ML030360451
| ML030360451 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/05/2003 |
| From: | Milano P NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Milano P, NRR/DLPM 415-1457 | |
| References | |
| TAC MB5506 | |
| Download: ML030360451 (9) | |
Text
February 5, 2003 Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING CITY WATER TANK SURVEILLANCE REQUIREMENTS, INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 (TAC NO. MB5506)
Dear Mr. Kansler:
In a letter dated June 24, 2002, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed amendment to change the Technical Specifications (TSs) for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment would revise TS Surveillance Requirements 3.7.7.1 and 3.7.7.2 for the city water system.
The U.S. Nuclear Regulatory Commission staff is reviewing the information provided in the June 24 submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). During a telephone call on January 30, 2003, the ENO staff indicated that a response to the RAI would be provided within 60 days.
If you should have any questions, please do not hesitate to call me.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-286
Enclosure:
RAI cc w/encl: See next page
Mr. Michael R. Kansler Senior Vice President and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING CITY WATER TANK SURVEILLANCE REQUIREMENTS, INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 (TAC NO. MB5506)
Dear Mr. Kansler:
In a letter dated June 24, 2002, Entergy Nuclear Operations, Inc. (ENO) submitted a proposed amendment to change the Technical Specifications (TSs) for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment would revise TS Surveillance Requirements 3.7.7.1 and 3.7.7.2 for the city water system.
The U.S. Nuclear Regulatory Commission staff is reviewing the information provided in the June 24 submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). During a telephone call on January 30, 2003, the ENO staff indicated that a response to the RAI would be provided within 60 days.
If you should have any questions, please do not hesitate to call me.
Sincerely,
/RA/
Patrick D. Milano, Sr. Project Manager, Section 1 Project Directorate 1 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 Reading S. Richards R. Laufer P. Milano S. Weerakkody J. Lehning S. Little P. Eselgroth, RGN-I OGC G. Hill (2)
ACRS Document Name: ML030360451.wpd Accession Number: ML030360451 OFFICE PDI-1:PM PDI-1:LA SPLB:SC SRXB:SC PDI-1:SC NAME PMilano SLittle SWeerakkody FAkstulewicz RLaufer DATE 02/03/03 02/03/03 02/03/03 02/05/03 02/05/03 OFFICIAL RECORD COPY
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 Faison 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 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 Mail Stop: L-ENT-15E New Orleans, LA 70113
Indian Point Nuclear Generating Unit No. 3 cc:
Mr. William M. Flynn, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. J. Spath, Program Director New York State Energy, Research, and Development Authority 17 Columbia Circle 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. 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 Mr. Karl Copeland Pace Environmental Litigation Clinic 78 No. Broadway White Plains, NY 10603 Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001
Enclosure REQUEST FOR ADDITIONAL INFORMATION REGARDING CITY WATER SYSTEM SURVEILLANCE REQUIREMENTS INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 (IP3)
In a letter dated June 24, 2001, Entergy Nuclear Operations, Inc. (the licensee) submitted a proposed amendment to revise Technical Specifications (TSs) surveillance requirements (SR) 3.7.7.1 and 3.7.7.2. Specifically, SR 3.7.7.1 would be changed to require the verification of the city water (CW) tank volume rather than CW header pressure and increase the SR frequency from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. SR 3.7.7.2 would be revised to verify all CW header isolation valves are open rather than only the one header supply isolation valve. The U.S. Nuclear Regulatory Commission (NRC) staff has the following questions regarding the information provided in the proposed amendment:
1.
The NRC staffs interpretation of the current TS 3.7.7 (which includes Limiting Condition for Operation (LCO) 3.7.7 and SR 3.7.7.1) is that the operability requirements apply to the CW system offsite supply and not to the CW tank. The staff has based its interpretation on the TS Bases discussion in Section B 3.7.7 and the former licensees Improved Technical Specifications (ITS) submittal (which established TS 3.7.7).
Specifically, the current TS Bases discussion concerning LCO 3.7.7 includes the statement that [t]he City Water Storage Tank is not required to contain a specific volume of water... In addition, the TS Bases discussion concerning SR 3.7.7.1 includes the statement that [t]his SR verifies that CW header pressure is greater than 30 psig which provides a high degree of assurance that the offsite CW supply is available to the site and properly aligned. In contrast, the June 24, 2002, application contains the statement that [t]he CW header pressure of 30 psig does not provide a true indication of availability of adequate volume of water in the CWT [city water tank].
Based upon the TS Bases citations above, the staff does not believe that the proposed change adequately reflects the intent of the current TS 3.7.7. Specifically, the staff believes that the proposed SR 3.7.7.1 must be evaluated, not on the basis of whether it prescribes a more accurate indication for determining what volume exists in the CWT, but as a proposed change in the specific components or sub-system of the CW system that must be operable to satisfy LCO 3.7.7 (i.e., the CWT rather than the CW offsite supply). Therefore, provide the basis for the licensees interpretation of TS 3.7.7.
2.
In Section 10.2 of the Final Safety Analysis Report (FSAR), in the section entitled Auxiliary Feedwater System, in the subsection entitled Single Failure Criteria, the licensing basis for the minimum volume for the auxiliary feedwater system (AFWS) primary suction source (i.e., the condensate storage tank or CST) is defined as that quantity... which is sufficient to remove residual heat generation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at hot shutdown conditions. A similar statement exists in the section entitled Condensate System, which is also in Section 10.2 of the FSAR. A similar basis for the AFWS can also be found in the Safety Evaluation Report for Indian Point Nuclear Generating Unit No. 3, dated September 21, 1973. For the back-up AFWS suction source proposed in June 24 application (i.e., the CWT), however, the licensee has proposed a different licensing basis, namely that quantity... adequate for a plant cooldown from 102% rated thermal power to RHR entry conditions in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.... Although the volume requirement calculated for the CST and CWT using these different bases is identical (i.e., 360,000 gallons), it is not clear why the CWT licensing basis should be different from the approved licensing basis of the AFWS, the system the required CWT volume would support. Therefore, either: (1) justify the acceptability of the proposed licensing-basis volume requirement that the CWT contain sufficient inventory to cool the reactor from 102% power to RHR entry conditions in 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, or (2) confirm that 360,000 gallons of CWT inventory is sufficient to meet the current licensing-basis requirement for the AFWS for maintaining the reactor at hot shutdown for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a trip from full power.
3.
Provide the following information concerning the calculation of the failure probabilities of both the CST and CWT:
a.
At what wind speeds are these tanks assumed to fail?
b.
What is the analytical basis for the wind speeds assumed to cause the tanks failure?
c.
What tank levels are assumed in the failure probability calculations?
d.
If tank levels greater than those required by TS are assumed in the calculations, please justify their use.
4.
What is the estimated frequency of the CST and CWT both failing due to phenomena generated by a tornado that is within the IP3 design-basis envelope (e.g., considering both high wind loadings alone and high winds combined with a tornado missile impact on one of the tanks)? Excluding the information already provided concerning the calculation of the CST and CWT failure probabilities, explain how the frequency of the tanks concurrent failure due to tornado-related phenomena was derived, including what model and important assumptions were used.
5.
The June 24, 2002, application states that the proposed frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for surveillance [3.7.7.1] has been determined to be acceptable based on the conditional core damage probability evaluated by a PRA [probabilistic risk assessment] study. To support the staffs independent review of the proposed surveillance period extension for SR 3.7.7.1, provide the following additional information:
a.
What is the calculated conditional core damage probability (CCDP) for the proposed interval extension?
b.
What model and important assumptions were used in calculating this CCDP?
c.
To what acceptance criterion was the calculated CCDP compared to determine its acceptability?
d.
What is the basis for using the chosen acceptance criterion?
6.
The Individual Plant Examination for External Events for IP3 states that the CWT is shared with Indian Point Unit 2. The IP3 FSAR also describes other functions performed by the CW system, in addition to serving as a back-up supply to the AFWS.
It is not clear from the TS Bases discussion concerning SR 3.7.7.1 that the 360,000 gallons required to be in the CWT must be dedicated to the IP3 AFWS. Please (1) confirm that the acceptance criterion for SR 3.7.7.1 for minimum volume is a dedicated volume for the IP3 AFWS, and (2) explain why the proposed TS surveillance interval of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is considered acceptable, despite the possibility that the CWT volume may be depleted by unrelated evolutions at IP3 or IP2.