JAFP-10-0008, Response to Request for Additional Information Regarding Generic Letter 2008-01 for the James A. FitzPatrick Nuclear Power Plant

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Response to Request for Additional Information Regarding Generic Letter 2008-01 for the James A. FitzPatrick Nuclear Power Plant
ML100220458
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 01/18/2010
From: Peter Dietrich
Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, JAFP-10-0008
Download: ML100220458 (5)
v • d • e


Text

"" Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Pete Dietrich Site Vice President JAFP-10-0008 January 18, 2010 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Subject:

Response to Request For Additional Information Regarding Generic Letter 2008-01 for the James A. FitzPatrick Nuclear Power Plant Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

References:

1. Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", dated January 11, 2008.
2. Supplemental Response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core.Cooling, Decay Heat Removal, and Containment Spray Systems" (JAFP-09-0037), dated March 31, 2009.
3. NRC Request for Additional Information, dated November 9, 2009.

Dear Sir or Madam:

On March 31, 2009, James A. FitzPatrick Nuclear Power Plant (JAF) submitted a Supplemental Response to NRC Generic Letter 2008-01 (Reference 2). On November 09, 2009, JAF received two Request for Additional Information (RAI) questions (Reference 3). On December 03, 2009, JAF and the NRC Staff participated in a conference call to clarify these questions.

JAF's response to these questions is contained in enclosure 1 to this letter.

There are no commitments made in this letter.

Should you have any questions,. lease contact Mr. Joseph Pechacek at (315) 349-6766.

I declare under penalty rury th the enclosed information is true and correct.

nd of Jan ry, 2010.

Pete Dietric Site Vice President AeW PD:JP:mh ,Uýk

JAFP-10-0008 Page 2 of 2

. Enclosure 1: RAI Questions and Responses cc:

Mr. Samuel Collins Mr Francis Murray Regional Administrator, Region I New York State Energy Research and U.S. Nuclear Regulatory Commission Development Authority 475 Allendale Road 17 Columbia Circle King of Prussia, Pennsylvania 19406-1415 Albany, New York 12203-6399 Mr. Bhalchandra Vaidya, Project Manager Mr. Paul Eddy Plant Licensing Branch I-1 New York State Department of Public Division of Operating Reactor Licensing Services Office of Nuclear Reactor Regulation 3 Empire State Plaza U.S. Nuclear Regulatory Commission Albany, New York 12233-1350 Mail Stop O-8-C2A Washington, DC 20555-0001 Mr. Charles Donaldson, Esquire Assistant Attorney General Resident Inspector's Office New York Department of Law U.S. Nuclear Regulatory Commission 120 Broadway James A. FitzPatrick Nuclear Power Plant New York, New York 10271 P.O. Box 136 Lycoming, New York 13093

JAFP-1 0-0008 Enclosure 1 RAI QUESTIONS and RESPONSES (2 Pages)

JAFP-10-0008 Enclosure 1 RAI Questions and Responses RAI QUESTION 1:

In the enclosure to letter dated March 31, 2009 you refer to "LO-LAR-2008-00020, CA-1 5 & CA-20" multiple times throughout the document relative to potential corrective actions. Specifically, you state that, "procedural enhancements were identified and will be made." You also make statements such as, "Consideration of venting at installed system vent locations could be an enhancement to the surveillance test," and "Procedural guidance should be considered to be developed for filling/venting systems following maintenance activities."

What specific improvement actions were ultimately implemented or are planned to be implemented per "LO-LAR-2008-00020, CA-15 & CA-20?" Please provide a general summary addressing this question for the staff to understand what was .completed and/or what will be completed.

RESPONSE

The following changes have been made following evaluation performed under LO-LAR-2008-00020, corrective actions 15 and 20.

Operating procedures for the Residual Heat Removal (RHR) and the Core Spray (CS) systems (OP-13 and OP-14 respectively) were revised to include additional guidance for filling and venting following maintenance.

Surveillance tests for the RHR Loop A and B Monthly Operability Tests (ST-2AN and ST-2AO) and the Core Spray Loop A and B Monthly Operability Tests (ST-3AA and ST-3AB) were revised to require a condition report be written in the event that air is observed while venting.

Venting is only performed in the event that the keep-full level switches are inoperable.

Surveillance tests for the RHR Loop A and B Quarterly Operability Tests (ST-2AL and ST-2AM) and the Core Spray Loop A and B Quarterly Operability Tests (ST-2PA and ST-2PB) were revised to require the venting of the keep-full level switches and to require a condition report be written in the event that air is observed while venting.

Page 1 of 2

JAFP-10-0008 Enclosure 1 RAI Questions and Responses RAI QUESTION 2:

Discuss the surveillance intervals for the monitored locations, including justifications for surveillance intervals greater than a month.

RESPONSE

On a monthly basis, the "A"and "B"Residual Heat Removal (RHR) loops are surveilled to assess whether the pipes are adequately full. (ST-2AN and ST-2AO, RHR Loop A and B Monthly Operability Tests).

On a monthly basis, the "A"and "B"Core Spray (CS) loops are surveilled to assess whether the pipes are adequately full. (ST-3AA and ST-3AB, Core Spray Loop A and B Monthly Operability Tests).

On a monthly basis, the High Pressure Coolant Injection (HPCI) is surveilled to assess whether the pipes are adequately full. (ST-4B, HPCI Monthly Operability Test).

Page 2 of 2

Text

"" Entergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Pete Dietrich Site Vice President JAFP-10-0008 January 18, 2010 U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

Subject:

Response to Request For Additional Information Regarding Generic Letter 2008-01 for the James A. FitzPatrick Nuclear Power Plant Entergy Nuclear Operations, Inc.

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-59

References:

1. Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", dated January 11, 2008.
2. Supplemental Response to NRC Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core.Cooling, Decay Heat Removal, and Containment Spray Systems" (JAFP-09-0037), dated March 31, 2009.
3. NRC Request for Additional Information, dated November 9, 2009.

Dear Sir or Madam:

On March 31, 2009, James A. FitzPatrick Nuclear Power Plant (JAF) submitted a Supplemental Response to NRC Generic Letter 2008-01 (Reference 2). On November 09, 2009, JAF received two Request for Additional Information (RAI) questions (Reference 3). On December 03, 2009, JAF and the NRC Staff participated in a conference call to clarify these questions.

JAF's response to these questions is contained in enclosure 1 to this letter.

There are no commitments made in this letter.

Should you have any questions,. lease contact Mr. Joseph Pechacek at (315) 349-6766.

I declare under penalty rury th the enclosed information is true and correct.

nd of Jan ry, 2010.

Pete Dietric Site Vice President AeW PD:JP:mh ,Uýk

JAFP-10-0008 Page 2 of 2

. Enclosure 1: RAI Questions and Responses cc:

Mr. Samuel Collins Mr Francis Murray Regional Administrator, Region I New York State Energy Research and U.S. Nuclear Regulatory Commission Development Authority 475 Allendale Road 17 Columbia Circle King of Prussia, Pennsylvania 19406-1415 Albany, New York 12203-6399 Mr. Bhalchandra Vaidya, Project Manager Mr. Paul Eddy Plant Licensing Branch I-1 New York State Department of Public Division of Operating Reactor Licensing Services Office of Nuclear Reactor Regulation 3 Empire State Plaza U.S. Nuclear Regulatory Commission Albany, New York 12233-1350 Mail Stop O-8-C2A Washington, DC 20555-0001 Mr. Charles Donaldson, Esquire Assistant Attorney General Resident Inspector's Office New York Department of Law U.S. Nuclear Regulatory Commission 120 Broadway James A. FitzPatrick Nuclear Power Plant New York, New York 10271 P.O. Box 136 Lycoming, New York 13093

JAFP-1 0-0008 Enclosure 1 RAI QUESTIONS and RESPONSES (2 Pages)

JAFP-10-0008 Enclosure 1 RAI Questions and Responses RAI QUESTION 1:

In the enclosure to letter dated March 31, 2009 you refer to "LO-LAR-2008-00020, CA-1 5 & CA-20" multiple times throughout the document relative to potential corrective actions. Specifically, you state that, "procedural enhancements were identified and will be made." You also make statements such as, "Consideration of venting at installed system vent locations could be an enhancement to the surveillance test," and "Procedural guidance should be considered to be developed for filling/venting systems following maintenance activities."

What specific improvement actions were ultimately implemented or are planned to be implemented per "LO-LAR-2008-00020, CA-15 & CA-20?" Please provide a general summary addressing this question for the staff to understand what was .completed and/or what will be completed.

RESPONSE

The following changes have been made following evaluation performed under LO-LAR-2008-00020, corrective actions 15 and 20.

Operating procedures for the Residual Heat Removal (RHR) and the Core Spray (CS) systems (OP-13 and OP-14 respectively) were revised to include additional guidance for filling and venting following maintenance.

Surveillance tests for the RHR Loop A and B Monthly Operability Tests (ST-2AN and ST-2AO) and the Core Spray Loop A and B Monthly Operability Tests (ST-3AA and ST-3AB) were revised to require a condition report be written in the event that air is observed while venting.

Venting is only performed in the event that the keep-full level switches are inoperable.

Surveillance tests for the RHR Loop A and B Quarterly Operability Tests (ST-2AL and ST-2AM) and the Core Spray Loop A and B Quarterly Operability Tests (ST-2PA and ST-2PB) were revised to require the venting of the keep-full level switches and to require a condition report be written in the event that air is observed while venting.

Page 1 of 2

JAFP-10-0008 Enclosure 1 RAI Questions and Responses RAI QUESTION 2:

Discuss the surveillance intervals for the monitored locations, including justifications for surveillance intervals greater than a month.

RESPONSE

On a monthly basis, the "A"and "B"Residual Heat Removal (RHR) loops are surveilled to assess whether the pipes are adequately full. (ST-2AN and ST-2AO, RHR Loop A and B Monthly Operability Tests).

On a monthly basis, the "A"and "B"Core Spray (CS) loops are surveilled to assess whether the pipes are adequately full. (ST-3AA and ST-3AB, Core Spray Loop A and B Monthly Operability Tests).

On a monthly basis, the High Pressure Coolant Injection (HPCI) is surveilled to assess whether the pipes are adequately full. (ST-4B, HPCI Monthly Operability Test).

Page 2 of 2

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