NL-13-015, Proposed License Amendment Regarding Connection of Non Seismic Boric Acid Recovery System to the Refueling Water Storage Tank

Proposed License Amendment Regarding Connection of Non Seismic Boric Acid Recovery System to the Refueling Water Storage Tank

ML13116A007
Person / Time
Site:	Indian Point
Issue date:	04/15/2013
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-13-015
Download: ML13116A007 (19)

Text

%Entergy Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President NL-13-015 April 15, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed License Amendment Regarding Connection of Non Seismic Boric Acid Recovery System to the Refueling Water Storage Tank Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc., (Entergy) hereby requests a License Amendment to Operating License DPR-26, Docket No. 50-247 for Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed Technical Specification (TS) change contained herein would revise 3.5.4, "Refueling Water Storage Tank (RWST)" such that the non-seismically qualified piping of the temporary Boric Acid Recovery System (BARS) may be connected to the Refueling Water Storage Tank (RWST) seismic piping. Operation of the BARS from the RWST will be under administrative controls for a limited period of time (i.e., 30 days for RWST filtration prior to each fuel cycle). This change will only be applicable until Refueling Outage R22 ends (Spring 2016).

Entergy has evaluated the proposed change in accordance with 10 CFR 50.91(a)(1) using the criteria of 10 CFR 50.92(c) and Entergy has determined that this proposed change involves no significant hazards, as described in Attachment 1. The marked up page showing the proposed change is provided in Attachment 2. The associated Bases change is provided in Attachment 3 for information. A copy of this application and the associated attachments are being submitted to the designated New York State official in accordance with 10 CFR 50.91.

Entergy requests approval of the proposed amendment by January 20, 2014 and an allowance of 30 days for implementation. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

"6

NL-13-015 Docket 50-247 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2013.

Sincerely, JAV/sp Attachments:

Enclosure:

1. Analysis of Proposed Technical Specification Change Regarding Connection of Non Seismic BARS to Refueling Water Storage Tank

2.

Marked Up Technical Specifications Page for Proposed Change Regarding Connection of Non Seismic BARS to Refueling Water Storage Tank

3.

Marked Up Technical Specification Bases Change Associated with the Proposed Change Regarding Connection of Non Seismic BARS to Refueling Water Storage Tank

1.

Indian Point 2 Drawings and Calculation cc:

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

ATTACHMENT 1 TO NL-13-015 ANALYSIS OF PROPOSED TECHNICAL SPECIFICATION CHANGE REGARDING CONNECTION OF NON SEISMIC BARS TO REFUELING WATER STORAGE TANK ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2DOCKET NO. 50-247

NL-13-015 Docket No. 50-247 Page 1 of 8

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc (Entergy) is requesting an amendment to Operating License DPR-26, Docket No. 50-247 for Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed Technical Specification (TS) change contained herein would revise 3.5.4, "Refueling Water Storage Tank (RWST)" such that the non-seismically qualified piping of the Boric Acid Recovery System (BARS) may be connected to the Refueling Water Storage Tank's (RWST) seismic piping and isolated by manual operation of RWST seismically qualified boundary valves under administrative controls for a limited period of time (i.e., 30 days per fuel cycle for filtration for removal of silica from the RWST water). This change will only be applicable for the next two fuel cycles and cannot be used after Refueling Outage R22 (Spring 2016).

The specific proposed change is listed in the following section.

2.0 PROPOSED CHANGE

The proposed TS change is as follows:

Directly under "LCO" add

- NOTE -

The RWST isolation valves 350, 727A and 845 connected to non-safety related piping may be opened under administrative controls for up to 30 days per fuel cycle for filtration until the end of refuel outage 22.

In addition, the Technical Specification Bases will be revised to clarify administrative controls.

3.0 BACKGROUND

Historically, IP2 was connecting the non seismic reverse osmosis system, identified as the Boric Acid Recovery System (BARS) to the seismic Spent Fuel Pool (SFP) Purification Loop to filter the refueling water storage tank (RWST) water while in plant conditions and modes for which the RWST was required to be operable. This alignment was utilized to remove silica from the RWST water. Removal of silica is necessary to maintain Reactor Coolant System (RCS) chemistry within fuel requirements and to improve water clarity during refueling to facilitate safe handling of fuel and to prevent delays in fuel movement. The water clarity is both a personnel and equipment safety consideration. Entergy had established the practice of recirculating the RWST for up to 30 days beginning up to about two months prior to a refueling outage for silica removal. Prior to refueling outage (RO) 2R20 the RWST was recirculated for a duration of 13 days. After recirculation the total concentration of silica was less than 1.1 ppm. Prior to RO 2R1 9 the RWST was recirculated for a duration of 11 days. A sample taken after recirculation had total concentration of silica of 1.3 ppm.

During plant operations 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, the residual heat removal pumps and the containment spray

NL-13-015 Docket No. 50-247 Page 2 of 8 pumps during normal operation (Modes 1 through 4). During cold shutdown and refueling operation (Modes 5 and 6), the RWST may be credited as a borated water supply should the boric acid storage system not be functional. The contents of the RWST are also used to flood the refueling cavity during refueling operation. The water in the RWST is borated to a concentration sufficient to ensure that shutdown margin is maintained when the reactor is at cold shutdown conditions should RWST water be added to the reactor.

It was recognized that alignment to BARS could render the RWST inoperable during a seismic event since the BARS is a non-seismic system. To maintain operability, procedure changes had been made to direct manual operator action to isolate the non seismic connections to the RWST to ensure adequate inventory during Modes 1 through 4 when the RWST was required to be operable. After reviewing Information Notice (IN) 2012-01, "Seismic Considerations-Principally Issues Involving Tanks," Entergy concluded that manual actions could not be credited for this purpose without prior NRC approval and subsequently discontinued this practice. 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 has been upgraded to seismic 1 so that during a seismic event no failure of the SFP Purification Loop piping is considered.

However, when the non seismic BARS is connected to the Purification Loop there is the possibility a seismic event could affect the available water in the RWST. For this reason the IN 2012-01 requires that the RWST TS action statement be entered when non-seismic connections are made to the RWST. The completion time of the action statement does not allow time for purification.

Removal of silica by use of the BARS system is preferred to other means. For example, using dilution creates large quantities of liquid radioactive waste, or removing silica from the spent fuel pool has the potential for further deterioration of the Boraflex material in the storage racks.

Consequently, and until modifications are made, this TS change request is being made to credit operator action to close the seismically qualified manual code boundary valves in the event of a seismic or design basis accident. Two refuel outages have been requested to complete modifications.

4.0 Technical Evaluation This assessment addresses the proposed change to TS 3.5.4, "Refueling Water Storage Tank (RWST)." The TS change would allow voluntary connection of the non-seismic BARS to the seismic piping of the SFP Purification System with a 30 day limit for re-circulating the contents of the RWST for the purpose of silica filtration through the BARS during Modes 1 through 4 when the RWST is required to be operable. The following assessment provides the basis for the acceptability of the proposed change to the TS which provides for operator action to close the seismically qualified manual code boundary valves to assure RWST operability when re-circulating the tank through non-safety related piping.

The non-seismic BARS is connected to the seismic SFP Purification System as follows:

The BARS suction line is connected to Valve 725 (see Drawing A227781, quadrant F-1 in the Enclosure) on the discharge to the Refueling Water Purification Pump (RWPP) by removing the valve bonnet and valve internals and installing a hose adapter plate.

The BARS discharge line is connected to 2 inch line #252 upstream of 2 inch valve 350 (see Drawing 9321 -F-2736, quadrant E-3 and Drawing 9321-F-2735 (valve 350 only),

NL-13-015 Docket No. 50-247 Page 3 of 8 quadrant 1-4 in the Enclosure) by removing the 2"-150 psig flange and installing a hose adapter plate.

The RWPP will take suction through manual isolation valve 855 on line 2"-AC-1 51 R#1 83 which is connected to the 16 inch line from the RWST downstream of isolation valve 846. Normally closed isolation valve 845 will be opened (Drawing A227781, quadrant I-1), and the RWPP will take suction through valve 727A and discharge to valve 725 (Drawing A227781 quadrants G-1 to E-1).

Flow through valve 725 adapter plate is to the non seismic BARS since the spent fuel pit demineralizer is isolated. The flow from valve 725 is through a 2 inch hose adapter plate to the BARS which discharges to seismic line #252 upstream of valve 350. Flow will be through valve 350 and return line 3"-SI-1 51 R#1 61 to the RWST. Flow would not be diverted back to the boric acid makeup system due to check valve 294 and normally closed manual valve 295 (see Drawings 9321 -F-2736, quadrant E-3 and Drawing 9321 -F-2735 (valve 350 only), quadrant 1-4). The proposed manual action to isolate the BARS in the event of an actual or potential loss of RWST considered the following:

Operator Action Considerations Entergy has confidence in the successful completion of manual actions due to the training program completed for all system operators and the specific procedural requirements for the BARS. During use of the BARS, the RWST level, temperature and boron concentration are monitored. A dedicated operator is assigned to remain in the vicinity of BARS at all times when the RWST Silica Cleanup Skid is aligned for operation. The operator has the ability to directly communicate with the Unit 2 control room and is equipped with an operational flashlight and trained on the location and operation of valves and the Refueling Water Purification Pump (Reference 2). If there is a RWST low level alarm received the Unit 2 control room supervisor will direct the operator to isolate the RWST Silica Cleanup System. The RWST Silica Cleanup System would also be isolated if:

There is a Safety Injection (SI) actuation Lights go out in the PAB A RWST Silica Cleanup System Hose ruptures or breaks An indication of tremors or earthquake is evident If the BARS has to be isolated for any of the reasons above, the dedicated operator would isolate suction to BARS through valves 845 and 727A, isolate discharge from BARS through valve 350, and secure the RWST Purification pump, if running.

Valves 845, 727A and 350 will be part of the Inservice Test Program with a test frequency of two years. Further, by procedure, valves 845, 727A and 350 will be cycled open and closed prior to putting the BARS in operation to provide reasonable assurance that all valves will close.

The allowable time for operator action to isolate the BARS unit has been calculated (Reference 1). This re-analysis was conservatively based on a simultaneous rupture of connections at valve 725 and at the flange upstream of valve 350. Scenarios for rupture with and without an SI signal were evaluated. The current RWST low level alarm is set to 37.01 feet, with the TS limit at 36.83 feet. In order to provide more time for the operator to perform the isolation function in a seismic or SI event during operation of BARS, the initial level of the RWST would be raised to 37.43 feet or higher, and a control room Plant Integrated Control System (PICS) alarm setpoint would be set at 37.33 ft (or higher) prior to aligning BARS. There would then be

NL-13-015 Docket No. 50-247 Page 4 of 8 4684 gallons of margin to the Technical Specifications limit (345,000 gallons) following a low RWST level alarm. If the RWST purification pump is in service providing flow to the BARS unit, a flow of 180 gallons per minute (gpm) was considered for the break flow through valve 725 and 91 gpm was considered for the break flow through the flange at valve 350. These are maximum flow rates resulting from pump runout and available head in the RWST. The total time available before reaching the TS limit would be 31 minutes, assuming the operator took 10 minutes to close valves 845/727A and trip the RWST purification pump (all in close proximity),

and an additional 21 minutes to close valve 350.

For the same break(s) scenario, and considering actuation of SI, the RWST purification pump would receive a trip signal, and the corresponding total flow through the two break locations would be less limiting than the above scenario with no SI signal.

The refueling water purification pump is located on the 68 foot elevation of the Primary Auxiliary Building (PAB) with the pump control switch on an adjacent wall. Valves 845 and 727A are within about twelve feet of each other on opposite sides of the pump. The return line isolation valve 350 is located on the PAB 99.5 foot elevation. There is a card reader at the entry point to the PAB on the 80 foot elevation, but once inside there are no restrictions to reach valve 350 from valves 845 and 727A. A simulation performed by Operations, with an operator dispatched from the control room resulted in closure of valve 845 and 350 in a total of 5 minutes. An additional 2 minutes is conservatively estimated for tripping the purification pump and valve 727A, resulting in a total of 7 minutes. This time would be even shorter since there would be a dedicated operator for the BARS.

This provides substantial margin to the total calculated time of 31 minutes to shutdown the BARS and maintain the RWST within the TS value following a control room alarm indication of 37.33 feet for RWST level.

Reference 2 will be revised to capture the RWST level requirements and operator action times.

Dose consequences associated with the operation of BARS The dose consequences in the highly unlikely event of a Loss of Coolant Accident (LOCA) when BARS is in operation are discussed below.

Following the injection phase of a large break LOCA (about 20 minutes), the preferred means of cold leg recirculation is to use the internal recirculation pumps. This results in the fluid being kept inside containment until hot leg recirculation. At about 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the recirculation pumps send fluid from the containment to the suction of the high head safety injection pumps, with the potential for sump fluid leakage to leak back to the RWST and impact BARS. This flow path is isolated from the Refueling Water Purification Pump by check valve 847 and motor operated valve 1810 (8"-SI-1 89R, line#155 on drawing 9321 -F-2735). It is possible for any leakage past these valves to migrate to the refueling water purification loop, however, this would be contained as the dedicated operator would close valves 845 and 727A.

Another potential for sump fluid leakage to impact BARS would be leakage through the 2 inch SI mini-flow line back to the RWST that is connected to valve 350. However, this would be limited to leakage through MOV 842/843, which are tested by 2-PT-R048 and have an acceptance criterion of 0.5 gallons per hour (gph). These valves and their acceptance criterion are also governed by the 2.0 gph limit for Emergency Core Cooling System (ECCS) leakage and so there would be no impact on dose.

NL-13-015 Docket No. 50-247 Page 5 of 8 The IP2 design is fairly unique in having internal recirculation pumps as well as residual heat removal (RHR) pumps. The RHR is the secondary means of achieving hot leg recirculation by drawing water from the reactor sump and delivering via the RWST suction line. This leakage pathway is not postulated because it would require a passive failure, which is not postulated to occur for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The leakage associated with this pathway is not part of the TS 5.5.2 program, because that program does not assume the single passive failure. Likewise, the RG 1.183 guidance does not impose any additional single failure to determine this leakage path.

Thus in the highly unlikely event of a LOCA during the operation of BARS, there will be no impact on accident dose consequences.

Operating Experience The BARS has been in use at IP2 since prior to refueling outage 16 in 2006, and Reference 2 will captures operator actions for isolation of BARS for any of the conditions discussed above. A search of Condition Reports since 2006 identified only logistic issues such as security clearance of the BARS equipment, manpower scheduling, tripping hazard due to BARS hoses, etc. There have been no seismic events during the use of BARS and no problems identified in the installing, use and removal of BARS.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (Entergy) has evaluated the safety significance of the proposed change to the Indian Point 2 Technical Specifications (TS) which revise IP2 TS 3.5.4, "Refueling Water Storage Tank (RWST)," to allow administrative control of the seismic RWST/non-seismic BARS interface. The proposed change has been evaluated according to the criteria of 10 CFR 50.92, "Issuance of Amendment'. Entergy has determined that the subject change does not involve a Significant Hazards Consideration, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No. The use of the non seismic Boric Acid Recovery System (BARS) to re-circulate and filter the Refueling Water Storage Tank (RWST) water does not involve any changes or create any new interfaces with the reactor coolant system or main steam system piping. Therefore, the connection of the BARS Purification Loop to the RWST would not affect the probability of these accidents occurring. The BARS is not credited for safe shutdown of the plant or accident mitigation. Administrative controls ensure that the BARS can be isolated as necessary and in sufficient time to assure that the RWST volume will be adequate to perform the safety function as designed. Since the RWST will continue to perform its safety function and overall system performance is not affected, the consequences of the accident are not increased.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

NL-13-015 Docket No. 50-247 Page 6 of 8

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No. The design of the RWST and the SFP Purification Loop has been revised to allow recirculation and purification using the BARS for a short period of time (not to exceed 30 days per fuel cycle) for the next two fuel cycles. The added BARS takes RWST water in and processes it out without additional connections that could affect other systems and without an impact from its installation. Procedures for the operation of the plant, including BARs, will not create the possibility of a new or different type of accident.

Contingent upon manual operator action, a BARS line break will not result in a loss of the RWST safety function. Similarly, an active or passive failure in the BARS will not affect safety related structures, systems or components.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No. The SFP Purification Loop and recirculation and purification of the RWST water using the BARS is not credited for safe shutdown of the plant or accident mitigation.

RWST volume will be maximized prior to purification and timely operator action can be taken to isolate the non seismic system from the RWST to assure it can perform its function. This will result in no significant reduction in the margin of safety.

Therefore the proposed change does not significantly reduce the margin of safety.

Based on the above, Entergy concludes that the proposed amendment to the Indian Point 2 Technical Specifications presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of 'no significant hazards consideration' is justified.

5.2 Applicable Requlatory Requirements / Criteria The NRC Order of February 11, 1980 required an evaluation of the degree of compliance with the GDC at the time. This section discusses continued compliance with certain of those criteria.

The plant will continue to meet Criterion 1 of 10 CFR 50 Appendix A which says "Structures, systems and components important to safety shall be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed.

Where generally recognized codes and standards are used, they shall be identified and evaluated to determine their applicability, adequacy, and sufficiency and shall be supplemented or modified as necessary to assure a quality product in keeping with the required safety function. A quality assurance program shall be established and implemented in order to provide adequate assurance that these structures, systems and components will satisfactorily perform their safety functions.

Appropriate records of the design, fabrication, erection, and testing of structures, systems and components important to safety shall be maintained by or under the control of the nuclear power plant licensee throughout the life of the unit' and Criterion 2 which says "Structures, systems, and components important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability

NL-13-015 Docket No. 50-247 Page 7 of 8 to perform their safety functions. The design bases for these structures, systems and components shall reflect: (1) appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena and (3) the importance of the safety functions to be performed."

The purification of the RWST will use the seismic piping meeting these criteria but will also use the non seismic piping which does not. Manual action will be used until the end of the next two refuel outages to assure isolation of the seismic piping from the non seismic piping during any condition requiring the RWST volume to be intact and threatening to reduce the RWST level below the TS allowable. This will assure continued compliance with these criteria.

The plant will continue to meet Criterion 35 which says "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 damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts." The RWST provides a support function for this criterion since it supplies the water which is injected following an event and must contain the amount of water required by analysis. Manual action will be used until the end of the next two refuel outages to assure isolation of the seismic piping from the non credited non seismic piping to assure RWST level meets the TS allowable. This will assure continued compliance with this criterion.

5.3 Environmental Considerations The proposed changes to the IP2 Technical Specifications do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE Joseph M. Farley Units 1 and 2 received approval for taking manual action to isolate the RWST from the non seismic SFP lines in Amendments 188 and 183, respectively (Reference 3). Indian Point 3 received approval for taking manual action to isolate the RWST from the non seismic SFP lines in Amendment 250 (Reference 4).

7.0 REFERENCES

1. IP-CALC-13-00005, Rev 1, "Engineering Evaluation of Postulated RWST Inventory Loss During the Reverse Osmosis Clean-up Skid Process in Accordance to 2-TAP-001-ROS due to a seismic Event', March 2013.

2. 2-OSP-10.1.1, Support Procedure - Safety Injection Accumulators and Refueling Water Storage Tank Operations.

NL-13-015 Docket No. 50-247 Page 8 of 8

3. NRC Letter to Southern Nuclear Operating Company, Inc., "Joseph M. Farley Nuclear Plant, Units 1 and 2, Issuance of Amendments regarding Refueling Water Storage Tank (TAC NOS. ME8005 AND ME8006)", dated March 24, 2012.

4. NRC letter to Entergy, "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)", dated February 22, 2013.

ATTACHMENT 2 TO NL-13-015 MARKED UP TECHNICAL SPECIFICATION PAGE FOR PROPOSED CHANGE REGARDING CONNECTION OF NON SEISMIC BARS TO REFUELING WATER STORAGE TANK Change indicated by Bold/Italics for addition Unit 2 Affected Page:

3.5.4-1 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

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 shall be OPERABLE.

- NOTE-The RWST isolation valves 350, 727A and 845 connected to non-safety related piping may be opened under administrative controls for up to 30 days per fuel cycle for filtration until the end of refuel outage 22.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

RWST boron A. 1 Restore RWST to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B. One of the two required B.1 Restore RWST level low 7 days channels of the RWST low alarm to OPERABLE level low low alarm status.

inoperable.

C. RWST inoperable for C.1 Restore RWST to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reasons other than OPERABLE status.

Condition A or B.

D. Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.

AND D.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 2 3.5.4-1 Amendment No.

ATTACHMENT 3 TO NL-13-015 MARKED UP TECHNICAL SPECIFICATION BASES CHANGE ASSOCIATED WITH THE PROPOSED CHANGES REGARDING CONNECTION OF NON SEISMIC BARS TO REFUELING WATER STORAGE TANK Change indicated by Bold/Italics for addition Unit 2 Affected Page:

3.5.4-4 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2DOCKET NO. 50-247

RWST B 3.5.4 BASES The IP2 ESFAS design does not include automatic switchover from the safety injection mode to the recirculation mode of operation based on low level in the RWST coincident with a safety injection signal. This function is performed manually by the operator who must be alerted by redundant alarms that annunciate RWST level low low. The switchover to the cold leg recirculation phase is manually initiated when the RWST level has reached the low low alarm setpoint and sufficient coolant inventory to support pump operation in recirculation mode is verified to be in the containment.

The RWST level low low alarm setpoint has both upper and lower limits.

The upper limit is set to ensure that switchover does not occur until there is adequate water inventory in the containment to provide ECCS pump suction.

(This is confirmed by recirculation and/or containment sump level indication.)

The lower limit is set to ensure switchover occurs before the RWST empties, to prevent ECCS pump damage.

Requiring 2 channels of RWST level low low alarm ensures that the alarm function will be available assuming a single failure of one channel.

The RWST satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO The RWST ensures that an adequate supply of borated water is available to cool and depressurize the containment in the event of a Design Basis Accident (DBA), to cool and cover the core in the event of a LOCA, to maintain the reactor subcritical following a DBA, and to ensure adequate level in the recirculation and containment sump to support ECCS operation in the recirculation mode.

To be considered OPERABLE, the RWST must meet the water volume, boron concentration, and temperature limits established in the SRs.

RWST OPERABILITY requires OPERABILITY of two channels of the RWST level low low alarm. This is required because the IP2 ESFAS design does not include automatic switchover from the safety injection mode to the recirculation mode of operation based on low level in the RWST coincident with a safety injection signal. This function is performed manually by the operator who must be alerted by redundant alarms that annunciate RWST level low low. The switchover to the cold leg recirculation phase is manually initiated when the RWST level has reached the low low alarm setpoint and sufficient coolant inventory to support pump operation in recirculation mode is verified to be in the containment.

A note allows the RWST valves that isolate non-seismic piping to be opened under administrative control for filtration until the end of RO 22.

INDIAN POINT 2 B 3.5.4-4 Revisionn-

4 ENCLOSURE 1 TO NL-13-015 INDIAN POINT 2 DRAWINGS AND CALCULATION Unit 2 Documents:

Drawing 227781 Drawing 9321-F-2735 Drawing 9321-F-2736 Calculation IP-CALC-13-00005, Rev I ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

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