ML11356A136

New York State (NYS) Revised Pre-Filed Evidentiary Hearing Exhibit NYSR0013C, UFSAR, Rev. 20, Indian Point Unit 3 (Submitted with License Renewal Application) (2007) (IP3 UFSAR, Rev. 20)

ML11356A136
Person / Time
Site:	Indian Point
Issue date:	12/22/2011
From:	State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML11356A134	List: ML11356A135 ML11356A136 ML11356A137 ML11356A138 ML11356A140 ML11356A141 ML11356A142
References
RAS 21609, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML11356A136 (210)

Text

NYSR0013C Revised: December 22, 2011 IP3 FSAR UPDATE 302 of 506 IPEC00035021 IPEC00035021

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IP3 FSAR UPDATE 2.9 ENVIRONMENTAL MONITORING PROGRAM 2.9.1 General A program to determine the environmental radioactivity in the vicinity of Indian Point Station was instituted in 1958, four years prior to the initial operation of Consolidated Edison's Indian Point Unit NO.1. The purpose of this survey was to determine the natural background radioactivity and to show the variations in the activities that may be expected from natural sources, fallout from bomb tests and other sources in the vicinity. This program has been continued to the present so that changes in the environment, resulting from station operations, could be accounted for. The results of these surveys are reported annually to the Nuclear Regulatory Commission.

In addition, the New York State Department of Health has conducted surveys throughout the State of New York since 1955, including extensive surveys in the vicinity of the Indian Point Station since 1958. In 1965 and 1966, they reported the findings in the vicinity of the Indian Point Station in two special reports. Since that time, their reporting has been on a statewide basis in quarterly bulletins and in annual reports.

In 1964, the New York University Medical Center began a research program on the ecology of the Hudson River. The New York University studies include the biology of the Hudson River, the distribution and abundance of fish in the river, pesticides and radio-ecological studies. The results of this program, supported by the United States Public Health Service, the New York State Department of Health, and the Consolidated Edison Company have been submitted in several program reports.

The various studies mentioned above included measurements of radioactivity in fresh water, river water, river bottom sediments, fish, aquatic vegetation, soil, vegetation and air in the vicinity of the Indian Point Station. The results of these monitoring programs have shown that the operation of the Indian Point Units 1, 2, and 3 have had no deleterious effects on the environment.

2.9.2 Survey Programs The survey of environmental radioactivity in the vicinity of Indian Point Station provides an indication of the integrity of the in-plant radiation monitoring instrumentation and can reveal any buildup of long lived radionuclides.

By determining the activity of filterable air particulate, vegetation, drinking water and above ground gamma fields, an indirect monitoring of discharges to the atmosphere is provided by the environmental survey program.

The effect of liquid effluents on the Hudson River is monitored by measuring the activity of the cooling water inlet to and discharge from the station, discharges from the plant, activity analysis of river shoreline soils and river fish and invertebrates.

A detailed description of the media sampled in accordance with plant Environmental Monitoring Program and the ODCM is given below:

Air Particulate and Organic Iodide 342 of 506 IPEC00035061 IPEC00035061

IP3 FSAR UPDATE Concentration of radioactive particles in the air is measured weekly from 5 stations.

Membrane filters precede charcoal impregnated filters. The particulate filters are assayed for gross beta activity and are composited for quarterly gamma spectral analysis. Charcoal filters have gamma spectral analysis for 1-131 performed weekly.

Reservoir Water Drinking water is sampled monthly from an area reservoir. The water sampled is analyzed for gross beta activity, and for other nuclides via gamma spectral analysis. A quarterly composite sample is analyzed for tritium.

Hudson River Water Continuous flow samples of the condenser inlet cooling water and discharge water are collected and composited. Samples are taken, at a frequency specified in the ODCM, from continuous samples and composited for a monthly gamma spectroscopy analysis, and for a quarterly tritium analysis.

Hudson River Shoreline Soil Twice a year, at least 90 days apart, samples of river shoreline soil are taken at two locations.

Gamma spectral analysis is performed on each sample.

Hudson River Fish and Shellfish Fish and invertebrates are caught seasonally (semi-annually if not seasonal) where available near the site and analyzed by gamma spectral analysis.

Vegetation Samples of broad leaf vegetation are collected monthly, if available, in the critical wind sections within several miles of the plant. Gamma spectral and lodine-131 analyses are performed on these samples.

Milk samples are obtained, when available, on a monthly basis (semi-monthly when animals are on pasture) from dairy farms, located within 5 miles of the site. The samples are analyzed for lodine-131 content, and for other nuclides by gamma spectral analysis.

Direct Gamma (Continuous)

At 40 locations near the site and out to about 5 miles, the background gross gamma radiation is continuously monitored. The measuring devices consist of two sets of thermoluminescent dosimeters (TLDs). The TLDs are removed at quarterly intervals and the amount of absorbed background radioactivity is recorded.

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IP3 FSAR UPDATE The environmental monitoring program conducted by Entergy supplies sufficient data to determine the compliance of Indian Point Unit Nos. 1, 2 and 3 with the requirements of 10 CFR

20. The environmental survey program which monitors air, water, river shoreline sediments, terrestial vegetation, milk and selected aquatic biota provides an indication of the cumulative amounts of radioactivity in the environment.

Results of the environmental monitoring program are reported on an annual basis to the nuclear Regulatory Commission, who are thereby advised of the short and long-term trends in the environment. In addition, discharges of radioactive liquids and gases are reported to the Nuclear Regulatory Commission.

In the event that the Indian Point Station Environmental Monitoring Program detects increases in the background radiation levels above the reporting levels specified in the Offsite Dose Calculation Manual (ODCM), Entergy will notify the Nuclear Regulatory Commission.

Although the design of Indian Point 3 and administrative controls are such that liquid and gaseous effluents are released in accordance with the requirements of 10 CFR 20, the environmental monitoring program conducted by IP3 and I P2 provides a redundant means of insuring that the operation of this facility does not pose any undue risk to the health and safety of the public.

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IP3 FSAR UPDATE Table 1. The Con Edison Meteorological Model Wind Direction U Wind Variability Frequency Building**

0 0 Speed in 20 in 20 Stabilit~t Wake Period ~ Sector Sector Class Frequency Effect 0-2 hrs 1 m/s steady 100% Inversion, I 100% yes 2-24 hrs 2 m/s steady 100% Inversion, I 100% yes 1-30 days 1.74 m/s Lapse, L1 13.7%

5.23 m/s Lapse, L2 6.1%

2.79 m/s Neutral, N 37.8%

2.03 m/s Inversion, I 42.4%

all meander 35% all 100% no

• Sutton parameters Cy , Cz and n for stability classes L1, L2 and N were derived from site meteorological experiments. For stability class I, the model adopted the Inversion parameters from USAEC TID-14844 "Calculation of Distance Factors for Power and Test Reactor Sites" by J. J. di Nunno, F. D. Anderson, R. E. Baker and R. L. Waterford, dated March 23, 1962.(12)

• • Employs virtual point source displacement Xa = (A/8 Cy C z )1/(2-n) where A = building area of 2,000 m 2 for periods 0-2 hrs and 1-30 days.

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IP3 FSAR UPDATE Table 2. The AEC-DRL Meteorological Model for Pressurized Water Reactors Wind Direction, U Wind Variability Frequency Building 0 0 Speed in 22.5 in 22.5 Stabilit~ Wake Period © Sector Sector Class Frequency Effect 0-8 hrs 1 mls steady 100% Pasquill F 100% yes 8-24 hrs 1 m/s meander 100% Pasquill F 100% no 1-4 days 3 mls Pasquill D 40%

2 m/s Pasquill F 60%

all meander 100% all 100% no 4-30 days 3 m/s Pasquill C 33.3%

3 m/s Pasquill D 33.3%

2 mls Pasquill F 33.3%

all meander 33.3% all 100% no

• Volumetric building wake correction as defined in Section 3-3.5.2 of AEC TID-24190 Meteorology and Atomic Energy 1968(6) with shape factor c = 0.5 and minimum across sectional area of reactor building only.

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IP3 FSAR UPDATE 4

Table 3. Values of 10 2:xlQ (sec/m 3 )

According to the Con Edison and AEC-DRL Models for Various Time Periods and Distances Con Edison AEC-DRL Distance from Source (m) 350 --.52.0.... 11 00 Time Period 0-2 hr 20.8 15.8 7.6 25.6 13.2 7.2 2-8 hr 11.4 21.6 8-24 hrs 30.4 19.6 0-8 hrs 19.0 28.8 0-24 hrs 49.4 48.4 Values of LxlQ for sequences longer than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at x = 350 and 520 are not given because standards at the site boundary are specified for the 0-2 hr period only.

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IP3 FSAR UPDATE Table 4. Values of Hourly Average 104 1/Q at 350 m from the Source During 15 Selected Light Wind Days, July 15 - Sept 15,1970 Hour Date 22 24 02 04 06 08 7/23-24 3.5 4.7 0.6 7/24-25 21.7 13.5 1.5 0.3 7/25-26 0.7 1.2 0.3 1.0 0.4 7/26-27 1.0 7/27-28 9.8 8.3 0.5 7/28-29 0.8 1.0 0.3 8/8-9 5.1 1.1 1.0 0.7 0.6 8/13-14 5.9 7.2 2.9 0.4 0.9 8/14-15 2.4 21.7 5.2 0.6 8/15-16 12.8 4.7 1.0 6.4 8/25-26 5.5 0.9 .8 8/26-27 15.4 10.8 8/27-28 5.5 0.9 0.6 9/12-13 3.7 7.2 6.8 7.7 0.5 9/13-14 15.4 9.9 0.7 0.4 0.8 2.6.L-47 375 of 506 IPEC00035094 IPEC00035094

IP3 FSAR UPDATE Table 5. Values of Hourly Average 104 1/Q at 520 m from the Source During 15 Selected Light Wind Days, July 15 - Sept 15,1970 Hour Date 22 24 02 04 06 08 7/23-24 2.2 3.4 0.4 7/24-25 15.7 9.8 0.9 0.1 7/25-26 0.3 0.7 0.1 0.6 0.2 7/26-27 0.6 7/27-28 7.1 6.1 0.2 7/28-29 0.4 0.6 0.2 8/8-9 3.2 0.6 0.6 0.4 0.3 8/13-14 3.6 5.2 2.1 2.5 0.5 8/14-15 1.5 15.2 3.7 0.3 8/15-16 7.9 3.4 0.6 4.6 8/25-26 3.4 0.5 0.5 8/26-27 9.5 7.9 8/27-28 3.4 0.5 0.4 9/12-13 2.3 5.2 4.9 0.5 0.3 9/13-14 9.5 7.1 0.4 0.3 0.5 2.6.L-48 376 of 506 IPEC00035095 IPEC00035095

IP3 FSAR UPDATE Table 6 Values of Hourly Average 104 1/0 at 1100 m from the Source During 15 Selected Light Wind Days, July 15 - Sept 15,1970 Hour Date 22 24 02 04 06 08 7/23-24 0.8 1.7 0.1 7/24-25 7.8 4.8 0.3 0 7/25-26 0.1 0.3 0 0.2 0.1 7/26-27 0.2 7/27-28 3.5 3.0 0.1 7/28-29 0.1 0.2 0 8/8-9 1.1 0.2 0.2 0.2 0.1 8/13-14 1.3 2.6 1.1 0.1 0.2 8/14-15 0.5 7.8 1.9 0.1 8/15-16 2.8 1.7 0.2 2.3 8/25-26 1.2 0.2 0.2 8/26-27 3.4 3.9 8/27-28 1.2 0.2 0.1 9/12-13 0.8 2.6 2.4 0.2 0.1 9/13-14 3.4 3.5 0.1 0.1 0.2 2.6.L-49 377 of 506 IPEC00035096 IPEC00035096

IP3 FSAR UPDATE Table 7. Probabilities and Safety Factors in the Con Edison and AEC-DRL Accident Meteorology Models Con Edison Model AEC-DRL Model 350m 520m 1100 m 350m 520m 1100m

% Probability of Exceeding Accident Model LX/Q 0-2 hr 0.8 068 0.4 1.3 1.0 0.5 0-8 hr 0.7 0 0-24 hr 0 0 Factor of Safety at 1% Probability Level 0-2 hr 1.1 1.2 1.3 1.3 1.0 1.2 0-8 hr 1.2 1.8 0-24 hr 2.0 1.9 Factor of Safety at 5% Probability Level 0-2 hr 7.0 7.9 12.6 8.5 6.6 12.0 0-8 hr 3.2 4.8 0-24 hr 3.1 3.0 Note 350m = distance from Unit 3 to site boundary 520m = distance from Unit 2 to site boundary 1100m = distance from Units 2 and 3 to low population zone.

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IP3 FSAR UPDATE Table 8. Wind Persistence at IP 3 under Inversion Conditions 0 0 0 In Combined Sectors 002 - 022 - 042 **

(The body of the table shows number of hourly occurrences of the designated duration and speed class)

Number of Maximum Speed in Sequence (m/s)*

Consec. Hours 0.3 -0.5 -1.0 -1.5 -2.0 3.0 During 10 months (26 Nov 1969 - 1 Oct 1970) 1 1 2 38 83 139 270 2 2 5 7 23 3 3 1 4 4 1 o 2 7 1 During 12 months (1 Jan 1971 - 31 Dec 1971) 1 1 6 66 115 217 431 2 18 60 181 3 2 23 89 4 4 39 5 2 19 6 1 5 7 1

• mph notation for speed in Table 1 of Rep TR 71-3(3) should be m/s.

• • see note on page 32 regarding sector notations.

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IP3 FSAR UPDATE Appendix A Chronological Review of Events Relating to the Accident Meteorology Models The Con Edison meteorological model was developed by Dr. Ben Davidson of New York University, using meteorological data collected at Indian Point during the period 1955-1957.

That meteorological investigation, conducted in support of the licensing application for Indian Point Unit No.1, yielded three reports which contained not only the meteorological summaries, but various dose calculations for postulated releases at stack height and at ground level.

These reports we submitted to the AEC in their entirety as Exhibits L-1, L-5 and L-6 of Docket 50-3, Indian Pont Unit No. 1(3)

Exh. L-1: N.Y.U. Tech. Rep. 372.1 "A Micrometeorological Survey of the Buchanan, N.Y.

Area", dated Nov. 1955, Exh. L-5: N.Y.U. Techn. Rep. 372-3" Evaluation of Potential Radiation Hazard Resulting from Assumed Release of Radioactive Wastes to the Atmosphere from Proposed Buchanan Nuclear Power Plant", dated April 1957, and Exh. L-6: N.Y.U. Tech. Rep. 372.4 "Summary of Climatological Data at Buchanan, N.Y.,

1956-1957", dated March 1958.

The meteorological data acquired during the foregoing study were synthesized into the Con Edison meteorological model which first appeared in the PSAR for Indian Point Unit No.2 (Docket No. 50-247). The supporting documentation for the model included:

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IP3 FSAR UPDATE Exhibits L-1 and L-6 (described above) in their entirety, Meteorology Sections 2 and 3 of Exhibit L-5 (described above),

U.S.W.B. Tech. Paper No. 15: Maximum Station Precipitation for 1,2,3, 6, 12 and 24 Hours, Part X: New York, dated Dec. 1954, and Additional meteorological data concerning wind behavior at an elevation of 70 ft above the Hudson River near the Indian Point site when the wind speed above the valley ridge lines fell into two classes; virtually zero and less than 16 mph. Those data had been collected during 1955, and had been used in generating the dose calculations in Exhibit L-5, but had not been presented previously in this form (low speed hodographs).

The Con Edison meteorological model postulated the sequence of wind condition shown in Table 1, beginning at the time of the postulated accident. The AEC did not comment directly as to the acceptability of the Con Edison model. It did request justification for the inversion frequency used in the 1-30 day period (question No. 16 in letter to Applicant dated Feb 28, 1966). This was provided in the First Supplement to the PSAR for I.P. 2 (Docket No. 50-247, Exhibit B-1).

The Con Edison meteorological model was used again in the PSAR for Indian Point Unit No.3 (Docket 50-286). During evaluation of the dose calculations, the AEC-DRL made known its own meteorological model which has subsequently been published formerly in Safety Guide No.4 of:

U.S. A.E.C.-D.R.S.: "Safety Guides for Water Cooled Nuclear Power Plants",

dated Nov. 2, 1970.

The meteorological sequence in the AEC-DRL model is shown in Table 2.

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IP3 FSAR UPDATE When the AEC-DRL model became known to Con Edison, the latter compared the two models for comparable time periods, and it was found that the Con Edison model yielded higher xlO values than did the AEC-DRL model in all periods except 2-8 hrs after the postulated accident. However, in a submittal to the AEC in the Fifth Supplement to the I.P. 3 PSAR, it was argued in Item 8 that the AEC-DRL assumption of a 1 mls wind speed during this six-hour period did not in fact occur, and that the Con Edison assumption of 2 mls for the same period was adequately conservative. This factor of 2 on wind speed, if applied with the AEC-DRL model in the 2-8 hr period, would reduce the AEC-DRL value of XIO for the period to below the Con Edison value, thereby rendering the Con Edison model more conservative in all categories.

The argument also called upon experimental evidence to show that the wind meandered during the 2-8 hr period, following a directional pattern of wind rotation. The omission of wind meander in both the AEC and Con Edison models during this period introduces conservatism into each model.

In preparation for the I.P. 3 Construction Permit hearings, Con Edison submitted to the AEC Licensing Board:

(1) Summary of Application (Docket 50-286) dated Feb. 20, 1969, and the AEC-DRL Technical Staff submitted:

(2) AEC-DRL Safety Evaluation dated Feb. 20, 1969, (3) Appendix C to AEC-DRL Safety Evaluation: Comments on PSAR and Fifth Supplement for I.P.3, dated May 24, 1968 and Jan. 2, 1969 (included as Pgs. 75 and 76 of (2) above).

(4) AEC-DRL Summary Statement dated March 20, 1969.

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IP3 FSAR UPDATE During the pre-hearing conference for I. P. 3 on March 11, 1969, Board Member Pigford requested clarification from both AEC-DRL and Con Edison regarding (a) the statement in Document 2 (above) that Con Edison did not have long-term data on stability-speed-direction persistence, and (b) the differences between the Con Edison and AEC-DRL meteorological models (transcript pgs. 70-71).

During the I. P. 3 Construction Permit hearings, on March 27, 1969, oral testimony was given by both Con Edison and AEC-DRL representatives in response to Dr. Pigford's questions.

It was established that "the absence of long-term data" referred to the fact that the original experimental data, taken in 1955, 1956 and 1957, were no longer available (transcript pg. 170),

leaving only the statistical summaries in the various reports and submittals previously cited.

The details of the Con Edison and AEC-DRL accident meteorologies, shown in Table 1 and 2, were also enumerated, and major points of discrepancy between the models were discussed.

Of particular interest to the Board was the rationale behind the AEC-DRL statement that the 0-8 hr meteorology used in the AEC model was conservative (pg. 660). This led to an extended discussion of the low wind speed hodographs shown in Figs. 2.6-1 and 2.6-2 of Section 2 of the Unit 3 PSAR, which provide the justification for both the Con Edison and AEC-DRL 0-8 hr meteorology models.

These hodographs show the progression of wind speed and direction during a typical day when the wind speed above ridge elevation is zero or small. The hodographs were constructed by averaging the measurements taken on 12 days (zero wind speed) and 35 days (small wind speed) during September and October, 1955.

The Con Edison positions was that the combination of average hodographs plus conservative assumptions regarding the persistence of wind speed, direction and 2.6.L-60 383 of 506 IPEC00035102 IPEC00035102

IP3 FSAR UPDATE stability provide adequate conservatism in its 0-24 hr meteorology model.

The AEC-DRL position was that an average hodograph implied the existence of some individual hodographs which might exhibit longer persistence of lower speed winds in the critical direction with strong stability, and that a more conservative model was called for in the absence of evidence to the contrary. In its Safety Evaluation, Document (2) above, the AEC-DRL stated that its standard meteorological model, given in Table 2, "conservatively characterizes the meteorology of the Indian Point site" in the absence of long-term data "on the specific joint frequency of stability-wind speed-wind direction persistence." The AEC-DRL consultant (ESSA Air Resources Environmental Laboratory) concurred in Document (3) above that the 1-8 hr meteorology in the AEC-DRL model was a " --reasonably conservative meteorological assumption ... " in view of the absence of join-frequency data.

Board member Pigford then attempted to obtain a numerical estimate of the probability of occurrence of the Con Edison and AEC-DRL 0-8 hr models in the critical wind direction sector by questioning AEC-DRL staff meteorologist Spickler and Con Edison consultant Halitsky. Mr.

Spickler reasoned that it would probably be less than 1%, since the combination of inversion stability and 1 mls wind speed occurred approximately 5% of the time for all directions combined. However, in view of the lack of persistence data for individual cases, Mr. Spickler characterized his estimate of 1% as an "educated guess" (page 67).

Dr. Pigford then requested that Dr. Halitsky estimate the probability of occurrence of the 0-8 hr meteorological sequences as defined by AEC-DRL and Con Edison (pgs. 675-676). Dr.

Halitsky requested some time to consider his reply. Further questioning was directed toward the validity of diffusion coefficients 2.6.L-61 384 of 506 IPEC00035103 IPEC00035103

IP3 FSAR UPDATE (pg 677), the need for diffusion testing to validate the Sutton diffusion model (pg 678ff and 745ff), plans for continued meteorological testing to generate the data needed to clarify the 0-8 hr assumptions (pg 682ft) and topographical effects on diffusion (pgs 749ff).

Prior to adjournment the Board posed several questions of a meteorological nature to both Con Edison and the AEC-DRL staff (pg 1671). Those were responded to at a resumption of the hearings on 13 May 1969. Mr. Spickler placed into the record the AEC-DRL standard meteorological model as shown in Table 2 (pg 1756). Two questions were directed to Dr.

Halitsky (pgs. 1671 and 1672):

a) Present a technical justification for the conclusion that the frequency spectrum of wind speeds and the range of air and low wind speeds is now and will continue to be the same as that measured in 1956.

b) Present a technical justification for the meteorological conditions used in the applicant's accident analysis indicating the estimated probability of occurrence of these conditions.

Question (a) was answered by reviewing the substance of NYU Report 372.4 which compared 1956 and 1957 meteorological data. Question b) was answered in part, but the discussion veered toward temperature gradients and plume rise, not returning to probabilities that day. Mr. Jensch raised the question again of conducting diffusion tests. Dr. Halitsky recommended against such test as being unnecessary.

On the following day Dr. Halitsky continued his reply to Question b) pgs. 1795ff). He stated that the Con Edison 30-day meteorology was conservative because inversions were assumed to occur twice as frequently as the average for 2.6.L-62 385 of 506 IPEC00035104 IPEC00035104

IP3 FSAR UPDATE the year, and the meander was assumed to occur in a 20° sector whereas the actual meander angle was more like 40°. The combination of those two effects introduced a factor of about 4 in the X/Q calculation.

Turning to the first day meteorology, considerable discussions then ensued regarding the interpretation of the hodographs in Figs. 2.6-1 and 2.6-2, particularly with respect to lapse rates during different hours of the day. Dr. Halitsky pointed out that the Con Edison model ignored meander and reversal during the first day, each of which would introduce a factor of 2 for a total of 4 on the calculated X/Q. Furthermore, the increase of wind speed from 1 m/s to 2 m/s during the 2-24 hr period appeared justified according to the average hodograph.

Dr. Pigford then brought the questioning back to the probability of occurrence of the Con Edison assumed meteorology (pg 1815). Dr. Halitsky offered an opinion of the probabilities of the first-day meteorology specified in the AEC-DRL and Con Edison models, based on Mr.

Spickler's previous estimate (pg 670) of "probably less than 1%" and Dr. Halitsky's estimate of two orders of magnitude less than Mr. Spickler's for the same model; i.e., assuming that the average hodograph occurs 100 days/yr, the AEC-DRL "anomalous" hodographs would occur

.01x100 = 1 day/yr according to Spickler and 1 day/100yrs according to Halitsky. The Con Edison "anomalous" hodograph, which is not as severe as the AEC-DRL version, would have an intermediate frequency, say 1 day/10yrs.

Dr. Pigford then requested a statement of probability for each of the three time periods in the Con Edison model. Dr. Halitsky was unable to furnish this information.

Dr. Pigford subsequently questioned Mr. Grob regarding the possibility of return flows over the site causing an accumulation of concentrations (pg 1846),

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IP3 FSAR UPDATE the possibility of accumulation of concentrations due to simultaneous operation of Units 1, 2 and 3 (pg 184) and the possibility of plumes leaving the Unit 1 stack and/or the tops of the Units 2 and 3 containment structures and impinging upon a local rise in terrain beyond the site boundary (pg 1853). Mr. Grob and Dr. Halitsky responded by giving qualitative descriptions of plume behavior and concluding that the postulated conditions would not yield higher concentrations than in the assumed accident meteorology.

Mr. Jensch then queried Mr. Spickler on wake effects with cylindrical structures at low wind speeds (pg 1862). Mr. Spickler cited various references, none of which reported tests in wind speeds as low as 1 m/s. Mr. Spickler concurred with Mr. Jensch as to the desirability of having wake concentration data at low wind speeds to justify inclusion of the wake factor in the meteorological model (pg 1864).

Dr. Halitsky completed his statement on the probability of occurrence of the Con Edison meteorological model by specifying a substantially zero probability since the first two periods in the model do not provide for wind meander which always occurs (pg 1914).

After conclusion of the hearings, both Con Edison and the AEC-DRL submitted written answers to the questions posed by Dr. Pigford at the pre-hearing conference. Con Edison concurred that data were lacking to prove that 8 hr wind persistence under low speed conditions could not occur. It also showed that the AEC-DRL value of Xu / Q during the 2-8 hr period, while twice as high as the Con Edison value for the same period, would produce only a 20% increase in dose. The AEC-DRL contended that relaxation of their long-term model is not justified until joint probability of persistence with speed and stability can be examined. It 2.6.L-64 387 of 506 IPEC00035106 IPEC00035106

IP3 FSAR UPDATE also stated that their model showed a 40% increase in dose over the Con Edison model.

The AEC-DRL also provided written comments on Dr. Halitsky's hearing testimony, i.e.: (a) they agreed with his testimony, (b) they believe that the Sutton equations are valid for this type of terrain and that smoke photography and wind measurements are adequate experimental techniques in lieu of direct concentration measurements, and (c) they believe that year to year variations in meteorology will be small and that accident meteorological assumptions would still be quite conservative.

In its Initial Decision granting a Construction Permit (Aug 13, 1969) the Board took note that Con Edison had undertaken a new meteorological program in the Indian Point area, and had stated that the new data would be used in connection with the proposed operations for Unit No.3. The Board strongly urged that a) Definitive criteria should be developed for judging the adequacy of the meteorological program (pg 12),

b) the present continuing study should be made as comprehensive as possible (pg 13),

and c) the possibility that ground concentrations higher than those at the site boundary might occur beyond the site boundary should be given detailed consideration (pg 16).

In response to the Board's recommendations, Con Edison revised its ongoing meteorological program in the Fall of 1969 to serve two functions; one was to acquire data which could be used for the scheduling of operational releases, the other was to acquire data which would help to resolve the unanswered questions, which arose during the hearings, regarding the 0-8 hr accident meteorology models.

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IP3 FSAR UPDATE The portion of the revised program relating to accident meteorology included experiments to obtain data on:

a) annual wind statistics b) low wind speed hodographs c) turbulence characteristics under low wind speed inversion conditions d) persistence statistics e) building wake effects on diffusion The results of experiments in the above categories were submitted to Con Edison in three reports. These are

1) N.Y.U. Tech. Rep. TR 71-3 "Wind Observations at Indian Point, 26 November 1969-1 October 1970" by J. Halitsky, E.J. Kaplin, and J. Laznow 17 May 1971.

2) N.Y.U. Tech. Rep. TR 71-10 "Low Wind Speed Turbulence Statistics and Related Diffusion Estimates for Indian Point, N.Yf" by D. M. Leahey and J. Halitsky 15 September 1971.

3) "Wind Test of Gas Dispersion from Indian Point Unit 1", by J. Halitsky 29 June 1971.

Item 1) was submitted to the AEC-DRL in Supplement 1, pgs Y-1 to Y-32 of the Unit No.3 FSAR.

Item 3) was submitted to the AEC-DRL in support of an application to reduce the stack height of Unit No.1 to meet structural safety requirements under tornado loadings. In preparation for the I.P.2. Operational Permit hearings, Con Edison submitted to the AEC Licensing Board:

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IP3 FSAR UPDATE (1) Summary of Application (Docket 50-247) dated Nov. 12, 1970, and the AEC-DRL Technical Staff submitted:

(2) AEC-DRL Safety Evaluation dated Nov. 16, 1970, (3) Appendix C to AEC-DRL Safety Evaluation; Comments on FSAR and Amendments 12 and 14 for I.P.2., dated Nov. 29, 1969 and Feb. 17, 1970 (included as Pgs 93,94 and 95 of (2) above).

In Item (2) pg 9, the AEC-DRL stated that the two years of (new) meteorological data presented by the applicant provide an adequate basis for selecting the meteorological parameters for both routine and accident meteorology calculations.

In Item (3), ESSA-AREL acknowledged the existence of the diurnal reversal of valley winds at the site but stated that in the absence of joint frequency data, an appropriately conservative assumption would be a steady wind of 1 mls speed for the first 8 hrs followed by a 22%0 meandering wind of 1 mls speed for the next 16 hrs in the same sector. ESSA characterized the latter assumption as "very conservative". It also stated that the Con Edison correction for building wake effect agreed well with the AEC-DRL method, but disagreed with the Con Edison procedure of including a virtual source displacement in the long term average diffusion model.

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IP3 FSAR UPDATE JOB NO. 6729 SURFACE WIND SPEEDS VERSUS DIRECTION WHEN SOME FORM OF PRECIPITATION STATION: BEAR MOUNTAIN, NEWYORK PERIOD: JANUARY 1944- DECEMBER 1948 Sponsored by: Consolidated Edison Company of New York, Date October 28, 1965 Book 2 of 2 USCOMM. WB-ASHVILLE 412 of 506 IPEC00035131 IPEC00035131

IP3 FSAR UPDATE JOB NO. 6729 OCCURRENCE OF WIND SPEED AND DIRECTION DURING STATION: BEAR MOUNTAIN, NEWYORK PERIOD: JANUARY 1944 - DECEMBER 1948 Sponsored by: Consolidated Edison Company of New York, Date October 28, 1965 Book 1 of 2 USCOMM. WB-ASHVILLE 413 of 506 IPEC00035132 IPEC00035132

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IP3 FSAR UPDATE 1

1. Introduction This is the second of two progress reports covering meteorological investigations in the Hudson River valley near Indian Point from August 1968 to the present.

The first report [Halitsky, Laznow and Leahev (1970)] described wind measurements at Indian Point, Bowline Point and Montrose until 30 June 1969, and provided details of changes in tower location and instrumentation introduced during the period July-November 1969.

This report presents an analysis of measurements taken at the present tower at Indian Point (lP 3) and at a ship, the Cape Charles (CC) anchored in the Hudson River, and compares them with similar measurements taken in 1955-1957 at approximately the same locations. The focus of this report is to evaluate whether site meteorology has changed significantly during the intervening years, and to elucidate aspects of the meteorology not reported previously.

In order to clarify the various tower locations and periods of operation, the following nomenclature was established in the first report and will be continued.

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IP3 FSAR UPDATE 2

Date Period Station Symbol Station Location 1955 J Ship "Jones" in Hudson River 1956-1957 IP1 Indian Point, southeast of plant 1968-1969 IP2 Indian Point, southwest of plant 1968- BP Bowline Point 1968- MP Montrose Point 1969- IP3 Indian Point (close to I P 1) 1970 CC Cape Charles (close to J)

Figs 1, 2 and 3 show the station locations and local topography.

2. Data Log Fig 4 shows the periods of data acquisition for all of the stations which were in operation in 1970. Station 3 P is included, even though its operation is now being funded by Orange and Rockland Utilities, Inc., order to show the total store of data for the region. The net radiometer (R) and ambient temperature (T) at I P 3, and the Aerovane (A) at the Cape Charles are supplementary instruments provided by N. Y. University.

All of the instruments except the bivane produced continuous records on slow-speed strip charts 91 inch, 2 inch or 3 inch per hour). The bivane chart drive was modified to run 50 minutes at 3 inch per hour followed by 10 minutes at 3 inches per minute and repeat. Thus, each chart (indicated by a dot in Fig 3) contained a 36-hr record of fast-and slow-speed data for each hour.

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IP3 FSAR UPDATE 3

The statistical data presented in this report represent periods when simultaneous wind speed, wind direction and temperature difference were available at I P 3. The overall period selected for analysis was 26 November 1969-1 October 1970. The degree of completeness of record is as follows:

Hours all data present Total Hours in period  % completeness Climet 5989 7440 80.5 Aerovane 6164 7440 82.8 Y-8 418 of 506 IPEC00035137 IPEC00035137

IP3 FSAR UPDATE 4

3. Annual Average Wind Statistics at the I P 1 and I P 3 Stations The annual average wind statistics at I P 3 for the 10-month measurement period in 1969-1970 are shown in graphical form in Figs 5 (a-h), 6 and 7. Also included in these figures, for comparison purposes, are the equivalent I P 1 statistics originally reported by Davidson and Halitsky (9157), Table 3.3 and subsequently incorporated into Se 2.6 of the Unit 2 FSAR.

The two sets of Aerovane statistics represent observations taken about 13 years apart with similar or identical instruments at almost the same locations. As seen in Fig 1, the two towers are about 200 ft apart, and the base of the I P e tower is about 15 ft lower in elevation.

The present site topography has fewer trees, more pavement, and new steel and concrete structures in the quadrant northwest of the tower.

Wind speed and direction were measured at the 100 ft elevation on each tower; therefore the absolute elevation of the I P e instrument is about 15 ft lower than that of the I P 1 instruments.

Temperature differences were measured between 95 ft and 7 ft on the 100 ft high I P 3 tower whereas 150 ft and 7 ft were used on the 310ft high I P 1 tower. However, the isothermal and adiabatic lapse rates were used to separate the lapse, neutral and inversion categories in both cases. This was accomplished by using an adiabatic ~T of - 0.5 F for I P 3 in place of the - 0.9 F used for I P 1.

Fig 5 shows the frequency distribution of wind directions as measured by the Aerovanes in 1956 and 1970.

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IP3 FSAR UPDATE 5

Fig 5a represents all winds irrespective of speed and temperature gradient class. The shapes of the curves are quite similar, the most important difference being a shift of the 1956 southerly maximum toward the southeast in 1970.

Fig 5 (bOd) shows the dependence on temperature gradient class. No major change is apparent in the neutral class, but the 1970 data show more frequent lapses and less frequent inversions in all directions.

Fig 5 (e-h) shows the dependence on speed class. The southeasterly shift observed in Fig 5a is seen to occur in the 5-8 mph and 9-13 mph speed classes. Low-speed winds in the 1-4 mph class were more frequent in 1970, especially for the 000°-045° direction range.

None of the above differences are sufficiently large to invalidate the 1956 wind statistics reported in Davidson and Halitsky (1957). Of the three noticeable differences, the decrease in frequency of inversions and the increase in southeasterly winds both contribute to reducing the concentrations in inhabited regions contiguous to the site. However, the increase frequency of low-speed winds from the northeasterly sector bears further examination.

Fig 6 shows a comparison of cumulative frequencies of wind speed for the two years.

The 1956 curves can not be extended below 2 mls because the published data show only two categories below that speed, i.e., calm and 1-4 mph, covering speeds from 0 - 4.5 mph. The cumulative frequency shown at a speed of 2 mls is the sum of these two categories. The 1970 data were classified in finer groupings and yielded well-defined curves in the low speed range. The 1970 data in Fig 6 were uncorrected for speed calibration. It is not known if corrections were applied to the 1956 data.

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IP3 FSAR UPDATE 6

The upper curves, representing all temperature gradients and directions, show good agreement for the two years. The inversion curves show good agreement during calms and near 2-3/m/s, but the 1970 inversion frequencies were smaller than the 1956 frequencies at the higher speeds. This discrepancy in high speed inversions is in the direction of enhancing the atmospheric diffusion potential over that which was postulated on the basis of the 1956 data. It is not known how much of the difference between the two years is due to the absence of October and November data in 1970.

Because of the high starting speed of the Aerovane, the curves of Fig 6 show spuriously high frequencies of low wind speeds. When the 1970 data are corrected for speed calibration (see Fig 6 of Halitsky et al (1970)], the data appear as in Fig 7.

In order to check the Aerovane data, we have included in Fig 7 the corresponding curves obtained from the more sensitive Climet instrument at the same location during the same period, corrected for speed calibration.

The difference between the Aerovane and Climet curves may be attributed to the poor behavior of the aerovane at low speeds. A true speed of 1 m/s is near the starting threshold of the Aerovane. The corresponding indicated speed may be anything in the range 0-2 mph or one division of the chart. At the same time, a one-division indication may be simply a zero setting error. For these reasons, it is believed that the Climet data should be regarded as more reliable.

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IP3 FSAR UPDATE 7

4. Valley Wind Hodographs During Virtually-Zero Pressure Gradient Conditions 4.1 Average Hodographs Average wind hodographs taken during the months of September and October 1955 are presented in FSAR Sec 2.6, Figs 2.6-1 and 2.6-2, to demonstrate that the wind reverses diurnally when the upper air (geostrophic) wind is zero or weak, thereby precluding the occurrence of protracted periods of calm or light wind.

The 1955 data were taken with an Aerovane mounted 70 ft above river elevation on the mast of a ship, the Jones, anchored in the Hudson River about one mile northwest of the tower (see Fig 2). Thirty-five days, during which weak pressure gradient conditions existed over the area, were selected for study. Of these 35 days, 12 days had virtually zero pressure gradient. The two Figures represent the average of wind vectors over the 12 or 35 day period, for each even-numbered hour during the day.

Both of the 1955 hodographs show a well-defined steady flow toward the SSW (030° winds) during the night 92000-0800 hrs), and a somewhat less steady flow toward the NNE (210° winds) during the day (1200-1600). During the transition hours (1000 and 1800 hrs) the flow was weak and variable. The average wind speeds during the night were about 2.5 m/s.

On the basis of these data, it was concluded that the accident meteorology model calling for a wind sequence of 1 mls steady for two hours followed by 2 mls steady in the same direction for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was conservative since the hodograph showed a wind reversal after 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. However, it has been pointed out that individual hodographs for each of the days may have exhibited lower wind speeds and may have failed to show the diurnal reversal.

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IP3 FSAR UPDATE 8

To explore this aspect, an Aerovane was installed 100 ft above river level on the mast of another ship, the Cape Charles, anchored in the Hudson River close to the former location of the Jones. The instrument was in operation from March 17, 1970 to Sept. 17, 1970. It had been hoped that the period could be extended to the end of October to gather test data for the same months that were used in the 1955 study, but the instrument had to be removed prematurely because the ship was being prepared for removal.

Using the available record, we selected the two-month period July 15-Sept. 15 as having the closest seasonal correspondence to the 1955 study, and found 17 days during which virtually-zero pressure gradient conditions existed, as determined frm surface weather maps for 0700 EST. The hourly wind velocity vector was determined for each even-numbered hour and a vector average was taken over the 17 days for those hours. The average hodograph is shown in Fig 8, together with the 1955 Jones hodograph.

The important characteristics of the 1955 hodograph were confirmed by the 1970 data. A predominant, diurnally-reversing circulation exists along the 030°-210° axis.

The nightime down-valley flow was slightly weaker (- 2.0 mls vs - 2.4 m/s) and began about an hour later (2100 vs 2000 hrs) in 1970 but both terminated at - 0900 hrs. The up-valley daytime flow was also somewhat weaker (- 1.5 mls vs - 2 m/s), and did not show the strong southerly wind at 1400 and 1600 hrs. The latter effect may be due to the more northerly locations of the Jones, near the nose of Dunderberg Mtn., where the flow direction changes rapidly (see Fig 2).

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IP3 FSAR UPDATE 9

Before analyzing the individual hodographs for each day, it should be noted that the Jones and Cape Charles are located very close to the steep southerly side of Dunderberg Mtn. (peak el. 1120 ft), and are therefore exposed to air currents which tend to flow parallel to the hillside. This topographic influence is not present at the plant site.

To determine what differences, if any, exist between the winds at the ships and the plant site, an average hodographs for 16 of the 17 days was calculated from the records of the Climet speed and direction instrument at the 100 ft elevation on the I P 3 tower (Fig 9). The Climet instrument was inoperative on 1 of the 17 days). The most significant change from the Cape Charles hodograph is the appearance of a southeasterly wind component during the afternoon and evening hours. This component also appeared at the Jones in 1955. Apparently this is an integral part of the valley circulation, causing the hodograph vector to rotate counterclockwise with increasing time, and was not experienced at the Cape Charles due to the deflecting influence of the hillside. A northwesterly down-slope wind may also have been present during the afternoon and evening at the Cape Charles, since the hillside is in shadow at that time.

4.2 Daily Hodographs Fig 10 (a-d) shows the 16 daily hodographs from which the average hodograph at the I P 3 tower, shown in Fig 9, was calculated. The nighttime down-valley flow appears in all 16 cases. The daytime up-valley flow is quite variable in both speed and direction, and is characterized by generally higher wind speeds and wider direction swings.

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IP3 FSAR UPDATE 10

5. Persistence of Low-Speed Winds Fig 11 contains a time history of each of the wind conditions during the night hours of the days corresponding to the hodographs of Fig 10 (a-d). The graphs are the variation of the wind speed with time for those hours when the wind direction was between 000° and 045°. We shall assume that the wind direction was steady if it remained in this 45° sector. (This is quite conservative, since a wind which meanders uniformly in a 45° sector of 500 m radius under inversion conditions produces an average concentration about 8 times smaller than the steady wind axial concentration.)

The observed wind angle ~ and temperature differences liT = T95 - T7 are noted under each observation. Positive values of liT indicate inversions. liT values between-0.5 and 0 indicate neutral. liT values smaller than - 0.5 deSignate lapses.

The longest period of direction persistence was 8 hrs, occurring on July 25-26, Aug. 8-9, Aug. 13-14, Sept. 12-13 and Sept. 13-14. The average winds speed in each case was at least 2 m/s. liT was recorded only 3 of these days, and an inversion occurred only during the first two hours of one of the days.

The period of poorest dispersion potential occurred on July 24-25. It lasted 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with a gradual increase of wind speed from 0.2 to 2.0 mis, a gradual decrease of temperature gradient from liT = 1.7 to - 0.8, and a gradual direction change from 007° to 043°. The occurrence of the strongest inversion during the early part of the night and its subsequent weakening and change to neutral or lapse beyond 0200 hrs seems to be a common phenomenon at the site.

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IP3 FSAR UPDATE 11 Wind persistence may also be examined by listing the number of occurrences that wind of specified characteristics persisted for a specified number of consecutive hours during the entire 10 month test period in 1969-70. The following talbe shows these data for inversion condition only.

Table 1. Wind Persistence at I P 3 Under Inversion Conditions 91969-1970)

Wind No. of Maximum speed in sequence (mph)

Sector Consec. Hrs. 0.3 0.5 LQ .1.§ 2.0 3.0 4.0 6.0 005°-020° 1 1 2 22 41 64 115 141 151 2 1 3 2 7 5 2 3 3 2 2 3 4 1 10 1 005°-020° 1 16 42 75 155 189 198 2 1 2 5 16 7 3 3 1 2 2 1 4 2 3 5 2 1 6 1 7 1 It is seen that very light winds do not persist beyond one hour, and high persistences begin to appear at about 3 m/s. For both sectors combined, the longest persistences for 11.0, 1.5 and 2.0 mls winds were 2 hrs, 4 hrs and 3 hrs, respectively.

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IP3 FSAR UPDATE 12 References Davidson, B. and J. Halitsky (1957): Evaluation of Potential Radiation Hazard Resulting from Assumed Release of Radioactive Wastes to Atmosphere from Proposed Buchanan Nuclear Power Plant. N. Y. University Dep't. of Meteorology and Oceanography Tech. Rep't. No 372.3 Halitsky, J., J. Laznow and D. Leahey 91970): Wind Observations at Indian Point, Montrose and Bowline Point. 31 August 1968 to 30 June 1969. N. Y. University Dep't. of Meteorology and Oceanography Tech. Rep't. TR-70-3.

FSAR: Final Facility Description and Safety Analysis Report. Consolidated Edison Co.

of N. Y., Inc. Nuclear Generating Unit No.2. Exhibit B-8.

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IP3 FSAR UPDATE CHAPTER 3 REACTOR 3.1 DESIGN BASIS 3.1.1 Performance Objectives The reactor thermal power analyzed is 3216 MWt.

The fuel rod cladding was designed to maintain its integrity for the anticipated fuel assembly life.

The effects of gas release, fuel dimensional changes, and corrosion-induced and irradiation-induced changes in the mechanical properties of cladding were considered in the design of the fuel assemblies.

Rod Control Clusters are employed to provide sufficient reactivity control to terminate any credible power transient prior to reaching the design minimum departure from nucleate boiling ratio (DNBR) of the applicable limit. This is accomplished by ensuring sufficient control cluster worth to shut the reactor down by at least 1.3% in the hot condition with the most reactive control cluster stuck in the fully withdrawn position.

Redundant equipment is provided to add soluble poison to the reactor coolant in the form of boric acid to maintain shutdown margin when the reactor is cooled to ambient temperatures.

In addition, the control rod worth in conjunction with the boric acid injection from the refueling water storage tank (RWST) is sufficient to prevent an unacceptable return to power level as a result of the maximum credible steam line break (one safety valve stuck fully open) even assuming that the most reactive control rod is fully withdrawn.

With the BIT functionally eliminated, the return to power following a credible steamline break accident has been evaluated showing that the event is bounded by the hypothetical steamline break. The departure from nucleate boiling (DNB) design basis is met with no consequential fuel failures predicted, and assuring that the return to power remains within the limits established for the protection of the health and safety of the public, with margin.

Plant specific analyses performed by Westinghouse for Indian point Unit 3, have shown that the Boron Injection Tank (BIT) may be bypassed, eliminated, or the concentration of its contents reduced, while continuing to meet applicable safety criteria.

The functional elimination of the BIT replaces the concentrated boric acid contained therein, with water from the Refueling Water Storage Tank (RWST); this obviates the need to maintain the BIT and its associated piping at elevated temperatures.

The lowering of the minimum required boric acid concentration in the BIT:

1) reduces the potential for degradation of carbon steel components and supports as a result of leakage;

2) eliminates the need to maintain recirculation of boric acid through BIT;

3) eliminates the need to maintain the BIT heaters and heat tracing on the associated SIS piping and recirculation lines; and 1 of 87 IPEC00035226 IPEC00035226

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4) eliminates the need for periodic checks of BIT concentration thereby reducing radiation exposure of plant personnel.

5) Eliminates the need to maintain closed the BIT inlet and outlet isolation valves.

Experimental measurements from critical experiments or operating reactors, or both, were used to validate the methods employed in the design. During design, nuclear parameters were calculated for every phase of operation of the first core and reload cycles and, where applicable, were compared with design limits to show that an adequate margin of safety existed. In the thermal hydraulic design of the core, the maximum fuel and clad temperatures during normal reactor operation and at overpower conditions were conservatively evaluated and found to be consistent with safe operating limitations.

3.1.2 Principal Design Criteria The General Design Criteria presented and discussed in this section are those which were in effect at the time when Indian Point 3 was designed and constructed. These general design criteria, which formed the bases for the Indian Point 3 design, were published by the Atomic Energy Commission in the Federal Register of July 11, 1967, and subsequently made a part of 10 CFR 50.

A study of compliance with 10 CFR Parts 20 and 50 in accordance with some of the provisions of the Commission's Confirmatory Order of February 11, 1980 has been completed. The detailed results of the evaluation of compliance of Indian Point 3 with the General Design Criteria presently established by the Nuclear Regulatory Commission (NRC) in 10 CFR 50 Appendix A, were submitted to the NRC on August 11, 1980, and approved by the Commission on January 19, 1982. These results are presented in Section 1.3.

Reactor Core Design Criterion 6: The reactor with its related controls and protection systems shall be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits which have been stipulated and justified. The core and related auxiliary system designs shall provide this integrity under all expected conditions of normal operation with appropriate margins for uncertainties and for specified transient situations which can be anticipated.

The reactor core, with its related control and protection system, was designed to function throughout its design lifetime without exceeding acceptable fuel damage limits. The core design, together with reliable process and decay heat removal systems, provide for this capability under all expected conditions of normal operation with appropriate margins for uncertainties and anticipated transient situations, including the effects of the loss of reactor coolant flow (Section 14.1.6), trip of the turbine generator (Section 14.1.8), loss of normal feedwater (Section 14.1.9) and loss of all offsite power (Section 14.1.12).

The Reactor Control and Protection System was designed to actuate a reactor trip for any anticipated combination of plant conditions, when necessary, to ensure a minimum Departure from Nucleate Boiling (DNB) ratio equal to or greater than the applicable limit.

The integrity of fuel cladding is ensured by preventing excessive clad heating and excessive cladding stress and strain. This is achieved by designing the fuel rods so that the following 2 of 87 IPEC00035227 IPEC00035227

IP3 FSAR UPDATE conservative limits are not exceeded during normal operation or any anticipated transient condition:

1) Minimum DNB ratio equal to or greater than the applicable limit

2) Fuel center temperature below 4700° F

3) The internal gas pressure of the lead rod in the reactor is limited to a value below that which would cause (1) the diametral gap to increase due to outward clad creep during steady-state operation, and (2) extensive DNB propagation to occur

4) Clad stresses less than the Zircaloy or ZIRLOTM yield strength

5) Clad strain less than 1%

The ability of fuel designed and operated to these criteria to withstand postulated normal and abnormal service conditions is shown by the analyses described in Chapter 14 to satisfy the demands of plant operation well within applicable regulatory limits.

The reactor coolant pumps provided for the plant are supplied with sufficient rotational inertia to maintain an adequate flow coastdown and prevent core damage in the event of a simultaneous loss of power to all pumps.

In the unlikely event of a turbine trip from full power without an immediate reactor trip, the subsequent reactor coolant temperature increase and volume insurge to the pressurizer results in a high pressurizer pressure trip and thereby prevents fuel damage for this transient. A loss of external electrical load of 50% of full power or less is normally controlled by rod cluster insertion together with a controlled stream dump to the condenser to prevent a large temperature and pressure increase in the Reactor Coolant System and thus prevent a reactor trip. In this case, the overpower-overtemperature protection would guard against any combination of pressure, temperature, and power which could result in a DNB ratio less than the applicable limit during the transient.

In neither the turbine trip nor the loss-of-flow events do the changes in coolant conditions provoke a nuclear power excursion because of the large system thermal inertia and relatively small void fraction. Protection circuits actuated directly by the coolant conditions identified with core limits are therefore effective in preventing core damage.

Suppression of Reactor Power Oscillations Criterion 7: The design of the reactor core with its related controls and protection systems shall ensure that power oscillations, the magnitude of which could cause damage in excess of acceptable fuel damage limits, are not possible or can be readily suppressed.

The potential for possible spatial oscillations of power distribution for this core has been reviewed. It was concluded that low frequency xenon oscillations may occur in the axial dimension, and the control rods can suppress these oscillations. The core is expected to be stable to xenon oscillations in the X-Y dimension. Excore instrumentation is provided to obtain necessary information concerning power distribution. This instrumentation is adequate to enable the operator to monitor and control xenon induced oscillations. (In-core instrumentation is used to periodically calibrate and verify the information provided by the Excore 3 of 87 IPEC00035228 IPEC00035228

IP3 FSAR UPDATE instrumentation.) The analysis, detection and control of these oscillations is discussed in Reference 2 of Section 3.2.

Redundancy of Reactivity Control Criterion 27: Two independent reactivity control systems, preferably of different principles, shall be provided.

Two independent reactivity control systems are provided, one involving rod cluster control (RCG) assemblies and the other involving chemical shimming.

Reactivity Hot Shutdown Capability Criterion 28: The reactivity control systems provided shall be capable of making and holding the core subcritical from any hot standby or hot operating condition.

The reactivity control systems provided are capable of making and holding the core subcritical from any hot standby or hot operating condition, including those resulting from power changes.

The Rod Cluster Control (RCC) assemblies are divided into two categories comprising control banks, and shutdown banks. The control banks used in combination with chemical shim control provide control of the reactivity changes of the core throughout the life of the core during power operation. These banks of RCC assemblies are used to compensate for short term reactivity changes at power that might be produced due to variations in reactor power level or in coolant temperature. The chemical shim control is used to compensate for the more slowly occurring changes in reactivity throughout core life such as those due to fuel depletion and fission product buildup.

Reactivity Shutdown Capability Criterion 29: One of the reactivity control systems provided shall be capable of making the core subcritical under any anticipated operating condition including anticipated operational transients sufficiently fast to prevent exceeding acceptable fuel damage limits. Shutdown margin should assure subcriticality with the most reactive control rod fully withdrawn.

The reactor core, together with the reactor control and protection system was designed so that the minimum allowable DNBR is at least the applicable limit and there is no fuel melting during normal operation including anticipated transients.

The shutdown groups are provided to supplement the control groups RCC assemblies to make the reactor at least 1.3% subcritical at the hot zero power condition following trip from any credible operating condition assuming the most reactive RCC assembly is in the fully withdrawn position.

Sufficient shutdown capability is also provided to prevent an unacceptable return to power level, assuming the most reactive rod to be in the fully withdrawn position for the most severe anticipated cooldown transient associated with a single active failure, e.g., accidental opening of a stream bypass, or relief valve, or safety valve stuck open. This is achieved by the combination of control rods and automatic boric acid addition via the Emergency Core Cooling System. With the BIT functionally eliminated, the return to power following a credible steamline break accident has been evaluated showing that the event is bounded by the hypothetical 4 of 87 IPEC00035229 IPEC00035229

IP3 FSAR UPDATE steamline break. The departure from nucleate boiling (DNB) design basis is met with no consequential fuel failures predicted, and assuring that the return to power remains within the limits established for the protection of the health and safety of the public, with margin.

The minimum shutdown margin was calculated to be at least 1.3% @EOL conditions assuming the maximum worth control rod in the fully withdrawn position allowing 10% uncertainty in the control rod calculations.

Manually controlled boric acid addition is used to maintain the shutdown margin for the long term conditions of xenon decay and plant cool down. Redundant equipment is provided to guarantee the capability of adding boric acid to the Reactor Coolant System.

Reactivity Holddown Capability Criterion 30: The reactivity control systems provided shall be capable of making the core subcritical under credible accident conditions with appropriate margins for contingencies and limiting any subsequent return to power that there will be no undue risk to the health and safety of the public.

Normal reactivity shutdown capability is provided within 2.7 seconds following a trip signal by control rods, with boric acid injection used to compensate for the long term xenon decay transient and for plant cool down. As discussed in response to the previous criteria, the shutdown capability prevents return to critical as a result of the cooldown associated with a safety valve stuck fully open.

Any time that the reactor is at power, the quantity of boric acid retained in the boric acid tanks and ready for injection always exceeds that quantity required for the normal cold shutdown.

This quantity always exceeds the quantity of boric acid required to bring the reactor to hot shutdown and to compensate for subsequent xenon decay. Boric acid is pumped from the boric acid tanks by one of two boric acid transfer pumps to the suction of one of three charging pumps which inject boric acid into the reactor coolant. Any charging pump and either boric acid transfer pump can be operated from diesel generator power on loss of station power. Using either one of the two boric acid transfer pumps, in conjunction with anyone of the three charging pumps, the RCS can be borated to hot shutdown even with the control rods fully withdrawn. Additional boration would be used to compensate for xenon decay. At a minimum CVCS design boration rate of 132 ppm/hr, the boron concentration required for cold shutdown can be reached well before xenon decays below its pre-shutdown level. The RWST is a suitable backup source for emergency boration. When two charging pumps are used to transfer borated water from the RWST to the reactor coolant, the boron concentration required for cold shutdown can be reached before xenon decays below its full power pre-shutdown level.

On the basis of the above, the injection of boric acid is shown to afford backup reactivity shutdown capability, independent of control rod clusters which normally serve this function in the short term situation. Shutdown for long term and reduced temperature conditions can be accomplished with boric acid injection using redundant components, thus achieving the measure of reliability implied by the criterion.

Alternately, boric acid solution at lower concentration can be supplied from the refueling water tank. This solution can be transferred directly by the charging pumps or alternately by the safety injection pumps. The reduced boric acid concentration lengthens the time required to achieve equivalent shutdown.

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