NL-04-025, Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process

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Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process
ML040760788
Person / Time
Site: Indian Point 
(DPR-064)
Issue date: 03/09/2004
From: Kansler M
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-04-025
Download: ML040760788 (11)
v • d • e


Text

'-- Ente-rgy Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler President March 09, 2004 NL-04-025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D. C. 20555-0001

SUBJECT:

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITION B OF TECHNICAL SPECIFICATION 3.5.1, "ACCUMULATORS," USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

Dear Sir:

In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Entergy Nuclear Operations, Inc. (ENO) is submitting a request for an amendment to the technical specifications (TS) for Indian Point 3.

The proposed amendment would extend the completion time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Condition B of Technical Specification (TS) 3.5.1, "Accumulators." The change is consistent with NRC approved Industry/Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-370, "Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants." The availability of this technical specification improvement was announced in the Federal Register on March 12, 2003 as part of the consolidated line item improvement process (CLIIP). provides a description of the proposed change and confirmation of applicability. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Attachment 3 provides the existing TS Bases pages marked-up to reflect the proposed change (for information only).

ENO requests approval of the proposed license amendment by September 10, 2004, with the amendment being implemented within 60 days of approval.

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7 Page 2 In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated New York State Official.

There are no new commitments identified in this letter. If you have any questions, please contact Ms. Charlene Faison at 914-272-3378.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 03/°07/S Very trulys yo Presi d

Entergy Nuc ear Operations, Inc.

Attachments: 1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-Up)
3. Proposed Technical Specification Bases Changes (Mark-Up) cc:

Mr. Patrick D. Milano, Sr. Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8-C2 Washington, DC 20555-0001 Mr. Hubert Miller Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Peter Smith Acting President New York State Energy, Research and Development Authority Corporate Plaza 286 Washington Avenue Extension Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire Plaza Albany, NY 12223 Sr. Resident Inspector's Office Indian Point 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan. NY 10511

ATTACHMENT 1 APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITION B OF TECHNICAL SPECIFICATION 3.5-1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS

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DESCRIPTION AND ASSESSMENT ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

Attachment I to NL-04-025 Docket No. 50-286 Page 1 of 2 Description and Assessment

1.0 DESCRIPTION

The proposed License amendment extends the completion time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for Condition B of Technical Specification (TS) 3.5.1, "Accumulators."

The changes are consistent with NRC approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-370, "Risk Informed Evaluation of an Extension to Accumulator Completion Times for Westinghouse Plants." The availability of this technical specification improvement was announced in the Federal Register on March 12,2003 as part of the consolidated line item improvement process (CLIIP).

2.0 ASSESSMENT

2.1 Applicabilitv of Published Safety Evaluation Entergy Nuclear Operations Inc. (ENO), has reviewed the safety evaluation published on July 15,2002 (67 FR 46542) as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-370 (i.e.,

WCAP-15049-A, "Risk-Informed Evaluation of an Extension to Accumulator Completion Times," dated May 18, 1999). ENO has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Indian Point 3 and justify this amendment for the incorporation of the changes to the Indian Point 3 Technical Specifications.

2.2 Optional Changes and Variations ENO is not proposing any variations or deviations from the technical specification changes described in TSTF-370 or the NRC staff's model safety evaluation published on July 15, 2002.

S1 to NL-04-025 Docket No. 50-286 Page 2 of 2

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Determination ENO has reviewed the proposed no significant hazards consideration determination published on July 15, 2002 (67 FR 46542) as part of the CLIIP. ENO has concluded that the proposed determination presented in the notice is applicable to Indian Point 3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

3.2 Verification and Commitments There are no new regulatory commitments associated with this proposed change.

4.0 ENVIRONMENTAL EVALUATION ENO has reviewed the environmental evaluation included in the model safety evaluation published on July 15,2002 (67 FR 46542) and as part of the CLIIP. ENO has concluded that the NRC staffs findings presented in that evaluation are applicable to Indian Point 3 and the evaluation is hereby incorporated by reference for this application.

ATTACHMENT 2 APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITION B OF TECHNICAL SPECIFICATION 3.5-1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

TS PAGE 3.5.1.1 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

Accumulators 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Four ECCS accumulators shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2, MODE 3 with reactor coolant system pressure > 1000 psig.

NOTES..-------.-.---.--.

1.

In MODE 3. all accumulator discharge isolation valves may be closed and energized for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> during the performance of reactor coolant system hydrostatic testing.

2.

In MODE 3. one accumulator discharge isolation valve may be closed and energized for up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for accumulator check valve leakage testing.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One accumulator inoperable A.1 Restore boron 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> due to boron concentration concentration to within not within limits of SR limits of 3.5.1.4.

SR 3.5.1.4.

B. One accumulator inoperable B.1 Restore accumulator to Z

ur o for reasons other than OPERABLE status.

Condition A.

(continued)

INDIAN POINT 3 3.5.1-1 Amendment 205

ATTACHMENT 3 APPLICATION FOR TECHNICAL SPECIFICATION IMPROVEMENT TO EXTEND THE COMPLETION TIME FOR CONDITION B OF TECHNICAL SPECIFICATION 3.5-1, "ACCUMULATORS", USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

BASES PAGES B 3.5.1-7 B 3.5.1-9 B 3.5.1 -10 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT 3 DOCKET NO. 50-286

Accumulators B 3.5.1 BASES ACTIONS A.1 (continued) the core subcritical. One accumulator below the minimum boron concentration limit, however, will have no effect on available ECCS water and an insignificant effect on core subcriticality during reflood. Boiling of ECCS water in the core during reflood concentrates boron in the saturated liquid that remains in the core.

In addition, current analysis techniques demonstrate that the accumulators do not discharge following a large main steam line break.

Even if they do discharge, their impact is minor and not a design limiting event.

Thus, 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is allowed to return the boron concentration to within limits.

,i hour'an this Condition, the required contents of three

(,it Y,accumulators cannot be assumed to reach the core during a LOCA.

Due to the severity of the consequences should.a LOCA occur in these conditions, theohour Completion Time to open the valve, remove powerto the valve, or restore the proper water volume or nitrogen cover pressure ensures that prompt action will be taken to return the

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inoperable accumulator to OPERABLE status.

The Completion Time minimizes the potential for exposure of the plant to a LOCA under If the accumulator cannot be returned to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LCO does not apply.

To achieve this status, the plant must be brought to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reactor coolant pressure reduced to < 1000 psig within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

(continued)

INDIAN POINT 3 B 3.5.1 - 7 Revision 0

Accumulators B 3.5.1 BASES SURVEILLANCE REQUIREMENTS SR 3.5.1.4 (continued) inleakage. Sampling the affected accumulator within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after an increase of 8.4 cubic feet will identify whether inleakage has caused

,a reduction in boron concentration to below the required limit.

Considering the nominal accumulator volume of 795 cubic feet of water, inleakage of 8.4 cubic feet of pure water would result in a boron concentration reduction of approximately 1X.

An increase in the accumulator volume of 8.4 cubic feet causes a change of approximately 10% in the indicated accumulator level.

It is not necessary to verify boron concentration if the added water inventory is from the refueling water storage tank (RWST).

because the water contained in the RWST is within the accumulator boron concentration requirements.

This is consistent with the recommendation of NUREG-1366 (Ref.(&.

SR 3.5.1.5 Verification every 31 days that power is removed from each accumulator discharge isolation valve operator when the reactor coolant system pressure is > 2000 psig ensures that an active failure could not result in the undetected closure of an accumulator motor operated isolation valve.

If this were to occur, only two accumulators would be available for injection given a single failure coincident with a LOCA. Since power is removed under administrative control, the 31 day Frequency will provide adequate assurance that power is removed.-

This SR allows power to be supplied to the motor operated discharge isolation valves when reactor coolant system pressure is < 2000 psig.

thus allowing operational flexibility by avoiding unnecessary delays to manipulate the breakers during plant startups or shutdowns.

Should closure of a valve occur, the SI signal provided to the valves would open a closed valve in the event of a LOCA.

(continued)

INDIAN POINT 3 B 3.5.1 - 9 Revision 0

Accumulators B 3.5.1 BASES (continued)

REFERENCES

1.

FSAR, Chapter 6.

2.

10 CR 50.46.

3.

FSAR. Chapter 14.

@NUREG-1366. February 1990.

9.

ca, P - tr A.e v INDIAN POINT 3 B 3.5. 1 -10 Revision 0

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