NL-15-012, Request for Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

Request for Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events

ML15034A506
Person / Time
Site:	Indian Point
Issue date:	01/28/2015
From:	Coyle L Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, NL-15-012, TAC MF0745
Download: ML15034A506 (7)

Text

Entergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-15-012 January 28, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

REFERENCES:

Entergy's Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (TAC No.

MF0745)

Indian Point Unit Numbers 3 Docket No. 50-286 License No. DPR-64

1.

NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 2..

Entergy letter to NRC (NL-13-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2013

3.

Westinghouse Nuclear Safety Advisory Letter NSAL 14-1, Rev 0 and Rev 1 "Impact of Reactor Coolant Pump No. 1 Seal Leakoff Piping on Reactor Coolant Pump Seal Leakage During a Loss of All Seal Cooling," dated February 10 and September 15, 2014

4.

Westinghouse Report PWROG-14015-P, Rev. 1, "No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power," September 19, 2014

5.

WCAP-1 7601 -P, Rev. 1, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock and Wilcox NSSS Designs," dated August 2012

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Order EA 049 (Reference 1) to Entergy Nuclear Operations, Inc. (Entergy). NRC Order EA-12-049 was immediately effective and directed Entergy to develop, implement, and maintain

NL-15-012 Docket 50-286 Page 2 of 3 guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. This letter transmits a request for relaxation from the requirements of NRC Order EA-12-049 for Indian Point Unit 3.

As described in the Overall Integrated Plan (Reference 2), the SGS mitigation strategies are based on generic Westinghouse reactor coolant pump (RCP) seal leakage rates. In response to Westinghouse Nuclear Safety Advisory Letter (NSAL) 14-1 (Reference 3),

Westinghouse has re-calculated generic leakage rates applicable to IP3 and determined that they are not enveloped by the generic leakage values (Reference 4). Entergy has evaluated options to reduce RCP seal leakage rates, which are part of the technical bases for demonstrating SGS compliance with the requirements of NRC Order EA 049. The current schedule requirement for IP3 implementation of NRC Order EA-12-049 is prior to restart from refueling outage (3R1 8) in the spring of 2015. The requested relaxation would defer full implementation of NRC Order EA-12-049 by one refueling outage, i.e., prior to restart from 3R19 in Spring 2017.

Entergy is currently planning to install an orifice on the seal leak off line in 3R18 that would prevent leakage rates from exceeding the generic leakage values assumed in Reference 5. The requested relaxation will not be required if implementation of Order EA-12-049 is achieved with the successful completion of the modification. If this modification is not completed, the relaxation would be required to allow Entergy to license and implement the approach used to bring IP3 into compliance during 3R19.

In accordance with the guidance of Section IV.B.1 of NRC Order EA-12-049, Entergy requests the Director, Office of Nuclear Reactor Regulation to relax the schedule requirement for full implementation prescribed by Condition IV.A.2 of the Order for the reasons provided in Attachment to this letter. Entergy considers that the requested relaxation would constitute a change in the implementation schedule requirements~of NRC Order EA-12-049 for IP3 and would be required by March 10, 2015 to allow continued compliance with the order.

This letter contains no new regulatory commitments. Should you have any questions regarding this submittal, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct; executed on January X6, 2015.

Sincerely, 7,

Isp

Attachment:

Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"

NL-15-012 Docket 50-286 Page 3 of 3 cc:

Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 Mr. John Boska, Senior Project Manager, NRC NRR DORL NRC Resident Inspectors Office Mr. John B. Rhodes., President and CEO, NYSERDA Ms. Bridget Frymire, New York State

ATTACHMENT TO NL-15-012 REQUEST FOR RELAXATION FROM NRC ORDER EA-12-049, "ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS" ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

NL-15-012 Docket 50-286 Attachment Page 1 of 3 Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" Relaxation Request Based on the guidance of Section IV of NRC Order EA-12-049 (Reference 1, references at the end of this request) Entergy hereby requests relaxation of the Order requirement for Indian Point (IP) Unit 3 to complete full implementation by no later than two refueling cycles after submittal of the overall integrated plan required by Condition C.1.a of the Order, or December 31, 2016, whichever comes first.

Order Requirement from Which Relaxation is Requested Condition IV.A.2 of NRC Order EA-12-049 requires full implementation of the Order requirements by no later than two refueling cycles after submittal of the overall integrated plan required by Condition C.1.a, or December 31, 2016, whichever comes first. For IP3, the current requirement for full implementation of NRC Order EA-12-049 is prior to restart from Refueling Outage 18 (3R1 8) in Spring 2015.

Condition IV.B.1 of NRC Order EA-12-049 required all Licensees to notify the Commission, within 20 days of the order, if they are unable to comply with any of the requirements described in Attachment 2 or 3 and to provide justification for seeking relief from any requirement. Entergy made no such request.

Entergy is now requesting relaxation of Condition IV.A.2 for IP3, to defer full implementation with the Order until prior to restart from the 3R19 outage in Spring 2017.

The deferral is for the reactor coolant pump (RCP) seal leak off compliance.

Justification for Relaxation Request As described in the IP3 Overall Integrated Plan (Reference 2) for compliance with NRC Order EA-12-049, the mitigation strategies depend on generic evaluations in WCAP-17601 (Reference 3) that apply to Westinghouse four loop pressurized water reactor designs. A maximum RCP seal leakage rate of 21 gpm per pump is one of the WCAP-17601 assumptions that was used in development of the IP3 mitigation strategies.

Subsequent Westinghouse evaluations (Reference 4) of RCP seal leakage in response to Nuclear Safety Advisory Letter (NSAL) 14-1 (Reference 5), indicate that the generic leakage rates in WCAP-17601 do not envelope calculated leakage rates applicable to the IP3 design.

Entergy has proposed options to the NRC staff to reduce RCP seal leakage to support the technical bases of the mitigation strategies, including plant modifications to increase the seal leak off line resistance:

Option 1 was the throttling of existing valves in the number 1 seal leak off to limit the potential leak off. The NRC has concerns with that option that could not be addressed in the 3R1 8 timeframe with assurance of success if it was

NL-15-012 Docket 50-286 Attachment Page 2 of 3 implemented. That option was pursued until the Audit of October 27 to 30, 2014.

At that time the NRC indicated that there were issues with the throttling valve requiring additional information to try to resolve. The use of orifices is under review with no specific issues at this time.

Option 2 was the installation of orifices in the number 1 RCP seal leak off line to limit the leakage. Following the Audit, Entergy initiated a modification to install the orifices. The current schedule for that modification is:

January 7, 2015 - Modification 10% status review meeting January 9, 2015 - Westinghouse design input January 23, 2015 - Westinghouse impact evaluation January 27, 2015 - Modification 50% status review meeting February 12, 2015 - Modification 90% status review meeting February 18, 2015 - EQRT complete February 19, 2015 - Engineering Change approved March 15, 2015 - Westinghouse basis calculation The justification for the relaxation request is as follows:

1. Entergy is making good faith efforts to address the issue of RCP seal line leakage through a design modification and will only require the relaxation if efforts to implement the design modification are not successful. This would affect the ability to fully implement the requirements of Order EA-1 2-049 by the end of 3RF018 (assuming the final NRC position on the Westinghouse analyses accepts the design).

2. The proposed schedule relaxation would be until the 3R19 outage in the Spring of 2017. This date is only about three months beyond the December 31, 2016 date that the order required as the latest date for full implementation. Based on current regulatory requirements and plant capabilities, a sequence of events similar to those encountered at the Fukushima Dai-ichi station is considered to be unlikely to occur in the United States. Therefore, the proposed schedule relaxation for full implementation of NRC Order EA-1 2-049 does not adversely affect nuclear safety or involve any significant increase in risk.

3. The Westinghouse NASL 14-1 (Rev 0) was not issued until February 2014 and was not foreseen when the NRC Order EA-12-049 was issued. It is, therefore, an unforeseen development that it was not feasible to address prior to the IP3 required implementation date. The NASL 14-1 (Rev 2) issued in September indicates new design details that could result in higher leakage and issues with the manner seal leakage is calculated. This indicates that this issue is still evolving.

Conclusion Full compliance with the mitigation strategy implementation schedule requirements of NRC Order EA-12-049 at IP3 would result in hardship or unusual difficulty

NL-15-012 Docket 50-286 Attachment Page 3 of 3 without a compensating increase in the level of safety. Therefore, in accordance with the guidance of Section IV of NRC Order EA-12-049, Entergy requests relaxation of the schedule requirement described in Condition IV.A.2 of NRC Order EA-12-049, to allow full implementation of NRC Order EA-12-049 to be completed prior to restart from IP3 Refueling Outage 19 in Spring 2017 if good faith efforts to install a modification in IP3 Refueling Outage 18 are not successful.

References

1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events," dated March 12, 2012

2. Entergy letter to NRC (NL-13-042), Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013

3. Westinghouse Report WCAP-17601-P, Revision 0, "Reactor Coolant System Response to the Extended Loss of AC Power Event for Westinghouse, Combustion Engineering and Babcock & Wilcox NSSS Designs," dated August 2012

4.

Westinghouse Report PWROG-14015-P, Rev. 1, No. 1 Seal Flow Rate for Westinghouse Reactor Coolant Pumps Following Loss of All AC Power, September 19, 2014

5. Westinghouse Nuclear Safety Advisory Letter NSAL 14-1, Rev 1, "Impact of Reactor Coolant Pump No. 1 Seal Leak off Piping on Reactor Coolant Pump Seal Leakage During a Loss of All Seal Cooling," dated September 15, 2014.