ML13177A130
| ML13177A130 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/26/2013 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of License Renewal |
| References | |
| Download: ML13177A130 (4) | |
Text
1 IPRenewal NPEmails From:
Green, Kimberly Sent:
Wednesday, June 26, 2013 10:27 AM To:
rwater1@entergy.com Cc:
IPRenewal NPEmails; Nguyen, Duc
Subject:
Draft RAI on change to MEB program Attachments:
Draft RAI Metal Enclosed Bus Inspection Program May 6 letter change.docx Hi Roger, In a letter dated May 6, 2013, Entergy revised its MEB program to remove the 480 V MEB associated with Substation A from the program. The staff has reviewed the letter and has determined that it needs additional information. Attached is a draft RAI. Please review and let me know if Entergy would like to have a phone call.
- Thanks, Kim
Hearing Identifier:
IndianPointUnits2and3NonPublic_EX Email Number:
4267 Mail Envelope Properties (F5A4366DF596BF458646C9D433EA37D7FF3F5840DD)
Subject:
Draft RAI on change to MEB program Sent Date:
6/26/2013 10:26:35 AM Received Date:
6/26/2013 10:26:38 AM From:
Green, Kimberly Created By:
Kimberly.Green@nrc.gov Recipients:
"IPRenewal NPEmails" <IPRenewal.NPEmails@nrc.gov>
Tracking Status: None "Nguyen, Duc" <Duc.Nguyen@nrc.gov>
Tracking Status: None "rwater1@entergy.com" <rwater1@entergy.com>
Tracking Status: None Post Office:
HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 372 6/26/2013 10:26:38 AM Draft RAI Metal Enclosed Bus Inspection Program May 6 letter change.docx 17875 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
D-RAI 3.0.3.2.11-1
Background:
On April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy or the applicant) applied for renewal of the operating licenses for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3). The Metal Enclosed Bus (MEB) Inspection Program is described in license renewal application (LRA) Section B.1.20 and includes an enhancement to revise appropriate procedures to add the 480V MEB associated with Substation A to the scope of the program.
This enhancement is also reflected in the LRA Updated Final Safety Evaluation Report (UFSAR) Section A.2.1.19. Entergy considered this bus to be within the scope of license renewal because it provides ac power to the IP2 diesel fire pump (DFP).
By letter dated May 6, 2013, Entergy stated that it is making a change to the LRA regarding the MEB Inspection Program and the associated regulatory commitments. Specifically, based on a recent evaluation, Entergy determined that the 480V bus is not used for starting the DFP, but it is used to maintain batteries in a charged state, which in turn provide dc power for starting the DFP and power instrumentation. Entergy stated that any loss of the 480V bus associated with Substation A would initiate an automatic start of the DFP via the batteries. Therefore, the 480V MEB associated with Substation A does not perform a license renewal intended function and thus, Entergy is removing the 480V MEB from the scope of program.
Issue:
10 CFR 54.4(a)(3) requires, in part, that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commissions regulation for fire protection (10 CFR 50.48) are within the scope of license renewal. This is iterated in Section 2.1.3.1.3 of NUREG-1800, Revision 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, which includes the following example:
if an NSR diesel generator is required for safe shutdown under the fire protection plan, the diesel generator and all SSCs specifically relied upon for that generator to comply with NRC regulations shall be included within the scope of license renewal under 10 CFR 54.4(a)(3). Such SSCs may include, but should not be limited to, the cooling water system or systems relied upon for operability, the diesel support pedestal, and any applicable power supply cable specifically relied upon for safe shutdown in the event of a fire.
The DFP is relied upon to demonstrate compliance with the Commissions regulation for fire protection, and therefore, is within the scope of license renewal. The staff considers the MEB associated with 480V Substation A to be within the scope of license renewal because it provides ac power to the chargers to maintain the DFP batteries at full charge. The fully charged batteries will be able to start the DFP during the fire events. It appears that if the 480V MEB is not part of an aging management program, the batteries which start the DFP may become depleted and unable to perform their intended function.
Request:
Provide a technical justification for why the 480V MEB Substation A is not relied upon for the DFP to demonstrate compliance with NRC regulations.