ML022730585

Request for Additional Information, Section 3.8.3 - Diesel Fuel Oil and Starting Air - Beyond Scope Issues No. 8

ML022730585
Person / Time
Site:	Indian Point
Issue date:	10/03/2002
From:	Vissing G NRC/NRR/DLPM/LPD1
To:	Kansler M Entergy Nuclear Operations
Vissing G
References
NUREG-1431, TAC MB5069
Download: ML022730585 (6)

Text

October 3, 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. 2 - REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING SECTION 3.8.3 - DIESEL FUEL OIL AND STARTING AIR - BEYOND SCOPE ISSUE NO. 8 (TAC NO.

MB5069)

Dear Mr. Kansler:

The Nuclear Regulatory Commission staff is reviewing your application for a license amendment dated March 27, 2002, to change the format and content of the current Technical Specifications (TSs) for the Indian Point Nuclear Generating Unit No. 2 (IP2) to be generally consistent with NUREG-1431, Standard Technical Specifications Westinghouse Plants Technical Specifications, Revision 2, dated April 2001.

On the basis of our review of the changes proposed for improved TS Section 3.8.3, Diesel Fuel Oil and Starting Air, we find that additional information identified in the enclosure is needed.

We have discussed this with your staff and it was agreeable to your staff to respond to this RAI and provide comments within 60 days from receipt of this letter.

If you have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-1441 or by electronic mail at gsv@nrc.gov.

Sincerely,

/RA/

Guy S. Vissing, Senior Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

As stated cc w/encl: See next page

ML022730585 OFFICE PDI-1/PM PDI-1/LA SPLB PDI-1/SC NAME GVissing SLittle SWeerakody RLaufer DATE 10/2/02 10-2-02 10-2-02 10/2/02 Indian Point Nuclear Generating Station Unit 2 Mr. Jerry Yelverton Ms. Charlene Fiason Chief Executive Officer Manager, Licensing Entergy Operations Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. Fred Dacimo Mr. John McCann Vice President - Operations Manager, Nuclear Safety and Licensing Entergy Nuclear Operations, Inc. Indian Point Nuclear Generating Unit 2 Indian Point Nuclear Generating Units 1 & 2 295 Broadway, Suite 1 295 Broadway, Suite 1 P. O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Harry P. Salmon, Jr.

Mr. Robert J. Barrett Director of Oversight Vice President - Operations Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. 440 Hamilton Avenue Indian Point Nuclear Generating Units 3 White Plains, NY 10601 295 Broadway, Suite 3 P.O. Box 308 Mr. John M. Fulton Buchanan, NY 10511-0308 Assistant General Counsel Entergy Nuclear Operations, Inc.

Mr. Dan Pace 440 Hamilton Avenue Vice President Engineering White Plains, NY 10601 Entergy Nuclear Operations, Inc.

440 Hamilton Avenue Mr. Thomas Walsh White Plains, NY 10601 Secretary - NFSC Entergy Nuclear Operations, Inc.

Mr. James Knubel Indian Point Nuclear Generating Unit 2 Vice President Operations Support 295 Broadway, Suite 1 Entergy Nuclear Operations, Inc. P. O. Box 249 440 Hamilton Avenue Buchanan, NY 10511-0249 White Plains, NY 10601 Regional Administrator, Region I Mr. Lawrence G. Temple U.S. Nuclear Regulatory Commission General Manager Operations 475 Allendale Road Entergy Nuclear Operations, Inc. King of Prussia, PA 19406 Indian Point Nuclear Generating Unit 2 295 Broadway, Suite 1 Senior Resident Inspector, Indian Point 2 P.O. Box 249 U. S. Nuclear Regulatory Commission Buchanan, NY 10511-0249 295 Broadway, Suite 1 P.O. Box 38 Mr. John Kelly Buchanan, NY 10511-0038 Director of Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Indian Point Nuclear Generating Station Unit 2 Mr. William M. Flynn, President Alex Matthiessen New York State Energy, Research, and Executive Director Development Authority Riverkeeper, Inc.

17 Columbia Circle 25 Wing & Wing Albany, NY 12203-6399 Garrison, NY 10524 Mr. J. Spath, Program Director Paul Leventhal New York State Energy, Research, and The Nuclear Control Institute Development Authority 1000 Connecticut Avenue NW 17 Columbia Circle Suite 410 Albany, NY 12203-6399 Washington, DC, 20036 Mr. Paul Eddy Karl Copeland Electric Division Pace Environmental Litigation Clinic New York State Department 78 No. Broadway of Public Service White Plains, NY 10603 3 Empire State Plaza, 10th Floor Albany, NY 12223 Jim Riccio Greenpeace Mr. Charles Donaldson, Esquire 702 H Street, NW Assistant Attorney General Suite 300 New York Department of Law Washington, DC 20001 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 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue Mail Stop: L-ENT-15E New Orleans, LA 70113

INDIAN POINT 2 IMPROVED TECHNICAL SPECIFICATIONS SECTION 3.8.3, DIESEL FUEL OIL AND STARTING AIR BEYOND SCOPE ISSUE NO. 8 1.0 The Energy Nuclear Operations Inc. (ENO) proposed to convert the Indian Point Unit No. 2 (IP2) Current Technical Specifications (CTSs) to the IP2 Improved Technical Specifications (ITSs) based on NUREG-1431, Standard Technical Specifications (STS) for Westinghouse Plants," Revision 2, dated April 2001. Sections 3.8.3 and Surveillance Requirement (SR) 3.8.3 of the STS include a Limiting Condition for Operation (LCO) and SR, respectively, for the emergency diesel generator (EDG) lube oil inventory required to be maintained in the EDG engine oil sumps. These STS LCO and SRs would be eliminated from the proposed ITS. ENO stated that the required EDG lube oil inventory would be maintained under administrative controls.

With regard to ENOs application requests for removing/relocating existing plant Technical Specifications (TSs) and SRs, the staffs position is that CTS/STS TS and SR that fall within or satisfy any of the four criteria described in 10 CFR 50.36(c)(2)(ii) must be retained in the TS, while those TS sections and SR sections that do not fall within or satisfy any of these criteria may be relocated to other licensees administratively controlled documents, such as plant Technical Requirements Manuals (TRMs).

The lube oil inventory maintained in EDG engine oil sumps is required to support the operation of EDGs which provide the standby AC power sources to the plant. The STS Sections 3.8.3 and SR 3.8.3, regarding EDG lube oil, have direct impact on EDG operability, and meet the minimum requirement1 as described in 10 CFR 50.36(c)(2)(ii) for inclusion in the TSs. Therefore, please revise the proposed ITS to retain the STS LCO and SR imposed on the lube oil inventory required to be maintained in the EDG engine sumps.

2.0 ENO proposed to re-designate Section LCO 3.8.3.E. and Section SR 3.8.3.4 of the STS as Section LCO 3.8.3.F and Section SR 3.8.3.5, respectively, in the ITS.

Section SR 3.8.3.4 of the STS requires verification that each EDG air start receiver pressure is >225 psig once per 31 days. Also, STS Section LCO 3.8.3.E requires that when one or more diesel generators with starting air receiver pressure <225 psig and > 125 psig, restore the starting air receiver pressure to >225 psig within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

ENO proposed to change the range of pressure limits for the air start receivers. Section SR 3.8.3.5 of the proposed ITS requires to verify that each EDG air start receiver pressure is >250 psig once per 31 days. Also, ITS Section LCO 3.8.3.E requires that when one or more diesel generators with starting air receiver pressure <250 psig and > 90 psig, restore the starting air receiver pressure to >250 psig within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.

1 Criterion 3 states: A structure, system, or component (SSC) that is part of the primary success path and which functions or actuates to mitigate a DBA

[Design-Basis Accident] or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

Enclosure

ENO has not provided the rationale for the above proposed changes to the pressure limits for the air start receivers. Please provide detailed discussion, including changes to system design, components, etc., to demonstrate the need for the above proposed changes to the pressure limits for the air start receivers. Also, please demonstrate that at the air receiver pressure of 90 psig, there is adequate capacity for at least one EDG start attempt.

3.0 With regard to the EDG air starting system, Standard Review Plan (SRP) Section 9.5.6, Emergency Diesel Engine Starting System, provides the guidance to size the air receivers. SRP Section 9.5.6, in part, states that as a minimum the air starting system should be capable of cranking a cold diesel engine five times without recharging the air receiver(s). The air starting system capacity should be determined as follows: (1) each cranking cycle duration should be approximately 3 seconds; (2) consist of two to three engine revolutions; or (3) air start requirements per engine start provided by the engine manufacturer; whichever air start requirement is larger. Also, the LCO in STS Section B

3.8.3 states

The starting air system is required to have a minimum capacity for five successive diesel generator start attempts without recharging the air start receivers.

In ITS Section B 3.8.3, regarding sufficient air start capacity for each EDG, ENO proposed to change the above cited five starts to four starts. It is the staffs position that the proposed ITS Section B 3.8.3, regarding sufficient air start capacity for each EDG, should be consistent with the guidance described in the STS. Therefore, please revise the proposed ITS to retain the five start air capacity requirement for the air receivers, and to comply with the STS guidance.