ML020250149
| ML020250149 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/08/2002 |
| From: | Milano P NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Milano, P , NRR/DLPM, 415-1457 | |
| References | |
| TAC MB3329 | |
| Download: ML020250149 (7) | |
Text
February 8, 2002 Mr. Michael Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED TECHNICAL SPECIFICATION AMENDMENT FOR LABORATORY TESTING OF NUCLEAR-GRADE CHARCOAL (TAC NO. MB3329)
Dear Mr. Kansler:
In a letter dated November 29, 1999, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed change to the Technical Specifications (TSs) for the Indian Point Nuclear Generating Unit No. 3 (IP3). Specifically, ENO requested a change to TS 5.5.10, Ventilation Filter Testing Program, to adopt the criteria of the American Society for Testing and Materials (ASTM)
Standard D3803-1989, Standard Test Method for Nuclear-Grade Activated Carbon, in accordance with the guidance of Generic Letter (GL) 99-02, Laboratory Testing of Nuclear-Grade Activated Carbon. In a letter dated September 20, 2000, the U.S. Nuclear Regulatory Commission (NRC) staff requested additional information regarding the proposed changes.
Based on the concerns raised in the request for additional information (RAI), ENO withdrew its November 29, 1999, application and submitted a revised request for amendment on October 23, 2001.
The NRC staff has reviewed the information in the October 23, 2001, application. On December 11, 2001, the staff held a telephone conference call with representatives of your staff to obtain additional clarification regarding the application. On the basis of the information discussed during the conference call, the NRC staff determined that ENO needs to provide additional information as detailed in the enclosed RAI. On February 4, 2002, the ENO staff indicated that a response would be provided within 60 days.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-286
Enclosure:
RAI cc w/encl: See next page
Indian Point Nuclear Generating Unit No. 3 cc:
Mr. Jerry Yelverton Chief Executive Officer Entergy Operations 1340 Echelon Parkway Jackson, MS 39213 Mr. Robert J. Barrett Vice President - Operations Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 3 295 Broadway, Suite 3 P. O. Box 308 Buchanan, NY 10511-0308 Mr. Dan Pace Vice President Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James Knubel Vice President Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Joseph DeRoy General Manager Operations Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 3 295 Broadway, Suite 3 P. O. Box 308 Buchanan, NY 10511-0308 Mr. John Kelly Director - Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene Fiason Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Harry P. Salmon, Jr.
Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 3 295 Broadway, Suite 3 P.O. Box 308 Buchanan, NY 10511-0308 Mr. John Donnelly Licensing Manager Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 3 295 Broadway, Suite 3 P.O. Box 308 Buchanan, NY 10511-0308 Mr. John McCann Manager, Licensing and Regulatory Affairs Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Unit 2 295 Broadway, Suite 1 P. O. Box 249 Buchanan, NY 10511-0249 Resident Inspectors Office U.S. Nuclear Regulatory Commission 295 Broadway, Suite 3 P.O. Box 337 Buchanan, NY 10511-0337 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue
Indian Point Nuclear Generating Unit No. 3 cc:
Mail Stop: L-ENT-15E New Orleans, LA 70113 Mr. William M. Flynn, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. J. Spath, Program Director New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy Electric Division New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Mr. Ronald Schwartz SRC Consultant 64 Walnut Drive Spring Lake Heights, NJ 07762 Mr. Ronald J. Toole SRC Consultant Toole Insight 605 West Horner Street Ebensburg, PA 15931 Mr. Charles W. Hehl SRC Consultant Charles Hehl, Inc.
1486 Matthew Lane Pottstown, PA 19465 Mr. Ronald Schwartz SRC Consultant 64 Walnut Drive Spring Lake Heights, NJ 07762 Mr. Ronald J. Toole SRC Consultant Toole Insight 605 West Horner Street Ebensburg, PA 15931 Mr. Charles W. Hehl SRC Consultant Charles Hehl, Inc.
1486 Matthew Lane Pottstown, PA 19465 Mr. Alex Matthiessen Executive Director Riverkeeper, Inc.
25 Wing & Wing Garrison, NY 10524 Mr. Paul Leventhal The Nuclear Control Institute 1000 Connecticut Avenue NW Suite 410 Washington, DC, 20036
Indian Point Nuclear Generating Unit No. 3 cc:
Mr. Karl Copeland Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603
February 8, 2002 Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED TECHNICAL SPECIFICATION AMENDMENT FOR LABORATORY TESTING OF NUCLEAR-GRADE CHARCOAL (TAC NO. MB3329)
Dear Mr. Kansler:
In a letter dated November 29, 1999, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed change to the Technical Specifications (TSs) for the Indian Point Nuclear Generating Unit No. 3 (IP3). Specifically, ENO requested a change to TS 5.5.10, Ventilation Filter Testing Program, to adopt the criteria of the American Society for Testing and Materials (ASTM)
Standard D3803-1989, Standard Test Method for Nuclear-Grade Activated Carbon, in accordance with the guidance of Generic Letter (GL) 99-02, Laboratory Testing of Nuclear-Grade Activated Carbon. In a letter dated September 20, 2000, the U.S. Nuclear Regulatory Commission (NRC) staff requested additional information regarding the proposed changes.
Based on the concerns raised in the request for additional information (RAI), ENO withdrew its November 29, 1999, application and submitted a revised request for amendment on October 23, 2001.
The NRC staff has reviewed the information in the October 23, 2001, application. On December 11, 2001, the staff held a telephone conference call with representatives of your staff to obtain additional clarification regarding the application. On the basis of the information discussed during the conference call, the NRC staff determined that ENO needs to provide additional information as detailed in the enclosed RAI. On February 4, 2002, the ENO staff indicated that a response would be provided within 60 days.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-286
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-1 R/F J. Munday S. Little P. Milano OGC ACRS B. Platchek, RI Accession Number: ML020250149 OFFICE PDI-1\\PM PDI-1\\LA DSSA\\SPLB\\SC DSSA\\SPLB PDI-1\\ASC NAME PMilano SLittle HWalker JHRaval PTam for JMunday DATE 2/6/02 2/6/02 2/6/2002 2/6/2002 2/8/02 OFFICIAL RECORD COPY
Enclosure INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 REQUEST FOR ADDITIONAL INFORMATION PROPOSED TECHNICAL SPECIFICATION AMENDMENT FOR LABORATORY TESTING OF NUCLEAR-GRADE CHARCOAL FOR NRC GENERIC LETTER 99-02 By letter dated November 29, 1999, Entergy Nuclear Operations, Inc. (ENO) submitted a Technical Specification (TS) amendment request in accordance with the guidance of Generic Letter (GL) 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, dated June 3, 1999. In a letter dated September 20, 2000, the NRC staff submitted a request for additional information (RAI) regarding Entergys request. By letter dated October 23, 2001, Entergy submitted a revised TS amendment request to revise Section 5.5.10 of Appendix A to the Indian Point 3 (IP3) TS and withdrew the amendment request dated November 29, 1999. The following RAI is based on our review of Entergys submittal dated October 23, 2001, and a followup telephone conference between the NRC staff and Entergy:
The following questions refer to Containment Fan Cooler Units (CFCU) and the Control Room Air Filtration System (CRAFS), unless otherwise noted:
1.
TS 5.5.10, "Ventilation Filter Testing Program," for the CFCUs requires that a laboratory test of a sample of the charcoal adsorber shows methyl iodide removal efficiency of 85%
when tested in accordance with American Society for Testing and Materials (ASTM)
D3803-89, at a temperature of 86 0F and a relative humidity of 95%. On page 5 of 10 of Attachment II to the October 23, 2001, submittal, ENO states that, The TS efficiency of 85% (equivalent to 15% penetration) provides a factor of safety (penetration assumed in analysis divided by penetration acceptance criteria) of 2 without considering the 1%
allowable bypass. The staff finds that, in reality, the total penetration is 16% (15%
penetration as laboratory tested and 1% bypass) for the CFCUs which will result in a safety factor of 1.875. The NRC staff guidance in GL 99-02 specifies a safety factor of
- 2. Clarify the discrepancy.
2.
On page 4 of 10 of Attachment II to the October 23 submittal, ENO stated that The Indian Point 3 CRVS [control room ventilation system] has two filters (Reference 6) with each having a 1" bed depth that was designed with a residence time of 0.075 seconds at 1,000 cfm. This equates to a face velocity of 66.7 ft/min... (Reference 3). However, (a) Item 2 on page 2 of 3, (b) tabulated items for the CRVS in Attachments I and III on Page 5.0-24, and (c) Item 3.b in Attachment II on page 1 of 10 identified a face velocity of 50 ft/min for 1-inch deep charcoal beds for the CRVS filters. Clarify the discrepancy with respect to the design face velocity and the face velocity used during laboratory testing of a sample of charcoal adsorber, and provide an explanation and justification as to how this condition meets the guidance of GL 99-02.
3.
On page 4 of 10, Paragraphs 3, 4, and 5, of Attachment II, to your submittal dated October 23, 2001, you stated that The current TS for CRAFS requires that impregnated charcoal shall have a methyl iodide removal efficiency 90% at +/- 20% of the accident design flow rate... The proposed TS increases the methyl iodide removal efficiency to
91%... The 1% increase in the required efficiency is to reflect the allowable value of 1% for bypass leakage... The TS efficiency of 91% provides a factor of safety of 1 and 1% allowable for bypass. Dose analyses assumed a methyl iodide removal efficiency of 90% for the charcoal filter. The total penetration is 9% including 1% bypass which results in a safety factor of 1.11.
Provide a discussion explaining how this situation meets the guidance of GL 99-02. On the basis of the above, it is not clear whether adequate protection will be afforded to the operators in the event of a design-basis accident.