ML073510242
| ML073510242 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/20/2007 |
| From: | Boska J NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Balduzzi M Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| GL-04-002, TAC MC4690 | |
| Download: ML073510242 (8) | |
Text
December 20, 2007 M`r. 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. 3 - APPROVAL OF REVISED EXTENSION REQUEST FOR CORRECTIVE ACTIONS REQUIRED BY GENERIC LETTER 2004-02 (TAC NO. MC4690)
Dear Mr. Balduzzi:
In a letter dated December 3, 2007, Agencywide Document Access and Management System (ADAMS) accession number ML073460042, Entergy Nuclear Operations, Inc. (Entergy) submitted a revised request for 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. 3 (IP3). Entergys previous request for an extension submitted on October 24, 2007 (ADAMS accession number ML073040291),
was denied by the Nuclear Regulatory Commission (NRC) on November 20, 2007 (ADAMS accession number ML073230158). Entergys current approach uses an expedited schedule to complete the modification installation prior to the next refueling outage. This newly-proposed extension would allow Entergy approximately 6 additional months to perform the remaining modifications and licensing activities necessary to achieve full compliance with GL 2004-02, by June 30, 2008.
The NRC staff has evaluated the information in your revised request and determined that it is acceptable to extend the completion date for the additional modifications and licensing activities as described in the referenced letter, until June 30, 2008. 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. 50-286
Enclosure:
As stated cc w/encl: See next page
ML073510242 OFFICE LPL1-1/PM LPL1-1/LA SSIB/BC LPL1-1/BC NAME JBoska SLittle MScott MKowal DATE 12/18/07 12/18/07 12/19/07 12/20/07
Indian Point Nuclear Generating Unit No. 3 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. 3 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 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
Enclosure INDIAN POINT UNIT 3 GENERIC SAFETY ISSUE (GSI)-191/GENERIC LETTER (GL) 2004-02 EXTENSION REQUEST APPROVAL In a letter dated October 24, 2007, Entergy Nuclear Operations, Inc. (Entergy) requested an extension to the corrective action due date of December 31, 2007, stated in NRC 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. 3 (IP3). NRC responded to this request with a letter dated November 20, 2007. In this response, the NRC denied Entergys request on the basis that Entergy had not made a convincing case why the proposed modifications and other changes cannot be accomplished before the next refueling outage. In a follow-up letter dated December 3, 2007, Entergy submitted a revised extension request proposing a shorter extension period.
Entergy has taken actions, as described in Entergys letters dated September 1, 2005 (ML052500197), and December 15, 2005 (ML053570222), toward accomplishing the corrective actions described in GL 2004-02, including replacing the sump screens with substantially larger sump strainers during the spring 2007 refueling outage. IP3 is continuing the evaluation of the adequacy of the replacement strainers.
IP3 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 fully address GL 2004-02 (including chemical effects), the following additional hardware modifications and operating license amendments are required.
- 2. Changing the refueling water storage tank (RWST) low-low level alarm setpoint
- 3. Revising Technical Specification (TS) Surveillance Requirement (SR) 3.6.7.1 to reflect the new buffer type and quantity
- 4. Revising TS SRs 3.5.4.5 and 3.4.5.6 to change the allowable setpoint range for the RWST low-low level alarm, and
- 5. Amending the Operating License to exempt IP3 sumps from the Single Failure Criterion referenced in 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 2, Safety Evaluation by the Office of Nuclear Reactor 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.
With regard to the first extension criterion, IP3 has a plant-specific technical/experimental plan, with milestones and schedules, to complete the GL 2004-02 corrective actions and modifications by June 2008. Specifically, the licensee has stated that it has completed the following actions:
- 1. Installation of recirculation sump strainers, containment sump strainers and flow channeling modifications
- 2. Dissolution/erosion measurements of plant-specific calcium silicate
- 3. Debris generation, debris transport, and downstream effects calculations and evaluations in accordance with WCAP-16406P, Revision 0.
- 4. Development of chemical effects test protocol
- 5. Strainer debris head loss testing
- 6. RWST level setpoint change license amendment request submitted to NRC The licensee stated that the following actions are in progress:
- 1. Chemical effects testing
- 2. Reevaluation of downstream effects to incorporate WCAP-16406P, Revision 1 scheduled for completion December 2007
- 3. Preparation of a program to inspect and control containment coatings scheduled for completion December 2007 4 Preparation of a program to inspect and control containment cleanliness scheduled for completion December 2007
- 5. Preparation of the buffer replacement modification package, engineering calculations and associated license amendment The licensee stated that the following actions are planned:
- 1. Installation of the containment sump buffering agent modification following NRC approval of the associated license amendment
- 2. Implementation of the RWST level alarm setpoint change following NRC approval of the associated license amendment
- 3. Issuance of the strainer certification/qualification report to include chemical effects scheduled for February 2008 With 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 IP3, minimizing the risk of degraded ECCS and CSS functions during the extension period:
- 1. Installation of much larger replacement sump strainers (4200 square feet total surface area vs. 80 square feet for the previously installed strainers) and replacement internal recirculation (IR) pumps
- 2. Installation of flow channeling modifications
- 3. Implementation of mitigative measures in response to NRC Bulletin 2003-01
- 4. Implementation of mitigative measures that ensure containment cleanliness, foreign material exclusion, and sump and flow/channel barrier operability
- 5. Implementation of mitigative measures to ensure that potential sources of debris in containment are minimized The licensee also noted several other favorable factors that are applicable to IP3, including a compartmentalized containment that makes transport of debris difficult, a delay of 20-30 minutes after a LBLOCA begins before recirculation begins (which would allow some debris to settle to the containment floor and not reach the strainer), and that IP3 net positive suction head analyses do not credit containment overpressure although it would occur following a LBLOCA.
The NRC believes that Entergy has a reasonable plan for IP3 that should 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 IP3 to adequately reduce risk for the requested approximately 6-month extension period. As part of an ongoing audit of the licensees actions addressing GL 2004-02, the NRC staff visited the IP site during the first week in December 2007, evaluated some of the actions the licensee stated it has taken, and obtained details of the licensees plans. Further, the NRC staff considered the licensees installation of flow channeling modifications to be an innovative and likely effective approach to reducing debris transport to the sump strainers.
Based on the licensees having satisfactorily addressed the applicable NRC criteria as discussed above, it is acceptable to extend the completion date for certain corrective actions for the issues discussed in GL 2004-02 (specifically, the modifications and document changes listed above) until June 30, 2008, for IP3. While the NRC accepts this date as reasonable allowance for contingencies regarding the containment sump buffering agent replacement, we note and agree with the licensees statement in its December 3, 2007, letter that it intends to expeditiously implement this modification following the spring 2008 Unit 2 refueling outage.
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.