ML13183A557
| ML13183A557 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/02/2013 |
| From: | Office of Nuclear Reactor Regulation |
| To: | Division of License Renewal |
| References | |
| Download: ML13183A557 (8) | |
Text
1 IPRenewal NPEmails From:
Green, Kimberly Sent:
Tuesday, July 02, 2013 4:42 PM To:
Waters, Roger M.
Cc:
IPRenewal NPEmails
Subject:
Draft Telecon Summary for Call on July 2, 2013 Attachments:
Telecon Summary 07-02-13 May 6th Change to MEB Program.docx
- Roger, Attached is the draft telecon summary for the phone call that was held on July 2 regarding draft RAI 3.0.3.2.11-1 on changes to the MEB Inspection Program. Please review and let me know if there are any discrepancies or errors. If no corrections are needed, I will issue the final call summary.
- Thanks, Kim
Hearing Identifier:
IndianPointUnits2and3NonPublic_EX Email Number:
4281 Mail Envelope Properties (F5A4366DF596BF458646C9D433EA37D70100EBEA5FD9)
Subject:
Draft Telecon Summary for Call on July 2, 2013 Sent Date:
7/2/2013 4:41:49 PM Received Date:
7/2/2013 4:42:17 PM From:
Green, Kimberly Created By:
Kimberly.Green@nrc.gov Recipients:
"IPRenewal NPEmails" <IPRenewal.NPEmails@nrc.gov>
Tracking Status: None "Waters, Roger M." <rwater1@entergy.com>
Tracking Status: None Post Office:
HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 333 7/2/2013 4:42:17 PM Telecon Summary 07-02-13 May 6th Change to MEB Program.docx 36180 Options Priority:
Standard Return Notification:
No Reply Requested:
No Sensitivity:
Normal Expiration Date:
Recipients Received:
LICENSEE:
Entergy Nuclear Operations, Inc.
FACILITY:
Indian Point Nuclear Generating Unit Nos. 2 and 3
SUBJECT:
SUMMARY
OF CONFERENCE CALL HELD ON JULY 2, 2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING MAY 6, 2013 LETTER REGARDING CHANGES TO METAL ENCLOSED BUS INSPECTION PROGRAM FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. held a telephone conference call on July 2, 2013, to discuss and clarify the staffs draft request for additional information (D-RAI) concerning changes made to the Metal Enclosed Bus (MEB) Inspection Program in the Indian Point Nuclear Generating Unit Nos.
2 and 3, license renewal application. The telephone conference call was useful in clarifying the intent of the staffs D-RAI.
provides a listing of the participants and Enclosure 2 contains the D-RAI item discussed with the applicant, including a brief description on the status of the item.
The applicant had an opportunity to comment on this summary.
Kimberly J. Green, Sr. Mechanical Engineer Aging Management of Plant Systems Branch Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286
Enclosure:
List of Participants cc w/encl: Listserv
- concurrence via e-mail OFFICE LA: DLR/RPB1*
PM: DLR/RAPB BC: RPB1:DLR LA: DLR/RPB1 PM: DLR/RAPB NAME KGreen YDiaz KGreen DATE
SUBJECT:
SUMMARY
OF CONFERENCE CALL HELD ON JULY 2, 2013, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND ENTERGY NUCLEAR OPERATIONS, INC., CONCERNING MAY 6, 2013 LETTER REGARDING CHANGES TO METAL ENCLOSED BUS INSPECTION PROGRAM FOR INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 DISTRIBUTION:
HARD COPY:
DLR RF E-MAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRerb Resource RidsNrrDlrRpob Resource RidsNrrDciCvib Resource RidsNrrDciCpnb Resource RidsNrrDraAfpb Resource RidsNrrDeEmcb Resource RidsNrrDeEeeb Resource RidsNrrDssSrxb Resource RidsNrrDssSbpb Resource RidsNrrDssScvb Resource RidsOgcMailCenter Resource YDiaz GMeyer, RI KGreen JTrapp, RI DNguyen DJackson, RI CDoutt DScrenci, RI OPA DPickett PCataldo, RI STurk, OGC NMcNamara, RI BMizuno, OGC BWelling, RI SBurnell, OPA KDunham, RI DMcIntyre, OPA MCatts, RI EDacus, OCA MHalter, RI NSheehan, RI OPA SStewart, RI APatel, RI
ENCLOSURE 1 TELEPHONE CONFERENCE CALL INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS JULY 2, 2013 PARTICIPANTS:
AFFILIATIONS:
Kim Green U.S. Nuclear Regulatory Commission (NRC)
Duc Nguyen NRC Cliff Doutt NRC Roger Waters Entergy Nuclear Operations, Inc. (Entergy)
Charlie Caputo Entergy John Curry Entergy Dave Lach Entergy Alan Cox Entergy Roger Rucker Entergy Steve Manzione Entergy Peter Guglielmino Entergy Jeff Cottam Entergy
ENCLOSURE 2 DRAFT REQUEST FOR ADDITIONAL INFORMATION INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3 LICENSE RENEWAL APPLICATION JULY 2, 2013 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Entergy Nuclear Operations, Inc. held a telephone conference call on July 2, 2013, to discuss and clarify the following draft request for additional information (D-RAI) concerning recent changes to the Metal Enclosed Bus Inspection Program in the Indian Point Nuclear Generating Unit Nos. 2 and 3 license renewal application (LRA).
D-RAI 3.0.3.2.11-1
Background:
On April 23, 2007, Entergy Nuclear Operations, Inc. (Entergy or the applicant) applied for renewal of the operating licenses for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3). The Metal Enclosed Bus (MEB) Inspection Program is described in license renewal application (LRA) Section B.1.20 and includes an enhancement to revise appropriate procedures to add the 480V MEB associated with Substation A to the scope of the program.
This enhancement is also reflected in the LRA Updated Final Safety Evaluation Report (UFSAR) Section A.2.1.19. Entergy considered this bus to be within the scope of license renewal because it provides ac power to the IP2 diesel fire pump (DFP).
By letter dated May 6, 2013, Entergy stated that it is making a change to the LRA regarding the MEB Inspection Program and the associated regulatory commitments. Specifically, based on a recent evaluation, Entergy determined that the 480V bus is not used for starting the DFP, but it is used to maintain batteries in a charged state, which in turn provide dc power for starting the DFP and power instrumentation. Entergy stated that any loss of the 480V bus associated with Substation A would initiate an automatic start of the DFP via the batteries. Therefore, the 480V MEB associated with Substation A does not perform a license renewal intended function and thus, Entergy is removing the 480V MEB from the scope of program.
Issue:
10 CFR 54.4(a)(3) requires, in part, that all systems, structures, and components relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commissions regulation for fire protection (10 CFR 50.48) are within the scope of license renewal. This is iterated in Section 2.1.3.1.3 of NUREG-1800, Revision 1, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, which includes the following example:
if an NSR diesel generator is required for safe shutdown under the fire protection plan, the diesel generator and all SSCs specifically relied upon for that generator to comply with NRC regulations shall be included within the scope of license renewal under 10 CFR 54.4(a)(3). Such SSCs may include, but should not be limited to, the cooling water system or systems relied upon for operability, the diesel support pedestal, and any applicable power supply cable specifically relied upon for safe shutdown in the event of a fire.
The DFP is relied upon to demonstrate compliance with the Commissions regulation for fire protection, and therefore, is within the scope of license renewal. The staff considers the MEB associated with 480V Substation A to be within the scope of license renewal because it provides ac power to the chargers to maintain the DFP batteries at full charge. The fully charged batteries will be able to start the DFP during the fire events. It appears that if the 480V MEB is not part of an aging management program, the batteries which start the DFP may become depleted and unable to perform their intended function.
Request:
Provide a technical justification for why the 480V MEB Substation A is not relied upon for the DFP to demonstrate compliance with NRC regulations.
Discussion During the call, the staff explained that it does not necessarily have the current licensing basis documents that describe the function and operation of the diesel fire pump and associated support equipment since the technical specifications related to fire protection were removed from plants technical specifications. Although Entergy explained in its May 6, 2013 letter that failure of the 480V Substation A causes the DFP to automatically start, the staff does not have enough information to understand how that occurs, the charging and maintenance of the batteries, or how the applicant knows if the batteries are not fully charged. Therefore, the staff agreed to revise the request as noted below.
Request:
Provide a technical justification for why the 480V MEB Substation A is not relied upon for the DFP to demonstrate compliance with NRC regulations. Please refer to any applicable documents or statements in your current licensing basis to support your justification.