ML071620225

NRC Receipt of Palisades Nuclear Plant Response to Generic Letter 2003-01 Control Room Habitability.

ML071620225
Person / Time
Site:	Palisades
Issue date:	06/28/2007
From:	Mahesh Chawla NRC/NRR/ADRO/DORL/LPLIII-1
To:	Balduzzi M Entergy Nuclear Operations
Chawla M, NRR/DORL, 415-8371
References
TAC MB9833
Download: ML071620225 (5)

Text

June 28, 2007 Mr. Michael Balduzzi Sr. Vice President, Regional Operations NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

PALISADES NUCLEAR PLANT - RESPONSE TO NRC RECEIPT OF GENERIC LETTER 2003-01 CONTROL ROOM HABITABILITY (TAC NO. MB9833)

Dear Mr. Balduzzi:

The transfer of ownership of Palisades Nuclear Plant from Consumers Energy Company (Consumers) to Entergy Nuclear Palisades (ENP) occurred on April 11, 2007. The Nuclear Regulatory Commission acknowledges the receipt of responses from Nuclear Management Company, LLC (NMC) (the former licensee), to Generic Letter (GL) 2003-01 Control Room Habitability dated August 7, 2003 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML032260542); November 25, 2003 (ADAMS Accession No. ML033300162); November 23, 2004 (ADAMS Accession No. ML043420198); July 7, 2005 (ADAMS Accession No. ML051940267); April 10, 2007 (ADAMS Accession No. ML071030336);

and the response from ENP (the current licensee) dated May 3, 2007 (ADAMS Accession No. ML071360054). From hereon, for simplification purpose, these responses will be referred as your responses. This letter provides a status of your response and describes any actions that may be necessary to consider your response to GL 2003-01 complete.

The GL requested that you confirm that your control room meets the applicable habitability regulatory requirements (e.g. General Design Criterion (GDC) 1, 3, 4, 5, and 19, draft GDC, or principal design criteria), with special attention to: (1) determination of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in your design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a); (2) determination that the most limiting unfiltered inleakage is incorporated into you hazardous chemical assessments (GL 2003-01, item 1b); and, (3) determination that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b). The GL further requested information on any compensatory measures in use to demonstrate control room habitability, and plans to retire them (GL 2003-01, Item 2).

You reported the results of ASTM E741(American Society for Testing Materials, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution) tracer gas tests for the Palisades Nuclear Plant control room which is pressurized for accident mitigation.

You determined that the maximum tested value for inleakage into the control room envelope (CRE), was 58 scfm which is less than the value of 85 cfm assumed in your design basis

radiological analyses for control room habitability (CRH). However, in your letter dated September 25, 2006, you submitted a license amendment request (LAR) to adopt full scope application of Alternative Source Term (AST) methodology as described in 10 CFR 50.67 following the guidance of Regulatory Guide 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. Your AST LAR submittal included a maximum allowable control room unfiltered inleakage value of 10 cfm. You stated that full qualification with respect to the GDC requirements could not be demonstrated without plant modifications, including replacing the control room normal air intake and purge isolation dampers, and that those modifications would be completed by the end of your fall 2007 refueling outage. Since this new allowable unfiltered inleakage value is less than the current maximum tested value of 58 cfm, the staff requests that you submit the results of post-modification CRE inleakage testing that you committed to in your AST LAR submittal dated September 25, 2006.

You also provided information that adequately supported a conclusion that the most limiting unfiltered in leakage into the CRE is incorporated into the hazardous chemical assessments, and that reactor control capability is maintained from either the control room or the alternate shutdown panel in the event of smoke.

The GL further requested that you assess your technical specifications (TS) to determine if they verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design basis analysis for CRH, and in light of the demonstrated inadequacy of a delta () P measurement to alone provide such verification (GL 2003-01, Item 1.c) As permitted by the GL, you provided a schedule for revising the surveillance requirement in the TS to reference an acceptable surveillance methodology. In your November 23, 2004, response, you indicated that you would develop TS changes and any associated plant modifications that verify CRH per TS Task Force Traveler 448 (TSTF448). In your May 3, 2007, letter, you stated that Entergy Nuclear Operations will submit a license amendment request based on TSTF-448 at Palisades Nuclear Plant by August 31, 2007.

The information you provided also appeared to support your position that no compensatory measures need to be in place to demonstrate CRH. It also supported the conclusion that you are committed to meet the intent of the GDCs regarding CRH. The information provided above and your commitment to submit a LAR based on TSTF-448 is acceptable for purposes of closing out your response to GL 2003-01.

If you have any questions regarding this correspondence, please contact me at 301-415-8371.

Sincerely,

/RA/

Mahesh Chawla, Project Manager Plant Licensing Branch III-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-255 cc: See next page

ML071620225 OFFICE LPL3-1/PM LPL3-1/LA SCVB/BC PGCB LPL3-1/(A)BC NAME MChawla THarris RDennig CJackson TTate PM for DATE 06/26/07 06/25/07 06/22/07 06/25/07 06/28/07 Palisades Plant cc:

Regional Administrator, Region III Nuclear Operations, Inc.

U.S. Nuclear Regulatory Commission 1340 Echelon Parkway Suite 210 Jackson, MS 39213 2443 Warrenville Road Lisle, IL 60532-4351 Mr. Bruce C. Williams Vice President, Oversight Supervisor Entergy Nuclear Operations, Inc.

Covert Township 1340 Echelon Parkway P. O. Box 35 Jackson, MS 39213 Covert, MI 49043 Mr. Christopher J. Schwarz Office of the Governor Site Vice President P. O. Box 30013 Entergy Nuclear Operations, Inc.

Lansing, MI 48909 Palisades Nuclear Plant 27780 Blue Star Memorial Highway U.S. Nuclear Regulatory Commission Covert, MI 49043 Resident Inspector's Office Palisades Plant General Manager, Plant Operations 27782 Blue Star Memorial Highway Entergy Nuclear Operations, Inc.

Covert, MI 49043 Palisades Nuclear Plant 27780 Blue Star Memorial Highway Michigan Department of Environmental Quality Covert, MI 49043 Waste and Hazardous Materials Division Hazardous Waste and Radiological Mr. Oscar Limpias Protection Section Vice President, Engineering Nuclear Facilities Unit Entergy Nuclear Operations, Inc.

Constitution Hall, Lower-Level North 440 Hamilton Avenue 525 West Allegan Street White Plains, NY 10601 P.O. Box 30241 Lansing, MI 48909-7741 Mr. John F. McCann Director, Nuclear Safety & Licensing Michigan Department of Attorney General Entergy Nuclear Operations, Inc.

Special Litigation Division 440 Hamilton Avenue 525 West Ottawa St. White Plains, NY 10601 Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Ms. Charlene D. Faison Manager, Licensing Mr. Michael R. Kansler Entergy Nuclear Operations, Inc.

President & CEO/CNO 440 Hamilton Avenue Entergy Nuclear Operations, Inc. White Plains, NY 10601 440 Hamilton Avenue White Plains, NY 10601 Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Sr. Vice President, Engineering and Technical Services Entergy

Mr. Ernest J. Harkness Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. William Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Joseph DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Laurie A. Lahti, Manager, Licensing Regulatory Affairs Entergy Nuclear Operations, Inc.

Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 April 20, 2007