JAFP-10-0059, Response to Request for Additional Information Regarding Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves

Response to Request for Additional Information Regarding Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves

ML101310214
Person / Time
Site:	FitzPatrick
Issue date:	05/11/2010
From:	Peter Dietrich Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-10-0059, TAC ME2810
Download: ML101310214 (8)

Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 JAFP-10-0059 May 11, 2010 United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Response to Request for Additional Information Re: James A. FitzPatrick Nuclear Power Plant Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves (TAC No. ME2810)

James A. FitzPatrick Nuclear Power Plant Docket No.

50-333 License No. DPR-59

References:

1. Entergy Letter, JAFP-09-0132, Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves (TAC No. ME2810), dated November 23, 2009

2. Entergy Letter, JAFP-10-0039, Response to Request for Additional Information Re: James A. FitzPatrick Nuclear Power Plant Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves (TAC No. ME2810), dated March 18, 2010

3. NRC Request For Additional Information Regarding James A. FitzPatrick Nuclear Power Plant Application for Amendment to Modify the Technical Specifications Requirements for Testing of Safety/Relief Valves (TAC No.

ME2810), dated March 29, 2010

Dear Sir or Madam:

On November 23, 2009, Entergy Nuclear Operations, Inc. (ENO), submitted an application for amendment to the Technical Specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF), that would revise the surveillance testing requirements for safety/relief valves

[Reference 1]. On March 18, 2010, JAF responded to a Request for Additional Information (RAI) from the Nuclear Regulatory Commission (NRC) staff [Reference 2]. On March 29, 2010, JAF received a follow-up RAI, based on NRC review of the initial RAI response [Reference 3].

That request was clarified in a conference calls with the staff on March 29, 2010, and April 5, 2010.

Based on the clarifying discussions with the staff, ENO is submitting the attached response to the follow-up RAI questions [Attachment 1].

Pete Dietrich Site Vice President - JAF

JAFP-10-0059 Page 2 of 2 The attached response does not affect the No Significant Hazards Determination submitted with the revised amendment application, dated March 18, 2010.

There are two new commitments made in this letter; they are summarized in Attachment 2.

Questions concerning this submittal may be addressed to Mr. Joseph Pechacek, Licensing Manager, at (315) 349-6766.

I declare under penalty of perjury that the foregoing is true and correct.

May 2010.

Pete Di trich Site Vice President - JAF PD/JP/ed Attachments:

1.

Response to Request for Additional Information Question 2.

Summary of Commitments cc:

Mr. Samuel Collins Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office U.S. Nuclear Regulatory Commission James A. FitzPatrick Nuclear Power Plant P.O. Box 136 Lycoming, NY 13093 Mr. Bhalchandra Vaidya, Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8-C2A Washington, DC 20555-0001 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza, 10 lh Floor Albany, NY 12223 Mr. Francis J. Murray Jr., President New York State Energy and Research Development Authority 17 Columbia Circle Albany, NY 12203-6399

JAFP-10-0059 Response to Request for Additional Information Question (3 Pages)

JAFP-10-0059 Response to Request for Additional Information Question Page 1 of 3 Question:

Entergy letter JAFP-10-0039, Attachment 2, section 4.0, third bullet in the paragraph on proposed testing, describes the SRV actuator functional test for the two-stage SRVs. The section then states that the three-stage SRV actuator will be tested in the same manner. With respect to the three-stage SRVs, how will the test ensure that the actuator will engage and open the second stage?

Response

In both the two-stage and three-stage valves, the actuator is required to move some specified distance to open the respective valve stage. In the three-stage valve, this movement includes a gap between the actuator stem and the second stage piston, and the required movement of the second stage piston to open the second stage disk. Since the actuator and piston stems are co-linear and are constrained to remain in alignment by the piston bore, there is high confidence that the actuator will engage the piston. Acceptance criteria will ensure sufficient actuator movement to engage and open the second stage on the three-stage SRVs.

Question:

Entergy letter JAFP-10-0039, Attachment 2, Page 4, Second paragraph, third sentence, states, Specific SRV maintenance procedures and plant Foreign Material Exclusion procedures and practices are sufficient to ensure proper mechanical functioning and unobstructed steam flow capability without periodic actuation testing. Describe the maintenance procedure and Foreign Material Exclusion controls to be employed.

Response

The following discussion describes the current procedural controls credited for ensuring that no foreign material obstructs the SRV flow path after reassembly.

Maintenance Procedure MP-002.04, Reactor Vessel Safety/Relief Valve (SRV) / Maintenance (ISI)

• Section 6, precautions includes the following precautions:

6.2 Dirt and foreign material must be prevented from entering open systems per EN-MA-118, Foreign Material Exclusion.

6.3 Means to isolate piping from valve (via clean plug, temporary dam, etc.) must be provided before grinding or performing repairs to valve seat.

6.14 When valve internals are removed AND valve will be left unattended, protective cover shall be installed to maintain Foreign Material Exclusion (FME).

In the procedure section on main body removal, step 8.8.9 states Cover all openings to prevent foreign objects from entering system.

JAFP-10-0059 Response to Request for Additional Information Question Page 2 of 3 In the procedure section for re-installation of the main body, Step 8.13.2 states, Remove piping covers AND ensure piping is clean and unobstructed.

EN-MA-118, Foreign Material Exclusion defines several types of Foreign Material Exclusion (FME) Zones. FME Zone 1 is defined as The highest level of FME control. A zone/area established when a loss of FME integrity could result in fuel failure, reduced system safety, station availability or significant cost for recovery. It is also established when a final visual inspection of internal cleanliness before system closure is not possible due to configuration, ALARA concerns or other circumstances.

EN-MA-118 includes the following requirements for an area designated as FME Zone 1:

5.11 FME ZONE 1 REQUIREMENTS

[1]

While they are being used inside the FME Zone 1, all items, tools, or materials not of a "fail-safe" design should have a lanyard attached as a backup measure to prevent their loss into the open system or component.

[2]

Stored items should be made fail-safe (e.g., tied off) to prevent inadvertent foreign material intrusion and should be properly labeled to identify storage purpose or end use, and responsible department or individual.

[3]

Upon job completion, be sure to account for all material and tools that were introduced into the FMEZ.

[4]

Completed log sheets are not required to be kept as a record. The completed log sheet(s) should be signed by the FME Monitor and retained in the work package until complete. These logs may be discarded once all items have been accounted for and any required closeout inspections have been completed.

[5]

A single entry point is generally preferred to control access to the FME Zone; however, additional entry locations can be established as long as logging requirements are maintained and tool accountability from separate entry points is appropriately reconciled.

[6]

An FME monitor shall control personnel and material access to the FMEZ 1 whenever work is in progress. Only necessary material and personnel are allowed access to the FMEZ.

[7]

An FMEA / buffer zone may be established and posted to maintain an area free from debris or material having a potential of being tracked, blown, or falling into the FMEZ.

This area should be kept clean to prevent FM from being tracked or kicked into the zone.

[8]

Personnel entering FME Zone 1 areas for routine inspections, or operator rounds shall secure loose items and self-check themselves to ensure all items brought into the Zone are removed when exiting the area. FME practices listed for Zone 1 areas shall be followed including logging of items, even if a FMEM is not present at the job location.

[9]

Inspect tools for parts that may fall off, and confirm the existence of a positive retention mechanism on all such parts. Inspect tools for excessive wear such as rounded heads on chisels, or a Chicago fitting clip bent or worn. Tools and equipment that contain lead, steel, or other types of shot (for example diver weight belts, dead blow hammers, etc.) that have a potential for the shot to come loose and become foreign material shall not be used in FME zones. Clean all tools entering the FMEZ of all dirt, debris, and excess lubricant that could be introduced into the system or component.

JAFP-10-0059 Response to Request for Additional Information Question Page 3 of 3

[10]

Catch screens or similar methods should be used to prevent dropping or loss of fasteners and washers when they are removed or replaced inside the FMEZ.

[11]

Clear plastic sheeting, sleeving, wrappers, bags, or clear hose or tubing should not be stored or allowed to accumulate in areas adjacent to the reactor cavity and spent fuel pool FME area boundaries.

[12]

Cranes Cranes with access over an FME Zone 1 shall be restricted from traveling over the FME Zone unless overhead areas are controlled according to Zone 1 requirements.

Whenever possible, move cranes to low risk FME areas (e.g., not parked over open spent fuel pool or filled reactor cavity) prior to performing crane maintenance.

Prior to moving a crane over or into a Zone 1 area:

The crane shall be inspected for foreign material.

The crane shall be free of debris, excess lubricant, and loose fasteners or components.

All nonfail-safe foreign materials shall be removed from the crane or logged in the material accountability log, or made failsafe.

The inspection may be performed by the job supervisor, crane operator, or other individual familiar with the FME requirements for the area.

Documentation of inspection is required on attachment 9.4.

The job supervisor or designee shall authorize moving the crane into the FME area.

If access to the crane and introduction of foreign material onto the crane are controlled following the initial crane inspection, additional crane inspections and entry authorizations are not required when moving the crane over or into a high risk FME area.

Lock wire installed in Zone 1 crane overhead areas should be secured or, where practical, replaced with a more benign means of component restraint.

Maintenance procedure MP-002.04 will be revised to stipulate the use FME Zone 1 controls when replacing SRV main bodies. Those controls, as described here, will provide assurance that the SRV discharge piping remains unobstructed.

JAFP-10-0059 Summary of Commitments (1 Page)

JAFP-10-0059 Summary of Commitments Page 1 of 1 This table identifies actions discussed in this letter for which Entergy commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.

TYPE (Check one)

COMMITMENT ONE-TIME ACTION CONTINUING COMPLIANCE SCHEDULED COMPLETION DATE (If Required)

Develop acceptance criteria that ensure sufficient actuator movement to engage and open the second stage on three-stage SRVs.

X Commitment Number A-18422 09/15/2010 Revise maintenance Procedure MP-002.04 to stipulate Foreign Material Zone 1 controls during the replacement of SRV Main bodies.

X Commitment Number A-18423 09/15/2010