ML102240488

Issuance of Amendment Ventilation Filter Testing Program

ML102240488
Person / Time
Site:	Indian Point
Issue date:	09/13/2010
From:	Boska J Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
FOIA/PA-2016-0148
Download: ML102240488 (13)

Text

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• • • • i' Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO.2 - ISSUANCE OF AMENDMENT RE: VENTILATION FILTER TESTING PROGRAM (TAC NO.

ME2742)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 265 to Facility Operating License No.

DPR-26 for Indian Point Nuclear Generating Unit NO.2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 19, 2009.

The amendment revises the TSs by changing the charcoal testing criteria in TS 5.5.9, "Ventilation Filter Testing Program." 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,

~;:a,~ect Manager a:~t ~iCenSing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-247

Enclosures:

1. Amendment No. 265 to DPR-26

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 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. 265 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 November 19, 2009, 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 (2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 265, 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 within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION 11~ /~h Nancy L. Salgado, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance:

September 13, 2010

ATTACHMENT TO LICENSE AMENDMENT NO. 265 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 5.5-10 5.5-10

- 3 instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

END pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive Amdt. 42 10-17-78 apparatus or components; (5)

END pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

Amdt. 220 09-06-01 C. This amended license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is SUbject to the additional conditions specified or incorporated below:

(1) Maximum Power Level END is authorized to operate the facility at steady state Amdt. 241 reactor core power levels not in excess of 3216 10-27-04 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 265, are hereby incorporated in the license. END shall operate the facility in accordance with the Technical Specifications.

(3) The following conditions relate to the amendment approving the conversion to Improved Standard Technical Specifications:

1. This amendment authorizes the relocation of certain Technical Specification requirements and detailed information to licensee-controlled documents as described in Table R, "Relocated Technical Specifications from the CTS," and Table LA, "Removed Details and Less Restrictive Administrative Changes to the CTS" attached to the NRC staffs Safety Evaluation enclosed with this amendment. The relocation of requirements and detailed information shall be completed on or before the implementation of this amendment.

Amendment No. 265

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.9 Ventilation Filter Testing Program (VFTP) (continued)

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Ventilation Filter Testing Program.

The Required testing shall:

a.

Demonstrate that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Position C.5.c of Regulatory Guide 1.52, Revision 2, March 1978, and ANSI N510-1975, while operating the system at ambient conditions and at a flow rate of 2000 cfm +/-10%.

b.

Demonstrate that an inplace test of the charcoal adsorber shows a penetration and system bypass < 0.05% when tested in accordance with Regulatory Position C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and ANSI N510-1975, while operating the system at ambient conditions and at a flow rate of 2000 cfm +/-10%.

c.

Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and a relative humidity of 95%, and a face velocity of 0.203 m/sec (40 ftlmin).

d.

Demonstrate that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than 6 inches water gauge when tested in accordance with Regulatory Guide 1.52, Revision 2, and N510-1975 at the system flowrate of 2000 cfm (+/- 10%).

5.5.10 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Waste Gas Holdup System, the quantity of radioactivity contained in gas storage tanks, and the quantity of radioactivity contained in unprotected outdoor liquid storage tanks. The gaseous radioactivity quantities shall be determined following the methodology in Branch Technical Position (BTP) ETSB 11-5, "Postulated Radioactive Release due to Waste Gas System Leak or Failure." The liquid radwaste quantities shall be determined in accordance with Standard Review Plan, Section 15.7.3, "Postulated Radioactive Release due to Tank Failures."

INDIAN POINT 2 5.5 - 10 Amendment No. 265

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 265 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 November 19, 2009, Agencywide Documents Access and Management System (ADAMS) Accession No. ML093340050, 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). The proposed changes would revise the TSs by changing the charcoal testing criteria in TS 5.5.9, "Ventilation Filter Testing Program," to increase the amount of iodine which must be adsorbed by the charcoal filter. The revised criteria will be more conservative than what is currently in TS Section 5.5.9, and more conservative than the charcoal filter performance that is assumed in the accident analyses for alternate source term.

2.0 REGULATORY EVALUATION

The Nuclear Regulatory Commission (NRC) staff's review evaluated the licensee's assessment of the impact of the proposed changes to the IP2 TS on design-basis analyses. The following explains the applicability of General Design Criteria (GDC) for IP2. The construction permit for IP2 was issued by the Atomic Energy Commission (AEC) on October 14, 1966, and the operating license was issued on September 28, 1973. The plant GDC are listed in the Updated Final Safety Analysis Report (UFSAR) Chapter 1.3, "General Design Criteria," with more details given in the applicable UFSAR sections. The AEC published the final rule that added Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971, with the rule effective on May 21, 1971. In accordance with an NRC staff requirements memorandum from S. J. Chilk to J. M. Taylor, "SECY-92-223 - Resolution of Deviations Identified During the Systematic Evaluation Program," dated September 18, 1992 (ADAMS Accession No. ML003763736), the Commission decided not to apply the Appendix A GDC to plants with construction permits issued prior to May 21, 1971. Therefore, the GDC which constitute the licensing bases for IP2 are those in the UFSAR.

As discussed in the UFSAR, the licensees for IP2 have made some changes to the facilities over the life of the unit that have committed to some of the GDCs from 10 CFR Part 50, Appendix A. The extent to which the Appendix A GDC have been invoked can be found in specific sections of the UFSAR and in other IP2 licensing basis documentation, such as license amendments.

- 2 The NRC staff also use the guidance of Regulatory Guide (RG) 1.52, "Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety Feature Atmosphere Cleanup Systems in Light-Water-Cooled Nuclear Power Plants," Revision 3, dated June 2001; Sections 6.4 and 9.4.1 of NUREG-0800, "Standard Review Plan;" Generic Letter (GL) 99-02, "Laboratory Testing of Nuclear-Grade Activated Charcoal," dated June 3, 1999; GL 2003-01, "Control Room Habitability," dated June 12,2003; and 10 CFR Part 50 Appendix A, GDC 19, "Control Room."

The licensee stated that the control room air filtration system is not in operation during normal plant operation. The licensee also stated that there is a single air filtration system consisting of an electric heater, high efficiency particulate air (HEPA) filter and two 2-inch charcoal filter beds.

Operation is initiated by a safety injection signal or high radiation signal which directs outside air to the filtration system and initiates operation of one of the two booster fans to provide flow through the filtration system.

In its letter dated November 19, 2009, Entergy stated:

As part of the NEI [Nuclear Energy Institute] pilot program for use of NUREG 1465, Indian Point 2 submitted a radiological analysis of the consequences of accidents using NUREG-1465 [Agencywide Document and Management System (ADAMS) No. ML100430988]. A Technical Specification (TS) amendment request was filed shortly afterwards based on this information [ADAMS No.

ML993400414]. The information submitted included dose calculations that assumed the Control Room charcoal adsorbers removed 90% of the organic and 95% of the elemental iodine. The TS did not identify the value to be used for laboratory testing using methyl iodine at that time and no such change was proposed. The NRC approved this amendment as TS Amendment 211 in July of 2000 [ADAMS No. ML003727500].

In response to Generic Letter 99-02 ["Laboratory Testing of Nuclear-Grade Activated Charcoal"], Indian Point submitted a response that included a Proposed Technical Specification Amendment [ADAMS 1\\10. ML993430276]. This proposed amendment changed the TS to require laboratory testing of the Control Room charcoal adsorbers to 95% for methyl iodine (organic) consistent with ASTM

[American Society for Testing and Materials] D3803-1989. The 95% was determined by Reference to UFSAR [Updated Final Safety Analysis Report]

Section 14.3.6.5 which cited an assumed efficiency of 90% and then the application of a safety factor of 2 consistent with the guidance of Generic Letter 99-02. The NRC approved the change as TS Amendment 215 in February of 2001 [ADAMS No. ML003767569].

Entergy did not identify this discrepancy when the TS were converted to the standard format. The NRC approved the conversion to the Improved Technical Specifications in 2003 as amendment 248.

This amendment is being submitted to correct these non-conservative TS.

Entergy has followed the guidance of Administrative Letter 98-10, and has performed laboratory testing of the Control Room charcoal adsorbers to the criteria proposed in this amendment request.

- 3

3.0 TECHNICAL EVALUATION

IP2's TS Section 5.5.9 "Ventilation Filter Testing Program (VFTP)" states the following: "A program shall be established to implement the following required testing of the Control Room Ventilation System in accordance with RG 1.52, Revision 2, March 1978, and ANSI1\\J51 0-1975.

Tests described in TSs 5.5.9.a, 5.5.9.b, 5.5.9.c, and 5.5.9.d shall be performed:

1) Within 31 days after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation since the last test (requires performance of 5.5.9.c only);

2) After 24 months of standby service;

3) After each complete or partial replacement of the HEPA filter train or charcoal adsorber filter;

4) After any structural maintenance on the system housing that could alter system integrity; and

5) After painting, fire, or chemical release in any ventilation zone communicating with the system while it is in operation."

TS 5.5.9 states that "The Required testing shall:

a. Demonstrate that an inplace test of the high efficiency particulate air (HEPA) filters shows a penetration and system bypass <0.05% when tested in accordance with Regulatory Position C.5.c of Regulatory Guide 1.52, Revision 2, March 1978, and ANSI N510-1975, while operating the system at ambient conditions and at a flow rate of 2000 cfm [cubic feet per minute] +/-10%.

b. Demonstrate that an inplace test of the charcoal adsorber shows a penetration and system bypass <0.05% when tested in accordance with Regulatory Position C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, and ANSI N510-1975, while operating the system at ambient conditions and at a flow rate of 2000 cfm +/-10%.

c. Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than 5.0% when tested in accordance with ASTM D3803-1989 at a temperature of 30°C (86°F) and a relative humidity of 95%, and a face velocity of 0.203 m/sec (40 ft/min).

d. Demonstrate that the pressure drop across the combined HEPA filters, the prefilters, and the charcoal adsorbers is less than 6 inches water gauge when tested in accordance with Regulatory Guide 1.52, Revision 2, and N510-1975 at the system flowrate of 2000 cfm (+/-10%)."

- 4 The requested amendment will change TS 5.5.9.c as follows:

From:

Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than 5.0% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 95%, and a face velocity of 0.203 m/sec (40 ft/min).

To:

Demonstrate that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than 2.5% when tested in accordance with ASTM 03803-1989 at a temperature of 30°C (86°F) and a relative humidity of 95%, and a face velocity of 0.203 m/sec (40 ft/min).

In accordance with !\\IRC staff's guidance outlined in GL 99-02, "Laboratory Testing of Nuclear Grade Activated Charcoal," safety-related air-cleaning units used in the engineered safety features ventilation systems of nuclear power plants reduce the potential onsite and offsite consequences of a radiological accident by adsorbing radioiodine. To ensure that the charcoal filters used in these systems will perform in a manner that is consistent with the licensing basis of a facility, most licensees have requirements in their facility's TS to periodically test (in a laboratory) samples of charcoal taken from the air-cleaning units. Therefore, laboratory testing of a sample of charcoal, as stated in the requested change, is consistent with the intent of GL 99-02 and is acceptable.

In accordance with RG 1.52, Revision 3, organic iodide and elemental iodine are the forms of iodine that are expected to be adsorbed by activated carbon during a design-basis accident (DBA). Organic iodide is more difficult for activated carbon to adsorb than elemental iodine.

Therefore, the laboratory test to determine the performance of the activated carbon adsorber is based on organic iodide. Methyl iodide is the organic form of iodine that is used in the laboratory test. Consequently, determining the penetration of a methyl iodide sample is more conservative than determining the penetration of an elemental iodine sample. Laboratory testing the charcoal adsorber sample using methyl iodide is included in the requested change and the NRC staff finds this acceptable.

In accordance with ASTM 03803, the 30°C, 95% relative humidity methyl iodide test is the most reliable test method to establish the methyl iodide removal efficiency of any adsorbent. The NRC staff agrees with this statement and, because the requested change uses this guidance of ASTM 03803, the NRC staff finds this acceptable.

With respect to Entergy's request to change from a methyl iodide penetration of <5.0% to a methyl iodide penetration of <2.5%, this change will increase the TS demonstrated filter efficiency from 90% to 95% while maintaining a safety factor of 2. A safety factor of 2 is in accordance with the guidance of RG 1.52, Revision 3. In accordance with IP2's licensing basis analysis of DBA consequences to control room occupants, the assumed filter efficiency of the Control Room Ventilation System (CRVS) for elemental iodine is 95% (one aspect of control

- 5 room occupant's protection is associated with the filter efficiency of the CRVS). The request to change the demonstrated methyl iodide penetration from <5% to <2.5% is conservative (i.e. the TS testing criteria for filter efficiency changes from 95% to 97.5%) and will ensure adequate protection of the control room occupants because of the higher test criteria. Consequently, the NRC staff finds this requested change acceptable.

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. 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 (75 FR 4115). 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: H. Walker Date: September 13, 2010

September 13, 2010 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO.2 - ISSUANCE OF AMENDMENT RE: VENTILATION FILTER TESTING PROGRAM (TAC NO.

ME2742)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 265 to Facility Operating License No.

DPR-26 for Indian Point Nuclear Generating Unit NO.2. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated November 19, 2009.

The amendment revises the TSs by changing the charcoal testing criteria in TS 5.5.9, "Ventilation Filter Testing Program." 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,

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

Enclosures:

1. Amendment No. 265 to DPR-26

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

See next page ADAMS ACCESSION NO.' ML102240488 "See memo dated 8/2/10 OFFICE LPL1-1/PM LPL1-1/LA SCVB/BC" AADB/BC OGC LPL1-1/BC NAME

...1Boska SUttle RDennig TTate STurk NSalgado DATE 8/12/10 8/19/10 8/2/10 8/30/10 9/3/10 9/13/10 OFFICIAL RECORD COpy

DATED: September 13, 2010 AMENDMENT NO. 265 TO FACILITY OPERATING LICENSE NO. DPR-26 INDIAN POINT UNIT2 DISTRIBUTION:

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RidsNrrDssScvb RidsNrrDraAadb RidsNrrDirsltsb RidsRgn 1MailCenter RidsOGCRp RidsAcrsAcnw_MailCTR HWalker cc: Distribution via Listserv