ML13088A204

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Issuance of Amendment Operability of Atmospheric Dump Valves
ML13088A204
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 04/15/2013
From: Pickett D
Plant Licensing Branch 1
To:
Entergy Nuclear Operations
Pickett D
References
TAC ME8750, FOIA/PA-2016-0148
Download: ML13088A204 (12)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 15, 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: OPERABILITY OF ATMOSPHERIC DUMP VALVES (TAC NO. ME8750)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 251 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Technical Specification (TSs) in response to your application dated May 23, 2012, as supplemented on August 3,2012.

The amendment revises TS 3.7.4, "Atmospheric Dump Valves (ADVs)," Limiting Condition for Operation 3.7.4 to require four operable ADVs instead of three.

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. 251 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. 251 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 May 23,2012, as supplemented on August 3,2012, 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 FR 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. 251, 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 Sean C. Meighan, Acting 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:

Apr; 1 15, 2013

ATTACHMENT TO LICENSE AMENDMENT NO. 251 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 Pages Insert Pages 3.7.4-1 3.7.4-1

- 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 11/27100 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 11/27100 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 )

Tech nical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 251, 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. 251

3.7.4 ADVs 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Dump Valves (ADVs)

LCO 3.7.4 Four ADV lines shall be OPERABLE.

APPLI CAB ILI TY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION A.

One required ADV 1 i ne inoperable.

A.1 REQUIRED ACTION Restore required ADV line to OPERABLE status.

COMPLETION TIME 7 days B.

Two or more required ADV lines inoperable.

C.

Required Action and associated Completion Time not met.

B.1 C.1 AND C.2 Restore all but one ADV line to OPERABLE status.

Be in MODE 3.

Be in MODE 4 without reliance upon steam generator for heat removal.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 6 hours 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> INDIAN POINT 3 3.7.4-1 Amendment 251

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 251 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 May 23, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12157A082), as supplemented by letter dated August 3,2012 (ADAMS ML12222A347), 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 proposed changes would revise Limiting Condition for Operation (LCO) 3.7.4 ofTS 3.7.4, "Atmospheric Dump Valves (ADVs),, to require 4 operable ADVs instead of 3.

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 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 and has committed to some of the GDCs from 10 CFR Part 50, Appendix A.

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

In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five

- 2 specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plant's TSs. As stated in 10 CFR 50.36(c)(2)(i), the "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 specification.... " TS Section 3.0, on "LCO and SR Applicability," provides details or ground rules for complying with the LCOs.

The ADVs provide a method for cooling the primary system to residual heat removal (RHR) entry conditions assuming the preferred heat sink via the steam bypass system to the condenser is not available. The ADVs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintaining a vacuum in the condenser to permit use of the preferred steam bypass system. One ADV is provided for each of the four steam generators.

As described in Chapter 14 of the UFSAR, the ADVs are relied upon by plant operators to cool down the primary system to RHR entry conditions for accidents or transients accompanied by a loss of offsite power. The steam generator tube rupture (SGTR) accompanied by a loss of offsite power is the limiting event for the ADVs. For this scenario, plant operators use the ADVs to perform a limited cooldown to establish adequate subcooling as a necessary step to terminate primary to secondary break flow in the affected steam generator.

The licensee's application states that four ADVs are required to be operable. One ADV is required from each of the four steam generators to ensure that at least three ADVs are available to conduct a plant cooldown following a SGTR because the affected steam generator with the ruptured tube and its associated ADV will be isolated and unavailable.

The current LCO 3.7.4 only requires that three ADVs be operable. The licensee has determined that this is non-conservative. As discussed above, all four ADVs must be operable to ensure that three are available following a SGTR and the subsequent isolation of the affected steam generator. Therefore, the licensee has requested to revise LCO 3.7.4 to require that all four ADVs be operable.

3.0 TECHNICAL EVALUATION

Indian Point Unit NO.3 converted to the improved technical specifications (ITS) with Amendment No. 205 on February 27,2001. Prior to the conversion, the custom TSs at IP3 did not include any operability requirements for the ADVs. When IP3 converted to the ITS, the licensee incorporated the operability requirements of the ADVs found in TS 3.7.4, "Atmospheric Dump Valves (ADVs)," from NUREG-1431, the Standard TSs for Westinghouse plants. In addition, the licensee also incorporated the ADV TS 3.7.4 Bases from NUREG-1431. As a result, the IP3 TSs were upgraded from having no operability requirements for the ADVs to having an LCO requirement that 3 ADVs be operable under the applicable operating modes.

The licensee's application of May 23,2012, stated that LCO 3.7.4, which requires that 3 ADVs be operable, was non-conservative and that the licensee had taken appropriate corrective

- 3 actions in accordance with Administrative Letter 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety." The licensee proposed to revise LCO 3.7.4 to require that 4 ADVs be operable instead of 3. The licensee stated that in its 4.85 percent stretch power uprate application of June 3, 2004, the SGTR analysis took credit for steam release from the three remaining intact steam generators in order to dissipate core decay heat and cool the plant down to the RHR system operating conditions. Therefore, an LCO requiring 4 operable ADVs is necessary to ensure that 3 ADVs will be available for plant cooldown since the ADV associated with the affected steam generator will not be available.

During the NRC staff's review, the staff asked the licensee to confirm the number of ADVs required for plant cooldown in the analysis of record for the SGTR event. The licensee's letter dated August 3,2012, stated that only 2 ADVs would be required for plant cooldown.

The licensee's application also included associated revisions to the TS Bases. The licensee stated that the TS Bases required revision because it does not reflect the licensing basis. When the licensee converted to the ITS, it erroneously incorporated the TS Bases 3.7.4 of NUREG 1431 that assumed the single active failure of an ADV. The licensee proposed to revise the IP3 TS Bases to state that no single active failure of an ADV is postulated.

In response to an NRC staff request for additional information, the licensee's letter of August 3, 2012, explained why a single active failure of an ADV is not part of the licensing basis at IP3.

The licensing basis SGTR thermal-hydraulic analysis is based upon hand calculations that result in a conservative estimate of the radiological consequences of an offsite release. Due to the vintage of the calculation, computer modeling of the plant transient behavior was not performed. The calculations did not model the ADVs and assumed that the secondary pressure would be maintained at the lowest safety valve setpoint following the reactor trip. As a result, the licensing basis SGTR hydraulic analysis does not consider operation of the ADVs or any other single active failure.

3.1 Conclusion The licensee has proposed to revise LCO 3.7.4 to require that 4 ADVs be operable instead of 3.

The NRC staff notes that plant cooldown following a SGTR event can be safely performed with only 2 ADVs. Therefore, the staff finds that the proposed change to LCO 3.7.4 is acceptable because it results in a more conservative plant configuration that supports additional operational flexibility.

Proposed revisions to TS 3.7.4 Bases state that no single active failure of a second ADV of an unaffected steam generator is postulated. The NRC staff agrees that the SGTR analysis of record does not model ADVs and that the proposed TS Bases is consistent with the IP3 UFSAR Chapter 14, Section 14.2.4 discussion of the SGTR event. The staff notes that the proposed TS Bases revisions provide a more accurate description of the licensing basis.

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.

-4

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 56880). 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: Douglas Pickett Matthew Hamm Date: April 15, 2013

April 15, 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: OPERABILITY OF ATMOSPHERIC DUMP VALVES (TAC NO. ME8750)

Dear Sir or Madam:

The Commission has issued the enclosed Amendment No. 251 to Facility Operating License No. DPR-64 for the Indian Point Nuclear Generating Unit NO.3. The amendment consists of changes to the Technical Specification (TSs) in response to your application dated May 23, 2012, as supplemented on August 3, 2012.

The amendment revises TS 3.7.4, "Atmospheric Dump Valves (ADVs)," Limiting Condition for Operation 3.7.4 to require four operable ADVs instead of three.

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. 251 to DPR-64
2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION:

See next page ADAMS ACCESSION NO.: ML13088A204 OFFICE

. NAME DATE LPL1-1/PM DPickett 04/03/2013 LPL1-1/LA KGoldstein 04/03/2013 STSBIBC RElliott 04/04/2013 OGC STurk (w/changes) 04/08/2013 LPL1-1/BC{A)

SMeighan 04/15/2013 OFFICIAL RECORD COPY

DATED: April 15, 2013 AMENDMENT NO. 251 TO FACILITY OPERATING LICENSE NO. DPR-64 INDIAN POINT UNIT3 DISTRIBUTION:

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