ML13046A166

Issuance of Amendment Connecting Non-Seismic Purification System Piping to the Refueling Water Storage Tank

ML13046A166
Person / Time
Site:	Indian Point
Issue date:	02/22/2013
From:	Pickett D Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Pickett D
References
TAC ME9263
Download: ML13046A166 (25)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 22, 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: CONNECTING NON-SEISMIC PURIFICATION SYSTEM PIPING TO THE REFUELING WATER STORAGE TANK (TAC NO. ME9263)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 250 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Technical Specifications (TS) in response to your application dated August 14, 2012, as supplemented by letters dated October 25, November 14, December 13,2012, and February 15, 2013.

The amendment revises Technical Specification 3.5.4, "Refueling Water Storage Tank," to permit non-seismically qualified piping of the Spent Fuel Pool purification system to be connected to the Refueling Water Storage Tank seismic piping under administrative controls for a limited period of time in order to purify the contents of the Refueling Water Storage Tank.

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. 250 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 2, 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. 250 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 August 14, 2012, as supplemented on October 25, November 14, December 13, 2012, and February 15, 2013, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-64 is hereby amended to read as follows:

- 2 (2)

Technical Specifications The Technical Specifications contained in Appendices A, Band C, as revised through Amendment No. 250, are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

.~ c.,tL ~-L2Y George A. Wilson, Chief Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: February 22, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 250 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 Replace the following page of the Appendix A Technical Specifications with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3.5.4-1 3.5.4-1

- 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. 250, 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. 250

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST and two channels of RWST low level alarm shall be OPERABLE.

NOTE 1 The RWST isolation valves AC-727A, AC-727B and AC-725 connected to non-safety related piping may be opened under administrative controls for up to 14 days per fuel cycle for filtration until the end of refuel outage 18.

APPLICABILITY :

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

RWST boron concentration not within limits of SR 3.5.4.3.

OR RWST borated water temperature not within limits of SR 3.5.4.1.

B.

One channel of RWST low level alarm inoperable.

A.1 B.1 Restore RWST to OPERABLE status.

Restore RWST low level alarm to OPERABLE status.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> 7 days C.

RWST inoperable for reasons other than Condition A or B.

C.1 Restore RWST to OPERABLE status.

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> D.

Required Action and associated Completion Time not met.

0.1 AND Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 0.2 Be in MODE 5.

36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> INDIAN POINT 3 3.5.4-1 Amendment 250

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 250 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 August 14, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12234A098), as supplemented by letters dated October 25 (ML12319A007), November 14 (ML12340A439), December 13,2012 (ML12361A048), and February 15, 2013, Entergy Nuclear Operations, Inc. (Entergy or the licensee) submitted a request for changes to the Indian Point Nuclear Generating Unit No.3 (IP3) Technical Specifications (TSs). The amendment revises TS 3.5.4, "Refueling Water Storage Tank," to permit non-seismically qualified piping of the Spent Fuel Pool (SFP) purification system to be connected to the Refueling Water Storage Tank (RWST) seismic piping under administrative controls for a limited period of time in order to purify the contents of the Refueling Water Storage Tank.

Historically, until February 15, 2012, IP3 was periodically using the SFP Purification Loop to filter the RWST water while in plant conditions and modes for which the RWST was required to be operable. The licensee used this alignment prior to refueling outages to filter the RWST water. During refueling outages, RWST water is used to flood the refueling cavity to support fuel movement. Filtering the RWST water in advance of the refueling outage is highly desirable in order to remove suspended solids and improve water clarity so that refueling bridge operators can clearly identify fuel assemblies prior to fuel movement. The licensee has developed procedures to direct manual operator actions to isolate the RWST from the SFP Purification Loop in the event of Control Room direction, safety injection (SI) signal actuation, instrumentation being inoperable, seismic motion, or unidentified area flooding. This operation was discontinued following the issuance of Information Notice (IN) 2012-01 "Seismic Considerations-Principally Issues Involving Tanks," on January 26, 2012 (ML11292A175).

Nuclear Regulatory Commission (NRC) IN 2012-01 provided examples and references to events in which licensees failed to recognize various seismic considerations and system alignment issues that could impact safety. Examples were identified in which licensees failed to recognize that aligning non-seismic piping to the RWST would require TS [Limiting Conditions for Operation] action statement entry. system modifications, or license amendments. The IN

- 2 noted that the TSs would not allow applying compensatory measures, such as manual actions in place of the closed boundary valve, for periods longer than the TS completion time for restoring the RWST to operable status, unless the TS expressly permit operation under such measures.

The licensee's letter of August 14, 2012, recognizes the circumstances described in the IN, including the need to apply for an amendment of TS 3.5.4 such that the TS would expressly permit operation under the specific circumstances of RWST recirculation for filtration to improve the quality of the water for refueling activities. Accordingly, the licensee submitted this license amendment request to seek NRC approval to permit non-seismically qualified piping of the Spent Fuel Pool purification system to be connected to the Refueling Water Storage Tank seismic piping under administrative controls for a limited period of time in order to purify the contents of the Refueling Water Storage Tank. This would be accomplished by realigning manual valves that are designated as American Society of Mechanical Engineers (ASME) code boundary valves. The piping configuration would only be permitted for a maximum of 14 days prior to the Spring 2013 and 2015 refueling outage for IP3. Following the Spring 2015 refueling outage, a permanent modification will be completed so that connection of seismic and non seismic piping would not be necessary to filter the RWST water.

The licensee has proposed to add the following note to TS 3.5.4:

'The RWST isolation valves AC-727A, AC-727B and AC-725 connected to nonsafety related piping may be opened under administrative controls for up to 14 days per fuel cycle for filtration until the end of refuel outage 18" The supplements dated October 25, November 14, December 13,2012, and February 15,2013, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination.

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 Updated Final Safety Analysis Report (UFSAR) Chapter 1.3, "General Design Criteria," with more details given in the applicable UFSAR sections. The AEC published the final rule that added Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," in the Federal Register (36 FR 3255) on February 20, 1971, with the rule effective on May 21, 1971. In accordance with an NRC staff requirements memorandum from S. J. Chilk to J. M. Taylor, "SECY-92-223 - Resolution of Deviations Identified During the Systematic Evaluation Program," dated September 18, 1992 (ADAMS Accession No. ML003763736), the Commission decided not to apply the Appendix A GDC to plants with construction permits issued prior to May 21, 1971. Therefore, the GDC which constitute the licensing bases for 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.

- 3 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.

The Commission's regulatory requirements related to the contents of TSs, set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, require that the TS limiting conditions for operations are consistent with assumed values of the initial conditions in the licensee's safety analyses. Section 50.36(c)(2)(i) states: "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

Title 10 of the Code of Federal Regulations, Part 50, Appendix A, "General DeSign Criteria for Nuclear Power Plants," establishes the minimum requirements for the principal design criteria of nuclear power plants.

Regulatory Guide 1.13 (RG 1.13), "Spent Fuel Storage Facility DeSign Bases," contains guidance for the design of spent fuel storage facilities to ensure conformance with the relevant GDCs. Regulatory Position C.6 states that drains or permanently connected systems that could reduce the coolant inventory to unsafe levels should not be installed. Regulatory Position C.13 states that a filtering system should be provided to remove radioactive materials and other contaminants from the spent fuel pool coolant.

3.0 TECHNICAL EVALUATION

3.1 Reactor Systems 3.1.1 Regulatory Evaluation NRC IN 2012-01, "Seismic Considerations - Principally Issues Involving Tanks" states, 'This IN provides examples and references to events in which licensees failed to recognize various seismic considerations and system alignment issues that could impact safety. The NRC staff has identified recent concerns about standby liquid control test tanks that were not seismically qualified when they contained water. This operating experience may apply to other tanks found on site at nuclear plants. The NRC identified other examples in which licensees failed to recognize that aligning non-seismic piping to the RWST would require TS LCO action statement entry, system modifications, or license amendments."

General Design Criteria (GDC):

GDC 2, "Design bases for protection against natural phenomena," requires that structures, systems and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions.

GDC 35, "Emergency core cooling," requires, in part, that a system to provide abundant emergency core cooling shall be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad

- 4 damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

3.1.2 Technical Evaluation During plant operation in Modes 1 through 4, the RWST is required to be operable to maintain a borated water supply for accident mitigation purposes. The RWST is aligned to the suction of the high head safety injection pumps during normal operation in Modes 1 through 4. The suction of the charging pumps is automatically aligned to the RWST on a safety injection signal.

During refueling operation in Modes 5 and 6, the RWST is required to be operable as a borated water supply should the boric acid storage system not be operable. The contents of the RWST are also used to flood the refueling cavity during refueling operations. The water in the RWST is borated to a concentration sufficient to ensure shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor.

The SFP Purification Loop is a subsystem of the spent fuel pool cooling system that is connected to portions of the RWST piping. The SFP Purification Loop piping is nonsafety grade and is not seismically qualified. During an evaluation of a seismic event, the failure of the non seismic SFP Purification Loop piping must be considered. Such a failure could potentially result in a loss of RWST inventory should the ASME code boundary valves between the RWST and the SFP Purification Loop be open with the SFP Purification Loop aligned to the RWST.

The licensee's Final Safety Analysis Report (FSAR) states "A second pumping system is used to circulate refueling water through the demineralizer and filter for purification. This is permitted under administrative controls (I.e., an operator familiar with the operational restrictions of the RWST Purification System who is in contact with the control room)." This system is connected to the Residual Heat Removal Pump suction line. The RWST is purified by pumping the water through the Spent Fuel Pit Demineralizer and the Spent Fuel Pit Filter before returning it to the RWST. The licensee stated that past practice was to circulate RWST water through the SFP filters for up to 30 days before refueling outages. Thus, past practice was longer than the 14 days currently being requested. The licensee also stated that minimum detectable levels of suspended solids were reached prior to 14 days of operation. Therefore, 14 days of operation should be sufficient time to remove suspended solids to minimum detectable levels. In order to support system alignment. the licensee has credited operator actions to close the RWST piping's seismically qualified manual code boundary valves in the event of a seismic or other event that requires isolation.

The licensee proposes to add a note to TS 3.5.4 to allow the SFP Purification Loop to be aligned to the RWST to filter the RWST water for up to 14 days per fuel cycle until the end of Refueling Outage 18. This would include both the Spring 2013 and 2015 refueling outages.

The note would allow this alignment under administrative controls. Administrative controls include procedures to isolate the SFP purification system based on events or direction from the control room. Also, methods of communication between the operator and the control room are discussed in the procedures.

Valves AC-725 and AC-727 A are on the inlet of the SFP Purification loop. These valves are seismic class 1 qualified valves. The globe valve AC-727 A is located upstream of the refueling water purification pump; the diaphragm valve AC-725 is located downstream of the refueling

- 5 water purification pump and is part of the class 1 seismic boundary. The return line also has valves to isolate from the non-seismic piping. Check valve AC-726B, globe valve AC 727B, and diaphragm valve SI-841 are seismic class 1 and can be used to isolate the return line from the non-seismic SFP purification system piping.

Prior to purification, administrative controls require the RWST level to be raised to the overflow level of 36.8 feet and overflow must be observed. Also the Plant Integrated Computer System is set so that a signal provides an alarm prior to the RWST level dropping to 36 feet. An alarm generated at 36 feet provides control room operators with time to take action before the RWST level reaches the TS minimum level of 35.4 feet. Other actions that will cause flow into or out of the RWST are also stopped before purification starts.

The licensee did not propose the use of a dedicated operator (i.e., one who has no other responsibilities during this system alignment) to isolate the manual operated valves. This is not necessary due to the unique design at IP3. The containment design includes internal recirculation pumps and heat exchangers that will be used for approximately 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> before contaminated sump water will be recirculated outside containment. Therefore, plant operators will have approximately 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to take the operator manual actions to realign the valves.

Plant operators are trained to perform the task and the procedure requires heightened awareness which involves directions to isolate on any of the events or direction required. The deSignated operators walk down the valves and the refueling water purification pump switch.

Procedurally, the operators are required to maintain the purification flow at s1 00 gpm using the seismic class 1 AC-727B valve to throttle the flow. Assuming a flow rate of 100 gpm, it would take approximately 46 minutes for the RWST to drain through the 2" pipe from the alarm level of 36 feet to the minimum TS required level of 35.4 feet assumed for FSAR accident analyses.

The licensee also calculated that the time to drain the RWST from the overflow setpoint of 36.8 feet to the TS minimum level of 35.4 feet is 100.3 minutes.

A verification walkdown to demonstrate the feasibility of control room operators to manually isolate the SFP purification system was last performed on November 19, 2012. The operator proceeded at a normal pace from the control room and completed the tasks of stopping the refueling water purification pump and closing manual valves AC-725 and AC-727A on the inlet of the SFP purification loop and manual valve AC-727B on the return line to the RWST. The time that it took to complete the task was 5 minutes. This verification walkdown provides reasonable assurance that the RWST will be isolated from the SFP Purification Loop within the 46 minutes of time calculated before the RWST water level reaches the TS minimum required level, such that there will be sufficient margin to the TS required RWST water level.

Isolation of the non-seismic SFP purification piping from the seismic RWST piping can be accomplished by closing at least one manual valve in both the RWST inlet and discharge piping.

The IP3 deSign includes two seismic class 1 manual valves in series in both the RWST inlet and discharge piping. and the administrative controls require the designated operator to close all four valves in addition to stopping the refueling water purification pump. The NRC staff has concluded that there is reasonable assurance that the deSignated operator will be able to perform his required functions within the procedurally required 46 minute completion time. As a result, the current TS required RWST water level and the current accident analysis remain valid.

- 6 3.1.3 Summary and Conclusion The NRC staff has reviewed the proposed changes to TS 3.5.4 that will permit non-seismically qualified piping of the SFP purification system to be connected to the RWST seismic piping by manual operation of seismically qualified ASME boundary valves under administrative controls for limited time periods. The limited time period is up to 14 days per fuel cycle for filtration of the RWST water. The changes are to be applied only for the next two fuel cycles. They cannot be used after Refueling Outage R-18 (Spring 2015). The staff has concluded that there is reasonable assurance that the designated operator will be able to perform the required functions within the procedurally required 46 minute completion time. Furthermore, the staff has found that there is reasonable assurance that the RWST level will remain above the TS minimum required level in the event of a seismic event. Therefore, NRC staff has concluded that the proposed TS change is acceptable.

3.2 Balance of Plant 3.2.1 Regulatory Evaluation As discussed above, Section 10 CFR 50 Appendix A, "General Design Criteria for Nuclear Power Plants," establishes the minimum requirements for the principal design criteria of nuclear power plants. General Design Criterion 2 (GDC-2), "Design bases for protection against natural phenomena," requires that Systems, Structures, and Components important to safety be designed to withstand natural phenomena such as earthquakes.

NRC IN 2012-01 communicated operating experience involving operability of the RWST at the Shearon Harris Nuclear Power Plant. The seismically qualified RWST was aligned to the non-seismically qualified SFP purification system for purification of the RWST contents, creating a breach of the seismically qualified boundary and resulting in the inoperability of the RWST.

The plant credited operator actions, if needed, to close the open valves at the seismically qualified boundary and declare the RWST operable for the duration of the planned purification activity. It was determined by the NRC staff that, while entry into a TS action statement is allowable for maintenance or surveillances, the TS does not allow compensatory measures to be credited for periods longer than the TS completion time unless the TS expressly allows operation in that condition.

3.2.2 Technical Evaluation The proposed change supports filtration of the RWST contents using the non-safety related SFP cooling system (SFPCS) purification loop. The contents of the RWST are filtered prior to refueling outages to improve the optical clarity of the water that will fill the refueling cavity. The proposed amendment credits operator actions to isolate the RWST in the event of a rupture in the SFPCS piping. The NRC staff reviewed the proposed amendment, among other things, for impact on the SFP and SFPCS.

Purification of the RWST via the SFPCS was performed regularly prior to this submittal. The IP3 FSAR, Section 9.3.2, describes the use of the SFPCS for purification of the SFP and RWST water volumes. The proposed amendment did not contain any changes to the method or components for connecting the RWST to the SFPCS.

- 7 As described in the FSAR, the SFPCS is not seismically qualified and is not required to maintain its integrity in the event of an earthquake. In accordance with GOC-2 and RG1.13, the SFPCS is connected to the SFP such that a rupture in any portion of the system will not drain the SFP below the fuel assemblies. The connection of the SFPCS to the RWST does not create the possibility to drain the SFP to an unsafe level. Neither does this connection interfere with the performance of the SFPCS's heat removal capability. Therefore, the NRC staff finds that the proposed amendment will not impact the SFP or SFPCS as described in the Indian Point Unit 3 FSAR.

3.2.3 Summary and Conclusion The NRC staff finds that the proposed amendment will provide adequate protection of the SFP and SFPCS while the RWST is aligned for purification. Further, the performance of RWST purification will be performed in accordance with past practice, procedures associated with the diagnosis and response to a rupture in the SFPCS are available, and credit for operator action is only permitted until refueling outage 18 (Spring 2015). Therefore, the NRC staff finds the proposed amendment acceptable.

3.3 Human Performance 3.3.1 Regulatory Evaluation The regulatory requirements and guidance which the NRC staff considered in its review of human performance aspects of the license amendment request (LAR) are as follows:

• Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, "General Design Criteria (GOC)," Criterion 19--Control room. "A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.... Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures";

10 CFR 50.120, "Training and qualification of nuclear power plant personnel";

NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition":

Chapter 13.2.1, "Reactor Operator Requalification Program; Reactor Operator Training",

Rev.3; Chapter 13.5.2.1, "Operating and Emergency Operating Procedures", Rev.3; and Chapter 18, Rev.2 provides review guidance for "Human Factors Engineering";

NUREG-1764, "Guidance for the Review of Changes to Human Actions", Rev.1.

- 8

• GL 82-33, "Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability";

NUREG-0700, "Human-System Interface Design Review Guidelines" Revision 2;

• NUREG-0711, "Human Factors Engineering Program Review Model," Revision 2; IN 97-78, "Crediting Operator Actions in Place of Automatic Actions and Modifications of Operator Actions, Including Response Times";

IN 2012-01, "Seismic Considerations-Principally Issues Involving Tanks".

3.3.2 Technical Evaluation 3.3.2.1 Description of Operator Action(s) and Assessed Safety Significance The proposed TS change would add a note to TS 3.5.4, "Refueling Water Storage Tank" to allow the non-seismically qualified piping of the Spent Fuel Pool (SFP) Purification Loop to be connected to the RWST's seismically qualified piping by manual operation of the RWST seismically qualified boundary valves. This action would be performed under administrative controls for limited periods of time, Le., 14 days per fuel cycle for filtration of suspended solids from the RWST water. This is proposed as an interim action until an alternate solution makes the action unnecessary. This change, as proposed, will only be in effect until Refueling Outage R18 (Spring 2015) ends.

In accordance with the generic risk categories established in Appendix A to NUREG-1764, this task sequence is considered "risk-important" due to the fact that its failure would jeopardize the ECCS injection and recirculation phases of a loss-of-coolant accident (LOCA). Because of its risk importance, the NRC staff performed a "Level One" review, Le., the most stringent of the graded reviews possible under the guidance of NUREG-1764.

3.3.2.2 Operating Experience Review The licensee did not perform an operating experience review for the proposed manual actions.

The currently proposed operator actions have been used in the plant for virtually its entire history. There have been no seismic events that would require operators to isolate the RWST from the non-seismic piping, and no failures by operators to properly circulate the RWST in the purification mode. In response to the staff's Request for Additional Information (RAI) dated November 15, 2012, the licensee provided copies of any corrective action items that identified problems involving the SFP Purification Loop or operation of the RWST boundary valves.

Seventeen condition reports (CRs) were identified by the licensee spanning the dates of December 20, 2002 to October 23, 2012. Of these, 3 CRs were relevant to a potential failure in the ability of operators to manually isolate the SFP Purification Loop from the RWST piping.

Two CRs (dated 6/8/12 and 10123/12) involved questions by the NRC resident inspector about

- 9 RWST operability that resulted in this LAR. The third involved a stuck isolation valve (AC-719A) which is one of the valves used in the RWST procedure (3-S0P-SI-003) to prevent inadvertent draining of RWST water into the Spent Fuel Pit. This CR from 2005 was resolved by corrective maintenance. No other instances of similar failures were identified by the licensee.

A review of relevant Licensee Event Reports (LERs) for the last ten years was done by the NRC staff to confirm that the proposed manual actions have a history of successful implementation.

The staff's search of IP3 LERs involving "RWST", found only one LER that was associated with the RWST operability issue being addressed by this LAR, and that LER involved the event that is the basis for this LAR.

A separate search of LERs for Westinghouse plants was conducted by the staff using the keyword "RWST". This search resulted in 23 LERs, eight of which involve the same issue of RWST inoperability caused by connection with non-seismic piping. The plants involved were Robinson 2, North Anna 1&2, Farley 1&2, Summer, Harris, Vogtle1, and IP3 (the last of these is the topic of this LAR). The licensee correctly identified Farley as a precedent for this LAR.

Based on IP3's operating history of successful implementation of operator manual actions to support aligning the seismic RWST piping to the non-seismic SFP purification system piping, the NRC staff finds the IP3 operating experience to be supportive of the proposed action.

3.3.2.3 Functional Requirements Analysis and Function Allocation Because the proposed operator action is not a new action, a functional requirements analysis and function allocation were not necessary. Prior experience at IP3 has shown that operators, when assigned this task, had sufficient time and resources available to perform it reliably. The proposed actions are guided by a controlled procedure, 3-S0P-SI-003. The NRC staff concludes that a new or revised functional requirements analysis and function allocation are not necessary based on the licensee's long-term use of a controlled procedure, demonstration of adequate margin to proposed time constraints (see Section 3.3.2.10 below), its characterization of the action as a time-critical action (see Section 3.3.2.11 below), and its intent to monitor the feasibility and reliability of the action (see Section 3.3.2.11 for discussion of long-term monitoring) until final use of the proposed action is complete, i.e., Refueling Outage R18 (Spring 2015).

3.3.2.4 Task Analysis Because the proposed operator manual actions are not new, the only aspect requiring task analysis was the establishment of time constraints for the action sequence. The licensee established the design value of 100.3 minutes and an operational value of 46 minutes for the time to close the valve that isolates the RWST from the non-seismic Spent Fuel Pool Purification Loop. The ability of operators to isolate the RWST within the design and operational values for the timing of the action sequence was validated (see 3.3.2.10, Human Factors Verification and Validation, below). The walkthrough testing demonstrated adequate margin to the operational time limit. The NRC staff finds the licensee's update to the task timing acceptable based on its validation of adequate margin to proposed time constraints.

- 10 3.3.2.5 Staffing Staffing and qualification are not affected by the proposed LAR. No new or additional crew members are required, nor are there any new or additional qualifications required to perform the action sequence within the time constraints established. The licensee clarified in its letter dated December 13, 2012, that each crew will have a designated operator who is trained on the symptoms of a seismic event and his or her specific responses required to protect the inventory of the RWST in accordance with 3-S0P-SI-003. These actions will only be required when the RWST is connected to non-seismic piping, i.e., 14 days or less per fuel cycle. The NRC staff finds that the licensee's staffing plans for manually isolating the RWST acceptable as an interim action until the end of R18 (Spring 2015).

3.3.2.6 Probabilistic Risk and Human Reliability Analyses The licensee did not use probabilistic arguments to justify this LAR and, therefore, Probabilistic Risk Assessment and Human Reliability Analyses were not reviewed for performance or risk insights in this safety evaluation (SE).

3.3.2.7 Human-System Interface Design Human-System Interface design, including the design of the Safety Parameter Display System will not be affected by the proposed LAR.

3.3.2.8 Procedure Design No changes are required to the Emergency Operating Procedures. Because the proposed actions are not new actions, the existing procedure, Procedure 3-S0P-SI-003, does not require any changes. The NRC staff finds the existing procedure acceptable based on: (1) the staff's confirmation that the required actions are described in the procedure, and (2) the licensee's validation and verification of the procedure to confirm its effectiveness (see Section 3.3.2.10 below).

3.3.2.9 Training Program and Simulator Design Because the actions are ex-Control Room actions, the IP3 simulator is not capable of modeling the proposed task sequences and will not, therefore, be used in training. The training program has been completed for all system operators, including the specific requirements of procedure 3-S0P-SI-003. If a seismic event occurs, O-AOP-Seismic requires that an operator verify RWST is isolated per 3-S0P-SFP-001. Additionally, operators deSignated to monitor the RWST during purification will be pre-briefed on their responsibilities. Based on the fact that the proposed action has a long history of successful implementation and is supported by written procedures and existing training, the NRC staff concludes that additional training is not necessary. Based on the above, the staff finds that the training being provided is acceptable.

- 11 3.3.2.10 Human Factors Verification and Validation Time testing of the proposed action was performed by the licensee to demonstrate sufficient margin to the established design values. The results of the licensee's study indicate that operators are able to isolate RWST flow to the non-seismic piping of the SFP Purification Loop.

The licensee found that the operator action is achievable as directed by procedure, and can be performed within 5 minutes, providing substantial margin to the 46 minute design value. Based on the results of these walkthrough demonstrations, the NRC staff finds that the actions are feasible and can be reliably performed by IP3 operators within the calculated time constraint (46 minutes) using existing, controlled procedures, training, and human/system interfaces.

3.3.2.11 Human Performance Monitoring Strategy The procedures and actions proposed by this LAR have been included in the licensee's Time Critical Operator Actions program as controlled by procedure OAP-115. This will ensure that subsequent changes to the plant, procedures, training, or programs will not invalidate the established action times. Based on the administrative protection against inadvertent change and the cyclical validation required by OAP-115, the NRC staff finds the licensee's long-term monitoring strategy acceptable.

3.3.3 Summary and Conclusion Based on the evaluation provided above and statements provided by the licensee, I.e., that time-testing results demonstrate significant margin to design, that appropriate administrative controls will be applied to procedures and training, and that the operators have substantial in house operating experience, the NRC staff concludes that the proposed LAR is acceptable with respect to human performance.

3.4 Component Performance and Testing 3.4.1 Summary and Conclusion As noted in the licensee's letters dated October 25 and December 13, 2012, manual valves AC-725, AC-727A, AC-727B, and SI-841 and check valve AC-726B will be added to the Indian Point Unit 3 lnservice Test (1ST) Program as active valves and will be exercise tested in the future according to the applicable requirements of the ASME Code for Operations and Maintenance of Nuclear Power Plants code of record. The manual valves will be tested at a frequency of no longer than two years. The check valve will be exercise tested prior to use.

The licensee further identified that only manual valve AC-727 A would be subject to leakage testing and that this valve is currently leakage tested in conjunction with the leakage test for other RWST isolation valves (I.e., SI-846 and SI-181 0). The NRC staff finds that inclusion of the subject valves in the Indian Point Unit 31ST Program and the proposed testing is sufficient to ensure the operational readiness of these valves.

- 12 3.5 Accident Dose 3.5.1 Regulatory Evaluation Section 50.67 of 10 CFR Part 50 (10 CFR 50.67), "Accident source term," states that the NRC may issue a license amendment to revise the licensee's accident source term only if the applicant's analysis demonstrates with reasonable certainty that: 1) an individual located at any point on the boundary of the exclusion area (EAB) for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 25 roentgen equivalent man (rem) total effective dose equivalent (TEDE), 2) an individual located at any point on the outer boundary of the low population zone (LPZ), who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage, would not receive a radiation dose in excess of 25 rem TEDE, and 3) adequate radiation protection is provided to permit access to and occupancy of the control room (CR) under accident conditions without personnel receiving radiation exposures in excess of 5 rem TEDE for the duration of the accident.

Section 10 CFR Part 50 Appendix A, "General Design Criteria for Nuclear Power Plants,"

establishes the minimum requirements for the principal design criteria of nuclear power plants.

General Design Criterion 19 (GDC-19), "Control Room" states, in part, that adequate radiation protection is to be provided to permit access to and occupancy of the CR under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. GDC-2, "Design Bases for Protection Against Natural Phenomena," requires that the systems, structures, and components important to safety be designed to withstand the effects of natural phenomena such as earthquakes, tornados, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety function.

As discussed above, NRC IN 2012-01 communicated operating experience involving operability of the RWST at the Shearon Harris Nuclear Power Plant. The seismically qualified RWST was aligned to the non-seismically qualified SFP purification system for purification of the RWST contents, creating a breach of the seismically qualified boundary and resulting in the inoperability of the RWST. The plant credited operator action, if needed to close the open valve at the seismically qualified boundary and declare the RWST operable for the duration of the planned purification activity. It was determined by the NRC staff that, while entry into a TS action statement is allowable for maintenance or surveillances, the TS does not allow compensatory measures to be credited for periods longer than the TS completion time unless the TS expressly allows operation in that condition. IN 91-56, "Potential Radioactive Leakage to Tank Vented to Atmosphere" September 19,1991, communicated that the engineered safety feature (ESF) system may leak through valves that isolate interfacing systems with the ESF systems to tanks that vent to the atmosphere. These tanks include the RWST.

RG 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," Rev. 0, July 2000 provides the methodology for analyzing the radiological consequences of several design basis accidents to show compliance with 10 FR 50.67.

- 13 Standard Review Plan (SRP), Section 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," Rev. 0, July 2000 provides review guidance to the staff for the review of alternative source term amendment requests. The SRP 15.0.1 states that the NRC reviewer should evaluate the proposed change against the guidance in RG 1.183.

License Amendment 224, dated March 22,2005, "Indian Point Nuclear Generating Unit NO.3 Issuance of Amendment Re: Full Scope Adoption of Alternative Source Term (TAC No.

MC3351)" implemented an alternative source term methodology for analyzing the radiological consequences of seven design-basis accidents using RG 1.183.

The regulatory requirements on which the NRC staff based its review are the reference values in 10 CFR 50.67, and the accident specific guideline values in Regulatory Position 4.4 of RG 1.183 and Table 1 of SRP Section 15.0.1. The RG 1.183 provides guidance to licensees on acceptable application of alternate source term (AST) submittals, including acceptable radiological analysis assumptions for use in conjunction with the accepted AST.

3.5.2 Technical Evaluation The proposed change would revise TS 3.5.4, "Refueling Water Storage Tank," such that the non-seismically qualified piping of the SFP purification system may be connected to the RWST's seismic piping by manual operation of seismically qualified boundary valves. The proposed change would add the following note to TS 3.5.4:

The RWST isolation valves AC-727A, AC-727B and AC-725 connected to non-safety related piping may be opened under administrative controls for up to 14 days per fuel cycle for filtration until the end of refuel outage 18.

This change supports recirculation of the RWST through the SFP purification system to clean the RWST contents prior to refueling outage operations. This safety evaluation input addresses the impact of the proposed change on previously analyzed design basis accident radiological consequences.

Background

Per SRP Section 15.0.1, the NRC staff evaluated the proposed change against the guidance in RG 1.183. RG 1.183, Regulatory Position 5.0 states, in part:

ESF systems that recirculate sump water outside of the primary containment are assumed to leak during their intended operation. This release source includes leakage through valve packing glands, pump shaft seals, flanged connections, and other similar components. This release source may also include leakage through valves isolating interfacing systems (Ref. A-7) [IN 91-56, "Potential Radioactive Leakage to Tank Vented to Atmosphere" September 19, 1991]. The radiological consequences from the postulated leakage should be analyzed and combined with consequences postulated for other fission product release paths to determine the total calculated radiological consequences from the LOCA [loss of coolant aCCident].

- 14 RG 1.183, Regulatory Position 5.1.2 also states:

Credit may be taken for accident mitigation features that are classified as safety-related, are required to be operable by technical specifications, are powered by emergency power sources, and are either automatically actuated or, in limited cases, have actuation requirements explicitly addressed in emergency operating procedures. The single active component failure that results in the most limiting radiological consequences should be assumed.

After the end of post-LOCA injection phase, the Emergency Core Cooling Systems (ECCS) and containment spray systems [ESF systems that recirculate sump water] are switched to the recirculation phase. This requires that water from the containment sump replace the RWST as the ESF systems' water supply. This is accomplished by realigning several system valves that interface between the ECCS and spray systems, and the RWST and the pathways leading back to the RWST. If these system valves are allowed to leak by design or the leakage of these valves is unknown, a leakage path between the containment sump and the RWST and any interfacing piping may exist due to valve seat leakage.

For the design basis LOCA radiological analyses it is assumed that 40% of the core iodine inventory is mixed homogeneously and instantaneously in the primary containment sump water at the time of release from the core. Because the ECCS takes suction from the sump and the sump water is assumed to be radioactive, the consequences of any ECCS leakage are considered in the radiological dose analyses. According to the IP3 UFSAR, Revision 4, 2011, the dose resulting from 4.0 gallons per minute leakage from the ECCS is considered in the IP3 design basis accident analyses.

The LAR dated, August 14,2012 states:

Suction from the RWST for the refuel water purification pump is taken from the sixteen inch line that connects the RWST to the Emergency Core Cooling System (ECCS). The suction line is initially a four inch line but it is reduced to two inch within four feet. The line is seismic class 1 until after the refueling water purification pump discharge valve AC-725.

Valve AC-725 (a diaphragm valve) and AC-727A (a globe valve) on the suction side of the refueling water purification pump, are used to isolate the RWST from non-seismic piping on the suction (inlet) side of the purification loop. The return line is also a two inch line (until close to the RWST where it joins other return lines and becomes three inch).

The seismic class 1 return line can be isolated from the non seismic line by check valve AC-7268, globe valve AC-7278, and diaphragm valve SI-841.

The non seismic class 1 pipe cannot be depended upon for design basis events and provisions are made to isolate the RWST from non seismic class 1 pipe in time to ensure that the TS 3.5.4 required volume of 35.4 feet continues to be met.

NRC Staffs Review The LAR dated August 14, 2012, did not provide a technical assessment of the impact of the proposed change on 10 CFR 50.67 doses (due to design basis accidents). Specifically, any ECCS leakage to the RWST or to the sixteen inch line that connects the RWST to the ECCS

- 15 (Line #155 on drawing No. 9321-F-27503, sheet 2, Revision 53 sent to the NRC by letter dated November 14, 2012) would be available to flow into the SFP refueling purification system because the previous closed isolation valves could now be open at the start of a design basis accident. ECCS leakage would flow through the SFP purification system until the isolation valves are closed or if they fail to close or leak. This could create a pathway for radioactive ECCS water to leak to the environment through any failed, non-seismic piping in the SFP purification system. Therefore, the NRC staffs November 15,2012, request for additional information (ML12284A446) requested that the licensee provide information regarding credible actions that could be taken to show compliance with 10 CFR 50.67, and the impact of the proposed change on worst single failure analysis.

Credible Actions and Single Failures The licensee for IP3 provided its response to the staffs November 15, 2012 RAI in a letter dated December 13,2012. The licensee stated that temporarily (until the end of refueling outage 18) administrative controls would be put into place to close isolation valves 725 and 727 A on the suction line from the RWST and to close 7278 on the return line to the RWST.

The licensee further stated that the 7268 check valve does not require an operator action to close.

The licensee stated, and the staff agrees, that these valves are all seismic category 1 as noted on drawing 9321-F27513, sheet 2, Revision 42 sent to the NRC by letter dated November 14, 2012. Drawing 9321-F27513, sheet 2 also shows that all the piping between the two valves is seismic category 1. The licensee stated, and the staff agrees. that external recirculation of ECCS fluids occurs after 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (per License Amendment 224, dated March 22, 2005, ADAMS Accession No. ML050750431). The licensee also stated that 46 minutes is considered the time available for operator actions to close the isolation valves under all circumstances. As indicated in Section 3.3 of this SEt the NRC staff has accepted this time as bounding for the planned operator actions.

The NRC staff evaluated the licensee's proposed credit for manual closure of SFP purification system isolation valve AC-727 A using RG 1.183, Regulatory Position 5.1.2. Consistent with Regulatory Position 5.1.2, the credited valve and piping are all seismic category 1, as discussed above, and are safety related (see the licensee's letter dated February 15, 2013). AC-727A is required to be operable by TS 5.5.2. Manual actions are credited for this valve for a limited duration (14 days per fuel cycle) until the end of refueling outage 18, and per the licensee's February 15, 2013 letter, valves AC-727A and AC-725 will be successfully cycled (open-closed) prior to operation of the purification system to provide reasonable assurance of operability.

Furthermore, since the time allowable for the operator to manually close the SFP purification system isolation valves (46 minutes) is less than the time for internal recirculation (6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />),

there will be no radioactive leakage into the SFP purification system except the leakage allowed by design for the isolation valves. The licensee stated, and the staff agrees, that a single failure of any of the valves credited for isolating the SFP purification system non-seismic piping from the ECCS low head to high head external recirculation loop (AC-727 A, and MOV 1810) would not increase the assumed leakage for the design basis LOCA. This is because the method of testing used by the licensee simultaneously tests these valves (Procedure 3PT-R178, "Alternate SI Low Head to High Head Recirc [Recirculation] Piping Leak Test") and limits the total leakage

- 16 SI Low Head to High Head Recirc [Recirculation] Piping Leak T est") and limits the total leakage through them to 5.0 gallons per hour. If one of these valves fails, the total leakage into the non-seismic piping is limited to a maximum of 5 gallons per hour. Additionally, AC-725, AC 727B and AC-726B should further restrict flow in the case of a single failure. Based upon the discussion above, the NRC staff finds that the proposed crediting of the AC-727A valve for the design basis dose analysis meets the intent of Regulatory Position 5.1.2.

Valve Leakage In a letter dated February 15, 2013, the licensee evaluated the impact of an assumed 5 gallon per hour valve leakage, discussed above, on the accident dose analysis used to show compliance with 10 CFR 50.67. The licensee's analysis uses the results of dose and atmospheric dispersion analyses incorporated into the licensing basis using 10 CFR 50.59, "Changes, tests, experiment" and analyses previously reviewed and approved by the NRC staff in License Amendment 224, dated March 22,2005 (ML050750431). The NRC staff evaluated the licensee's proposed analysis change against RG 1.183, Regulatory Position 5.0.

The staff. used the information previously approved by the staff and the inputs incorporated by 10 CFR 50.59 to independently evaluate the proposed change. The staff independently calculated the RWST atmospheric dispersion factors using a point release assumption, and used these values to confirm that there is reasonable assurance that the personnel in the CR will not receive accident exposures in excess of 5 rem TEDE. Using the same methodology as used for the CR, the staff confirmed the licensee's assessment of the EAB and LPZ doses.

Based upon this review, the staff confirmed that the IP3 EAB and LPZ doses will continue to meet the requirements of 10 CFR 50.67.

3.5.3 Summary and Conclusion The NRC staff reviewed the assumptions, inputs, and methods used by the licensee to assess the radiological impacts of the proposed TS changes in the context of the AST. The staff finds that the licensee used analysis methods and assumptions consistent with the conservative guidance of RG 1.183. The staff finds the methods and assumptions used by the licensee are in compliance with applicable requirements. The staff compared the doses estimated by IP3 to the applicable acceptance criteria. The staff finds reasonable assurance that the licensee's estimates of the total effective dose due to design basis accidents comply with the requirements of 10 CFR 50.67 and the guidance of RG 1.183.

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

- 17 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 63350). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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 Contributors: J. Miller E. Davidson G. Lapinsky J. Billerbeck M. Blumberg Date: February 22, 2013

DATED: February 22.2013 AMENDMENT NO. 250 TO FACILITY OPERATING LICENSE NO. DPR-64 INDIAN POINT UNIT3 DISTRIBUTION:

PUBLIC LPL1-1 RtF RidsNrrDorl RidsNrrDorlLpl1-1 RidsNrrDorlDpr RidsNrrPMlndianPoint RidsNrrLAKGoldstein RidsNrrDssStsb RidsNrrDssSrxb RidsNrrDssSbpb RidsNrrDeEptb RidsNrrDraAadb RidsNrrDra Ahpb RidsRgn1 MailCenter RidsOGCRp RidsAcrsAcnw_MailCTR ABurritt, R1 MHamm, STSB JMiller, SRXB EDavidson, SBPB MBlumberg, MDB JBillerbeck, EPTB GLapinksy, AHPB cc: Distribution via ListServ

February 22, 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: CONNECTING NON-SEISMIC PURIFICATION SYSTEM PIPING TO THE REFUELING WATER STORAGE TANK (TAC NO. ME9263)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 250 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Technical Specifications (TS) in response to your application dated August 14, 2012, as supplemented by letters dated October 25, November 14, December 13,2012, and February 15, 2013.

The amendment revises Technical Specification 3.5.4, "Refueling Water Storage Tank," to permit non-seismically qualified piping of the Spent Fuel Pool purification system to be connected to the Refueling Water Storage Tank seismic piping under administrative controls for a limited period of time in order to purify the contents of the Refueling Water Storage Tank.

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. 250 to DPR-64

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

See next page ADAMS ACCESSION NO'.. ML13046A166

• OFFICE

• NAME DATE OFFICE NAME E

LPL1-1/PM DPickett 02/15/2013 STSB RElliott (CShulton for) 02/20/2013 LPL1-1/LA KGoldstein 02/19/2013 AADB nate (w/comments) 02/19/2013 EPTB/BC AMcMurtray by email dated 01/25/2013 AHPB UShoop by memo dated 02/11/2013 SBPB GCasto by memo dated 12/19/2012 OGC STurk (w/changes noted) 02/21/2013 SRXB CJackson by memo dated 02/08/2013 LPL1-1/BC GWilson 02/22/2013 OFFICIAL RECORD COpy