Text

Actions Taken in Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations
	ML073390309
Person / Time
Site:	Indian Point
Issue date:	11/28/2007
From:	Dacimo F; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-06-003, NL-07-1397, TAC MD2671
	Download: ML073390309 (6)
	v • d • e

Entergy Nuclear Northeast Entergy Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration November 28, 2007 Re: Indian Point Unit Nos. 2 & 3 Docket Nos. 50-247, 50-286 NL-07-139 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Actions Taken in Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations (TAC No.

MD2671)

REFERENCES:

1. NRC Generic Letter 2006-03 dated April 10, 2006, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations"

2. Entergy letter dated June 8, 2006 Dacimo to Document Control Desk, "Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations"

Dear Sir or Madam:

By letter dated June 8, 2006 (Reference 2), Entergy Nuclear Operations, Inc. submitted a response to Generic Letter 2006-03 (Reference 1) for Indian Point Unit Nos. 2 and 3. The response to Requested Information 2.d of the generic letter provided a description of and implementation schedules for corrective actions, including a description of any licensing actions or exemption requests needed to support changes to the plant licensing basis. The purpose of this letter is to provide, in response to Requested Information 3 of the generic letter, a description of the actions taken to resolve the nonconforming Hemyc configurations at Indian Point Unit Nos. 2 and 3 described in the original response to Requested Information 2.d.

There are no new commitments contained in this letter. If you have any questions or require additional information, please contact Mr. R.W. Walpole, Manager, Licensing at (914) 734-6710.

Z/2S

NL-07-139 Docket Nos. 50-247, 50-286 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on A',emb w ,2007.

Sincerely, Fred R. Dacimo Site Vice President Indian Point Energy Center Attachments:

1. Actions Taken in Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspectors, IPEC Mr. Paul D. Tonko, President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT 1 to NL-07-139 Actions Taken in Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOs. 2 and 3 DOCKET NOs. 50-247, 50-286

NL-07-139 Docket Nos. 50-247, 50-286 Attachment 1 Page 1 of 3 Actions Taken in Response to Generic Letter 2006-03, "Potentially Nonconforming Hemyc and MT Fire Barrier Configurations" Indian Point Unit 2 The responses to the Requested Information in Generic Letter (GL) 2006-03 were provided in Attachment 1 of Entergy letter dated June 8, 2006 (Reference 1). The response to Requested Information 2.d stated:

"Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the existing Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports. The modification to accomplish this is scheduled to be installed prior to December 1, 2007. The modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP2 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation."

The Hemyc configurations that required additional protection were identified in the response

,to Requested Information 2.a. The areas in which the Hemyc configurations are installed are the Auxiliary Feedwater Pump Room (23 Auxiliary Feedwater Pump power cables), the Piping Penetration Area (isolation valves and tubing for alternate safe shutdown pneumatic instruments), and the Component Cooling Water (CCW) Heat Exchanger and Pump areas (23 CCW Pump power cables). The compensatory measures that were implemented were identified in the response to Requested Information 2.c, and consisted of hourly fire watch tours and ensuring that detection systems were operable.

The modification to install additional protection of the electrical raceway supports and the accompanying engineering evaluation have been completed. Note that there are no electrical raceway supports associated with the Hemyc configuration protecting the 23 Auxiliary Feedwater Pump power cables, so this raceway should have been excluded in Reference I from requiring additional protection. The Hemyc configurations have been returned to service and the compensatory measures that were in place are no longer required for those configurations. Detection systems are required to be operable as part of the fire protection program.

NL-07-139 Docket Nos. 50-247, 50-286 Attachment 1 Page 2 of 3 Indian Point Unit 3 The responses to the Requested Information in Generic Letter (GL) 2006-03 were provided in Attachment 2 of Entergy letter dated June 8, 2006 (Reference 1). The response to Requested Information 2.d stated:

"A review of the installed Hemyc ERFBS has been performed relative to the necessary protection required given the fire hazards of the areas. A request for revision of two existing exemptions will be submitted to change the fire resistive rating of the Hemyc ERFBS in the table in the response to item 2.a from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 30 minutes. This submittal should be made in July 2006.

Based on a review of the results of the 2005 NRC Hemyc testing program, it has been determined that the Hemyc ERFBS will require the installation of additional protection of the electrical raceway supports and certain metallic penetrating items. The modification to accomplish this is not currently scheduled as it is contingent upon NRC approval of the revision to the exemption requests. It is anticipated that the modification would not be installed prior to December 1, 2007. To support the installation, the modification will also be accompanied by an engineering evaluation that documents that the installed Hemyc ERFBS is capable of providing a fire resistance rating of at least 30 minutes, based in part, on comparison of the IP3 installed configurations to the results of the 2005 NRC Hemyc testing and other available industry Hemyc fire testing. Compensatory measures will remain in place until completion of the installation."

The Hemyc configurations that are the subject of the exemption request and which required additional protection were identified in the response to Requested Information 2.a. The areas in which the Hemyc configurations are installed are the Upper Electrical Penetration Area (alternate safe shutdown instrument cables), the Upper Electrical Penetration Area and Upper Electrical Tunnel (one channel of Source Range instrument cables), the Lower Electrical Tunnel (alternate safe shutdown instrument cables), and the CCW Pump area (33 CCW Pump power cables). The compensatory measures that were implemented were identified in the response to Requested Information 2.c, and consisted of hourly fire watch tours and ensuring that detection systems were operable.

The exemption request for the affected Hemyc configurations was submitted by letter dated July 24, 2006 (Reference 2), and responses to the March 15, 2007 Request for Additional Information (Reference 3) were submitted in References 4 and 5. A supplemental submittal was made in Reference 6. The exemption request was approved in Reference 7 (note that a revision is pending to include the commitment wording from Reference 6 rather than Reference 5, but this will not change any aspects of the approval).

As committed to in Reference 6 and approved in Reference 7 (and to be contained in the pending revision), the modification to install additional protection of the electrical raceway supports and certain metallic penetrating items and to install over-banding on the box-type configuration located outside containment will be completed by December 1, 2008. The accompanying engineering evaluation will also be completed at that time. As required by

NL-07-139 Docket Nos. 50-247, 50-286 Attachment 1 Page 3 of 3 Reference 7, the compensatory measures will remain in place until the affected Hemyc configurations are returned to service.

References

1. Entergy letter dated June 8, 2006 (letter number NL-06-060) Dacimo to Document Control Desk, "Response to Generic Letter 2006-03, Potentially Nonconforming Hemyc and MT Fire Barrier Configurations"

2. Entergy letter dated July 24, 2006 (letter number NL-06-078), F.R. Dacimo to Document Control Desk, "Request for Revision of Existing Exemptions from 10 CFR 50, Appendix R: One-Hour Hemyc Electrical Raceway Fire Barrier System, Fire Areas ETN-4 and PAB-2"

3. NRC letter dated March 15, 2007, J.P. Boska to M.R. Kansler, "Indian Point Nuclear Generating Unit No. 3 - Request for Additional Information Regarding the Revision of Existing Exemptions from Title 10 of the Code of Federal Regulations Part 50, Appendix R Requirements (TAC No. MD2671)"

4. Entergy letter dated April 30, 2007 (letter number NL-07-054), F.R. Dacimo to Document Control Desk, "Response to Request for Additional Information Regarding the Request for Revision of Existing Exemptions from 10 CFR 50, Appendix R: One-Hour Hemyc Electrical Raceway Fire Barrier System, Fire Areas ETN-4 and PAB-2 for Indian Point Nuclear Generating Unit No. 3"

5. Entergy letter dated May 23, 2007 (letter number NL-07-061), F.R. Dacimo to Document Control Desk, "Supplemental Response to Request for Additional Information Regarding the Request for Revision of Existing Exemptions from 10 CFR 50, Appendix R: One-Hour Hemyc Electrical Raceway Fire Barrier System, Fire Areas ETN-4 and PAB-2 for Indian Point Nuclear Generating Unit No. 3 (TAC No. MD2671)"

6. Entergy letter dated August 16, 2007 (letter number NL-07-084), F.R. Dacimo to Document Control Desk, "Supplement to the Request for Revision of Existing Exemptions from 10 CFR 50, Appendix R: One-Hour Hemyc Electrical Raceway Fire Barrier System, Fire Areas ETN-4 and PAB-2 for Indian Point Nuclear Generating Unit No. 3 (TAC No. MD2671)"

7. NRC letter dated September 28, 2007, J.P. Boska to M.A. Balduzzi, "Indian Point Nuclear Generating Unit No.3 - Exemption from the Requirements of 10 CFR Part 50, Appendix R (TAC No. MD2671)"