NL-12-041, Response to Request for Additional Information Regarding Operator Manual Action

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Response to Request for Additional Information Regarding Operator Manual Action
ML12074A028
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/01/2012
From: Ventosa J
Entergy Nuclear Northeast
To: Bill Dean
Division of Nuclear Materials Safety I
References
NL-12-041
Download: ML12074A028 (16)
v • d • e


Text

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Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventou Site Vice President Administration NL-12-041 Mar(;h 1, 2012 Mr. William M. Dean Regional Administrator USNRC Region I 475 Allendale Road King of Prussia, PA 19406

Subject:

Response to Request for Additional Information Regarding Operator Manual Actions Indian Point Nuclear Generating Units 2 & 3 Docket Nos. 50-247, 50-286 License Nos. DPR-26, DPR-64

References:

1. NRC letter dated February 1, 2012, "Indian Point Energy Center Units 2 & 3-Request for Additional Information Regarding Operator Manual Actions"
2. NRC letter dated February 1, 2012, "Indian Point Nuclear Generating Unit NO.2 - Exemption from the Requirements of 10 CFR Part 50, Appendix R, Paragraph III.G.2 (TAC No. ME0798)
3. NRC letter dated February 1, 2012, "Indian Point Nuclear Generating Unit No.3 - Exemption from the Requirements of 10 CFR Part 50, Appendix R, Paragraph III.G.2 (TAC No. ME0799)

Dear Sir:

By letters dated February 1, 2012 (References 2 and 3), exemptions from the requirements of 10 CFR 50, Appendix R, Paragraph III.G.2 for the use of operator manual actions (OMAs) were granted in part and denied in part for Indian Point Units 2 and 3. A request for additional information regarding the plans by Entergy Nuclear Operations, Inc. (Entergy) for achieving compliance with fire protection regulations in light of the denied exemptions was also transmitted by letter dated February 1, 2012 (Reference 1). The information contained herein is provided in response to Reference 1, and l:ontains Entergy's current and planned actions, and the schedule for completion of corrective actions that will resolve each of the identified OMA concems, and thereby establish full compliance with the requirements of the applicable subsection of 10 CFR 50, Appendix R, Section III.G for both units.

NL-12-041 Docket Nos. 50-247 & 50-286 Page 2 of 3 Prior to receipt of the letters (References 2 and 3), Entergy had been informed that not all of the exemption requests would be approved via telecons with NRC on May 9,2011 and May 31, 2011. In response to these verbal notifications, Entergy implemented compensatory actions for all plant areas associated with all of the requested OMAs, irrespective of whether the exemptions were expected to be denied or granted for these plant areas. Those actions, in the form of roving hourly fire watch patrols, continue in place at this time and will be maintained until such time as each OMA issue is resolved.

As established by the Indian Point Fire Protection Program, the compensatory hourly fire watch patrols are maintained in all affected plant areas that are normally accessible during plant power operation. Where certain OMAs are invoked for zones within the reactor containment building, in recognition of personnel safety and ALARA concerns, the fire protection program provides for an equivalent compensatory action in the form of an hourly log of reactor containment building temperature, maintained by control room oper:ators. If an unexplained increase in containment building temperature were to be observed, operators would be dispatched to investigate and initiate further actions as necessary.

The resolution of the III.G.2 OMA concerns for those OMAs denied exemption will be accomplished through an integrated approach involving both engineering analysis and plant physical modifications. In certain cases, it is Entergy's expectation that revision of the respective Appendix R post-fire safe-shutdown analysis and methodology will form the basis for elimination of certain OMAs. In the remaining cases, it is expected that plant physical modifications will be necessary to eliminate the need for certain OMAs.

These modifications, as presently conceptualized, are expected to involve installation of appropriately rated fire barriers, potential rerouting of circuits, and potential modification of circuit protection and/or control schemes. presents a listing of the Unit 2 OMAs that were denied and Attachment 2 presents the Unit 3 denied OMAs. The tables in the attachments present the OMAs sorted by the fire zone(s) of concern, i.e., those fire zones for which use of the discrete OMAs had been requested, and they include a description of the planned resolution and scheduled completion date for each of the OMAs.

Given the substantial technical challenge imposed by the OMA resolution effort, and recognizing that the requisite engineering evaluations are in progress at this time, the presently conceptualized solutions may change, in that the scope of analyses and/or the natur,e and scope of plant physical modifications may require revision as the OMA resolutions are finalized. The target completion dates shown in Attachments 1 and 2 represent Entergy's current informed projection, and any change in resolution concept and/or completion schedule that may be determined to be necessary as an outcome of the engineering analysis and evaluation process will be promptly communicated to NRC.

/

NL-12-041 Docket Nos. 50-247 & 50-286 Page 3 of 3 Please note that for Unit 2, one of the requested OMAs for Fire Area K (Operate 21 AFW Pump flow control valves to control AFW flow to Steam Generators 21 & 22) was not addressed in the Exemption transmitted by Reference 2. It has been designated as OMA Number "19" in Attachment 1. The modification that is planned for Fire Area K to eliminate OMAs 14 and 15 will also eliminate this OMA, so approval of this OMA is not required. If any additional discrepancies are discovered they will be addressed via separate correspondence.

New regulatory commitments made in this submittal are identified in Attachment 3 to this letter.

In the event of any questions, please contact Mr. Robert W. Walpole, Manager, Licensing at 914-254-6710.

Sincerely, JV/gd Attachments: 1. Resolution of Indian Point Unit 2 III.G.2 OMAs For Which Exemptions Have Been Denied

2. Resolution of Indian Point Unit 3 III.G.2 OMAs For Which Exemptions Have Been Denied
3. List of Regulatory Commitments cc: Mr. John Boska, Senior Project Manager, NRC NRR DORL U.S. Nuclear Regulatory Commission Document Control Desk NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Department of Public Service

Attachment 1 to NL-12-041 Resolution of Indian Point Unit 2 III.G.2 OMAs For Which Exemptions Have Been Denied ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 & 50-286 License Nos. DPR-26 & DPR-64

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 1 Page 1 of 4 RESOLUTION OF IHOIANPOJNT UNIT 2 111.6.2 OMAS FOR WHICH EXEMPTIOHS HAVE BEEN OENIED Fire Area . OMA Scheduled No} Planned Resolution CompletIon IZone Data F/5A 6 Revise Appendix R safe-shutdown analysis and methodology to Q32012 credit equipment train independent of the fire area/zone, thereby I eliminating this OMA FI6 6 As described for OMA 6, Fire Area F,Fire Zone5A Q32012 7 RevlseAr>Pen~lx R safe-shutdown ana'~and methodojogy to Q42012 credit equlpment~ independent of .... lire areafzone. tlereby eliminating this OMA FI7A 6 As described for OMA 6, Fire Area F, Fire Zone SA Q32012 7 As described for OMA 7, Fire Area F, Fire Zone 6 Q42012

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FI22A 6 As described for OMA 6, fire Area F, Fire Zone SA Q32012 F/27A 5 Revise Appendix R safe-shutdown analysis and methodology to Q32012 credit equipment train independent of the fire area/zone, thereby eliminating this OMA 6 As described for OMA 6. Fire Area F. Fire Zone SA 032012 FI33A 5 As desCribed for OMA 5, Fire Area F,rU'e Zone 27A 032012 F/59A 5 As described for OMA 5. Fire Area F, Fire Zone 27A 032012 Hl72A 8 Revise* Appendlx R safe..shutdoWn analysis and methodol.ogy"to 032012 oredit*equlpmenttrain independent of. the fire arealzone, thereby eliminating thlsOMA H175A 8 Revise Appendix R safe-shutdown analysis and methodology to 032012 credit a train of equipment free of fire damage in the fire area/zone, thereby eliminating this OMA 9,10 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating these OMAs RFO Hl77A 8 I As described for OUA 8, Fire Area H, Fire Zone 72A 032012

~,10 As ~ forOMAs 9,10, Fire Area H, Fire Zone 75A Spring 2014 RFO H/84A I, 8 i As described for OMA 8, Fire Area H, Fire Zone 72A 032012 HI85A 8 As desCribed for OMA 8, Fire Area H. Fi"" Zone 72A 032012 I As identified in table on pages 5 and 6 in Exemption transmitted by Reference 2

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 1 Page 2 of4 RESOlUTION OF INDIAN POINT UNIT 2 UL6.20MAS FOR WHICH EXEMPTIONS HAVE SeeN DENtED FireAr.. OMA Schdled I Zone No.1 Planned Resolution completion Date H/87A 8 As described for OMA 8, Fire Area H, Fire Zone 72A 032012 9,10 As described for OMAs 9,10, Fire Area H, Fire Zone 75A Spring 2014 RFO J/19 11 Reassess ~*drCuit and powe~,upp1y loading.analy$es and 032012 revlseAppendix R safHhutdowrumalySis and methodology to provide the basis fOr elimination ofthIS OMA J/25 12 Revise Appendix R safe-shutdown analysis and methodology to Q42012 credit equipment train independent of the fire area/zone, thereby eliminating this OMA JI39A 11 As described for ~\11. Fire. ~J.FlJeZone 19 Q32012 12 As~ fQrO .... 12. Fire Arrea"iF.,. ~"25

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Q42012 J/43A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Q32012 12 As described for OMA 12, Fire Area J, Fire Zone 25 042012 13 Revise Appendix R safe-shutdown analysis and methodology to i 032012 credit equipment train independent of the fire area/zone, thereby ellminating this OMA JJ45A 11 . AsdeseribedforOMA 11. FireAreaJ.FireZone.1~ Q32012 J/46A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Q32012 12 I As described for OMA 12. Fire Area J, Fire Zone 25 Q42012 13 As described for OMA 13. Fire Area J, Fire Zone 43A Q42012 JJ47A 11 As descnbed for OMA 11. Fire Area J,Fir(:l ZOne 19 Q32012 J/50A 11 I As described for OMA 11. Fire Area J. Fire Zone 19 2012 i uc",,-,,-i:Jc... for OMA 12. Fire Area J. Fire Zone 25 042012 JJ270 12 As deseflbed for OMA 12, Fire Area J, Fire Zone 25 042012

NL*12*041 Docket Nos. 50-247 & 50*286 Attachment 1 Page 3 of4 RESOLUTION OF INDIAN POINT UNIT 2 IfI.G.20MAS FOR WHICH EXEMPTIONS HAVE BEEN DENIED Scheduled Fire Area OMA Planned Resolution Completion I Zone No."

Date Kl60A 14 Implement modification to protect circuits of concern, thereby 042012 eliminating this OMA I, 15 Implement modification to protect circuits of concern, thereby eliminating this OMA I 042012 I

! 19 Implement modification to protect circuits of concern, thereby 042012 eliminating this OMA Note: This OMA was not addressed in the Exemption transmitted by Reference 2 and has been given the next sequential number Kl65A 14 As described for OMA 14, Fire AreaK, Fire Zone 60A 042012 15 As described for OMA 15. Fire AreaK. Fire Zone 60A 042012 19 As desCrIbed forOMA 19, Fire Area K. Fire ZOne 60A 042012

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 1 Page 4 of4 Description of Unit 2 Denied OMAs

5. Open HCV-142 bypass valve 227 to align charging pump makeup path to the Reactor Coolant System (RCS)
6. Align charging pump suction source to the Refueling Water Storage Tank (RWST)
7. Transfer instrument buses 23 and 23A to alternate power
8. Fail open valves 204A (charging flow to Loop 2 hot leg) and 204B (charging flow to Loop 1 cold leg) to align charging pump makeup path to the RCS
9. Activate or enable Alternate Safe Shutdown System pneumatic instruments (steam generator level:, pressurizer pressure and level) at Fan House local control panel
10. Enable Alternate Safe-Shutdown System source-range channel and Loop 21 and 22 hot leg (Th) and cold leg (Tc) temperature channels
11. Trip breakers 52/5A and 52-SAC on Bus 5A and 52/6A and 52fTAO at Bus 6A and remove control power fuses
12. Transfer Instrument Buses 23 and 23A to emergency power source
13. Align charging pump suction to RWST
14. Operate transfer switch EDC5 and close supply breaker at substation 12FD3 to transfer 21 AF'JIj' Pump to Alternate Safe Shutdown System power source
15. Open 21 AFW Pump recirculation bypass valve BFD-77
19. Operate 21 AFW Pump flow control valves to control AFW flow to Steam Generators 21 & 22 NOTE: The descriptions are copied from the table on pages 5 and 6 in Exemption transmitted by Reference 2

Attachment 2 to NL-12-041 Resolution of Indian Point Unit 3 III.G.2 OMAs For Which Exemptions Have Been Denied ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 & 50-286 License Nos. DPR-26 & DPR-64

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 2 Page 1 of 5 R&SOLUTION OF fNOfANPoQINT UNIT 3 Iff.G~QM.A$FQRWHIQI*.I;~ HA'(E:BSSI ~I;O FI",Area' ***OMA ZOneNo.'!

ETN-4{1} I 2 Revise Appendix R safe-shutdown analysis and methodology to 022012 7A credit existing separation within the fire area/zone, thereby eliminating this OMA 3 Revise Appendix R safe-shutdown analysis and methodology to 022012 credit existing separation within the fire area/zone, thereby eliminating this OMA 4 . Revise Appendix R safe-shutdown analysis and methodology to 022012 credit existing separation within the fire area/zone, thereby eliminating this OMA 6 . Revise Appendix R safe-shutdown analysis and methodology to 022012 credit existing separation within the fire area/zone, thereby eliminating this OMA 7 Revise Appendix R safe-shutdown analysis and methodology to 022012 credit existing separation within the fire area/zone, thereby eliminating this OMA 8 Revise Appendix R safe-shutdown analysis and methodology to 022012 credit existing separation within the fire area/zone, thereby eliminating this OMA ETN-4{1} I 022012 60A Q22012 Q2 2012 022012 042012 04 2012 022012 I As identified in table on pages 5 and 6 in Exemption transmitted by Reference 3

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 2 Page 2 of5 RESOLUTION OF ~**POINT UNIT 3 "

111.<1.2 OMAS FOR WHICH EXEMPTIONS HAVE BEEN DENIED Scheduled F1reArea*/ OMA Planned Resolution Completion 1

Zone No. Date ETN-4{'I} I 12 Revise Appendix R safe-shutdown analysis and methodology to 042012 60A credit existing separation within and/or independent of the fire (continued) area/zone, thereby eliminating this OMA 13 Implement power/control circuit modification to ensure post-fire 042012 functionality of the SelVice Water strainers for III.G.2 fire scenarios. thereby eliminating this OMA

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ETN-4{3}1 14 ~---------------+~----~ 042012 73A 15 042012 042012 042012 18 Revise Appendix R safe-shutdown analysis and methodology to 042012 credit equipment train independent of the fire area/zone, thereby eliminating this OMA PA&>2{5}J 19 Revise AppendQc R safMhutdOwn analysis and methodology to 042012 17A credit equipment Qln independent of the fire areaiZone, thereby elimineting this OMA 042012 042012 PAB~2{t)} I 19 As described for OMA 19, Fire Area PAB-2{5}, Fire Zone 17A Q42012 19A 20 As described for OMA 20, Fire Area PAB-2{5}, Fire 2012 PAS-2{5} I 22 As desQribed for 0MA22, Fire Are'S. PA8-2{5}. Fire Zone 17A 042012 2M PAB-2{5} I As described for OMA 22, Fire Area PAB-2{5}, Fire Zone 17A Q42012 27A

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 2 Page 30f5 RE$.OLUTION OF 1N~,P9~ UNIT 3 IJUa.2OMAS FORWH~HI:XSttPTioNSHAVIS 8EENDENlED Scheduled

'.,Areal OMA CQmpIetIOn ZOne No.1 PlanftedResoIUtion Date PAB-2{5} I 22 As described for OMA 22. Fire Area PAB-2{5} 117A 042012 30A PAB-2{5} I 21 Revise Appendl)C R ~ a~ysis anqmemodOlogy to 042012 59A credit,.~Ulpmenttrairlinde~~:Ofthe n ereaIZooe, thereby i efimil1~ thi80MA TBl-5/37A 25 Implement power/control circuit modification to ensure post-fire 042012 functionality of the Service Water strainers for III.G.2 fire scenarios, thereby eliminating this OMA TBL;'s I 38A 25 AS desetibedforOMA 2S, Fire Area TBL--5. Fire Zone 37A 042012 TBL-5/43A 25 As described for OMA 25. Fire Area TBl-5. Fire Zone 37A 042012 TBL-S/44A 2S AS described for OMA 25, Fire Area TBL-S. Fire Zone 37A 04 2012 TBl-5/52A 23 [ImPlement modification to protect affected circuits in this zone, 042012 thereby eliminating this OMA 24 Implement modification to protect affected circuits in this zone. 04 2012 thereby eliminating this OMA TBL-5 I 5A4A . 24 AS ~for oMA24, Fire Area TBL;'S, Fire Zone52A 042012 YARD-7/22 26 Reevaluate Appendix R safe-shutdown analysis, methodology. 042012 and fire protection licensing basis to validate whether the OMA may be eliminated 27 Implement power/control circuit modification to ensure post* fire 042012 functionality of the Service Water strainers for 1II.G.2 fire

. scenarios. thereby eliminating this OMA YARD-71 27 AS described for OMA 27, Fire Area YARD-7, Fire ZOne 22 042012 222

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 2 Page 4 of 5 Description of Unit 3 Denied OMAs

2. Swap 32 Component Cooling Water (CCW) pump to alternate power supply or align city water to charging pumps
3. Operate 480V Bus 3A breaker locally to start 31 AFW Pump
4. Locally operate the bypass valve for Flow Control Valve (FCV)-1121 in support of use of 31 AFW pump S. Operate HCV-1118 manually to control 32 AFW pump
6. Align Appendix R Diesel Generator (ARDG) to 480V Buses 2A, 3A, SA, and 312
7. Swap 31 or 32 charging pump to alternate power supply
8. Locally operate FCV-40SB, FCV-40SD, or FCV-406B to control AFW flow to Steam Generators (SGs)
9. Locally open valve 227 to establish charging [previously "CVCS"] makeup flowpath to Re,actor Coolant System (RCS)
10. Locally close Level Control Valve (LCV)-112C and open valve 288 to align charging pump suction to the Refueling Water Storage Tank (RWST)
11. Locally operate Pressure Control Valve PCV-1139 to ensure steam supply to 32 AFW Pump
12. Locally operate PCV-1310A and PCV-1310B to ensure steam supply to 32 AFW pump
13. Loc;ally manually perform Service Water (SW) pump strainer backwash as required
14. Operate HCV-1118 manually to control 32 AFW pump 1S. Locally operate PCV-1139 to ensure steam supply to 32 AFW pump
16. Locally operate 32 PCV-1310A, PCV-1310B to ensure steam supply to 32 AFW pump
17. Loc:ally operate FCV-40SC and FCV-40SD to control AFW flow to SG
18. Loc:ally close valve LCV-112C, and open valve 288 to align charging pump suction path to RVVST

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 2 Page 5 of 5

19. Locally close supply breaker for 32 Charging Pump [previously "CVCS"] Pump
20. Locally control 32 charging [previously "CVCS"] pump using scoop tube positioner
21. Open bypass valve 227 to establish charging flowpath to RCS around potentially failed closed HCV-142
22. Locally close valve LCV-112C and open bypass valve 288 to establish flowpath from RWST to charging pump suction
23. Locally operate [bypass valve for] FCV-1121 AFW pump recirculation valve during pump startup
24. Locally operate FCV-406A and FCV-406B to control AFW flow to SGs
25. Locally/manually backwash SW pump strainer as required if power to strainer associated with selected SW pump is lost (use one of STR PMP-31 through STR PMP-36)
26. Locally start ARDG to supply Motor Control Center (MCC) 312A in support of the use of SW pump 38
27. Locally/manually backwash SW pump strainer as required if power to strainer associated with selected SW pump is lost NOTE: The descriptions are copied from the table on pages 5 and 6 in Exemption transmitted by Reference 3

Attachment 3 to NL-12-041 List of Regulatory Commitments ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247 & 50-286 License Nos. DPR-26 & DPR-64

NL-12-041 Docket Nos. 50-247 & 50-286 Attachment 3 Page 1 of 1 List of Regulatory Commitments The following table identifies those actions committed to by Entergy in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

~! COMMITMENT IMPLEMENTATION SCHEDULE 1 Any change in resolution concept and/or completion Upon schedule that may be determined to be necessary as identification of an outcome of the engineering analysis and evaluation any needed process will be promptly communicated to NRC change(s)

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