ML073230169
| ML073230169 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/20/2007 |
| From: | Mark Kowal NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Balduzzi M Entergy Nuclear Operations |
| reeves, R NRR/DORL/LPL1-1 301-415-5239 | |
| References | |
| GL-04-002, TAC MC4689 | |
| Download: ML073230169 (7) | |
Text
November 20, 2007 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - APPROVAL OF EXTENSION REQUEST FOR CORRECTIVE ACTIONS REQUIRED BY GENERIC LETTER 2004-02 (TAC NO. MC4689)
Dear Mr. Balduzzi:
In a letter dated September 17, 2007, [Agencywide Document Access and Management System (ADAMS) accession number ML072680835] Entergy Nuclear Operations, Inc. (Entergy) requested an extension to the December 31, 2007, completion deadline for the corrective actions required by Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors for the Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed extension would allow Entergy approximately 3 additional months to perform the final corrective actions, facility modifications, and all licensing activities necessary to achieve full compliance with GL 2004-02, with completion of this effort to coincide with the completion of the IP2 spring 2008 refueling outage, scheduled to begin on March 25, 2008.
The Nuclear Regulatory Commission (NRC) staff has evaluated the information you provided and determined that it is acceptable to extend the completion date for the corrective actions and modifications as described in the referenced letter, until the completion of the IP2 spring 2008 refueling outage. The results of the NRC staffs evaluation of this request are enclosed.
Please contact the Indian Point Project Manager, John Boska, at (301) 415-2901 if you have any questions on this issue.
Sincerely,
/RA/
Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247
Enclosure:
As stated cc w/encl: See next page
ML OFFICE LPL1-1/PM LPL1-1/LA SSIB/BC LPL1-1/BC NAME JBoska SLittle MScott MKowal DATE 11/19/07 11/19/07 11/19/07 11/20/07
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. Michael R. Kansler President & CEO / CNO Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Sr. Vice President Engineering & Technical Services Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Anthony Vitale - Acting General Manager, Plant Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249 Mr. Oscar Limpias Vice President Engineering Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Joseph P. DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. John A. Ventosa GM, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Ernest J. Harkness Director, Oversight Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Mr. Patric W. Conroy Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Robert Walpole Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249 Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601
Indian Point Nuclear Generating Unit No. 2 cc:
Mr. Paul Tonko President and CEO New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. John P. Spath New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector=s Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Senior Resident Inspector=s Office Indian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858 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 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Phillip Musegaas Riverkeeper, Inc.
828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Ms. Susan Shapiro via email Mr. Sherwood Martinelli FUSE USA via email
INDIAN POINT UNIT 2 GSI-191/GL 2004-02 EXTENSION REQUEST APPROVAL In a letter dated September 17, 2007, Entergy Nuclear Operations, Inc. (Entergy) requested an extension to the corrective action due date of December 31, 2007 stated in NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors" (GL 2004-02) for the Indian Point Nuclear Generating Unit No. 2 (IP2).
Entergy has taken actions, as described in their letters dated September 1, 2005 (ML052500197), and December 15, 2005 (ML053570222), toward bringing IP2 into compliance with GL 2004-02, including replacing the sump screens with substantially larger sump strainers during the spring 2006 refueling outage. Further, IP2 is continuing the evaluation of the adequacy of the replacement strainers.
Indian Point Unit 2 has two independent sumps in the containment buildingthe Recirculation Sump and the Containment Sumpthat provide for the recirculation function. The Recirculation Sump is the preferred source of cooling in the recirculation mode of operation, and the Containment Sump is the back-up source. The current design and licensing basis for the Recirculation Sump and Containment Sump is that they are functionally redundant at the initiation of recirculation. However, the licensee stated that evaluations have shown that to comply with GL 2004-02 (including chemical effects), the following additional hardware modifications and operating license amendments are required.
- 2. Installing screens on certain crane wall penetrations.
- 3. Installing grating on the containment sump trench.
- 4. Modifying screens to accommodate sump level instrument housing.
- 5. Increasing the surface area of the containment sump strainer.
- 6. Revising Technical Specification SR 3.6.7.1 to reflect the new buffer type and quantity.
- 7. Amending the Operating License to exempt IP2 sumps from the Single Failure Criteria of 10 CFR 50.46(d) for a large-break loss-of-coolant-accident (LBLOCA) to allow the use of the Alternate Break Methodology as endorsed by the NRC in Nuclear Energy Institute (NEI) 04-07, Volume 1, Pressurized Water Reactor Sump Performance Methodology, and NEI 04-07, Volume 2, Safety Evaluation by the Office of Nuclear Regulatory Regulation Related to NRC Generic Letter 2004-02, Revision 0, dated December 2004.
The criteria for granting an extension to the due date of December 31, 2007, for completion of GL 2004-02 corrective actions are stated in SECY-06-0078. Specifically, an extension may be granted if:
the licensee has a plant-specific technical/experimental plan with milestones and schedule to address outstanding technical issues with enough margin to account for uncertainties, and the licensee identifies mitigative measures to be put in place prior to December 31, 2007, and adequately describes how these mitigative measures will minimize the risk of degraded emergency core cooling system (ECCS) and containment spray system (CSS) functions during the extension period.
Enclosure In regard to the first extension criterion, IP2 has a plant-specific technical/experimental plan, with milestones and schedules, to complete the GL 2004-02 corrective actions and modifications by March 2008. Specifically, the licensee has stated that it will:
- 1. Begin chemical effects testing in November 2007.
- 2. Reevaluate downstream effects to address Westinghouse WCAP-16406P, Revision 1, by November 2007.
- 3. Prepare a containment coating inspection and control program by November 2007.
- 4. Prepare a containment cleanliness inspection and control program by November 2007.
- 5. Issue a strainer certification/qualification report to include chemical effects by February 2008.
- 6. Install the remaining modifications during the spring 2008 refueling outage, and
- 7. Obtain approval of license amendments prior to restart from the spring 2008 refueling outage.
In regard to the second extension criterion, the licensee has stated that the following modifications, mitigative measures, compensatory measures, and/or favorable conditions are in effect at Indian Point Unit 2, minimizing the risk of degraded ECCS and CSS functions during the extension period.
- 1. Larger surface area sump strainers (3200 ft2 strainer replaces 50 ft2 Recirculation Sump screen and 412 ft2 strainer replaces 30 ft2 Containment Sump screen) and flow-channeling measures to reduce debris transport to the sump screens.
- 2. Mitigative measures as described in IP2s response to NRC Bulletin 2003-01, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors. These measures include:
Provision of training to the licensed operators to present the mechanisms and potential consequences of sump clogging.
Provision of procedural guidance within the Emergency Operating Procedures (EOPs) on symptoms and identification of sump blockage.
Development of a new EOP (ECA-1.3, Loss of Emergency Coolant Recirculation Caused by Sump Blockage).
Provision of procedural guidance not to start a second recirculation pump if cavitation is expected.
Provision of procedural guidance to consider refilling the Refueling Water Storage Tank should sump blockage be a concern.
- 3. Mitigative measures that assure containment cleanness, foreign material exclusion and sump and flow channel/barrier operability. These measures include:
Procedural control of containment cleanness (OAP-007 Containment Entry and Egress) that applies after each containment entry and prior to exiting Mode-5 during plant startup.
Procedural controls for foreign material exclusion (IP-SMM-MA-118, Foreign Material Exclusion) that apply to inspection, operation, maintenance and outage activities.
Satisfaction of operability of the sumps and flow channel/barrier by Engineering visual inspection and procedure step sign-off (OAP-007, Containment Entry and Egress).
- 4. Mitigative measures to assure that potential sources of debris in containment are minimized. These measures include:
Procedure changes to ensure that materials introduced into containment as a result of the engineering change process are identified and evaluated to determine their effect on sump performance.
Procedure changes to ensure that configuration control of insulation inside containment is maintained in compliance with GL 2004-02.
The NRC has confidence that Entergy has a plan for IP2 that will result in the installation of final GSI-191 modifications that provide acceptable strainer function with adequate margin for uncertainties. Further, the NRC has concluded that Entergy has put mitigation measures in place at IP2 to adequately reduce risk for the requested approximately 3-month extension period. It is, therefore, acceptable to extend the completion date for certain corrective actions for the issues discussed in GL 2004-02 (specifically, the seven modifications and/or document changes listed above) until prior to restart after the IP2 spring 2008 refueling outage, currently scheduled to begin March 25, 2008. Should Entergy elect to begin the outage more than 30 days after March 25, 2008, Entergy will need to provide the NRC additional justification for further delay in completing corrective actions for GL 2004-02.
Approval of the requested extension to the GL 2004-02 corrective action due date shall not be construed as approval of any operating license amendment described in the licensees extension request.