NL-02-003, License Amendment Request (LAR) No. 02-003) - Deletion of Technical Specifications for Fuel Storage Building Air Filtration System
| ML020150478 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 01/08/2002 |
| From: | Dacimo F Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-02-003 | |
| Download: ML020150478 (20) | |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
Indian Point Energy Center "295 Broadway, Suite 1 PO. Box 249 Buchanan, NY 10511-0249 January 8, 2002 Re:
Indian Point Unit No. 2 Docket No. 50-247 NL-02-003 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001
SUBJECT:
License Amendment Request (LAR No.02-003) - Deletion of Technical Specifications for the Fuel Storage Building Air Filtration System
References:
- 1. NRC letter to Con Edison, titled "Indian Point Nuclear Generating Unit No. 2 - Re: Issuance of Amendment Affecting Containment Air Filtration, Control Room Air Filtration, and Containment Integrity During Fuel Handling Operations (TAC No. MA6955)," dated July 27, 2000 Pursuant to 1 OCFR50.90, Entergy Nuclear Operations, Inc. (ENO) requests an amendment to the Indian Point Unit No. 2 (IP2) Technical Specifications (TS) to delete the requirements governing the Fuel Storage Building Air Filtration System. The proposed changes affect IP2 TS 3.8, "Refueling, Fuel Storage and Operations with the Reactor Vessel Head Bolts Less Than Fully Tensioned," and TS 4.5.F, "Fuel Storage Building Air Filtration System." This change provides a significant cost savings and operational flexibility to IP2 without any increase in the consequences of the analyzed fuel handling accident in the fuel storage building. This request is consistent with the I P2 radiological consequences analysis performed to show compliance with 1 OCFR50.67 that was reviewed and found acceptable by the NRC as discussed in the staff's Safety Evaluation (Ref. 1)
The Station Nuclear Safety Committee (SNSC) and the Nuclear Facilities Safety Committee (NFSC) have reviewed the proposed changes. Both committees concur that the proposed changes do not represent a significant hazards consideration as defined by 10CFR50.92(c). to this letter provides the description and evaluation of the proposed change. The revised TS pages are provided in Attachment 2 (strikeout/shadow format).
ENO requests that the proposed changes be approved by June 30, 2002 with an effective date within 60 days of approval. The approval date is requested so that IP2 can benefit from the requested change during the refueling outage scheduled for the Fall of 2002.
NL 02-003 Page 2 of 4 In accordance with 1 0CFR50.91, a copy of this submittal with its associated attachments is being submitted to the designated New York State official.
This submittal contains new commitments listed in Attachment 3.
Should you have any questions or require additional information, please contact Mr.
John F. McCann, Manager Nuclear Safety and Licensing, at (914) 734-5074.
Sincerely, Fred Dacimo Vice President - Operations Indian Point 2 Attachments cc:
See page 3
NL 02-003 Page 3 of 4 cc:
Hubert J. Miller Regional Administrator US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management US Nuclear Regulatory Commission Mail Stop 0-8-2C Washington, DC 20555 NRC Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza Albany, NY 12223 Mr. William F. Flynn NYS ERDA Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12223-6399
NL 02-003 Page 4 of 4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
Entergy Nuclear Operations, Inc.
)
Docket Nos. 50-247 Indian Point Nuclear Generating Unit No. 2
)
APPLICATION FOR AMENDMENT TO OPERATING LICENSE Pursuant to Section 50.90 of the Regulations of the Nuclear Regulatory Commission, Entergy Nuclear Operations, as holder of Facility Operating No. DPR-26, hereby applies for amendment of the Indian Point Unit 2 Technical Specifications contained in Appendix A of the license.
The specific proposed Technical Specification revisions are set forth in Attachment 2.
The associated assessments demonstrate that the proposed changes do not involve a significant hazards consideration as defined in 10CFR50.92(c).
As required by 1 OCFR50.91 (b)(1), a copy of this Application and an analysis concluding that the proposed changes do not involve a significant hazards consideration have been provided to the designated New York State official ENTERGY NUCLEAR OPERATIONS, INC.
BY:
Fred Dacimo Vice President - Operations Indian Point 2 STATE OF NEW YORK COUNTY OF WESTCHESTER Subscribed and sworn to before me this
- day 2002.
Notary Public K-APEN L O-ANCA-rTPR Notary Pjic, S.,
14o 1 Euaf1 f-County
ATTACHMENT 1 TO NL 02-003 LICENSE AMENDMENT REQUEST Deletion of Technical Specifications for the Fuel Storage Building Air Filtration System ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT UNIT NO. 2 DOCKET NO. 50-247 NL 02-003 Page 1 of 4 LICENSE AMENDMENT REQUEST DESCRIPTION OF THE PROPOSED CHANGE Entergy Nuclear Operations, Inc. (ENO) is requesting a change to the Indian Point Unit No. 2 (IP2) Technical Specifications (TS) to delete the requirements for the Fuel Storage Building (FSB) Air Filtration System. The TS that are affected by the proposed change are TS 3.8, "Refueling, Fuel Storage and Operations with the Reactor Vessel Head Bolts Less Than Fully Tensioned," and TS 4.5.F, "Fuel Storage Building Air Filtration System."
REASON FOR THE PROPOSED CHANGE The FSB Air Filtration System no longer meets any criteria of 1 0CFR50.36 for inclusion in the TS as a Limiting Condition for Operation. The TS for operation of the FSB Air Filtration system are no longer consistent with the UFSAR analysis for Fuel Handling Accident (FHA) Analysis in the FSB.
EVALUATION OF THE PROPOSED CHANGE The FSB Air Filtration System is currently in TS because it met criterion 3 of 10CFR50.36(c)(2)(ii). The system had been credited in the IP2 UFSAR as a system that was part of the primary success path and which functioned to mitigate a FHA in the FSB. System operability was required to filter and thus limit the atmospheric release of fission products in the event of a FHA in the FSB to a small fraction of the 1 OCFR1 00 limits.
1 OCFR50 Appendix A Criterion 61, "Fuel Storage and Handling and Radioactivity Control Requirements," requires that:
The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.
In License Amendment 211 (Ref. 1), the Licensing Basis for IP2 for offsite radiation exposure from analyzed accidents was changed from 10CFR100 to 10CFR50.67. As described in the SER for License Amendment 211 and in the current IP2 UFSAR 14.2.1.1, the limits of 10CFR50.67 are met for both offsite dose and control room dose for a FHA in the FSB with no credit for the removal of iodine by the FSB Air Filtration System. In fact, the doses are less than 25% of the 10CFR50.67 limits.
The FHA analysis assumes that fuel movement occurs at the time allowed by TS 3.8 (i.e., 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> after shutdown). Since the radiological consequences at that time are well within regulatory requirements, all irradiated fuel movement in the FSB at IP2 is NL 02-003 Page 2 of 4 movement of not-recently-irradiated fuel.1 This provides added assurance that potential dose from a FHA in the FSB will remain below regulatory limits.
Since the FSB air filtration system is not required to mitigate a FHA in the FSB, there is no criterion in 10CFR50.36 that requires its inclusion in the TS.
The FSB ventilation system, including the Air Filtration system, is currently described in the UFSAR section 9.10, "Fuel Storage Building Ventilation System." There are currently no plans to change the design of the FSB Ventilation system. However IP2 anticipates that a future design change will remove the charcoal filters. If the proposed TS change is approved, future changes to the FSB Ventilation system will be controlled by 1 0CFR50.59. This level of control is appropriate for the safety significance of the FSB air filtration system. This proposed TS change, if approved, would ensure ENO and NRC resources are not utilized for changes to a system that now has reduced safety significance.
ENO will continue to operate the FSB ventilation system during the movement of irradiated fuel assemblies in the FSB. This will ensure that any radioactivity from a damaged fuel assembly will be released to atmosphere through a monitored and elevated plant vent, thus ensuring effective ALARA compliance with 1 OCFR20. ENO will allow the FSB ventilation boundary to be open while irradiated fuel movement is in progress provided administrative controls are in place to quickly close the openings in the event of a FHA. This provides flexibility for personnel and equipment access while continuing to provide the assurance that potential releases from a FSB FHA are released to the atmosphere through a monitored and elevated pathway. To maintain an adequate level of regulatory control, ENO commits to relocate to UFSAR section 9.10 the TS 3.8 system operating requirements and the TS 4.5.F system testing requirements.
The proposed deletion of the TS and anticipated operational changes would allow increased operational flexibility in the FSB when irradiated fuel assemblies are being moved. At the same time, licensing basis conditions that are conservative with respect to the FHA analysis will be maintained.
The proposed TS is consistent with requirements presented in NUREG-1431, "Standard Technical Specifications-Westinghouse Plants." NUREG-1431 only requires operability of the FSB Air Filtration system when recently irradiated fuel is being moved within the FSB. Approval of the proposed TS will facilitate the IP2 transition to the Standard Technical Specifications.
1 NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," describes fuel as not being recently irradiated if the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 1 OCFR1 00. Standard Review Plan, Section 15.7.4, Rev. 1, defines "well within" 10CFR100 to be 25% or less of the 10CFR100 values. The acceptance limits for offsite radiation exposure will be 25% of 1 0CFR1 00 values or the NRC staff approved licensing basis (e.g., a specified fraction of 10 CFR 100 limits). Since the current licensing basis for IP2 for radiological consequences is 1 OCFR50.67 rather than 1 OCFR1 00, the ENO conclusion that the fuel is not recently irradiated is based on 1 OCFR50.67 rather than 1 OCFR1 00 values.
NL 02-003 Page 3 of 4 Conclusion In conclusion, based on the considerations above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.
NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes described above do not involve a significant hazards consideration. This conclusion is based on the evaluation, in accordance with 1 OCFR50.91 (a)(1), of the three standards set forth in 1 OCFR50.92(c).
- 1.
Does the proposed license amendment involve a significant increase in the probability or in the consequences of an accident previously evaluated?
The fuel storage building air filtration system is not involved in the initiation of any accident nor does it function to prevent any accident. The fuel storage building air filtration system was an accident mitigating system. Therefore there is no affect on the probability of occurrence of a fuel handling accident in the fuel storage building.
The fuel storage building air filtration system was designed to provide an accident mitigation function by filtering the radionuclides that might have been released from a damaged fuel assembly in the event of a fuel handling accident.
The charcoal adsorber was the primary component that supported this filtration function. However based on the recent IP2 analyses to show compliance with 1 OCFR50.67, it has been shown that the doses to the public and to control room operators due to a fuel handling accident remain well within regulatory limits even assuming no credit for either isolation or filtration. Therefore the charcoal filtration function is not required in the event of a fuel handling accident.
There would be no change to the radiological consequences of the fuel handling accident in the fuel storage building analysis as a result of the proposed change.
The proposed changes ensure that the assumptions of the fuel handling accident analysis for the release of radioactivity from a damaged fuel assembly in the fuel storage building are maintained.
Therefore, there will be no increase in the probability or in the consequences of an accident previously evaluated.
- 2.
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
The fuel storage building air filtration system is not an accident initiator. It was designed as an accident mitigation system to filter the radionuclides that may be released from a damaged fuel assembly during a fuel handling accident. The fuel storage building air filtration system does not affect any accident initiator NL 02-003 Page 4 of 4 Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed amendment involve a significant reduction in a margin of safety?
The margin of safety is defined by 1 OCFR50.67 and 1 OCFR50 Appendix A Criterion 19. The radiological consequences of a fuel handling accident in the fuel storage building have been shown to be well within the regulatory requirements even when assuming no credit for the fuel storage building air filtration system operation.
The proposed change ensures that the assumptions of the current fuel handling analysis for the release of radioactivity from a damaged fuel assembly are maintained.
Therefore, the change does not result in a change to any of the safety analyses or any margin of safety.
CONCLUSION Based on the above evaluation, ENO has concluded that the proposed change will not result in a significant increase in the probability or consequences of any accident previously analyzed; will not result in a new or different kind of accident from any accident previously analyzed; and does not result in a reduction in any margin of safety.
Accordingly, these proposed changes do not involve a significant hazards consideration. The Station Nuclear Safety Committee (SNSC) and the Nuclear Facilities Safety Committee (NFSC) have reviewed the proposed changes. Both committees concur that the proposed changes do not involve a significant hazards consideration as defined by 10CFR50.92(c).
ENVIRONMENTAL ASSESSMENT An environmental assessment is not required for the above proposed changes because the requested changes to the Indian Point Generating Station Unit 2 Technical Specifications conform to the criteria for "actions eligible for categorical exclusion," as specified in 1 OCFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed changes do not involve a significant hazards consideration as discussed in the preceding section. The proposed changes do not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. In addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.
REFERENCE
- 1. NRC letter to Con Edison, titled "Indian Point Nuclear Generating Unit No. 2 - Re:
Issuance of Amendment Affecting Containment Air Filtration, Control Room Air Filtration, and Containment Integrity During Fuel Handling Operations (TAC No.
MA6955)," dated July 27, 2000
ATTACHMENT 2 TO NL 02-003 TECHNICAL SPECIFICATION PAGES IN STRIKEOUT/SHADOW FORMAT Deleted text is shown as eeo~t.
Added text is shown as shaded.
ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT UNIT NO. 2 DOCKET NO. 50-247
TABLE OF CONTENTS (Cont'd)
Section Title Page 4.5 Engineered Safety Features 4.5-1 A.
System Tests 4.5-1 B.
Containment Spray System 4.5-2 C.
Hydrogen Recombiner System 4.5-2 D.
Containment Fan Cooler System 4.5-2 E.
Control Room Air Filtration System 4.5-3 F.
Fuol Storao Bu'ilding.A.ir Fltration System DELETED 4.5-4 G.
Post-Accident Containment Venting System 4.5-6 H.
Recirculation Fluid pH Control System 4.5-7 4.6 Emergency Power System Periodic Tests 4.6-1 A.
Diesel Generators 4.6-1 B.
Diesel Fuel Tanks 4.6-2 C.
Station Batteries (Nos. 21, 22, 23, & 24) 4.6-2 D.
Gas Turbine Generators 4.6-2 E.
Gas Turbine Fuel Supply 4.6-3 4.7 Main Steam Stop Valves 4.7-1 4.8 Auxiliary Feedwater System 4.8-1 4.9 Reactivity Anomalies 4.9-1 4.10 Radioactive Effluents 4.10-1 A.
Radioactive Liquid Effluents 4.10-1 B.
Radioactive Gaseous Effluents 4.10-2 C.
Uranium Fuel Cycle Dose Commitment 4.10-3 D.
Solid Radioactive Waste 4.10-3 E.
Routine Reporting Requirements 4.10-3 4.11 Radiological Environmental Monitoring 4.11-1 A.
Monitoring Program 4.11-1 B.
Land Use Census 4.11-2 C.
Interlaboratory Comparison Program 4.11-3 D.
Routine Reporting Requirements 4.11-4 4.12 Shock Suppressors (Snubbers) 4.12-1 A.
Visual Inspection 4.12-1 B.
Functional Testing 4.12-4 C.
Functional Test Acceptance Criteria 4.12-6 D.
Record of Snubber Service Life 4.12-6 4.13 Steam Generator Tube Inservice Surveillance 4.13-1 A.
Inspection Requirements 4.13-1 B.
Acceptance Criteria and Corrective Action 4.13-5 C.
Reports and Review of Results 4.13-5 Amendment No. 24=v iv
6.
refueling crane for this event must be equal to or greater than the maximum load to be assumed by the refueling crane during the refueling operation. A thorough visual inspection of the refueling crane shall be made after the dead-load test and prior to fuel handling.
The fuel ctcrage building eharooal filtraticn system mquet be cperatinO g.hono:w spent f
,ol Mcv.m.nt isc.ald.
- plia,
,,ithin t.h8 spont u._, tcragc s roc "nr the spent fuo` has had a continuoucs 35 day Edocay peid DELETED
-I-----:^' DELETED
- 7.
Radiation levels in the spent fuel storage area shall be monitored continuously whenever spent fuel movement is taking place in that area.
- 8.
The equipment door, or a closure plate that restricts direct air flow from the containment, shall be properly installed. In addition, at least one isolation valve shall be operable or locked closed in each line penetrating the containment and which provides a direct path from containment atmosphere to the outside.
- 9.
Radiation levels in containment shall be monitored continuously.
- 10.
During alteration of the core (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling shall be present to directly supervise the activity and, during this time, this person shall not be assigned other duties.
- 11.
The minimum water level above the top of the reactor pressure vessel flange shall be at least 23 feet (El. 92'0") whenever movement of spent fuel is taking place inside the containment.
- 12.
If any of the conditions specified above cannot be met, suspend all operations under this specification (3.8.B). Suspension of operations shall not preclude completion of movement of the above components to a safe conservative position.
C.
The following conditions are applicable to the spent fuel pit any time it contains irradiated fuel:
- 1.
The spent fuel cask shall not be moved over any region of the spent fuel pit until the cask handling system has been reviewed by the Nuclear Regulatory Commission and found to be acceptable. Furthermore, any load in excess of the nominal weight of a spent fuel storage rack and associated handling tool shall Amendment No. 24=6 3.8-3
The roquiromoint for tho fuol storago building eharcoal filtraticn Gcyctomf to 168 OPrating......
cpent fuel movomont ic being madoe pr..ido addod a-urane that th. off.ito dc l...
within acooptablo limitsoin the event cf a fuol handling acoidont. The ad-ditimenal ime-n-th1 of-c-n fuol dooay tim* Wi.. P;d. tho a
ranoo that tho ffOt dptbl ait and thoRarofoero the o-h~a roAl flftrfation CA
'ctom wourtld no6Mt horgio to6 bOoporating.
The spent fuel storage pit water level requirement in Specification 3.8.C.2 provides approximately 24 feet of water above fuel assemblies stored in the spent fuel storage racks.
The fuel enrichment and burnup limits in Specification 3.8.D.1 and the boron requirements in Specification 3.8.D.2 assure the limits assumed in the spent fuel storage safety analysis will not be exceeded.
The requirement that at least one RHR pump and heat exchanger be in operation ensures that sufficient cooling capacity is available to maintain reactor coolant temperature below 1400F, and sufficient coolant circulation is maintained through the reactor core to minimize the effect of a boron dilution incident and prevent boron stratification.
The requirement to have two RHR pumps and heat exchangers operable when there is less than 23 feet of water above the vessel flange ensures that a single failure will not result in a complete loss of residual heat removal capability. With the head removed and at least 23 feet of water above the flange, a large heat sink is available for core cooling, thus allowing adequate time to initiate actions to cool the core in the event of a single failure.
References (1)
FSAR Section 9.5.2 AmnmetNo6Revised by letter dated Jun" 14, 2001 3.8-6 Amendment No. 244-1
- 4.
At least once every Refueling Interval(#) by:
- a.
verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 6 inches water gauge while operating the system at ambient conditions and at a flow rate of 2000 cfm +/-10%.
- b.
verifying that, on a Safety Injection Test Signal or a high radiation signal in the control room, the system automatically switches into a filtered intake mode of operation with flow through the HEPA filters and charcoal adsorber banks. 1
- c.
verifying that the system maintains the control room at positive pressure relative to the adjacent areas during the pressurization mode of operation at a makeup flow rate of 2000 cfm+/-1 0%.
- 5.
After each complete or partial replacement of an HEPA filter bank, by verifying that the HEPA filter banks remove greater than or equal to 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the system at ambient conditions and at a flow rate of 2000 cfm +/-10%.
- 6.
After each complete or partial replacement of a charcoal adsorber bank, by verifying that the charcoal adsorbers remove greater than or equal to 99.95%
of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the system at ambient conditions and at a flow rate of 2000 cfm +10%.
F.
,-OT,,^E DING AIR
,D,-r.ATO, SVSTEM DELETED Th fu-. ator-,
building air filtra t io systom sepifiod in Sp.. cifieation !.3 Q.h.
be At..o... o-o p, from hon onr room, flo-th....ro.h tho HEP!'. filtora nal nd harcoal adcorborc and oifigthat tho cyctomf Opor'!-
for at 1oact 15F minutc Amendment No. 2-1-9 4.5-4
4.5-5 Amendment No.
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- 4.
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- 2.
At 9AP-h Fat, wing, pF;eF te Faf weling epwations, oF (I oft-r cap x FOtmnanhe during sy6twýR
5=
Aftr och Pomloto or parial roplapomon@t oaHE).
bytc baniyin.
,gthat tho HEP.A. tultorbaF h nmovo FOEgroator than Or 00gual to W04 of tho-D)p w honto are tostod in placoinaoora w.ith ANSIQ NM4 Q0 1075 'hA oprtng the Systomn at ambiont condltioncopc andat n flowr rato of 20,000 atm +/-10%.
- 6. fto oah pmp-to or pairtial roplacomont of a hrolahrorbnk, byx
@a*.
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- i v
_-1
- i.
- a. eh.vee"
-~.*
- a.
1v, -ii 1
- oriyingthat tho hrooal adconrb-ra ramovog groator than or -nguai to 00.0504 of a halogenated hydrooarFbon rofrigorant test gac whon tho' rotcodi laai aooordlanoo with ANSIQ h510 10:75 whilo o~poiraktin tin-cycto= at ambin conditiona and at a flowu rat-of 20,00 of m +/-0%
G.
POST-ACCIDENT CONTAINMENT VENTING SYSTEM The post-accident containment venting system shall be demonstrated operable:
- 1.
At least once every Refueling lnterval(#), or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) at any time painting, fire or chemical releases could alter filter integrity by:
- a.
verifying no flow blockage by passing flow through the filter system.
- b.
verifying that the system satisfies the in-place testing acceptance criteria and uses the test procedures of Regulatory Positions C.5.a, C.5.c and C.5.d of Regulatory Guide 1.52, Revision 2, March 1978, at ambient conditions and at a flow rate of 200 cfm +/-10%.
- c.
at Refueling Intervals (#), verifying, within 31 days after removal, that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodide penetration of less than 15.0 % when tested in accordance with ASTM D3803-1 989 at a temperature of 30 OC [86 OF], a relative humidity of 95 %, and a face velocity of 0.203 rn/sec [40 ft/min].
- 2.
Within 31 days of completing 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal adsorber operation, verify that a laboratory test of a sample of the charcoal adsorber, when obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, shows a methyl iodide penetration of less than 15.0 % when tested in accordance with ASTM 03803-1989 at a temperature of 30 'C [86 OF], a relative humidity of 95 %, and a face velocity of 0.203 rn/sec [40 ft/min].
Amendment No. 2=
5 4.5-4.5-6
The hydrogen recombiner system is an engineered safety feature which would function following a loss-of-coolant accident to control the hydrogen evolved in the containment. The passive autocatalytic recombiners(PARs) contain no control or support equipment which would require surveillance. No specific degradation mechanism has yet been identified for the catalysts plates in standby service. Periodic visual examination and cleaning if necessary is done to prevent significant gas blockage by dust or debris. Representative plates are periodically removed and their response to an approximately 1.5% hydrogen gas mixture is evaluated for evidence of unexpected degradation.
The biannual testing of the containment atmosphere sampling system will demonstrate the availability of this system.
The recirculation fluid pH control system is a passive safeguard with the baskets of trisodium phosphate located in the containment sump area. Periodic visual inspections are required (Refueling#) to verify the storage baskets are in place, have maintained their integrity, and filled with trisodium phosphate.
The control room air filtration system is designed to filter the control room atmosphere for intake air during control room isolation conditions. The control room air filtration system is designed to automatically start upon control room isolation. High-efficiency particulate absolute (HEPA) filters are installed upstream of the charcoal adsorbers to prevent clogging of these adsorbers. The charcoal adsorbers are installed to reduce the potential intake of radioiodine by control room personnel. The required in-place testing and the laboratory charcoal sample testing of the HEPA filters and charcoal adsorbers will provide assurance that Criterion 19 of the General Design Criteria for Nuclear Power Plants, Appendix A to 10 CFR Part 50 continues to be met.
Th19 fuol tora@g building air fitration cyctom ic doigno@Ad to filtor tho-dicc-6hargo Of tho W-1l stcrage building attmcsphora to tho plant... t.
HERuA^ filters and c o
ad.orb4rc aro installed-to roduco-potontial roloacoc of radlionativo mfaterial to the at-mosphors. Ac roguired by Speoific-atienA 3..B.-B6, tho fuel storage building -Air filtration Systom mAust6 beo rtn whenever.. spont fuol is boing moew*d unMoss the spot Q
fuel has had a continuous 35 da docay pe.-.-;
Tho roquirod in plaea tet.ing adt laboratory charcoal samplo testing of 10 CFR 50.67 cont inuetobol m..
o....
Amendment No. 244 4.5-9 R
,evised by loftor datod Juno 11, 201*
Thus, the allowable methyl iodide penetration, by system, is as follows:
UFSAR Reference Allowable Methyl Iodide Penetration 4.5.E Control Room Air Filtration System
&P Fuel Storage Buil'ding Air Filtr~ation Sytm 4.5.G Post-Accident Containment Venting System 90%
70%
Sec. 14.3.6.5 Sec. 14.3.6.1.3 W W I-;
- I.4;-1
/
÷,-,,
Table 1.2 2 just pr.vid.a.b i
etha effieioney. Sines ths methyl add ffieionoy iclwrth@n tho 5.0%
15.0%
T.i...i......
ro motnyl......
- ed^id; and clo n-l-l ;1 zomb.nzd,,.d, d c,4, ffi.c.i;o; U UCO UT IflO UUfI1CIrU
- :..............,
,.
References (1) UFSAR Section 6.2 (2) UFSAR Section 6.4 (3) NRC Generic Letter 99-02, dated June 3, 1999 (4) UFS.^.R Tiblo 11.2 2 UFSAR 14.2.1.1 (5) UFSAR Section 14.3.6.1.3 (6) UFSAR Section 14.3.6.5
- 1.
In this instance Refueling Interval is defined by R##.
A ed et o
,4,-,,-,.oIc b, lo-Ho, datod Jn 1,
200 1
- t TS Sec.
System Name Filter Efficiency Amendment No. 24=45
- th*
4.5-11
ATTACHMENT 3 TO NL 02-003 Commitments ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT UNIT NO. 2 DOCKET NO. 50-247 NL 02-003 Page 1 of 1 Commitments No.
Commitment Description Implementation Schedule 1
ENO will allow the FSB ventilation boundary to be Prior to allowing the open while irradiated fuel movement is in ventilation boundary to be progress provided administrative controls are in open during such fuel place to quickly close the openings in the event of movement a FHA.
- 2.
ENO will relocate the FSB air filtration system Within the implementation operating requirements of TS 3.8 to UFSAR period of the approved section 9.10.
License Amendment
- 3.
ENO will relocate the FSB air filtration system Within the implementation testing requirements of TS 4.5.F to UFSAR period of the approved section 9.10.
License Amendment