ML082630499
| ML082630499 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/06/2008 |
| From: | Mahesh Chawla Plant Licensing Branch III |
| To: | Schwarz C Entergy Nuclear Operations |
| Chawla M, NRR/DORL, 415-8371 | |
| References | |
| TAC MD7856 | |
| Download: ML082630499 (7) | |
Text
October 6, 2008 Mr. Christopher J. Schwarz Vice President, Operations Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530
SUBJECT:
PALISADES NUCLEAR PLANT - 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 NOS. MD7856)
Dear Mr. Schwarz:
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, 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 13, 2008 (ADAMS Accession No. ML081340542), Entergy Nuclear Operations, Inc. (the licensee) submitted a 3-month response to GL 2008-01 for Palisades Nuclear Plant (PNP). The NRC staffs assessment of the responses for PNP 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 PNP, 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) 415-8371 or mahesh.chawla@nrc.gov.
Sincerely,
/RA/
Mahesh Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-255
Enclosure:
As stated cc w/encl: See next page
If you have any questions regarding this letter, please feel free to contact me at (301) 415-8371 or mahesh.chawla@nrc.gov.
Sincerely,
/RA/
Mahesh Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-255
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsOgcRp Resource LPL3-1 R/F RidsAcrsAcnw_MailCTR Resource RidsNrrDorlLpl3-1 Resource RidsRgn3MailCenter Resource RidsNrrLABTully Resource DBeaulieu, DPR/PGCB RidsNrrPMPalisades Resource SSun, DSS/SRXB RidsNrrPMBraidwood Resource WLyon, DSS/SRXB ADAMS Accession Number: ML082630499 NRR-106 OFFICE LPL3-1/PM LPL3-1/LA PGCB/BC DSS/DD LPL3-1/BC NAME MChawla BTully MMurphy JWermiel LJames DATE 9/25/08 9/25/08 09/23/08 09/22/08 10/6/08 OFFICIAL RECORD COPY
Enclosure U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 PALISADES NUCLEAR PLANT DOCKET NO. 50-255
- 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 13, 2008, Entergy Nuclear Operations, Inc. (ENO), the licensee, submitted a 3-month response to GL 2008-01 for Palisades Nuclear Plant (PNP). The licensee stated that they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of PNP cannot be completed due to portions of the GL subject systems being inaccessible during power operation. These sections of piping are inaccessible for the following reasons: (1) the walkdowns of these areas of high radiation during power operations; or (2) erection of scaffolding may be prohibitive during power operations for locations near safety related equipment or if high radiation levels exist in the area of concern that would preclude scaffolding installation.
As an alternative course of action, the licensee plans to complete walkdowns of the inaccessible piping during power operation in the next PNP refueling outage scheduled for 2009. The licensee stated that all other system detailed walkdowns would be performed during the 9-month timeframe as prescribed by GL 2008-01. The licensees letter dated May 13, 2008, further indicates the following course of action:
- 1. Complete the detailed walkdowns of inaccessible sections of systems described in GL 2008-01 prior to startup from the 2009 refueling outage.
- 2. Complete evaluation of GL 2008-01 subject systems within 60 days following the completion of the 2009 refueling outage.
- 3. Any other corrective actions that are identified that cannot be completed during the 2009 refueling outage will be implemented prior to restart following the 2010 refueling outage.
ENO will provide a supplemental submittal within 60 days of the completion of the 2009 refueling outage describing any remaining corrective actions and their schedule for completion.
The licensee stated that the alternative course of action is acceptable based on the following:
- 1. Previous surveillance testing performed on GL 2008-01 subject systems and interviews with operations personnel have confirmed that there are currently no known gas voiding issues at PNP.
- 2. In-service testing of the GL 2008-01 subject systems are routinely performed and no known issues impacting pump operability have been identified during this testing.
- 3. Venting procedures have been improved at the PNP and pump vent valves are provided to ensure adequate pump venting and filling for gas accumulation issues.
Based on the above considerations, the licensee stated that it has confidence that the GL 2008-01 subject systems can perform their required design functions based on the above-described operating experience, surveillance, performance testing, and past corrective actions that have been performed to manage gas intrusion issues at the PNP. As such, the licensee concluded that completing the walkdowns of those areas only accessible during an outage 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, licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, surveillance, corrective actions associated with managing gas accumulation at the PNP.
The NRC staff notes examples where the licensees 3-month submittal dated May 13, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, although the submittal states that except for the piping that is only accessible during an outage, all other system detailed walkdowns would be performed during the 9-month timeframe as prescribed by GL 2008-01. Also the licensee does not state whether it planned to submit the GL requested information for the accessible piping within the 9-month timeframe (i.e., by October 11, 2008). In addition, although the licensee states that it would complete the evaluation of GL 2008-01 subject systems within 60 days following the completion of the 2009 refueling outage, 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 PNP, 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 60 days following the completion of the 2009 refueling outage at the PNP.
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 13, 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.
Palisades Plant cc:
Supervisor Covert Township P. O. Box 35 Covert, MI 49043 Office of the Governor P. O. Box 30013 Lansing, MI 48909 U.S. Nuclear Regulatory Commission Resident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Radiological Protection Section Radiological Assessment Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Senior Vice President Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995 Vice President Oversight Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995 Senior Manager, Nuclear Safety
& Licensing Entergy Nuclear Operations P. O. Box 31995 Jackson, MS 39286-1995 Senior Vice President and COO Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations 440 Hamilton Avenue White Plains, NY 10601 Manager, Licensing Entergy Nuclear Operations Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 June 18, 2008