ML060660297

License Amendment, Amendment Revises Pressurizer Level Limit in Mode 3

ML060660297
Person / Time
Site:	Indian Point
Issue date:	03/22/2006
From:	Boska J NRC/NRR/ADRO/DORL/LPLA
To:	Kansler M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MC7061, FOIA/PA-2016-0148
Download: ML060660297 (13)

Text

March 22, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: PRESSURIZER LEVEL LIMIT IN MODE 3 (TAC NO.

MC7061)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 246 to Facility Operating License No. DPR-26 for the Indian Point Nuclear Generating Unit No. 2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 25, 2005, as supplemented on January 23, 2006. The amendment revises the TS limit on pressurizer water level in mode 3 (hot standby).

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosures:

1. Amendment No. 246 to DPR-26

2. Safety Evaluation cc w/encls: See next page

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Gary J. Taylor Ms. Charlene D. Faison Chief Executive Officer Manager, Licensing Entergy Operations, Inc. Entergy Nuclear Operations, Inc.

1340 Echelon Parkway 440 Hamilton Avenue Jackson, MS 39213 White Plains, NY 10601 Mr. John T. Herron Mr. Michael J. Columb Senior Vice President and Director of Oversight Chief Operating Officer Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Mr. James Comiotes Mr. Fred R. Dacimo Director, Nuclear Safety Assurance Site Vice President Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 295 Broadway, Suite 1 295 Broadway, Suite 1 P.O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Patric Conroy Mr. Paul Rubin Manager, Licensing General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. Indian Point Energy Center Indian Point Energy Center 295 Broadway, Suite 1 295 Broadway, Suite 2 P. O. Box 249 P.O. Box 249 Buchanan, NY 10511-0249 Buchanan, NY 10511-0249 Mr. Travis C. McCullough Mr. Oscar Limpias Assistant General Counsel Vice President Engineering Entergy Nuclear Operations, Inc.

Entergy Nuclear Operations, Inc. 440 Hamilton Avenue 440 Hamilton Avenue White Plains, NY 10601 White Plains, NY 10601 Ms. Stacey Lousteau Mr. Brian OGrady Treasury Department Vice President, Operations Support Entergy Services, Inc.

Entergy Nuclear Operations, Inc. 639 Loyola Avenue 440 Hamilton Avenue Mail Stop: L-ENT-15E White Plains, NY 10601 New Orleans, LA 70113 Mr. John F. McCann Regional Administrator, Region I Director, Licensing U.S. Nuclear Regulatory Commission Entergy Nuclear Operations, Inc. 475 Allendale Road 440 Hamilton Avenue King of Prussia, PA 19406 White Plains, NY 10601

Indian Point Nuclear Generating Unit No. 2 cc:

Senior Resident Inspectors Office PWR SRC Consultant Indian Point 2 400 Plantation Lane U. S. Nuclear Regulatory Commission Stevensville, MD 21666-3232 P.O. Box 59 Buchanan, NY 10511 Mr. Jim Riccio Greenpeace Mr. Peter R. Smith, President 702 H Street, NW New York State Energy, Research, and Suite 300 Development Authority Washington, DC 20001 17 Columbia Circle Albany, NY 12203-6399 Mr. Phillip Musegaas Riverkeeper, Inc.

Mr. Paul Eddy 828 South Broadway Electric Division Tarrytown, NY 10591 New York State Department of Public Service Mr. Mark Jacobs 3 Empire State Plaza, 10th Floor IPSEC Albany, NY 12223 46 Highland Drive Garrison, NY 10524 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Ray Albanese Executive Chair Four County Nuclear Safety Committee Westchester County Fire Training Center 4 Dana Road Valhalla, NY 10592 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Daniel C. Poole PWR SRC Consultant P.O. Box 579 Inglis, FL 34449 Mr. William T. Russell

March 22, 2006 Mr. Michael R. Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: PRESSURIZER LEVEL LIMIT IN MODE 3 (TAC NO.

MC7061)

Dear Mr. Kansler:

The Commission has issued the enclosed Amendment No. 246 to Facility Operating License No. DPR-26 for the Indian Point Nuclear Generating Unit No. 2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated May 25, 2005, as supplemented on January 23, 2006. The amendment revises the TS limit on pressurizer water level in mode 3 (hot standby).

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

John P. Boska, Senior Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosures:

1. Amendment No. 246 to DPR-26

2. Safety Evaluation cc w/encls: See next page Accession Number: ML060660297 *see SE dated March 2, 2006 OFFICE LPL1-1\PM LPL1-1\LA SPWB/BC ITSB/BC OGC LPL1-1\BC NAME JBoska SLittle JNakoski* TBoyce SUttal RLaufer DATE 3/08/06 3/08/06 3/2/06 3/10/06 3/20/06 3/20/06 Official Record Copy

DATED: March 22, 2006 AMENDMENT NO. 246 TO FACILITY OPERATING LICENSE NO. DPR-26 INDIAN POINT UNIT 2 PUBLIC LPL1-1 R/F RidsOGCMailCenter RidsNrrDorlLpla GHill (2)

RidsNrrDirsItsb RidsAcrsAcnwMailCenter RidsNrrLASLittle RidsNrrPMJBoska ECobey, RI FForsaty cc: Plant Mailing list

ENTERGY NUCLEAR INDIAN POINT 2, LLC ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-247 INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 246 License No. DPR-26

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated May 25, 2005, as supplemented on January 23, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (I) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-26 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 246, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: March 22, 2006

ATTACHMENT TO LICENSE AMENDMENT NO. 246 FACILITY OPERATING LICENSE NO. DPR-26 DOCKET NO. 50-247 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.4.9-1 3.4.9-1 3.4.9.2 3.4.9-2

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 246 TO FACILITY OPERATING LICENSE NO. DPR-26 ENTERGY NUCLEAR OPERATIONS, INC.

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

1.0 INTRODUCTION

By letter dated May 25, 2005 (Reference 1, Agencywide Documents Access and Management System (ADAMS) accession number ML051590186), as supplemented on January 23, 2006 (Reference 2, ADAMS accession number ML060380563), Entergy Nuclear Operations, Inc.

(Entergy or the licensee) submitted a request for changes to the Indian Point Nuclear Generating Unit No. 2 (IP2) Technical Specifications (TSs) to revise the pressurizer water level limit TS for Mode 3 (Hot Standby). The current TS requires the pressurizer to be operable with an indicated water level of less than or equal to 65.1% in Modes 1, 2, and 3. The current pressurizer water level limit will remain unchanged for Modes 1 and 2 (Power Operation and Startup, respectively). The requested amendment will provide additional operating flexibility for performing a plant cooldown. The supplement dated January 23, 2006, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staff's original proposed no significant hazards consideration.

2.0 REGULATORY EVALUATION

The Nuclear Regulatory Commission's (NRC's) regulatory requirements related to the content of the TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications. This regulation requires that a TS Limiting Condition for Operation (LCO) be established for a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. In this regard, pressurizer level is an initial condition for these analyses. Limiting the maximum operating water level preserves the steam space for pressure control and ensures the capability to establish and maintain pressure control for steady state operation and to minimize the consequences of potential overpressure transients.

3.0 TECHNICAL EVALUATION

3.1 Background The pressurizer with a steam vapor space provides a point in the reactor coolant system (RCS) where liquid and vapor are maintained in equilibrium under saturated conditions for pressure control purposes. The pressurizer water level is maintained by a control system that varies level as a function of reactor coolant average temperature. The temperature-dependent water level provides sufficient water in the pressurizer to prevent the pressurizer from emptying on a normal reactor trip from 100% power, while maintaining a sufficient steam space to prevent overfilling the pressurizer with water following an overpressure event, such as loss of load at 100% power.

The current IP2 LCO 3.4.9 specifies the maximum pressurizer water level limit during Modes 1, 2, and 3 operations to ensure that the pressurizer is capable of establishing and maintaining pressure control for steady-state operation and to minimize the consequences of potential overpressure transients. This LCO is an input assumption to the safety analyses performed from a critical reactor condition.

The RCS relies on the Pressurizer Safety Valves (PSVs) for overpressure protection during Modes 1, 2, and 3 operations. Action Item II.D.1 of NUREG-0737, Clarification of TMI Action Plan Requirements, (Reference 5) called for licensees to conduct testing to qualify the RCS relief and safety valves under expected operating conditions for design-basis transients and accidents. Because the IP2 PSVs are not qualified for water relief (Reference 1, Section 5.2),

the PSV overpressure protection operation should be limited to steam relief. Water relief through PSVs could result in a failure of the PSVs to re-close, causing a SBLOCA due to the unisolable PSV opening. This would not comply with the acceptance criteria, stated in Section 15.5.1-15.5.2 of NUREG-0800, Standard Review Plan, that accidents of moderate frequency should not generate a more serious plant condition without other faults occurring independently.

Therefore, the maximum pressurizer water level limit should be such that pressurizer overfill and PSV water relief are avoided during anticipated operational occurrences.

3.2 Proposed TS Change The licensee proposed increasing the pressurizer water level limit for IP2 from indicated 65.1%

to indicated 84% for Mode 3 operation. The licensee stated (Reference 1, Section 4.0) that this higher water level limit in Mode 3 provides additional operational flexibility and efficiency with expected time savings of 1 to 2 hours0.0833 days <br />0.0119 weeks <br />0.00274 months <br /> for performing plant cooldown at or near the maximum allowable rate. This is because the higher water level compensates for reactor coolant contraction and allows greater flexibility for establishing boron concentration required for shutdown margin.

The current TS LCO 3.4.9 requires the pressurizer to be operable with an indicated water level of # 65.1% in Modes 1, 2, and 3. The proposed amendment will retain this limit for Modes 1 and 2, but will establish a limit for indicated water level of # 84% for Mode 3. The proposed amendment covers the following LCO and surveillance requirement (SR):

• Revise LCO 3.4.9, item a, from Pressurizer water level # 65.1% to Pressurizer water level # 65.1% in Modes 1 and 2, or # 84% in Mode 3.

• Revise SR 3.4.9.1 from Verify pressurizer water level is # 65.1% to Verify pressurizer water level is # 65.1% in Modes 1 and 2, or # 84% in Mode 3.

3.3 NRC Staff Evaluation The LCO for pressurizer water level limit is the initial condition in the safety analyses for overpressure events, such as loss of load and loss of normal feedwater. The licensee has indicated (Reference 2, Section B 3.4.9) that the limiting scenario for these accident analyses is with the reactor at full power. The proposed TS change to increase the maximum indicated pressurizer water level limit from 65.1% to 84% applies to Mode 3, hot standby, only.

Therefore, this TS change does not affect the existing requirement for Modes 1 and 2; nor does it affect the validity of the initial condition assumption and the result of the design-basis safety analyses of transients and accidents initiated at power operating conditions.

The NRC staffs evaluation of the revised pressurizer water level limit is based on prevention of pressurizer overfill to avoid PSV water relief for events initiated from Mode 3 operation. The licensee contends that in Mode 3 a higher initial pressurizer level is acceptable because the potential magnitude of a pressurizer insurge due to thermal expansion of the reactor coolant is much smaller than that which would occur in Mode 1 with the plant at full power.

Potential sources of insurge into the pressurizer during Mode 3 results from a Chemical and Volume Control System (CVCS) malfunction that maximizes charging flow or an inadvertent safety injection. In the letter dated May 25, 2005 (Reference 1), the licensee provided an assessment of the time that the operator has to respond to a CVCS malfunction to avoid overfilling the pressurizer when the pressurizer level is at 84% in Mode 3. In the event that a charging pump is operating without letdown, the operator would have more than 20 minutes to respond to that condition. In the unlikely event that all three charging pumps are operating without letdown, the operator would have nearly 8 minutes to respond to the condition.

The licensee also stated that the effect of an inadvertent safety injection on pressurizer water level is limited, because IP2 is a low-head injection plant. The nominal shutoff head of the safety injection pump is 1500 pounds per square inch gage (psig). Therefore, in the event of a safety injection actuation in Mode 3 with pressure above the pump shutoff head, no mass injection would occur and the pressurizer level would not be affected. In the event of a safety injection with RCS pressure below the pump shutoff head, the resulting mass injection would compress the pressurizer steam space and system pressure would increase to the pump shutoff head, at which point additional mass injection and increase in pressurizer level would terminate.

Requirements for fracture toughness for the reactor coolant pressure boundary are specified in 10 CFR 50.60, "Acceptance criteria for fracture prevention measures for lightwater nuclear power reactors for normal operation", which invokes Appendices G and H to 10 CFR Part 50.

The pressure-temperature limits for operating the plant are established, in part, by the operating curves that ensure that the reactor pressure boundary fracture toughness requirement of Appendix G to 10 CFR Part 50 are satisfied. Per TS 3.4.3 pressure-temperature limit curves for cooldown, the fracture toughness requirements in Mode 3 are protected by the PSVs with no operator action required.

Based on the above evaluation, the NRC staff concludes that there is reasonable assurance that the pressurizer overfill and water relief through the PSVs can be avoided in the events of CVCS malfunction or inadvertent safety injection actuation during Mode 3 operation with the

pressurizer water level at the 84% limit. Therefore, the staff concludes that the proposed TS change to increase the pressurizer indicated water level limit for Mode 3 from 65.1% to 84% is acceptable. It should be noted that the proposed change does not affect the pressurizer indicated limit of 65.1% for Modes 1 and 2 operation.

Further, as the purpose of the licensee's amendment request is to support a specific and limited plant evolution (i.e., plant cooldown from Mode 3 to Mode 4), the licensee has committed to implement administrative controls requiring a dedicated operator be assigned for operating and controlling the CVCS, including monitoring pressurizer level, whenever pressurizer level in Mode 3 is above the current TS limit of 65.1%. Specifically, the licensee will revise the TS Bases and the operating procedure for plant cooldown to implement this dedicated operator requirement. To this end, the licensee has made the following commitments:

a. Licensee Commitment No. NL-05-062-A Revise Technical Specification Bases to specify a requirement that a dedicated operator is assigned for operating and controlling the CVCS, including monitoring pressurizer level, whenever pressurizer level in Mode 3 is above the Mode 1 and 2 limit.

b. Licensee Commitment No. NL-05-062-B Revise the operating procedure for plant cooldown from Mode 3 to Mode 4 to implement the requirement for a dedicated operator as stated in the revised Technical Specification Bases.

The licensees administrative processes under its Commitment Management Program will assure proper and timely implementation of these commitments. These commitments provide additional assurance that pressurizer overfill with PSV water relief will be avoided.

The NRC staff has reviewed the license amendment request and has concluded that the proposed change continues to meet the regulatory requirements of 10 CFR 50.36 and there exists reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (70 FR 35736). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0 REFERENCES

1. Entergy letter NL-05-062 to NRC, Proposed Changes to IP2 Technical Specifications Regarding Pressurizer Water Level Requirements, dated May 25, 2005.

2. Entergy letter NL-06-011 to NRC, "Response to Request for Additional Information regarding LAR for Pressurizer Level Requirements" (TAC No. MC7061), dated January 23, 2006.

3. NRC letter to Entergy, regarding request for additional information, TAC No. MC7061, dated October 14, 2005.

4. Indian Point Nuclear Generating Unit No. 3 - Issuance of Amendment Re: Pressurizer Level Limit in Mode 3, TAC No. MB5296, dated March 25, 2003.

5. NUREG-0737, Clarification of TMI Action Plan Requirements.

Principal Contributor: Fred M. Forsaty Date: March 22, 2006