NL-20-060, Status of Remaining Actions for Generic Letter 2004-02
| ML20224A391 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 08/11/2020 |
| From: | Gaston R Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GL-2004-02, NL-20-060 | |
| Download: ML20224A391 (3) | |
Text
Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing
10 CFR 50.82(a)(1)(i) 10 CFR 50.4(b)(8)
NL-20-060 August 11, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Status of Remaining Actions for Generic Letter 2004-02 Indian Point Nuclear Generating Unit Nos. 2 and 3 NRC Docket Nos. 50-247 and 50-286 Renewed Facility Operating License Nos. DPR-26 and DPR-64 In Reference 1, Entergy Nuclear Operations, Inc. (Entergy) certified that, in accordance with 10 CFR 50.82 (§50.82)(a)(1)(i) and §50.4(b)(8), it plans to permanently cease power operations at Indian Point Nuclear Generating Unit No. 2 (IP2) by April 30, 2020 and IP3 by April 30, 2021.
In Reference 2, Entergy certified that in accordance with §50.82(a)(1)(i), power operations ceased at IP2 on April 30, 2020. In addition, in accordance with §50.82(a)(1)(ii), Entergy also certified that the fuel was permanently removed from the IP2 reactor vessel and placed in the IP2 spent fuel pool on May 12, 2020. Entergy understands and acknowledges that upon docketing of these certifications, the IP2 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. Considering that
§50.82(a)(1)(i), and §5050.82(a)(1)(ii) have already been docketed for IP2, there is no longer a concern for sump clogging or in-vessel fuel heat-up due to debris deposition at IP2 While Entergy has not completed the remaining actions to close Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors," for IP3, Entergy has completed extensive analyses, testing, and modifications to substantially improve sump performance during a postulated design basis loss-of-coolant accident (LOCA) at IP3. The modifications include installation of passive containment sump strainer assemblies for segregating post-LOCA generated debris from the containment sump envelope, and installation of passive debris screens on containment sump vent lines to mitigate post-LOCA generated debris entry into the containment sump envelope.
NL-20-060 Page 2 of 3
Procedural controls, specification requirements, and containment and equipment inspections have been implemented to limit and mitigate debris generation and chemical effects that may impact sump strainer performance following a LOCA. In addition, operators have received training regarding the mechanisms and potential consequences of sump clogging.
Actions at IP3 with respect to post-LOCA in-vessel fibrous debris are deemed to be unnecessary since the in-vessel debris loads at IP3 are relatively low. The IP3 debris quantities determined for both the Hot Leg and Cold Leg breaks are less than the PWROG acceptance guidelines associated with the IP3 design. As a result, for the one remaining open GL 2004-02 concern (i.e., in-vessel debris), IP3 is in a low safety risk situation wherein any action in the remaining months of operation is not regarded as essential or safety / cost beneficial.
Considering the schedule uncertainties that exist for resolution of GL 2004-02: the remaining work to complete analyses; testing; license amendment request submittal, NRC review, and license amendment issuance; modification installation; and the Entergy plan to permanently cease power operations at IP3, there is insufficient time available for the remaining GL 2004-02 closure efforts to result in an appreciable safety benefit for IP3 prior to the permanent shutdown date on April 30, 2021. In addition, considering that the GL 2004-02 closure efforts are no longer applicable to IP2, the purpose of this letter is to provide notification that Entergy does not plan to take additional actions for GL 2004-02 closure at IP2 and IP3.
Accordingly, this letter provides notification of the cancellation of the following regulatory commitment contained in Reference 4:
Complete the analyses of the susceptibility of the ECCS and CSS recirculation functions for Indian Point Unit 2 and Unit 3 to the adverse effects of post-accident debris blockage and operations with debris-laden fluids identified in Generic Letter 2004-02.
If you have any questions regarding this submittal, please contact Ms. Mahvash Mirzai, Manager, Regulatory Assurance, at 914-254-7714. There are no new regulatory commitments made in this letter.
Respectfully, Ron Gaston RWG/gd
NL-20-060 Page 3 of 3
References:
- 1)
Entergy Nuclear Operations, Inc. (Entergy) letter to U.S. Nuclear Regulatory Commission (NRC), "Notification of Permanent Cessation of Power Operations," (Letter NL-17-021) (ADAMS Accession No. ML17044A004), dated February 8, 2017
- 2)
Entergy letter to NRC, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel,"
(Letter NL-20-042) (ADAMS Accession No. ML20133J902), dated May 12, 2020
- 3)
NRC letter, "Staff Re-evaluation of Closure Path for Generic Safety Issues 191 and Generic Letter 2004-04," (ADAMS Accession No. ML18311A297), dated November 30, 2018
- 4)
Entergy letter NRC, "90-Day Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," (Letter NL 023) (ADAMS Accession No. ML050660254), dated February 28, 2005 cc:
NRC Senior Project Manager, NRC NRR DORL Regional Administrator, NRC Region I NRC Senior Resident Inspector, Indian Point Energy Center President and CEO, NYSERDA New York State (NYS) Public Service Commission