NL-13-072, Status of Planned Resolutions of the Unapproved III.G.2 Operator Manual Actions

Status of Planned Resolutions of the Unapproved III.G.2 Operator Manual Actions

ML13142A226
Person / Time
Site:	Indian Point
Issue date:	05/02/2013
From:	Ventosa J Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-072
Download: ML13142A226 (14)

Text

Enterqy Nuclear Indian Point Energy Center 450 Broadway, GSB

%n P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President NL-13-072 May 2, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

Status of Planned Resolutions of the Unapproved III.G.2 Operator Manual Actions Indian Point Nuclear Generating Unit Nos. 2 & 3 Docket Nos. 50-247, 50-286 License Nos. DPR-26, DPR-64

References:

1. Entergy letter NL-12-179 dated December 7, 2012, "Revision to the Reply to Notices of Violation Regarding Unapproved III.G.2 Operator Manual Actions"

2. Entergy letter NL-12-122 dated September 17, 2012, "Reply to Notices of Violation Regarding Unapproved III.G.2 Operator Manual Actions"

3. NRC letter dated August 16, 2012, "Indian Point Nuclear Generating Units 2 and 3 - NRC Inspection Report 05000247/2012009 and 05000286/2012008 and Notices of Violation"

4. 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)"

5. 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 or Madam:

By letter dated September 17, 2012 (Reference 2), Entergy Nuclear Operations, Inc.

(Entergy) replied to the violations issued in Reference 3 for Indian Point Nuclear Generating Unit No. 2 (IP2) and Unit No. 3 (IP3) for the use of unapproved operator manual actions (OMAs) to mitigate safe shutdown equipment malfunctions caused by a fire-induced single spurious actuation in lieu of protecting the equipment in accordance C)d

NL-13-072 Docket Nos. 50-247 & 50-286 Page 2 of 3 with 10 CFR Part 50 Appendix R, Paragraph III.G.2. The violations resulted from the denial of a number of OMAs in the Exemptions transmitted by letters dated February 1, 2012 (References 4 and 5). A revised response to the NOV was transmitted by letter dated December 7, 2012 (Reference 1).

Attachments 1 and 2 herein provide the status update of the Planned Resolutions for the unapproved OMAs, which were last provided in Attachments 2 and 3 in Reference 1, as follows:

• For IP2 (Attachment 1), the "Scheduled Completion Date" for OMAs 7, 12, 13, 14, 15 and 19 in all applicable Fire Areas/Fire Zones is now "Completed" (previously "Q4 2012") as the Planned Resolutions were completed in the fourth quarter of 2012. Note that the Planned Resolutions of all remaining IP2 unapproved OMAs require an outage to implement, which is currently scheduled for Spring 2014.

• For IP3 (Attachment 2), the Planned Resolution for OMA 9 in Fire Area ETN-4{1}

Fire Zone 60A was to revise the Appendix R safe-shutdown analysis and methodology to credit existing separation within and/or independent of the fire area/zone, thereby eliminating this OMA. Although the evaluation was completed according to the original Scheduled Completion Date of "Q4 2012,"

the evaluation determined that the ability to eliminate this OMA was linked to planned Charging system modifications associated with OMA 10, which had a Scheduled Completion Date of "Q2 2013." As the modification has been installed during the recent 2013 refueling outage, the "Scheduled Completion Date" is now "Completed" for OMAs 9 and 10. Entergy committed in Reference 2 to inform the NRC of any changes in resolution concept and/or completion schedule that may be determined to be necessary as an outcome of the ongoing engineering analysis and evaluation process. This schedule change to OMA 9 was communicated via telecom to NRC Region I in January, 2013, at which time it was agreed to provide this status update letter after the recent IP3 refueling outage.

• For IP3, the "Scheduled Completion Date" for OMAs 12, 14, 15, 16, 17, 18, 19, 20, 21, 22, and 26 in all applicable Fire Areas/Fire Zones is now "Completed" (previously "Q4 2012") as the Planned Resolutions were completed in the fourth quarter of 2012.

• Note that the Planned Resolutions for all of the IP3 unapproved OMAs are now complete.

There are no new commitments contained in this letter. In the event of any questions, please contact Mr. Robert W. Walpole, Manager, Licensing at 914-254-6710.

NL-13-072 Docket Nos. 50-247 & 50-286 Page 3 of 3 Sincerely, JAV/gd Attachments:

1. Status of Resolution of Indian Point Unit 2 Unapproved III.G.2 OMAs (Revision of Attachment 2 from Entergy Letter NL-1 2-179 dated December 7, 2012)

2. Status of Resolution of Indian Point Unit 3 Unapproved III.G.2 OMAs (Revision of Attachment 3 from Entergy Letter NL-12-179 dated December 7, 2012) cc: Mr. William Dean, Regional Administrator, NRC Region I Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Ms. Bridget Frymire, New York State Department of Public Service Mr. Francis J. Murray, Jr., President and CEO, NYSERDA NRC Resident Inspectors

Attachment 1 to NL-13-072 Status of Resolution of Indian Point Unit 2 Unapproved III.G.2 OMAs (Revision of Attachment 2 from Entergy Letter NL-12-179 dated December 7, 2012)

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-13-072 Docket Nos. 50-247 & 50-286 Attachment 1 Page 1 of 4 F/5A 6 Revise Appendix R safe-shutdown analysis and methodology to Spring 2014 credit equipment train independent of the fire area/zone and RFO implement modification to establish separate fire area OR implement modification to protect circuits of concern, thereby eliminatina this OMA F/7A 6 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating this OMA RFO 7 As described for OMA 7, Fire Area F, Fire Zone 6 Completed 20 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating this OMA (see Note on page 4) RFO 21 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating this OMA (see Note on page 4) RFO F/27A 5 Revise Appendix R safe-shutdown analysis and methodology to Spring 2014 credit equipment train independent of the fire area/zone, thereby RFO eliminating this OMA I I 6 As described for OMA 6, Fire Area F, Fire Zone 7A Spring 2014 RFO Spring 2014 I I F/59A 5 As described for OMA 5, Fire Area F, Fire Zone 27A 1 RFO I As identified in table on pages 5 and 6 in Exemption transmitted by 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)", with the exception of OMAs 19, 20 and 21 - see Note on page 4

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 1 Page 2 of 4 H/75A 8 Revise Appendix R safe-shutdown analysis and methodology to Completed credit a train of equipment free of fire damage in the fire area/zone, thereby eliminating this OMA 4 4 9,10 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating these OMAs RFO 9-4 9 H/77A 8 As described for OMA 8, Fire Area H, Fire Zone 72A Completed 9,10 As described for OMAs 9,10, Fire Area H, Fire Zone 75A Spring 2014 RFO I H/85A I 8 I As described for OMA 8. Fire Area H. Fire Zone 72A I ComDleted I 11 Reassess electrical circuit and power supply loading analyses and Completed I revise Appendix R safe-shutdown analysis and methodology to I J/1 9 provide the basis for elimination of this OMA J/39A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed t 1 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed I J/45A I 11 I As described for OMA 11, Fire Area J, Fire Zone 19 1 Completed I I J/47A I 11 I As described for OMA 11. Fire Area J. Fire Zone 19 I Comoleted I

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 1 Page 3 of 4 J/270 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed h~b K/60A 14 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA 15 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA _

19 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA (see Note on page 4)

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 1 Page 4 of 4 Description of Unit 2 Unapproved 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 52/TAO 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 AFW 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

20. Locally operate 21 Charging Pump scoop tube positioner

21. Locally start 21 Charging Pump using the emergency control station located in the 480V Switchgear Room NOTE: With the exception of OMAs 19, 20 and 21, the descriptions are copied from the table on pages 5 and 6 in Exemption transmitted by 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)". OMA 19 was not addressed in the Exemption transmitted by that letter.

OMAs 20 and 21 were inadvertently omitted from the exemption request process, and are therefore unapproved OMAs. The three OMAs have been given the next sequential numbers.

Attachment 2 to NL-13-072 Status of Resolution of Indian Point Unit 3 Unapproved III.G.2 OMAs (Revision of Attachment 3 from Entergy Letter NL-12-179 dated December 7, 2012)

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-13-072 Docket Nos. 50-247 & 50-286 Attachment 2 Page 1 of 5 ETN-4{1} / 2 Revise Appendix R safe-shutdown analysis and methodology to Completed 7A credit existing separation within the fire area/zone, thereby eliminating this OMA 3 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminating this OMA 4 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminating this OMA 6 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminating this OMA 7 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminating this OMA 8 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminatina this OMA 2 As identified in table on pages 5 and 6 in Exemption transmitted by 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)"

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 2 Page 2 of 5 ETN-4{1}

1 12 Revise Appendix R safe-shutdown analysis and methodology to Completed 60A credit existing separation within and/or independent of the fire (continued) area/zone, thereby eliminating this OMA

.4- +

13 Implement power/control circuit modification to ensure post-fire Completed functionality of the Service Water strainers for III.G.2 fire scenarios, thereby eliminating this OMA PAB-2{3} / 6 18 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA 19 I PAB-2{5}!/

19A I 20 As described for OMA 19, Fire Area PAB-2{5}, Fire Zone 17A I As described for OMA 20, Fire Area PAB-2{5}, Fire Zone 17A I Completed Completed I.........

I I 27A PAB-2{5}/

22 As described for OMA 22, Fire Area PAB-2{5}, Fire Zone 17A I Completed I

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 2 Page 3 of 5 I PAB-2{5} / 22 As described for OMA 22, Fire Area PAB-2{5} / 17A Completed I 30A 25 Implement power/control circuit modification to ensure post-fire Completed I TBL-5 / 37A functionality of the Service Water strainers for III.G.2 fire scenarios, thereby eliminating this OMA I I TBL-5 / 43A I 25 I As described for OMA 25, Fire Area TBL-5, Fire Zone 37A I Completed I TBL-5 / 52A 23 Implement modification to protect affected circuits in this zone, t1 thereby eliminating this OMA Completed I 24 Implement modification to protect affected circuits in this zone, Completed I Ithereby eliminatina this OMA YARD-7 /22 26 Reevaluate Appendix R safe-shutdown analysis, methodology, Completed and fire protection licensing basis to validate whether the OMA may be eliminated 27 Implement power/control circuit modification to ensure post-fire Completed functionality of the Service Water strainers for III.G.2 fire scenarios, thereby eliminating this OMA

NL-13-072 Docket Nos. 50-247 & 50-286 Attachment 2 Page 4 of 5 Description of Unit 3 Unapproved 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)-1 121 in support of use of 31 AFW pump

5. Operate HCV-1 118 manually to control 32 AFW pump

6. Align Appendix R Diesel Generator (ARDG) to 480V Buses 2A, 3A, 5A, and 312

7. Swap 31 or 32 charging pump to alternate power supply

8. Locally operate FCV-405B, FCV-405D, or FCV-406B to control AFW flow to Steam Generators (SGs)

9. Locally open valve 227 to establish charging [previously "CVCS"] makeup flowpath to Reactor Coolant System (RCS)

10. Locally close Level Control Valve (LCV)-1 12C and open valve 288 to align charging pump suction to the Refueling Water Storage Tank (RWST)

11. Locally operate Pressure Control Valve PCV-1 139 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. Locally manually perform Service Water (SW) pump strainer backwash as required

14. Operate HCV-1 118 manually to control 32 AFW pump

15. Locally operate PCV-1 139 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. Locally operate FCV-405C and FCV-405D to control AFW flow to SG

18. Locally close valve LCV-1 12C, and open valve 288 to align charging pump suction path to RWST

NL-13-072 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-1 12C and open bypass valve 288 to establish flowpath from RWST to charging pump suction

23. Locally operate [bypass valve for] FCV-1 121 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 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)