JAFP-14-0145, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML14353A258
Person / Time
Site:	FitzPatrick
Issue date:	12/19/2014
From:	Brian Sullivan Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Division of Operating Reactor Licensing
References
JAFP-14-0145
Download: ML14353A258 (4)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-14-0145 December 19, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, ML12053A340, dated March 12, 2012

2. Entergy letter, Flooding Walkdown Report - Entergys Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, JAFP-12-0135, dated November 27, 2012

3. Entergy Letter, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments, dated January 30, 2014, JAFP-14-0010

4. NEI letter, Generic Template for Closure of Flooding Design Basis Walkdown Restricted Access Items, APC 13-13, dated May 13, 2013

5. Entergy letter, Extension to Commitment in Flooding Walkdown Report for Restricted Access Equipment, JAFP-14-0121, dated October 30, 2014

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 4 of Reference 1 requested that each licensee perform flood protection walkdowns and report the results. James A. FitzPatrick Nuclear Power Plant (JAF) submitted a Flooding Walkdown Report by Reference 2.

JAFP-14-0145 Page 2 of 2 Reference 2 identified items where restricted access prevented walkdown of certain flood protection features. Walkdowns of the restricted access items have been completed with the exception of the two perimeter drain pumps which have been reclassified as inaccessible features per the guidance provided in NEI 12-07 (Rev. 0-A) "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" section 3.6.

The results are provided in the attachment to this letter. This submittal closes all the open items identified in Reference 2.

The attachment to this letter provides a list of the restricted access items inspected as well as those items reclassified as inaccessible, their respective disposition, and any action planned or taken. As a result of the inspections:

• There are no additional deficiencies found in the supplemental walkdown.

• No temporary measures were required as a result of the completed inspections.

• The restricted access item inspected was within the plant maintenance and monitoring programs.

• Available physical margin (APMs) were evaluated and documented in the walkdown record forms for each applicable item inspected in accordance with NEI 12-07.

• Two of the restricted access items were reclassified as inaccessible.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 19th day of December, 2014.

Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/mh

Attachment:

Flooding Walkdown Report Open Items cc: NRC Regional Administrator NRC Resident Inspector Mr. Douglas Pickett, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. John B. Rhodes, President and CEO, NYSERDA

JAFP-14-0145 Attachment Flooding Walkdown Report Open Items (1 Page)

Attachment JAFP-14-0145 Flooding Walkdown Report Open Items Description of Feature Deficiencies Deficiency Actions Taken or Planned Inaccessible Description Identified (yes/no)

(yes/no)

Description Electrical Manhole #2 No None. EC 51443 documents changes in EN-DC-170, No (MH-2) Att. 9.3 Flooding Walkdown Record form for Electrical Manhole #2. The purpose of the revision is to make administrative changes to be consistent with Reference 3.

Rx Bldg. Perimeter Drain No None. Pumps monitoring is performed under SP-01.11; Yes, This walkdown item has been Sump Pump A (75P-4A) the 12-dia. perimeter drains were inspected in reclassified as inaccessible versus a 2010. Video was reviewed for drain pipe previous classification of restricted degradation and determined to be acceptable access. The pump is located in 3 x 4 (JAF-RPT-12-00016, Section 7.1.3). sump pit which is only accessible by a 30 dia. x 36 vert. conc. shaft which extends EC 51443 documents that the pump has been downward from the bottom of a surface reclassified as inaccessible versus a restricted manhole; the pump is removed from the access feature. It also provides basis for sump pit and brought to the surface for reasonable assurance that pump 75P-4A will maintenance activities.

perform its external flood protection / mitigation function.

Rx Bldg. Perimeter Drain No None. Pumps monitoring is performed under SP-01.11; Yes, This walkdown item has been Sump Pump B (75P-4B) the 12-dia. perimeter drains were videoed in reclassified as inaccessible versus a 2010. Video was reviewed for drain pipe previous classification of restricted degradation and determined to be acceptable access. The pump is located in 3 x 4 (JAF-RPT-12-00016, Section 7.1.3). sump pit which is only accessible by a 30 dia. x 36 vert. conc. shaft which extends EC 51443 documents that the pump has been downward from the bottom of a surface reclassified as inaccessible versus a restricted manhole; the pump is removed from the access feature. It also provides basis for sump pit and brought to the surface for reasonable assurance that pump 75P-4B will maintenance activities.

perform its external flood protection / mitigation function.

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Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Brian R. Sullivan Site Vice President - JAF JAFP-14-0145 December 19, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendations 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 License No. DPR-059

Reference:

1. NRC letter, Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, ML12053A340, dated March 12, 2012

2. Entergy letter, Flooding Walkdown Report - Entergys Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.3 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, JAFP-12-0135, dated November 27, 2012

3. Entergy Letter, Update to Response to NRC 10 CFR 50.54(f) Request for Information Regarding Near-Term Task Force Recommendation 2.3, Flooding - Review of Available Physical Margin (APM) Assessments, dated January 30, 2014, JAFP-14-0010

4. NEI letter, Generic Template for Closure of Flooding Design Basis Walkdown Restricted Access Items, APC 13-13, dated May 13, 2013

5. Entergy letter, Extension to Commitment in Flooding Walkdown Report for Restricted Access Equipment, JAFP-14-0121, dated October 30, 2014

Dear Sir or Madam:

On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 4 of Reference 1 requested that each licensee perform flood protection walkdowns and report the results. James A. FitzPatrick Nuclear Power Plant (JAF) submitted a Flooding Walkdown Report by Reference 2.

JAFP-14-0145 Page 2 of 2 Reference 2 identified items where restricted access prevented walkdown of certain flood protection features. Walkdowns of the restricted access items have been completed with the exception of the two perimeter drain pumps which have been reclassified as inaccessible features per the guidance provided in NEI 12-07 (Rev. 0-A) "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" section 3.6.

The results are provided in the attachment to this letter. This submittal closes all the open items identified in Reference 2.

The attachment to this letter provides a list of the restricted access items inspected as well as those items reclassified as inaccessible, their respective disposition, and any action planned or taken. As a result of the inspections:

• There are no additional deficiencies found in the supplemental walkdown.

• No temporary measures were required as a result of the completed inspections.

• The restricted access item inspected was within the plant maintenance and monitoring programs.

• Available physical margin (APMs) were evaluated and documented in the walkdown record forms for each applicable item inspected in accordance with NEI 12-07.

• Two of the restricted access items were reclassified as inaccessible.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact Chris M. Adner, Regulatory Assurance Manager, at 315-349-6766.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 19th day of December, 2014.

Sincerely, Brian R. Sullivan Site Vice President BRS/CMA/mh

Attachment:

Flooding Walkdown Report Open Items cc: NRC Regional Administrator NRC Resident Inspector Mr. Douglas Pickett, Senior Project Manager Ms. Bridget Frymire, NYSPSC Mr. John B. Rhodes, President and CEO, NYSERDA

JAFP-14-0145 Attachment Flooding Walkdown Report Open Items (1 Page)

Attachment JAFP-14-0145 Flooding Walkdown Report Open Items Description of Feature Deficiencies Deficiency Actions Taken or Planned Inaccessible Description Identified (yes/no)

(yes/no)

Description Electrical Manhole #2 No None. EC 51443 documents changes in EN-DC-170, No (MH-2) Att. 9.3 Flooding Walkdown Record form for Electrical Manhole #2. The purpose of the revision is to make administrative changes to be consistent with Reference 3.

Rx Bldg. Perimeter Drain No None. Pumps monitoring is performed under SP-01.11; Yes, This walkdown item has been Sump Pump A (75P-4A) the 12-dia. perimeter drains were inspected in reclassified as inaccessible versus a 2010. Video was reviewed for drain pipe previous classification of restricted degradation and determined to be acceptable access. The pump is located in 3 x 4 (JAF-RPT-12-00016, Section 7.1.3). sump pit which is only accessible by a 30 dia. x 36 vert. conc. shaft which extends EC 51443 documents that the pump has been downward from the bottom of a surface reclassified as inaccessible versus a restricted manhole; the pump is removed from the access feature. It also provides basis for sump pit and brought to the surface for reasonable assurance that pump 75P-4A will maintenance activities.

perform its external flood protection / mitigation function.

Rx Bldg. Perimeter Drain No None. Pumps monitoring is performed under SP-01.11; Yes, This walkdown item has been Sump Pump B (75P-4B) the 12-dia. perimeter drains were videoed in reclassified as inaccessible versus a 2010. Video was reviewed for drain pipe previous classification of restricted degradation and determined to be acceptable access. The pump is located in 3 x 4 (JAF-RPT-12-00016, Section 7.1.3). sump pit which is only accessible by a 30 dia. x 36 vert. conc. shaft which extends EC 51443 documents that the pump has been downward from the bottom of a surface reclassified as inaccessible versus a restricted manhole; the pump is removed from the access feature. It also provides basis for sump pit and brought to the surface for reasonable assurance that pump 75P-4B will maintenance activities.

perform its external flood protection / mitigation function.

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