ML20259A200

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CFR 50.71(e) Submittal
ML20259A200
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 09/14/2020
From: Vitale A
Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20259A199 List:
References
NL-20-066
Download: ML20259A200 (14)


Text

Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249 Tel 914-254-6700 Anthony J. Vitale Site Vice President 10 CFR 50.71 (e)

NL-20-066 September 14, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Indian Point Unit No. 2 10 CFR 50.71 (e) Submittal Indian Point Nuclear Generating Unit No. 2 Docket No. 50-247 Renewed Facility License No. DPR-26

References:

1) Entergy Nuclear Operations, Inc. (Entergy) letter to U.S. Nuclear Regulatory Commission (NRC), "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel,"

(Letter No. NL-20-042) (ADAMS Accession No. ML20133J902), dated May 12,2020 11

2) NEI 98-03, "Guidelines for Updating Final Safety Analysis Reports, Revision 1, June 1999
3) NEI 99-04, "Guidelines for Managing NRC Commitments," Revision 2, December 1995 In Reference 1, Entergy Nuclear Operations, Inc. (Entergy) notified the U.S. Nuclear Regulatory Commission (NRC) of the permanent cessation of power operations and the permanent removal of fuel from the Indian Point Nuclear Generating Unit No. 2 (IP2) reactor vessel. Note that the IP2 defueling outage was completed on May 12, 2020. Accordingly, licensing basis documents were revised to reflect this condition. The Updated Final Safety Analysis Report (UFSAR) was revised and renamed the Defueled Safety Analysis Report (DSAR) and was issued as Revision 0 on June 1, 2020. Entergy, in accordance with 10 CFR 50.71(e), hereby transmits Revision O of the DSAR for IP2, and certifies that there have been no changes since its issuance. Entergy submitted the previous UFSAR revision (i.e., Revision 27) on September 17, 2018.

NL-20-066 Page 2 of 3 Entergy is submitting copies of the entire IP2 DSAR (which now includes the IP2 Technical Requirements Manual or TRM as Appendix B), the IP2 Technical Specification Bases, and the Holtec International, "Licensing Report on the Inter-Unit Transfer of Spent Nuclear Fuel at the Indian Point Energy Center, Revision 10," as enclosures to this letter. Attachment 1 contains the File Index for the enclosures.

The DSAR is a Non-Redacted version as it does not contain certain information meeting the NRC's criteria on sensitive information, as specified in SECY-04-0191, "Withholding Sensitive Unclassified Information Concerning Nuclear Power Reactors from Public Disclosure."

As the DSAR is a major rewrite of the UFSAR, changes to the text and tables since the last revision are not indicated by revision bars. Further, DSAR figures retain the previous UFSAR figure numbers as explained in the "Instructions and Key." The DSAR also contains information that has been classified as "Historical" information according to the NEI 98-03 definition (Reference 2) and is no longer subject to updating. Material designated as "Historical" information in the DSAR is indicated by a green highlighted background. to this letter, "Summary Report of IP2 UFSAR Rev. 27 to DSAR Rev. 0 Changes,"

contains a summary with a brief description of the actions taken (modify, retain, delete) for the information contained in revising the UFSAR Revision 27 to DSAR Revision 0. The entire DSAR is included as Enclosure 2.

IP2 Technical Specification 5.5.12.d, "Technical Specification Bases Control Program," requires that changes to the Bases implemented without prior NRC approval be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e). The required information is provided in , "Summary of Revisions to the IP2 Technical Specification Bases," and the entire document is provided as Enclosure 3. Note that the Bases were also revised and renamed the Permanently Defueled Technical Specification Bases and were issued as Revision 0 on June 1, 2020.

The TRM is now included in the DSAR as Appendix B. A summary of revisions to the I P2 TRM is provided in Attachment 3, and the entire document is provided with Enclosure 2.

NEI 99-04 (Reference 3) provides guidance on the commitments which may be changed without prior NRC approval, but which require periodic NRC staff notification either annually or along with the FSAR updates as required by 10 CFR 50.71 (e). Enclosure 4, "IP2 Commitment Change Summary Report, 11 contains the commitment changes that have not previously been filed with the NRC in separate correspondence. These commitments have been statused as "Historic" as they are no longer relevant to the permanent defueled status of IP2.

As specified in NEI 98-03 (Reference 2), the Holtec International, "Licensing Report on the Inter-11 Unit Transfer of Spent Nuclear Fuel at the Indian Point Energy Center, Revision 10, is a 11 licensee controlled document that is explicitly "incorporated by reference into the I P2 DSAR.

Under this approach, the referenced document is subject to the change control requirements of 10 CFR 50.59 and the update/reporting requirements of 10 CFR 50.71 (e). The entire document is provided as Enclosure 5.

NL-20-066 Page 3 of 3 There are no new commitments contained in this letter. In the event of any questions, please contact Ms. Mahvash Mirzai, Manager, Regulatory Assurance, at 914-254-7714.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on __ '3_-_\_l\_-2-_0_ _

Respectfully, Anthony J. Vitale AJV/gd Attachments: 1. NRC File Index for the Enclosures

2. Summary of Revisions to the IP2 Technical Specification Bases
3. Summary of Revisions to the IP2 Technical Requirements Manual (TRM)

(now included as DSAR Appendix B)

Enclosures:

1. Summary Report oflP2 UFSAR Rev. 27 to DSAR Rev. 0 Changes
2. IP2 DSAR Revision O (consisting of 14 separate files)
3. IP2 Permanently Defueled Technical Specification Bases Revision O
4. IP2 Commitment Change Summary Report
5. Holtec International, "Licensing Report on the Inter-Unit Transfer of Spent Nuclear Fuel at the Indian Point Energy Center," Revision 10 cc w/o enclosures: NRC Region I Regional Administrator NRC Senior Project Manager, NRR DORL NRC Senior Resident Inspector New York State Department of Public Service New York State Liaison Officer Designee, NYSERDA

Attachment 1 NL-20-066 NRC File Index for the Enclosures

NL-20-066 Page 1 of 1 NRC File Index for the Enclosures File Naming Table Document Title File Name Multiple File Document -

Indian Point 2 DSAR, Rev. 0 (Enclosure 2) 001 _ 1. 1 Introduction and Chapter 1, Introduction and Summary Summary.pdf Chapter 1, Figures 001_ 1.2 DSAR Ch 1 Figures.pdf Chapter 2, Site and Environment 002_2.1 Site & Environment.pdf Chapter 2, Figures 002_2.2 DSAR Ch 2 Figures.pdf 003_3.1 Facility Design and Chapter 3, Facility Design and Operation Operation.pdf Chapter 3, Figures 003_3.2 DSAR Ch 3 Figures.pdf 004_4.1 Waste Disposal and Chapter 4, Waste Disposal and Radiation Protection Radiation Protection.pdf Chapter 4, Figures 004_4.2 DSAR Ch 4 Figures.pdf 005_5.1 Conduct of Facility Chapter 5, Conduct of Facility Operations Operations.pdf Chapter 6, Safety Analysis 006_6.1 Safety Analysis.pdf Appendix A, License Renewal 007_7 .1 App A, Lie Renewal.pdf Appendix B, Technical Requirements Manual (TRM) 008_8.1 IP2 TRM R0.pdf Instructions and Key 009_9.1 Instructions and Key.pdf Table of Contents 01O_10.1 TOC.pdf Single File Documents Enclosure 1 - Summary Report of IP2 UFSAR Rev. 27 to 001 _DSAR RO Summary DSAR Rev. 0 Changes Report.pdf Enclosure 3 - Indian Point 2 Permanently Defueled Technical 002_IP2 Tech Spec Bases R0.pdf Specification Bases Enclosure 4 - I P2 Commitment Change Summary Report 003_Comm Change Summary.pdf Enclosure 5 - Holtec Licensing Report on the Inter-Unit 004_Holtec Licensing Report Transfer of Spent Nuclear Fuel at the Indian Point Energy R10.pdf Center (Non-Proprietary)

Attachment 2 NL-20-066 Summary of Revisions to the IP2 Technical Specification Bases

NL-20-066 Page 1 of 1 Summary of Revisions to the IP2 Technical Specification Bases (Since last reported September 17, 2018)

AFFECl'ED , 1-EFFECTIVE SECTIONS REV . ~oAllE .

BASES UPDATE PACKAGE 61-09182019 Revised to correct the discrepancy between Revision B 3.0 3 09/18/2019 Numbers of pages 1-18.

BASES UPDATE PACKAGE 62-11062019 Revised to implement TS Amendment 290 regarding B 3.7.12 3 11/06/2019 Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool Revised to implement TS Amendment 290 regarding B 3.7.13 8 11/06/2019 Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool BASES UPDATE PACKAGE 63-12102019 Revised to implement TS Amendment 291 regarding B 3.0 4 12/10/2019 TSTF-529 Rev 4 (Clarify Use and Application Rules)

BASES UPDATE PACKAGE 64-06012020 Initial issue of Bases for Defueled Technical Specifications ALL 0 6/1/2020 in conjunction with Technical Specification Amendment 294 for permanently defueled condition

Attachment 3 NL-20-066 Summary of Revisions to the IP2 Technical Requirements Manual (TRM)

(now included as DSAR Appendix B)

NL-20-066 Page 1 of 1 Summary of Revisions to the IP2 Technical Requirements Manual (TRM)

(since last reported September 17, 2018)

AFFECTED NEW EFFECTIVE DESCRIPTION SECTIONS REV# DATE 83.7.G 5 10/20/2018 Correction of safety classification of 21/22 Containment PAB Exhaust Fan from safety related to augmented quality 5.0 15 10/30/2018 Revision to remove the requirement to provide annual exposure information to the NRC for each unit separately in the annual 10 CFR 20.2206 report of station radiation doses 5.5 16 8/8/2019 Editorial corrections for 5.5.8 (Primary Coolant Sources Outside Containment - deletion of Secondary Boiler Slowdown Purification System) and 5.5.M (Safety Function Determination Program - correction of procedure number)

ALL 0 6/1/2020 Initial issue of TRM as Appendix 8 of the DSAR in conjunction with Technical Specification Amendment 294 for permanently defueled condition

Enclosure 1 NL-20-066 Summary Report of IP2 UFSAR Rev. 27 to DSAR Rev. 0 Changes

Enclosure 2 NL-20-066 IP2 DSAR Revision 0 (consisting of 14 separate files)

Enclosure 3 NL-20-066 IP2 Permanently Defueled Technical Specification Bases Revision O

Enclosure 4 NL-20-066 IP2 Commitment Change Summary Report

Enclosure 5 NL-20-066 Holtec International, "Licensing Report on the Inter-Unit Transfer of Spent Nuclear Fuel at the Indian Point Energy Center, Revision 10 (Non-Proprietary)