ML12319A092

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Issuance of Amendment Request to Use the Backup Spent Fuel Pool Cooling System When the Spent Fuel Pool Cooling System Is Out of Service
ML12319A092
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 01/28/2013
From: Pickett D
Plant Licensing Branch 1
To:
Entergy Nuclear Operations
Pickett D
References
TAC ME8097, FOIA/PA-2016-0148
Download: ML12319A092 (13)


Text

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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.3-ISSUANCE OF AMENDMENT RE: REQUEST TO USE THE BACKUP SPENT FUEL POOL COOLING SYSTEM WHEN THE SPENT FUEL POOL COOLING SYSTEM IS OUT OF SERVICE (TAC NO. ME8097)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 249 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Updated Final Safety Analysis Report (UFSAR) in response to your application dated February 6,2012, as supplemented by letters dated May 2 and August 6,2012.

The amendment approves changes to UFSAR Section 9.13. "Backup Spent Fuel Pool Cooling System." to allow use of the backup spent fuel pool cooling system when the spent fuel pool cooling system is out of service.

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.

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286

Enclosures:

1. Amendment No. 249 to DPR-64
2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 ENTERGY NUCLEAR INDIAN POINT 3, LLC ENTERGY NUCLEAR OPERATIONS, INC.

DOCKET NO. 50-286 INDIAN POINT NUCLEAR GENERATING UNIT NO.3 AMENDMENT TO FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATIONS Amendment No. 249 License No. DPR-64

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

A. The application for amendment by Entergy Nuclear Operations, Inc. (the licensee) dated February 6,2012, as supplemented on May 2 and August 6, 2012, 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 Updated Final Safety Analysis Report, and paragraph 2.C.(2) of Facility Operating License No. DPR-64 is hereby amended to read as follows:

-2 (2) Technical Specifications The Technical Specifications contained in Appendices A, B, and C as revised through Amendment No. 249, are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications.

3. The license amendment is effective as of its date of issuance and shall be implemented within 30 days. Implementation of the amendment shall also include revision of the Updated Final Safety Analysis Report as described in the licensee's letter dated February 6, 2012, as supplemented by letters dated May 2 and August 6, 2012.

FOR THE NUCLEAR REGULATORY COMMISSION

~~d George A. Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License Date of Issuance: January 28. 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 249 FACILITY OPERATING LICENSE NO. DPR-64 DOCKET NO. 50-286 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

- 3 (4) ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, Amdt. 203 to receive, possess, and use in amounts as required any 11/27/00 byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5) ENO pursuant to the Act and 10 CFR Parts 30 and 70, to Amdt. 203 possess, but not separate, such byproduct and special 11/27/00 nuclear materials as may be produced by the operation of the facility.

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; and 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 ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 3216 megawatts thermal (100% of rated power).

(1) Technical Specifications The Technical Specifications contained in Appendices A, B. and C, as revised through Amendment No. 249. are hereby incorporated in the License. ENO shall operate the facility in accordance with the Technical Specifications.

(3) (DELETED) Amdt. 205 2-27-01 (4) (DELETED) Amdt. 205 2-27-01 D. (DELETED) Amdt.46 2-16-83 E. (DELETED) Amdt.37 5-14-81 F. This amended license is also subject to appropriate conditions by the New York State Department of Environmental Conservation in its letter of May 2, 1975, to Consolidated Edison Company of New York, Inc., granting a Section 401 certification under the Federal Water Pollution Control Act Amendments of 1972.

Amendment No. 249

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 249 TO FACILITY OPERATING LICENSE NO. DPR-64 ENTERGY NUCLEAR OPERATIONS, INC.

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

1.0 INTRODUCTION

By letter dated February 6,2012, Agencywide Documents Access and Management System (ADAMS) Accession No. ML12060A322, as supplemented by letters dated May 2 (ADAMS Accession No. ML12138A176) and August 6,2012 (ADAMS Accession No. ML12226A003),

Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request for changes to the Indian Point Nuclear Generating Unit NO.3 (IP3) Updated Final Safety Analysis Report (UFSAR). The amendment would revise the 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.

The supplements dated May 2 and August 6, 2012, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on August 21,2012 (77 FR 50537).

2.0 REGULATORY EVALUATION

The following explains the applicability of General Design Criteria (GDC) for IP3. The construction permit for IP3 was issued by the Atomic Energy Commission (AEC) on August 13, 1969, and the operating license was issued on December 12, 1975. The plant GDC are discussed in the 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 IP3 are those in the UFSAR.

As discussed in the UFSAR, the licensee for IP3 has made some changes to the facility over the life of the unit that has committed to some of the GDCs from 10 CFR Part 50, Appendix A.

-2 The extent to which the Appendix A GDC have been invoked can be found in specific sections of the UFSAR and in other IP3 licensing basis documentation, such as license amendments.

GDC-61 of 10 CFR 50 Appendix A, "Fuel Storage and Handling and Radioactivity Control,"

requires, in part, that fuel storage and handling systems be designed to assure adequate safety under normal and postulated accident conditions, to have residual heat removal capability and to prevent significant reduction in fuel storage coolant inventory under accident conditions.

While the licensing of IP3 predates the issuance of GDC-61, a discussion of the plant's compliance with the requirements of GDC-61 is contained in Section 1.3 of the IP3 UFSAR. As described in the UFSAR, the spent fuel pool (SFP) cooling system has been designed to remove the heat generated by stored spent fuel assemblies and the SFP structure has been designed such that it is not possible to uncover the spent fuel by way of drains or piping connections.

Section 10 CFR 50.65(a){4), "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," requires licensees to assess and manage the increase in risk that may result from proposed maintenance activities. With the SFPCS out of service for maintenance or repair, the function of removing heat from the SFP would be performed by the BSFPCS. Per the proposed amendment, the licensee will employ additional administrative controls to ensure that the BSFPCS will have adequate heat transfer capabilities and reliability while it operates as the sole source of cooling for the SFP.

The SFPCS is designed to remove the heat load associated with a full core offload in addition to six previously discharged cores. A pump draws water from the SFP, circulate it through a heat exchanger cooled by component cooling water, and return it to the SFP. The SFPCS is designed to seismic Class II and the SFP demineralizer cleanup loop is designed to seismic Class III. The SFP is constructed of reinforced concrete with a stainless steel liner and is designed to seismic Class I. Design tornado missiles will not penetrate the walls of the SFP.

As described in Section 9.3.3 of the UFSAR, failure of the SFPCS or the SFP cleanup loop will not result in the uncovering of the spent fuel in the SFP.

The BSFPCS is described in Section 9.3.3 of the UFSAR. Similar to the SFPCS, the BSFPCS is designed to seismic Class II. The system is designed to preclude seismic interaction with the SFP and its components. The BSFPCS is composed of a primary loop that circulates water from the SFP through a heat exchanger and a secondary loop that provides the heat sink. The primary loop consists of two 100 percent capacity pumps, a plate heat exchanger, associated piping, and local instrumentation. The secondary loop contains two open-circuit evaporative cooling towers, with make-up provided by the demineralized water system, two 100 percent capacity pumps, associated piping, and local instrumentation. As described in the UFSAR, the BSFPCS is used in parallel with the SFPCS to provide additional cooling during refueling operations.

The BSFPCS was originally installed under the 10 CFR 50.59 change process in 1999 and was intended for operation as a standalone system in order to remove the SFPCS from service for maintenance. In 2001, an NRC special inspection found that the licensee had violated 10 CFR 50.59, as it was written at the time of the change, by removing the SFPCS from service and relying on the BSFPCS alone for SFP cooling. The inspection team determined that operation of the BSFPCS as a standalone system without the SFPCS available required NRC approval of

-3 a license amendment prior to implementation because the BSFPCS was less reliable than the SFPCS. Additionally, the inspection team identified issues with the licensee's risk management actions and the control of procedures to identify and mitigate a loss of SFP cooling. These findings were summarized in Inspection Report 05000286/2001-006 (ADAMS Accession No ML012270430).

Following the NRC special inspection, the findings were entered into the licensee's corrective action program. As a result, the licensee improved the reliability of the BSFPCS by installing permanent piping for the primary and backup sources of cooling tower makeup. In the time since the special inspection, the BSFPCS has only been put into service in parallel with the SFPCS.

The proposed license amendment would modify the IP3 UFSAR to allow standalone use of the BSFPCS when the SFPCS is unavailable due to maintenance or repair. Use of the BSFPCS as a standalone system is expected to be infrequent. The licensee has identified administrative controls for the purpose of managing the risk associated with having the SFPCS out of service.

The licensee has identified necessary maintenance activities that will result in unavailability of the SFPCS. First, the SFPCS heat exchanger must be inspected to satisfy IP3 License Renewal commitments. Second, two service water system valves require repair or replacement. The proposed amendment would allow the licensee to complete these maintenance activities while continuing to provide adequate cooling of the SFP.

The SFPCS heat exchanger inspection is planned for the end of the current operating cycle, before fuel has been discharged from the reactor vessel. Without fresh spent fuel assemblies in the SFP, the heat load will be lower and more time will be available to take actions in the event of a loss of SFP cooling. The service water valve maintenance will require draining the service water system. Service water cools the residual heat removal loop, component cooling water loop, and by extension the SFPCS. With the service water system drained, these systems are rendered unavailable. Residual heat removal provides cooling for the reactor coolant system during shutdown; therefore, the full core must be offloaded to the SFP during this maintenance activity. This means that the higher heat load in the SFP associated with a full core offload must be cooled while the SFPCS is unavailable and the additional risk associated with this configuration must be managed.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the proposed amendment to assure that the risk associated with removing the SFPCS from service during maintenance or repair would be adequately managed.

The BSFPCS was compared to the SFPCS to assess any gaps in heat removal capability.

Consideration was given to the proposed administrative controls in determining whether the BSFPCS provides adequate heat removal to approve its use as a standalone system during maintenance. In its review, the staff used guidance from Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants,"

endorsed in NRC Regulatory Guide 1.160, "Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," to evaluate the acceptability with respect to 10 CFR 50.65(a)(4).

- 4 The NRC staff compared the design of the SFPCS and BSFPCS to evaluate whether the BSFPCS by itself could provide adequate cooling for the SFP. Currently the SFPCS will maintain the SFP bulk temperature below 200°F with a full core discharge, as stated in UFSAR Section 9.3.1. The maximum heat load allowable is that which will ensure the SFP temperature remains below 200°F with the SFPCS in service. The SFPCS includes two redundant pumps to circulate SFP water, one heat exchanger, and the system discharges heat to the safety-related component cooling water (CCW) system. The SFPCS pumps can operate at all temperatures up to SFP boiling, and can be powered by the emergency diesel generators if needed.

The proposed amendment states that the BSFPCS will maintain the SFP bulk temperature below 175°F when the SFPCS is out of service. The maximum heat load allowable with only the BSFPCS in service is variable based upon the outside wet bulb temperature. The BSFPCS has two redundant primary loop pumps, two redundant secondary loop pumps, and one heat exchanger. It discharges heat to the atmosphere via two 50 percent capacity cooling towers.

The BSFPCS primary loop pumps can only operate up to a SFP temperature of approximately 196°F before losing net positive suction head. Both the primary and secondary loop pumps can be powered by a portable diesel generator if power is lost.

With consideration for the heat load in the SFP and outside temperature, the BSFPCS is capable of providing adequate cooling for the SFP. The proposed temperature limit of 175°F for the BSFPCS is lower than the currently licensed limit for the SFPCS. However, the main gap between the SFPCS and BSFPCS lies in the reduced reliability of the BSFPCS heat sink (due to equipment failure or loss of makeup), the variation of its maximum heat load with weather, and the loss of net positive suction head as the SFP temperature increases. In the license amendment request and supplements, the licensee proposed the following administrative controls to compensate for any reduction in reliability when the BSFPCS is operating alone:

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 to power the BSFPCS when the scheduled work exceeds the time to raise the temperature to boiling without cooling.
3. The SFP will be brought to a temperature as low as reasonable, but not lower than the lower design temperature limit, prior to starting the work.
4. The ambient wet bulb temperature will be assured to be at or below the temperature, with a 5°F margin, which is calculated to keep the SFP below 150°F (for online work) and 175°F (for core offload work) given the residual heat load at the time work starts.

Additional margin will be provided by keeping recovery times within the time the SFP would reach 190°F. The recovery time is the time to detect BSFPCS failure (i.e., based on monitoring times) added to the time to restart the main or redundant pumps on the backup diesel (assumes offsite power lost) given the residual heat load at the time the work starts. The time to start the diesel and pumps will be demonstrated in the field in order to determine time required. The wet bulb temperature will be taken about noon on the day work is to commence (or the day before) in order to allow for daily temperature swings.

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 196°F is reached

-5 will be used. The licensee's letter of August 6, 2012, provided a single failure analysis of the BSFPCS and associated actions to prevent SFP temperatures from reaching 196°F.

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 5°F if the BSFPCS were to be lost. For example, if the SFP temperature rise was 10°F per hour, then the wet bulb temperature will be taken every 30 minutes and the proper operation of the BSFPCS and the makeup water supply will be validated every 30 minutes.
7. The SFP High Temperature alarm set point will assure that the alarm alerts the control room that the calculated temperature is exceeded.
8. The normal water supply and backup water supply to the secondary loop of the BSFPCS and the sources of SFP makeup (Primary Water Storage Tank, RWST through the plant demineralizers and from the Fire Water Tank) will be protected when the BSFPCS is the only source of cooling.

These administrative controls limit the maximum heat load in the SFP, provide margin to account for variations in weather, establish frequent monitoring of the system functions, and require planning for mitigation and recovery actions following a loss of SFP cooling.

By adding a 5°F margin to the measured wet bulb temperature, the licensee conservatively addresses the cooling capacity of the BSFPCS. Combined with the control that work will be scheduled when the SFP heat load is at a reduced value, this will establish margin between the BSFPCS heat removal capability and the SFP heat load. Establishing this margin limits the impact of unforeseen changes in the weather on the BSFPCS heat removal capability. This available margin will expand over time as the spent fuel assemblies in the SFP continue to cool.

When the BSFPCS is operating as the only source of SFP cooling, the licensee will maintain a heightened awareness of the system performance in order to quickly identify problems that impact the cooling capability. Frequent monitoring of the system, as proposed, will provide more opportunities to find and resolve problems with the system quickly. Should there be a failure of the BSFPCS that is not identified by monitoring, the SFP High Temperature alarm will provide additional indication to the control room.

In the event of a failure of the BSFPCS, the time available for diagnosing and resolving the failure will be limited. Under the proposed administrative controls, the licensee will have evaluated potential failure modes, evaluated the time required for recovery, and staged a backup diesel prior to starting the maintenance. Makeup sources to the SFP will be protected in accordance with plant procedures to ensure they remain available while the BSFPCS is in service and there is adequate time to align makeup if it is required.

In addition, license conditions require that the licensee develop and maintain mitigation strategies to prevent fuel damage in the SFP following large fires and explosions. Procedures have been developed to implement pre-positioned equipment that can be used to supply emergency makeup water to the SFP. The licensee has identified diverse water sources and means of supplying cooling water to the SFP within a short period of time if necessary.

The guidance of NUMARC 93-01 suggests that risk management actions focus on providing increased risk awareness, providing more rigorous planning and control of the activity,

- 6 controlling the duration of the increased risk, and limiting the magnitude of the increased risk.

Additionally the risk assessment should reflect appropriate planning and contingencies to address loss of SFP cooling. The NRC staff has evaluated the BSFPCS design and capability along with the proposed administrative controls governing the system's usage and finds that they meet the goals expressed in the NUMARC 93-01 guidance. Based on the information provided describing the usage of the BSFPCS and administrative controls, the staff finds that there is reasonable assurance that the licensee will assess and manage the risk associated with maintenance activities in accordance with the requirement of 10 CFR 50.65(a)(4).

The NRC staff reviewed the proposed license amendment to ensure that there would be no effect on the plant's compliance with GOC-61, as documented in Section 1.3 of the UFSAR, or the design basis for the SFPCS. No physical plant modifications were identified in the amendment. Section 9.3.3 of the UFSAR describes the calculation of delay time prior to offloading spent fuel from the reactor, the basis for which is the heat removal capability of the SFPCS. The staff issued a request for additional information to clarify that the BSFPCS heat removal capability would not be added to that of the SFPCS when calculating the delay time before spent fuel offload from the reactor. In its response, the licensee stated that the BSFPCS heat removal capability would not be credited when calculating this delay time and provided a revision to UFSAR Section 9.3.3 reflecting this statement. No other possible impacts were identified; therefore the staff finds that there will be no change in the plant's compliance with GOC-61 or the SFPCS design basis.

The proposed license amendment will allow the license to use the BSFPCS as a standalone system for SFP cooling when the SFPCS is out of service for maintenance or repair. The BSFPCS will continue to be allowed to operate in parallel with the SFPCS to improve SFP conditions during refueling. The licensee has provided information demonstrating that there is reasonable assurance that the risk associated with maintenance of the SFPCS will be appropriately assessed and managed in accordance with 10 CFR 50.65(a)(4). In addition, through a combination of administrative controls and monitoring during system operation, the licensee has demonstrated that the BSFPCS will provide sufficient cooling to maintain the SFP within acceptable limits. Based on these findings, the NRC staff finds the proposed license amendment to be 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 (77 FR 50537). Accordingly, the amendment meets the eligibility criteria for categorical

-7 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) there is reasonable assurance that 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: Evan Davidson Date: January 28,2013

January 28, 2013 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.3 - ISSUANCE OF AMENDMENT RE: REQUEST TO USE THE BACKUP SPENT FUEL POOL COOLING SYSTEM WHEN THE SPENT FUEL POOL COOLING SYSTEM IS OUT OF SERVICE (TAC NO. ME809?)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 249 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Updated Final Safety Analysis Report (UFSAR) in response to your application dated February 6,2012, as supplemented by letters dated May 2 and August 6,2012.

The amendment approves changes to UFSAR Section 9.13, "Backup Spent Fuel Pool Cooling System," to allow use of the backup spent fuel pool cooling system when the spent fuel pool cooling system is out of service.

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, IRA!

Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-286

Enclosures:

1. Amendment No. 249 to DPR-64
2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

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