ML13184A082

Summary of Conference Call Held on July 2, 2013, Between the NRC and Entergy Nuclear Operations, Inc., Concerning May 6, 2013 Letter Regarding Changes to Metal Enclosed Bus Inspection Program for IP Nuclear Generating Units 2 and 3

ML13184A082
Person / Time
Site:	Indian Point
Issue date:	09/23/2013
From:	Kimberly Green Division of License Renewal
To:	Entergy Nuclear Operations
Green K, 415-1627
References
Download: ML13184A082 (6)

Text

LICENSEE:

FACILITY:

SUBJECT:

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 September 23, 2013 Entergy Nuclear Operations, Inc. Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF CONFERENCE CALL HELD ON JULY 2, 2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING MAY 6, 2013 LETTER REGARDING CHANGES TO METAL ENCLOSED BUS INSPECTION PROGRAM FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. held a telephone conference call on July 2, 2013, to discuss and clarify the staff's draft request for additional information (O-RAl) concerning changes made to the Metal Enclosed Bus (MEB) Inspection Program in the Indian Point Nuclear Generating Unit Nos. 2 and 3, license renewal application.

The telephone conference call was useful in clarifying the intent of the staff's O-RAl. Enclosure 1 provides a listing of the participants and Enclosure 2 contains the O-RAl item discussed with the applicant, including a brief description on the status of the item. The applicant had an opportunity to comment on this summary. Docket Nos. 50-247 and 50-286

Enclosures:

1. List of Participants 2 D-RAIItem cc w/encl Listserv '* ... (I /)('"! :1 ,,_..... r , , ,, , .... , 1 u , I ) ' I Kimberly J. Green, Sr. Mechanical Eng1neer Aging Management of Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation September 23, 2013 LICENSEE*

Entergy Nuclear Operations, Inc. FACILITY:

Indian Point Nuclear Generating Unit Nos. 2 and 3

SUMMARY

OF CONFERENCE CALL HELD ON JULY 2, 2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC, CONCERNING MAY 6, 2013 LETTER REGARDING CHANGES TO METAL ENCLOSED BUS INSPECTION PROGRAM FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. held a telephone conference call on July 2, 2013, to discuss and clarify the staff's draft request for additional information (D-RAI) concerning changes made to the Metal Enclosed Bus (MEB) Inspection Program in the Indian Point Nuclear Generating Unit Nos. 2 and 3, license renewal application.

The telephone conference call was useful in clarifying the intent of the staff's D-RAI. Enclosure 1 provides a listing of the participants and Enclosure 2 contains the D-RA1 item discussed with the applicant, including a brief description on the status of the item. The applicant had an opportunity to comment on this summary. Docket Nos. 50-247 and 50-286

Enclosures:

1. List of Participants

2. D-RAI Item cc w/encl: Listserv DISTRIBUTION:

See next page IRA! Kimberly J. Green, Sr. Mechanical Engineer Aging Management of Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation ADAMS Accession No* ML13184A082 " *concurrence via e-mail OFFICE LA: DLRIRPB1*

PM DLRIRAPB BC RPB1:DLR PM: DLRIRAPB NAME YEdmonds KGreen YDiaz KGreen DATE 7110113 9120/13 9122113 9123113 OFFICIAL RECORD COPY SUBJECT

SUMMARY

OF CONFERENCE CALL HELD ON JULY 2, 2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING MAY 6, 2013 LETTER REGARDING CHANGES TO METAL ENCLOSED BUS INSPECTION PROGRAM FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DISTRIBUTION:

HARDCOPY:

DLR RF E-MAIL: PUBLIC RidsNrrDir Resource RidsNrrDirRpb1 Resource RidsNrrDirRpb2 Resource RidsNrrDirRarb Resource RidsNrrDirRasb Resource RidsNrrDirRapb Resource RidsNrrDirRerb Resource RidsNrrDirRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMaiiCenter Resource YDiaz KGreen DNguyen CDoutt DPickett STurk, OGC BMizuno, OGC SBurnell.

OPA DMclntyre, OPA EDacus, OCA NSheehan, Rl OPA GMeyer, Rl JTrapp, Rl DJackson, Rl DScrenci, Rl OPA PCataldo, Rl NMcNamara, Rl SWelling, Rl KDunham. Rl MCatts, Rl MHalter, Rl SStewart, Rl APatel, Rl TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS JULY22013 PARTICIPANTS:

AFFILIATIONS:

Kim Green U.S. Nuclear Regulatory Commission (NRC) Due Nguyen NRC Cliff Doutt NRC Roger Waters Entergy Nuclear Operations, Inc. (Entergy}

Charlie Caputo Entergy John Curry Entergy Dave Lach Entergy Alan Cox Entergy Roger Rucker Entergy Steve Manzione Entergy Peter Guglielmino Entergy Jeff Cottam Entergy ENCLOSURE 1

DRAFT REQUEST FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION JULY 2, 2013 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. held a telephone conference call on July 2, 2013, to discuss and clarify the following draft request for additional information (D-RAI) concerning recent changes to the Metal Enclosed Bus Inspection Program in the Indian Point Nuclear Generating Unit Nos. 2 and 3 license renewal application (LRA). D-RAI3.0.3.2.11-1

Background:

On April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy or the applicant) applied for renewal of the operating licenses for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3). The Metal Enclosed Bus (MEB) Inspection Program is described in license renewal application (LRA) Section 8.1.20 and includes an enhancement to revise appropriate procedures to add the 480V MEB associated with Substation A to the scope of the program. This enhancement is also reflected in the LRA Updated Final Safety Evaluation Report (UFSAR) Section A.2.1.19.

Entergy considered this MEB to be within the scope of license renewal because it provides ac power to the IP2 diesel fire pump (DFP). By letter dated May 6, 2013, Entergy stated that it is making a change to the LRA regarding the MEB Inspection Program and the associated regulatory commitments.

Specifically, based on a recent evaluation, Entergy determined that the 480V MEB is not used for starting the OFP, but it is used to maintain batteries in a charged state, which in turn provide de power for starting the OFP and power instrumentation.

Entergy stated that any loss of the 480V MEB associated with Substation A would initiate an automatic start of the OFP via the batteries.

Therefore, the 480V MEB associated with Substation A does not perform a license renewal intended function and thus, Entergy is removing the 480V MEB from the scope of program. Issue: Title 10 of the Code of Federal Regulations 10 CFR 54.4(a)(3) requires, in part, that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulation for fire protection (10 CFR 50.48) are within the scope of license renewal. This is iterated in Section 2.1.3.1.3 of Revision 1, "Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants," which includes the following example: ... if an NSR diesel generator is required for safe shutdown under the fire protection plan, the diesel generator and all SSCs specifically relied upon for that generator to comply with NRC regulations shall be included within the scope of license renewal under 10 CFR 544(a)(3).

Such SSCs may include, but should not be limited to, the cooling water system or systems relied upon for operability, ENCLOSURE 2 the diesel support pedestal, and any applicable power supply cable specifically relied upon for safe shutdown in the event of a fire. The DFP is relied upon to demonstrate compliance with the Commission's regulation for fire protection, and therefore, is within the scope of license renewal. The staff considers the MEB associated with 480V Substation A to be within the scope of license renewal because it provides ac power to the chargers to maintain the DFP batteries at full charge. The fully charged batteries will be able to start the DFP during the fire events. It appears that if the 480V MEB is not part of an aging management program, the batteries which start the DFP may become depleted and unable to perform their intended function.

Request: Provide a technical justification for why the 480V MEB Substation A is not relied upon for the DFP to demonstrate compliance with NRC regulations.

Discussion During the call, the staff explained that it does not have all current licensing basis documents that describe the function and operation of the diesel fire pump and associated support equipment.

Although Entergy explained in its May 6, 2013 letter that failure of the 480V Substation A causes the DFP to automatically start, the staff does not have enough information to understand how that occurs, the details of charging and maintenance of the batteries, or how the applicant knows if the batteries are not fully charged. Therefore, the staff agreed to revise the request as noted below. Request: Provide a technical justification for why the 480V MEB Substation A is not relied upon for the DFP to demonstrate compliance with NRC regulations.

Please refer to any applicable documents or statements in your current licensing basis to support your justification.