NL-12-093, Revision to Response to Request for Additional Information Regarding Operator Manual Actions

Revision to Response to Request for Additional Information Regarding Operator Manual Actions

ML12220A006
Person / Time
Site:	Indian Point
Issue date:	07/11/2012
From:	Ventosa J Entergy Nuclear Northeast
To:	Bill Dean NRC Region 1
References
NL-12-093
Download: ML12220A006 (8)

Text

Entergy Nuclear Northeast Indian Point Energy Center

.sa~' 17 4~,,,,.450 Broadway, GSB I"'if IP.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President Administration NL-12-093 July 11, 2012 Mr. William M. Dean Regional Administrator USNRC Region I 2100 Renaissance Boulevard, Suite 100 King of Prussia, PA 19406-2713

Subject:

Revision to Response to Request for Additional Information Regarding Operator Manual Actions Indian Point Nuclear Generating Unit 2 Docket No. 50-247 License No. DPR-26

References:

1. NRC letter dated February 1, 2012, "Indian Point Nuclear Generating Unit No.2 - Exemption from the Requirements of 10 CFR Part 50, Appendix R, Paragraph III.G.2 (TAC No. ME0798)

2. NRC letter dated February 1, 2012, "Indian Point Energy Center Units 2 & 3-Request for Additional Information Regarding Operator Manual Actions"

3. Entergy letter NL-12-041 dated March 1,2012, "Response to Request for Additional Information Regarding Operator Manual Actions"

Dear Sir:

By letter dated February 1, 2012 (Reference 1), exemptions from the requirements of 10 CFR 50, Appendix R, Paragraph III.G.2 for the use of operator manual actions (OMAs) were granted in part and denied in part for Indian Point Unit 2. A request for additional information regarding the plans by Entergy Nuclear Operations, Inc. (Entergy) for achieving compliance with fire protection regulations in light of the denied exemptions was also transmitted by letter dated February 1,2012 (Reference 2). Entergy's response to Reference 2 was provided in Reference 3. Entergy committed to inform the NRC in Reference 3 of any changes in resolution concept and/or completion schedule that may be determined to be necessary as an outcome of the engineering analysis and evaluation process. Accordingly, the attachment to this letter provides a revision to the response for Unit 2, and contains Entergy's current and planned actions and the

NL- 12-093 Docket No. 50-247 Page 2 of 3 schedule for completion of corrective actions that will resolve each of the identified OMA concerns, and thereby establish full compliance with the requirements of the applicable subsection of 10 CFR 50, Appendix R, Section IIl.G.

The attachment presents a listing of the Unit 2 OMAs that were denied. The table in the attachment presents the OMAs sorted by the fire zone(s) of concern, i.e., those fire zones for which use of the discrete OMAs had been requested, and they include a description of the planned resolution and scheduled completion date for each of the OMAs. It has been determined that a plant modification will be required to eliminate OMA 6 in Fire Area/Zone F/7A and Fire Area/Zone F/27A rather than a revision to the safe-shutdown analysis and methodology to credit an equipment train independent of these zones. Also, the two OMAs that were inadvertently omitted from the exemption request process were added to Fire Area/Zone F/7A as OMAs 20 and 21, and these will be eliminated by another plant modification. The footnote in the table, the note for OMA 19 in Fire Area/Zone K/60A, and the note on page 4 were also revised. These changes to the attachment are identified by revision bars. There are no other changes to the information provided in Reference 3.

As noted in Reference 3, given the substantial technical challenge imposed by the OMA resolution effort, and recognizing that the requisite engineering evaluations are in progress at this time, the presently conceptualized solutions may change, in that the scope of analyses and/or the nature and scope of plant physical modifications may require revision as the OMA resolutions are finalized. The target completion dates shown in the attachment represent Entergy's current informed projection, and any change in resolution concept and/or completion schedule that may be determined to be necessary as an outcome of the engineering analysis and evaluation process will be promptly communicated to NRC, as previously committed to in Reference 3. There are no new regulatory commitments made in this submittal.

In the event of any questions, please contact Mr. Robert W. Walpole, Manager, Licensing at 914-254-6710.

Sincerely, JAV/gd

Attachment:

Resolution of Indian Point Unit 2 11l.G.2 OMAs For Which Exemptions Have Been Denied (Revised from Letter NL-12-041 dated March 1, 2012)

NL-12-093 Docket No. 50-247 Page 3 of 3 cc: Mr. Douglas V. Pickett, Senior Project Manager, NRC NRR DORL U.S. Nuclear Regulatory Commission Document Control Desk NRC Resident Inspectors Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Department of Public Service

Attachment to NL-12-093 Resolution of Indian Point Unit 2 III.G.2 OMAs For Which Exemptions Have Been Denied (Revised from Letter NL-12-041 dated March 1, 2012)

ENTERGY NUCLEAR OPERATIONS, INC.

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 License No. DPR-26

NL-12-093 Docket No. 50-247 Attachment Page 1 of 4 RESOLUTION OF INDIAN POINT UNIT 2, SIU.G.2 OMAS FOR WHICH EXEMPTIONS HAVE BEEN DENIED I 'Scheduled Fire Area OMA Planned Resolution CI ti

/Zone No.' -Date Date " ,

F/5A 6 Revise Appendix R safe-shutdown analysis and methodology to 03 2012 credit equipment train independent of the fire area/zone, thereby eliminating this OMA F/6' 6 As described for OMA 6, Fire Area F, Fire Zone SA .03Q2012, 7 Revise Appendix R safe-shutdown analysis and methodology to 042012 credit equipment train independent of the.fire area/zone. thereby eliminating this OMA F/7A Implement modification to protect. circuits of concern, thereby Spring 2014 eliminating this OMA RFO 7 As described for OMA 7, Fire Area F, Fire Zone 6 Q4 2012 20 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating this OMA (see Note on page 4) RFO 21 Implement modification to protect circuits of concern, thereby Spring 2014 eliminating this OMA (see Note on page 4) RFO F/22A 6 As described for OMA 6, Fire Area F, Fire Zone 5A Q3 2012 F/27A 5 Revise Appendix R safe-shutdown analysis and methodology to Q32012 credit equipment train independent of the fire area/zone, thereby eliminating this OMA 6 As described for OMA 6, Fire Area F, Fire Zone 7A Spring 2014 RFO F/33A 5 As described for OMA 5, Fire Area F, Fire Zone 274A 032012 F/59A 5 As described for OMA 5, Fire Area F, Fire Zone 27A 03 2012 l-H172A 8 Revise Appendix R safe-shutdown analysis and methodology to. 3 2012 credit equipment train independent of the,fire arealzone, thereby,.,

eliminating this OMA H/75A 8 Revise Appendix R safe-shutdown analysis and methodology'to 03 2012 credit a train of equipment free of fire damage in the fire area/zone, thereby eliminating this OMA L 9,10 Implement modification eliminating these OMAs to protect circuits of concern, thereby Spring RFO2014 As identified in table on pages 5 and 6 in Exemption transmitted by Reference I, with the exception of OMAs 19.

20 and 21 - see Note on page 4

NL-12-093 Docket No. 50-247 Attachment Page 2 of 4 RESOLUTION OF. INDIAN POINT UNITr2 IIi.G.2 OMAS FOR WHICH EXEMPTIONS HAVEBEEN DENIED -

FirneArea r 0iere NA MA Planned Resolution Scheduled Completion

/Zone No.'  : - . Dainlteo Date Hf77A 8 As described for OMA 8, Fire Area H. Fire Zone 72A 032012 9.10 As described for OMAs 9,10, Fire Area H, Fire Zone 75A Spring 2014 RFO H/84A. 8 As described for OMA 8, Fire Area H, Fire Zone 72A 03 2012 H,5A 8 As described for OMA Fire Area H, Fire Zone 72A 03,

,, 2012 H187A 8 As described for OMA 8, Fire Area H, Fire Zone 72A Q32012 9,10 As described for OMAs 9,10, Fire Area H, Fire Zone 75A Spring 2014 RFO J/1 9 11 Reassess electrical circuit and power supply loading analyses and 03 2012 revise Appendix R safe-shutdown analysis and methodology to provide'the basis for elimination of this OMA J/25 12 Revise Appendix R safe-shutdown analysis and method0logy to 042012 credit equipment train independent of-the ftire area/zone, thereby

__ .__eliminating this OMA_

J/39A 11 As described for OMA 11, Fire Area J, Fire Zone 19 03 2012 12 As described for OMA 12, Fire Area J, Fire Zone 25 Q42012 J/43A I11 As described for OMA 11. Fire Area J, Fire Zone 19, 032012 12, As described for OMA 12, Fire Area J, Fire Zone 25 Q4 2012

--13 Revise Appendix R safe-shutdown analysis and methodology to 032012 credit equipment train independent of the fire area/zone, thereby

• _eliminating this'OMA J/45A 11 As described for OMA 11, Fire Area J, Fire Zone 19 03 2012 J/46A 11 As described forOMA 11, Fire Area J, Fire Zone 19 "032012 12 As described for OMA 12, Fire Area J, Fire Zone 25 04 2012 13 As described for OMA 131, Fire Area J, Fire Zone 43A 04 2012 J/47A 11 As described for OMA 11, Fire Area J, Fire Zone 19 03 2012 J/50A 11 As described for OMA 11 Fire Area J, Fire Zone 19 03 2012 12 As described for OMA 12, Fire Area J, Fire Zone 25 042012 J/270 12 As described for OMA 12, Fire Area J, Fire Zone 25 Q4 2012

NL-12-093 Docket No. 50-247 Attachment Page 3 of 4 RESOLUTION OF INDIAN POINT UNIT 2 IILG.2 OMAS FOR WHICH EXEMPTIONS HAVE BEEN DENIED Fire-Area OMA Shdue I Zone, Planned Resolution Completion Date K/60A 14 Implement. modification to protect circuits of concern, thereby 04 2012 eliminating this OMA 15 Implement modification to protect circuits of concern, thereby 04 2012 eliminating this OMA 19 Implement modification to protect circuits of concern, thereby Q4 2012 eliminating this OMA (see Note on page 4)

K/65A 14 As descibed for OMIA 14, FireAa K, Fire Zone 60A 042012.

15 A/s descnrbed for OMA 15. Fire Area K, Fire Zone 60A 042012 19 As described for OMA 19, Fire Area K, Fire Zone 60A

NL-12-093 Docket No. 50-247 Attachment Page 4 of 4 Description of Unit 2 Denied OMAs

5. Open HCV-142 bypass valve 227 to align charging pump makeup path to the Reactor Coolant System (RCS)

6. Align charging pump suction source to the Refueling Water Storage Tank (RWST)

7. Transfer instrument buses 23 and 23A to alternate power

8. Fail open valves 204A (charging flow to Loop 2 hot leg) and 204B (charging flow to Loop 1 cold leg) to align charging pump makeup path to the RCS

9. Activate or enable Alternate Safe Shutdown System pneumatic instruments (steam generator level, pressurizer pressure and level) at Fan House local control panel

10. Enable Alternate Safe-Shutdown System source-range channel and Loop 21 and 22 hot leg (Th) and cold leg (T.) temperature channels

11. Trip breakers 52/5A and 52-SAC on Bus 5A and 52/6A and 52/TAO at Bus 6A and remove control power fuses

12. Transfer Instrument Buses 23 and 23A to emergency power source

13. Align charging pump suction to RWST

14. Operate transfer switch EDC5 and close supply breaker at substation 12FD3 to transfer 21 AFW Pump to Alternate Safe Shutdown System power source

15. Open 21 AFW Pump recirculation bypass valve BFD-77

19. Operate 21 AFW Pump flow control valves to control AFW flow to Steam Generators 21 &

22

20. Locally operate 21 Charging Pump scoop tube positioner

21. Locally start 21 Charging Pump using the emergency control station located in the 480V Switchgear Room NOTE: With the exception of OMAs 19, 20 and 21, the descriptions are copied from the.

table on pages 5 and 6 in Exemption transmitted by Reference 1. OMA 19 was not addressed in the Exemption transmitted by Reference 1. OMAs 20 and 21 were inadvertently omitted from the exemption request process, and are therefore unapproved OMAs. The three OMAs have been given the next sequential numbers.