NL-04-134, Proposed Change to Technical Specifications Regarding Elimination of Hydrogen Recombiner Requirements, and Relaxation of Hydrogen Monitor Requirements (TSTF-447)

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Proposed Change to Technical Specifications Regarding Elimination of Hydrogen Recombiner Requirements, and Relaxation of Hydrogen Monitor Requirements (TSTF-447)
ML043140231
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 10/22/2004
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-04-134
Download: ML043140231 (24)


Text

kEntergy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB Entergy P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration October 22, 2004 Re: Indian Point Units 2 & 3 Docket No. 50-247 & 50-286 NL-04-134 Document Control Desk U.S. Nuclear Regulatory Commission Mail Stop O-P1-17 Washington, DC 20555-0001

Subject:

Proposed Change to Technical Specifications Regarding Elimination of Hydrogen Recombiner Requirements, and Relaxation of Hydrogen Monitor Requirements (TSTF-447)

Reference:

1) Technical Specification Task Force (TSTF) Improved Technical Specification Change Traveler, TSTF-447, Revision 1.
2) Federal Register Notice 68 FR 55416, "Notice of Availability of Model Application Concerning Technical Specification Improvement to Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process,"

dated September 25, 2003.

Dear Sir:

Pursuant to 10CFR50.90, Entergy Nuclear Operations, Inc. (Entergy) is submitting a request for an amendment to the Technical Specifications for Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3).

The proposed amendment will delete the requirements in the Technical Specifications (TS) associated with hydrogen recombiners, and hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change p (at

NL-04-134 Docket 50-247 & 50-286 Page 2 of 3 Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors" (Reference 1). The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (Reference 2). provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves various changes to the TS Bases. Attachment 3 provides marked-up and revised TS Bases for information only.

Entergy has determined that this License Amendment Request (LAR) does not involve a significant hazard consideration as determined per 10 CFR 50.92. In accordance with 10 CFR 50.91, a copy of this application and the associated attachments are being submitted to the designated New York State official.

The new regulatory commitment required for implementation of the requested license amendment is summarized in Attachment 4. Entergy requests approval of the proposed amendment by April 2005 with the amendment being implemented within 60 days. If you have any questions or require additional information, please contact Mr. Kevin Kingsley at (914) 734-6695.

I declare under penalty of perjury that the foregoing is true and correct. Executed on IOei/Ot lyl Fred R. Dacimo Site Vice President Indian Point Energy Center cc: next page

NL-04-134 Docket 50-247 & 50-286 Page 3 of 3 cc: Mr. Patrick D. Milano, Senior Project Manager Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0 8 C2 Washington, DC 20555-0001 Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Senior Resident Inspector's Office Indian Point Unit 2 Nuclear Power Plant U.S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Resident Inspector's Office Indian Point Unit 3 U.S. Nuclear Regulatory Commission P.O. Box 337 Buchanan, NY 10511-0337 Mr. Peter R. Smith, President New York State Energy, Research and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-6399

ATTACHMENT I TO NL-04-134 DESCRIPTION AND ASSESSMENT OF PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING HYDROGEN RECOMBINERS AND HYDROGEN MONITORS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

Attachment I to NL-04-134 Docket 50-247 and 50-286 Page 1of 3

1.0 INTRODUCTION

The proposed License amendment changes Technical Specification (TS) sections 3.3.3 and 3.6.8 for both Indian Point Unit 2 (IP2) and Indian Point Unit 3 (IP3) regarding hydrogen recombiners and hydrogen monitors.

The changes are consistent with Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this technical improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with Revision 1 of TSTF-447, the proposed TS changes include:

Indian Point 2

  • Table 3.3.3-1 Item 10, Hydrogen Monitors Deleted
  • Table 3.3.3-1 Item 11, Hydrogen Monitors Deleted
  • Table 3.3.3-1 Note Item C, Hydrogen Monitors Deleted
  • TS3.6.8 Hydrogen Recombiners Deleted As described in TSTF-447, the changes to TS requirements also result in changes to various TS Bases. Proposed changes to the TS Bases are provided for information only in Attachment 3.

The TS Bases changes will be submitted with a future update in accordance with the Technical Specification Bases Control Program.

3.0 BACKGROUND

The background for this application is addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447 Revision 1, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

Attachment 1to NL-04-134 Docket 50-247 and 50-286 Page 2 of 3 4.0 REGULATORY REQUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447 Revision 1, 'Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors," the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Entergy has reviewed the model safety evaluation (SE) published on September 25, 2003 (68 FR 55416), and verified its applicability as part of the CLIIP. This verification included a review of the NRC staffs model SE, as well as the information provided to support TSTF-447, Revision

1. Entergy has concluded that the justifications presented in the TSTF proposal and the model SE prepared by the NRC staff are applicable to IP2 and IP3 and justify this amendment for the incorporation of the changes to the respective plant Technical Specifications as described in Section 2.0 above. Entergy currently has hydrogen monitors installed at.lP2 and IP3 that are capable of diagnosing beyond design basis accident scenarios and a commitment is being made (see Section 6.1) to maintain this capability.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, Revision 1, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documentation.

6.1 Verification of Commitments As discussed in the model SE published in the Federal Register on September 25, 2003 (68 FR 55416), for this TS improvement, Entergy is making the following verifications and regulatory commitment:

1. Entergy has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at IP2 and IP3 and is making a regulatory commitment to maintain that capability for both units. The hydrogen monitors will be included in a preventive maintenance program to assure that the monitors are maintained reliable and functional. This regulatory commitment will be implemented within 60 days of issuance of the license amendment.
2. IP2 and IP3 do not have an inerted containment.

Attachment 1 to NL-04-134 Docket 50-247 and 50-286 Page 3 of 3 7.0 NO SIGNIFICANT HAZARDS CONSIDERATION Entergy has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the proposed determination presented in the notice is applicable to IP2 and IP3, and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).

8.0 ENVIRONMENTAL EVALUATION Entergy has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. Entergy has concluded that the staff's findings presented in that evaluation are applicable to IP2 and IP3, and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. Entergy is not proposing variations or deviations from the TS changes described in TSTF-447, Revision 1 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

ATTACHMENT 2 TO NL-04-134 MARK-UP OF TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING HYDROGEN RECOMBINERS AND HYDROGEN MONITORS Indian Point 2:

Page 3.3.3-2 Page 3.3.3-4 Page 3.6.8-1 Page 3.6.8-2 Indian Point 3:

Page 3.3.3-4 Page 3.3.3-5 Page 3.6.8-1 Page 3.6.8-2 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

PAM Instrumentation 3.3.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME RCS Cold Leg Temperature (WNide Range) channel inoperable and no OPERABLE SG Pressure channel for the associated SG.

D. Required Action and D.1 Enter the Condition Immediately associated Completion referenced in Table 3.3.3-1 Time of Condition C not for the channel or train.

met.

E. As required by Required E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action D.1 and referenced in AND Table 3.3.3-1.

E.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. As required by Required F.1 Initiate action in Immediately Action D.1 and accordance with referenced in Specification 5.6.6.

Table 3.3.3-1.

SURVEILLANCE REQUIREMENTS

- NOTE -

SR 3.3.3.1 and SR 3.3.3.3 apply to each PAM instrumentation Function in Table 3.3.3-1.

SURVEILLANCE FREQUENCY SR 3.3.3.1 Perform CHANNEL CHECK for each required 31 days instrumentation channel that is normally energized.

SR 3.3.3.2 Perform CHANNEL CALIBRATION of the following: 92 days

a. Function 10, Containment Hydrogen Monitors; and b- a. Function 22, RWST Level Instruments.

INDIAN POINT 2 3.3.3 - 2 Amendment No. 238

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 1)

Post Accident Monitoring Instrumentation CONDITION FUNCTION REQUIRED CHANNELS REFERENCED FROM REQUIRED ACTION D.1

1. Reactor Coolant System (RCS) Hot Leg 1 per loop (a) E Temperature (Wide Range)
2. RCS Cold Leg Temperature (Wide Range) 1 per loop (b) E
3. RCS Pressure (Wide Range) 2 E
4. Reactor Vessel Level Indication System (RVLIS) 2 F
5. Containment Sump Water Level (Recirculation 2 E Sump)
6. Containment Water Level (Containment Sump) 3
7. Containment Pressure 2
8. Containment Pressure (High Range) 2
9. Containment Area Radiation (High Range) 2
10. Containment Hydrogn- Monitors NOT USED 2
11. Pressurizer Level 2
12. Steam Generator (SG) Water Level (Narrow Range) 2 per steam generator
13. Steam Generator Water Level (Wide Range) 4
14. Condensate Storage Tank level 2
15. Core Exit Temperature - Quadrant 1 2 trains(c)
16. Core Exit Temperature - Quadrant 2 2 trains(c)
17. Core Exit Temperature - Quadrant 3 2 trains(c)
18. Core Exit Temperature - Quadrant 4 2 trains(c)
19. Auxiliary Feedwater Flow 4
20. Steam Generator Pressure 2 per steam line
21. RCS Subcooling Margin Monitor 2
22. RWST Level 2 (a) The required redundant channel for each of the four loops of RCS hot leg temperature is a qualified Core Exit Temperature train in the quadrant associated with that loop.

(b) The required redundant channel for each of the four loops of RCS cold leg temperature is any channel of steam generator pressure for that loop.

(c) A CET train consists of two core exit thermocouples (CETs).

INDIAN POINT 2 3.3.3-4 Amendment No. 238

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen RecembbineFs Not Used a o~ ^ ^ c -L--ll 1-- rmr-MAMI f-L..J..v IW ny aIVUrogen recomHincrt Finali DC UJrztdfDLt.

AQQI fF lrAQII I-rV-

- Llfi>DILI I I .

FlAnnact IVIVUCh 4 n--

I

')

_1lU _.

AGTIONS GONlIT4ON REQUIRED ACTION COMIPLETION TIME A. One hydFogeR A.1 Restore hydrogen 30 days recombiner inoperable. recombiner to OPERABLE 6tatur.

r I Xf-M.~z hI- rnref~

AhoUF B. Two hydrFgRn raromhinere inaoprable. means that the Post Accident Containment AND Venting Systcm function is maintained. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafte AN-D Q '. 0^a+e ra en^ strr,.an dAysl WaVcrw r h 4rf'%MDED A DI C Itato vumm mWV - -l-LC s~tatus.

C. Required Action and C.1 Be in MODE 3. 6 hOUF6 associated Completion Time not met.

INDIAN POINT 2 3.6.8-1 Amendment No. 238

Hydrogen Recombiners 3.6.8 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Verify by visual inspection that each hydrogen 24 months recombiner has no significant fouling by forcign niateials.

SR 3.6.8.2 V.erify the required Fsponse of a sample-plate from 18 months eaGh hydrogen recombiner to a test mixture of hydFogenRgas, INDIAN POINT 2 3.6.8-2 Amendment No. 238

PAM Instrumentation 3.3.3 Table 3.3.3-1 (page 1 of 2)

Post Accident Monitoring Instrumentation CONDITION REFERENCED FROM REQUIRED ACTION D.1 SR 3.3.3.2 FUNCTION REQUIRED CHANNELS FREQUENCY

1. Neutron Flux 2 24 months
2. RCS Hot Leg Temperature (Wide Range) 1 per loop 24 months (Tbmt)
3. RCS Cold Leg Temperature (Wide Range) 1 per loop 24 months (Told )
4. RCS Pressure (Wide Range) 2 24 months
5. Reactor Vessel Water Level 2 24 months
6. Containment Water Level (Wide Range) 2 24 months
7. Containment Water Level (Recirculation 2 24 months Sump)
8. Containment Pressure 2 18 months
9. Automatic Containment Isolation Valve 2 per penetration flow 24 months Position pathla8(b)
10. Containment Area Radiation (High Range) 2 24 months
11. Containment Hydrogen Monitors NOT USED 924 ays
12. Pressurizer Level 2 24 months
13. SG Water Level (Narrow Range) 2 per SG 24 months
14. SG Water Level (Wide Range) and 1 each per SG 24 months. SGL Auxiliary Feedwater Flow 18 months. AFF
15. NOT USED
16. Steam Generator Pressure 2 per SG E 24 months
17. Condensate Storage Tank Level 2 F 24 months
18. Core Exit Thermocouples-Quadrant 1 2 (d c) E 24 months
19. Core Exit Thermocouples-Quadrant 2 2 (d c) E 24 months
20. Core Exit Thermocouples-Quadrant 3 2 (d c) E 24 months
21. Core Exit Thermocouples-Quadrant 4 2 Cdc) E 24 months
22. Main Steam Line Radiation 1 per steam line F 24 months
23. Gross Failed Fuel Detector 2 F 24 months
24. RCS Subcooling Margin 2 E 24 months See NOTES, next page.

INDIAN POINT 3 3.3.3-4 Amendment 211

PAM Instrumentation 3.3.3 TABLE 3.3.3-1 (page 2 of 2)

Post Accident Monitori ng Instrumentation NOTES:

(a) Not required for isolation valves whose associated penetration is isolated by at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

(b) Only one position indi cation channel is required for penetration flow paths with only one installed control room indication channel.

(c) Hydrogen monitor OPERABILITY requires that at least one of the ass ociated containment fan cooler unit is OPERABLE.

(4c)A channel consists of two core exit thermocouples (CETs).

INDIAN POINT 3 .3.3.3-5 Amendment 211

Hydrogen Recombiners 3.6.8 3.6 CONTAINMENT SYSTE MS 3.6.8 Hydrogen Recormbincrs Not Used

_b v..

I O

-n Tr .-m h\-Aono ----

... .- n.rcer

.IW rcvuil m n--

r- -L.-I hinrn~Ani I_ r UMLK/ \-tSLL.-

ADDI TrAOTI TTV. MnnCr 1 -A I ACTIONS CONDITION- REQUIRED ACTION COMPLETION TIME A. Onc hydrogen A.1 NOTE recoGMbincr inoperable. LCO 3.0.1 is not applicable.

Rcstorc hydrogen 30-days recombincr to OPERABLE status.

B. Rcquired Action and B.1 Bc in MODE 3. 6 houps acSSOi atod Compl eti on Time not met.

INDIAN POINT 3 3.6.8-1 Amendment 205

Hydrogen Recombiners 3.6.8 SURVEILLANCE REQUIREME-NTS SURVEILLANCE FREQUENCY SR 3.6.8.1 Perform a system functional test for each 6months hydrogen recombincr.

SR 3.6.8.2 Visually examine each hydrogen recombiner 24-menths-enclosure and verify there is no evidencc of abnormal conditions.

SR 3.6.8.3 Perform a resistanc to ground test for each 24 meoths heatesr phan co INDIAN POINT 3 3.6.8-2 Amendment 205

ATTACHMENT 3 TO NL-04-134 MARK-UP OF TECHNICAL SPECIFICATION BASES PAGES FOR PROPOSED CHANGES TO THE TECHNICAL SPECIFICATION BASES REGARDING HYDROGEN RECOMBINERS AND HYDROGEN MONITORS Indian Point 2:

Page B 3.3.3-8 Page B 3.3.3-17 Page B 3.6.1-1 Indian Point 3:

Page B 3.3.3-10 Page B 3.6.8-1 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

PAM Instrumentation B 3.3.3 This LCO is satisfied by the OPERABILITY of any 2 of the 6 channels supported by PT-948A, PT-948B, PT-948C, PT-949A, PT-949B or PT-949C. Each channel provides indication in the control room over a range of -5 psig to 75 psig.

8. Containment Pressure (High Range)

Containment Pressure (High Range) is a Type C, Category I Function that is provided for verification of RCS and containment OPERABILITY. This Function would be used for the assessment of the potential for a containment boundary breach.

This LCO is satisfied by the OPERABILITY of PT-3300 and PT-3301. Each channel provides indication in the control room over a range of -10 psig to 150 psig.

9. Containment Area Radiation (High Range)

Containment Area Radiation is a Type A, Category I Function that is provided to monitor for the potential of significant radiation releases and to provide release assessment for use by operators in determining the need to invoke site emergency plans. Containment radiation level is used to determine if a high energy line break (HELB) has occurred, and whether the event is inside or outside of containment.

This LCO is satisfied by the OPERABILITY of High Range Containment Radiation Monitors R-25 and R-26. Each channel has a range of 1 R/hour to 107 R/hour. Acceptable criteria for calibration are provided in Table II.F-13 of NUREG-0737.

10. Containment Hydree Monitors Not Used Hydrogen Monitors are a Type C, Category I Function that is provided to detect high hydrogen concentration conditions that represent a potential for containment breach from a hydrogen explosion. This variable is also important in verifying the adequacy of mitigating actions.

This LGO is satisfied by the OPERABILITY of two hydrogen analyzers:

AIT 5109 1 (channel 1) and AIT 5110 1 (channel 2). Each channel has a range of 0% to 10%. Calibration is performed using a calibration span gas.

INDIAN POINT 2 B 3.3.3-8 Revision 0

PAM Instrumentation B 3.3.3 SR 3.3.3.1 Performance of the CHANNEL CHECK 6ntce every 31 days ensures that a gross instrumentation failure has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION. The high radiation instrumentation should be compared to similar unit instruments located throughout the unit.

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized. Instruments that are normally isolated or normally not in service are considered de-energized.

The Frequency of 31 days is based on operating experience that demonstrates that channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels.

SR 3.3.3.2 and SR 3.3.3.3 A CHANNEL CALIBRATION is performed every 92 days for the hydogen monGitor and RWST level and every 24 months, or approximately at every refueling for all other Table 3.3.3-1 Functions. CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Core Exit thermocouple INDIAN POINT 2 B 3.3.3-17 Revision 0

Hydrogen Recombiners B 3.6.8 B 3.6 CONTAINMENT SYSTEMS B 3.6.8 Hydrogen Re-ombinems Not Used (all pages of B 3.6.8 are deleted)

BASES BAGKGROUND The function of the hydrogen reonmbiners6 is to eliminate the potential breach of containment due to a hydrogen oxygen reaction.

Per 10 CFR 50.44, "Standards for Combustible Gas Control Systems in Light Water Gooled Reactors" (Ref. 1), and G-DG 4n1, ' COfntainmcnt Atmosphere Cleanup" (Ref. 2), hydrogen recombiners are required to reduce the hydrogen concentration in the containment following a loss of coolant accident (LOCA) or steam linc break (SLB). The recombiners aconmplish this by reCombining hydrog6n and oxygen to form wateF vapor. The vapor remains in containment, thus e!iminating any discharge to the environmcnt.

Two 100% capacity independent hydrogen recombiner units are provided.

The 112 hydrogen recombiners are pa-siealutocatalytic recombineres which contain no moving parts and do not need electrical power or any other support system. Recombination is accomplished by the attraction of oxygen and hydrogen molecules to the surfac of the catalyst. The hydrogen recombiners are designed for self starting and self sustaining epe~atiGR Each hydrogen recombiner conRists of a stainless steel sheet metal box open at thc bottom and at both sides on the top. There arc 88 catalytic cartridges inserted into each box. Each cartridge fabricated from perforated stcel plates holds catalyst pellets. The spaces between the cartridges ccrve as flow channels for the gases. The exothermic reaction of the combination produces heat, which results in-a convective flow that draws morc gases from the Containment atmosphere iRnt the unit from below. Airflow enters at the bottom and thc catalyst combines hydrogen and oxygen in the flow channels to form gaseous water.

A single iesombineF is capabie of limiting the peak hydogen concentration in containment to less than A.0 "'. Thc second recombiner is redundant and is installed to provide margin and increasedoRntainment coverage.

Both hydrogen recombiners are located outside the missile shield wall inside containment at the 95 foot level. They are seismically qualified and have undernenvirmental qualification testing in accordance w~ith IEFE 627 and IEFF 244.

INDIAN POINT 2 B 3.6.1 -1 Revision 0

PAM Instrumentation B 3.3.3 BASES LCO The LCO requirement for containment Area Radiation (high range) monitoring is satisfied by radiation monitors designated R-25 and R-26.

E nn.anmn4 tokd tie ,,,--rs - Not Used Hydrogen Monitors arc provided to detect high hdrentonditions that rprsent at fo rc ot inm ent b each from 1 hyd rogen xplosion. Thi:s variablc is also important in verifying the adequacy of mitigating The LcO requiremcnt for containment Hydrogen monitoring is satisf;ied b contanment hydr gen sampling monitors designated ICMC A and HCMC B.

Hydrogen monitor OPERABILITY requi res that at least one of the associated containment fan cooler units (FC-U) ;is PERABL£E . IICMC A is associated with Fcu 32 or 35 and HCMC B iS assocriated with rEcu, RI or RR or 34.

12. Pressurizer Level Pressurizer Level is used to determine whether to terminate SI, if still in progress, or to reinitiate SI if it has been stopped. Knowledge of pressurizer water level is also used to verify that the unit is maintained in a safe shutdown condition.

The LCO requirement for 2 channels of pressurizer level indication is satisfied by any two of the level instruments designated LT-459, LT-460 and LT-461.

13. steam Generator water Level (Narrow Ranae)

SG water Level is required to monitor operation of decay heat removal via the SGS.

Each steam Generator (SG) has three narrow range transmitters which span a range from the top of the tube bundles up to the moisture separator.

(continued)

INDIAN POINT 3 B 3.3.3 -10 Revision 02

Hydrogen Recombiners B 3.6.8 B 3.6 CONTAINMENT SYSTEMS

4. -

rirnmmfl Rer'r Not used (all pages of B 3.6.8 are deleted) n *j~ i!'.'elnnc BASE&

BACKGROUND The function of the hydrogen recombiners is to climinatc the potential brcach of containmcnt due to a hydrogen oxygen reaction.

Per 10 cFR 50.44, "standards for Combustibic Cas Control Systems in light WIter cooled Reactors" (Ref.

1), and GDC 11 4 "ContainetAmsheeCenp Ref.

2), hydroc reobiners arerqidtocucth hydrogen concentratien in thccn&imn follo wi ng los of' e mlant aeident (6'GA) or stcam lnc -

(SLB1) . The recombiner-s accomplish tIs-- byrecombining hydrogen. an r^- ;a ^=o, x _-m]<.:,1

-n to form water vao. Th Y.,_ ao remains in containment, thus-eliminating any discharge to the environment. The hydrogen recombiners arc manually a d s lammable limits would not be reached until several days after a Design GasiS Accident (DsA).

Two 100% capaeity independent hydrogen recombiner systems r,,s~~~ are provided. Each consists 1s t aa-SoF3M os of controls A_ _1-vlocate in the control rm a power s y nd recombiner. Recombination is aecomplished by heating a hydrogen air mixture above 1150 °

-recombinr is capable of maintaining the hydrogen concentration in containment below the 4.1 volume percent (v/o) flammability limit. Two recombiners are provided to meet the requ-irement for redundancy and

Independece. Each- recombn is powered from a separate Engineered safety reatures bus, and is provided with a separate power panel and control panel.

APP! WrALE - AFfTY AIA! YSFS ehydrogen rec mbiner prorvide fort carbil;ity of UIL..I Lu .LJ rnnt-~'lnn t~ ;a^uivWI H' Jh~d'-~~ il FsWrV inrr

  • UIJ .-,t.n l in

[ }VL concentration of 4.1 v/o followiga DBA. This control would prevent a containment wide hydrogen burn, thus ensuring the pressure and temperature aSSumed Eenwthi ued-}

INDIAN POINT 3 B 3.6.8 -1 Revision 02

ATTACHMENT 4 TO NL-04-134 COMMITMENTS FOR IMPLEMENTATION OF LICENSE AMENDMENT REQUEST TO ADOPT TSTF-447, REVISION I ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 & 3 DOCKET NO. 50-247 AND 50-286

Attachment 4 to NL-04-134 Docket 50-247 and 50-286 Page 1 of 1 Commitment for Implementation of Licensing Amendment Request ID DESCRIPTION DATE NL-04-134-A Entergy has verified that a hydrogen monitoring 60 days (for IP2) system capable of diagnosing beyond design-basis following NRC accidents is installed at IP2 and IP3 and is making a approval of NL-04-134-1 regulatory commitment to maintain that capability for the License (for IP3) both units. The hydrogen monitors will be included Amendment in a preventive maintenance program to assure that Request the monitors are maintained reliable and functional.