NL-12-029, Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System Is Out of Service

Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System Is Out of Service

ML12060A322
Person / Time
Site:	Indian Point
Issue date:	02/06/2012
From:	Ventosa J Entergy Nuclear Northeast
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-029
Download: ML12060A322 (17)

Text

z-Entergy Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President Administration February 6, 2012 NL-12-029 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System is Out of Service Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) hereby requests a License Amendment to Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment will revise the Updated Final Safety Analysis Report (UFSAR) to allow use of the Backup Spent Fuel Pool Cooling System (BSFPCS) when the Spent Fuel Pool Cooling System (SFPCS) is out of service.

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 Entergy has determined that this proposed change involves no significant hazards considerations, as described in Attachment 1. The proposed changes to the UFSAR are shown in Attachment 2-The calculation associated with this submittal is found -in. 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 in 12 months with 30 days allowed for implementation. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 254-6710.

pt

NL-12-029 Docket No. 50-286 Page 2 of 2 ZI declare under penalty of perjury that the foregoing is true and correct. Executed on February

_!__2, 2012.

Sincerely, JAV/sp Attachments:

1. Analysis of Proposed Updated Final Safety Analysis Report Change Regarding Backup Spent Fuel Pool Cooling System

2.

Markup of Updated Final Safety Analysis Report to Reflect Proposed Changes Regarding Backup Spent Fuel Pool Cooling System

Enclosure:

1.

IP-CALC-10-00121 Backup Spent Fuel Pool Cooling System (BSFPCS)

Hear Removal Capability cc:

Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspector, IP3 Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-12-029 ANALYSIS OF PROPOSED UPDATED FINAL SAFETY ANALYSIS REPORT CHANGE REGARDING BACKUP SPENT FUEL POOL COOLING SYSTEM ENTERGY NUCLEAR OPERATIONS, INC.

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

NL-12-029 Docket No. 50-286 Page 1 of 9

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc (Entergy) is requesting an amendment to Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed change will revise the Updated Final Safety Analysis Report (UFSAR) to allow use of the Backup Spent Fuel Pool Cooling System (BSFPCS) when the Spent Fuel Pool Cooling System (SFPCS) is out of service.

2.0 PROPOSED CHANGE

S The proposed change will revise the UFSAR to describe the BSFPCS and the limitations on use.

Section 9.3.3 will be revised:

Change The Backup Spent Fuel Pool Cooling system has been installed to allow for operation in parallel with the Normal SFP Cooling System to improve pool conditions during refueling activities. The BSFPCS is a manual system served by an independent cooling water source (demineralized water). A primary loop handles the SFP water and consists of two 100% capacity pumps, a plate heat exchanger, associated piping, and local instrumentation. A secondary loop is the heat sink for the system, and includes two, open-circuit evaporative cooling towers, two 100 % capacity feed pumps, associated piping, and local instrumentation. Make-up and fill for the secondary loop is normally provided by demineralized water, with an alternate, emergency source available through the Fire Protection System.

Power for all equipment is supplied from the 480 VAC MCCs El and E2. For greater availability of power, and reliability of the cooling function, the BSFPCS includes a transfer switch that allows alignment to either the normal power sources MCC El and E2, or a rental diesel generator unit (with Engineering discretion). This feature allows an alternate power source in the event the MCCs become inoperable.

To The Backup Spent Fuel Pool Cooling system has been installed to allow maintenance and repair and operate in parallel with the Normal SFP Cooling System to improve pool conditions during refueling activities (see Section 9.13).

A new BSFPCS section will be added:

9.13 Backup Spent Fuel Pool Cooling System 9.13.1 Design Bases The Backup Spent Fuel Pool Cooling System (BSFPCS) has been installed to allow maintenance and repair and to operate in parallel with the normal SFP Cooling System (SFPCS) to improve spent fuel pool (SFP) conditions during refueling activities. The BSFPCS is designed to extend the period of time the SFPCS could be taken out of service during periods of maximum heat load (a full-core offload completed no earlier than 254 hours0.00294 days <br />0.0706 hours <br />4.199735e-4 weeks <br />9.6647e-5 months <br /> subcritical).

NL-12-029 Docket No. 50-286 Page 2 of 9 9.13.2 System Description The Backup Spent Fuel Pool Cooling System (BSFPCS) consists of a primary loop and a secondary loop. The primary loop handles the SFP water. The secondary loop is the system heat sink. The primary loop components are located in the Fuel Storage Building (FSB). The secondary loop components are located both inside the FSB and routed outside to the waste holdup tank pad where the cooling towers are located.

The primary loop takes suction from the SFP using one of two BSFPC pumps (primary loop), flows through the BSFPC plate heat exchanger (HX) and returns to the SFP. The BSFPC pumps (primary loop) are 100 percent capacity, 25 horsepower primary loop pumps designed for 1500 gpm at 45 feet of head. The primary loop pumps are locally controlled and the local control station has red and green status lights. There are duplicate status lights at the secondary loop pump control station. Disconnect switches for the motors have padlocks to ensure only one motor is energized at a time. System piping is stainless steel.

The secondary loop takes suction from the two BSFPC open-circuit evaporative cooling towers, flows through the BSFPC HX and returns to the cooling towers. The secondary loop has two 100 percent capacity, 200 horsepower secondary loop pumps rated for 2500 gpm each at 192 feet of head. There are red and green status lights at the control station.

Disconnect switches for the motors have padlocks to ensure only one motor is energized at a time.

The BSFPCS heat exchanger is a plate and frame type. The secondary loop is maintained at a higher pressure than the primary loop to prevent leakage from the SFP into the secondary loop. Each primary pump receives a trip signal when the differential pressure is less than 10 psid. The secondary loop pump remains running to preclude a leak path from the primary loop into the secondary loop. Differential pressure less than 10 psid also illuminates yellow status lights at the primary and secondary loop pump control stations.

The secondary loop cooling towers are two 50 percent capacity, open-circuit evaporative cooling towers. Each tower has a fan that pulls air over the water as it is sprayed over the fill material to assist cooling by evaporation. The fans cycle independently, depending on the temperature at the outlet of the cooling towers. The first fan will start at.71 OF and stop at 700F. The second fan will start at 760F and stop at 750F. The tower also functions as a container for the water in the secondary loop. Makeup water is supplied from the Demineralized Makeup Water System (DMWS) line going to the Primary Water Storage Tank (PWST). Emergency Make up is from the fire protection system. There is hard piping from both the DMWS and fire protection piping for the cooling tower makeup. The water treatment system, common to both IP2 and IP3, provides makeup to the DWMS. Fill requirements are 1600 gallons with a maximum required makeup of 72 gpm. The secondary system is stainless steel to prevent corrosion.

Pressure and temperature indicators are provided locally at pump discharges and on the plate heat exchanger discharges to evaluate proper operation. Their ranges are consistent with maximum operating conditions. A temperature element in the cooling tower basin and associated controls will regulate cooling tower fans as necessary for efficient operation.

NL-12-029 Docket No. 50-286 Page 3 of 9 The spent SFP local temperature indication is also available to monitor pool conditions.

Normal power to the BSFPCS is supplied from 480 VAC MCC El via Power Panel PP-582 (primary pumps) and 480 VAC MCC E2 (secondary pumps). There is a transfer switch that allows power to the BSFPCS to be supplied from a portable diesel generator.

The system will be kept in dry layup most of the time and has been designed to accommodate this. Typically, the BSFPCS will only be used during refueling outages in order to supplement the SFPCS by reducing the SFP temperature to as low as feasible.

During maintenance and repairs the BSFPCS may be used as the sole source of cooling.

This is expected to be infrequent.

9.13.3 Safety Evaluation The BSFPCS is not designed seismic I or for a tornado event. The system is designed to preclude seismic interaction with the spent fuel pool and its components. The primary loop has Seismic II supports. The secondary loop is designed in the same manner from the heat exchanger to the first isolation valves on the inlet and outlet piping. The cooling towers also have seismic II supports.

Failures in the system piping due to seismic events, tornados or moderate energy line breaks do not cause unacceptable interactions. The lines are moderate energy because the operating pressures are about 17 to 85 psig and the temperatures are all below 142 OF, except for the primary pump discharge to the heat exchanger at 190 OF. Primary and secondary side piping has a design pressure and temperature of 21 Opsig and 300°F (the secondary side fill and makeup supplies are 150 psig and 5000F). Also, pump shutoff head pressures are less than 100 psig. A moderate energy line break would not affect equipment. A moderate energy piping break on the pump discharge would be different than one on the SFPCS. The BSFPCS does not have an anti-siphoning hole in it's suction line at the 93 feet 1 inch elevation like the SFPCS, but the bottom of the suction line is at 87 feet 8 inch which is well above the SFPCS suction line at 74 feet 4-3/4 inch. This would allow an additional SFP reduction of 5 feet 5 inches but would not affect the ability to provide makeup to preclude pool boiling.

The system is normally run as backup to the SFPCS to provide enhanced cooling during outages. Under these conditions the BSFPCS is an enhancement and not credited to meet the design basis cooling requirements. During periods that the SFPCS is taken out of service for necessary maintenance or repair the BSFPCS may be used to cool the SFP as a stand-alone system provided the limitations for such use, described below, are met.

The potential for loss of offsite power during periods when the BSFPCS is the only cooling in place will be accommodated by a backup diesel that would be temporarily brought in.

The backup diesel will be required for those cases where the scheduled work exceeds the time to raise the temperature to boiling without cooling.

The BSFPCS can maintain the SFP bulk temperature at 1750F per calculation IP-CALC 00121 with the heat loads and wet bulb temperatures shown below:

NL-12-029 Docket No. 50-286 Page 4 of 9 Wet Bulb Temperature [F]

Heat Load [BTU/Hr] at 1750F 40 36,451,000 45 35,622,000 50 34,938,000 55 34,146,000 60 33,425,000 65 32,525,000 70 31,696,000 75 31,048,000 Administrative controls will be in place to assure that the BSFPCS is used as the sole source of heat removal only under the following conditions:

1. Work will be scheduled when the SFP heat load is at a reduced value rather than the design value.

2. A backup diesel will be tested and made available where the scheduled work exceeds the time to raise the temperature to boiling without cooling.

3. The SFP will be brought to temperature as low as feasible, but not lower than the design temperature, prior to starting the work.

4. The wet bulb temperature is at or below the temperature that will keep the SFP below 1750F for the residual heat load at the time work starts.

9.13.4 Inspection and Testing Requirements The BSFPCS is put into layup and taken out of layup in accordance with plant procedures. The system is functionally tested prior to being placed into service.

3.0 BACKGROUND

The existing spent fuel pit pump and heat exchanger will handle the decay heat load from a partial core offload (which is defined as an off load which maintains the Spent Fuel Pit heat load below 17 x 106 BTU/hr) while maintaining the spent fuel pit water temperature below 1500F. With a full core discharge the water temperature is maintained below 200°F with service water temperature of 950F. The UFSAR says "This manually controlled loop may be shutdown safely for reasonable time periods, as shown in Table 9.3-3, for maintenance or replacement of malfunctioning components." These capabilities are based on no movement of irradiated fuel in the reactor until the reactor has been subcritical for at least 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> and an additional delay time prior to spent fuel discharge is administratively controlled by operating procedures so the full-core offload is completed no earlier than 254 hours0.00294 days <br />0.0706 hours <br />4.199735e-4 weeks <br />9.6647e-5 months <br />.

Spent Fuel Pit bulk temperature is calculated assuming one of the two Spent Fuel Pit coolant pumps are in service. No credit is taken for heat loss to the pool liner, slab, concrete walls or the air, nor is credit taken for heat loss through evaporation. The 84 hour9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> decay time and the 23 feet of water above the top of the stored spent fuel are also consistent with the assumptions used in the dose calculation for the fuel handling accident.

NL-12-029 Docket No. 50-286 Page 5 of 9 It should be noted that the use of the Backup Spent Fuel Pool Cooling System (BSFPCS) can significantly reduce pit temperature. Although the BSFPCS is not credited in the Spent Fuel Pit thermal hydraulic analysis, it is a useful tool for maintaining working conditions in the vicinity of the Spent Fuel Pit and for keeping the pit temperature below 150OF during partial and full-core off loads.

The BSFPCS was originally designed and placed into service as a stand-alone system using the 10 CFR 50.59 process. In 2001, the NRC required the BSFPCS to be approved by NRC for standalone use and had concerns with a loss of power event and the adequacy of the makeup to the cooling towers. The makeup to the cooling tower has been improved since that time by piping the makeup and a backup makeup line to the system. The BSFPCS has not been used as a stand-alone system since the NRC's 2001 regulatory decision.

Maintenance is planned for the next outage which will require the SFPCS to be out of service and the allowed usage of the BSFPCS as a stand-alone system will allow maintenance to be performed.

4.0 TECHNICAL ANALYSIS

The BSFPCS is described in Section 2 as part of the proposed FSAR change. The approval of the BSFPCS to provide standalone cooling for the SFP when the SFPCS is out of service provides additional margin for those times when it is taken out of service for maintenance or repair of the SFPCS or the supporting systems. Some repairs for supporting systems can only be performed during refueling outages. This is at a period of when the heat load in the SFP is at its highest. The FSAR Sections 9.3.3.1.3 and 9.3.3.2.3 currently allow the SFPCS to be taken out of service for maintenance and repair with no backup and the spent fuel pool is designed to allow resumption of cooling with the SFP at 212 0F. The BSFPCS provides the means to cool the SFP during this period. If the maintenance and repair were determined to be longer than the time to boil then the BSFPCS would allow the work to be done rather than just delay it or seek relief from the requirements.

Neither the SFPCS nor the BSFPCS mitigate accidents and are not associated with the initiation of any accidents. During an accident the SFPCS will be a heat load for the component cooling water system, which supports it. The BSFPCS will reject heat to the air. The existing design considers failure of the SFPCS and provides for makeup to the SFP as a means for cooling and maintaining level. The same would be true for BSFPCS failure.

The BSFPCS meets many of the same design criteria as the SFPCS:

The BSFPCS is not designed for a seismic event or a tornado. It is designed to preclude seismic interaction with the spent fuel pool and its components.

The BSFPCS is not single failure proof but it does have redundant primary and secondary side pumps.

Moderate energy line breaks do not cause unacceptable interactions. The lines are moderate energy because the operating pressures and temperatures are about 17 to 85 psig and the temperatures are all below 142 OF, except for the primary pump discharge to the heat exchanger at 190 OF. Also, pump shutoff head pressures are less than 100 psig.

NL-12-029 Docket No. 50-286 Page 6 of 9 The SFPCS can be loaded on the EDG should offsite power be lost. A backup diesel will be made available and performance tested whenever the scheduled work exceeds the time to raise the temperature to boiling without cooling.

The SFPCS can take suction from the SFP when the water is boiling while the BSFPCS cannot. The primary and secondary loop pumps have design flow rates of 1500 gpm and 2500 gpm with a total developed head of 45 feet and 192 feet, respectively. These pumps have shutoff heads of less than the system design pressure of 150 psig. The primary pumps have a required NPSHR of 5.2 feet at the design flow of 1500 gpm and a fluid temperature of 1910F. The available NPSHA at 1500 gpm and 190°F fluid is 8 feet. The secondary side pumps have a required NPSHR of 13.1 feet at the design flow of 2500 gpm and a basin fluid temperature of 900F. The available NPSHA at 2500 gpm and 90°F basin fluid is 26 feet.

The BSFPCS is normally run as backup to the SFPCS to provide enhanced cooling during outages. Under these conditions the BSFPCS is an enhancement and not credited to meet the design basis cooling requirements. During periods that the SFPCS is taken out of service, the BSFPCS will maintain the SFP within 1750F to prevent the SFP from boiling. The BSFPCS can maintain the SFP bulk temperature at 1750F and 150°F per calculation I P-CALC-10-00121 with the heat loads and wet bulb temperatures shown below:

Wet Bulb Temperature [OF]

Heat Load [BTU/Hr] at 1750F Heat Load [BTU/Hr] at 150°F 40 36,451,000 27,482,000 45 35,622,000 26,618,000 50 34,938,000 25,933,000 55 34,146,000 25,141,000 60 33,425,000 24,421,000 65 32,525,000 23,520,000 70 31,696,000 22,692,000 75 31,048,000 22,044,000 The decay heat load assuming a full core discharge and previously discharged assemblies is determined consistent with USNRC Standard Review Plan, Branch Technical Position ASB 9-2.

This heat load and the heat up rate with a total loss of cooling were determined in a generic calculation:

Total Decay Heat Load Heat up Rate on Loss of Days after Shutdown

[full core + previously Cooling

[day]

discharged assemblies]

[0F/hour]

[MBTU]

6 42.93 17.9 8

38.82 16.2 10 36.12 15.1 12 34.14 14.3 14 32.56 13.6 16 31.24 13.1 18 30.07 12.6 20 29.05 12.1

NL-12-029 Docket No. 50-286 Page 7 of 9 25 26.86 11.2 30 25.08 10.5 40 22.41 9.4 An example of how the BSFPCS will be put into service is shown by the Inspection of the' above two tables. These show that the BSFPCS is capable of removing more heat than is generated after being shutdown for 16 days with a wet bulb temperature of 70OF or less while maintaining the bulk SFP temperature below 1750F.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (Entergy) has evaluated the safety significance of the proposed change to the Indian Point 3 Final Safety Analysis Report that allows use of the Backup Spent Fuel Pool Cooling System as a stand-alone system when the Spent Fuel Pool Cooling System is out of service. This proposed change has been evaluated according to the criteria of 10 CFR 50.92, "Issuance of Amendment'. Entergy has determined that the subject change does not involve a Significant Hazards Consideration as discussed below:

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

No. The proposed changes revise the Updated Final Safety Analysis Report (UFSAR) to allow using the Backup Spent Fuel Pool Cooling System (BSFPCS) as a stand-alone system when the Spent Fuel Pool Cooling System (SFPCS) is out of service for maintenance and repair. The SFPCS is allowed to be taken out for maintenance and repairs. The current design, if the SFPCS were out of service due to maintenance, repair or failure, would be to add make up water to the SFP to provide cooling and prevent loss of water level due to boiling. The use of the BSFPCS during times when the SFPCS is out of service for maintenance and repairs provides alternate cooling to limit the SFP temperature during these periods. The failure of the SFPCS and the addition of water is not an accident and consequences are not evaluated. Therefore, the BSFPCS does not mitigate consequences of an accident previously evaluated. Similarly, the BSFPCS is not the initiator of any accident.

Therefore the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

No. The proposed changes revise the UFSAR to allow using the BSFPCS when the SFPCS is out of service for maintenance and repair. The proposed changes involve the use of alternate equipment but failures do not result in different consequences from those of the existing system. The proposed revision to use the BSFPCS as a stand-alone system is not a change to the way that existing equipment is operated. The change involves the use of an alternate cooling system but the design is not associated with accident initiation so no

NL-12-029 Docket No. 50-286 Page 8 of 9 new accident initiators are created. The proposed change involves administrative controls to assure the system capability.

Therefore the proposed change 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?

No. The proposed changes revise the UFSAR to allow using the BSFPCS as a stand-alone system when the SFPCS is out of service for maintenance and repair. The SFPCS is considered more robust than the BSFPCS in terms of its capability to restore operation with a hotter spent fuel pool. However, the BSFPCS will be used as a stand alone system only when taking the SFPCS out of service for maintenance and repair. The current allowance is to take the SFPCS out of service for repairs so the BSFPCS will provide margin to reduce the likelihood of SFP boiling. While in service, a postulated moderate energy line break in the BSFPCS can increase the amount of water that can be lost from the SFP. However, the reduced level does not affect the ability to supply makeup water to the SFP to raise the level and provide cooling so there is no significant reduction in the margin for safety.

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

Based on the above, Entergy concludes that the proposed amendment to the Indian Point 3 FSAR 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 Regulatory Requirements / Criteria General Design Criterion (GDC) 2, contained in Appendix A to 10 CFR Part 50, requirements for the capability to withstand the effects of natural phenomena such as earthquakes, tornadoes, and hurricanes. This will continue to be met since compliance is based on the compliance of the fuel pool makeup water supply.

GDC 4 requirements for the capability of the system and the structure housing the system to withstand the effects of external missiles. This will continue to be met since compliance is based on the same design criteria as the SFPCS (not protected from tornado missiles).

GDC 5 requirements for shared systems and components important to safety being capable of performing required safety functions. This will continue to be met since the BSFPCS and its components are not shared.

GDC 61 requirements related to the system design for fuel storage and handling of radioactive materials, including the following elements:

A. The capability for periodic testing of components important to safety.

B. Provisions for containment.

C. Provisions for decay heat removal that reflect its importance to safety.

D. The capability to prevent reduction in fuel storage coolant inventory under accident conditions.

E. The capability and capacity to remove corrosion products, radioactive materials and impurities from the pool water and reduce occupational exposures to

NL-12-029 Docket No. 50-286 Page 9 of 9 radiation.

These requirements continue to be met. The BSFPCS is tested prior to placing in service. The provisions for containment are met by operating the primary loop at a lower pressure than the secondary loop to assure SFP water does not go to the environment. The BSFPCS will keep the SFP cool in order to maintain the coolant inventory and will rely on the SFPCS for inventory makeup when it is returned to service. The removal of corrosion products, impurities and radioactive materials is still a function of the SFPCS when returned to service. Due to the limited times the SFPCS will be out of service these requirements are considered still met.

GDC 63 requirements for monitoring systems provided to detect conditions that could result in the loss of decay heat removal, to detect excessive radiation levels, and to initiate appropriate safety actions. These requirements continue to be met. Conditions that could result in loss of decay heat removal are detectable using the system temperature and pressure instruments during system start up and operation. Excessive radiation levels are monitored by cther systems.

10 CFR 20.1101 (b) as it relates to radiation doses being kept as low as is reasonably achievable (ALARA). In meeting this regulation, RG 8.8, positions C.2.f(2) and C.2.f(3) can be used as a basis for acceptance. These requirements continue to be met because the SFP water level is maintained, the duration of the BSFPCS usage without removal of radioactive materials does not allow a buildup, and the recirculation of water in the BSFPCS is essentially the same as in the SFPCS.

5.3 Environmental Considerations The proposed changes to the IP3 FSAR 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.

6.0 PRECEDENCE No precedence has been identified for any FSAR changes to adopt a similar BSFPCS.

ATTACHMENT 2 TO NL-12-029 MARKUP OF UPDATED FINAL SAFETY ANALYSIS REPORT TO REFLECT PROPOSED CHANGES REGARDING BACKUP SPENT FUEL POOL COOLING SYSTEM Deletions sto4keeut / Additions bold and italic ENTERGY NUCLEAR OPERATIONS, INC.

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

IP3 FSAR UPDATE Lpo4:

etal" r

y h" nSctom letl~ l 0w.2'p ji rluiredf to of~craýt to,,uppori rciicititioi uRIM tMCtiolt. SeC Since the component cooling pumps are not running during this injection phase, the water volume of the Component Cooling Water System is used as a heat sink. The temperature rise of the fluid is discussed in Section 6.2.2.

Residual Heat Removal Loop Two pumps and two heat exchangers are utilized to remove residual and sensible heat during plant cooldown. If one of the pumps and/or one of the heat exchangers is not operative, safe operation or safe cooldown of the plant is not affected; however, the time for cooldown is extended. The function of this equipment following a Loss-of-Coolant Accident is discussed in Chapter 6.

Spent Fuel Pit Coolinq Loop This manually controlled loop may be shutdown safely for reasonable time periods, as shown in Table 9.3-3, for maintenance or replacement of malfunctioning components.

The Backup Spent Fuel Pool Cooling system has been installed to allow maintenance and repair and operate in parallel with the Normal SFP Cooling System to improve pool conditions during refueling activities (see Section 9.13). The BSF-PCS is a manual system.r...ved by an

,ndepe*ndnt coolin.g Wate.

oUr..

(demineralizod water). A Prima~' loop handles the SEP1 water and consists of two 100% capacity pumps, a plate heat exchanger, associated piping, and local in"trumentation. A secondary loop is the heat Gink for the system, and includes two, oe circuit e.aporative cooling towers, two 100 % capacity food pumps',

associated piping, and localinsrmnain Make-up and fill for the seconEdary loop is nR~maily proVided by deinraizdwater, with an alternate, emergency sou-rce3 a-vaila-ble through the FirFe Protection Systemf.

PoWer for all equipment is supplied f4rm the 480 VAG MCs El and E2. For" greater availability o!f power, and reliability of the cooling function, the B9F=PCS inc31ludes1 A-transfer switch that allows alignment to eithe the nrGmal

'pe s Ml G El and, E2, or a reMnal diesel generator *uni (with Engineering discretion).

This feature allows a;n alterat power source inthe 8evet the MCGs becom~e inoperable.

Leakaqe Provisions Component Cooling Loop Water leakage from piping, valves, and equipment in this system inside the Containment is not considered to be generally detrimental unless the leakage exceeds the makeup capability. With respect to water leakage from piping, valves, and equipment outside the Containment, welded construction is used where possible to minimize the possibility of leakage. The component cooling water could become contaminated with radioactive water due to a leak in any heat exchanger tube in the Chemical and Volume Control, Sampling, or Auxiliary Coolant Systems, or due to a leak in the thermal barrier cooling coil for the mechanical seal on a reactor coolant pump.

Tube or coil leaks in components being cooled would be detected during normal plant operation by the leak detection system described in Sections 4.2 and 6.7. Such leaks are also detected Chapter 9, Page 54 of 182 Revision 04, 2011

9.13 Backup Spent Fuel Pool Cooling System 9.13.1 Design Bases The Backup Spent Fuel Pool Cooling System (BSFPCS) has been installed to allow maintenance and repair and to operate in parallel with the normal SFP Cooling System (SFPCS) to improve spent fuel pool (SFP) conditions during refueling activities. The BSFPCS is desiqned to extend the period of time the SFPCS could be taken out of service during periods of maximum heat load (a full-core offload completed no earlier than 254 hours0.00294 days <br />0.0706 hours <br />4.199735e-4 weeks <br />9.6647e-5 months <br /> subcritical).

9.13.2 System Description The Backup Spent Fuel Pool Cooling System (BSFPCS) consists of a primary loop and a secondary loop. The primary loop handles the SFP water. The secondary loop is the system heat sink. The primary loop components are located in the Fuel Storage Building (FSB). The secondary loop components are located both inside the FSB and routed outside to the waste holdup tank pad where the cooling towers are located.

The primary loop takes suction from the SFP using one of two BSFPC pumps (primary loop).

flows through the BSFPC plate heat exchanger (HX) and returns to the SFP. The BSFPC pumps (primary loop) are 100 percent capacity, 25 horsepower primary loop pumps designed for 1500 gpm at 45 feet of head. The primary loop pumps are locally controlled and the local control station has red and green status lights. There are duplicate status lights at the secondary loop pump control station. Disconnect switches for the motors have padlocks to ensure only one motor is energized at a time. System piping is stainless steel.

The secondary loop takes suction from the two BSFPC open-circuit evaporative cooling towers, flows through the BSFPC HX and returns to the cooling towers. The secondary loop has two 100 percent capacity, 200 horsepower secondary loop pumps rated for 2500 gpm each at 192 feet of head. There are red and green status lights at the control station.

Disconnect switches for the motors have padlocks to ensure only one motor is energized at a time.

The BSFPCS heat exchanger is a plate and frame type. The secondary loop is maintained at a higher pressure than the primary loop to prevent leakage from the SFP into the secondary loop. Each primary pump receives a trip signal when the differential pressure is less than 10 psid. The secondary loop pump remains running to preclude a leak Path from the primary loop into the secondary loop. Differential pressure less than 10 psid also illuminates yellow status lights at the primary and secondary loop pump control stations.

The secondary loop cooling towers are two 50 percent capacity, open-circuit evaporative cooling towers. Each tower has a fan that pulls air over the water as it is sprayed over the fill material to assist cooling by evaporation. The fans cycle independently, depending on the temperature at the outlet of the cooling towers. The first fan will start at 71 OF and stop at 70TF. The second fan will start at 760F and stop at 750F. The tower also functions as a container for the water in the secondary loop. Makeup water is supplied from the Demineralized Makeup Water System (DMWS) line going to the Primary Water Storage Tank (PWST). Emergency Make up is from the fire protection system. There is hard piping from both the DMWS and fire protection piping for the cooling tower makeup. The water treatment system, common to both IP2 and IP3, provides makeup to the DWMS. Fill requirements are 1600 gallons a maximum required makeup of 72 gpm. The secondary system is stainless steel to prevent corrosion.

Pressure and temperature indicators are provided locally at pump discharges and on the plate heat exchanger discharges to evaluate proper operation. Their ranges are consistent with maximum operating conditions. A temperature element in the cooling tower basin and associated controls will regulate cooling tower fans as necessary for efficient operation. The

spent SFP local temperature indication is also available to monitor Pool conditions.

Normal power to the BSFPCS is supplied from 480 VAC MCC El via Power Panel PP-582 (primary pumps) and 480 VAC MCC E2 (secondary pumps). There is a transfer switch that allows power to the BSFPCS to be supplied from a portable diesel generator.

The system will be kept in dry layup most of the time and has been designed to accommodate this. Typically, the BSFPCS will only be used during refuel outages in order to supplement the SFPCS by reducing the SFP temperature to as low as feasible. During maintenance and repairs the BSFPCS may be used as the sole source of cooling. This is expected to be infrequent.

9.13.3 Safety Evaluation The BSFPCS is not designed seismic I or for a tornado event. The system is designed to preclude seismic interaction with the spent fuel pool and its components. The primary loop has Seismic II supports. The secondary loop is designed in the same manner from the heat exchanger to the first isolation valves on the inlet and outlet piping. The cooling towers also have seismic II supports.

Failures in the system piping due to seismic events, tornados or moderate energy line breaks do not cause unacceptable interactions. The lines are moderate energy because the operating pressures are about 17 to 85 psig and the temperatures are all below 142 OF except for the primary pump discharge to the heat exchanger at 190 OF. Primary and secondary side piping has a design pressure and temperature of 21Opsig and 300°F (the secondary side fill and makeup supplies are 150 psig and 5000F). Also, pump shutoff head pressures are less than 100 psig. A moderate energy line break would not affect equipment. A piping break on the pump discharge would be different than one on the SFPCS. The BSFPCS does not have an anti-siphoning hole in it's suction line at the 93' 1" elevation like the SFPCS, but the bottom of the suction line is at 87' 8" which is well above the SFPCS suction line at 74' 4-3/4".

This would allow an additional SFP reduction of 5 feet 5 inches but would not affect the ability to provide makeup to preclude pool boiling.

The system is normally run as backup to the SFPCS to provide enhanced cooling during outages. Under these conditions the BSFPCS is an enhancement and not credited to meet the design basis cooling requirements. During periods that the SFPCS is taken out of service for necessary maintenance or repair the BSFPCS may be used to cool the SFP as a stand-provided the limitations for such use, described below, are met.

The potential for loss of offsite power during periods when the BSFPCS is the only cooling in place will be accommodated by a backup diesel that would be temporarily brought in. The backup diesel will be required for those cases where the scheduled work exceeds the time to raise the temperature to boiling without cooling.

The BSFPCS can maintain the SFP bulk temperature at 1750F per calculation IP-CALC 00121 with the heat loads and wet bulb temperatures shown below:

Wet Bulb Temperature [°F1 Heat Load [BTU/Hrl at 1750F 40 361451000 45 35,6221000 50 34,938.000 55 34,1461000 60 33,4251000 65 32,525,000 70 31,6961000 75 31,048.000

Administrative controls will be in place to assure that the BSFPCS is used as the sole source of heat removal only under the following conditions:

1. Work will be scheduled whent the SFP heat load is at a reduced value rather than the design value.

2.

A backup diesel will be tested and made available whenever the scheduled work exceeds the time to raise the temperature to boiling without cooling.

3. The SFP will be brought to temperature as low as feasible, but not lower than the design temperature, prior to starting the work.

4. The wet bulb temperature is at or lower than the temperature that will keep the SFP below 175°F for the residual heat load at the time work starts.

9.13.4 Inspection and Testing Requirements The BSFPCS is put into lavup and taken out of layup in accordance with plant procedures. The system is functionally tested prior to being placed into service.