NL-02-042, License Amendment Request (LAR-02-007),, Changes to Effectively Coordinate Indian Point Units 1 & 2 Programs

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License Amendment Request (LAR-02-007),, Changes to Effectively Coordinate Indian Point Units 1 & 2 Programs
ML021540253
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 05/30/2002
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, NRC/FSME
References
LAR-02-007, NL-02-042
Download: ML021540253 (39)
v • d • e


Text

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

Indian Point Energy Center I I'!

IJ 295 Broadway, Suite 1 P0. Box 249 Buchanan, NY 10511-0249 May 30, 2002 Re:

Indian Point Unit No. 1 Docket No. 50-3 NL-02-042 U. S. Nuclear Regulatory Commission ATTN: Document Control. Desk Mail Stop O-P1 -17 Washington, D.C. 20555-0001

SUBJECT:

License Amendment Request (LAR-02-007) - Changes to Effectively Coordinate Indian Point Units 1 and 2 Programs

References:

1. NRC Letter to Consolidated Edison, "Order to Authorize Decommissioning and Amendment No. 45 to License No. DPR-5 for Indian Point Unit No. 1 (TAC No. M59664)," dated January 31, 1996
2. Entergy Nuclear Operations, Inc. letter to the NRC, NL-02-016, "License Amendment Request (LAR 02-005) Conversion to Improved Standard Technical Specifications," dated March 27, 2002 Pursuant to 1 OCFR50.90, Entergy Nuclear Operations, Inc. (ENO) hereby requests the following amendment to the Indian Point Nuclear Generating Unit No. 1 (IP1)

Amended Provisional Operating License No. DPR-5. This request proposes changes to various sections of the IP1 Technical Specifications (TS). IP1 is completely enclosed within the protected area for Indian Point Nuclear Generating Unit No. 2 (IP2). IP1 depends on the IP2 TS and processes for the implementation of certain regulatory requirements.

The requested changes will simplify the IP1 TS to facilitate the IP2 transition to the Improved Technical Specifications (ITS). The details of the proposed changes are provided in the attachments to this letter. ENO also proposes that the IP1 TS be reformatted, reordered and repaginated for consistency and clarity. Attachment 1 to this letter provides the description and evaluation of the proposed changes for the IP1 TS.

The revised TS pages for IP1 are provided in Attachment 2 (strikeout/shaded format).

ENO also requests that certain changes presented herein supersede requirements of the "Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility" (Ref. 1) (the Order) to ensure compliance with the current requirements of 1 OCFR50.59, "Changes, Tests, and Experiments," and 50.82, 'Termination of License,"

for evaluating whether changes can be made to IP1 without prior NRC approval. provides the details of the proposed changes and an evaluation showing compliance with the intent of the Order and with current regulations.

I \\ O

NL-02-042 Page 2 of 3 ENO also requests that the expiration date of Provisional Operating License No. DPR-5 for IP1 be changed to the current expiration date for the Facility Operating License No.

DPR-26 for IP2. This is to make the license expiration date consistent with the intent of the Order (Ref. 1). Attachment 4 provides the details of the proposed changes and an evaluation showing compliance with the intent and the staff's safety evaluation of the Order.

The onsite safety review committee and the offsite safety review committee have reviewed the proposed changes and concurred that the proposed changes involve no significant hazards consideration as defined by 10CFR50.92(c).

ENO requests a timely review of this application and that the approval of the proposed IP1 changes be issued prior to or coordinated with the approval of the IP2 License Amendment Request (Ref. 2) for conversion to the ITS. An implementation date of within 60 days of approval is requested.

In accordance with 1 OCFR50.91, a copy of this submittal and the associated attachments are being submitted to the designated New York State official.

There are no commitments contained in this submittal. Should you or your staff have any questions regarding this submittal, please contact Mr. John F. McCann, Manager, Nuclear Safety and Licensing at (914) 734-5074.

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

Sincerely, Executed on N1""-

Fred Dacimo Vice President - Operations Indian Point Unit 2 cc:

See page 3 Attachments

NL-02-042 Page 3 of 3 cc:

Hubert J. Miller Regional Administrator US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. John L. Minns, Project Manager, Section 1 Project Directorate IV Division of Licensing Program Management US Nuclear Regulatory Commission Mail Stop 10-D-4 Washington, DC 20555 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 Flynn NYS ERDA Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12223-6399

ATTACHMENT 1 TO NL-02-042 LICENSE AMENDMENT REQUEST FOR INDIAN POINT NUCLEAR GENERATING UNIT NO. 1 ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 1 DOCKET NO. 50-3

NL-02-042 Page 1 of 8 LICENSE AMENDMENT REQUEST DESCRIPTION OF THE PROPOSED CHANGE Entergy Nuclear Operations, Inc. (ENO) is requesting a change to the IP1 TS to simplify the IP1 TS and facilitate the Indian Point Nuclear Generating Unit No. 2 (IP2) transition to the ITS.

The IP1 TS that are affected by the proposed change are Sections:

1.0, General Information 1.1, Definitions 0 1.2, Exclusion Distance and Restricted Area

& 2.11, Fire Protection 3.1, Responsibility a 3.2, Organization 3.3, Operating Instructions and Procedures 4.1, Operating Limitations-General

  • 5.2, Testing 0 5.4, Sealed Sources a 6.1, Routine Reports and Reportable Occurrences 6.2, Special Reports 6.3, Reportable Event Action 6.4, (untitled)

Other editorial changes are proposed. ENO also requests that the IP1 TS be reformatted, reordered, and repaginated for clarity and consistency.

EVALUATION OF THE PROPOSED TS CHANGES The changes to each TS section are individually evaluated as follows:

Changes to Section 1.0, General Information Description of Change

1. Delete reference to the site size. The Indian Point Energy Center (IPEC) site that is occupied by IP1, IP2, and IP3 is accurately described in IP2 TS Section 5.1, "Design Features - Site."
2. Past tense is used to describe the IP1 reactor.
3. Clarify that the Decommissioning Plan was approved by the Commission's "Order Approving Decommissioning Plan And Authorizing Decommissioning Of Facility," dated January 31, 1996.
4. Delete definitions 1.1.2, 1.1.4, and 1.1.6.

N L-02-042 Page 2 of 8 Evaluation of Change The changes do not affect ENO's method of complying with any regulation. They ensure that the general information presented is accurate and not duplicative of information presented in the IP2 TS. Since the sections containing the deleted definitions are being deleted, the definitions are no longer needed.

Changes to Section 2.11, Fire Protection Description of Change The paragraph stating that the Fire Protection and Detection system provided for protection of IP2 safe shutdown systems are addressed in the IP2 TS is deleted.

Evaluation of Change The statement is inaccurate since the IP2 TS requirements to protect IP2 safe shutdown systems from fire have been relocated to License Condition 2.K by IP2 License Amendment No. 186. The statement is unnecessary since the regulatory requirements for the protection of IP2 safe shutdown systems from fire are completely governed by the IP2 License Condition 2.K.

Changes to Sections 3.1, Responsibility, 3.2, Organization, and 3.3 Operating Instructions and Procedures Description of Change Responsibility and Organization requirements that are duplicated in both the IP1 and IP2 TS are deleted from the IP1 TS.

Evaluation of Change As described in Section 1 of the IP1 TS:

"Unit No. 1 and Unit No. 2 are physically contiguous and share a number of systems and facilities as well as a common operating organization. The technical specifications contained herein recognize this commonality as well as the intended use of the Unit No. 1 facilities to support Unit No. 2 until retirement of that unit, and contain specific references to Appendix A to the Indian Point Unit No. 2 Facility Operating License No. DPR-26."

The changes will simplify the administration of the Indian Point site for both ENO and the NRC. Future changes to the organization and to the assignment of responsibilities will require only a single License Amendment.

The effectiveness of the ENO organization to ensure compliance with both the IP1 and the IP2 licenses is not affected. The clarifications that remain clearly establish the responsibility of the IP2 licensed Operations Department personnel for the operation of IP1.

NL-02-042 Page 3 of 8 Changes to Sections 4.1.2, 4.1.3, 4.1.4, Operating Limitations - General, and 5.2.6, Testing, for deletion of specific section numbers in the references to the 1P2 TS Description of Change References to specific section numbers in the IP2 TS are deleted.

Evaluation of Change Removing the specific IP2 TS section numbers from the IP1 TS does not change the requirement to comply with the applicable IP2 TS sections. In the future, the IP2 TS may be changed without the need to also process a companion amendment to the IP1 License. The identification of the specific IP2 section that is applicable to the IP1 activity is obvious from the activity.

Changes to Sections 4.1.4, Operating Limitations - General, and 5.2.5, Testing, for the deletion of requirements for a radiation monitor for the Nuclear Services Building Sewage Effluent Line Description of Change The requirements for the radiation monitoring system for the nuclear services building sewage effluent line are deleted.

Evaluation of the Change The Nuclear Services Building (NSB) sewage effluent line radiation monitoring system was required to ensure that radioactive releases through the line were within the 1 OCFR20 limits. The toilet facilities for which monitoring was specified were originally located within the Radiologically Controlled Area (RCA) of the Nuclear Service Building (NSB) at elevation 53', elevation 72', and elevation 84'. Two toilets, one located at elevation 84' and one located at elevation 72', were removed from the NSB in the mid 1980's. The toilet facilities at the 53' elevation of the NSB were originally located within the RCA, however the RCA boundary has been relocated and the toilet facilities are now located outside the RCA. Therefore, there is no sewage from the NSB that originates within the RCA and monitoring of this path can be removed from the IP1 TS.

ENO therefore concludes that there will be no change in the effectiveness of the controls at the IPEC site to comply with the liquid radioactive effluent requirements of 10CFR20.

NL-02-042 Page 4 of 8 Changes to Section 4.1.5 and 4.1.6, Operating Limitations - General, and 5.4, Sealed Sources Description of Change The requirements for the IPEC Units 1 and 2 site Meteorological Monitoring, Radiological Environmental Monitoring and Sealed source programs are deleted from the IP1 TS.

Evaluation of Change These programs are common IPEC Units 1 and 2 site programs whose activities cannot be identified by a Unit. The requirements of these programs are currently stated in the IP2 TS. However, neither of these programs meets any of the requirements of 10CFR50.36. Thus, neither program is included in NUREG-1431.

Therefore, with the implementation of the ITS at IP2, the requirements for these programs will reside in licensee controlled documents. Eliminating the need to process duplicate License Amendments should these programs be changed conserves both NRC and ENO's resources while ensuring the appropriate level of regulatory control, i.e., the 10CFR50.59 process.

Changes to Sections 4.1.7, Operating Limitations - General Description of Change The requirements for a radiation protection plan are eliminated from the TS.

Evaluation of Change There is a single, common radiation protection program for IPEC Units 1 and 2. The requirements for ENO compliance with 10CFR20 are included in IP1 license paragraph 3 and IP2 license condition 2.C.

Changes to Sections 6.1, Routine Reports and Reportable Occurrences, 6.2, Special Reports, and 6.3, Reportable Event Action Description of Change Reporting requirements are incorporated into the IP1 TS by reference to the corresponding IP2 TS.

Evaluation of Change The requirements of the deleted sections are duplicative of IP2 TS requirements, so the IP2 requirements are incorporated by reference. Deleting these requirements does not affect the responsibility of ENO to make the reports, but it will simplify the administration of the ENO's licenses.

Since definitions 1.1.2, 1.1.4, and 1.1.6 are only used in the IP1 TS in the deleted sections, they are also deleted.

NL-02-042 Page 5 of 8 Changes to Sections 6.4, Applicability of FSAR Description of Change This change adds clarification that pages 171 through 176 are part of Section 3.7.1.

The section is relocated to "Definitions" and references to documents are clarified.

Evaluation of Change The information in the IP1 FSAR is largely historical. The only remaining safety functions relate to the maintenance of the spent fuel. The intent of this TS paragraph was to identify the sections of the IP1 FSAR that are applicable to its current license conditions. The change is a clarification since section 3.7.2 does not include pages 171 through 176. Section 3.7.2 describes the Spent Fuel Cooling system. Pages 171 through 176 are the part of Section 3.7.1 that describes the Fuel Handling Building Crane and Facilities. Both are applicable. The relocation and correct identification of references is editorial.

None of the proposed TS changes foreclose release of the site for possible unrestricted use; result in significant environmental impacts not previously reviewed; or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. None of the changes involve a major dismantlement activity or affect the approved Decommissioning Plan.

NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes described above involve no significant hazards consideration.

This conclusion is based on the evaluation, in accordance with 10 CFR 50.91 (a)(1), of the three standards set forth in 10 CFR 50.92(c).

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

The NSB sewage effluent line radiation monitor is not required to function to mitigate any postulated accident. The design or operation of the radiation monitor on the existing sewage effluent discharge line will not be changed by deleting operability and surveillance requirements for the NSB sewage effluent radiation monitor from the IP1 TS. The nuclear services building sewage effluent line is neither an accident initiator nor mitigator.

The other proposed changes do not result in a change to the design or operation of any plant structure, system or component. Therefore any assumptions of the operability or performance of any structure, system or component in accident evaluations are unchanged.

NL-02-042 Page 6 of 8 The proposed fire protection TS 2.11 involves deleting requirements from the IP1 TS that are solely applicable to IP2. Any assumptions of the operability or performance of any structure, system or component in IP2 accident evaluations, including the Fire Plan, are unchanged. Therefore, there is 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 proposed TS change involves the deletion of operability and surveillance requirements for radioactive effluent monitoring of the NSB sewage effluent from the IP1 TS. The proposed TS changes do not affect the design or operation of any plant structure, system, or component.

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?

This change to TS 1.0 does not affect a design function for or the operation of any plant structure, system, or component. The change does not affect the method of ENO's compliance with any regulation.

The proposed TS change involving IP1 TS 2.11 statement governs the protection of IP2 safe shutdown systems from fire. Effective protection of IP2 safe shutdown systems from fire is mandated by IP2 License Condition 2.K. The effectiveness of ENO compliance with IP2 License Condition 2.K is not affected by this change. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

The proposed changes to TS sections 3.1 and 3.2 involve eliminating the duplication of requirements in the IP1 TS and incorporating the requirements by reference to the IP2 TS. A single ENO organization operates both IP1 and IP2. The effective organizational requirements to ensure compliance with all ENO IP1 and IP2 site requirements are mandated by the IP2 TS. The effectiveness of ENO's safety management of the Indian Point site is not affected by this change. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

The proposed TS change to sections 4.1 and 5.2 involves eliminating the reference in the IP1 TS to the specific applicable section number of the IP2 TS. A single organization operates both IP1 and IP2. The applicable IP2 TS is obvious by the activity title. The effectiveness of ENO's safety management of the Indian Point site is not affected by this change. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

N L-02-042 Page 7 of 8 Effective compliance with the 10CFR20 requirements for radiation protection and monitoring radioactive effluent releases is mandated by other IP1 and IP2 TS and license provisions. The effectiveness of ENO compliance with 10CFR20 requirements is not adversely affected by the elimination of TS requirements for the radiation protection plan and radioactive effluent monitoring on the nuclear services building sewage effluent line.

The proposed TS change involves requirements for the site Meteorological Monitoring and Radiological Environmental Monitoring programs. However, IP2 TS provisions mandate effective compliance for meteorological and radiological environmental monitoring. The effectiveness of ENO compliance with 1 0CFR50.47, 1 OCFR1 00, and 1 OCFR20 requirements is not adversely affected by this change. In addition, this change does not affect a design function or the operation of any plant structure, system, or component. IP2 TS provisions mandate effective compliance with requirements for radiation protection. The effectiveness of ENO's compliance with 1 OCFR20 is not adversely affected by this change or the change to the section for sealed sources. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

The proposed TS change involves the location of routine and event reporting requirements. However, other IP2 TS provisions mandate effective compliance with reporting requirements. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

The effectiveness of ENO's compliance with 1 OCFR50.59 is not adversely affected by the clarification and relocation of the applicability of the FSAR. In addition, this change does not affect a design function or the operation of any plant structure, system, or component.

Therefore, the change does not result in a change to any of the safety analyses or any margin of safety.

CONCLUSION In all cases, the proposed changes to the TS do not involve physical changes to the plant, changes to the operation of plant systems, or changes to the plant safety analyses. Accordingly, these proposed requirements involve no significant hazards consideration. The onsite safety review committee and the offsite safety review committee have reviewed the proposed changes. Both committees concur that the proposed changes involve no significant hazards consideration as defined by 1 OCFR50.92(c).

NL-02-042 Page 8 of 8 ENVIRONMENTAL ASSESSMENT An environmental assessment is not required for the proposed changes because the requested changes to the IP1 TS conform to the criteria for "actions eligible for categorical exclusion," as specified in 10CFR51.22(c)(9). The requested changes will have no impact on the environment. The proposed changes involve no 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.

ATTACHMENT 2 TO NL-02-042 IP1 LICENSE AMENDMENT REQUEST TECHNICAL SPECIFICATION PAGES IN STRIKEOUT/SHADED FORMAT Deleted text is shown as strokeout.

Added text is shown as shaded.

ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 1 DOCKET NO. 50-3

Section 1.0 1.1 1.2 1.3 Amendment No. -54 TECHNICAL SPECIFICATIONS TABLE OF CONTENTS Title General Information Definitions Exclusion Distance and Restricted Area Principal Activities Reactor Facility Design Performance Requirements Electrical Power Supply 2.10.2 Fuel Storage Fire Protection Administrative and Procedural Safeguards Responsibility Organization Operating Instructions and Procedures Operating Limitations General 4...

Radiation Protcction Program Release of Radioactive Liquids and Gases 4.-.8 D.E.ETED Radioactive Waste 4.4.9 Spcnt Fuel Steragc and Ha.dlingRadloactive Monitoring Systems Radiological Environmental Monitoring Spent Fuel Storage and Handling Maintenance General Testing Spent Fuel Storage Pool Sampling Sealed Sources Plant Reporting Requirements Routine Roeplts and Reportable Occurrcnces Spial Reports Reportable Evcnt Action 2.0 2.51 2.2 2.-t4 3

3.0 3.1 3.2 3.3 4.0 4.1 4.2 4.3 4.4 4.5 4.6 5.0 Page 4

2 13 3

4 4

4 5

6 7

8 8

9 9

9 4-0 4-0 44 14 14 1-2 4-2 4-5 4-5 5.1 5.2 5.3 6.4 6-2 673 6.0

Appendix A to Provisional Operating License DPR-5 For the Entergy Nuclear Indian Point 2, LLC and Entergy Nuclear Operations, Inc.

1.0 GENERAL INFORMATION The facility, known as the Indian Point Station Unit No. 1, is located on a the-235 ae site in the Village of Buchanan, Westchester County, New York. The Indian Point Station Unit No. 2 and the Indian Point Station Unit No. 3 share this site.

Indian Point Unit No. 1 includes a pressurized water reactor, which operated with an authorized maximum steady state power level of 615 thermal megawatts until October 31, 1974. Pursuant to thea June 19, 1980 "Commission Order Revoking Authority to Operate Facility" and thea "Decommissioning Plan for Indian Point Unit No. 1" submitted by Con Edison to NRC en October 17,1980 in accordancc with that OFdc, approved by the NRC in an Order dated January 31, 1996, the reactor remains in a defueled status and the unit continues to operate as a support facility for overall Indian Point Units 1 and 2-site operations. Unit No. 1 and Unit No. 2 are physically contiguous and share a number of systems and facilities as well as a common operating organization. The technical specifications contained herein recognize this commonality as well as the intended use of the Unit No. 1 facilities to support I Unit No. 2 until retirement of that unit, and contain specific references to Appendix A to the Indian Point Station Unit No. 2 Facility Operating License No. DPR-26. Unit No. 1 contains radioactive waste processing facilities, which provide waste processing services for both Unit No. 1 and Unit No. 2. Radiological effluent limits are met on an overall site basis and specific operating limits and surveillance requirements for effluent monitoring instrumentation, including stack noble gas monitoring, are discussed in Appendix A to the Indian Point Unit No. 2 Fa"ility Operating Lioenec No. DPR 26 the Offsite Dose Calculation Manual.

Amendment No. 50 Page 1

1.1 Definitions 1.1.1 Final Safety Analysis Report The Final Safety Analysis Report (FSAR) for Indian Point Unit No. 1, shall be deemed to refer to, as appropriate, the "Final Hazards Summary Report for the Consolidated Edison Indian Point Reactor Core B" and the following exhibits, which are a part of the original license application for IPI:

"* Docket 50-3 Exhibit K-5 (Rev. 1), "Hazards Summary Report Consolidated Edison Thorium Reactor." (January, 1960) Figures 1-2, 1-3, 3-14 only.

"* Docket 50-3 Exhibit K-5A1 1, "Supplementary Information on Plant Design of Consolidated Edison Nuclear Steam Generating Station," (August 1960)

Section 3.7.1, pages 171 through 176 only and Section 3.7.2.

1.1.2 Operable-Operability A system, subsystem, train, component or device shall be operable or have operability when it is capable of performing its intended safety function(s).

Implicit in this definition shall be the assumption that necessary instrumentation, controls, electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its safety function(s) are also capable of performing their related support functions.

1.1.2 Member(s) of the PublicO Member(s) of the Public includes all pcrsons whe are not moupatieonaly associated with the site. This category does ndotes due employees of cither Entcrgy Nuclear Indian Point 2, LLC (EN 1P2), Entcrgy Nuclear OperationS, Inc.

(ENO), or other site licensec, their contractors or vendors. Also excluded from this category arc persons who enter the site to serviec cquiVpmcnt or to make 1.1.3 Offsite Dose Calculation Manual (ODCM)

The Offsite Dose Calculation Manual contains the current methodology and parameters used in the calculation of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm/trip setpoints, and in the conduct of the environmental radiological monitoring program. Requirements for the ODCM are specified in Appendix A to the Indian Point Nuclear Generating Unit No. 2 Facility Operating License No.

DPR-26.

Amendment No.

PPage 2 1 A DMr..,-

fl--..,-.--

fflflfl The Process Control Program is a manual containing and/or referencing adocted operational information concorning the solidification of radioactive wastes from liquid syetem&s 1.1.54 Site Boundary The Site Boundary is that line beyond which the land is neither owned, leased, nor otherwise controlled by either ENIP2, ENO, or other site licensee.

Amendment No. -50

-- Cr......

i Page 2

1.1.6 Solidificationp S*olidification is the c-n,.-in of wet wastes Into a form that mects shipping aRd burial ground requirements.

1.1 75 Unrestricted Area An Unrestricted Area is any area at or beyond the Site Boundary, access to which is not controlled by either ENIP2, ENO, or other site licensee for purposes of protection of individuals from exposure to radiation and radioactive materials.

1.2 Exclusion Distance and Restricted Area 1.2.1 The minimum distance from the reactor facility to the nearest land boundary of the exclusion area, as defined in P-aR10CFR1 00 of the Commission's r.*.tiop.., shall be 1400 feet.

1.2.2 The minimum distance from the reactor center line to the boundary of the site exclusion area and the outer boundary of the low population zone as defined in 1 0CFR1 00.3 is 460 meters and 1100 meters, respectively. For the purpose ef satisfying 10 CFR pat 20, the Rstr;icted Area is the same as the Exclusion AFr-a defincd in Figure 2.2 2 of Section 2.2 of the IP#2 FSAR.

1.3 Principal Activities 1.3.1 The principal activities carried on within the Exclusion Area shall be the generation, transmission and distribution of steam and electrical energy (except by gas-fired power plant); associated service activities; activities relating to the controlled conversion of the atomic energy of fuel to heat energy by the process of nuclear fission; and the storage, utilization and production of special nuclear, source and byproduct materials. Transmission and distribution of natural gas shall be through the use of facilities located as described in the application as amended.

Amendment No.

P50 Page 3

2.0 REACTOR FACILITY DESIGN PERFORMANCE REQUIREMENTS 2.51 Electrical Power Supply 2.5.1 Mailr Sup.pnes 2.5.-.1 Power for electrical equipment shall normally be supplied by at least two independent transmission feeders from the Consolidated Edison system. If power is lost to the spent fuel storage area radiation monitor, a portable monitor will be promptly set up in the spent fuel storage area.

2.4-0.2 Fuel Storage 2.4-0.2.1 No fuel other than irradiated fuel from Indian Point Unit No. 1 shall be stored in the Unit No. 1 spent fuel storage area. No fresh fuel shall be stored at Unit No. 1.

2.4-0.2.2 Spent fuel storage shall be provided in the storage pools in the Fuel Handling Building. The Fuel Handling Building and the spent fuel storage pool will contain the spent fuel until such time as offsite spent fuel management facilities are provided for, and the spent fuel is transferred to the Department of Energy, or as authorized by 10 CFR Part 72.

2.41-0.2.3 Spent fuel storage shall be provided with racks that shall limit the effective multiplication factor to less than 0.75.

2.4-0-.2.4 Radiation levels in the spent fuel storage area shall be monitored continuously with a high level alarm indication in a location manned by a licensed operator

  • whenever there is irradiated fuel stored therein. If the monitor is inoperable, a portable monitor may be used. In such cases, provisions shall be made for prompt notification of a licensed operator upon actuation of the portable monitor's high level alarm.

Amendment No, 4-5 Page 4

2.4-&.2.5 If a spent fuel pool contains spent fuel, the spent fuel cask shall not be moved over that pool or within a distance of that pool such that the cask could strike the pool if it fell or tipped.

2.4-0-.2.6 A dead-load test shall be successfully performed on the fuel handling building crane before fuel movement begins. The load assumed by the crane for this test must be equal to or greater than the maximum load to be assumed by the crane during the fuel handling operation. A thorough visual inspection of the crane shall be made after the dead load test and prior to fuel handling.

  • Licensed Operator for IP-2 2.44-3 Fire Protection Overall site fire protection is provided by a fire protection system, which is common to both Unit No. 1 and Unit No. 2. Operation, maintenance and testing are controlled by statien common procedures.

Fire pretcction and detection systems provided for prote~tion Of Indian Point Encrgy Ccntcr Unit No. 2 safe shutdown systems arc addressed in Appondix A to thc Indian Poin Energy Center Urnit No. 2 Facility Operating Liccnse No. DPR 26.

3.0 ADMINISTRATIVE AND PROCEDURAL SAFEGUARDS 3.1 Responsibility 3.1.1 The Vice President Nuclear Power shall be rcsponsible for ovcrall facility activitics and shall delegate in writing the SUccession to this rcSp.nsibility during his abscncc.

Responsibilities are as specified in Appendix A to the Indian Point Nuclear Generating Unit No. 2 Facility Operating License No. DPR-26.

3.1..2 The Plant Manager shall bc responsible for facility operations and shall delegate in writing the SUGession to this responsibility during his abscncc.

Amendment No. 45 48 Page 5

3.2 Organization 3.2.1 Onsite and offsitc organizations shall be established for unit operation and corporate management, respectively. The onsite and offeite organization shall incl~ude the positions for activitie affe tiing the safety of the nuclear power plant.

The organization requirements are as specified in Appendix A to the Indian Point Nuclear Generating Unit No. 2 Facility Operating License No. DPR-26.

Lines of authority, responsibility, and eoFFMmuniaeato snail be established and dcfined for the highest mnanagemnent levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts, funetional descriptions of departmental responsibilities and relationships, and job descrfiptions for key personnel positions, or in equivalent forms of docGumenitation. These requirements shall be documented in the Quality Assurance Program Description

{QAPD).

b.

Thc Plant Manager shall be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.

c.

The Vice President Nuclear Power shall have corporate responsibility for overall plant nuclear safety and shall take any measures needed to) ensure aeceptablc performance of the staff in operating, maintaining, and providing tecehnical support to the plant to ensure nuclear safety.

a.

i~ rindrividuuals HE) train trhe operating staff and those who carry. ou e

[RI-[ItrH It':;I[:t; -1IrlI LLJ..It'. ";1'i ;

r-;Jr:R-II[ t. IUIRGLIU 1may4V r[port tle td appropriate onsite manalger, V organizational freedom to ens pressures.

eowcver, ujre their they shall have su.fficient inRdependence from operating Amendment No. 4-5, 48, 49 Page 6 a.

SII i I

II I

I I

l=I

f.

The review and audit functionS of the Station Nuclear Safety Committee (SNSC) and the Nuclear Facilities Safety Committee (NFSC) are desri'bed in the Quality Assurance Program Description (QAP\\D)-.

@a.

All fuel handling shall be under the direct supervision of a licensed operator.*

hb.

The Shift Manager is responsible for operations at the Unit No. 1 facility.

i. The qualification requirements of the Operations Manager and the Assistant Operations Manager are provided in Sections 6.2.2 and 6.3 of Appendix A to the Indian Point Unit No. 2 Facility Operating License NO. DPR 26,
  • Licensed operator for IP-2 3.3 Operating Instructions and Procedures 3.3.1 No fuel will be loaded into the reactor core or moved into the reactor containment building without prior review and authorization by the Nuclear Regulatory Commission.

3.3.2 Detailed written instruction setting forth procedures used in connection with the operation and maintenance of the nuclear power plant shall conform to the Te-hnical Specifications requirements specified in Appendix A to the Indian Point Nuclear Generating Unit No. 2 Facility Operating License No. DPR-26.

3.3.3 Operation and maintenance of equipment related to safety when there is no fuel in the reactor shall be in accordance with written instructions.

Amendment No. 46, 48, 49 Page 7

4.0 OPERATING LIMITATIONS 4.1 General 4.41-.Whenever any operation is being performed that could result in the release of radioactivity or create a change in radiation levels, supporting facilities shall be maintained and operated as required in these Technical Specifications.

4.4-2 Release of Radioactive Liquids and Gases The concentration of radioactive materials released in liquid or gaseous form to unrestricted areas shall not exceed the limits specified in 10 CFR Part 20.

Release of radioactive liquids and gases shall also be consistent with the requirements of 10 CFR Part 50, Appendix I, as specified in Specifications 3.9 and 4.10 of Appendix A to the I*ndan Point Unit No. 2 Facility Operating Liccnse No. DPR 26 the ODCM.

4.4-.3 Radioactive Waste All radioactive waste material shall be handled in accordance with 10 CFR Part 20. In addition, solid radioactive waste shall be controlled as specified in the Process Control Program. Specifications 3.9.D and 4.1 0.D of Appcndix A to the Indian Point Station Unit No. 2 FacEility OperatinRg LiGe*se N. DPR 26-.

4.-4 Radiation Monitorincq Radiation monitoring systems shall be maintained operable for: (1) nuclear services building sewagc, (2) sphere foundation sump, (32) secondary purification blowdown cooling water, and (43) area radiation monitors. If monitoring systems are not operable, effluent sampling and/or local monitoring shall be accomplished to replace the non-operating system. In addition, Unit 1 radioactive effluent monitoring instrumentation shall be operable as specified in Specification 3.9 of Appendix A to Indian Point Unit No.

2 Facility Operating License No. DPR-D 26 the ODCM.

4.1.5 The Indian Point site meteorological monitoring systern shall be maintained and operated as specified in Specifications 3.15 and 4.19 of Appendix A to the Indian Pon Unit No). 2 Facility Operating License No. DPR 26.

4.1-.65 Radiological Environmental Monitoring The Indian Point site Radiological Environmental Monitoring Program shall be conducted as specified in Specificati* n 4.11 of Appendix A to the Indian Point Unit No. 2 Facility Operating License No. DPR 26 the ODCM.

Amendment No. 4-5 Page 8

4.1.7 Radiation Protection Prociram Procedures for personnel radiation protection shall be prepared consistent with thc requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations inVOlVing personnel radiation exposure.

4.1.8 DELETED 4.-.-96 Spent Fuel Storage and Handling 4.4-.96.1 All irradiated fuel shall be stored in the racks provided in the Fuel Handling Building Storage pools, with sufficient shielding that ensures that the radiation level on the operating deck is < 1 5 mr/hr. Should the radiation level be found to be above 15 mr/hr, corrective action shall be initiated to restore the level to < 15 mr/hr.

Amendment No.

4-P Page 9

4.-1.:96.2 Whenever, spent fuel storage pool water inventory is provided for personnel shielding, the normal water level shall be maintained at or above elevation 48 feet (approximately 6 feet above the top of the spent fuel racks). Any pool in which spent fuel is stored shall be subject to weekly verification of water level.

Should the water level be found to be below elevation 48 foot, both pool level and radiation level on the operating deck shall be verified daily. Should the water level be found to be below elevation 47 foot, corrective action shall be initiated to investigate the reason for the reduced level and restore the level to

> 48 foot.

4.-1-_96.3Water chemistry in any spent fuel storage pool containing spent fuel shall be maintained within the following limits:

Chlorides:

_< 1.5 ppm pH:

4.0 - 8.0 Conductivity

< 20 ps/cm Should any of the above parameters be found to deviate from the specified limits an effort shall be promptly initiated to investigate the cause of the deviation and a process to restore the parameter to within the applicable limit shall be established in a timely fashion.

4.1-196.4Ventilation capable of directing all Fuel Handling Building airborne effluents through monitoring pathways shall be available during any fuel movement or other activity that might potentially damage spent fuel assemblies.

5.0 MAINTENANCE 5.1 General 5.1.2 Components addressed in these technical specification requirements, which have been repaired, replaced, or otherwise subjected to temporary or permanent modification, shall be tested in accordance with procedures, Amendment No, 45 Page 1 0

which are appropriate in view of the nature of the repair, replacement, or modification, and the condition of the system.

5.2 Testing 5.2.151 Functional radiation monitoring systems (only for the following: nu'lcar serviccs building sewage, sphere foundation sump-and secondary purification blowdown cooling water) and area radiation monitoring systems shall be:

(a) qualitatively checked daily to verify acceptable operability of instrument channel behavior during operation, and (b) tested quarterly by injection of a simulated signal into the instrument channel to verify that it is operable, including alarm and/or trip initiating action. The quarterly interval is defined as quarterly plus or minus 25% of the quarter.

5.2.62 Unit 1 radioactive effluent monitoring instrumentation shall satisfy the surveillance requirements as specified in Specifioati*n 4.10 of Appendix A to th, Indian Point Unit No. 2 Facility Operating Liccnse No. DPR 26 the ODCM.

5.3 Spent Fuel Storage Pool Sampling Any spent fuel storage pool containing spent fuel stored in water shall be sampled monthly for chloride level, pH and Cesium 137 activity. If Cesium 137 activity is found to be elevated above normal levels, an effort shall be promptly initiated to investigate the cause of the elevated level and take subsequent corrective action, as appropriate.

5.4 S*aled Sources All sc*ald s-urccs located on the Indian P-int Units 1 and 2 Site arc maintained undcr the Indian Pont Unit No. 2 Facility Operating License No. DPR 26 and sur.e..lane and use of such sources are addressed in Appendix A to the Indian Point Unit No.2 Facility NIl,-

i'*DD Oc*

Amendment No. -50 Ope rating Lii Page 11 ppqp K1-MOID on

6.0 PLANT REPORTING REQUIREMENTS D-Rl- ;nt Drnreportc an, RI*Jnn kifln-,

,'nrrenn,'-

Reporting Requirements are as specified in Appendix A to the Indian Point Nuclear Generating Unit No. 2 Facility Operating License No. DPR-26. in addition to the applicabl reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submi'tted to the Regional Administrator Region I, unless otherwise noed 6.1.2.1 The Annual Radiological Environmental Operating Roport covering the operation of the unit during the previous calendar year shall bo submitted prior to May 1 of each year.

6.1.2.2 The Annual Radiological Environmental Operating Report shall include summaries, interpretations, and statistical evaluation of the results of the radiological environmental surveillance activities for the report period-,

including (as appropriate) a comnparison with preoperational studies, operational controls and previous environGmental surveillance reports, and a asessment of the observed impacts of the plant operation en the enirnent. The report shall also incluide the resuilts of land use censuse

-required by Specification 4.11.B3. of Appendix A to the Indian Point Unit No. 2 Facility Operating License No. IDPR 26-.

The Annual Radiological Environmental Operating Report shall i nclude the results of analysis of all radioloegical environmental samples and of all environmental radiation measurements tae during the period pursuant to the locations specified in the Table and Figures in teOIDOM, as well as summarized and tabulated results of these analyses an measurements as descrfibed in the OIDCM. in the event that soeindiida results are not available for finclu~sion with the report, the report shall be submitted noting and explaining the reasons for the missng Fesults. The missing data shall be submitted as soon as possible i a supplementary report.

Amendment No, 45 6.4 64.12

+ A single submittal may be mde+

for a multiple ut station. Tho submittal should oombino thoso sootions that aro oommon to all units at tho statiin.

Page 12

The rcports shall also include the following: a summary description of the radiological environmental monitoring program; at least two legible mnaps 3 covering all sampling locations keyed to a table giving distances and dire*Rions from the ecnterline o*f o*c reactor; the results of EN participation in the Interlaboratory Comparison Program; discussion of all deviations from the sampling sc~hedule; and discussion of all analyses in wnicn tfle LLUD required was not aeflievaoie.

6.1.3 Radioactive Effluent Release RgE~qoW 6.1.3.1 Routine Radioactive Effluent Release RepodtS covering the previo~us 12 months of operation shall be submitted by May 1 of each year.

6.1.3.2 The Radioactive Effluent Release Rcpo~t shall include a sumnmary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in the Regulator,' Guide 1.21, "Measuring, Evaluating, and Repodting Radioactivity in Solid Wastes and Releases of Radioactive Materias in Liquid Gaseous Effluents fFrom Light Water Cooled Nuclear Power Plants", Revision 1, June 1 974, with data sumnmarized on a quarterly basis following the format of Appendix B thereof.

The Radioactive Effluent Release Report to be submittcd by May 1 of each year shall incILudo an annual sumnmary of hourly meteorological data collected over the previous year. This annual summary may be efither in the formn of an hour by hour listing of mnagnetic tape of wind speed, wind direGtion, atmospheric stability, and precipitation (if measured), or in the form o~f joint frequency distribution o~f wind speed, wind direction, and atmospheric stabi lity.4 This same repor

' A single submittal may be made for a multiple unit station. The submittal sho)uld combine those sections that are common to all units at the statoion.

3 One map shall cover stat ions near the site boundary; a second shall include more distani stations.

.In lieu o.f s-ubmis*nSion with the first half year Radioactive Effluent Release Repo.d, ENO has the provided to the NRC upon request.

Amendment No. 45 I

I 1

I I I

I I

I Page 13

shall include an assessment of the radiation doses due to the radio~active liquid and gaseous effluents released fromn the unit or station during the previou calendar year. This samne report shall also include an assessment of the radiation doses fFrom radioactive liquid and gaseous effluents to members of the public due to their activities inside the site boundary during the report period. All assuMptiOnS used in mnaking these assessments, i.e., specifi activity, exposu~re time anrd location, shall be included in these reports. The meteorologfical conditions c~onurrent with the time o~f release of radioactive materials in gaseo~us effluents, as determnined by sampling frequency and measurement, shall be uised forF determining the gaseou-s pathway doses. Approximnate and conservative approximate methods are acceptable. The assessment of radiation doses shall be pedoermed i n aGeordanee with the methodology and parameters i the Offsite Dose Caleulation Manual (0DC;M).

Acceptable methods for calculating the dose contribution fromn liquid and gaseous eff luents are given in Regulatory Guide 1..109 Rev. 1, October 1977.

The Radioactive Effluent Release Report shall inclIude the following informnation for each class of solid waste (in co)mpliance with 10 CFR Part 61 shipped offsite duFrig the report period:,

a)

Container volume-.

b)

Total Curie quantity (specify whether determined by mneasurement or estimate),

e)Principal radionuelides (specify whether determined by mneasurement or estimate)-,

d)

Source of waste and p ro~e scing employed (e.g., dewatered spent resin, co~mpacted dry waste, evaporator bottom),

e)

Type of container (e.g., LSA, Type A, Type B, Large Quantity),

and Amendment No. 46 Page 14

f)

Solidification agent or absorb

(~.

eet rafradhd)

The Radioactive Effluent Rele.

description of unplanned relcaas r.JUId, live materias i,* [i e Report shall include a list and s from the site to unrestricted areas of and liquid effluents made during the Thc Radioactive Effluent Release Report shall include any changes made durinRg the reporting period to the Procese GControl Program (PC;P) and to the Offsite Dose CaGLculation Manual (ODCM), as well as a listing of new locations for dose calcu~lations and/or environmenal monitoring identif ied by the land use c~ensus pursuant to Specification 4.411. oBEf Appendix A to the Indian Point Unit No. 2 Facility Operating License No. DPR 26.

6.2.1 Reports of major safety related corrective maintenance shall be submitted to the DiOrectorF, Office of Resource Management, U.S. Nuclear Regulatory Comnmission, Washington, DC 20555, with a copy to the Regional Administrator Region 1, no later than 6 months following completion of such maintenance.

6.2.2 Each such report shall include a desc~ription of any major safety related corrective maintenance performed including the system and comnponentinovd 6.

b.s. 1 A hCDerflpDI L-vent is ae~lneo as any oT the co~nimns, spncIIflp in it] rrPH GD7 ao 6.3.2 The following actions shall bc taken in the event of a reportable Event:

a.

A repo-rt shall be submitted to thc Crommission pursuan-t to the requirements of 1-0 CFR 50.73 and Amendment No, 4-5 Page 15 S..... j wr "ef

'**'i

EVI--jit ik'*'"-"'

(e.g., Gement, urea ferrnaldehydeý S.

I..................

b.

Each Reportable Event epor. submitted to the Commission shall be submitted to the NF=SC Chairman, and the Vise President Nuclear Po"'r rand be reviewed by the SNSC.

6.4 An" referenees to the term "Safety Analysis Repodt", "SAR" or "FSAR" for Indian Point Stain Unit No. 1, shall be deemned to refer, as appropriate, to the following exhibits whic~h are apa o the application: K 5 (Rev. 1) Figures 1 2,1 3, 3 14 oRly, K 5Al 1 Section 3.7.2 pages 171 thAeugh 176o,4 Pag Amendment No. 4-6 Page ]6

ATTACHMENT 3 TO NL-02-042 IP1 LICENSE AMENDMENT REQUEST Evaluation of Changes to the Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 1 DOCKET NO. 50-3

NL-02-042 Page 1 of 3 Evaluation of Changes to the Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility Description of Change ENO requests that the IP1 license be amended to supersede the following requirements of the "Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility," dated January 31, 1996, (the Order) to ensure compliance with the current requirements of 10CFR50.59, "Changes, Tests, and Experiments," and 50.82, "Termination of License," for evaluating whether changes may be made to IP1 without prior NRC approval.

The specific changes requested are:

"* On page 2, second paragraph, replace the phrase "...after performing a review based upon criteria similar to the criteria of Title 10 of the Code of Federal Regulations (10 CFR 50.59) to ensure that such changes do not involve an unreviewed safety question." with the phrase ", without prior Commission approval, provided the requirements of 10 CFR 50.59 and 10 CFR 50.82(a)(6) and (7) are satisfied."

"* Order Condition (a)(1), replace the phrase "...unless the proposed changes, tests or experiments involve a) a change in the Technical Specifications (TSs) incorporated in the license or b) an unreviewed safety question, or c) major dismantlement activities such as the removal of the reactor pressure vessel or other major radioactive components" with the phrase "provided the requirements of 10 CFR 50.59 and 10 CFR 50.82(a)(6) and (7) are satisfied".

"* Delete Order Conditions (a)(2), (b) and (c).

Reason for the Change The conditions of the Order for determining whether or not changes may be made to IP1 without prior NRC approval are no longer consistent with the Commission's regulations. The proposed changes will ensure effective compliance with the Commission's requirements by eliminating ambiguity and confusion. This will also simplify the administration of programs at the Indian Point site.

Evaluation of Change 1 OCFR50.82, "Termination of License," states:

"For power reactor licensees who, before the effective date of this rule

[July 29, 1996], either submitted a decommissioning plan for approval or possess an approved decommissioning plan, the plan is considered to be the PSDAR submittal required under paragraph (a)(4) of this section and the provisions of this section apply accordingly."

1 OCFR50.82(a)(6) and (7) for power reactor licensees states:

"(6)

Licensees shall not perform any decommissioning activities, as defined in §50.2, that --

NL-02-042 Page 2 of 3 (i) Foreclose release of the site for possible unrestricted use; (ii) Result in significant environmental impacts not previously reviewed; or (iii) Result in there no longer being reasonable assurance that adequate funds will be available for decommissioning.

(7)

In taking actions permitted under §50.59 following submittal of the PSDAR, the licensee shall notify the NRC, in writing and send a copy to the affected State(s), before performing any decommissioning activity inconsistent with, or making any significant schedule change from, those actions and schedules described in the PSDAR, including changes that significantly increase the decommissioning cost."

Since the IP1 Decommissioning Plan for long-term safe storage was submitted on October 17 1980, the Decommissioning Plan constitutes a PSDAR for the purposes of complying with 1 OCFR50.82. 1 0CFR50.82 describes the conditions under which changes can be made. Since the Decommissioning Plan only approved the SAFSTOR of IP1 and not the dismantlement, the Order requires the submittal of a detailed dismantling plan for NRC review and approval prior to major dismantlement activities at IPi.

1 OCFR 50.59, "Changes, tests and experiments," has been revised since the Order was issued. 10CFR50.59 no longer uses the term "unreviewed safety question" and uses different criteria than stated in the Order for determining whether or not prior Commission approval is required for implementing a change, test, or experiment.

IP1 License Condition 3.C requires the retention of records under applicable regulations. 10CFR50.59 applies to IP1 changes, tests, and experiments. Order Condition (b) is duplicative of (but slightly different) from the current 10CFR50.59(d).

Order Condition (c) is duplicative of the requirements in 10CFR50.59(c)(1) and (2) that specify whether a license amendment, pursuant to 10 CFR 50.90, is required prior to implementing a proposed change, test, or experiment.

The requested changes do not foreclose release of the site for possible unrestricted use; result in significant environmental impacts not previously reviewed; or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. The requested changes do not involve a major dismantling activity nor do they affect the Decommissioning Plan.

NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes described involve no significant hazards consideration. This conclusion is based on the evaluation of the three standards set forth in 10 CFR 50.92(c).

NL-02-042 Page 3 of 3

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

The proposed IP1 license change involves deleting specific language in the Order that was common terminology in past regulations but is not currently used. The proposed change does not involve a change to any IP1 system, structure, or component. Therefore, the proposed change does not increase the probability or the consequences of any accident previously evaluated in the IP1 FSAR or the IP1 Decommissioning Plan.

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

The proposed IP1 license change involves deleting specific language in the Order that was common terminology in past regulations but is not currently used. The proposed change does not affect the design or operation of any plant structure, system, or component. 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 proposed IP1 license change involves deleting specific language in the Order that was common terminology in past regulations but is not currently used. The effectiveness of ENO compliance with 1 OCFR50.59 and 1 OCFR50.82 is not adversely affected by this change. Effective compliance with the provisions of the Order to submit a detailed dismantling plan for NRC review and approval prior to major dismantling activities at IP1 is not affected. In addition, this change does not affect any design function or the operation of any plant structure, system, or component. Therefore, the change does not result in a change to any of the safety analyses or to any margin of safety.

ATTACHMENT 4 TO NL-02-042 IP1 LICENSE AMENDMENT REQUEST Evaluation of Change to the Expiration Date of the License ENTERGY NUCLEAR OPERATIONS, INC INDIAN POINT NUCLEAR GENERATING UNIT NO. 1 DOCKET NO. 50-3

NL-02-042 Page 1 of 3 Evaluation of Change to the Expiration Date of the License Description of Change ENO requests that the IP1 license be amended to change to expiration date from "midnight, October 14, 2006" to "midnight, September 28, 2013."

Reason for the Change The expiration date of the license is not consistent with the decommissioning plan approved by the NRC in its January 31, 1996 "Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility" (the Order).

Evaluation of Change The decommissioning plan was approved for long-term safe storage (SAFSTOR) of the IP1 spent fuel and residual radioactivity until the adjacent Indian Point Unit No. 2 has been permanently shutdown. Not only the Order but the staff's safety evaluation and environmental assessment regarding the Order clearly indicated approval for the licensee to possess and maintain IP1 in safe storage until IP2 is shutdown, at which time disposal of spent fuel and ultimate decommissioning would be jointly accomplished. The Safety Evaluation clearly states:

"This evaluation considers the possession-only license amendment, safety issues related to SAFSTOR of IP-1 to September 28, 2013, and the Con Ed financial assurance plan."

In its Safety Evaluation accompanying the Commission's August 27, 2001 Order (Ref 2) transferring the IP1 and IP2 licenses from Consolidated Edison to Entergy, the staff clearly understood that the decommissioning of IP1 would not occur before the cessation of operations of IP2 and affirmed the ENO financial assurance plan for the joint decommissioning of IP1 and IP2.

The IP2 Facility Operating license No. DPR-26 originally expired on October 14, 2006, 40 years after the issuance of the IP2 construction permit. However, in IP2 License Amendment No. 118 (Ref 3), the license expiration date was changed to September 28, 2013.

As described in the staff's January 31, 1996 Safety Evaluation for IP1 License Amendment No. 45, the Notice of Consideration of Issuance of Amendment and Opportunity for Hearing was published in the Federal Register on December 31, 1985.

The notice stated a license renewal date of October 14, 2006 to coincide with the permanent planned shutdown of IP2. Subsequent to the notice, the IP2 license expiration date was changed and the NRC was notified of the intent to delay dismantlement of IP1 until after that date. The safety evaluation for IP1 License Amendment No. 45 states:

"This safety evaluation and the enclosed environmental assessment of the decommissioning plan are consistent with the 2013 date. However, we have renewed License No. DPR-5 to October 14, 2006 to be consistent with the license

N L-02-042 Page 2 of 3 renewal application as noticed in the December 31, 1985 Federal Register Notice in order to put new TSs for the current shutdown condition in place."

This recognition of the coupling of the IP1 decommissioning with the permanent cessation of IP2 operations, the IP2 license termination date in 2013, and the inconsistency between IP1 and IP2 license termination dates was also recognized in the staff's Environmental Assessment for IP1 License Amendment No. 45.

The NRC has consistently recognized the coupling of the IP1 and IP2 decommissioning.

To accomplish this, the expiration date of the current IP1 possession-only license should be changed to coincide with the expiration of the IP2 operating license.

The requested change does not foreclose release of the site for possible unrestricted use; result in significant environmental impacts not previously reviewed; or result in there no longer being reasonable assurance that adequate funds will be available for decommissioning. The proposed change does not involve a major dismantling activity nor does it affect the Decommissioning Plan.

NO SIGNIFICANT HAZARDS CONSIDERATION The proposed changes described above involve no significant hazards consideration.

This conclusion is based on the evaluation of the three standards set forth in 10 CFR 50.92(c).

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

In its Safety Evaluation and Environmental Assessment for its January 31, 1996 Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility, the NRC evaluated the acceptability of the possession-only license and safety issues related to SAFSTOR of Indian Point Nuclear Generating Unit No. 1 until September 28, 2013. The requested change does not involve any activity that could change the assumptions of the prior Safety Evaluation and Environmental Assessment.

Therefore, the proposed license amendment does not involve a significant 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?

In its Safety Evaluation and Environmental Assessment for its January 31, 1996 Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility, the NRC evaluated the acceptability of the possession-only license and safety issues related to SAFSTOR of Indian Point Nuclear Generating Unit No. 1 until September 28, 2013. The requested change does not involve any activity that could change the assumptions of the prior Safety Evaluation and Environmental Assessment.

NL-02-042 Page 3 of 3 Therefore, the proposed amendment does 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?

In its Safety Evaluation and Environmental Assessment for its January 31, 1996 Order Approving Decommissioning Plan and Authorizing Decommissioning of Facility, the NRC evaluated the acceptability of the possession-only license and safety issues related to SAFSTOR of Indian Point Nuclear Generating Unit No. 1 until September 28, 2013. The requested change does not involve any activity that could change the assumptions of the prior Safety Evaluation and Environmental Assessment.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

REFERENCES:

1. NRC letter to Consolidated Edison, "Order to Authorize Decommissioning and Amendment No. 45 to License No. DPR-5 for Indian Point Unit 1 (TAC No.

M59664)," dated January 31, 1996

2. NRC letter to Consolidated Edison, "Indian Point Nuclear Generating Unit Nos. 1 and 2 - Order Approving Transfer of Licenses from the Consolidated Edison Company of New York, Inc., to Entergy Nuclear Indian Point 2, LLC, and Entergy Nuclear Operations, Inc. and Approving Conforming Amendments (TAC Nos.

MB0743 and MB0744), dated August 27, 2001

3. NRC letter to Consolidated Edison, issuing Amendment No. 118 to Facility Operating License No. DPR-26, dated April 21, 1987
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