ML091950328
| ML091950328 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/06/2009 |
| From: | Joseph E Pollock Entergy Corp, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-08-001, NL-09-075 | |
| Download: ML091950328 (6) | |
Text
ah Enuterg Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 Tel (914) 734-6700 J. E. Pollock Site Vice President NL-09-075 July 6, 2009 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1 -17 Washington, D.C. 20555-0001
Subject:
References:
Indian Point Entergy Center (IPEC) Unit 3 Generic Letter 2008-001,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Nine Month Supplemental (Post Outage) Response to NRC Generic Letter 2008-001 Indian Point Unit No 3 Docket No. 50-286 DPR-64
- 1. NRC Generic Letter 2008-001,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" dated January 11, 2008.
- 2. Three Month Response to Generic Letter 2008-001 dated April 11, 2008, Letter No. NL-08-065.
- 3. NRC Letter dated September 15, 2008, "Indian Point Generating Unit No.
3-RE: Generic Letter 2008-001, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", Proposed Alternative Course of Action.
- 4. Nine Month Response to Generic Letter 2008-001 dated October 9, 2008, Letter No. NL-08-136.
- 5. NRC Letter to Nuclear Energy Institute, dated July 8, 2008 (ML0818305557).
Dear Sir or Madam:
The Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-001 (Reference 1), to request that each licensee evaluate the licensing basis, design, testing, and corrective action programs for the Emergency Core Cooling Systems (ECCS), Residual Heat Removal (RHR) System (RHRS), and Containment Spray System (CSS), to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and that appropriate actions are taken when conditions adverse to quality are identified.
GL 2008-001 requested each licensee to submit a written response in accordance with 10 CFR 50.54(f) within 9 months of the date of the GL. Additionally, the NRC requested that if a licensee cannot meet the requested response date, the licensee "shall provide a response within 3 months of the date of the GL."
On April 7, 2008, Entergy Nuclear Operations, Inc.
Docket No. 50-286" NL-09-075 Page 2 of 2 (Entergy) notified the NRC that Indian Point Unit No. 3 (IP-3) could not complete all the requested actions required by the GL within 9 months and submitted the required 3 month letter (Reference -2).
- On October 9, 2008, Entergy submitted -the required 9 month response (Reference 4).
In the 9 month response Entergy committed to complete its assessments of those inaccessible portions of these systems/functions during the next IP-3 refueling outage currently scheduled for the spring of 2009 and provide a supplement to this report with those results within 90 days after startup from that outage. Accordingly, as requested in Reference 3, attached is Entergy's supplemental response to the nine month response letter (Reference 4). This supplemental response is being submitted within 90 days of startup (initial criticality April 15, 2009) from the IP-3 cycle 15 refueling outage (3R15) in which the deferred actions were completed. GL response activities that remain to be accomplished, such as the long-term items identified in Reference 3, are considered to be confirmatory.
In summary, Entergy has concluded that the subject systems/functions at Indian Point Units 2 and 3 are in compliance with the Technical Specification definition of Operability, and that Indian Point Unit 2 and Unit 3 are in compliance with 10 CFR 50, Appendix B, Criterion IIl, V, XI, XVI and XVII, with respect to the concerns outlined in GL 2008-001 regarding gas accumulation in the accessible portions of these systems/functions.
This letter contains no new commitments and no revisions to existing commitments.
Should you have any questions regarding this matter, please contact Mr. Robert Walpole, Manager, Licensing, Indian Point Energy Center at (914) 734-6710:
The requested information is being provided pursuant to the requirements of 10 CFR 50.54(f).
I declare under the penalty of perjury that the foregoing information is true and correct.
Executed on "Xa-\\_- (,
,2009.
Sincerely, JEP/cbr
Attachment:
- 1.
IP-3 NRC Generic Letter 2008-01,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Nine Month Supplemental (Post Outage) Response to NRC Generic Letter 2008-001 cc:
Mr. Samuel J. Collins, Region I Administrator, U.S. Nuclear Regulatory Commission Mr. John P. Boska, Senior Project Manager, U.S. Nuclear Regulatory Commission NRC Resident Inspectors, Indian Point Units 2 and 3.-
Mr. Paul Eddy, New york State Department-of Public Service.
Mr. Francis J. Murray, President and CEO, NYSERDA
Attachment I to NL-09-075 IP-3 Generic Letter 2008-001,"Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems" Nine Month Supplemental (Post Outage) Response to NRC Generic Letter 2008-001 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
Docket No. 50-286 NL-09-075 Page 1 of 3 IP-3 Ninety Day Post Outage Supplemental Response to NRC Generic Letter 2008-01 This attachment provides the Nine-Month Supplemental (Post Outage)- Response to Generic Letter 2008-01 for actions that were deferred until the next refueling outage as requested by the NRC in Reference 3 of the cover letter.
The following information is provided in this attachment:
a) A description of the results of evaluations that were performed for IP-3 pursuant to Generic Letter 2008-01 on the previously incomplete activities, such as system piping walkdowns inside containment (see section A of this attachment).
b) A description of any additional corrective actions for IP-3 determined necessary to assure system operability and compliance with the quality assurance criteria in Sections III, V, Xl, XVI, and XVII of Appendix B to 10 CFR Part 50 and the licensing basis and operating license with respect to the subject systems, including a schedule and a basis for that schedule (see Section B1 of this Attachment) and, c) A summary of any changes or updates to previous corrective actions for IP-3, including any schedule change and the basis for the change (see Section B2 of this Attachment.).
The original conclusions documented in the 9-months response (reference-4) for Indian Point Units 2 and 3 have not changed.
A. EVALUATION RESULTS
- 1. Design Basis Documents The engineering evaluation of the confirmatory walkdowns discussed below (see A.2) identified no need to change the existing Design Basis Documents. Three new vent valves discussed below (see A.3) were added during the outage. Design Basis Documents including plant drawings and procedures have been updated to reflect the addition of the new vent valves.
- 2. Confirmatory Walkdowns The confirmatory walkdowns of all accessible piping of the subject systems located inside the IP-3 Containment as identified in referenced 4 of the cover letter were completed during the IP-3 cycle 15 refueling outage (3R15) in the spring of 2009.
These walkdowns were performed using the same methods used in previous walkdowns as described in reference 4 of the cover letter. The engineering evaluation of the walkdowns confirmed no operability impact consistent with the previously reported results in reference 4 of the cover letter.
- 3. Vent Valves The engineering evaluation of the confirmatory walkdowns identified no need to install new vent valves, or modifications to existing vent valves. Three new vent valves were added during the outage as discussed below (see B.2.g).
Docket No. 50-286 NL-09-075 Page 2 of 3
- 4. Procedures Changes to the existing procedures or development of new procedures are not required as a result of this evaluation. Procedure changes committed in the 9-month response (reference 4 of the cover letter) were completed as discussed below for IP-3 prior to the cycle 15 refueling outage in the spring of 2009.
B. DESCRIPTION OF NECESSARY ADDITIONAL CORRECTIVE ACTIONS
- 1. Additional Corrective Actions No new corrective actions were identified as a result of the walkdowns performed during IP-3 cycle 15 refueling outage (3R15). No additional regulatory commitments are being made in this response.
- 2. Corrective Action Updates Five Corrective Actions were listed in the 9-Month Response (reference 4 of the cover letter). They are reaffirmed below with an update as appropriate.
- a. IPEC will revise the monthly test procedure PT-M108 prior to January 11, 2009.
Status: This corrective action is complete.
- b. IP-3 will complete the walkdown for the subject systems located inside the Containment during cycle 15 outage (3R1 5) scheduled for spring of 2009.
Status: This corrective action is complete.
- c. A supplemental response to NRC to include IP-3 walkdown evaluation results will be submitted within 90 days after the startup from the IP-3 cycle 15 outage (3R15).
Status: This response satisfies this action.
I
- d. UFSAR changes were prepared and will be processed for inclusion in the next scheduled UFSAR update submittal (6 months after the refueling outage per 10CFR50.71).
Status: Changes to the Unit 3 UFSAR will be submitted with the next scheduled update on October 15, 2009. Changes to Unit 2 UFSAR will be submitted with the next scheduled update in the fall of 2010.
- e. IPEC will evaluate resolution of the TS issues with respect to the elements contained in the industry TSTF effort to determine applicability and further assess any changes to the TS and TS Basis.
Status: The completion date for this regulatory commitment is contingent upon the approval of the TSTF.
Docket No. 50-286 NL-09-075 Page 3 of 3
- f. As enhancement, Indian Point will revise the fill and vent procedures for the subject systems prior to startup from the refueling outages, spring of 2010 for IP-2 and spring of 2009 for IP-3.
Status: The fill and vent procedures for IP-3 were revised prior to the cycle 15 refueling outage (3R15) in the spring of 2009. IP-2 procedures will be revised prior to the IP-2 refueling outage scheduled for the spring of 2010.
- g. As an enhancement, seven new vent valves will be added which include three new vent valves at IP-3 and four new vent valves at IP-2, to prevent future gas accumulation as per the work management process.
Status: The following three new vent valves were added for the IP-3 SI system during the cycle 15 refueling outage (3R15):
A new vent valve on 31 SI pump suction.
A new vent valve on 33 SI pump suction and A new vent valve on alternate suction line to 32 SI pump The four new vent valves at IP-2 listed below will be added during the IP-2 cycle 19 refueling outage (2R19) scheduled for spring 2010.
A new vent valve on 21 SI pump suction A new vent valve on 23 SI pump suction and A new vent valve on alternate suction line to 22 SI pump A new vent valve downstream of valve 732 in RHR. (Note: similar valve was previously added at IP-3)
Conclusion Entergy has evaluated the previously unevaluated portions of the applicable systems at IP-3 that perform the functions described in Generic Letter 2008-001 and has concluded that these systems are operable.