NL-12-062, Supplement to Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System Is Out of Service

Supplement to Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System Is Out of Service

ML12138A176
Person / Time
Site:	Indian Point
Issue date:	05/02/2012
From:	Ventosa J Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-062, TAC ME8097
Download: ML12138A176 (6)

Text

EntMrgy Enterav Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President Administration May 2, 2012 NL-12-062 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

REFERENCES:

Supplement to Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System is Out of Service (TAC No. ME8097)

Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64 1.

Entergy Letter, NL-12-029, to NRC regarding Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System is Out of Service, dated February 6, 2012

2.

NRC Letter Regarding Acceptance Review for Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System is Out of Service (TAC No.

ME8097), dated April 18, 2012

Dear Sir or Madam:

Entergy Nuclear Operations, Inc, (Entergy) requested a License Amendment, Reference 1, to revise the Indian Point 3 (IP3) Updated Final Safety Analysis Report (UFSAR) to allow use of the Backup Spent Fuel Pool Cooling System (BSFPCS) when the Spent Fuel Pool Cooling System (SFPCS) is out of service. On April 18, 2012 the NRC staff identified the need for additional information to complete their acceptance review (Reference 2). Entergy is supplementing the original submittal with additional information in response to this request, see Attachment 1.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 254-6710.

AOpp thJAL

NL-12-062 Docket No. 50-286 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on May 2, 2012.

Sincerely,

Attachment:

1. Supplemental Information on Proposed Updated Final Safety Analysis Report Change Regarding Backup Spent Fuel Pool Cooling System cc:

Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspector, IP3 Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-12-062 SUPPLEMENTAL INFORMATION ON PROPOSED UPDATED FINAL SAFETY ANALYSIS REPORT CHANGE REGARDING BACKUP SPENT FUEL POOL COOLING SYSTEM ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

NL-12-062 Docket No. 50-286 Page 1 of 3 The proposed revision to the Updated Final Safety Analysis Report (UFSAR) Regarding Backup Spent Fuel Pool Cooling System was submitted to the NRC on February 6, 2012. On April 18, 2012 the NRC staff identified the need for additional information to complete their acceptance review. The following are the requests for information and the Entergy response.

Question 1 The application does not specifically address the findings of the 2001 Special Inspection of the BSFPCS and their resolution. This includes:

1. Reliability of the BSFPCS versus reliability of the SFPCS.

2. Use of the SFP High Temperature Alarm during periods of elevated SFP temperature.

3. Risk management actions to be put in place during use of the BSFPCS with SFPCS out of service.

Response

1. The BUSFPCS provides a less reliable SFP cooling source than the normal SFP cooling system because there is less time to recover a loss of SFP cooling. The SFPCS can operate at any SFP temperature up to boiling (212 0F). The BSFPCS can only operate up to a SFP temperature of about 196 0F, at which time the primary pump loses NPSH, with the resultant loss of SFP cooling and continued heat up to boiling. Physical modifications to the BSFPCS since the special NRC inspection of the BSFPCS (05000286/2001-006) are the hard piping of the makeup water and the backup fire protection water discussed in the original submittal. No other physical modifications have been made.

Administrative controls will be used as follows:

" Effective recovery actions will be defined for normal types of events (e.g., loss of power, loss of makeup water, pump failure, loss of suction, etc) when only the BSFPCS is operating. These recovery actions will be evaluated for time of implementation in order to allow assessment of practical actions before 1960F is reached for various pool temperatures and heat-up rates.

Monitoring the wet bulb temperature, monitoring BSFPCS operation and monitoring the contractor water system supply will be performed in the time frame to raise temperature in the SFP by 50F if the BSFPCS were to be lost.

2. The SFP High Temperature alarm set point will be administratively controlled to assure that the alarm alerts the control room that the peak calculated temperature is exceeded for any evolution where the SFPCS is taken out of service and the BSFPCS is relied upon.

3. A shutdown risk assessment is a quantitative assessment and could not be performed to evaluate the color condition that would be entered while operating only the BSFPCS since this condition is not currently allowed (since the BSFPCS is not currently licensed for use, our risk management procedure does not allow use to take both SFPC pumps out of service). The risk

NL-12-062 Docket No. 50-286 Page 2 of 3 management procedure will be revised to reflect licensing of the BSFPCS with the various risk mitigation measures. We believe that this condition will put the plant in no higher than a yellow condition. The procedure does not allow entry into a red condition.

The proposed FSAR revision Section 9.13.3 in the February 6, 2012 letter will be modified to reflect the above by changing the last paragraph from:

"Administrative controls will be in place to assure that the BSFPCS is used as the sole source of heat removal only under the following conditions:

1. Work will be scheduled when the SFP heat load is at a reduced value rather than the design value.

2. A backup diesel will be tested and made available where the scheduled work exceeds the time to raise the temperature to boiling without cooling.

3. The SFP will be brought to temperature as low as feasible, but not lower than the design temperature, prior to starting the work.

4. The wet bulb temperature is at or below the temperature that will keep the SFP below 1750F for the residual heat load at the time work starts."

To say the following:

"Administrative controls will be in place to assure that the BSFPCS is used as the sole source of heat removal only under the following conditions:

1. Work will be scheduled when the SFP heat load is at a reduced value rather than the design value.

2. A backup diesel will be tested and made available where the scheduled work exceeds the time to raise the temperature to boiling without cooling.

3. The SFP will be brought to temperature as low as feasible, but not lower than the design temperature, prior to starting the work.

4. The wet bulb temperature is at or below the temperature that will keep the SFP below 1750F for the residual heat load at the time work starts.

5. The approximate time for recovery actions defined for normal types of events (e.g.,

loss of power, loss of makeup water, pump failure, loss of suction, etc) will be identified and, if there is a loss of BSFPCS, those which could be implemented before 1960F is reached will be used.

6. Monitoring of the wet bulb temperature, BSFPCS operation and contractor water system supply will be performed at a frequency consistent with the time for the SFP to rise by 50F if the BSFPCS were to be lost.

N L-1 2-062 Docket No. 50-286 Page 3 of 3

7. The SFP High Temperature alarm set point will assure that the alarm alerts the control room that the calculated temperature is exceeded."

Question 2 In order to preserve existing margin, the heat removal capacity of the BSFPCS should not be considered when calculating the delay time prior to spent fuel offload from the reactor. The application does not clarify whether the BSFPCS heat removal capacity will be credited together with the SFPCS heat removal capacity when calculating this delay time. (As described in UFSAR Section 9.3.3).

Response

The existing margin will be maintained by clarifying that the heat removal capacity of the BSFPCS will not be credited when calculating the delay time prior to spent fuel offload from the reactor. This will be accomplished as follows:

The February 6, 2012 letter proposed to revise Section 9.3.3 which currently reads as follows:

"The Backup Spent Fuel Pool Cooling system has been installed to allow for operation in parallel with the Normal SFP Cooling System to improve pool conditions during refueling activities. The BSFPCS is a manual system served by an independent cooling water source (demineralized water). A primary loop handles the SFP water and consists of two 100% capacity pumps, a plate heat exchanger, associated piping, and local instrumentation. A secondary loop is the heat sink for the system, and includes two, open-circuit evaporative cooling towers, two 100 % capacity feed pumps, associated piping, and local instrumentation. Make-up and fill for the secondary loop is normally provided by demineralized water, with an alternate, emergency source available through the Fire Protection System.

Power for all equipment is supplied from the 480 VAC MCCs El and E2. For greater availability of power, and reliability of the cooling function, the BSFPCS includes a transfer switch that allows alignment to either the normal power sources MCC El and E2, or a rental diesel generator unit (with Engineering discretion). This feature allows an alternate power source in the event the MCCs become inoperable."

The proposed revision will be altered to the following:

"The Backup Spent Fuel Pool Cooling system has been installed to allow maintenance and repair and operate in parallel with the Normal SFP Cooling System to improve pool conditions during refueling activities (see Section 9.13). The heat removal capacity of the Backup Spent Fuel Pool cooling System is not allowed to be credited when calculating the delay time prior to spent fuel offload from the reactor."