ML081570086
| ML081570086 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/15/2008 |
| From: | Boska J NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Entergy Nuclear Operations |
| Boska J, NRR, 301-415-2901 | |
| References | |
| GL-08-001, TAC MD7837 | |
| Download: ML081570086 (6) | |
Text
September 15, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249
SUBJECT:
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NO. MD7837)
Dear Sir or Madam:
On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated April 11, 2008, Entergy Nuclear Operations, Inc. (Entergy) submitted a 3-month submittal to GL 2008-01 for Indian Point Nuclear Generating Unit No. 3 (IP3). The NRC staffs assessment of the responses for IP3 is contained in the enclosure to this letter.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for IP3, with the exception of the clarifications and associated requests discussed in the enclosure, they are acceptable. This letter allows the licensee to implement its proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosure.
If you have any questions regarding this letter, please feel free to contact me at (301) 415-2901.
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:
As stated cc: See next page If you have any questions regarding this letter, please feel free to contact me at (301) 415-2901.
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:
As stated cc w/encl: See next page Distribution:
PUBLIC RidsNrrDorlLpl1-1 RidsNrrPMJBoska RidsOGCMailCenter LPL1-1 Reading File RidsNrrLASLittle RidsAcrsAcnw&mMailCenter RidsNrrDorlDpr RidsRgn1MailCenter JWermeil ADAMS Accession Number: ML081570086 OFFICE LPL1-1/PM LPL1-1/LA PGCB/BC DSS/DD LPL1-1/BC NAME JBoska SLittle MMurphy JWermeil MKowal DATE 9/05/08 9/10/08 9/15/08 9/10/08 9/15/08 OFFICIAL RECORD COPY
Indian Point Nuclear Generating Unit No. 3 cc:
Senior Vice President Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Vice President Oversight Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety &
Licensing Entergy Nuclear Operations, Inc.
P.O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Manager, Licensing Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 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 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. 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. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. Sherwood Martinelli FUSE USA via email
U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
- 1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR), GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
- 2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a 3-month response to GL 2008-01 for Indian Point Nuclear Generating Unit No. 3 (IP3). The licensee indicated that for IP3 the only GL 2008-01 reporting requirement that will not be completed by the required response time is walkdowns and inspections of some segments of piping in the GL subject systems, including the high-pressure safety injection system, containment spray system, residual heat removal system, and recirculation system.
Since portions of the GL subject system are inaccessible or located in high dose areas during power operation, an outage is required to complete the walkdowns and inspections. The licensee will complete the walkdown and evaluation of the normally accessible portions of the GL systems by October 11, 2008. The licensee plans to complete the remaining walkdowns and inspections of the inaccessible portions of the GL systems during the next refueling outage Enclosure
that is scheduled for the spring of 2009, and supplement the 9-month response to the GL by October 9, 2009. The licensee provided the following commitments for completion of its GL response:
- 1.
Complete the walkdowns of the inaccessible portions of the system in the next refueling outage that is planned for the spring of 2009.
- 2.
Submit a supplemental response to GL 2008-01 by October 9, 2009.
The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and schedule for the 9-month submittal. Specifically, although the submittal states the walkdown and evaluation of the normally accessible portions of the GL systems will be completed by October 11, 2008, it is not clear if that is the date the information will be submitted to the NRC. In addition, although the submittal commits to submit a supplemental response to GL 2008-01 by October 9, 2009, it is not clear if this date is expected to be within 90 days following startup from the spring 2009 refueling outage.
The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the IP3 spring 2009 refueling outage, provide all GL requested information to the NRC by October 11, 2008.
(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the spring 2009 refueling outage at IP3.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, Technical Specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.