NL-04-158, Supplement to Proposed Change to Technical Specifications Regardinq Full Scope Adoption of Alternate Source Term

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Supplement to Proposed Change to Technical Specifications Regardinq Full Scope Adoption of Alternate Source Term
ML043630313
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 12/15/2004
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-04-158, TAC MC3351
Download: ML043630313 (10)
v • d • e


Text

'En tergy Entergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB PO. Box 249 Buchanan, NY 10511-0249 Tel 9147346700 Fred Dacimo Site Vice President Administration December 15, 2004 Re:

Indian Point Unit No. 3 Docket No. 50-286 NL-04-158 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

References:

Supplement to Proposed Change to Technical Specifications Regardinq Full Scope Adoption of Alternate Source Term (TAC No. MC3351)

1) Entergy letter NL-04-068 to NRC, "Proposed Change to Technical Specifications Regarding Full Scope Adoption of Alternate Source Term", dated June 2, 2004.
2) Entergy letter NL-04-138 to NRC, "Proposed License Amendment Regarding Control Room Ventilation System", dated October 26, 2004

Dear Sir:

The purpose of this letter is to supplement the proposed amendment to the Operating License for Indian Point Nuclear Generating Unit No. 3 (IP3) regarding the full scope adoption of alternate source term (AST) (Reference 1). In order to adopt AST, it is necessary to modify the Control Room Ventilation System (CRVS) to enable it to be operated in new configurations for Control Room Habitability. This modification will be installed prior to the next scheduled refueling outage. Reference 2 submitted a request to place the CRVS in the new modified configuration to permit tracer gas testing, to temporarily leave the CRVS in that configuration until the upcoming refueling outage, and to credit protective actions for control room operators in the event unfiltered in-leakage based on tracer gas testing exceeds current analysis assumptions. Additional Technical Specification changes are included herein to make permanent the change requested in Reference 2, and to reflect changes to the Control Room Ventilation System and implementation of the Alternate Source Term as contained in Reference 1.

,D-D )

NL-04-158 Docket No. 50-286 Page 2 of 5 The additional changes consist of the following:

  • Technical Specification Surveillance Requirement SR 3.7.11.4 - change from

"' 400 cfm" to "> 1500 cfm".

This Technical Specification change adopts the > 1500 CFM makeup flow rate criterion contained in Reference 1, which is part of the modification for the CRVS for Control Room Habitability. This is the mode that provides the greatest benefit to dose reduction for the control room operators and is consistent with the Reference 1 analyses. This change effectively makes permanent the change requested in Reference 2.

change from "10% incident mode" to "CRVS Mode 3".

  • Technical Specification Surveillance Requirement SR 3.7.11.4 - change from 'the 10% incident mode of" to "CRVS Mode 3".
  • Bases pages B 3.7.11-2 and B 3.7.11-8 are included for information, and revise text as appropriate to reflect the dose evaluation for the alternate source term contained in Reference 1. Additional bases changes to support the proposed AST amendment will be made under the 50.59 process upon issuance of the license amendment.

The current licensing basis design and operating configuration of the CRVS is described in Section 9.9 of the FSAR and in Section 3.7.11 of the Technical Specification Bases.

The current licensing basis dose analysis for control room operators is described in Section 14.3.5 of the FSAR.

Entergy intends to modify the operating configuration of the CRVS.

The current configuration of the control room ventilation system has 4 modes of operation. CRVS Mode 1 is 'Off, the system is shut down. CRVS Mode 2 is 'Normal',

the system supplies a mixture of conditioned return air (from the Control Room) and outside air. In CRVS Mode 3 ("10% Incident Mode"), the system takes a portion of the return air from the Control Room, mixes it with outside air before going through a

NL-04-1 58 Docket No. 50-286 Page 3 of 5 Charcoal Filter Unit and then supplies it to the Control Room after conditioning. In CRVS Mode 4 ("100% Incident Mode"), the system takes a portion of the return air, directs it through the Charcoal Filter Unit, and then supplies it to the Control Room after conditioning (there is no outside air supplied). CRVS Mode 3 is used for radiological release events and CRVS Mode 4 is used for hazardous chemical release events, although the Charcoal Filtering Unit is not credited for hazardous chemical removal in the event analysis.

Changes to the current configuration are for operation in CRVS Modes 3 and 4. For CRVS Mode 3, recirculation through the filtration system is being eliminated. Also for CRVS Mode 3, the filtered make-up flow through the filtration system is being increased from < 400 CFM to > 1500 CFM to be consistent with the analysis contained in Reference 1. For CRVS Mode 4, recirculation through the filtration system is also being eliminated.

The new configuration of the control room ventilation system will have 4 modes of operation. CRVS Mode 1 is 'Off, the system is shut down. CRVS Mode 2 is 'Normal',

the system supplies a mixture of conditioned return air (from the Control Room) and outside air. CRVS Mode 3 (known as "10% Incident Mode") will provide pressurization of the Control Room by directing all outside air through a Charcoal Filter Unit and then supplying it to the Control Room after conditioning. CRVS Mode 4 (redesignated to "100% Recirculation Mode") will continue to be used for hazardous chemical release events. The system will not take in any outside air and there will be no flow through the Charcoal Filter Unit.

The "no significant hazards consideration" submitted with Reference 1 is unchanged by this amendment request because the dose calculations performed assumed the value of makeup flow rate being requested herein. Further, there is no impact on the "no significant hazards consideration" that was submitted with Reference 2 for the temporary change because the value of the makeup flow rate herein is the same as was requested.

A copy of this application and the associated attachments are being submitted to the designated New York State official.

Entergy requests approval of the proposed amendment by March 15, 2005 to support the schedule for implementation of modifications to the CRVS for Control Room Habitability. Further, the time between the issuance of the license amendment and the implementation date is requested to be 30 days.

NL-04-1 58 Docket No. 50-286 Page 4 of 5 There are no new commitments contained in this letter. If you have any questions or require additional information, please contact Mr. Patric W. Conroy at 914-734-6668.

I declare under penalty of perjury that the foregoing is true and correct. Executed on Sity Fred R. Dacimo Site Vice President Indian Point Energy Center Attachments:

1. Proposed Technical Specification Changes (markup)

NL-04-158 Docket No. 50-286 Page 5 of 5 cc:

Mr. Patrick D. Milano Senior Project Manager, Project Directorate I Division of Licensing Project Management Office of Nuclear reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop O-8-C2 Washington, D.C. 20555-0001 Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Mr. Peter R. Smith President, New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-6399

ATTACHMENT I to NL-04-158 Markup of Technical Specification and Bases Pages for Proposed Changes Regarding Control Room Ventilation System Entergy Nuclear Operations, Inc.

Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286

CRVS Actuation Instrumentation 3.3.7 3.3 INSTRUMENTATION 3.3.7 Control Room Ventilation System (CRVS) Actuation Instrumentation LCO 3.3.7 The CRVS actuation instrumentation for each Function in Table 3.3.7-1 shall be OPERABLE.

APPLICABILITY:

MODES 1. 2. 3. and 4 ACTIONS Condition y

NOr E........................

ec F Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Place CRVS in *6* CA'S 7 days with one channel or train incident midc.

inoperable.

/mode 3 B. One or more Functions B.1.

Place CRVS in-}6* CRVs 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with two channels or two

-inidefntmode-.

trains inoperable.

('ode. 3 C. Required Action and C.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time for Condition A or B AND not met.

C.2 Be in'MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> INDIAN POINT 3 3.3.7-1 Amendment 205

CRVS 3.7.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 Operate each CRVS train for > 15 minutes.

31 days SR 3.7.11.2 Perform required CRVS filter testing in In accordance accordance with the Ventilation Filter Testing with VFTP Program (VFTP).

SR 3.7.11.3 Verify each CRVS train actuates on an actual or 24 months simulated actuation signal.

SR 3.7.11.4 Verify one CRVS train can maintain a slight 24 months on a positive pressure relative to the adjacent STAGGERED TEST enclosed area during the 10 incident mode of CRV5 BASIS Mnode 5 operation at a makeup flow rate of-_ 400 cfm.

Ž1500 INDIAN POINT 3 3.7.11-2 Amendment 205

'- Venhleza'ov'

-5 f(ovidd e

CQ'

%ha outs)de afr deavlo hfw Da'tr 4 J~tivi 6j -4e ofeOrrt d

( Ch c2S CRVS a n (s) anlJ.he et/Ixh','(crxi esha-B 3.7.11 a-.n; fans and approximatcly 156 (1500 cfm) unfiltered outside air mnoeu-4r

-Jenialo rn a

fes plzvfii~ov b)olncident mode with outside air makeup (i-.e-.10% incident mode)

CCR Viladw 4r4cg z4sit ofapomately 8?'i (9259 cfm) unfiltered reeireulated del aecl oLA2JeoawrJ n 4(ivZ y floew driven by the twa soafety related air-canditioning fans, at DaerB

, viby, 4ihe o e ihon least 10% (o 1000 cfim) filtered recirculated flow driven by oP4A-C r/CS fanv6) atc ;+s cither one of the twe filter booster fans and 35 to 400 cfm afoc

-h'dmr-bseavio; F1isltoo~lts.Ueair makcup,

_(R 5 Inohde t ent mode with no outside air makeup (i.e. 100% ine4dent f(ercuvatron i

rri,s mode6ee ;s ro mode cansists of 85 (9C100 cfm) unfiltcred recirculated flow VeI4;1aon p(OV-ed 4o 4e ha 864h A aed '

Dayws toyclosed appraimataly 1;S filtered recirculated flow driven by cither qnThe onk os C,

S onc of thc two filter beestcr fans and no cutsidc air makeup.

Notc that thc required recirculation rates arc demonstrated with C,~,qCSsW ryill ne tests eendueted with the air eanditiening system (CRACS) operating. An ineperable CRACS fan will affcet the flow balamee of the CRYS due te intereAnneeted duetwerk. Therefere, if the fan asseciated with onc of the air conditioning units gevcrncd by LCO 3.7.12 is ineperable, Canditios in beth 6CO 3.7.11, Ccntreal Refflm Vcntilation System, and LCO 3.7.12, Control Room Air Conditioning System (CRACS), will apply.

respi'e CRVS Poe 3 (

air makeup is the p4fefrred method of ncc t ^iode)

--- ~

operation during any radiological event because it provides outside air for pressurization of the Control Room.

Calculations indicatc that wery l*aw fJowrates (c.g. 35 cfm) of v

utsidc air makeup nill maintain the Control A nom at a slight pasitivc pressurc.

Nevertheless, due to the difficulty of adjusting and maintaining th-a flow dampers to providc a low flew, the dampers arc typically adjuetd to preyide a flew ef appreximately 250 efmn (2.5% eutside

  • ~~-1 X_-A-

^ ~._+.^..

r e

ro.m m..s AZ air makcup).

Howevcr, a high. r volumc nf nt-idr air jakaup to h4 as becn demorvA1?fed vsu-

  • s8

, 46a ;"creasec p{eSrV't;Z{441'0 help5 afenaite un4\\~^ in11kqV4 et (continued)

INDIAN POINT 3 B 3.7.11 - 2 Revision 2

CRVS B 3.7.11 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.11.3 This SR verifies that each CRVS train starts and operates on an actual or simulated actuation signal.

The Frequency of 24 months is based on operating experience which has demonstrated this Frequency provides a high degree of assurance that the booster fans will operate and dampers actuate to the correct position when required.

SR 3.7.11.4 This SR verifies the integrity of the control rod enclosure, and the assumed inleakage rates of the potentially c taminated air.

The control room positive pressure, with respect o potentially contaminated adjacent areas, is periodically test d to verify proper functioning of the CRVS. During +he-operation i the incident made

-wi-th--eutside air ma R (i.e. 10% incident mode), the CRVS is designed to maintain the control room at a slight positive Dressur with respect to adjacent areas in order to unfiltered e

inleakage.

The CRVS i:

dcsigned to maintain this positive pressure with very low.olumes of outside air makeup.

Due to the difficulty of adjusting and maintaining the flow dampers to provide a low flow, it was determind that the damper sheuld be adjusted to provide-a-flow of approximately 250 cfm (2.5°6 outsidc air makeup).

Note that the higher the volume of outside air makeup to the Control

-oom, the higher the thyroid dose to the operators during an accidcnt.

The (CsFCYvI~f j15c0D acceptance criteria of 100 cfm (4.0; outside air makeup) is the used in the Control Room dose assessment.

The SR Frequency of 24 months on a staggered test basis is acceptable because operating experience has demonstrated that the control room boundary is not normally disturbed. Staggered testing is acceptable because the SR is primarily a verification of Control Room integrity because fan operation is tested elsewhere.

(continued)

INDIAN POINT 3 B 3.7.11 - 8 Revision 2

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