3.3.1-58 A Turbocharger Pressure Gray cast Air - indoor (ext) boundary iron material monitoring (A-77)

Tbhr Pressure Gray cast Air - indoor (int) Loss of External surfaces V.A-19 3.2.1-32 E urocaerboundary iron material monitoring (E-29)

Pressure V.F-2 Turbocharger boundary Aluminum Air - indoor (int) None None (EP.-3) 3.2.1-50 C Periodic -- -- G Turbochare Pressure Aluminum Exhaust as Loss of surveillance and boundary (int) material preventive maintenance

NL-13-131 Page 13 of 14 Docket 50-247 Attachment I Table 3.3.2-2-1P2 Service Water System Summary of Aging Management Review Table 3.3.2-2-1P2: Service Water System Component Intended Aging Effect Aging NUREG- TableI No Material Environment Requiring Management 1801 Vol. Item tes Type Function Management Programs 2 Item ELM Pressure Plastic Raw water (int) Chanqe in Service Water F boundary material Integrity properties Piping Pressure Plastic Air - indoor (ext) None None F boundary

NL-13-131 Page 14 of 14 Docket 50-247 Attachment 1 3.3.2.1.2 Service Water Materials Service water system components are constructed of the following materials.

  • Plastic Aging Effects Requiring Management The following aging effects associated with the service water system require management.
  • chanae in material Droperties
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