ML033010220
| ML033010220 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 11/14/2003 |
| From: | Vissing G NRC/NRR/DLPM/LPD1 |
| To: | Kansler M Entergy Nuclear Operations |
| Vissing G, NRR/DLPM, 415-1441 | |
| References | |
| TAC MC0184 | |
| Download: ML033010220 (7) | |
Text
November 14, 2003 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
JAMES A. FITZPATRICK NUCLEAR POWER PLANT - REQUEST FOR ADDITIONAL INFORMATION CONCERNING RELIEF REQUEST VRR-08 (TAC NO. MC0184)
Dear Mr. Kansler:
The Nuclear Regulatory Commission (NRC) staff has reviewed your submittal dated July 8, 2003, concerning the subject proposed relief request VRR-08 to the James A.
FitzPatrick Inservice Testing Program. The NRC staff has determined that it needs additional information to continue its review. The enclosed request for additional information identifies the information needed to continue the review. The staff discussed the issue with your staff on October 23, 2003, and your staff indicated that you could respond within 60 days from receipt of this letter.
Sincerely,
/RA/
Guy S. Vissing, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/encl: See next page
- See previous concurrence OFFICE PDI-1/PM PDI-1/LA EMEB PDI-1/SC NAME GVissing SLittle*
GBedi for DTerao PTam for RLaufer DATE 11/13/03 11/13/03 11/13/03 11/13/03
FitzPatrick Nuclear Power Plant cc:
Mr. Gary Taylor Chief Executive Officer Entergy Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Theodore H. Sullivan Vice President, Operations Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Brian OGrady General Manager, Plant Operations Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 100 Lycoming, NY 13093 Mr. Dan Pace Vice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Randall Edington Vice President, Operations Support Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John Kelly Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Resident Inspector's Office U. S. Nuclear Regulatory Commission P.O. Box 136 Lycoming, NY 13093 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Director of Oversight Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. William Maquire Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Mr. Andrew Halliday Manager, Regulatory Compliance Entergy Nuclear Operations, Inc.
James A. FitzPatrick Nuclear Power Plant P.O. Box 110 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
FitzPatrick Nuclear Power Plant cc:
Oswego County Administrator Mr. Steven Lyman 46 East Bridge Street Oswego, NY 13126 Mr. Peter R. Smith, Acting President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. John M. Fulton Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Ken L. Graesser BWR SRC Consultant 38832 N. Ashley Drive Lake Villa, IL 60046 Mr. Jim Sniezek BWR SRC Consultant 14601 Layhill Road Silver Spring, MD 20906 Mr. Ron Toole BWR SRC Consultant 605 West Horner Street Ebensburg, PA 15931 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue Mail Stop L-ENT-15E New Orleans, LA 70113
Enclosure REQUEST FOR ADDITIONAL INFORMATION (RAI)
JAMES A. FITZPATRICK NUCLEAR POWER PLANT RELIEF REQUEST VRR-08 HIGH-PRESSURE COOLANT INJECTION (HPCI) AND REACTOR BUILDING CLOSED LOOP COOLING (RBCLC) SYSTEMS CHECK VALVES
Reference:
Entergy Nuclear Operations, Inc., James A FitzPatrick Nuclear Power Plant (Fitzpatrick), Submittal of Relief Request VRR-08 for Third 10-year Interval Inservice Testing Program.
The Nuclear Regulatory Commission (NRC) staff requests the following additional information to complete its review.
RAI 1: The licensee has referenced a recently-approved Valve Relief Request for Entergys River Bend Station Unit 1. See ADAMS Accession Number (ML030300276) as a comparable submittal to the one submitted by the licensee for FitzPatrick in VRR-08. It should be noted that the River Bend Station submittal contained significantly more information than that provided in VRR-08. Please provide complete details (including your reasoning for each valve) in Relief Request VRR-08, as was provided in the Basis for Relief sections of River Bends relief requests. Please see the River Bend Stations submittal to supplement the information in VRR-
- 08. In addition, please include all the appropriate responses of the following RAIs in the relief request, as necessary.
RAI 2: Provide the American Society of Mechanical Engineers Class and size of the reactor building closed-loop cooling (RBCLC) valve 15RBC-214.
RAI 3: Provide all the related piping and instrumentation drawings which contains the relief requests check valves in the HPCI and RBCLC systems.
RAI 4: Relief Request VRR-08 does not address the safety and risk significance of on-line inservice testing (IST) of the check valves. Please address (either in a qualitative or quantitative manner) the potential risk of disassembly and inspection of this check valve on-line compared to while the plant is shutdown for all check valves greater than 2 inches nominal pipe diameter including the HPCI and RBCLC check valves.
RAI 5: Provide sufficient information for NRC staff to reach a safety or risk determination with regards to the leak testing experience and leak tightness reliability of the associated valves and the potential consequences of a loss of isolation capability during disassembly, inspection, and manual exercising of the larger size valves.
RAI 6: Based on the risk significance discussed in RAI 4 above, discuss what preventive or compensatory measures are necessary to maintain safety and minimize risk while performing on-line IST.
RAI 7: Under the section entitled Basis for Relief, the licensee states that the maintenance rule 10 CFR 50.65(a)(4) requires licensees to assess and manage the increase of risk that may result from proposed maintenance activities. However, in order for the staff to evaluate whether the proposed IST alternative is acceptable, the licensee must demonstrate that the alternative provides an acceptable level of quality and safety pursuant to 10 CFR 50.55a(a)(3)(i).
Performing a risk assessment of the proposed on-line testing at the time of IST does not address why on-line testing provides an acceptable level of quality and safety at this time.
Meeting the maintenance rule is a separate regulatory requirement. Nonetheless, discuss how risk insights, as well as other factors, will be used to establish when IST should be performed either on-line or during refueling outages.
RAI 8: Explain how Technical Specification requirements for the HPCI system and/or RBCLC system will be satisfied while performing on-line IST of these check valves in their respective systems. Specifically, address the limiting condition for operation and describe the actions the licensee will take to ensure that on-line IST will be accomplished within the allowed outage time.
Discuss the typical amount of time needed to complete the IST of this check valve, based on previous testing experience. Similarly, describe any contingency plans that will be in effect to provide reasonable confidence that the allowed outage time will not be exceeded if the check valve is found to be in a significantly degraded or unacceptable condition.
RAI 9: For several check valves in the HPCI system for which you are requesting relief, you have provided the associated refueling outage justifications for allowing these check valves to be tested during refueling outages. For each of these check valves, the licensee should discuss why it is now practical to test these valves on-line when the refueling outage justifications appear to justify that testing on-line on a quarterly basis was impractical.