ML081820056
| ML081820056 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 09/15/2008 |
| From: | James Kim Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Kim J, NRR/DORL, 415-4125 | |
| References | |
| GL-08-001, TAC MD7863 | |
| Download: ML081820056 (8) | |
Text
September 15, 2008 Vice President, Operations Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
SUBJECT:
PILGRIM NUCLEAR POWER STATION - 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. MD7863)
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 May 7, 2008, Entergy Nuclear Operations (the licensee) submitted a 3-month response to GL 2008-01 for Pilgrim Nuclear Power Station (PNPS). The NRC staffs assessment of the responses for PNPS 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 PNPS, 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 James Kim at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: See next page
If you have any questions regarding this letter, please feel free to contact James Kim at (301) 415-4125.
Sincerely,
/RA/
James Kim, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-293
Enclosure:
As stated cc w/encl: See next page Distribution:
PUBLIC RidsNrrDorlLpl1-1 RidsNrrPMJKim RidsOGCMailCenter LPL1-1 Reading File RidsNrrLASLittle RidsAcrsAcnw&mMailCenter RidsNrrDorlDpr RidsRgn1MailCenter JWermeil ADAMS Accession Number: ML081820056 OFFICE LPLI-1:PM LPLI-1:LA PGCB:BC DSS/DD LPLI-1/BC NAME JKim SLittle MMurphy JWermeil MKowal DATE 8/29/2008 9/4/2008 9/15/2008 9/8/2008 9/15/08 OFFICIAL RECORD COPY
Pilgrim Nuclear Power Station cc:
Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 MA Department of Public Health Radiation Control Program Schrafft Center, Suite 1M2A 529 Main Street Charlestown, MA 02129 Massachusetts Emergency Management Agency Attn: John Giarrusso, Nuclear Preparedness Manager 400 Worcester Road Framingham, MA 01702-5399 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Site Vice President Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 General Manager, Plant Operations Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Director, Nuclear Safety Assurance Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Manager, Licensing Entergy Nuclear Operations Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508
Pilgrim Nuclear Power Station cc:
Senior Vice President Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39286-1995 Vice President, Oversight 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 Vice President, Operations Entergy Nuclear Operations, Inc.
Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Michael Kansler President & CEO/CNO Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39268-1995 Mr. John F. McCann Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Senior Manager, Nuclear Safety &
Licensing Entergy Nuclear Operations, Inc.
P.O. Box 31955 Jackson, MS 39268-1995 Assistant General Counsel Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Ms. Stacey Lousteau Treasury Department Entergy Services, Inc.
639 Loyola Avenue New Orleans, LA 70113 Mr. James Sniezek 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster 5931 Barclay Lane Naples, FL 34110-7306 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348 Mr. John Doering P.O. Box 189 Parker Ford, PA 19457
NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 PILGRIM NUCLEAR POWER STATION DOCKET NO. 50-293
- 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 May 7, 2008, Entergy Nuclear Operations (the licensee) submitted a 3-month response to GL 2008-01 for Pilgrim Nuclear Power Station (PNPS). The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems cannot be completed. The GL subject systems include the emergency core cooling system (high-head safety injection, intermediate head safety injection and low-head safety injection system), shutdown cooling system, and containment spray system. The required walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation for the following reasons: (1) the walkdowns of these systems require entry into areas of high radiation or inerted atmosphere (less than 4% oxygen inside drywell); (2) restrictions on removal of insulation from piping prevent removal of sections of insulation needed to perform evaluation of the piping systems; and (3) erection of scaffolding may be prohibitive for locations over safety related equipment or if high radiation levels exist in the area of concern precluding scaffolding insulation.
Enclosure
The licensee also stated that all other system walkdowns will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage (RFO) scheduled for April 2009. The licensees letter dated May 7, 2008, listed the following commitments:
- 1. Complete the detailed walkdowns of inaccessible sections of GL subject systems prior to startup from the next refueling outage planned for April 2009.
- 2. Evaluate GL subject systems within 90 days following the completion of the next RFO 17.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. Previous surveillance testing performed on GL subject systems and interviews with operations personnel indicate that there are currently no gas voiding issues.
- 2. Operating procedures include monthly venting of the GL subject systems to ensure that systems are maintained sufficiently filled. No current issues have been identified in the performance of these procedures.
- 3. Inservice testing of the GL subject systems are routinely performed and no known issues impacting pump operability have been identified during this testing. PNPS has improved venting procedures to ensure adequate system venting and filling.
Based on the above considerations, the licensee stated that it has confidence that the GL subject systems can perform their required design functions based on the above-described operating experience, surveillances, performance testing, and past corrective actions that included procedural changes to better facilitate venting the affected piping systems. As such, the licensee concluded that completing performance of detailed walkdowns on a portion of subject piping systems that are inaccessible during power operation outside of the requested 9-month timeframe is an acceptable alternative course of action.
- 3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, procedures and corrective actions associated with managing gas accumulation at PNPS.
The NRC staff notes examples where the licensees 3-month submittal dated May 7, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible portions by the timeframe prescribed in the GL (i.e., by October 11, 2008). In addition, although the submittal states that the licensees evaluations of the inaccessible sections of the subject systems will be completed within 90 days following completion of RFO 17, it is not clear if that is the date the information will be submitted to the NRC.
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 PNPS, April 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 the completion of the next RFO 17 at PNPS.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees 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 May 7, 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 followup inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.