NL-21-039, Response to Request for Additional Information - License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary
| ML21140A451 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/20/2021 |
| From: | Gaston R Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML21140A450 | List: |
| References | |
| NL-21-039 | |
| Download: ML21140A451 (13) | |
Text
Entergy Nuclear Operations, Inc.
1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing Proprietary Information - Withhold from Public Disclosure Under 10 CFR 2.390 The balance of this letter may be considered non-proprietary upon removal of Enclosure 1.
10 CFR 50.90 NL-21-039 May 20, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
Subject:
Response to Request for Additional Information - License Amendment Request to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device Indian Point Nuclear Generating Unit No. 3 NRC Docket No. 50-286 Renewed Facility Operating License No. DPR-64
References:
- 1) Entergy Nuclear Operations, Inc. (Entergy) letter to U. S. Nuclear Regulatory Commission (NRC), "Proposed License Amendment to Revise the Indian Point Nuclear Generating Unit No. 3 Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device" (ADAMS Accession No. ML20084U773), dated March 24, 2020
- 2) NRC Electronic mail from R. Guzman (NRC) to P. Couture (Entergy),
Subject:
"Indian Point Unit No. 3 - Subsequent Request for Additional Information: LAR to Revise Licensing Basis for New Auxiliary Lifting Device (Public Redacted Version) (EPID L-2020-LLA-0051)," (ADAMS Accession No. ML21112A267), dated April 22, 2021 In Reference 1, Entergy Nuclear Operations, Inc. (Entergy) submitted a request for a proposed amendment to Renewed Facility Operating License (FOL) DPR-64 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment requested U.S. Nuclear Regulatory Commission (NRC) approval to incorporate, into the IP3 Licensing Basis, the installation and use of a new single failure proof auxiliary lifting device (i.e., the Holtec International (Holtec) HI-LIFT) to handle a dry cask storage (DCS) transfer cask (i.e., the HI-TRAC) in the IP3 Fuel Storage Building (FSB).
NL-21-039 Page 2 of 2 In Reference 2, the NRC transmitted a request for additional information (RAI) concerning the proposed license amendment. The following Enclosures to this letter provide a response to the NRC RAI.
provides a proprietary version of the narrative RAI response. This enclosure contains information proprietary to Holtec, and is therefore supported by an affidavit signed by Holtec, the owner of the information, which is provided in Enclosure 3.
provides a non-proprietary, redacted version of the narrative RAI response.
provides the Holtec Affidavit in support of Enclosure 1. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the NRC and addresses, with specificity, the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations.
There are no new regulatory commitments in the enclosed RAI response.
Should you have any questions or require additional information, please contact Mr. Matthew Johnson, Nuclear Manager - IPEC Decommissioning at (914) 254-6288.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), a copy of this application, with non-proprietary enclosures, is being provided to the designated State Officials.
I declare under penalty of perjury; the foregoing is true and correct. Executed on May 20, 2021.
Respectfully, Ron Gaston RWG/jls Response to Request for Additional Information, Proprietary :
Response to Request for Additional Information, Non-proprietary :
Holtec Affidavit Pursuant to 10 CFR 2.390, dated May 19, 2021 cc:
NRC Region I Regional Administrator NRC Senior Resident Inspector, Indian Point Nuclear Generating Unit Nos. 2 and 3 NRC Senior Project Manager, NRC/NRR/DORL President and CEO, NYSERDA (with Enclosures 2 and 3 only)
New York State Public Service Commission (with Enclosures 2 and 3 only)
NYS Department of Health - Radiation Control Program (with Enclosures 2 and 3 only)
NYS Emergency Management Agency (with Enclosures 2 and 3 only)
$ %"&'()
NL-21-039 Response to Request for Additional Information Non-Proprietary
NL-21-039 Page 1 of 4 Response to Request for Additional Information Non-Proprietary
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Background===
By application dated March 24, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20084U773), Entergy Nuclear Operations, Inc., (Entergy, the licensee) requested to revise the Indian Point Nuclear Generating Unit No. 3 (IP3) licensing basis for spent fuel cask handling. The licensee requested approval to incorporate into the IP3 licensing basis, the installation and use of a new single failure proof auxiliary lifting device (i.e.,
the Holtec International HI-LIFT) to handle a dry cask storage transfer cask (i.e., the HI-TRAC) in the IP3 Fuel Storage Building. The change to the IP3 licensing would be documented in a revision to the IP3 Updated Final Safety Analysis Report (UFSAR).
Section 1.3, "General Design Criteria," of the IP3 UFSAR states that the licensee conducted a study of the method of compliance with NRC regulations contained in 10 CFR Part 50, including the General Design Criteria (GDC) of Appendix A to 10 CFR Part 50, and that the results of the compliance study were updated to reflect changes made to the configuration since the study was completed. The study was conducted in accordance with the provisions of NRC Confirmatory Order of February 11, 1980 and were submitted to the NRC on August 11, 1980.
RAI 8 (SCPB-Plant Systems): Defense-in-depth Regulatory Basis:
10 CFR Part 50, Appendix A, GDC 4, "Environmental and Dynamic Effects Design Bases," specifies appropriate protection for SSCs important to safety against dynamic effects, including the effects of missiles that may result from equipment failures.
Request In Section 3.6.5 of the enclosure to the license amendment request dated March 24, 2020 (ADAMS Accession No. ML20084U773), Entergy provided the following non-proprietary information regarding response to an inoperable swing cylinder:
The hydraulic cylinders that operate the swing arms are mechanically load tested and procured with enhanced factors of safety to make a catastrophic mechanical failure non-credible. Seal leaks and counterbalance valve failures are possible, but they tend to be gradual failures. In this case (i.e., loss of hydraulic power), as well as swing cylinder control failure, hydraulic fluid can be manually bled from the cylinders, allowing gravitational force to pull the swing arms towards one end of travel. In the event the swing arms are at the apex position, rigging can be manually attached, and used to pull the swing arms sufficiently far for gravitational force to become effective. In either case, operators are able to throttle the fluid that is bled off from the cylinders to maintain a slow, controlled motion, such that the swing arms will be at the end of their travel. At that point, the load can then be lowered and placed in a safe condition.
NL-21-039 Page 2 of 4 In the section of the proprietary HI-LIFT Specification for IPEC Unit 3, HI-2188549, addressing
((
)).
Consistent with regulatory guidance in NUREG-0554, heavy load handling systems should be designed to stop and hold the load following a loss of power and equipment failure. The NRC staff considers the described conditions to be credible combinations of events for the HI-LIFT design. In order to satisfy defense-in-depth principles related to maintaining handling system reliability commensurate with the frequency and consequences of challenges, additional information is necessary to understand the consequences of challenges that could cause or result from uneven operation of the hydraulic cylinders and the expected operator actions to compensate for those conditions.
Establish the maximum acceptable threshold regarding uneven operation of the hydraulic cylinders, where the HI-LIFT structure, in its most limiting orientation(s),
remains capable of supporting its full rated load and describe how this threshold was determined.
Please describe if and how the cranes control system can detect, correct for, and/or alert operators in the case of uneven operation of the hydraulic cylinders. Describe any defense in depth measures that provide assurance that any uneven operation of the hydraulic cylinders will not result in reaching the threshold mentioned above.
Entergy Response:
Response to Bullet 1:
Maximum acceptable threshold limits regarding uneven operation of the hydraulic cylinders were established by performing sensitivity analyses of the HI-LIFT, utilizing the ANSYS model of the HI-LIFT discussed in Section F.1 of HI-2188625, Revision 2, "Structural Evaluation of HI-LIFT Device and Fuel Storage Building Walls at Indian Point Unit 3." Revision 1 of HI-2188625 was submitted as Attachment 4 to the original March 24, 2020 license amendment request (LAR) (ADAMS Accession No. ML20084U773). Revision 2 was submitted as Enclosure 2 in the October 2, 2020 RAI response (ML20276A322). The discussion in Section F.1 of HI-2188625 is the same in both revisions. The sensitivity analyses are performed for the HI-LIFT to support the full rated load under the two most limiting orientations: ((
)).
All other aspects of the analytical model are kept consistent with those documented in HI2188625, Revision 2. Subsequently, a maximum threshold limit for uneven operation is established by ensuring that all HI-LIFT load bearing components maintain compliance with ASME NOG-1 allowable stresses under normal and seismic load cases. The established maximum threshold limit in terms of hydraulic cylinder rod displacement is approximately
((
NL-21-039 Page 3 of 4
)).
In other words, one cylinder rod can extend approximately (( )) more than the other cylinder while maintaining compliance with all ASME NOG-1 allowable stresses for the HI-LIFT. The load bearing spent fuel building walls are also re-evaluated under the bounding loads from the above discussed sensitivity analyses and demonstrated to meet all applicable limits specified in ACI 318-63, "Building code requirements for reinforced concrete."
The HI-LIFT control system will be designed to detect, correct for, and/or alert operators in the case of uneven operations at a portion of the maximum threshold limit listed above. The sensitivity simulations discussed here are documented in HI2188625, Revision 3.
Response to Bullet 2:
Installation and commissioning activities will ensure the HI-LIFT and control systems are properly functioning before the first cask is lifted. The HI-LIFT will be adjusted at installation to provide close alignment of cylinders. Control sensors are calibrated, primary and redundant control systems are verified through functional testing, and HI-LIFT mechanical elements are verified through load testing. Therefore, the initial configuration and condition of the equipment establishes the baseline for subsequent monitoring, in-service inspection, and preventative maintenance activities.
The hydraulic swing cylinder primary control system will use a flow balancing system with the ability to vary the flow to each cylinder, using variable speed pumps or similar system. Position indication sensors will be installed to detect the positions of each cylinder rod, to provide ongoing feedback to the control system. The primary control system logic constantly compares the relative positions of each cylinder rod, and adjusts the flow to each cylinder accordingly to maintain relative positions of each cylinder rod within a preset limit of approximately ((
)). If the primary control system reaches its preset limit for relative cylinder position, it will stop motion, and alert the operator at the control console. If the primary controls reach this limit and stop motion, operators will initiate troubleshooting procedures to diagnose and repair components of the system before resuming travel. The manual hydraulic fluid bleed-off procedure (described in HI-2188549, Revision 2, Section 7.1.3) may be employed if needed to reposition the HI-LIFT and lifted load without the use of electronic controls.
To provide protection from primary control system failure, a redundant control system will monitor cylinder rod positions. If rod positions reach a preset limit of approximately (( )),
the redundant control system will provide an alarm to operators and disconnect electrical power to the hydraulic pumps, which removes hydraulic pressure to the system, causing counterbalance valves to close, and cylinders to stop and hold position. If the redundant controls reach this limit and stop motion, operators will initiate troubleshooting procedures to diagnose and repair components of the system before resuming travel. As stated above, the manual hydraulic fluid bleed-off procedure (described in HI-2188549, Revision 2, Section 7.1.3) may be employed if needed to reposition the HI-LIFT and lifted load without the use of electronic controls.
NL-21-039 Page 4 of 4 Note that the control system limits presented above will be confirmed during factory acceptance testing and commissioning activities, and will be adjusted as needed to ensure appropriate margin is maintained with regard to threshold limits.
In the event of minor seal leakage affecting the cylinders or counterbalance valve, the control system would receive feedback that one cylinder is beginning to lag, and it can increase flow to the lagging cylinder and/or reduce flow to the opposite cylinder to compensate. ((
))
Inspections, monitoring and preventative maintenance will ensure leaks never exceed the ability of the control system to compensate. To provide objectivity to inspections, the maximum acceptable total leak rate will be 1% of the pump flow capacity taken at the maximum normal cylinder operating pressure (( )) which occurs when the swing arms are fully extended over the pool.
The requirement to conduct in-service inspections of the hydraulic components is listed in Table 6.1 of HI-2188549, Revision 2. Requirements for visual detection of external leaks will be augmented to specify a limiting leak rate of 1% of the hydraulic pump flow capacity. Table 6.1 will be augmented to add in-service inspection for internal leaks, to occur monthly, or after four (4) cask loading cycles, whichever occurs first. Internal leaks will be inspected by pressurizing the stationary cylinder with hydraulic fluid to the maximum normal cylinder operating pressure and measuring fluid flow into the cylinder required to maintain the pressure. Other test arrangements may be used as long as they demonstrate equivalent accuracy.
NL-21-039 Holtec Affidavit Pursuant to 10 CFR 2.390 dated May 19, 2021