Text

Proposed Changes to the Technical Specifications Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate
	ML080670211
Person / Time
Site:	Indian Point
Issue date:	02/28/2008
From:	Joseph E Pollock; Entergy Nuclear Operations
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	GL-04-002, NL-07-129, NL-08-041
	Download: ML080670211 (24)
	v • d • e

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 11112 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration February 28, 2008 Re: Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 NL-08-041 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001

SUBJECT:

Proposed Changes to the Technical Specifications Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate

REFERENCES:

1) NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004.

2), Entergy Letter NL-07-129, "Revised Request for Extension of Completion Date for Indian Point Unit 3 Corrective Actions and Modifications Required by Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors"" dated December 3, 2007.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby requests an amendment to the Operating License for Indian Point Nuclear Generating Unit No. 3 (IP3), to replace the containment buffering agent from sodium hydroxide (NaOH) to sodium tetraborate decahydrate (STB). The purpose of this change is to minimize the potential for sump screen blockage concerns under post loss-of-coolant accident conditions due to a potential adverse chemical interaction between NaOH and certain insulation materials used in containment. This request is an integral part of Entergy's resp~onse to GL 2004-02 (Reference 1) and represents one of the remaining modifications required to achieve full compliance with the requirements of GL 2004-02 as documented in Reference 2.

Indian Point Unit 3 Docket No. 50-286 NL-08-041 Page 2 of 2 Entergy has evaluated the proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c) and has determined that this proposed change involves no significant hazards considerations as described in Attachment 1. The proposed changes to the Technical Specifications are shown in Attachment 2. The associated TS Bases changes are provided in Attachment 3 for information. 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.

Entergy requests approval of the proposed amendment as soon as possible with implementation to occur no later than June 30, 2008. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr.

R Walpole at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 2**, 2008.

Sincerely, J. E. Pollock Site Vice President Indian Point Energy Center Attachments:

1: Analysis of Proposed Changes to the Technical Specifications Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate 2: Markup of Existing Technical Specification Pages for Proposed Changes Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate 3: Markup of Technical Specification Bases Pages for Proposed Changes Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DOLR Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector's Office, Indian Point Unit 3 Mr. Paul D. Tonko, President, NYSERDA Mr. Paul Eddy, New York State Department of Public Service

ATTACHMENT 1 TO NL-08-041 ANALYSIS OF PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING REPLACEMENT OF THE SODIUM HYDROXIDE BUFFER WITH SODIUM TETRABORATE DECAHYDRATE ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

Attachment 1 Docket No. 50-286 NL-08-041 Page 1 of 10

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc. (Entergy) requests an amendment to the Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3) by revising Technical Specification (TS) 3.6.7, "Spray Additive System".

Entergy intends to replace the sodium hydroxide as the buffering agent for pH control during recirculation with sodium tetraborate decahydrate (Na 2B4OT.10H 2 0), hereinafter called sodium tetraborate (STB). The purpose of this change is to minimize the potential for sump screen blockage concerns under post loss-of-coolant accident (LOCA) conditions due to a potential adverse chemical interaction between sodium hydroxide and certain insulation materials used in containment. The use of sodium hydroxide ensures an alkaline pH for the solution recirculated in the containment sumps. The alkaline pH minimizes the evolution of iodine and minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid. The proposed use of STB serves this same function, maintaining the intent of the TS, but results in less predicted precipitate generation and resultant sump screen blockage.

2.0 PROPOSED CHANGE

The Indian Point Unit 3 TS 3.6.7 will be revised as follows:

Change the TS name from "Spray Additive System" to "Recirculation pH Control System"

Change the LCO from "The Spray Additive System shall" to "The Recirculation pH Control System shall"

Change Condition Aland Required Action A.1 from "Spray Additive System" to "Recirculation pH Control System"

Delete existing SR 3.6.7.1 to 3.6.7.5 and replace them with new SR 3.6.7.1 that reads:

"Perform a visual inspection of the eight sodium tetraborate storage baskets to verify each of the following:

a. Each storage basket is in place and intact; and,

b. Collectively contain >8096 pounds (160 cubic feet) of sodium tetraborate decahydrate, or equivalent."

The associated TS Bases changes are provided in Attachment 3 for information purposes.

Attachment 1 Docket No. 50-286 NL-08-041 Page 2 of 10

3.0 BACKGROUND

TS currently require the use of sodium, hydroxide as the buffering agent for the post-LOCA recirculation fluid. The sodium hydroxide is stored in one spray additive tank which contains 4000 gallons or more of a NaOH solution with a concentration >35% and <38% by weight. The spray additive tank has a flow path to each containment spray pump that consists of an eductor, valves and instrumentation. Each eductor draws the NaOH solution from the common tank using a portion of the borated water as motive force. The design achieves a pH in the spray of between 9.0 and 10.0 as a result of mixing of the boric acid from the Refueling Water Storage Tank which has a pH of approximately 4.5. The percent solution and volume of solution ensures a minimum long-term equilibrium containment sump pH of 8.0. This provides for continued iodine retention effectiveness of the sump water and minimizes the occurrence of chloride and caustic induced stress corrosion cracking of systems and components exposed to the fluid.

Sodium hydroxide was initially selected as a post-LOCA buffering agent because of its favorable characteristics. In particular, it stores easily and the quantity needed to increase the coolant pH above 7.0 is reasonable. As a buffering agent, addition is mainly required to reduce release of iodine fission products from the coolant to the containment atmosphere as iodine gas, in order to control the radiological consequences of the accident. Long-term iodine retention is assured only when the equilibrium sump solution pH is above 7.0. In addition to dose considerations, raising the pH in the post-LOCA containment pool to a value greater than 7.0 reduces the general corrosion rate of some structural materials and inhibits stress corrosion cracking in austenitic stainless steel.

The Pressurized Water Reactor Owners Group (PWROG) investigated the ability to reduce chemical precipitant formation simply by replacing sodium hydroxide with another chemical that is less reactive with the materials in containment to form precipitants. The program tested alternative buffering agents to determine the efficacy of these materials to replace sodium hydroxide. The results of the PWROG activity were reported in WCAP-1 6596-NP (Reference 1). The results of the candidate buffer testing were used to determine the appropriate replacement for sodium hydroxide at IP3 and STB was selected as an acceptable alternative.

Replacement of the sodium hydroxide with STB in baskets would eliminate active components with a reduction in testing and maintenance. Further benefits include elimination of caustic cleanup due to inadvertent actuation.

4.0 TECHNICAL ANALYSIS

4.1 Implementation The proposed modification involves the installation of eight (8) baskets that will be seismically designed and mounted at elevation 46' in the Vapor Containment building. The design is in compliance with the AISC 9 th Edition (Reference 2), supplemented by ASME Section III as appropriate. The structural qualification includes the effects of deadweight and seismic loading including the weight/mass of the contents (i.e., STB). Since the structure is bolted, thermal effects are negligible and consequently, not analyzed. The seismic loading requirements are consistent with the Indian Point Unit 3 Updated Final Safety Analysis Report.

Attachment 1 Docket No. 50-286 NL-08-041 Page 3 of 10 The baskets and anchor bolts are made out of Stainless Steel Type 304 material. The use of dual certified 304/304L materials is acceptable. The approximate dimensions of the current design for each basket are 48.5" per side and 16.5" high.

The intent is to install the baskets while the plant is on-line or in an outage of sufficient duration.

The eight baskets will be installed first and then the transition would be made. Current TS 3.6.7, Condition A, with a 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months allowed outage time for the sodium hydroxide will be entered as applicable prior to isolating the sodium hydroxide tank. The sodium hydroxide tank will be isolated to assure no addition of sodium hydroxide (e.g., manually close the three manual valves in the flowpath). The STB will be brought into containment in enclosed containers suitable for the LOCA environment or the STB will be brought into the containment and emptied into the baskets during the time Condition A is entered. The revised Technical Specification will be implemented during this allowed outage time of Condition A and the revised Condition A will be entered effective at the time the existing Condition A was entered. The revised Condition A will be exited when the STB is in place.

After the STB is declared operable, the sodium hydroxide tanks will be maintained in an isolated condition. This condition was evaluated and found acceptable (Reference 3). The evaluation concluded there was no issue with the Containment Spray System operation due to isolation of the sodium hydroxide since the flow path remained unchanged through the eductors.

4.2 TS 3.6.7 changes The proposed change to TS 3.6.7, which replaces the use of sodium hydroxide with STB, is consistent with the existing TS. Both additives maintain pH control to ensure iodine retention and to minimize stress corrosion cracking in stainless steel. However, the use of sodium hydroxide has been shown to potentially exacerbate post-LOCA sump screen blockage due to a potential adverse chemical interaction with certain insulation materials used in containment.

Therefore, to preclude the potential for a possible adverse NaOH/insulation interaction, Entergy is proposing to replace the sodium hydroxide with the hydrated form of STB which has essentially the same buffering agent characteristics but with less potential adverse consequences. A fully hydrated form of STB is proposed which makes it is less likely to absorb large amounts of water from the potentially humid containment conditions. If exposed to dry containment conditions, there is a potential for some loss of water. The chemical properties of the buffer do not change as the result of the potential water loss, but weight does decrease (Reference 1).

The proposed change to TS 3.6.7 revises the system name from "Spray Additive System" to "Recirculation pH Control System" to reflect the method of pH control. The sodium hydroxide was a spray additive where the STB is dissolved in the post LOCA fluid collected in the Vapor Containment. The action statements for sodium hydroxide and STB are the same. The existing TS SR 3.6.7.1 to 3.6.7.5 are deleted to reflect the change to-design. The new SR will provide for visual inspection and verification that the baskets remain intact during refuel outages. This specification is the same as the TS proposed for IP2 (Reference 4) and approved (Reference 12).

Attachment 1 Docket No. 50-286 NL-08-041 Page 4 of 10 4.2.1 STB Mass and Volume Determination Based on NUREG-0800, Section 6.5.2 (Reference 5), long-term iodine retention is assumed only when the equilibrium sump solution pH is above 7.0. Subsection 11.1 .g specifies that the pH of all solutions in the containment sump and all additives for reactivity control, fission product removal, or other purposes (boric acid) should be maintained at a level high enough to assure that significant long-term iodine re-evolution does not occur. Long-term iodine retention may be assumed only when the equilibrium sump solution pH, after mixing and dilution with primary Icoolant, Containment Spray, and ECCS injection sources (RWST and Accumulators),

is above 7.0. Branch Technical Position 6-1 (Reference 6) states that consideration should be given to hydrogen generation if a pH greater than 7.5 is used. This modification is reducing the

pH to within 7.5 so the previously evaluated hydrogen generation due to corrosion is conservative.

Entergy had an analysis performed to determine the amount of STB needed to maintain the post-LOCA containment sump pH >7.0 following recirculation at IP3 (Reference 7). STB pH and dissolution tests were performed and were used for the analysis. The test data showed that the buffer dissolves readily, confirming the information contained in WCAP-1 6596-NP (Reference 1). The analysis considered the minimum andmaximum quantities of boron and borated water and the time-dependent post-LOCA sump temperatures. In addition, the

.formation of acid from radiolysis of air and water, radiolysis of chloride bearing electrical cable insulation and jacketing, and spilled reactor core inventory were included. The pH of the sump pool was determined for values of 8,096 and 10,000 pound mass of STB considering the rate of acid formation. The pH values at the onset of recirculation and for 30 days (by which time the sump pool pH has reached an equilibrium value) are as follows:

pH Values Minimum Sump Water Maximum Sump Water 8,096 Ibm 10,000 Ibm 8,096 Ibm 10,000 Ibm Initial pH 7.3 7.4 7.2 7.3 30 day pH 7.2 7.3 7.1 7.2 Based on the above, either volume of STB is adequate to maintain the required pH range. The proposed surveillance requirement is based on the lesser amount.

4.3 STB Location The Recirculation pH Control System will consist of eight baskets that are located at elevation 46'. They are located to provide assurance that the STB will be readily dissolved to provide the pH control.

4.4 STB Evaluation Use of STB is predicted to result in a significant reduction in precipitate formation with no adverse side effects as demonstrated by the integrated chemical effects test (ICET) with NaOH and STB (Reference 8), the results of the PWROG chemical effects testing (Reference 9), and alternate buffer testing documented in WCAP-16596-NP (Reference 1). Additionally:

Attachment 1 Docket No. 50-286 NL-08-041 Page 5 of 10

STB provides a buffering capability in the range of 7.1 to 7.4. The STB will be contained in 8 stainless steel, seismically qualified, wire mesh baskets strategically located in the post-accident flooded region of the containment.

No new types of precipitates are formed in the target pH range of 7.0 to 8.0, which is within the range of IP3 pH control (Reference 1);

" STB will provide additional dissolved boron for reactivity control.

STB is readily dissolved. STB is expected to form clumps due to local dissolution and re-precipitation under the in-service conditions of the containment environment (Reference 1). This phenomenon does not chemically change the STB portion of the material. Test results showed that relative to that of the granular form, the clumped STB took longer to dissolve as a result of the surface area reduction but nevertheless dissolved readily.

The stability of STB in the containment environment can be considered comparable to or slightly better than trisodium phosphate (TSP), a similar buffering agent which has been used extensively in PWR environments (Reference 1). The stability of STB to radiation exposure has been demonstrated to be satisfactory based on years of use in PWR environments.

An assessment of the use of STB has concluded that there are no adverse effects on the corrosion of zirconium-based alloys and stainless steel which are used in the fabrication of fuel assemblies and core components; therefore, replacement of the sodium hydroxide containment buffer with STB is not expected to have any detrimental effects on the fuel.

STB has been approved for use at PWRs utilizing an ice condenser containment building and at IP2. Although the method for introducing STB to the post-accident containment sump pool differs from that at ice condenser plants (dissolving versus released from melting ice), environmental considerations are not significantly different.

Both systems are passive in nature releasing the buffering agent only in the event of a high energy line break inside containment.

The STB delivery system dissolves the buffering agent during the injection and recirculation phase (when water level reaches the STB) which varies from the current sodium hydroxide delivery system which delivers the buffering agent during injection phase of the accident. This has no effect on the existing dose calculation since the pH is maintained above 7.0.

Minimal or no effects on equipment qualification from the STB are expected based on the Indian Point Unit 2 evaluation for adopting the STB buffering agent (Reference 4).

Isolation of the NaOH tank does not adversely affect the containment water level post-accident (Reference 3).

Attachment 1 Docket No. 50-286 NL-08-041 Page 6 of 10 NUREG-0800 (References 5 and .6) sets a minimum pH of 7.0 for post-accident emergency coolant water to reduce the probability of Stress Corrosion Cracking (SCC) of austenitic stainless steel components, non-sensitized or sensitized, non-stressed or stressed. Replacing the sodium hydroxide buffering agent with STB would not increase the potential for SCC because the STB would ensure that a pH of >7.0 is maintained during recirculation. Additionally, both sodium hydroxide and STB are used as corrosion inhibitors for carbon/low alloy steels (Reference 10).

Application of the WCAP-16530-NP (Reference 9) chemical model for IP3 specific conditions predicted that under LOCA conditions, a reduction from 180 to 110 pounds of sodium aluminum silicate (NaAISi 3O8 ) would be realized if the sodium hydroxide buffer were replaced with STB.

No aluminum oxyhydroxide (AIOOH) or calcium phosphate (Ca 3(PO 4 )2) is formed with either sodium hydroxide or STB. Subsequent to this evaluation, some insulation material was removed, aluminum quantities were reduced, and the debris generation calculation was revised resulting in a predicted precipitate quantity of about 90 pounds of NaA[Si 3O.

4.4 Conclusion Entergy has determined that STB is an acceptable alternative to sodium hydroxide based on industry testing of buffers outlined in WCAP-16596-NP (Reference 1) and through plant-specific application of the chemical model developed in WCAP-16530-NP (Reference 9), as modified. In addition, Entergy has determined that in order to maintain a sump pH of > 7.0 a minimum weight of sodium tetraborate decahydrate of >8,096 pounds is required. A minimum sump pH of 7.0 prevents significant amounts of iodine, released from failed fuel and dissolved in the recirculation water, from converting to a volatile form and evolving into the containment atmosphere. The proposed amendment does not affect the dose analyses, as the initial condition of reducing the amount of re-evolving iodine is achieved by maintaining a sump pH of

> 7.0. Therefore, 10 CFR 50.67 limits during a LOCA would not be exceeded.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by assessing the change using the three criteria of 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response - No The proposed amendment does not involve a significant increase in the probability of an accident previously evaluated because the containment buffering agent is not an initiator of any analyzed accident. The proposed change does not impact any failure modes that could lead to an accident.

Attachment 1 Docket No. 50-286 NL-08-041 Page 7 of 10 The proposed amendment does not involve a significant increase in the consequences of an accident previously evaluated. The buffering agent in containment is designed to buffer the acids expected to be produced after a LOCA and is credited in the radiological analysis for iodine retention. Utilizing STB as a buffering agent ensures the post LOCA containment sump mixture will have a pH > 7.0. The proposed change of replacing sodium hydroxide with STB results in the radiological consequences remaining within the limits of 10 CFR 50.67. There is no dose change with the pH above 7.0.

Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response - No The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. STB is a passive component that is proposed to be used at IP3 as a buffering agent to increase the pH of the initially acidic post-LOCA containment water to a more neutral pH. Changing the proposed buffering agent from sodium hydroxide to STB does not constitute an accident initiator or create a new or different kind of accident previously analyzed. The operation of the Containment Spray System remains the same with the isolation of the sodium hydroxide to the eductors because the flow path of the spray remains constant through the eductors. The proposed amendment does not involve operation of any required systems, structures or components in a manner or configuration different from those previously recognized or evaluated. No new failure mechanisms will be introduced by the changes being requested.

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 change involve a significant reduction in a margin of safety?

Response - No The proposed amendment does not involve a significant reduction in a margin of safety.

The proposed amendment of changing the buffering agent from sodium hydroxide to STB results in equivalent control of maintaining sump pH at 7.0 or greater, thereby controlling containment atmosphere iodine and ensuring the radiological consequences of a LOCA are within regulatory limits. The change of buffering agent from NaOH to STB also reduces the amount of sodium aluminum silicate precipitate thereby reducing the overall amount of precipitate that may be formed in a postulated LOCA. The buffer change would minimize the potential chemical effects and should enhance the ability of the emergency core cooling system to perform the post-accident mitigating functions.

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

Attachment 1 Docket No. 50-286 NL-08-041 Page 8 of 10 Based on the above, Entergy concludes that the proposed amendment to replace the containment sump buffering agent requirement for the use of sodium hydroxide with STB presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Requlatory Requirements/Criteria 10 CFR 50.49 Environmental Qualification of Electrical Equipment Important to Safety Replacing NaOH with STB, as a buffering agent for containment sump pH control, is expected to have minimal or no impact on Equipment Qualification.

10 CFR 50.67 Accident Source Term The regulatory requirements associated with accident assessments are summarized below:

Offsite and Control Room Doses:

An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release should not receive a radiation dose in excess of the accident-specific total effective dose equivalent (TEDE) value noted in RG 1.183, Table 6.

An individual located at any point on the outer boundary of the LPZ who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage) should not receive a radiation dose in excess of the accident-specific TEDE value noted in RG 1.183, Table 6.

" Adequate radiation protection is provided to permit occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem) TEDE for the duration of the accident.

The proposed amendment does not affect the dose analyses, as the initial condition of reducing the amount of re-evolving iodine is achieved by maintaining a sump pH of >

7.0. Therefore, 10 CFR 50.67 limits during a LOCA would not be exceeded. There is no dose change with the pH above 7.0.

5.3 Environmental Consideration The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 1 Docket No. 50-286 NL-08-041 Page 9 of 10 6.0 PRECEDENCE STB is already in use at ice condenser plants (Reference 11) and has a long and acceptable track record. Utilization of STB in place of NAOH as a buffering agent at IP3 serves an analogous function to its use in ice condenser plants, albeit via a different delivery mechanism (dissolution of granular STB versus melting STB ice).

By letter dated August 21, 2006 (ADAMS Accession # ML062340039), as supplemented by letters dated September 6, 2006 (ADAMS Accession # ML062570173), and October 10, 2006 (ADAMS Accession # ML062860428), Omaha Public Power District (OPPD) submitted a license amendment request to utilize STB for Fort Calhoun. By letter dated November 13, 2006 (ADAMS Accession # ML063120248), the NRC approved the license amendment request for OPPD.

Indian Point Unit 2 recently submitted a Technical Specification change from TSP to STB by letter dated October 24, 2007 (TAC NO. MD7182) that was approved by Letter dated February 7, 2008 (TAC NO. MD7182).

7.0 REFERENCES

1. WCAP-1 6596-NP, "Evaluation of Alternative Emergency Core Cooling System Buffering Agents," Revision 0, July 2006.

2. American Institute of Steel Construction (AISC) th Edition

/ 9

3. Westinghouse Letter "Transmittal of Letter LTR-SEE-III-08-13 Indian Point 3 SAT Deletion Evaluation for the Containment Sump Program" dated January 18, 2008 (INT-08-1).

4. Entergy Letter to the NRC "Proposed Changes to the Technical Specifications Regarding Replacement of the Trisodium Phosphate Buffer with Sodium Tetraborate" dated October 24, 2007 (NL-07-077).

5. NUREG-0800, "Standard Review Plan," Section 6.5.2, "Containment Spray as a Fission Product Cleanup System," Revision 4 dated March 2007.

6. Branch Technical Position 6-1 "pH For Emergency Coolant Water for Pressurized Water Reactors" Revision 0 dated March 2007.

7. POLESTAR Proprietary Calculation PSAT3121 CT.QA.03 "Calculation of Post-Accident pH with STB Buffer for Indian Point Unit 3," Revision 0, dated January 4, 2008.

8. LA-UR-05-9177, "Integrated Chemical Effects Test Project: Test #5 Data Report," January 2006.

9. WCAP-16530-NP, "Evaluation of Post-Accident Chemical Effects in Containment Sump Fluids to Support GSI-1 91," Revision 0, as modified by Westinghouse errata letters WOG-06-102, WOG-06-232, WOG-06-273, and the responses to the NRC Requests for Additional Information (RAI) in WOG-06-387

Attachment 1 Docket No. 50-286 NL-08-041 Page 10 of 10

10. Uhlig's Corrosion Handbook, 2 nd Edition. Edited by Revie, R. Winston: John E. Wiley &

Sons, 2000.

11. NUREG-1431, Rev 3, Volume 2, "Standard Technical Specifications, Westinghouse Plants."

12. NRC Letter to Entergy, "Issuance of Amendment Re: Changes to Technical Specifications To Replace Trisodium Phosphate Buffer With Sodium Tetraborate (TAC NO MD7182),"

dated February 7, 2008.

ATTACHMENT 2 TO NL-08-041 MARKUP OF EXISTING TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES REGARDING REPLACEMENT OF THE SODIUM HYDROXIDE BUFFER WITH SODIUM TETRABORATE DECAHYDRATE Bold, italics for added text Strikeout for deleted text Affected Tech Spec Page: 3.6.7-1 3.6.7-2 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

Recirculation pH ControlSrayAdd- .... System 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Recirculation pH Controlpray-Addit System LCO 3.6.7 The Recirculation pH ControlZray-Additive Sysltem shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.: Recirculation pH A.1 Restore Recirculation 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Control aey--Add* ve pH ControlSpay System inoperable. Additive System to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 5. 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify ea. h spray additive m..anual, power 3 d..ays operated, and automfatic valve in the flow pat that is not locked, sealed, itherwis or secured in positien is in the corre(t pcsititnd.

(conti nued)

INDIAN POINT 3 3.6.7-1 Amendment 2G5*

Recirculation pH Control Spray Additive System 3.6.7 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.7.2 Verify spray additive tank sol ution volumcl is 4-84-4aysý SR 3.6.7.3 Verify spray additive tank( Na9H solutien 1-84--da-y.&

concentration is Ž!35% and !538?t by weight.

SR 3.6.7.4 Verify each spray additive autofati valve ing 24 mflnths the flew path that is not lock~ed, sealed, or other-wise-secured in position, actuates tote correct position onl an actual or simfulated actuation signal.

SR 3.6.7.5 Verify spray additive systemn flow fromf each yer SR 3.6.7.1 Perform a visual inspection of the eight 24 months sodium tetraborate storage baskets to verify each of the following:

a. Each storage basket is in place and intact; and,

b. Collectively contain _ 8096 pounds (160 cubic feet) of sodium tetraborate decahydrate, or equivalent.

INDIAN POINT 3 3.6.7 - 2 Amendment No. 20@5

ATTACHMENT 3 TO NL-08-041 MARKUP OF EXISTING TECHNICAL SPECIFICATION BASES PAGES FOR PROPOSED CHANGES REGARDING REPLACEMENT OF THE SODIUM HYDROXIDE BUFFER WITH SODIUM TETRABORATE DECAHYDRATE Bold, italics for added text 8tikeout for deleted text Affected Tech Spec Bases Pages: B 3.6.7-all B 3.6.6- 2 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

Recirculation pH ControlSptyA f'N System B 3.6.7 B 3.6 CONTAINMENT SYSTEMS B 3.6.7 Recirculation pH Control pfy-AdditSystem BASES BACKGROUND The RecirculationpH Control Spfay Additive System is a subsys~ten-effOt Containment SPray System passive safeguard with baskets of sodium tetraborate decahydrate (STB), or equivalent,that assists in reducing the iodinefission product inventory in the containmentatmosphere resultingfrom a Design Basis Accident (DBA).

Radioiodine in its various forms is the fission product of primary concern in the evaluation of a DBA. It is absorbed by the spray from the containment atmosphere.

To enhance the iodine abseirptiein retention capacity of the spray during recirculationfrom the sump, the spray solution is adjusted to an alkaline pH that promotes iodine hydrolysis, in which iodine is converted to nonvolatile forms.

RBeeatis of its stability wheii erxnrsd to Fadiatiei and elevated t.mne.at..

. . .diiim hydr-xide (NaOH) is the preferred sprhay additi.e. The sodium tetraborate decahydrate (STB)O. added to the spray also ens ures an alkalmne pi-i of tne solution re*ir.ulated from the containment su.mp. is stored in baskets in the containment building. The initial spray, a boric acid solution from the refueling water storage tank has a pH of about 4.5. As the initial spray solution and, subsequently the recirculation solution comes in contact with the STB, the STB dissolves raisingthe pH of the sump solution. Reference 2 indicates that the pH should be between 7.0 and 9.5 and that the potentialfor increasedhydrogen generationfrom aluminum should be addressedatpHgreaterthan 7.5. An alkaline pH minimizes the evolution of iodine as well as the occurrence of chloride and caustic stress corrosion on mechanical systems and components.

The Spray Additive System consists of one spray additive tanik that is shared by the two trains of containment spray. Each train prvie a floew path from~ the spray tan to a conitainm~fent spray pumap and consists of an eductor for each containiment spraty pump, valves, instrumentation, and coninecting piping. Each eductor dr-aws the NaOH4 spray solution from the commont tanik usinig a peffien of the borated water

,discharged by the containment spray pump as the motive flow. The eduetor miixes the NaOH4 solution and the borated water and dischar-ges the mixture into the spray pumfp suction line. The eduetors are dlesigned to ensure that the pH of the spray mixture is between 9.0 and 10.0.

The Containm-ent Spray System actuation signal opens the valves from the spray additive tank to the spray pump sutions aftea2 minu(te delay. The 35% to 38%

NaCH4 solution is drawn into the spray pum utos The spray additive tank eapaeity provides for the-(continued)

I INDIAN POINT 3 B 3.6.7 - I Revisim 2

RecirculationpH Control Spray Additive System B 3.6.7 BASES BACKGROUND addition of NaoH solution. t. all of the water sprayed from the RWST (continued) into

.. ontainmf.en.t via the Containment Spray S......l. The p solution and

-ercent volflumne of sollution sprayed inite eeontainmient enslures a minimuml long terlm equilibriaum containmient sump pH4 of approximately 8.0. This enisures The ccntinuled iodinie retention effectiveness of the sumnp water during the recircuilation phase oe spray oper-ation and also minimizes the occurrfence of chloride induced stress

~orrsioncraking of the stainiless steel recirculaticn pipfing.

APPLICABLE SAFETY ANALYSES The Spray Additive System, incnucion with the Fan Cooler- Systema, is essenitial to the r-emoval o-f -Airborfn e i 6 dine within conitaiinment following a DBA.

Following the assumed release of radioactive materials into containment, the containment is assumed to leak at its design value volume following the accident.

The analysis assumes that 80% of containment is covered by the spray (Ref. I). The pH of the initialsprayfrom the RWST is about 4.5.

The RecirculationpH Control System is a passive safeguard with the baskets of STB located in the containment. The initialspray solution and subsequently the recirculationsolution come in contact with the STB in the baskets and dissolves to raise the pH. The RecirculationpH System is OPERABLE when there is sufficient STB available to guaranteea sump pH of _7.0 during the recirculation phase of a postulated LOCA. Calculation of pH was performedfor STB. The mass of STB requiredto provide an equilibrium sump pH solution of about 7.1 is 8,096 pounds. A 10,000 mass of STB provides a sump pH of about 7.2.

The DBA response timfe assumed for the Spray Additive System is the samne as for the Containment Spay System (plus a 2 minute delay) anId is discussed in the Bases for LCO 3.6.6, "Containmlent Spray anid Fan Cooler System."

The DB3A analyses assume that one tr-ain of the Containment Spr-ay Systemn is inoeperable and that the spray additiv~e is added to the remaininig Conitainmlent Spray Syse-lflow paýh The Recirculation pH Control *a)-Additive System satisfies Criterion 3 of 10 CFR 50.36.

LCO The RecirculationpH Control Sgpray-Addifive System reduces the release of radioactive material to the environment in the event of a DBA. To be considered OPERABLE, the STB baskets must be in place and intactand collectively contain

>8,096pounds (160 cubic feet) of STB or equivalent, volume and concentration of the spray additive solution must be sufficient to provide NaOH ijecti(on into the spray flew~ until the Conitainmenit Spray Syste sc ionpth is switched from the RWAST to the recirculation sum orcnanetmandtoraisethe average (continued)

INDIAN POINT 3 B 3.6.7 -- 2 Revisiontl

RecirculationpH Control SpayAdditi-e System B 3.6.7 BASES

[CO spfdy solution pH4 to a level coniducive to iodine r-emoval, namely, to (continued) between 7.9 and 10.0. This pH range maxi.. ize. . the. ffe.ti.... n of. the iodin.e removal mechanism, without initrdueing .ondition*s that m.ay in.du.e eaustie stress

xlolosi rack*ing of mnechanieal system components. in addit*in, it is essential that valves in the Spray Additive Systemn flew~ paths are properly positionied and that auteomatic valves are capable of activating to their correct positions.

APPLICABILITY In MODES 1, 2, 3, and 4, a DBA could cause a release of radioactive material to containment requiring the operation of the RecirculationpH Control Spray-Additi-ve System. The RecirculationpH Control Sp-ay-Additi-ve System assists in reducing the iodine fission product inventory prior to release to the environment.

In MODES 5 and 6, the probability and consequences of these events are reduced due to the pressure and temperature limitations in the)se MODES. Thus, the RecirculationpH Control Spray Additive System is not required to be OPERABLE in MODE 5 or 6.

ACTIONS A. I If the RecirculationpH Control Spray Additive System is inoperable, it must be restored to OPERABLE within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The pH adjustment of the Containment Spray System..flow for corrosion protection and iodine removal enhancement is reduced in this condition. The Containment Spray System and Containment Fan Cooler System are available and would remove iodine from the containment atmosphere in the event of a DBA. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the redundant flow path capabilities and the low probability of the worst case DBA occurring during this period.

B.I and B.2 If the RecirculationpH Control Spray Additi System cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the (continued)

INDIAN POINT 3 B 3.6.7 -- 3 Revision-4

RecirculationpH Control Spray Additive System B 3.6.7 BASES ACTIONS B.I and B.2 (continued) plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for restoration of the RecirculationpH Control SpFay Addii-ve System in MODE 3 and 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to reach MODE 5. This is reasonable when considering the reduced pressure and temperature conditions in MODE 3 for the release of radioactive material from the Reactor Coolant System.

SURVEILLANCE REQUIREMENTS SR 3.6.7.1 This SR provides visual verification that each of the eight storage sodium tetraboratebaskets is in place and intact and collectively contain > 8,096 pounds (160 cubicfeet) of sodium tetraboratedecahydrate,or equivalent. This amount of STB is sufficient to ensure that the recirculationsolutionfollowing a LOCA is at the correctpH level. The 24 month frequency is sufficient to ensure that the stainless steel baskets are intact and contain the appropriateamount of STB.

Verifying the eorr-eet alignment of Spray Additive System manual, power operated, and automfatic valves in the spray additive flow path provides assurance that the system is able to provide additive to the Containment Spr-ay Systemf in the event of-a DBA. This SR does noet apply to valves that are locked, sealed, or otherwise secured inpositineine these valves wAere verified to be in the correct positionl prior tO lockinig, Sealing or serig. This SR does not requirfe any testing orfav manipulation. Rather, it involves verification, throuigh a System walkdown, that these valve etside een taiinment and capable of potentially being mispcsiticned are in the correctpoion SR--3-46 To proevide effective iodine remoival, the conitaiinment spray mfust be an alkaline selutien. Since the RWST contents are norfmally acidic, the 'volumfe of the spray additiv~e tank must provide a sufficient volume of spr-ay additive to ad~just pH for all w'ateF injected. This SR is per-formed to verify the availabIlity of sufic2ient NaOH solutien in the Spray Additive System. The 184 day FrFequencey was developed based on the low' probability' of an undctected change in tank volume (continued)

INDIAN POINT 3 B 3.6.7 -- 4 Revism

RecirculationpH Control Spray Additive System B 3.6.7 BASES SURVEILLANCE REQUIREMENTS SR-: 3.6.7 (eontinuied) occurrinig dur~ing the SR interval (the tank is isolated durfing noermal unit aperatiefns).

Tank level is also inidicated and alar-med in the control room, so that there is high eanfidenee that a substantial change in level would be detected.

SR-3-.6,74 This SR provides verificatien of the NaOH4 coneentration in the spray additive tank and is sufficient to enisure that the spray solution beinig in~jeeted inito containmffent is at the corr-ect p14 level. The 184 day Freuencyis su.fficaient to enlsure that the eoneneftratien level of NaOH4 in the spray, additive tank remains withinth established limfits. This is based on the low likelihood of an uncontr-olled change in eaneentfation (the tank is nor~mally, isolated) and the probability that anly Substantial Yarianee in tank volume will be detected.

SR=-3&j47 This SR proevides verification that each automatic valve in the Spr-ay Additive Syste flow path actuiates to its cfectpsiin This Survweillance is not required for-valves that are locked, sealed, Or Eotherwise See ured in the Fequir-ed position une administrative controels. The test is performed with the isolation valves in the spraytj supply lines at the containment and the spray additive tank isolation valves blocked 4eleed.

The 24 moneth Frequency is based on the need to performn this Surveill-ance under- the eondifiens that apply durfing a planit outage and the potential for an unplanned transient if the Surveillancewee peffomed with the r-eactor- at power. Oper-ating experiefiee has shown that these components usuially pass the Surfveillancee when per-formed at the 24 monfth Freqjuency.I (continued)

INDIAN POINT 3 B 3.6.7 -- 5 Revision 4

RecirculationpH Control Spray Additi-'e System B 3.6.7 BASES SURVEILLANCE REQUIREMENTS SR 3.6. 7. (continued)

Therefore, the Frequency' was eeoncluded to be aeeeptable fromn a reliability' Standpoit

&R--3-.6.7 To enisur-e that the eorreet pH4 level is established in the borated water selutien proevided by' the Conttainm~ent Spr-ay'Sy'stem, flow in the Spray' Additive Sy'stem is Yerifiedoenee every'5 yeaFS. This SR provides assuranee that NaOH wil b inltrodueed into the flew path upon Containmffent Spray' Sse intitn. This test is satisfied by' a verificatiOn Of spray' additive sy'stemi flow, without pumping any' NaOH4 selutien fromf the spr-ay' additive tank and without dr-aininig the spray' additive tank.

Water may' be used in lieu of NaOH4 for-the peffor-manee ef this SR which is not initenided to requir~e the transfer of NaOH4. Due to the passive niature of the spray' flowcotros, the 5 year Frequency' is sufficient to identify' componenit additive degradation that maay' affeet flowIA.

REFERENCES 1. FSAR, Chapters 6 and 14.

2. NUREG-0800, "StandardReview Plan," Section 6.5.2, "ContainmentSpray as a Fission ProductCleanup System,"

Revision 4 dated March 2007 containing Branch Technical Position 6-1 "pH For Emergency Coolant Water for PressurizedWater Reactors" Revision 0 dated March 2007.

INDIANPOINT3 B 3.6.7 -- 6 Revisin4

Containment Spray System and Containment Fan Cooler System B 3.6.6 BASES BACKGROUND After the Refueling Water Storage Tank has been exhausted, the (continued) containment recirculation pumps or the Residual Heat Removal (RHR) pumps are used to supply the Containment Spray ring headers for the long-term containment cooling and iodine removal during the containment recirculation phase. In this configuration, the RHR heat exchangers provide the necessary cooling of the recirculated containment spray.

The Containment Spray System provides a spray of cold borated water mixed with s*dium hydroxide (NaOt ) fr. m the spray additive tank-into the upper regions of containment to reduce the containment pressure and temperature. Additionally, these systems reduce fission products from the containment atmosphere during a DBA. The RWST solution temperature is an important factor in determining the heat removal capability of the Containment Spray System during the injection phase. In the recirculation mode of operation, heat is removed from the containment sump or recirculation sump water by the residual heat removal heat exchangers.

Both trains of the Containment Spray System are needed to provide adequate spray coverage to meet the system design requirements for containment heat removal assuming the Fan Cooler System is not available.

The Spray Additive System.n injeets an NaoH solation into the spray. The RecirculationpH ControlSystem functions by dissolving STB into the ContainmentSpray water. The resulting alkaline pH of the spray enhances the ability of the spray to scavenge fission products from the containment atmosphere. The NaOHI added STB dissolved in the spray water a4se ensures an alkaline pH for the solution recirculated in the containment sump.

The alkaline pH of the containment sump water minimizes the evolution of iodine and minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid.

The Containment Spray System is actuated either automatically by a containment High-High pressure signal or manually. An automatic actuation starts the two containment spray pumps, opens the containment spray pump discharge valves, and begins the injection phase. A manual actuation of the Containment Spray System requires the operator to actuate two separate push buttons on the main control board to begin the same sequence. The injection phase continues until the RWST water supply is exhausted. After the Refueling Water Storage Tank has been exhausted, the containment recirculation pumps or the (continued)

INDIAN POINT 3 B 3.6.6 -- 2 Revision2

Text

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, N.Y. 10511-0249 11112 Tel (914) 734-6700 J.E. Pollock Site Vice President Administration February 28, 2008 Re: Indian Point Nuclear Generating Unit No. 3 Docket No. 50-286 NL-08-041 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, D.C. 20555-0001

SUBJECT:

Proposed Changes to the Technical Specifications Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate

REFERENCES:

1) NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors," dated September 13, 2004.

2), Entergy Letter NL-07-129, "Revised Request for Extension of Completion Date for Indian Point Unit 3 Corrective Actions and Modifications Required by Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors"" dated December 3, 2007.

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc. (Entergy) hereby requests an amendment to the Operating License for Indian Point Nuclear Generating Unit No. 3 (IP3), to replace the containment buffering agent from sodium hydroxide (NaOH) to sodium tetraborate decahydrate (STB). The purpose of this change is to minimize the potential for sump screen blockage concerns under post loss-of-coolant accident conditions due to a potential adverse chemical interaction between NaOH and certain insulation materials used in containment. This request is an integral part of Entergy's resp~onse to GL 2004-02 (Reference 1) and represents one of the remaining modifications required to achieve full compliance with the requirements of GL 2004-02 as documented in Reference 2.

Indian Point Unit 3 Docket No. 50-286 NL-08-041 Page 2 of 2 Entergy has evaluated the proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92(c) and has determined that this proposed change involves no significant hazards considerations as described in Attachment 1. The proposed changes to the Technical Specifications are shown in Attachment 2. The associated TS Bases changes are provided in Attachment 3 for information. 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.

Entergy requests approval of the proposed amendment as soon as possible with implementation to occur no later than June 30, 2008. There are no new commitments identified in this submittal. If you have any questions or require additional information, please contact Mr.

R Walpole at (914) 734-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February 2**, 2008.

Sincerely, J. E. Pollock Site Vice President Indian Point Energy Center Attachments:

1: Analysis of Proposed Changes to the Technical Specifications Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate 2: Markup of Existing Technical Specification Pages for Proposed Changes Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate 3: Markup of Technical Specification Bases Pages for Proposed Changes Regarding Replacement of the Sodium Hydroxide Buffer with Sodium Tetraborate Decahydrate cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DOLR Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector's Office, Indian Point Unit 3 Mr. Paul D. Tonko, President, NYSERDA Mr. Paul Eddy, New York State Department of Public Service

ATTACHMENT 1 TO NL-08-041 ANALYSIS OF PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS REGARDING REPLACEMENT OF THE SODIUM HYDROXIDE BUFFER WITH SODIUM TETRABORATE DECAHYDRATE ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

Attachment 1 Docket No. 50-286 NL-08-041 Page 1 of 10

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc. (Entergy) requests an amendment to the Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3) by revising Technical Specification (TS) 3.6.7, "Spray Additive System".

Entergy intends to replace the sodium hydroxide as the buffering agent for pH control during recirculation with sodium tetraborate decahydrate (Na 2B4OT.10H 2 0), hereinafter called sodium tetraborate (STB). The purpose of this change is to minimize the potential for sump screen blockage concerns under post loss-of-coolant accident (LOCA) conditions due to a potential adverse chemical interaction between sodium hydroxide and certain insulation materials used in containment. The use of sodium hydroxide ensures an alkaline pH for the solution recirculated in the containment sumps. The alkaline pH minimizes the evolution of iodine and minimizes the occurrence of chloride and caustic stress corrosion on mechanical systems and components exposed to the fluid. The proposed use of STB serves this same function, maintaining the intent of the TS, but results in less predicted precipitate generation and resultant sump screen blockage.

2.0 PROPOSED CHANGE

The Indian Point Unit 3 TS 3.6.7 will be revised as follows:

Change the TS name from "Spray Additive System" to "Recirculation pH Control System"

Change the LCO from "The Spray Additive System shall" to "The Recirculation pH Control System shall"

Change Condition Aland Required Action A.1 from "Spray Additive System" to "Recirculation pH Control System"

Delete existing SR 3.6.7.1 to 3.6.7.5 and replace them with new SR 3.6.7.1 that reads: