ML071620225
| ML071620225 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/28/2007 |
| From: | Chawla M L NRC/NRR/ADRO/DORL/LPLIII-1 |
| To: | Balduzzi M A Entergy Nuclear Operations |
| Chawla M L, NRR/DORL, 415-8371 | |
| References | |
| TAC MB9833 | |
| Download: ML071620225 (5) | |
Text
June 28, 2007Mr. Michael BalduzziSr. 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 habitabilityregulatory 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 TestMethod 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 datedSeptember 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 submittalincluded 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 limitingunfiltered 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 theyverify 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 () Pmeasurement 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 compensatorymeasures 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 RegulationDocket No. 50-255 cc: See next page
ML071620225OFFICELPL3-1/PMLPL3-1/LASCVB/BCPGCBLPL3-1/(A)BCNAMEMChawlaTHarrisRDennigCJacksonTTate PM for DATE06/26/0706/25/0706/22/0706/25/0706/28/07 Palisades Plant cc:Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351SupervisorCovert Township P. O. Box 35 Covert, MI 49043Office of the GovernorP. O. Box 30013 Lansing, MI 48909U.S. Nuclear Regulatory CommissionResident Inspector's Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043Michigan Department of Environmental QualityWaste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741Michigan Department of Attorney GeneralSpecial Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913Mr. Michael R. KanslerPresident & CEO/CNO Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601Mr. John T. HerronSr. Vice President Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601Sr. Vice President,Engineering and Technical Services EntergyNuclear Operations, Inc.1340 Echelon Parkway Jackson, MS 39213Mr. Bruce C. WilliamsVice President, Oversight Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213Mr. Christopher J. SchwarzSite Vice President Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043General Manager, Plant OperationsEntergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043Mr. Oscar LimpiasVice President, Engineering Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601Ms. Charlene D. FaisonManager, Licensing Entergy Nuclear Operations, Inc.
440 Hamilton Avenue White Plains, NY 10601 Mr. Ernest J. HarknessDirector 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 10601Mr. Joseph DeRoyVice President, Operations Support Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213Laurie A. Lahti, Manager, LicensingRegulatory Affairs Entergy Nuclear Operations, Inc.
Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 April 20, 2007