ML080080319

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Issuance of Amendment Changes to Technical Specifications to Replace Trisodium Phosphate Buffer with Sodium Tetraborate
ML080080319
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 02/07/2008
From: Boska J
NRC/NRR/ADRO/DORL/LPLI-1
To: Balduzzi M
Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MD7182, FOIA/PA-2016-0148
Download: ML080080319 (14)


Text

February 7, 2008 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: CHANGES TO TECHNICAL SPECIFICATIONS TO REPLACE TRISODIUM PHOSPHATE BUFFER WITH SODIUM TETRABORATE (TAC NO. MD7182)

Dear Mr. Balduzzi:

The Commission has issued the enclosed Amendment No. 253 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 (TS) in response to your application dated October 24, 2007.

The amendment revises TS 3.6.7 Recirculation pH Control System to replace the trisodium phosphate buffer with sodium tetraborate to minimize the potential for sump screen blockage under post-loss-of-coolant accident conditions.

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. 253 to DPR-26
2. Safety Evaluation cc w/encls: See next page

February 7, 2008 Mr. Michael A. Balduzzi Sr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: CHANGES TO TECHNICAL SPECIFICATIONS TO REPLACE TRISODIUM PHOSPHATE BUFFER WITH SODIUM TETRABORATE (TAC NO. MD7182)

Dear Mr. Balduzzi:

The Commission has issued the enclosed Amendment No. 253 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 (TS) in response to your application dated October 24, 2007.

The amendment revises TS 3.6.7 Recirculation pH Control System to replace the trisodium phosphate buffer with sodium tetraborate to minimize the potential for sump screen blockage under post-loss-of-coolant accident conditions.

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. 253 to DPR-26
2. Safety Evaluation cc w/encls: See next page Package No.: ML080420212 Amendment No.: ML080080319 Tech Spec No.: ML080420216
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for AHiser MScott STurk MKowal DATE 1/25/08 1/28/08 12/21/07 1/28/08 1/30/08 2/07/08 Official Record Copy

DATED: February 7, 2008 AMENDMENT NO. 253 TO FACILITY OPERATING LICENSE NO. DPR-26 INDIAN POINT UNIT 2 PUBLIC LPL1-1 R/F RidsOGCRp RidsNrrDorlLpl1-1 GHill (2) (paper copies)

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RidsNrrPMJBoska ECobey, RI cc: Plant Mailing list

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Michael R. Kansler President & CEO / CNO Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. Vice President Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Sr. Vice President Engineering & Technical Services Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Anthony Vitale - Acting General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249 Mr. Oscar Limpias Vice President Engineering Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. Joseph P. DeRoy Vice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. John A. Ventosa GM, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Ernest J. Harkness Director, Oversight Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. Patric W. Conroy Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Robert Walpole Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249 Mr. William C. Dennis Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

Indian Point Nuclear Generating Unit No. 2 cc:

Mr. Paul Tonko President and CEO New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. John P. Spath New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector=s Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. William DiProfio PWR SRC Consultant 48 Bear Hill Road Newton, NH 03858 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001 Mr. Phillip Musegaas Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524 Mr. Sherwood Martinelli FUSE USA via email

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. 253 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 October 24, 2007, 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. 253, are hereby incorporated in the license. ENO 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 prior to entry into Mode 4 following completion of the spring 2008 refueling outage.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: February 7, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 253 FACILITY OPERATING LICENSE NO. DPR-26 DOCKET NO. 50-247 Replace the following page of the License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3

3 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3.6.7-1 3.6.7-1

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 253 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 October 24, 2007, Agencywide Documents Access and Management System (ADAMS) Accession No. ML073040292, Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Indian Point Nuclear Generating Unit No. 2 (IP2)

Technical Specifications (TS). The proposed change would replace the containment building sump buffer, currently trisodium phosphate (TSP), with sodium tetraborate (STB).

2.0 REGULATORY EVALUATION

The Nuclear Regulatory Commission (NRC ) staff review addresses the impact of the proposed change from TSP to STB on the containment sump performance, especially potential chemical effect impact on sump screen blockage and head loss during the recirculation phase of a loss-of-coolant accident (LOCA).

There are two sumps in the containment building at IP2, known as the recirculation sump and the containment sump. In this document they will be referred to as containment sumps. Both sumps are part of the emergency core cooling system (ECCS). Every nuclear power plant is required by Section 50.46 of Title 10 of the Code of Federal Regulations (10 CFR) to have an ECCS to mitigate a design-basis accident. 10 CFR 50.46(a)(1)(i) states in part, that each pressurized light-water nuclear power reactor... must be provided with an emergency core cooling system (ECCS) that must be designed so that its calculated cooling performance following postulated loss-of-coolant accidents conforms to the criteria set forth in paragraph (b) of this section. 10 CFR 50.46(b)(5), Long-term cooling, states After any calculated successful initial operation of the ECCS, the calculated core temperature shall be maintained at an acceptably low value and decay heat shall be removed for the extended period of time required by the long-lived radioactivity remaining in the core.

In addition, the NRC staff utilized the following regulatory guidance in performing this review:

NUREG-0800, Section 6.5.2, Containment Spray as a Fission Product Cleanup System, which states, in part, that long-term iodine retention may be assumed only when the equilibrium sump solution pH, after mixing and dilution with the primary coolant and ECCS injection, is above 7.

Regulatory Guide 1.82, Revision 3, Water Sources for Long-Term Recirculation Cooling Following a Loss-of-Coolant Accident, Section 1.1.2, which states, in part, that debris that could accumulate on the sump screen should be minimized.

3.0 TECHNICAL EVALUATION

This IP2 amendment removes TSP from containment. Current IP2 containment materials include sources of phosphate (from the TSP) and calcium (from insulation materials). The combination of these materials is expected to form a calcium phosphate precipitate in a post-LOCA containment pool.

NRC and the nuclear industry jointly sponsored Integrated Chemical Effects Tests (ICET) to investigate potential chemical effects in representative post-LOCA containment environments.

The ICET series was conducted by Los Alamos National Laboratory (LANL), at the University of New Mexico. ICET #3 showed that the presence of calcium silicate (cal-sil) insulation and TSP in a simulated post-LOCA containment pool rapidly formed a calcium phosphate precipitate.

NRC Information Notice (IN) 2005-26, Results of Chemical Effects Head Loss Tests in a Simulated PWR Sump Pool Environment, along with IN 2005-26, Supplement 1, Additional Results of Chemical Effects Tests in a Simulated PWR Sump Pool Environment, discussed results from NRC sponsored head-loss testing at Argonne National Laboratory (ANL). These ANL test results showed that substantial head loss can occur if sufficient calcium phosphate is produced in a simulated post-LOCA containment pool and is transported to a pre-existing bed on the containment sump screens. To preclude this occurrence, this IP2 amendment removes TSP from the IP2 containment.

Post-LOCA containment pool buffering is primarily required to reduce the release of iodine fission products from the pool to the containment atmosphere as iodine gas, in order to control the radiological consequences of the accident. Maintaining a pH above 7 prevents significant amounts of iodine, released from fuel failures and dissolved in the recirculation water, from converting to a volatile form and evolving into the containment atmosphere. Since the ability to control pH in a post-LOCA containment pool is affected by removal of TSP, IP2 proposes to use STB as the new buffering agent.

The method of introducing the buffer material to the post-LOCA environment is the same for STB as it is for TSP. The existing four TSP baskets would be used to hold the STB. The licensee confirmed that the baskets are adequately sized to hold the required amount of STB.

The minimum and maximum amounts of STB were determined by the licensee. Their analyses included consideration of minimum and maximum quantities of boron and borated water and the time-dependent post-LOCA sump temperature. The analyses also included radiolysis of air and water, radiolysis of chloride-bearing electrical cable insulation and jacketing, and spilled reactor core inventory. The licensee determined that the minimum amount of STB required to maintain the minimum sump pH of 7.0 is greater than or equal to 8,096 lbs. The NRC staff performed a detailed evaluation to confirm the licensees pH calculations from IP-CALC-07-00129. The NRC staff reviewed the licensees methodology, assumptions, and performed hand calculations to verify the resulting pH value after 30 days. The NRC staffs independent verification demonstrated the containment sump pH would remain above 7 for at least 30 days with the quantities of STB described above.

The NRC staff reviewed the licensees regulatory and technical analyses related to the impact of the proposed change from TSP to STB on containment sump performance, particularly the potential impact from chemical effects on sump screen blockage and head-loss aspects of design-basis accidents. The licensees evaluation determined that STB is an acceptable alternative to TSP based on industry testing of buffers outlined in WCAP-16596-NP, Evaluation of Alternative Emergency Core Cooling System Buffering Agents, and through plant-specific application of the chemical model developed in WCAP-16530-NP, Evaluation of Post-Accident Chemical Effects in Containment Sump Fluids to Support [Generic Safety Issue] GSI-191.

Under the existing TSP conditions, the model predicts approximately 738 lbs of chemical precipitates. For the proposed STB condition using conservative values for pH, temperature, and quantities of contributing materials, the model predicts approximately 65 lbs of chemical precipitates. Based on the WCAP-16530-NP model, the switch from TSP to STB results in a reduction in the mass of predicted chemical precipitates of approximately 673 lbs. In addition the switch to STB eliminates the formation of calcium phosphate precipitates which have been shown to have severe head-loss implications at early stages of a simulated post-LOCA event (see NRC IN 2005-26).

The NRC staff finds that changing buffer materials from TSP to STB at IP2 will result in an improved situation from a chemical effects standpoint. However, despite the significant reduction in the total amount of chemical precipitates, the WCAP-16530-NP model still predicts approximately 65 lbs of precipitate under STB conditions. The licensee will still need to demonstrate acceptable ECCS performance under the proposed STB conditions in order to fully resolve GSI-191 for IP2.

Based on verification calculations, the NRC staff finds that replacing the TSP containment sump buffer with STB in the quantities specified by the licensee will provide acceptable containment sump buffering such that the sump pH will be maintained in an acceptable range under LOCA conditions.

Although potential chemical effects exist with the use of STB in the IP2 containment, the NRC staff determined that chemical effects at IP2 will be of lower quantity and will be delayed to a more favorable time with STB compared to TSP. Based on the proper buffering to be provided by STB in the quantities specified and the relative reduction in the mass of chemical precipitates in the case of a LOCA, the NRC staff finds that the replacement of TSP with STB in the quantities specified is acceptable.

The NRC staff will be reviewing the licensees approach to resolving potential chemical effects associated with STB as part of the resolution process for NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors.

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 (72 FR 68211). 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.

Principal Contributor: E. Wong Date: February 7, 2008