ML080290097
| ML080290097 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/31/2008 |
| From: | Boska J NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Balduzzi M Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| TAC MC4689, TAC MC4690 | |
| Download: ML080290097 (9) | |
Text
January 31, 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 NOS. 2 AND 3 - DRAFT OPEN ITEMS FROM STAFF AUDIT OF CORRECTIVE ACTIONS TO ADDRESS GENERIC LETTER 2004-02 (TAC NOS. MC4689 AND MC4690)
Dear Mr. Balduzzi:
Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors, requested that all pressurized-water reactor licensees (1) evaluate the adequacy of the emergency sump recirculation function with respect to potentially adverse effects associated with post-accident debris, and (2) implement any plant modifications determined to be necessary. Entergy Nuclear Operations, Inc. (Entergy or the licensee), has conducted an evaluation of sump performance for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), and has completed significant modifications, including installation of new internal recirculation sump strainers and vapor containment sump strainers at both units with additional modifications at IP2 planned for the spring 2008 refueling outage.
The Nuclear Regulatory Commission (NRC) staff conducted a detailed audit of the new sump designs and associated analyses, evaluations, testing and modifications for IP2 and IP3 during the week of December 3, 2007. This audit was an in-process snapshot of the licensees GL 2004-02 corrective actions with focus on IP3. The licensees GL 2004-02 corrective actions are currently scheduled to be completed prior to restart from the refueling outage scheduled to begin March 25, 2008, for IP2 and June 30, 2008, for IP3. This is the last of several staff audits conducted over an approximate 2-year period to establish a sample basis to assist in verifying the adequacy of pressurized-water reactor licensee corrective actions to address GL 2004-02.
Enclosed with this letter are the draft open items from the audit for consideration when finalizing your corrective actions. This letter is publicly available to allow other licensees using the same vendor to consider addressing the audit items during their resolution of GL 2004-02. These draft open items are subject to change as the audit report is developed, finalized and issued.
Please note that the audit report will contain no conclusion as to the overall adequacy of the GL 2004-02 corrective actions for IP2 and IP3. That conclusion will be reached at the completion of the NRC staffs review of the licensees supplemental GL 2004-02 response (which the staff expects to receive by February 29, 2008), and responses to the audit report open items, as discussed below. This response should also address the NRC requests for additional information regarding GL 2004-02 that were sent to you in a letter dated February 9, 2006, to the extent they are not answered in the GL 2004-02 supplemental response.
M. Balduzzi Entergy is expected to respond to the final open items, which will be contained in the audit report, within 60 days of issuance of that report. Because of the timing of the audit, the open item responses will likely be submitted after Entergy submits the supplemental GL response.
To the extent the information requested in the audit open items has already been addressed in the supplemental GL response, the open item responses may reference the previously submitted information rather than restate it.
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:
As stated cc w/encl: See next page
ML080290097 OFFICE LPL1-1/PM LPL1-1/LA SSIB/BC LPL1-1/BC NAME JBoska SLittle MScott MKowal DATE 1/30/08 1/30/08 1/31/08 1/31/08
Indian Point Nuclear Generating Unit Nos. 2 & 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 Nos. 2 & 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 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 Mr. Sherwood Martinelli FUSE USA via email
Enclosure DRAFT OPEN ITEMS FROM DECEMBER 2007 AUDIT OF CORRECTIVE ACTIONS FOR GENERIC LETTER 2004-02 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286 Open Item 1: Internal Recirculation Sump Testing and Analyses Documentation The internal recirculation sump appears to be the most important sump from a plant safety perspective. Based on the test results (without considering chemical effects), it appears that the internal recirculation sump will perform its design function acceptably. However, the test procedures and test results concentrated on the vapor containment sump and did not provide clear traceability to show that these tests bounded the internal recirculation sump conditions.
The licensee concentrated on the vapor containment sump because it is more challenging.
However, since the internal recirculation sump is important for safety, the documentation for this case should be clear. The licensee should provide a summary of the testing and analysis results for the internal recirculation sump.
Open Item 2: Fibrous Debris Preparation and Introduction during Array Testing The fibrous debris preparation and introduction during array testing was not prototypical (as defined if considering the debris transport calculation). Instead, the debris was generically prepared by boiling, shredding, and mixing with water. Non-prototypical debris bed formation could result in non-conservative head losses during testing. The debris should be prepared and introduced to ensure prototypical bed formation. The licensee should provide a summary of how its test practices have addressed this issue.
Open Item 3: Head Loss Correlation Use for Design Bases The analysis techniques used in the strainer certification calculation for Indian Point Nuclear Generating Unit No. 2 (IP2) used the NUREG-62241 head loss correlation to adjust the test data. The NUREG-6224 correlation was developed for use with homogeneous and uniform debris beds. The beds formed during array testing may have been homogeneous, but were not of uniform thickness. Manipulation of the test data with head loss correlations may provide a tool for evaluation of potential modifications or emergent conditions, but should not be used for the strainer design basis. The licensee should demonstrate that a test was conducted that bounds applicable scenarios or should justify its present approach.
1 G. Zigler, J. Brideau, D. V. Rao, C. Shaffer, F. Souto, and W. Thomas, "Parametric Study of the Potential for BWR ECCS Strainer Blockage Due to LOCA Generated Debris," Final Report, NUREG/CR-6224, SEA-93-554-06-A:1, October 1995.
Open Item 4: Failure of Alkyd Coatings The licensee is assuming only 80 percent of the alkyd original equipment manufacturer (OEM) coatings outside the zone of influence will fail. The NRC staffs position is that 100 percent failure should be assumed (i.e., all 29.6 lbs). The licensee should revise its existing calculations to conform with the current staff position or justify assuming less than 100 percent failure of the alkyd coatings, and should provide a summary of how this issue has been resolved.
Open Item 5: Zone of Influence for Un-topcoated Zinc The licensee used a 4.28 length/diameter spherical equivalent zone of influence for un-topcoated zinc. This value is less than the five length/diameter zone of influence that was recommended by the Westinghouse report and accepted by the staff. The licensee should revise its existing calculations to conform with the current staff position or justify the current approach, and should provide a summary of how this issue has been resolved.
Open Item 6: Long-term Fibrous Debris Erosion An adequate technical basis (e.g., test data) was not provided to support the assumption of 10 percent fibrous debris erosion in the containment pool over a 30-day period. The licensee should provide a justification for this assumption or revise it as determined appropriate.
Open Item 7: Capture of Small Fibrous Debris on Gratings An adequate technical basis was not provided to support the assumption that 40 percent of small pieces of fibrous debris will be captured on gratings in the upper containment. The licensee should provide a justification for this assumption or revise it as determined appropriate.
Open Item 8: Long-Term Erosion of Calcium Silicate Debris The testing performed with the IP2 calcium silicate with asbestos (that is being applied to IP3) was not performed for a sufficiently long period to give high confidence of no erosion of the material, as opposed to a small erosion rate that could lead to a significant fraction of erosion over a 30-day period. The licensee should provide justification for its conclusions about erosion of this material.
Open Item 9: Plant-Specific Erosion of Calcium Silicate Insulation A different process (molding) may have formed the calcium silicate without asbestos at IP3 than the material tested for erosion, which was taken from IP2 (formed by hydraulic pressing).
Therefore, based on discussion with a calcium silicate manufacturer, the IP3 calcium silicate without asbestos could be more fragile than the IP2 material and could experience higher erosion. The licensee should provide justification for the use of erosion data from the IP2 calcium silicate with asbestos to the IP3 calcium silicate without asbestos.
Open Item 10: Internal Recirculation Pumps, Vendor Testing Using Single-Stage Impeller The IP3 internal recirculation pumps are three-stage pumps. The certified net positive suction head required data provided by the pump vendor was obtained from a testing protocol that used a single-stage impeller. The licensee should provide a justification for the application of the data for the single-stage pump to the three-stage IP3 pump.
Open Item 11: Raised Minimum Flow Requirement Effect on Net Positive Suction Head Calculation During the audit, it was determined that a procedure revision had raised the minimum measured flow requirement to each loop during the recirculation phase of a loss-of-coolant accident (LOCA) (Condition Report CR-IP3-2007-04492). Because of this change, the licensee needs to determine whether the maximum flows assumed in the sump modification calculations are conservative with regard to net positive suction head requirements and debris transport velocities. The licensee should provide a summary of this determination in its response to the NRC.
Open Item 12: Chemical Effects Methodology Chemical effects remain a general open item for the IP audit. The chemical effects test data was not available for NRC staff review at the time of the audit. In addition, the licensee and their vendor have not settled on the final methodology that will be used to apply the chemical test data to the larger scale head loss test results. For this reason, the staff was unable to review the methodology for resolution of chemical effects. The licensee should provide a description of its chemical effects methodology, including details as described in the NRC staffs chemical effects evaluation guidance.
Open Item 13: VUEZ Testing Chemical Issues The staff has identified a number of outstanding issues with the integrated chemical effects head loss testing performed for IP3 by Alion at the VUEZ test facilities. The resolution of the following chemical issues associated with this testing is considered an open item:
Whether the pH profile for the test was conservative with respect to both material dissolution and precipitate formation Timing of hydrochloric and nitric acid additions Timing of lithium hydroxide additions Impact of initially high pH condition created by fiber and calcium silicate sitting in the de-ionized water prior to chemical additions Potential impact of thermal cycling on test fluid to simulate a heat exchanger Modeling of zinc and aluminum coatings as solid samples (as mass) rather than particulate (as surface area)
Impact of discarding material from pre-boiling of fibers; versus including that material in the test tank Uneven mixing of test fluid due to large amounts of coupons and sample baskets in the tank
Impact of removing test fluid for sampling and for making room for coupons and baskets Over-packing of fiber in baskets, such that the fibers may be too dense to interact with the test fluid The licensee should provide a summary of how these issues have been addressed.
Open Item 14: VUEZ Testing Non-Chemical Issues The staff has identified a number of outstanding issues with the integrated chemical effects head loss testing performed for IP3 by Alion at the VUEZ test facilities. The resolution of the following non-chemical issues associated with this testing is considered an open item:
The Alion/VUEZ procedure of pouring of debris beds onto the test screen results in the formation of unusually porous debris beds with low head loss, as compared to debris beds formed under representative flow conditions.
The Alion bump-up factor methodology has not been demonstrated to be valid for scaling the head loss results of the VUEZ testing to a strainer module. In particular, the differences in the characteristics of the debris beds formed in the array testing at the Alion test facilities and the flat plate at VUEZ have not been adequately accounted for in the scaling process.
The difference in the sequences of debris addition for the Alion array testing and the VUEZ flat plate testing has not been adequately justified.
The debris size distribution used for the VUEZ testing has been observed to contain clumps and agglomerations, which lead to the formation of non-uniform debris beds that are not representative of beds that are predominately formed by fines.
The existing calculations for IP3 do not clearly explain how the debris loadings for the VUEZ test cases were derived or justify why they are considered bounding with respect to the strainer design.
Repeatability of the VUEZ head loss test results has not been adequately demonstrated.
Measurement uncertainties associated with the recorded head loss test results at VUEZ have not been accounted for analytically in the head loss calculations, demonstrated to be negligible, or demonstrated to be bounded by other conservatisms.
The licensee should provide a summary of how these issues have been resolved.
Open Item 15: Evaluations of Downstream Effects of Debris on Systems and Components The licensees evaluations of the downstream effects of debris on systems and components were preliminary. The evaluations were under revision to incorporate the evaluation methods of Revision 1 of WCAP 16406-P and to update debris transport and flow rate parameters. The licensee should provide updated flow rates, a summary of methods and results of debris transport tests and evaluations, and a summary of pump-wear calculation methods and results using the guidance in WCAP 16406-P, Revision 1, for the affected components.
Open Item 16: Evaluations of Downstream Effects In-Vessel The licensees evaluation of downstream chemical effects on fuel was not available for review
as it was under development. The licensee should provide a summary of assumptions, methods, and analysis results for the in-vessel chemical effects evaluations.