NL-19-079, 50.59(d)(2) Summary Report of Changes, Tests and Experiments

50.59(d)(2) Summary Report of Changes, Tests and Experiments

ML19274B203
Person / Time
Site:	Indian Point
Issue date:	09/26/2019
From:	Vitale A Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-19-079
Download: ML19274B203 (4)

Text

' ..

,.~Entergy; . Entergy Nyclffr Operations, Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249 Inc.

Tel 914 254 6700 Anthony J. Vitale Srte Vice President 10 CFR 50.59(d)(2)

NL-19-079 September 26, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738

Subject:

50.59(d)(2) Summary Report of Changes, Tests and Experiments Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 License No. DPR-64

Dear Sir or Madam:

Pursuant to 10 CFR 50.59(d)(2), Entergy Nuclear Operations, Inc. (Entergy) herein submits in the Attachment a 50.59 summary report of the changes, tests and experiments implemented at Indian Point Unit No. 3 between May 19, 2017 and April 9, 2019, and/or utilized in support of the UFSAR update. The 50.59 Evaluations set forth in the report represent the changes in the facilities, changes in procedures, or tests and experiments implemented pursuant to 10 CFR 50.59.,

There are r10 new commitments made by Entergy in this submittal. If you have any questions or require additional information, please contact Ms. Mahvash Mirzai, Acting Regulatory Assurance Manager at (914) 254-7714.

Sincerely, AJV/gd

Attachment:

50 59(d)(2) Summary Report of Changes. Tests and Experiments cc: NRG Region I Regional Administrator NRC Senior Project Manager, NRA DORL NRC Senior Resident Inspector New York State Department of Public Service President and CEO, NYSERDA

Attachment to NL-19-079 50.59(d)(2) Summary Report of Changes, Tests and Experiments ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 Renewed License No DPR-64

NL-19-077 Attachment 1 Page 1 of 2 50.59(d)(2) Summary Report of Changes, Tests and Experiments 50.59 Evaluation No. Rev.No TITLE Operation of Auxiliary Feedwater System with CT-19-3001-00 -EVAL 0 82-7 Throttled Open up to 1O gpm without a Dedicated Operator Brief Description of the Change, Test or Experiment:

Due to sodium incursion into the Condensate Storage Tank (CST) from the city water system from seat leakage past closed valves PCV-1189 (33 AFWP City Water Makeup Valve) and BFD-FCV-1123 (33 AFWP Recirculation Control Valve), efforts have been ongoing to remove the sodium by flushing and sampling 33 AFWP suction piping while overflowing the CST with 200 gpm of makeup and cleaning up the CST by recirculating water through the Suez cleanuptskid.

The activity of flushing water from 33 AFWP suction Jeader 1s directed from system operating procedure 3-SOP-AFW-002 Section 4.2, "Flush and Sample ABFP Suction Piping". The system operating procedure requires a dedicated operator to be present inside the AFWP Building during flushing of any AFWP suction header to immediately close the drain valve if it becomes necessary for the AFW system to perform its design basis function.

To allow 33 Auxiliary Feedwater Pump (AFWP) Suction Header Drain Valve CT-82-7 to be throttled open up to 1O gpm for continuous flushing without a dedicated operator to perform mitigating actions as required by 3-SOP-AFW-002 with the plant operating at mode 4 or above.

CT-82-7 is a 1" normally closed manual drain valve. This valve is required to maintain pressure boundary integrity in order to ensure adequate inventory In the CST and adequate flow to 33 AFWP.

Summary of the 10 CFR 50.59 Evaluation The condensate storage tank (CST) provides a passive flow of water by gravity to the AFW System. The minimum Technical Specification required CST inventory during operation is 360,000 gallons, which is sufficient to hold the plant at hot shutdown for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following a trip from full power. The water from the CST is used by the AFW system to remove decay and sensible heat from Reactor Coolant System via the steam generators. CST elevation 1s such that suff1c1ent net positive suction head (NPSH) 1s available for the AFW pumps. In addition, an alternate supply of water to the AFW System pumps is provided by a connection to the 1.5-million-gallon City Water Storage Tank (CWST). The CWST maintains a minimum volume of 360,000 gallons of water available 'to provide an alternate water supply to the AFW system.

EC 84031 was developed to provide the work scope for a Temporary Modification to maintain CT-82-7 1n a throttled open pos1t1on without a dedicated operator present inside the AFWP Building. Having the drain valve continuously throttled open without a dedicated operator present inside the AFVVP Building could potentially challenge the Technical Specif1cat1on required volume of water in the CST and the ability of 33 AFW pump to deliver required flow.

/

NL-19-077

• Attachment 1 Page 2 of 2 50.59(d)(2) Summary Report of Changes, Tests and Experiments As an alternative to having a dedicated operator present inside the AFWP Building during the period in which CT-82-7 is open to flush 33 AFWP suction piping, the following compensatory controls have been identified and will be implemented:

1. CT-82-7 will be throttled open to no more than 1O gpm. This will limit the rate of CST inventory depletion and provide operating personnel ample time to Isolate CT-82-7 to ensure the 360,000 gallon minimum volume limit is not challenged.

2. Normal makeup to the CST will be maintained while CT-82-7 is throttled open to ensure that CST water inventory exceeds the 360,000-gallon minimum volume limlt.

1. To further ensure that the 360,000 gallons CST Technical Specification level is protected, the setpoint for the CST Trouble Alarm will be changed from the current setting of 19.77 feet to 20.66 feet and automatic isolation of CT-LCV-1158-1 and CT-LCV-1158-2 will be changed from 18.77 feet to 19.66 feet. This change in setpolnts provides more than 19,000 gallons of additional inventory in the CST. The additional inventory provides enough excess water to not challenge the 360,000 gallons minimum Technical Specification requirement for over 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> even If CST makeup was not available and valve CT-82-7 remained throttled open at 10 gpm. The additional volume protects the required mission time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of inventory for the CST.

4. Operators will verify CT-82-7 is locked or otherwise secured in its preset throttled position once per shift and verify flow rs no greater than 1O gpm every 7 days.

5. Plant operatlons personnel will bl:l briefed on these compensatory controls.