NL-07-078, Station Blackout (SBO) / Appendix R Diesel Generator Commitment, Response to NRC Review Status of License Renewal Application

Station Blackout (SBO) / Appendix R Diesel Generator Commitment, Response to NRC Review Status of License Renewal Application

ML071800318
Person / Time
Site:	Indian Point
Issue date:	06/21/2007
From:	Dacimo F Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-07-078
Download: ML071800318 (5)

Text

Enteray Nuclear Northeast Indian Point Energy Center En e 450 Broadway, GSB E

pI& W P.O. Box 249 Buchanan, NY 10511-0249 Fred Dacimo Site Vice President Tel 914 734 6700 June 21, 2007 Re:

Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 NL-07-078 Document Control Desk U.S. Nuclear Regulatory Commission Mail Stop O-Pl-17 Washington, DC 20555-0001

Subject:

Station Blackout (SBO) I Appendix R Diesel Generator Commitment for Indian Point Nuclear Generating Unit No. 2 in Response to NRC Review Status of License Renewal Application

References:

1. Entergy letter NL-07-039, dated April 23, 2007, License Renewal Application

2. Entergy letter NL-07-056, dated May 3, 2007, Supplement to License Renewal Application

3. NRC letter (Accession No. ML071630049), dated June 18, 2007, Review Status of the License Renewal Application for the Indian Point Nuclear Generating Unit Nos. 2 and 3

Dear Sir or Madam:

By letter dated April 23, 2007, Entergy Nuclear Operations, Inc. (ENO) submitted an application pursuant to 10 CFR Part 54, to renew the Indian Point Nuclear Generating Unit Nos. 2 and 3 (Indian Point Energy Center) operating licenses (Reference 1). ENO supplemented that application by letter dated May 3, 2007 (Reference 2). This letter provides clarifying information to support the NRC review of the Indian Point Energy Center (IPEC) License Renewal Application (LRA).

In a letter dated June 18, 2007, the NRC Staff informed ENO that "certain information is needed for the staff to complete the acceptance review" of the LRA (Reference 3). The Staff believes that the "current licensing basis for Unit 2 was not fully represented in accordance with Part 54.4(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR 54.4(a)(3))." Specifically, "the LRA did not include information on the gas turbines currently credited as an alternate power supply for the Appendix R and SBO events" (Reference 3). The additional information provided 74126

Docket No. 50-247 NL-07-078 Page 2 of 3 in this letter clarifies and supports that the Unit No. 2 current licensing basis (CLB) is fully represented in the LRA consistent with Section 54.4(a)(3).

The LRA includes information on the gas turbine system. Although the gas turbines will not be credited as an alternate power supply to meet Appendix R and SBO requirements during the period of extended operation for purposes of Section 54.4(a)(3), the gas turbine system is included in the scope of license renewal. For purposes of aging management review, the license renewal rule, Section 54.21 (a)(3), requires, "For each structure and component identified in paragraph (a)(1) of this section, demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation." During the period of extended operation, the new SBO/Appendix R diesel generator will be credited to meet Appendix R and SBO requirements for purposes of Section 54.4(a)(3). Consequently, to comply with 54.21, the aging management review in the LRA addresses the SBO/Appendix R diesel generator system.

ENO believes that statements in the LRA (see for example Section 2.1.1.3.5) that the new SBO/Appendix R diesel generator will be credited during the period of extended operation constitute a prospective change in the current licensing basis. The NRC has identified a need to ensure the change in question is clearly incorporated into the IPEC CLB in order to provide the information necessary for NRC to complete its acceptance review of the LRA.

Consistent with our telephone call of June 6, 2007 and the follow-up telephone call of June 11, 2007, ENO provides the following commitment:

ENO clarifies and supplements Section 2.1.1.3.5 of the LRA with a commitment that the Unit No. 2 SBO/Appendix R diesel generator will be installed and operational by April 30, 2008. This committed change to the facility meets the requirements of 10 CFR 50.59 (c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.

One new commitment is being made in this letter (Attachment 1). If you have any questions, please contact Mr. T.R. Jones, Manager, Licensing at (914) 734-6670.

Sin Fred R. Dacimo Site Vice President Indian Point Energy Center

Docket No. 50-247 NL-07-078 Page 3 of 3 Attachments:

1.

SBO / Appendix R Diesel Generator Commitment cc:

Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector's Office, IPEC Mr. Peter R. Smith, President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-07-078 SBO I Appendix R Diesel Generator Commitment ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

Docket No. 50-247 NL-07-078 Page 1 of 1 Commitment for Indian Point Nuclear Generating Unit No. 2 SBO/Appendix R Diesel Generator ID DESCRIPTION:

DATE NL-07-078-CO1 ENO clarifies and supplements Section 2.1.1.3.5 of the April 30, 2008 LRA with a commitment that the Unit No. 2 SBO/Appendix R diesel generator will be installed and operational by April 30, 2008. This committed change to the facility meets the requirements of 10 CFR 50.59 (c)(1) and, therefore, a license amendment pursuant to 10 CFR 50.90 is not required.