ML17061A112
| ML17061A112 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/02/2017 |
| From: | James Trapp Division of Nuclear Materials Safety I |
| To: | Vitale A Entergy Nuclear Operations |
| Schroeder D | |
| References | |
| EA-16-223, IR 2016002 | |
| Download: ML17061A112 (3) | |
See also: IR 05000286/2016002
Text
A. Vitale
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD.
KING OF PRUSSIA, PA 19406-2713
March 2, 2017
Mr. Anthony J. Vitale
Site Vice President
Entergy Nuclear Operations, Inc.
Indian Point Energy Center
450 Broadway, GSB
P.O. Box 249
Buchanan, NY 10511-0249
SUBJECT: WITHDRAWAL OF NON-CITED VIOLATION 05000286/2016002-02
Dear Mr. Vitale:
In your letter dated September 29, 2016 (ML16281A4861), you contested a Green non-cited
violation (NCV) that was documented in the Indian Point Entergy Center (Indian Point) 2016
second quarter integrated inspection report dated August 30, 2016 (ML16243A245). The NCV
was against 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, and
described a failure by Entergy Nuclear Operations (Entergy) to follow the operability process as
prescribed in Entergy procedures at Indian Point. Specifically, in March 2016, Entergy
identified actual or potential degradation of approximately 25 percent of the baffle-former bolts in
the Indian Point Unit 2 reactor vessel. A sufficient number of bolts are required to ensure proper
core flow during normal and postulated accident conditions, and also to ensure that control rods
can be inserted to shut down the reactor. Entergy performed a root cause evaluation and
replaced the degraded bolts. Entergy also performed an immediate operability determination for
Unit 3 in accordance with its procedure EN-OP-104, Operability Determination Process.
However, after concluding that no degraded condition existed on Unit 3, Entergy concluded that
a more detailed operability evaluation of that unit was not required. The NRC did not initially
agree with Entergys basis for this conclusion.
Your September 29, 2016, letter provided an interpretation of Entergy procedure EN-OP-104
related to the baffle-former bolt condition that was different from the NRCs position as
described in the inspection report, and requested that the violation be withdrawn. Your letter
stated, in part, Entergys determination that direct evidence of a degraded or non-conforming
condition was required to necessitate the performance of a full operability evaluation per your
procedure.
1
Designation in parentheses refers to an Agencywide Documents Access and Management System
(ADAMS) accession number. Documents referenced in this letter are publicly-available using the
accession number in ADAMS.
A. Vitale 2
In response to your letter, the NRC formed a panel to review the information you provided. The
staff members involved were independent of the initial inspection effort. Based on a thorough
review of the issue, the NRC has concluded that the violation as written cannot be supported.
Specifically, the independent review noted different steps within the procedure that could be
interpreted to either support or refute Entergys claim related to the need for direct evidence of a
degraded or non-conforming condition. As a result of this potential for differing interpretations of
your procedural requirements, the NRC has determined that it was not appropriate to issue a
violation for a failure to comply with the procedure. Therefore, the NCV is hereby withdrawn,
and we will modify our records accordingly.
The NRC acknowledges that the operability implications of operating experience on systems,
structures, and components requires judgment, especially in cases where direct inspection and
testing results are not readily available. Given the similarities between Unit 3 and Unit 2, and
other operating plants where degradation was observed, a technically adequate assessment
was warranted to affirm the presumption of operability of the emergency core cooling systems
capability to provide long-term core cooling. While the NRC has determined that your initial
assessment of this condition relied on assumptions that were not fully supported, an adequate
analysis was ultimately developed to provide reasonable assurance of operability for the
emergency core cooling system function until the next refueling outage when inspections could
be performed. As such, the NRC does not plan any additional action related to this issue.
As you are aware, on September 29, 2016, the Nuclear Energy Institute (NEI) provided the NRC
a letter related to this NCV (ML16274A473) which expressed the intention to clarify the
conditions/criteria for entry into the operability process. As stated in our response to NEI
(ML16293A951), the NRC staff looks forward to continued meaningful interactions with industry
and the public to help ensure necessary and appropriate clarity in operability determination
guidance.
This letter will be made available for public inspection and copying at
http://www.nrc.gov/readingrm/adams.html and at the NRC Public Document Room in
accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
If you have any questions regarding this matter, please contact Mr. Daniel Schroeder at
(610) 337-5262.
Sincerely,
/RA/
James M. Trapp, Director
Division of Nuclear Materials Safety
Docket No. 50-286
License No. DPR-64
cc: Distribution via ListServ
A. Vitale 3
SUBJECT: WITHDRAWAL OF NON-CITED VIOLATION 05000286/2016002-02 DATED
MARCH 2, 2017
DISTRIBUTION: (via email)
DDorman, RA
DLew, DRA
MScott, DRP
DPelton, DRP
RLorson, DRS
JYerokun, DRS
TSetzer, DRP
BSmith, DRP
JSchussler, DRP
SRich, DRP, RI
CSafouri, DRP, RI
JBowen, RI OEDO
RidsNrrPMIndianPoint Resource
RidsNrrDorlLpl1-1 Resource
JTrapp, DNMS
DSchroeder, DRP
MGray, DRS
DOCUMENT NAME: G:\DRP\BRANCH2\a - Indian Point\IP disputed NCV withdrawal letter final.docx
ADAMS Accession Number: ML17061A112
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/DRP RI/DRP RI/OE RI/ORA RI/DRP
NAME TSetzer DSchroeder BBickett BKlukan MScott
DATE 2/7/17 2/6/17 2/8/17 2/8/17 2/15/17
OFFICE RI/DRS RI/DNMS
NAME RLorson JTrapp
DATE 2/14/17 3/2/17
OFFICIAL RECORD COPY