ML073230158

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Indian Point, Unit No.3 - Denial of Extension Request for Corrective Actions Required by Generic Letter 2004-02 (TAC No. MC4690)
ML073230158
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 11/20/2007
From: Kowal M G
NRC/NRR/ADRO/DORL/LPLI-1
To: Balduzzi M A
Entergy Nuclear Operations
reeves, R NRR/DORL/LPL1-1 301-415-5239
References
GL-04-002, TAC MC4690
Download: ML073230158 (5)


Text

November 20, 2007

Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - DENIAL OF EXTENSION REQUEST FOR CORRECTIVE ACTIONS REQUIRED BY GENERIC LETTER 2004-02 (TAC NO. MC4690)

Dear Mr. Balduzzi:

In a letter dated October 24, 2007, [Agencywide Document Access and Management System (ADAMS) accession number ML073040291] Entergy Nuclear Operations, Inc. (Entergy) requested an extension to the December 31, 2007, completion deadline for the corrective actions required by Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors" for the Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed extension would allow Entergy approximately 14 additional months to complete the modifications and licensing activities necessary to achieve full compliance with GL 2004-02, with completion of this effort to coincide with the completion of the IP3 spring 2009 refueling outage.

The Nuclear Regulatory Commission (NRC) staff has evaluated the information provided in Entergy's letter and has determined that the arguments presented in the letter are not adequate to grant a 14-month extension. The NRC views the scope of the additional modifications required to demonstrate compliance with GL 2004-02 as achievable before the next refueling outage and, therefore, the extension request is denied.

In its letter, Entergy stated that the installation of significantly larger sump strainers and other modifications designed to reduce debris transport to the sumps has been completed. However, the planned modification to change the buffering agent from sodium hydroxide to sodium tetraborate has not been implemented. Further, the letter stated that the planned operating-license amendments to reflect a change to the low-low level set-point of the refueling water storage tank, the change of buffering agent, and the implementation of the exemption from the single failure criterion for large-break loss-of-coolant accidents (LBLOCAs) have not been initiated. Entergy proposed to complete these activities by the close of the IP3 spring 2009 refueling outage, scheduled to begin on March 10, 2009.

The NRC's criteria for granting extensions are contained in SECY-06-0078. The SECY requires that the licensee have a plant-specific technical/experimental plan with milestones and schedules to address outstanding technical issues, and have in place mitigative measures that minimize the risk of degraded emergency core cooling system (ECCS) and containment spray system (CSS) functions during the extension period. The SECY also recommends that for proposed extensions beyond several months, the mitigative measures include temporary physical improvements to the ECCS sump or materials inside containment to better ensure a high level of ECCS sump performance.

After reviewing Entergy's submittal, the NRC staff concludes that Entergy has a plan to complete the remaining corrective actions and has compensatory measures in place. However, NRC finds that Entergy has not made a convincing case why the proposed modifications and other changes cannot be accomplished before the next refueling outage. Further, the importance of completing the corrective actions required to prevent sump strainer clogging was expressed in the "Director's Decision Under 10 CFR 2.206" (ML041700619), which specifically addressed the

petition regarding the operability of the Indian Point Nuclear Gener ating Unit Nos. 2 and 3 sumps. For these reasons, a 14-month extension beyond December 31, 2007, is not acceptable. Therefore, as previously stated, the NRC denies Entergy's request, dated October 24, 2007, for an extension of the GL 2004-02 corrective actions completion date of December 31, 2007. Entergy may submit another extension request for NRC consideration, proposing a shorter extension consistent with the time needed to prepare for and implement remaining corrective actions in an expeditious manner.

Please contact the Indian Point Project Manager, John Boska, at (301) 415-2901 if you have any questions on this issue.

Sincerely, /RA/ Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-286

cc: See next page

ML OFFICE LPL1-1/PM LPL1-1/LA SSIB/BC LPL1-1/BC NAME JBoska SLittle MScott MKowal DATE 11/20/07 11/19/07 11/19/07 11/20/07 Indian Point Nuclear Generating Unit No. 3

cc:

Mr. Michael R. Kansler President & CEO / CNO Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213

Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213

Sr. Vice President Engineering & Technical Services Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213

Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

Mr. Anthony Vitale - Acting General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249

Mr. Oscar Limpias Vice President Engineering Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213

Mr. Joseph P. DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213

Mr. John A. Ventosa GM, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Mr. John F. McCann Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

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

1340 Echelon Parkway Jackson, MS 39213

Mr. Patric W. Conroy Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

Mr. Robert Walpole Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249

Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Indian Point Nuclear Generating Unit No. 3

cc:

Mr. Paul Tonko President and CEO New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399

Mr. John P. Spath New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399

Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350

Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Senior Resident Inspector

=s Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511

Senior Resident Inspector

=s Office Indian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511

Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271

Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532

Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511

Mr. William DiProfio PWR SRC Consultant

48 Bear Hill Road Newton, NH 03858

Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236

Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232

Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001

Mr. Phillip Musegaas Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591

Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524

Ms. Susan Shapiro via email

Mr. Sherwood Martinelli

FUSE USA via email