ML061730006

Request for Additional Information Regarding Amendment Application to Revise Technical Specifications

ML061730006
Person / Time
Site:	Indian Point
Issue date:	07/12/2006
From:	Boska J Plant Licensing Branch III-2
To:	Kansler M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MD2178, TAC MD2179
Download: ML061730006 (6)

Text

July 12, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING AMENDMENT APPLICATION TO REVISE TECHNICAL SPECIFICATIONS (TAC NOS. MD2178 AND MD2179)

Dear Mr. Kansler:

On May 31, 2006, Entergy Nuclear Operations, Inc. (Entergy), submitted an application for a proposed amendment for Indian Point Nuclear Generating Unit Nos. 2 and 3 which would revise the Technical Specifications (TSs) on steam generator tube integrity per the TS Task Force (TSTF) change document TSTF-449, "Steam Generator Tube Integrity."

The Nuclear Regulatory Commission staff is reviewing the 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 June 21, 2006, the Entergy staff indicated that a response to the RAI would be provided within 60 days of the date of this letter.

Please contact me at (301) 415-2901 if you have any questions on this issue.

Sincerely,

/RA/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286

Enclosure:

RAI cc w/encl: See next page

ML061730006 OFFICE LPL1-1/PM LPL1-1/LA CSGB/BC LPL1-1/BC NAME JBoska SLittle AHiser RLaufer DATE 7/05/06 7/10/06 7/11/06 7/12/06 Indian Point Nuclear Generating Unit Nos. 2 & 3 cc:

Mr. Gary J. Taylor Ms. Charlene D. Faison Chief Executive Officer Manager, Licensing Entergy Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Mr. Michael J. Columb Senior Vice President and Director of Oversight Chief Operating Officer Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. James Comiotes Mr. Fred R. Dacimo Director, Nuclear Safety Assurance Site Vice President Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 450 Broadway, GSB 450 Broadway, GSB P.O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Patric Conroy Mr. Paul Rubin Manager, Licensing General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 450 Broadway, GSB 450 Broadway P. O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Assistant General Counsel Mr. Oscar Limpias Entergy Nuclear Operations, Inc.

Vice President Engineering 440 Hamilton Avenue Entergy Nuclear Operations, Inc. White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Mr. Peter R. Smith, President New York State Energy, Research, and Mr. Christopher Schwarz Development Authority Vice President, Operations Support 17 Columbia Circle Entergy Nuclear Operations, Inc. Albany, NY 12203-6399 440 Hamilton Avenue White Plains, NY 10601 Mr. Paul Eddy New York State Department Mr. John F. McCann of Public Service Director, Licensing 3 Empire State Plaza Entergy Nuclear Operations, Inc. Albany, NY 12223 440 Hamilton Avenue White Plains, NY 10601 Indian Point Nuclear Generating Unit Nos. 2 & 3

cc:

Regional Administrator, Region I Mr. Jim Riccio U.S. Nuclear Regulatory Commission Greenpeace 475 Allendale Road 702 H Street, NW King of Prussia, PA 19406 Suite 300 Washington, DC 20001 Senior Resident Inspectors Office Indian Point 2 Mr. Phillip Musegaas U. S. Nuclear Regulatory Commission Riverkeeper, Inc.

P.O. Box 59 828 South Broadway Buchanan, NY 10511 Tarrytown, NY 10591 Senior Resident Inspectors Office Mr. Mark Jacobs Indian Point 3 IPSEC U. S. Nuclear Regulatory Commission 46 Highland Drive P.O. Box 59 Garrison, NY 10524 Buchanan, NY 10511 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. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232

REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR TUBE INTEGRITY TECHNICAL SPECIFICATIONS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286 In a letter dated May 31, 2006, Agencywide Documents Access and Management System Accession No. ML061590405, Entergy Nuclear Operations, Inc. (Entergy), submitted an application for a proposed amendment to the Technical Specifications (TSs) for Indian Point Nuclear Generating Unit Nos. 2 and 3 which would revise the TSs on steam generator tube integrity per the TS Task Force (TSTF) change document TSTF-449, "Steam Generator Tube Integrity." The Nuclear Regulatory Commission (NRC) staff is reviewing the submittal and has the following questions:

1. In proposed TS 5.5.7.a for Unit 2 and TS 5.5.8.a for Unit 3, you indicated that condition monitoring will be performed when steam generator tubes are inspected, plugged, to confirm that the performance criteria are being met. Please discuss your plans to correct this apparent typographical error. The phrase should read: are inspected or plugged.

2. In proposed TS 3.4.17 for Unit 2 and 3, the second limiting condition for operation contains the phrase [or repaired] whereas all other references to tube repair have been crossed out. Since repair is not authorized for Unit 2 or 3, please discuss your plans for removing this phrase.

3. In proposed TS 3.4.13, the added text for Action B is not clear. Please confirm that the proposed addition is OR Primary to secondary leakage not within limit.

4. The proposed wording for the last sentence in TS 5.5.8.b.2 for Unit 3 is not clear. It currently reads: Leakage is not to exceed 0.3 gpm [gallons per minute] per SG not to exceed 1 gpm total leakage. Please discuss your plans to clarify this sentence in both your proposed TS and in your Bases (page B 3.4.17-3). For example, Leakage is not to exceed 0.3 gpm per SG and 1 gpm through all SGs.

5. In your proposed Bases, the reference numbers do not appear correct. Please discuss your plans to correct the reference numbers in the Bases. For example:

Insert B 3.4.13 B for Unit 2: Reference 4 in the first paragraph should be Reference 5.

Insert B 3.4.13 D (WOG) for Unit 2: Reference 5 in the first and third paragraph should be Reference 6.

Insert B 3.4.13 B for Unit 3: Reference 4 in the first paragraph should be Reference 3.

Enclosure

Insert B 3.4.13 D (WOG) for Unit 3: Reference 5 in the first and third paragraph should be Reference 4.

6. In the second paragraph on proposed TS Bases page B 3.4.17-2 for Unit 2, there is reference to General Design Criterion (GDC) 19 and Title 10 of the Code of Federal Regulations (10 CFR) Part 100. However, on page B 3.4.13-2, there is reference to a Westinghouse report and NRC Regulatory Guide 1.183. Please confirm that 10 CFR 50.67 is not applicable to your current Unit 2 licensing basis dose assessments.

Similarly, on proposed TS Bases page B 3.4.13-2 for Unit 3, the dose consequences were indicated to be within the limits of 10 CFR 50.67 and the NRC staff approved licensing bases whereas on page B 3.4.17-2, the dose consequences are indicated to be within the limits of GDC19 and 10 CFR 100, or the NRC-approved licensing basis.

Please clarify this apparent discrepancy.

7. In your current Unit 3 safety analyses for reactor coolant system operational leakage (refer to page B 3.4.13-2), there is a statement that the 1 gallon per minute (gpm) primary to secondary leakage is relatively inconsequential. You have proposed to change the 1 gpm to 0.9 gpm. Please discuss the basis for revising this limit. In addition, confirm that the 0.9 gpm is consistent with your current licensing basis for Unit 3.

8. On page B 3.4.13-2 of the Unit 3 TS Bases, there is a statement that the safety analysis for the steam line break accident assumes 432 gallons per day primary to secondary leakage through the affected steam generator. This statement appears to be incomplete. Please confirm that your current licensing basis steam line break accident analysis not only assumes 432 gallons per day leakage but also that the total leakage from all steam generators is limited to 1 gpm. If so, discuss your plans to modify your TS Bases. If this is not the case, please confirm the adequacy of insert B 3.4.13A for Unit 3, which indicates that leakage is limited to 1 gpm from all steam generators.

9. In the Unit 3 Bases for Surveillance Requirement (SR) 3.4.13.1 (page B 3.4.13-5), you indicated that the surveillance is modified by two notes. The next statement then starts with Therefore, this SR..... TSTF-449 indicated that this should have been modified to indicate that Note 1 states.... Please discuss your plans to modify the Bases to be consistent with TSTF-449.

10. Several of the marked-up TS pages you submitted do not match the previously NRC issued pages. For Unit 2, pages ii, iv, and 1.1-3 were issued by the NRC as Amendment No. 238. For Unit 3, page ii was issued by the NRC as Amendment No. 205, and page iv as Amendment No. 207. Please revise the marked-up pages to show the changes from the NRC issued pages.