NL-14-059, 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

ML14135A290
Person / Time
Site:	Indian Point
Issue date:	04/29/2014
From:	Ventosa J Entergy Nuclear Operations
To:	Document Control Desk
References
NL-14-059
Download: ML14135A290 (14)

Text

Enterqy Nuclear Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President NL-14-059 April 29, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

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-1 3-072 dated May 2, 2013, "Status of Planned Resolutions of the Unapproved III.G.2 Operator Manual Actions"

2. 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"

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

4. 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"

5. 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)"

6. 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-14-059 Docket Nos. 50-247 & 50-286 Page 2 of 3

Dear Sir or Madam:

By letter dated September 17, 2012 (Reference 3), Entergy Nuclear Operations, Inc.

(Entergy) replied to the violations issued in Reference 4 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 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 5 and 6). A revised response to the NOV was transmitted by letter dated December 7, 2012 (Reference 2). By letter dated May 2, 2013, a status update of the Planned Resolutions for the unapproved OMAs was provided. herein provides the status update of the Planned Resolutions for the unapproved OMAs for IP2, which was last provided in Attachment 2 in Reference 2, as follows:

The "Scheduled Completion Date" for OMAs 5, 6, 9, 10, 20 and 21 in all applicable Fire Areas/Fire Zones is now "Completed" (previously "Spring 2014 RFO") as the Planned Resolutions were completed during or following the Spring 2014 RFO. Note that the physical work for resolution of OMA 6 in Fire Zones 6, 7A, 22A and 27A of Fire Area F was completed on April 25 following the Spring 2014 RFO. The full resolution of this OMA required the construction of a fire-rated enclosure around valve LCV-1 12C. Branch Chief John Rogge was notified on March 17, 2014 that this enclosure modification would be completed online following the RFO.

As previously reported in Reference 2, the Planned Resolutions for all of the IP3 unapproved OMAs are complete. Attachment 2 provides the status as previously reported in Reference 2.

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.

Sincerely, JAV/gd

NL-14-059 Docket Nos. 50-247 & 50-286 Page 3 of 3 Attachments:

1. Status of Resolution of Indian Point Unit 2 Unapproved III.G.2 OMAs (Revision of Attachment 1 from Entergy Letter NL-13-072 dated May 2, 2013)

2. Status of Resolution of Indian Point Unit 3 Unapproved III.G.2 OMAs (Attachment 2 from Entergy Letter NL-13-072 dated May 2, 2013) 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. John B. Rhodes, President and CEO, NYSERDA NRC Resident Inspectors

Attachment 1 to NL-14-059 Status of Resolution of Indian Point Unit 2 Unapproved III.G.2 OMAs (Revision of Attachment 1 from Entergy Letter NL-13-072 dated May 2, 2013)

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-14-059 Docket Nos. 50-247 & 50-286 Attachment 1 Page 1 of 4 STATUS OF RESOLUTION OF INDIAN POINT UNIT 2 UNAPPROVED III.G.2 OMAS Fire Area OMA Scheduled IZone No.M Planned Resolution Completion Date F/5A 6 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone and implement modification to establish separate fire area OR implement modification to protect circuits of concern, thereby eliminating this OMA F/6 6 As described for OMA 6, Fire Area F, Fire Zone 5A Completed 7 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA F/7A 6 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA 7 As described for OMA 7, Fire Area F, Fire Zone 6 Completed 20 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA (see Note on page 4) 21 Implement modification to protect circuits of concern, thereby Completed eliminating this OMA (see Note on page 4)

F/22A 6 As described for OMA 6, Fire Area F, Fire Zone 5A Completed F/27A 5 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA 6 As described for OMA 6, Fire Area F, Fire Zone 7A Completed F/33A 5 As described for OMA 5, Fire Area F, Fire Zone 27A Completed F/59A 5 As described for OMA 5, Fire Area F, Fire Zone 27A Completed H/72A 8 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA 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-14-059 Docket Nos. 50-247 & 50-286 Attachment 1 Page 2 of 4 STATUS OF RESOLUTION OF INDIAN POINT UNIT 2 UNAPPROVED III.G.2 MAS FireZone Area OMA No.A Planned Resolution Scheduled Completion Date 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 9,10 Implement modification to protect circuits of concern, thereby Completed eliminating these OMAs 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 Completed H/84A 8 As described for OMA 8, Fire Area H, Fire Zone 72A Completed H/85A 8 As described for OMA 8, Fire Area H, Fire Zone 72A Completed H/87A 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 Completed J/19 11 Reassess electrical circuit and power supply loading analyses and Completed revise Appendix R safe-shutdown analysis and methodology to provide the basis for elimination of this OMA J/25 12 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA J/39A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed J/43A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed 13 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA J/45A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed J/46A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed 13 As described for OMA 13, Fire Area J, Fire Zone 43A Completed J/47A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed J/50A 11 As described for OMA 11, Fire Area J, Fire Zone 19 Completed 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed

NL-14-059 Docket Nos. 50-247 & 50-286 Attachment 1 Page 3 of 4 STATUS OF RESOLUTION OF INDIAN POINT UNIT 2 UNAPPROVED III.G.2 MAS Fire Area OMA Scheduled Zone No.A Planned Resolution Completion Date J/270 12 As described for OMA 12, Fire Area J, Fire Zone 25 Completed 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)

K/65A 14 As described for OMA 14, Fire Area K, Fire Zone 60A Completed 15 As described for OMA 15, Fire Area K, Fire Zone 60A Completed 19 As described for OMA 19, Fire Area K, Fire Zone 60A Completed

NL-14-059 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-14-059 Status of Resolution of Indian Point Unit 3 Unapproved III.G.2 OMAs (Attachment 2 from Entergy Letter NL-13-02 dated May 2, 2013)

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-14-059 Docket Nos. 50-247 & 50-286 Attachment 2 Page 1 of 5 STATUS OF RESOLUTION OF INDIAN POINT UNIT 3 UNAPPROVED III.G.2 OMAS Fire Area / OMA Scheduled Zone NoMA Planned Resolution Completion Date 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 eliminating this OMA ETN-4{1} / Revise Appendix R safe-shutdown analysis and methodology to Completed 60A credit existing separation within the fire area/zone, thereby eliminating this OMA 6 As described for OMA 6, Fire Area ETN-4{1}, Fire Zone 7A Completed 7 As described for OMA 7, Fire Area ETN-4{1}, Fire Zone 7A Completed 8 As described for OMA 8, Fire Area ETN-4{1}, Fire Zone 7A Completed 9 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within and/or independent of the fire area/zone, thereby eliminating this OMA 10 Implement modification to protect circuits of concern for valves Completed LCV-112B and LCV-112C, thereby eliminating this OMA 11 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within the fire area/zone, thereby eliminating this OMA I 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-14-059 Docket Nos. 50-247 & 50-286 Attachment 2 Page 2 of 5 STATUS OF RESOLUTION OF INDIAN POINT UNIT 3 UNAPPROVED III.G.2 OMAS Fire Area I OMA Scheduled Zone No.2 Planned Resolution Completion Date ETN-4{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 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 ETN-4{3} / 14 Revise Appendix R safe-shutdown analysis and methodology to Completed 73A credit existing separation within and/or independent of the fire area/zone, thereby eliminating this OMA 15 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within and/or independent of the fire area/zone, thereby eliminating this OMA 16 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within and/or independent of the fire area/zone, thereby eliminating this OMA 17 Revise Appendix R safe-shutdown analysis and methodology to Completed credit existing separation within and/or independent of the fire area/zone, 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 PAB-2{5} / 19 Revise Appendix R safe-shutdown analysis and methodology to Completed 17A credit equipment train independent of the fire area/zone, thereby eliminating this OMA 20 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA 22 Revise Appendix R safe-shutdown analysis and methodology to Completed credit equipment train independent of the fire area/zone, thereby eliminating this OMA PAB-2{5} / 19 As described for OMA 19, Fire Area PAB-2{5}, Fire Zone 17A Completed 19A 20 As described for OMA 20, Fire Area PAB-2{51, Fire Zone 17A Completed PAB-2{5} / 22 As described for OMA 22, Fire Area PAB-2{5}, Fire Zone 17A Completed 20A PAB-2{5} / 22 As described for OMA 22, Fire Area PAB-2{5}, Fire Zone 17A Completed 27A

NL-14-059 Docket Nos. 50-247 & 50-286 Attachment 2 Page 3 of 5 STATUS OF RESOLUTION OF INDIAN POINT UNIT 3 UNAPPROVED III.G.2 OMAS Area I FireZone OMA Scheduled No.M Planned Resolution Completion Date PAB-2{5} / 22 As described for OMA 22, Fire Area PAB-2{5} / 17A Completed 30A PAB-2{5} I 21 Revise Appendix R safe-shutdown analysis and methodology to Completed 59A credit equipment train independent of the fire area/zone, thereby eliminating this OMA TBL-5 / 37A 25 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 TBL-5 / 38A 25 As described for OMA 25, Fire Area TBL-5, Fire Zone 37A Completed TBL-5 / 43A 25 As described for OMA 25, Fire Area TBL-5, Fire Zone 37A Completed TBL-5 / 44A 25 As described for OMA 25, Fire Area TBL-5, Fire Zone 37A Completed TBL-5 / 52A 23 Implement modification to protect affected circuits in this zone, Completed thereby eliminating this OMA 24 Implement modification to protect affected circuits in this zone, Completed thereby eliminating this OMA TBL-5 / 54A 24 As described for OMA 24, Fire Area TBL-5, Fire Zone 52A Completed 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 YARD-7 I 27 As described for OMA 27, Fire Area YARD-7, Fire Zone 22 Completed 222

NL-14-059 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-112C, and open valve 288 to align charging pump suction path to RWST

NL-14-059 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)