JAFP-08-0092, James A. FitzPatrick, Extension Request for Response to GL 2008-01

James A. FitzPatrick, Extension Request for Response to GL 2008-01

ML082600552
Person / Time
Site:	FitzPatrick
Issue date:	09/12/2008
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-08-001, JAFP-08-0092
Download: ML082600552 (8)

Text

En tergy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.James A. Fitzpatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840 Pete Dietrich Site Vice President

-JAF NPP September 12, 2008 JAFP-08-0092 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Entergy Nuclear Operations, Inc.James A. FitzPatrick Nuclear Power Station License No. DPR-59 Docket No. 50-333 Extension Recluest for Response to GL 2008-01

Reference:

1. Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems", dated January 11,2008 2. NRC Letter Documenting the Results of the Telephone Conversation Between Representatives of the Nuclear Energy Institute (NEI), the Boiling Water Reactor Owners Group (BWROG), the Pressurized Water Reactor Owners Group (PWROG) and the NRC Staff Regarding Generic Letter (GL) 2008-01, dated July 8, 2008

Dear Sir or Madam:

The N-uclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01 (Reference

1) to address the issue of gas accumulation in emergency core cooling, decay heat removal, and containment spray systems. The letter requires licensees to determine whether their licensing basis, design, testing and corrective actions are adequate to ensure that gas accumulation is maintained less than the amount that challenges operability of these systems, and to take appropriate action when conditions adverse to quality are identified.

The GL requested each licensee to submit a written response within 9 months of the date of the GL issuance.

The GL further requested that if the licensee cannot meet the 9-month response date, the licensee shall provide a response within 3 months of the GL describing an alternative course of action and the bases for acceptability.

On July 8, 2008, the NRC issued a letter requiring licensees that submitted a 3-month response to complete all remaining work where an additional refueling outage is necessary, during the first refueling outage that begins after October 11, 2008 (Reference 2).A1-3q4 u R42, JAFP-08-0092 Page 2 of 3 During a teleconference held on August 11, 2008, JAF informed the NRC that the 9-month response date (October 11, 2008) would not provide sufficient time to evaluate areas of the subject systems where worker access would not become available until the September 13, 2008 refueling outage (R18). JAF suggested that an' alternative action plan would be preferred, and that delaying these evaluations until the first refueling outage that begins after October 11, 2008 (R19 in 2010), as allowed.by NRC letter dated July 8, 2008 (Reference 2), would not be necessary.

Accordingly, it was agreed that, 1. As soon as practicable, JAF will submit a request for an extension of time to respond to the GL. The request will propose an alternative action plan based upon the NRC template information received August 20, 2008.2. By October 11, 2008, JAF will submit a 9-month response to the GL as proposed in the alternative action plan.3. By March 31, 2009, JAF will submit a supplemental response to the GL as proposed in the alternative action plan.Attachment 1 contains a description of JAF's proposed Alternative Plan of Action and includes an, explanation for the absence of a 3-month extension request as. provided in the GL, clarification of issues to be discussed in the October 11, 2008 and the March 3-1;., 2009;responses, and the basis. for requesting

'an extension of time.Attachment 2 identifies two (2 new regulatory commitments.

If you have any questions or require additional information, piease contact Mr. Eugene Dorman, Acting Licensing Manager, at 315-349-6810.

I declare under penalty of perjury that the contents of this response are true and correct'to the best of my knowledge and belief. Executed on this 1 2 th day of September, 2008.Pete Dietrich Site Vice President Pd:jm;ci cc: next page JAFP-08-0092 3 of 3 Attachments:

1. Extension Request and Alternative Plan of Action 2. List of Regulatory Commitments cc: Mr. Samuel J. Collins, Regional Administrator U.S. Nuclear Regulatory Commission, Region I 475 Allendale Road King of Prussia, PA 19406-1415 Office of NRC Resident Inspector James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, New York 13093 Mr. Paul Tonko, President New York State Energy Research and Development Authority"17 Col0umbia Circle Albany, New York 12203-6399 Mr. Bhalchandra Vaidya, Project Manager Plant Licensing Branch U.S. Nuclear Regulatory Commission Mail Stop O-8-C2A Washington, DC 20555 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Mr. Paul Eddy-New York State& Department..of Public Services 3 Empire State Plaza Albany, New York 12223-1350 ATTACHMENT 1 to JAFP-08-0092 James A. FitzPatrick Nuclear Power Station Docket No. 50-333 EXTENSION REQUEST AND ALTERNATIVE PLAN OF ACTION ATTACHMENT 1 to JAFP-08-0092 3-Month GL Extension Not Requested Generic Letter (GL) 2008-01 required each licensee to submit a written response within 9 months of the date of issuance.

The GL further required that if the licensee cannot meet the 9-month response date, the licensee must provide a response within 3 months of the GL describing an alternative course of action and the bases for acceptability.

JAF did not submit a 3-month response requesting an alternate course of action, as provided in the GL. JAF initially prepared a limited scope plan in which an evaluation of plant systems not previously evaluated would be compiled with evaluations relating to the management of gas accumulation previously identified and corrected under JAF's corrective action program. System areas not previously evaluated were prioritized based upon known core damage risk estimates.

JAF believed that this limited scope effort combined with the previous evaluations would provide sufficient justification for continued operability of the subject plant systems.In their July 8, 2008 letter (Reference 2), the NRC clarified their expectations regarding the content and timeframe for licensee responses to the GL. The July 8, 2008 letter, along with participation in Nuclear Energy Institute (NEI) meetings, led JAF to conclude that a broader response to the GL would be required, including a thorough evaluation of plant system areas not normally accessible during power operation.

Alternative Plan of Action Phase I. Proposal for 9-Month Response to GL JAF contracted with ABS Consulting, Inc. to perform plant walk-downs and void analyses on the referenced plant systems, except those where pla'nt conditions precluded worker access. These outside-containment walk-downs were completed in August, 2008. ABS Consulting, Inc. will forward.their completed analyses of the walk-downs performed and a preliminary plant review will be conducted in time to support the 9-month GL response date.Therefore, and as agreed during the August 11, 2008 teleconference, JAF will submit a 9-month response to the GL no later than October 11, 2008. This 9-month response will include a description of the results of the systems evaluated prior to the September 13, 2008 refueling outage (R18), a description of the corrective actions required based upon the preliminary plant reviews, a statement regarding which corrective actions have been completed, a schedule for completing any remaining corrective actions and the basis for the schedule.Phase I1. Proposal for Supplement to 9-Month Response to GL During the R1 8 outage JAF will perform the remaining walk-downs of the subject systems areas determined to be inaccessible during Phase 1 of this plan. Therefore, as agreed during the August 11, 2008 teleconference, by March 31, 2009, JAF will submit a supplemental response to the GL including a description of the results of the systems evaluated, a description of the corrective actions required based upon final plant reviews, a statement regarding which corrective actions have been completed, a schedule for completing the remaining corrective actions, the basis for the schedule and the means by which any long term corrective actions will be tracked for implementation.

1 of 2 ATTACHMENT 1 to JAFP-08-0092 Basis for Extension Request The basis for the request for an extension of time derives from the R1 8 refueling outage's proximity to the 9-month GL response due date and the high degree of confidence that the subject systems will perform their intended function in accordance with design basis accident analyses.The 9-month response date of October 11, 2008 leaves JAF insufficient time to perform the required engineering analyses, plant reviews and managerial approvals required pursuant to 10CFR 50.54(f).

JAF recognizes that a realistic time frame upon which a number of plant activities must occur, post-R1 8, extends the development of a completed response to the GL until March 31, 2009. Required post-R1 8 activities include the compilation of data obtained during walk-downs, including elevation measurements and drawing updates; submittal of the final analyses by ABS Consulting Inc.; plant review of the ABS Consulting Inc. analyses, including identification of procedural enhancements, operator training and long term corrective actions; and final managerial review and approval of the GL response pursuant to 10CFR 50.54(f).

JAF proposes to maintain communication with the site Resident Inspector throughout this process.Based upon plant experience, JAF has a high degree of confidence that the subject systems, High Pressure Coolant Injection (HPCI), Core Spray (CS) and Low Pressure Coolant Injection (LPCI) will perform as intended.

Having completed the Phase1 plant walk-downs, ABS Consulting,, Inc. identified no problem areas within these systems where immediate corrective actions were necessary to justify continued operation.

Moreover, the subject system pumps are tested periodically at or near the maximum flow rate expected under accident conditions such that any significant voids present in either the suction or discharge piping would have become evident in pump trend data and analysis.

Significant gas accumulation has not been found at the high point vents in these systems during routine system venting procedures.

These systems have been in operation since the previous refueling outage with no surveillance test failures or any other indications of degraded performance that can be attributed to gas intrusion.

Upon completion of the R18 outage, system piping will be properly filled and vented by Operations staff. System discharge piping will be subject to operational checks utilizing plant equipment which serves to maintain the piping "full", thereby preventing the possibility of water hammer upon pump start. In addition, previous corrective action analyses have established procedural enhancements which ensure that piping will not be subject to gas intrusion in capacities which compromise design bases accident mitigation assumptions.

Based upon the foregoing, JAF requests an extension of time until March 31, 2009 to complete the supplemental response to GL 2008-01.2 of 2 ATTACHMENT 2 to JAFP-08-0092 James A. FitzPatrick Nuclear Power Station Docket No. 50-333 List of Regulatory Commitments ATTACHMENT 2 to JAFP-08-0092 LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Entergy in this document.Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED COMMITMENT (Check one) COMPLETION DATE ONE-TIME CONTINUING ACTION COMPLIANCE

,/ N/A October 11, JAF will submit a 9-month response to 2008 GL 2008-01, including a description of the results of the systems evaluated prior to the R1 8 refueling outage, a description of the corrective actions required based upon the preliminary plant review of ABS Consulting analysis, a statement regarding which corrective actions have been completed, a schedule for completing any remaining corrective actions and the basis for the schedule.JAF will submit a supplemental 0N/A March31, response to GL 2008-01, including a description of the results of the systems evaluated, a description of the corrective actions required, a statement regarding which corrective actions have been completed, a schedule for completing the remaining corrective actions, the basis for the schedule and the means by which any long term actions determined necessary will be tracked for implementation.

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