ML121290620
| ML121290620 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/15/2012 |
| From: | Pickett D Plant Licensing Branch 1 |
| To: | Entergy Nuclear Operations |
| Pickett D, NRR/DORL/LPL1-1, 415-1364 | |
| References | |
| BL-11-001, TAC ME6441, TAC ME6442 | |
| Download: ML121290620 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 15, 2012 Vice President, Operations Entergy Nuclear Operations, Inc.
Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249
SUBJECT:
CLOSEOUT OF BULLETIN 2011-01,"MITIGATING STRATEGIES'-INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 - (TAC NOS. ME6441 AND ME6442)
Dear Sir or Madam:
On May 11,2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01,
'Mitigating Strategies' (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360), to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The purpose of the bulletin was to obtain a comprehensive verification that licensees' mitigating strategies to maintain or restore core cooling, spent fuel cooling, and containment following a large explosion or fire were compliant with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(hh)(2).
The bulletin required two sets of responses pursuant to the provisions of 10 CFR 50.54(f).
Entergy Nuclear Operations, Inc., the licensee, provided its responses to the bulletin by letters dated June 10 and July 8, 2011 (ADAMS Accession Nos. ML11172A107 and ML11200A128, respectively). By letter dated November 15, 2011 (ADAMS Accession No. ML113140223), the NRC sent the licensee a request for additional information (RAI) on its July 8, 2011, response.
The licensee responded to the RAI by letter dated December 14, 2011 (ADAMS Accession No. ML11362A396).
The NRC staff has reviewed the information submitted by the licensee and concludes that its response to the bulletin is acceptable. As summarized in the enclosed safety evaluation, the staff verified that the licensee provided the information requested in the bulletin. No further information or actions under the bulletin are requested.
Sir or Madam -2 Please feel free to contact me at 301-415-1364 if you have any questions.
Sincerely Douglas Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RESPONSE TO BULLETIN 2011-01 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DOCKET NOS. 50-247 AND 50-286
1.0 INTRODUCTION
On May 11, 2011, the U.S. Nuclear Regulatory Commission (NRC) issued Bulletin 2011-01, "Mitigating Strategies," (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML111250360) to all holders of operating licenses for nuclear power reactors, except those that have permanently ceased operation and have certified that fuel has been removed from the reactor vessel. The bulletin required two sets of responses pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(f). The first responses were due 30 days after issuance of the bulletin. By letter dated June 10, 2011 (ADAMS Accession No. ML11172A107), Indian Point Nuclear Generating Unit Nos. 2 and 3 (Indian Point) provided its response to this first set of questions (first response). The second responses were due 60 days after issuance of the bulletin. By letter dated July 8, 2011 (ADAMS Accession No. ML11200A128), Indian Point provided its response to this second set of questions (second response). By letter dated November 15, 2011 (ADAMS Accession No. ML113140223), the NRC sent a request for additional information (RAI) on the second response. Indian Point responded to the RAI by letter dated December 14, 2011 (ADAMS Accession No. ML11362A396). As summarized below, the NRC staff has verified that Indian Point provided the information requested in the bulletin.
2.0 TECHNICAL EVALUATION
On February 25, 2002, the NRC issued EA-02-026, "Order for Interim Safeguards and Security Compensatory Measures" (ICM Order). Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities using readily available resources (equipment and personnel) that can be effectively implemented under the circumstances associated with the loss of large areas of the plant due to explosions or fire.
By letter dated July 11, 2007 (ADAMS Accession No. ML071920023), the NRC staff issued its Safety Evaluation (SE) to document the final disposition of information submitted by Indian Point regarding Section B.5.b of the ICM Order. Along with the SE, the staff issued a conforming license condition to incorporate the B.5.b mitigating strategies into the licensing basis.
Enclosure
-2 On March 27, 2009, the NRC issued 10 CFR 50.54(hh)(2) as a new rule, in order to capture the B.5.b mitigating strategies and related license conditions as regulatory requirements for both current and future licensees. At that time, licensee compliance with the conforming license conditions was sufficient to demonstrate compliance with 10 CFR 50.54(hh)(2) (74 FR 13926) so no further actions were required on the part of current licensees.
2.1 30-Day Request In order to confirm continued compliance with 10 CFR 50.54(hh)(2), the bulletin requested that licensees address the following two questions within 30 days of issuing the bulletin:
- 1. Is the equipment necessary to execute the mitigating strategies, as described in your submittals to the NRC, available and capable of performing its intended function?
- 2. Are the guidance and strategies implemented capable of being executed considering the current configuration of your facility and current staffing and skill levels of the staff?
The NRC staff reviewed Indian Point's first response to determine if it had adequately addressed these questions.
2.1.1 Question 1: Availability and Capability of Equipment In its first response, Indian Point confirmed that equipment it needs to execute the 10 CFR 50.54(hh)(2) mitigating strategies is available and capable of performing its intended function. The NRC staff verified that this confirmation covered equipment needed for each of the three phases of B.5.b mitigation strategies. Therefore, the NRC staff finds that Indian Point has adequately responded to Question 1.
2.1.2 Question 2: Guidance and Strategies Can Be Executed In its first response, Indian Point confirmed that the guidance and strategies it has implemented for 10 CFR 50.54(hh)(2) are capable of being executed considering the current facility configuration, staffing levels, and staffs skills. Since Indian Point has considered its current facility configuration, staffing levels, and staff's skills, and confirmed that it can execute its implemented guidance and strategies, the NRC staff finds that Indian Point has adequately responded to Question 2.
2.2 60-Day Request The bulletin required a response to the following five questions within 60 days of issuing the bulletin:
- 1. Describe in detail the maintenance of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it is functional when needed.
- 2. Describe in detail the testing of equipment procured to support the strategies and guidance required by 10 CFR 50.54(hh)(2) in order to ensure that it will function when needed.
-3
- 3. Describe in detail the controls for ensuring that the equipment is available when needed.
- 4. Describe in detail how configuration and guidance management is ensured so that strategies remain feasible.
S. Describe in detail how you ensure availability of offsite support.
The NRC staff reviewed Indian Point's submittals to determine if it had adequately addressed these questions. The NRC staff also reviewed the July 11, 2007, SE to determine what equipment, training, and offsite resources at Indian Point were relied upon by NRC staff to conclude that Indian Point's actions would ensure compliance with Section B.S.b of the ICM Order and the conforming license condition.
2.2.1 Questions 1 and 2: Maintenance and Testing of Equipment Questions 1 and 2 of the 60-day request required licensees to describe in detail the maintenance and testing of equipment procured to support the strategies and guidance required by 10 CFR SO.S4(hh)(2) in order to ensure that it is functional when needed. In its second response, Indian Point listed the equipment used to support the 10 CFR SO.S4(hh)(2) mitigating strategies which receives maintenance or testing. For each item, Indian Point described the maintenance and testing performed, including the frequency and basis for the maintenance or testing activity.
The NRC staff verified that Indian Point listed equipment that typically requires maintenance or testing which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, Indian Point stated that the portable pump, hoses, monitors with nozzles, and communications equipment receive maintenance or testing.
The NRC staff noted that the functional testing of radios was listed in response to Question 3.
The NRC staff also noted that the fuel level for the portable pump is verified during maintenance. Indian Point identified other items that support the mitigating strategies that receive maintenance or testing.
The NRC staff verified that Indian Point described the process used for corrective actions and listed the testing performed to ensure that the strategies were initially feasible. Indian Point stated in its second response that its 10 CFR Part SO, Appendix B, corrective action program is used to document equipment failure, establish priorities, and perform trending.
Based upon the information above, the NRC staff finds that Indian Point has provided the information requested by Questions 1 and 2.
2.2.2 Question 3: Controls on Equipment Question 3 of the 60-day request required licensees to describe in detail the controls on equipment, such as inventory requirements, to ensure that the equipment is available when needed. A list of inventory deficiencies and associated corrective actions to prevent loss was also requested.
The NRC staff verified that Indian Point described its process for ensuring that B.S.b equipment will be available when needed. In its second response, Indian Point identified equipment
-4 included in its inventory, the inventory frequency, storage requirements, and items verified.
Items verified include proper quantity, location, and accessibility of equipment. Indian Point states that at the time of its second response, there were no outstanding inventory deficiencies that would render the strategies not viable.
The NRC staff verified that Indian Point inventoried equipment which was relied upon to make conclusions in the SE or commonly needed to implement the mitigating strategies. In its second response, Indian Point stated that procured non-permanently installed B.5.b equipment is inventoried in accordance with station procedures. Indian Point did not specify the minimum inventory frequency for B.5.b equipment, but all items listed were inventoried at least quarterly.
The second response specifically states that the following items are included in the inventory:
portable pump; portable power supply; hoses; communications equipment; nozzles; connectors and adapters; nitrogen bottles; tools; instruments; and firefighter turnout gear. The staff noted that a vehicle to move the portable pump and other B.5.b equipment was not listed. In its RAI response, Indian Point stated that it did not need a vehicle to execute the B.5.b mitigation strategies, although several are normally available. Indian Point stated that it demonstrated during a timed drill in 2008 that the portable pump could be manually moved into position within the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> required for the spent fuel pool strategies. Indian Point also identified other items that support the mitigating strategies that are inventoried.
Based upon the information above, the NRC staff finds that Indian Point has provided the information requested by Question 3.
2.2.3 Question 4: Configuration and Guidance Management Question 4 of the 60-day request required licensees to describe in detail how configuration and guidance management is assured so that the strategies remain feasible.
The NRC staff verified that Indian Point described its measures to evaluate plant configuration changes for their effects on the mitigating strategies and to ensure its procedures are current.
In its second response, Indian Point stated that plant configuration changes are procedurally evaluated against the licensing basis, which includes the B.5.b mitigating strategies. Indian Point states that the design change process requires a review of affected procedures and that procedure changes are validated to ensure that the B.5.b mitigating strategies remain viable.
The NRC staff verified that Indian Point described measures it has taken to validate the procedures or guidelines developed to support the mitigating strategies. In its second response, Indian Point identified testing in response to Question 2 that demonstrated the ability to execute some strategies. Indian Point also states that "initially, mitigating strategies were validated by walkdowns, engineering evaluations and/or table top reviews" and they were similarly revalidated in 2011.
The NRC staff verified that Indian Point described the training program implemented in support of the mitigating strategies and how its effectiveness is evaluated. In its July 8 and December 14,2011, responses, Indian Point described the training provided to its operations personnel; emergency response organization, including key decision makers; security personnel; and fire brigade. Indian Point also identified the frequency with which each type of training is provided and the methods for training evaluating.
- 5 Based upon the information above, the NRC staff finds that Indian Point has provided the information requested by Question 4.
2.2.4 Question 5: Offsite Support Question 5 of the 60-day request required licensees to describe in detail how offsite support availability is assured.
The NRC staff verified that Indian Point listed the offsite organizations it relies upon for emergency response, including a description of agreements and related training. The NRC staff compared the list of offsite organizations that Indian Point provided in its second response with the information relied upon to make conclusions in the SE. Indian Point stated that it maintains memorandum of understanding and other types of agreements with these offsite organizations and that these agreements were current at the time of its second response. Indian Point also identified the review period, if any, for each of these agreements and the training and site familiarization it provides to these offsite organizations. Indian Point stated that it reviewed its corrective action program back to 2008 and found no issues involving lapsed agreements related to offsite support for B.5.b events.
Based upon the information above, the NRC staff finds that Indian Point has provided the information requested by Question 5.
3.0 CONCLUSION
As described above, the NRC staff has verified that Indian Point has provided the information requested in Bulletin 2011-01. Specifically, Indian Point responded to each of the questions in the bulletin as requested. The t\IRC staff concludes that Indian Point has completed all of the requirements of the bulletin and no further information or actions under the bulletin are needed.
Principal Contributor: B. Purnell, NRR Date: May 15, 2012
Sir or Madam - 2 Please feel free to contact me at 301-415-1364 if you have any questions.
Sincerely Ira!
Douglas Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
Safety Evaluation cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL1-1 r/f RidsNrrDorlLpl1-1 RidsNrrDprPgcb BPurnell, PGCB EBowman, PGCB RidsNrrPMlndianPoint RidsNrrLASLittle RidsRgn1 MailCenter RidsOGCRp RidsAcrsAcnw_MaiICTR RidsNrrDorlDPR MGray, R1 ADAMS ACCESSION NO.: ML121290620 OFFICE LPL 1-1/PM LPL 1-1/LA PGCB/BC(A} LPL1-1/BC NAME DPickett SLittie KMorgan-Butler by GWilson memo dated DATE 05/15/12 05/14/12 04/19/12 05/15/12 OFFICIAL RECORD COPY