ML14069A534

Unit No. - Request for Additional Information Regarding the Steam Generator License Amendment Request to Revise Technical Specification for Permanent Alternate Repair Criteria

ML14069A534
Person / Time
Site:	Indian Point
Issue date:	03/18/2014
From:	Pickett D Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Pickett D, NRR/DORL, 415-1364
References
TAC MF3369
Download: ML14069A534 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 18, 2014 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2- REQUEST FOR ADDITIONAL INFORMATION REGARDING THE STEAM GENERATOR LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION FOR PERMANENT ALTERNATE REPAIR CRITERIA (TAC NO. MF3369)

Dear Sir or Madam:

By letter dated January 16, 2014, Entergy Nuclear Operations, Inc. submitted a proposed license amendment for alternate repair criteria for steam generator tube inspection and repair for Indian Point Nuclear Generating Unit No. 2.

The staff of the Steam Generator Tube Integrity and Chemical Engineering Branch of the Office of Nuclear Reactor Regulation is reviewing the submittal and has determined that additional information is required in order to complete the evaluation. The specific questions are found in the enclosed request for additional information (RAI). Based on our discussions we understand that a response to the RAI will be provided within 30 days of the date of this letter.

Please contact me at (301) 415-1364 if you have any questions on this issue.

Sincerely, Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE STEAM GENERATOR LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION FOR PERMANENT ALTERNATE REPAIR CRITERIA INDIAN POINT NUCLEAR GENERATING UNIT NO.2 ENTERGY NUCLEAR OPERATIONS. INC.

DOCKET NO. 50-247 By letter dated January 16, 2014 (Agencywide Document Access and Management System (ADAMS) Accession No. ML14027A514), Entergy Nuclear Operations, Inc. (the licensee) submitted a request for a license amendment in the form of changes to the technical specifications for Indian Point Nuclear Generating Unit No.2 (IP2). The Nuclear Regulatory Commission staff has the following request for additional information related to your submittal.

Background

The current technical specification (TS) limiting condition for operation (LCO) on operational primary-to-secondary leakage is 150 gallons per day (gpd) through any one steam generator (SG). The purpose of this limit is to minimize the frequency of tube ruptures and to ensure that primary-to-secondary leakage does not exceed that assumed in the accident analyses.

For IP2, the main steam line break (MSLB) accident analysis assumes leakage is 150 gpd per SG, or increases to 150 gpd per SG due to accident conditions. The technical support document for the proposed license amendment (WCAP-17828, Rev. 0) demonstrates that operational leakage from cracks located at or below the H* distance is expected to increase by a factor of 1.75 during a MSLB. Therefore, if operational leakage from such cracks approaches the 150-gpd LCO limit, the expected leakage under postulated MSLB conditions would be

1. 75 X 150 gpd, exceeding the assumptions in the accident analysis.

Amongst the other plants that have approved H* amendments, only Catawba Unit 2 has a similar situation. As part of its license amendment for H*, Catawba Unit 2 reduced its LCO limit by a factor approximately equal to its leakage factor (3.27), resulting in a TS LCO of 45 gpd through any one SG.

Request #1 Please discuss the basis for not including a change to the LCO limit (TS Section 3.4.13), or discuss your plans for submitting a proposed change.

Background

All plants receiving a permanent license amendment for H*, have committed to using their plant-specific leakage factor developed in the appropriate WCAP supporting the license amendment request, as shown below:

Enclosure

For the condition monitoring assessment, the component of operational leakage from the prior cycle from below the H* distance will be multiplied by a factor of

1. 75 and added to the total accident leakage from any other source and compared to the allowable accident induced leakage limit. For the operational assessment, the difference in the leakage between the allowable accident induced leakage and the accident-induced leakage from sources other than the tubesheet expansion region will be divided by 1. 75 and compared to the observed operational leakage. An administrative limit will be established to not exceed the calculated value.

Request #2 Please discuss your plans for submitting such a commitment in conjunction with your license amendment request.

Background

The technical supporting document, "Acceptable Value of the Locations of the Bottom of the Expansion Transition (BET) for Implementation of H*" (LTR-SGMP09-111 P-Attachment, Rev. 1), dated September 2010, contains an analysis of BET locations for plants requesting implementation of permanent H* amendments. This document does not contain BET data for IP2.

Request #3 Please provide the BET information discussed above and assess the acceptability of the BET measurement for each tube for the purposes of supporting the proposed H* distance.

ML14069A534 OFFICE LPL1-11PM LPL 1-11LA ESGBIBC LPL 1-11BC NAME DPickett KGoldstein GKulesa by memo dated BBeasley DATE 03 I 14 I 2014 03 I 12 I 2014 03 I 07 I 2014 03118/2014