ML073521073
| ML073521073 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/07/2008 |
| From: | Boska J NRC/NRR/ADRO/DORL/LPLA |
| To: | Balduzzi M Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| TAC MD7183 | |
| Download: ML073521073 (8) | |
Text
January 7, 2008 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. 3 - REQUEST FOR ADDITIONAL INFORMATION ON PROPOSED TECHNICAL SPECIFICATION CHANGES FOR REFUELING WATER STORAGE TANK LOW-LOW LEVEL ALARM SETPOINT (TAC NO. MD7183)
Dear Mr. Balduzzi:
On October 24, 2007 (see Agencywide Documents Access and Management Systems Accession No. ML073040293), Entergy Nuclear Operations, Inc. (Entergy), submitted a request for a license amendment to change the Technical Specifications requirements for the setpoint and the definition of the low-low level alarm on the Refueling Water Storage Tank, at the Indian Point Nuclear Generating Unit No. 3.
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 December 17, 2007, the Entergy staff indicated that a response to the RAI would be provided within 30 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 No. 50-286
Enclosure:
RAI cc w/encl: See next page
ML073521073 *See memo dated 12/4/07 OFFICE LPL1-1/PM LPL1-1/LA EICB/BC I
ITSB/BC(A)
LPL1-1/BC NAME JBoska SLittle WKemper*
TKobetz MKowal DATE 1/2/08 1/3/08 12/4/07 1/7/08 1/7/08
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 REQUEST FOR ADDITIONAL INFORMATION PROPOSED TECHNICAL SPECIFICATION CHANGES FOR REFUELING WATER STORAGE TANK LOW-LOW LEVEL ALARM SETPOINT ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286 In a letter dated October 24, 2007 (ADAMS Accession No. ML073040293), Entergy Nuclear Operations, Inc. (Entergy), submitted a request for a license amendment to change the Technical Specifications (TS) regarding adjustments of the low-low level alarm setpoint range on the Refueling Water Storage Tank (RWST) at the Indian Point Nuclear Generating Unit No. 3 (IP3).
The Nuclear Regulatory Commission (NRC) staff has reviewed the information Entergy provided and determined that the following additional information is required in order to complete the evaluation:
Part A. Questions Related to Tank Volume and Operator Response A1.
Volumes Available for Injection and Recirculation: Your submittal stated in Section 4.0, Technical Analysis, that the proposed change would ensure a minimum level of approximately 217,400 gallons of RWST water to be available for the injection phase and approximately 58,100 gallons of RWST water to be available for use during and following the transition from injection to recirculation. Provide the calculation that supports these values.
Your submittal states that the minimum RWST volume available for injection prior to the low-low level alarm change was 195,800 gallons with 66,700 gallons available during and following the transition from injection to recirculation. By lowering the RWST alarm point by 1.5 feet this appears to result in 210,800 gallons for injection and 51,700 gallons available during and following the transition from injection to recirculation.
A2.
Operator Response: Your submittal stated in Section 4.0, Technical Analysis, Operator Action Time for Switchover, that the switchover to recirculation was demonstrated on the IP3 simulator to occur by the time RWST level reached 4.5 ft. Provide the details of how this conclusion was reached.
Your submittal implies that multiple crews were tested but it doesnt state if this was an average level reached by the crews, how many crews were tested, if any crews failed to complete recirculation prior to reaching the low level, etc.
Part B. Questions Related to Instrumentation & Controls The license amendment request (LAR) proposes TS changes associated with RWST low-low level alarm setpoint range. This LAR includes the proposed changes to the setpoint range of Surveillance Requirement (SR) 3.5.4.5 and SR 3.5.4.6 in TS 3.5.4, Refueling Water Storage Tank. To support the NRC staffs assessment of the acceptability of the LAR in regard to setpoint changes, please provide the following:
B1.
Setpoint Calculation Methodology: Provide documentation (including sample calculations) of the methodology used for establishing the limiting setpoint (or nominal setpoint) and the limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing as described below. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.
B2.
Safety Limit (SL)-Related Determination: Provide a statement as to whether or not the setpoint is a limiting safety system setting (LSSS) for a variable on which an SL has been placed as discussed in 10 CFR 50.36(d)(1)(ii)(A). Such setpoints are described as SL-Related in the discussions that follow. In accordance with 10 CFR 50.36(d)(1)(ii)(A), the following guidance is provided for identifying a list of functions to be included in the subset of LSSS specified for variables on which SLs have been placed as defined in Standard Technical Specifications (STS) Sections 2.1.1, Reactor Core SLs and 2.1.2, Reactor Coolant System Pressure SLs. This subset includes automatic protective devices in TS for specified variables on which SLs have been placed that: (1) initiate a reactor trip; or (2) actuate safety systems. As such, these variables provide protection against violating reactor core safety limits, or reactor coolant system pressure boundary safety limits.
Examples of instrument functions that might have LSSS included in this subset in accordance with the plant-specific licensing basis, are pressurizer pressure reactor trip (pressurized-water reactors), rod block monitor withdrawal blocks (boiling-water reactors), feedwater and main turbine high water level trip (boiling-water reactors), and end of cycle recirculation pump trip (boiling-water reactors). For each setpoint, or related group of setpoints, that you determined not to be SL-Related, explain the basis for this determination.
B3.
For the Setpoint that is determined to be SL-Related: The NRC letter to the Nuclear Energy Institute Setpoint Methods Task Force (SMTF) dated September 7, 2005 (ADAMS Accession Number ML052500004), describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-Related setpoints.
Specifically: Part A of the Enclosure to the letter provides Limiting Conditions for Operation (LCO) notes to be added to the TS, and Part B includes a check list of the information to be provided in the TS Bases related to the proposed TS changes.
- a.
Describe whether and how you plan to implement the SRTS suggested in the September 7, 2005, letter. If you do not plan to adopt the suggested SRTS, then explain how you will ensure compliance with 10 CFR 50.36 by addressing items b and c, below.
- b.
As-Found Setpoint Evaluation: Describe how surveillance test results and associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the criteria for determining operability of the instrument being tested are located in a document other than the TS, (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.
- c.
As-Left Setpoint Control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses. If the controls are located in a document other than the TS, (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.
B4.
For the Setpoint that is not determined to be SL-Related: Describe the measures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the As-Left trip setting after completion of periodic surveillance is consistent with your setpoint methodology. Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it is ensured that the controls will be implemented.
B5.
RWST Low Level Alarm References on TS Page 3.5.4-1: Discuss why RWST low level on TS page 3.5.4-1 has not been recommended for a change to RWST low-low level.
RWST low level appears in three locations on TS page 3.5.4-1, in LCO 3.5.4, Condition B, and Required Action B.1. To be consistent with the proposed changes to SR 3.5.4.5 and SR 3.5.4.6, RWST low level on TS page 3.5.4-1 should be changed to RWST low-low level.
B6.
Impact on Commitment to Regulatory Guide 1.97: Discuss the impact of the proposed change on the licensees commitment to Regulatory Guide (RG) 1.97. In a letter dated January 7, 1986 (Accession No. 8601130394), the licensee declared RWST low level alarm as a RG 1.97 Type A variable. This declaration was reflected in a safety evaluation dated April 3, 1991 (Accession No. 9104090184). Does the proposed change cause the RWST low level alarm Type A variable to become RWST low-low level alarm?
Document any change to the licensees commitment to RG 1.97.
B7.
Impact on TS 3.3.3: Discuss the impact of the proposed change on TS 3.3.3, Post Accident Monitoring Instrumentation. Since RWST level alarm is a RG 1.97 Type A variable, it should included in Table 3.3.3-1 of TS 3.3.3. The NRC staffs position is that the accident monitoring TS should include all RG 1.97 Type A instruments and all RG 1.97 Category 1, non-Type A instruments, in accordance with the unit's RG 1.97, Safety Evaluation Report. This position is stated in a letter from T. E. Murley (NRC) to W. S.
Wilgus (B&W Owners Group), NRC Staff Review of Nuclear Steam Supply System Vendor Owners Groups Application of the Commissions Interim Policy Statement Criteria to Standard Technical Specifications, dated May 1988. Document why or why not RWST low-low level alarm should be added to Table 3.3.3-1 of TS 3.3.3.
References:
- 1. NRC Letter to Nuclear Energy Institute SMTF dated September 7, 2005 (ADAMS Accession Number ML052500004)
- 2. NRC Regulatory Information Summary 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels, dated August 24, 2006