NL-12-0471, Supplemental Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)

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Supplemental Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)
ML12129A457
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 04/23/2012
From: Ventosa J
Entergy Corp, Entergy Nuclear Northeast, Entergy Nuclear Operations
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-12-0471, TAC L24299, TAC ME1671, TAC ME1672
Download: ML12129A457 (114)


Text

Entergy Nuclear Northeast Indian Point Energy Center P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A. Ventosa Site Vice President Administration NL-12-047 April 23, 2012 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-Pl-17 Washington, DC 20555-0001

Subject:

Indian Point Nuclear Power Plant Units 2 and 3 Supplemental Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)

Indian Point Units 2 & 3 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64

References:

1) Entergy letter NL-09-076, 07/08/09, "Indian Point Nuclear Power Plant Units 2 and 3 - Application for Unit 2 Operating License Condition Change and Units 2 and 3 Technical Specification Changes to Add Inter-Unit Spent Fuel Transfer Requirements"
2) Entergy letter NL-09-100, 09/28/09, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Supplemental Information Regarding the Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)"
3) Entergy letter NL-10-093, 10/05/10, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Additional Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)"
4) Entergy letter NL-11-052, 07/28/11, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Additional Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)"
5) Entergy letter NL-1 1-118, 10/28/11, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Additional Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos. ME1671, ME1672, and L24299)"
6) Entergy Letter NL-1 1-130, 12/15/11, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Additional Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos.

ME1671, ME1672, and L24299)"

Awol

NL-1 2-047 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Page 2 of 3

7) Entergy Letter NL-12-007, 03/02/12, "Indian Point Nuclear Power Plant Units 2 and 3 - Response to Request for Additional Information Regarding the Inter-Unit Spent Fuel Transfer License Amendment Request (TAC Nos.

ME1671, ME1672, and L24299)"

Dear Sir or Madam:

This letter provides Entergy Nuclear Operations, Inc (Entergy) additional information regarding the Entergy license amendment requests concerning inter-unit transfer of fuel (Reference 1), the supplement to the amendment request (Reference 2), and the responses to previous RAIs (References 3 through 7).

In Reference 7, Entergy identified that additional revisions to the licensing report and the previously proposed IP2 and IP3 Appendix C Technical Specifications (TS) would be required and that there would also be a new proposed change to IP2 Appendix A TS LCO 3.7.13.

Reference 7 also identified that revisions to the licensing report would be required because Entergy is procuring a new HI-TRAC and that certain components would be provided with a stainless steel weld overlay. Also in Reference 7, in response to RAI-14, Entergy proposed that the Unit 3 fuel transferred to the Unit 2 Spent Fuel Pool would be stored in Regions 1-1 and 1-2.

The reactivity margins presented in the response to RAI-14 were determined for Region 1-1.

Region 1-2 allows for fresh fuel storage and inherently has more margin relative to Region 1-1.

Based on additional discussions with the Nuclear Regulatory Commission (NRC), Entergy is now proposing that the transferred fuel be stored in Region 1-2 only. This change has been incorporated in the proposed TS and the revised licensing report included herein.

Attachments 1, 2, and 3 contain the proposed Technical Specifications revisions based on the response to RAI-14, and additional discussions with the NRC. Note that there is no change to the proposed Unit 3 Appendix A TS 3.7.15 as submitted in Reference 4. The additional supporting information provided in this submittal does not alter the conclusion that this proposed activity does not constitute a significant hazard, as documented in Reference 2. Attachments 4 and 5 contain the Unit 2 and Unit 3 NSHDs, respectively. Enclosures 1 and 2 contain the proprietary licensing report and supporting Holtec reports and evaluations, respectively. A non proprietary version of this submittal will be provided by May 7, 2012.

In response to a verbal NRC request Entergy confirms that the procedures that govern the inter-unit transfer of fuel have been written in accordance with existing Entergy standards for procedure development and are therefore appropriately human factored.

This submittal includes information deemed proprietary by an entity that is providing support to Entergy on this project. As such, in Enclosure 3, a 10 CFR 2.390 affidavit has been executed by the owner of the information.

There are no new regulatory commitments in this submittal.

In accordance with 10 CFR 50.91, a copy of this submittal is being provided to the designated New York State official.

NL-12-047 Docket Nos. 50-247 and 50-286 License Nos. DPR-26 and DPR-64 Page 3 of 3 If you have any questions or require additional information, please contact Mr. Robert Walpole, Licensing Manager at 914-254-6710.

I declare under penalty of perjury lhaý the foregoing is true and correct to the best of my knowledge. Executed on 4193 Sincerely, JAV/rw Attachments and

Enclosures:

Attachment 1: Indian Point Unit 2 - Appendix C to the Operating License Inter-Unit Fuel Transfer Technical Specifications Attachment 2: Indian Point Unit 3 - Appendix C to the Operating License Inter-Unit Fuel Transfer Technical Specifications Attachment 3: Indian Point Unit 2 - Proposed Revision to Appendix A TS Attachment 4: No Significant Hazards Consideration for Indian Point Unit 2 Pertaining to Inter-Unit Fuel Transfer Attachment 5: No Significant Hazards Consideration for Indian Point Unit 3 Pertaining to Inter-Unit Fuel Transfer Enclosure 1: Holtec International Licensing Report HI-2094289, Revision 6 (Holtec Proprietary)

Enclosure 2: Holtec International Supporting Reports and Evaluations (Holtec Proprietary)

Enclosure 3: Affidavit executed pursuant to 10 CFR 2.390 governing the proprietary information included in the Holtec reports and evaluations cc: NRC Resident Inspector's Office Mr. John Boska, Senior Project Manager, NRC NRR DORL Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William M. Dean, Regional Administrator, NRC Region 1 Mr. Francis J. Murray Jr., President and CEO, NYSERDA (w/o proprietary information)

Ms. Bridget Frymire, New York State Dept. of Public Service (w/o proprietary information)

ATTACHMENT 1 TO NL-12-047 Indian Point Unit 2 Appendix C to the Operating License Inter-Unit Fuel Transfer Technical Specifications Entergy Nuclear Operations, Inc.

Indian Point Unit 2 Docket No. 50-247

APPENDIX C TO FACILITY OPERATING LICENSE FOR ENTERGY NUCLEAR INDIAN POINT 2, LLC (ENIP2)

AND ENTERGY NUCLEAR OPERATIONS, INC. (ENO)

INDIAN POINT NUCLEAR GENERATING UNIT No. 2 INTER-UNIT FUEL TRANSFER TECHNICAL SPECIFICATIONS PART I: SPENT FUEL TRANSFER CANISTER AND TRANSFER CASK SYSTEM FACILITY LICENSE NO. DPR-26 DOCKET NO. 50-247 Amendment No.

Facility Operating License Appendix C - Inter-Unit Fuel Transfer Technical Specifications SPENT FUEL SHIELDED TRANSFER CANISTER AND TRANSFER CASK SYSTEM

1.0 DESCRIPTION

The spent fuel transfer system consists of the following components: (1) a spent fuel shielded transfer canister (STC), which contains the fuel; (2) a transfer cask (HI-TRAC 10OD) (hereafter referred to as HI-TRAC), which contains the STC during transfer operations; and (3) a bottom missile shield.

The STC and HI-TRAC are designed to transfer irradiated nuclear fuel assemblies from the Indian Point 3 (IP3) spent fuel pit to the Indian Point 2 (IP2) spent fuel pit. A fuel basket within the STC holds the fuel assemblies and provides criticality control. The shielded transfer canister provides the confinement boundary, water retention boundary, gamma radiation shielding, and heat rejection capability. The HI-TRAC provides a water retention boundary, protection of the STC, gamma and neutron radiation shielding, and heat rejection capability. The STC contains up to 12 fuel assemblies.

The STC is the confinement system for the fuel. It is a welded, multi-layer steel and lead cylinder with a welded base-plate and bolted lid. The inner shell of the canister forms an internal cylindrical cavity for housing the fuel basket. The outer surface of the canister inner shell is buttressed with lead and steel shells for radiation shielding. The minimum thickness of the steel, lead and steel shells relied upon for shielding starting with the innermost shell are 3/4 inch steel, 2 3/4 inch lead and 3/4 inch steel, respectively. The canister closure incorporates two 0-ring seals to ensure its confinement function. The confinement system consists of the canister inner shell, bottom plate, top flange, top lid, top lid 0-ring seals, vent port seal and cover plate, and drain port seal and coverplate. The fuel basket, for the transfer of 12 Pressurized Water Reactor (PWR) fuel assemblies, is a fully welded, stainless steel, honeycomb structure with neutron absorber panels attached to the individual storage cell walls under stainless steel sheathing.

The maximum gross weight of the fully loaded STC is 40 tons.

The HI-TRAC is a multi-layer steel and lead cylinder with a bolted bottom (or pool) and top lid.

For the fuel transfer operation the HI-TRAC is fitted with a solid top lid, an STC centering assembly, and a bottom missile shield. The inner shell of the transfer cask forms an internal cylindrical cavity for housing the STC. The outer surface of the cask inner shell is buttressed with intermediate lead and steel shells for radiation shielding. The minimum thickness of the steel, lead and steel shells relied upon for shielding starting with the innermost shell are 3/4 inch steel, 2 % inch lead and 1 inch steel, respectively. An outside shell called the "water jacket" contains water for neutron shielding, with a minimum thickness of 5". The HI-TRAC bottom and top lids incorporate a gasket seal design to ensure its water confinement function. The water confinement system consists of the HI-TRAC inner shell, bottom lid, top lid, top lid seal, bottom lid seal, vent port seal, vent port cap and bottom drain plug.

The HI-TRAC provides a water retention boundary, protection of the STC, gamma and neutron radiation shielding, and heat rejection capability. The bottom missile shield is attached to the bottom of the HI-TRAC and provides tornado missile protection of the pool lid bolted joint. The HI-TRAC can withstand a tornado missile in other areas without the need for additional shielding. The STC centering assembly provides STC position control within the HI-TRAC and also acts as an internal impact limiter in the event of a non-mechanistic tipover accident.

INDIAN POINT 2 1 Amendment

Facility Operating License Appendix C - Inter-Unit Fuel Transfer Technical Specifications 2.0 CONDITIONS 2.1 OPERATING PROCEDURES Written operating procedures shall be prepared for cask handling, loading, movement, surveillance, maintenance, and recovery from off normal conditions such as crane hang-up. The written operating procedures shall be consistent with the technical basis described in Chapter 10 of the Licensing Report (Holtec International Report HI-2094289).

2.2 ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 8 of the Licensing Report (Holtec International Report HI-2094289).

2.3 PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A training exercise of the loading, closure, handling/transfer, and unloading, of the equipment shall be conducted prior to the first transfer. The training exercise shall not be conducted with irradiated fuel. The training exercise may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The training exercise shall include, but is not limited to the following:

a) Moving the STC into the IP3 spent fuel pool.

b) Preparation of the HI-TRAC for STC loading.

c) Selection and verification of specific fuel assemblies and non-fuel hardware to ensure type conformance.

d) Loading specific assemblies and placing assemblies into the STC (using a single dummy fuel assembly), including appropriate independent verification.

e) Remote installation of the STC lid and removal of the STC from the spent fuel pool.

f) Placement of the STC into the HI-TRAC with the STC centering assembly.

g) STC closure, establishment of STC water level with steam, verification of STC water level, STC leakage testing, and operational steps required prior to transfer, as applicable.

h) Establishment and verification of HI-TRAC water level.

i) Installation of the HI-TRAC top lid.

j) HI-TRAC closure, leakage testing, and operational steps required prior to transfer, as applicable.

k) Movement of the HI-TRAC with STC from the IP3 fuel handling building to the IP2 fuel handling building along the haul route with designated devices.

I) Moving the STC into the IP2 spent fuel pool.

m) Manual crane operations for bare STC movements including demonstration of recovery from a crane hang-up with the STC suspended from the crane.

INDIAN POINT 2 2 Amendment

APPENDIX C TO FACILITY OPERATING LICENSE FOR ENTERGY NUCLEAR INDIAN POINT 2, LLC (ENIP2)

AND ENTERGY NUCLEAR OPERATIONS, INC. (ENO)

INDIAN POINT NUCLEAR GENERATING UNIT No. 2 INTER-UNIT FUEL TRANSFER TECHNICAL SPECIFICATIONS PART I1: TECHNICAL SPECIFICATIONS FACILITY LICENSE NO. DPR-26 DOCKET NO. 50-247 Amendment No.

TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1 Definitions 1.2 Logical Connectors 1.3 Completion Times 1.4 Frequency 2.0 NOT USED 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.1 INTER-UNIT FUEL TRANSFER 3.1.1 Boron Concentration 3.1.2 Shielded Transfer Canister (STC) Loading 3.1.3 Shielded Transfer Canister (STC) Initial Water Level 3.1.4 Shielded Transfer Canister (STC) Pressure Rise 3.1.5 Shielded Transfer Canister (STC) Unloading 4.0 DESIGN FEATURES 4.1 Inter-Unit Fuel Transfer 5.0 PROGRAMS 5.1 Transport Evaluation Program 5.2 Metamic Coupon Sampling Program 5.3 Technical Specifications Bases Control Program 5.4 Radiation Protection Program INDIAN POINT 2 Amendment

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

-- NOTE -----------------.... .

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

INTACT FUEL ASSEMBLIES INTACT FUEL ASSEMBLIES are fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks, and which can be handled by normal means. Fuel assemblies without fuel rods in fuel rod locations shall not be classified as INTACT FUEL ASSEMBLIES unless dummy fuel rods are used to displace an amount of water greater than or equal to that displaced by the original fuel rod(s).

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an STC while it is being loaded with fuel assemblies and while the STC is being placed in the HI-TRAC. LOADING OPERATIONS begin when the first fuel assembly is placed in the STC and end when the HI-TRAC is suspended from or secured on the TRANSPORTER.

NON-FUEL HARDWARE (NFH) NFH is defined as Burnable Poison Rod Assemblies (BPRAs), Thimble Plug Devices (TPDs), Wet Annular Burnable Absorbers (WABAs), Rod Cluster Control Assemblies (RCCAs), Neutron Source Assemblies (NSAs), Hafnium Flux Suppressors, and Instrument Tube Tie Rods (ITTRs).

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities performed on a HI-TRAC loaded with one or more fuel assemblies when it is being moved after LOADING OPERATIONS or before UNLOADING OPERATIONS.

TRANSFER OPERATIONS begin when the HI-TRAC is first suspended from or secured on the TRANSPORTER and end when the TRANSPORTER is at its destination and the HI-TRAC is no longer secured on or suspended from the TRANSPORTER.

TRANSPORTER TRANSPORTER is the device or vehicle which moves the HI-TRAC. The TRANSPORTER can either support the HI-TRAC from underneath or the HI-TRAC can be suspended from it.

(continued)

INDIAN POINT 2 1.1-1 Amendment

Definitions 1.1 1.1 Definitions (continued)

Term Definition UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an STC or HI-TRAC while it is being unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the HI-TRAC is no longer suspended from or secured on the TRANSPORTER and end when the last fuel assembly is removed from the STC.

ZR ZR means any zirconium-based fuel cladding authorized for use in a commercial nuclear power plant reactor.

INDIAN POINT 2 1.1-2 Amendment

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action).

The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

(continued)

INDIAN POINT 2 1.2-1 Amendment

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 VERIFY...

AND A.2 Restore...

In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A. 1 and A.2 must be completed.

(continued)

INDIAN POINT 2 1.2-2 Amendment

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Stop...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three ACTIONS may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

INDIAN POINT 2 1.2-3 Amendment

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the Spent Fuel Shielded Transfer Canister and Transfer Cask System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the Spent Fuel Shielded Transfer Canister and Transfer Cask System is not within the LCO Applicability.

Once a Condition has been entered, subsequent subsystems, components, or variables expressed in the Condition, discovered to be not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

(continued)

INDIAN POINT 2 1.3-1 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Perform Action B.1 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met. B.2 Perform Action B.2 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND complete action B.2 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(continued)

INDIAN POINT 2 1.3-2 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system A. 1 Restore system 7 days not within limit, to within limit.

B. Required B.1 Complete 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and action B.1.

associated Completion AND Time not met.

B.2 Complete 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> action B.2.

When a system is determined not to meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

INDIAN POINT 2 1.3-3 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS


NOTE--.. .. ...---------------

Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> compliance with LCO.

B. Required B.1 Complete action 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and B.1.

associated Completion AND Time not met.

B.2 Complete action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B.2.

The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis.

When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

IMMEDIATE When "Immediately" is used as a Completion Time, the Required Action COMPLETION should be pursued without delay and in a controlled manner.

TIME INDIAN POINT 2 1.3-4 Amendment

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR)

Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

(continued)

INDIAN POINT 2 1.4-1 Amendment

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). Ifthe interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is not in a condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the specified condition. Failure to do so would result in a violation of SR 3.0.4.

(continued)

INDIAN POINT 2 1.4-2 Amendment

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES (continued) EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting activity AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting the activity.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

"Thereafter' indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity.

INDIAN POINT 2 1.4-3 Amendment

Not Used 2.0 2.0 NOT USED This section is intentionally left blank INDIAN POINT 2 2.0-1 Amendment

LCO Applicability 3.0 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 Not applicable.

LCO 3.0.4 When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS or that are related to the unloading of an STC.

LCO 3.0.5 Equipment removed from service or not in service in compliance with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate it meets the LCO or that other equipment meets the LCO. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing.

INDIAN POINT 2 3.0-1 Amendment

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met ifthe Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with Actions or that are related to the unloading of an STC.

INDIAN POINT 2 3.0-2 Amendment

Boron Concentration 3.1.1 3.1 INTER-UNIT FUEL TRANSFER 3.1.1 Boron Concentration LCO 3.1.1 The boron concentration of the water in the Spent Fuel Pit and the STC shall be > 2000 ppm.

APPLICABILITY: Whenever one or more fuel assemblies are in the STC.

E -----------------------------------------------

k. i.r'r

............... ............... .......... I-I-Only applicable to the spent fuel pit when the STC is in the spent fuel pit ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. Boron concentration not A.1 Suspend LOADING Immediately within limit. OPERATIONS or UNLOADING OPERATIONS.

AND A.2 Suspend positive reactivity Immediately additions.

AND A.3 Initiate action to restore boron Immediately concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY NOTE -Once, within 4 This surveillance is only required to be performed ifthe STC is hours prior to submerged in water in the spent fuel pool or ifwater is added to, or entering the recirculated through, the STC when the STC is in the HI-TRAC. Any Applicability of this added water must meet the boron concentration requirement of LCO LCO.

3.1.1.


-AND -

SR 3.1.1.1 Verify the boron concentration is within limit using two Once per 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> separate measurements. thereafter.

INDIAN POINT 2 3.1.1-1 Amendment

STC Loading 3.1.2 3.1 INTER-UNIT FUEL TRANSFER 3.1.2 Shielded Transfer Canister (STC) Loading LCO 3.1.2 INTACT FUEL ASSEMBLIES placed into the Shielded Transfer Canister (STC) shall be classified in accordance with Table 3.1.2-1 based on initial enrichment and burnup and shall be restricted based on the following:

a. INTACT FUEL ASSEMBLIES classified as Type 2 may be placed in the STC basket (see Figure 3.1.2-1) with the following restrictions:
1. Post-irradiation cooling time, initial enrichment, and allowable average burnup shall be within the limits for the cell locations as specified in Table 3.1.2-3;
2. Decay heat including NON FUEL HARDWARE < 650 Watts (cells 5 through 12);
3. Decay heat including NON FUEL HARDWARE <1105 Watts (cell 1, 2, 3 or 4);
4. Post-irradiation cooling time and the maximum average burnup of NON FUEL HARDWARE shall be within the cell locations and limits specified in Table 3.1.2-2. In accordance with Table 3.1.2-2 RCCAs and Hafnium Flux Suppressors cannot be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket.

- NOTE -

If one or more Type I fuel assemblies are in the STC, cells 1, 2, 3, AND 4 must be empty, with a cell blocker installed that prevents inserting fuel assemblies and/or NON-FUEL HARDWARE.

b. INTACT FUEL ASSEMBLIES classified as Type 1 or Type 2 may be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket (see Figure 3.1.2-1) with the following restrictions:
1. Post-irradiation cooling time, initial enrichment, and allowable average burnup shall be within the limits for the cell locations as specified in Table 3.1.2-3;
2. Decay heat including NON FUEL HARDWARE < 650 Watts;
3. Post-irradiation cooling time and the maximum average burnup of NON FUEL HARDWARE shall be within the cell locations and limits specified in Table 3.1.2-2. In accordance with Table 3.1.2-2 RCCAs and Hafnium Flux Suppressors cannot be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket.
c. Only INTACT FUEL ASSEMBLIES with initial average enrichment > 3.2 and < 4.4 wt% U-235 and discharged prior to IP3 Cycle 12 shall be placed in the STC basket.

INDIAN POINT 2 3.1.2-1 Amendment

STC Loading

3.1.2 APPLICABILITY

Whenever one or more fuel assemblies are in the STC.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more fuel A.1.1 Initiate action to Immediately assemblies or NON restore compliance FUEL HARDWARE in with LCO 3.1.2.

the STC do not meet the LCO limits. OR A.1.2 Initiate action to move fuel to the IP3 spent fuel pit in accordance with IP3 Appendix A Technical Specification LCO 3.7.16.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify by administrative means that the fuel Prior to placing the fuel assembly and NON FUEL HARDWARE meets the assembly in the STC.

requirements specified in the LCO for placement in the STC.

SR 3.1.2.2 Verify by visual inspection that a cell blocker which Prior to placing a Type 1 prevents inserting fuel assemblies and/or NON- fuel assembly in the STC.

FUEL HARDWARE into cells 1, 2, 3, and 4 of the STC is installed.

INDIAN POINT 2 3.1.2-2 Amendment

STC Loading 3.1.2 Cell Cell Cell Cell 12 1 2 7 Cell Cell Cell Cell 11 4 3 8

\* Cell Cell /

Figure 3.1.2-1 Shielded Transfer Canister Layout (Top View)

INDIAN POINT 2 3.1.2-3 Amendment

STC Loading 3.1.2 Table 3.1.2-1 Minimum Burnup Requirements at Varying Initial Enrichments(a)

Configuration A(c) Configuration B(d)

Maxm Aseml(f)(y) Minimum Assembly Minimum Assembly Average Burnup Average Burnup (wt% U235) (MWD/MTU)(b) (MWD/MTU)(b) 2.0 5,400 6,000 2.5 13,800 18,800 3.0 22,100 28,600 3.5 30,000 37,300 4.0 36,900 44,600 4.5 42,700 52,500 5.0 48,700 Note (e)

(a) Fuel that does not meet the minimum assembly average burnup at a given initial enrichment is classified as Type 1 fuel. Fuel that meets the minimum assembly average burnup at a given initial enrichment is classified as Type 2 fuel.

(b) Linear interpolation between enrichment levels to determine minimum burnup requirements is permitted.

(c) Assemblies that have not been located in any cycle under a control rod bank that was permitted to be inserted during full power operation or where it can be shown that the insertion did not exceed 8 inches below the top of the active fuel.

(d) Assemblies that have been located under a control rod bank that was permitted to be inserted during full power operation and where the insertion was more than 8 inches below the top of the active fuel. This configuration also applies to fuel assemblies that have contained a Hafnium Flux Suppressor.

(e) Configuration B assemblies with enrichment greater than 4.5 are classified as Type 1 fuel.

(f) Natural or enriched uranium blankets are not considered in determining the fuel assembly average enrichment for comparison to the maximum allowed initial average enrichment.

(g) Rounding to one decimal place to determine initial enrichment is not permitted.

INDIAN POINT 2 3.1.2-4 Amendment

STC Loading 3.1.2 Table 3.1.2-2 NON FUEL HARDWARE(a) Post Irradiation Cooling Times and Allowable Average Burnup Maximum Burnup Post-irradiation (MWD/MTU)

Cooling Time (years) BPRAs and (b)(c) Hafnium Flux WABAs(b) TPDs RCCAs Suppressors

-6 < 20000 N/A - 630000 < 20000

>7 - *20000 - -

>8 < 30000 - - < 30000

>9 < 40000 < 30000 - -

Ž10 < 50000 < 40000 - -

Ž11 *60000

  • 45000 - -

>12 - *50000 - -

Ž13 < 60000 - -

Ž14 -

Z: 15 < 90000 -

>16 <5630000 -

Ž20 -

Allowed Up to twelve Up to twelve Up to four (4) Up to four (4)

Quantity and (12) per (12) per per transfer in per transfer in Location transfer in any transfer in Cells 1, 2, 3, Cells 1, 2, 3, location any location and/or 4 and/or 4 (a) NON-FUEL HARDWARE burnup and cooling time limits are not applicable to Instrument Tube Tie Rods (ITTRs), since they are installed post-irradiation. NSAs are not authorized for loading in the STC.

(b) Linear interpolation between points is only permitted for BPRAs, WABAs, and TPDs, with the exception that interpolation is not permitted for TPDs with burnups greater than 90 GWd/MTU and cooling times greater than 15 years.

(c) N/A means not authorized for loading at this cooling time.

INDIAN POINT 2 3.1.2-5 Amendment

STC Loading 3.1.2 Table 3.1.2-3 Allowable STC Loading Configurations Configuration(c) Cells 1,2, 3, 4 (a)(b) Cells 5, 6, 7, 8, 9, 10, 11, 1 2 (a)(b)

Burnup < 55,000 MWD/MTU Burnup < 40,000 MWD/MTU 1 Cooling time > 10 years Cooling time > 25 years Initial Enrichment > 3.4 wt% U-235 Initial Enrichment > 2.3 wt% U-235 Burnup < 45,000 MWD/MTU Burnup <45,000 MWD/MTU 2 Cooling time > 10 years Cooling time > 20 years Initial Enrichment ? 3.2 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup < 55,000 MWD/MTU Burnup < 45,000 MWD/MTU 3 Cooling time > 10 years Cooling time > 20 years Initial Enrichment > 3.4 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup < 45,000 MWD/MTU Burnup <40,000 MWD/MTU 4 Cooling time > 10 years Cooling time > 12 years Initial Enrichment > 3.6 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup <45,000 MWD/MTU Burnup < 40,000 MWD/MTU 5 Cooling time > 14 years Cooling time > 12 years Initial Enrichment > 3.4 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup < 45,000 MWD/MTU Burnup < 40,000 MWD/MTU 6 Cooling time > 20 years Cooling time > 20 years Initial Enrichment a 3.2 wt% U-235 Initial Enrichment > 2.3 wt% U-235 (a) Initial enrichment is the assembly average enrichment. Natural or enriched uranium blankets are not considered in determining the fuel assembly average enrichment for comparison to the minimum allowed initial average enrichment.

(b) Rounding to one decimal place to determine initial enrichment is permitted.

(c) Fuel with five middle Inconel spacers are limited to cells 1, 2, 3, and 4 for all loading configurations except loading configuration 6 which allows fuel with Inconel spacers in all cells.

INDIAN POINT 2 3.1.2-6 Amendment

STC Initial Water Level 3.1.3 3.1 INTER-UNIT FUEL TRANSFER 3.1.3 Shielded Transfer Canister (STC) Initial Water Level LCO 3.1.3 The established water level in the STC shall be 9.0+0.5/-1.5 inches below the bottom of the STC lid.

APPLICABILITY: Prior to TRANSFER OPERATIONS when the STC is in the HI-TRAC and the STC lid has been installed.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. STC water level not within ---- NOTE -.-----------. Immediately limit. Water used for level restoration must meet the boron concentration requirement of LCO 3.1.1.

A.1 Initiate action to restore STC water level.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify the initial STC water level is within limit by Once prior to verifying the following during STC water level TRANSFER establishment: OPERATIONS.

a. steam is emitted from the STC drain tube; and
b. the volume of water removed is > 35.4 gallons and < 47.9 gallons.

INDIAN POINT 2 3.1.3-1 Amendment

STC Pressure Rise 3.1.4 3.1 INTER-UNIT FUEL TRANSFER 3.1.4 Shielded Transfer Canister (STC) Pressure Rise LCO 3.1.4 The pressure rise in the STC cavity shall be < 0.2 psi/hr averaged over a rolling 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period.

APPLICABILITY: Over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after successful completion of LCO 3.1.3 and prior to TRANSFER OPERATIONS when the STC is in the HI-TRAC and the STC lid has been installed.

I ACTIONS CONDITION REQUIRED ACTION OME TIME A. Rate of STC cavity A.1.1 Establish a vent path on the Immediately pressure rise not within STC.

limit.

AND


-NOTE Water used for recirculation must meet the boron concentration requirement of LCO 3.1.1.

A. 1.2 Begin circulation of borated water in the STC to establish and maintain the STC water exit temperature < 180 0 F.

AND A.1.3 Begin actions to determine the reason for exceeding the pressure rise limit.

(continued)

INDIAN POINT 2 3.1.4-1 Amendment

STC Pressure Rise 3.1.4 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME B. Required Action A.1.3 B.1.1 Return the STC to the spent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> indicates a fuel misload. fuel pool and remove the STC lid.

AND B.1.2 Return any misloaded fuel to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the IP3 spent fuel pit in accordance with IP3 Appendix A Technical Specification LCO 3.7.16.

C. Required Action A.1.3 C.1 Develop and initiate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> does not indicate a fuel corrective actions necessary misload. to return the STC to compliance with LCO 3.1.3 and LCO 3.1.4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 -------------------- NOTE -------------------------- - Once prior to Pressure measurements shall be taken once upon TRANSFER establishing required water level AND hourly OPERATIONS.

thereafter for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Pressure may initially drop during pressure stabilization.

Verify by direct measurement that the rate of STC cavity pressure rise is within limit.

S R 3.1.4.2 Verify that an ASME code compliant pressure relief During valve or rupture disc and two channels of pressure performance of SR instrumentation with a range of at least 0.1 psia to 15 3.1.4.1.

psia and calibrated to within 1% accuracy within the past 12 months are installed on the STC.

INDIAN POINT 2 3.1.4-2 Amendment

STC Unloading 3.1.5 3.1 INTER-UNIT FUEL TRANSFER 3.1.5 Shielded Transfer Canister (STC) Unloading


NOTE.

1. Only IP3 spent fuel assemblies are permitted to be in the STC.
2. Once each IP3 spent fuel assembly removed from the STC has been placed in an IP2 spent fuel rack location and disconnected from the spent fuel pit bridge crane, it may not be returned to the STC.

LCO 3.1.5 IP3 spent fuel assemblies transferred to IP2 via the STC must be either in an approved IP2 spent fuel pit storage rack location per IP2 Appendix A Technical Specification LCO 3.7.13, in their authorized STC fuel basket cell, or be in transit between these two locations.

APPLICABILITY: Whenever the STC is in the Unit 2 spent fuel pit.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more fuel A. 1 Initiate action to Immediately assemblies not in the restore compliance required location, with LCO 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify by administrative means that a fuel Once, after each re-loaded assembly returned to the STC has been re- fuel assembly is retumed to loaded into the same STC cell from which it was the STC.

removed.

INDIAN POINT 2 3.1.5-1 Amendment

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Inter-Unit Fuel Transfer 4.1.1 Fuel Assemblies Fuel assemblies selected for inter-unit transfer of fuel shall meet the fuel characteristics specified in Table 4.1.1-1.

4.1.2 Criticality 4.1.2.1 The Shielded Transfer Canister (STC) is designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
b. kef < 0.95 iffully flooded with unborated water;
c. A nominal 9.218 inch center-to-center distance between fuel assemblies placed in the STC basket;
d. Basket cell ID: 8.79 in. (nominal);
e. Basket cell wall thickness: 0.28 in. (nominal);
f. B4C in the Metamic neutron absorber: a 31.5 wt.% and <33.0 wt.%;
g. The B4C in the Metamic neutron absorber will contain boron with an isotopic B-10 content of at least 18.4%;
h. Metamic panel thickness: > 0.102 in.;
i. The size and location of the neutron absorber panels shall be in accordance with drawing 6015, revision 6, which can be found in the Licensing Report (Holtec International Report HI-2094289).

4.1.2.2 Drainage The STC is designed and shall be maintained to prevent inadvertent draining.

4.1.2.3 Capacity The STC is designed and shall be maintained with a capacity of no more than 12 fuel assemblies.

(continued)

INDIAN POINT 2 4.0-1 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.1.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (AS ME Code), 2004 Edition, is the governing Code for the STC, as clarified below, except for Code Sections V and IX.The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 2004 Edition, is performed. Table 4.1.3-1 lists approved alternatives to the ASME Code for the design of the STC.

4.1.4 Geometric Arrangements and Process Variables The following are geometric arrangements and process variables that require a one time verification as part of each inter-unit fuel transfer operation:

1. LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures

> 0°F.

2. LOADING OPERATIONS shall only be conducted when the spent fuel pit water temperature and the fuel handling building ambient temperatures are both <

1 00°F.

3. LOADING OPERATIONS shall only be conducted when the IP3 spent fuel pit contains no unirradiated fuel assemblies.
4. LOADING OPERATIONS shall only be conducted when the irradiated fuel assemblies in the IP3 spent fuel pit have been subcritical for at least 90 days.
5. TRANSFER OPERATIONS shall only be conducted when the outside air temperature is < 100°F.
6. TRANSFER OPERATIONS shall only be conducted when the STC trunnions are offset from the HI-TRAC trunnions in the azimuthal direction by at least 30 degrees.
7. TRANSFER OPERATIONS shall only be conducted after STC seal leak tests3 have demonstrated no detected leakage when tested to a sensitivity of 1x10 ref-cm 3/s in accordance with the "pre-shipment" test requirements of ANSI N14.5.
8. Prior to installing the HI-TRAC lid the HI-TRAC water level shall be verified by two separate inspections to be within +0/-1 inch of the top of the STC lid.

(continued)

INDIAN POINT 2 4.0-2 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued)

9. TRANSFER OPERATIONS shall only be conducted after the combined leak rate through the HI-TRAC top lid and vent port cover seals are confirmed to be water tight using an acceptable leak test from ANSI N14.5 and the pool lid seal is verified to be water tight by visual inspection.
10. TRANSFER OPERATIONS shall not occur with a TRANSPORTER that contains > 50 gallons of diesel fuel.

Table 4.1.1-1 Fuel Assembly Characteristics Fuel Assembly Class 15xl 5(a)

No. of Fuel Rod Locations 204 Cladding Type ZR Guide/Instrument Tube Type ZR Design Initial U (kg/assembly) < 473 Fuel Rod Clad O.D. (in) > 0. 422 Fuel Rod Clad I.D. (in) <0.3734 Fuel Pellet Diameter (in) 5 0. 3659 Fuel Rod Pitch (in) < 0.563 Active Fuel Length (in) < 144 Fuel Assembly Length (in) < 160 Fuel Assembly Width (in) < 8.54 No. of Guide and/or Instrument Tubes 21 Guide/Instrument Tube Thickness (in) 0. 017 Axial Blanket Enrichment (wt % U-235)(b) < 3.2 Axial Blanket Length (in)(b) >6 (a) All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within the 15xl 5 class.

(b) Applicable only if axial blankets are present.

(continued)

INDIAN POINT 2 4.0-3 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued)

Table 4.1.3-1 (page 1 of 2)

List of ASME Code Alternatives for the STC Component Reference ASME Code Requirement Alternative, Justification &

Code Compensatory Measures Section/Article STC ND-1000 Statement of Cask confinement boundary is designed, and will Confinement requirements for Code be fabricated in accordance with ASME Code, Boundary stamping of Section III, Subsection ND to the maximum components. practical extent, but Code stamping is not required.

STC ND-2000 Requires materials to be Holtec approved suppliers will supply materials Confinement supplied by ASME- with CMTRs per ND-2000.

Boundary approved material supplier.

STC and STC ND-3100 Provides requirements These requirements are not applicable. The basket NG-3100 for determining design Licensing Report, serving as the Design assembly loading conditions, such Specification, establishes the service conditions as pressure, and load combinations for fuel transfer.

temperature, and mechanical loads.

STC ND-7000 Vessels are required to No overpressure protection is provided. Function Confinement have overpressure of cask vessel is as a radionuclide confinement Boundary protection. boundary under normal and hypothetical accident conditions. Cask is designed to withstand maximum internal pressure and maximum accident temperatures.

STC ND-8000 States requirement for STC to be marked and identified in accordance Confinement name, stamping and with drawing 6013(a). Code stamping is not Boundary reports per NCA-8000 required. QA data package prepared in accordance with Holtec's approved QA program.

INDIAN POINT 2 4.0-4 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued)

Table 4.1.3-1 (page 2 of 2)

List of ASME Code Alternatives for the STC Component Reference ASME Code Requirement Alternative, Justification &

Code Compensatory Measures SectionlArticle STC Basket NG-4420 NG-4427(a) requires a Modify the Code requirement (intended for core Assembly fillet weld in any single support structures) with the following text prepared to continuous weld may accord with the geometry and stress analysis be less than the imperatives for the fuel basket: For the longitudinal specified fillet weld STC basket fillet welds, the following criteria apply:

dimension by not 1) The specified fillet weld throat dimension must be more than 1/16 inch, maintained over at least 92 percent of the total weld provided that the total length. All regions of undersized weld must be less undersize portion of than 3 inches long and separated from each other by the weld does not at least 9 inches. 2) Areas of undercuts and porosity exceed 10 percent of beyond that allowed by the applicable ASME Code the length of the weld. shall not exceed 1/2 inch in weld length. The total Individual undersize length of undercut and porosity over any 1-foot weld portions shall not length shall not exceed 2 inches. 3) The total weld exceed 2 inches in length in which items (1) and (2) apply shall not length. exceed a total of 10 percent of the overall weld length. The limited access of the STC basket panel longitudinal fillet welds makes it difficult to perform effective repairs of these welds and creates the potential for causing additional damage to the basket assembly (e.g., to the neutron absorber and its sheathing) if repairs are attempted. The acceptance criteria provided in the foregoing have been established to comport with the objectives of the basket design and preserve the margins demonstrated in the supporting stress analysis.

From the structural standpoint, the weld acceptance criteria are established to ensure that any departure from the ideal, continuous fillet weld seam would not alter the primary bending stresses on which the design of the fuel baskets is predicated. Stated differently, the permitted weld discontinuities are limited in size to ensure that they remain classifiable as local stress elevators ("peak stress", F, in the ASME Code for which specific stress intensity limits do not apply).

STC Basket NG-8000 States requirements STC basket to be marked and identified in Assembly for nameplates, accordance with drawing 6015(a). No Code stamping stamping and reports is required. The STC basket data package is to be in per NCA-8000. conformance with Holtec's QA program.

(a) Holtec International Report HI-2094289 INDIAN POINT 2 4.0-5 Amendment

Programs, 5.0 5.0 PROGRAMS The following programs shall be established, implemented and maintained.

5.1 Transport Evaluation Proqram

a. For lifting of the loaded STC or loaded HI-TRAC using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.
b. This program is not applicable when the loaded HI-TRAC is in the fuel building or is being handled by equipment providing support from underneath (e.g., on air pads).
c. The loaded HI-TRAC may be lifted to any height necessary during TRANSFER OPERATIONS provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.
1. The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.
2. The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. This includes applicable stress limits from ANSI N14.6.
3. The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.
d. The lift height of the loaded HI-TRAC above the transport route surface or other supporting surface shall be limited to 6 inches, except as provided in Specification 5.1.c.

5.2 Metamic Coupon Samplinq Program A coupon surveillance program shall be implemented to maintain surveillance of the Metamic neutron absorber material under the radiation, chemical, and thermal environment of the STC.

The surveillance program will be implemented to monitor the performance of Metamic by installing a minimum of four bare coupons near the maximum gamma flux elevation (mid height) at no less than four circumferential downcomer areas around the STC fuel basket. At any time during its use the STC must have a minimum of one coupon installed in each quadrant. Metamic coupons used for testing must have been installed during the entire fuel loading history of the STC.

The following specifications apply:

(i) Coupon size will be nominally 4" x 6". Each coupon will be marked with a unique identification number.

(continued)

INDIAN POINT 2 5.0-1 Amendment

Programs 5.0 5.0 PROGRAMS (continued)

(ii) Pre-characterization testing: Before installation, each coupon will be measured and weighed. The measurements shall be taken at locations pre-specified in the test program. Each coupon shall be tested by neutron attenuation before installation in the STC. The weight, length, width, thickness, and results of the neutron attenuation testing shall be documented and retained.

(iii) Four coupons shall be tested at the end of each inter-unit fuel transfer campaign. A campaign shall not last longer than two years. The coupons shall be measured and weighed and the results compared with the pre-characterization testing data. The results shall be documented and retained.

(iv) The coupons shall be examined for any indication of swelling, delamination, edge degradation, or general corrosion. The results of the examination shall be documented and retained.

(v) The coupons shall be tested by neutron attenuation and the results compared with the pre-characterization testing data. The results of the testing shall be documented and retained. Results are acceptable ifthe measured value is within +/-2.5% of the value measured for the same coupon at manufacturing.

(vi) The coupons shall be returned to their locations in the STC unless anomalous material behavior is found. If the results indicate anomalous material behavior, evaluation and corrective actions shall be pursued.

5.3 Technical Specifications (TS) Bases Control Proqram This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:
1. a change in the TS incorporated in the license; or
2. a change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.
d. Proposed changes that do not meet the criteria of Specification 5.3.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71(e).

(continued)

INDIAN POINT 2 5.0-2 Amendment

Programs 5.0 5.0 PROGRAMS (continued) 5.4 Radiation Protection Program 5.4.1 The radiation protection program shall appropriately address STC loading and unloading conditions, including transfer of the loaded TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA).

The actions and criteria to be included in the program are provided below.

5.4.2 Total (neutron plus gamma) measured dose rates shall not exceed the following:

a. 1400 mrem/hr on the top of the STC (with lid in place).
b. 5 mrem/hr on the side of the TRANSFER CASK 5.4.3 The STC and TRANSFER CASK surface neutron and gamma dose rates shall be measured as described in Section 5.4.6 for comparison against the limits established in Section 5.4.2.

5.4.4 If the measured surface dose rates exceed the limits established in Section 5.4.2, then:

a. Administratively verify that the correct contents were loaded in the correct fuel basket cell locations.
b. Perform a written evaluation to determine whether TRANSFER OPERATIONS can proceed without exceeding the dose limits of 10 CFR 72.104 or 10 CFR 20.1301.

5.4.5 If the verification and evaluation performed pursuant to Section 5.4.4 show that the fuel is loaded correctly and the dose rates from the STC and TRANSFER CASK will not cause the dose limits of 10 CFR 72.104 or 10 CFR 20.1301 to be exceeded, TRANSFER OPERATIONS may occur. Otherwise, TRANSFER OPERATIONS shall not occur until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.4.6 STC and TRANSFER CASK surface dose rates shall be measured at approximately the following locations:

a. The dose rate measurement shall be taken at the approximate center of the STC top lid. Two (2) additional measurements shall be taken on the STC lid approximately 180 degrees apart and 12 to 18 inches from the center of the lid, avoiding the areas around the inlet and outlet ports. The measurements must be taken when the STC is in the HI-TRAC after the steam space is established and prior to HI-TRAC lid installation.

(continued)

INDIAN POINT 2 5.0-3 Amendment

Programs 5.0 5.0 PROGRAMS (continued)

b. A minimum of four (4) dose rate measurements shall be taken on the side of the TRANSFER CASK approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket.

INDIAN POINT 2 5.0-4 Amendment

ATTACHMENT 2 TO NL-12-047 Indian Point Unit 3 Appendix C to the Operating License Inter-Unit Fuel Transfer Technical Specifications Entergy Nuclear Operations, Inc.

Indian Point Unit 3 Docket No. 50-286

APPENDIX C TO FACILITY OPERATING LICENSE FOR ENTERGY NUCLEAR INDIAN POINT 3, LLC (ENIP3)

AND ENTERGY NUCLEAR OPERATIONS, INC. (ENO)

INDIAN POINT NUCLEAR GENERATING UNIT No. 3 INTER-UNIT FUEL TRANSFER TECHNICAL SPECIFICATIONS PART I: SPENT FUEL TRANSFER CANISTER AND TRANSFER CASK SYSTEM FACILITY LICENSE NO. DPR-64 DOCKET NO. 50-286 Amendment No.

Facility Operating License Appendix C - Inter-Unit Fuel Transfer Technical Specifications SPENT FUEL SHIELDED TRANSFER CANISTER AND TRANSFER CASK SYSTEM

1.0 DESCRIPTION

The spent fuel transfer system consists of the following components: (1) a spent fuel shielded transfer canister (STC), which contains the fuel; (2) a transfer cask (HI-TRAC 10OD) (hereafter referred to as HI-TRAC), which contains the STC during transfer operations; and (3) a bottom missile shield.

The STC and HI-TRAC are designed to transfer irradiated nuclear fuel assemblies from the Indian Point 3 (IP3) spent fuel pit to the Indian Point 2 (IP2) spent fuel pit. A fuel basket within the STC holds the fuel assemblies and provides criticality control. The shielded transfer canister provides the confinement boundary, water retention boundary, gamma radiation shielding, and heat rejection capability. The HI-TRAC provides a water retention boundary, protection of the STC, gamma and neutron radiation shielding, and heat rejection capability. The STC contains up to 12 fuel assemblies.

The STC is the confinement system for the fuel. It is a welded, multi-layer steel and lead cylinder with a welded base-plate and bolted lid. The inner shell of the canister forms an internal cylindrical cavity for housing the fuel basket. The outer surface of the canister inner shell is buttressed with lead and steel shells for radiation shielding. The minimum thickness of the steel, lead and steel shells relied upon for shielding starting with the innermost shell are 3/4 inch steel, 2 3/4 inch lead and 3/4 inch steel, respectively. The canister closure incorporates two O-ring seals to ensure its confinement function. The confinement system consists of the canister inner shell, bottom plate, top flange, top lid, top lid O-ring seals, vent port seal and cover plate, and drain port seal and coverplate. The fuel basket, for the transfer of 12 Pressurized Water Reactor (PWR) fuel assemblies, is a fully welded, stainless steel, honeycomb structure with neutron absorber panels attached to the individual storage cell walls under stainless steel sheathing.

The maximum gross weight of the fully loaded STC is 40 tons.

The HI-TRAC is a multi-layer steel and lead cylinder with a bolted bottom (or pool) and top lid.

For the fuel transfer operation the HI-TRAC is fitted with a solid top lid, an STC centering assembly, and a bottom missile shield. The inner shell of the transfer cask forms an internal cylindrical cavity for housing the STC. The outer surface of the cask inner shell is buttressed with intermediate lead and steel shells for radiation shielding. The minimum thickness of the steel, lead and steel shells relied upon for shielding starting with the innermost shell are 3/4 inch steel, 2 % inch lead and 1 inch steel, respectively. An outside shell called the "water jacket" contains water for neutron shielding, with a minimum thickness of 5". The HI-TRAC bottom and top lids incorporate a gasket seal design to ensure its water confinement function. The water confinement system consists of the HI-TRAC inner shell, bottom lid, top lid, top lid seal, bottom lid seal, vent port seal, vent port cap and bottom drain plug.

The HI-TRAC provides a water retention boundary, protection of the STC, gamma and neutron radiation shielding, and heat rejection capability. The bottom missile shield is attached to the bottom of the HI-TRAC and provides tornado missile protection of the pool lid bolted joint. The HI-TRAC can withstand a tornado missile in other areas without the need for additional shielding. The STC centering assembly provides STC position control within the HI-TRAC and also acts as an internal impact limiter in the event of a non-mechanistic tipover accident.

INDIAN POINT 3 1 Amendment

Facility Operating License Appendix C - Inter-Unit Fuel Transfer Technical Specifications 2.0 CONDITIONS 2.1 OPERATING PROCEDURES Written operating procedures shall be prepared for cask handling, loading, movement, surveillance, maintenance, and recovery from off normal conditions such as crane hang-up. The written operating procedures shall be consistent with the technical basis described in Chapter 10 of the Licensing Report (Holtec International Report HI-2094289).

2.2 ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 8 of the Licensing Report (Holtec International Report HI-2094289).

2.3 PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A training exercise of the loading, closure, handling/transfer, and unloading, of the equipment shall be conducted prior to the first transfer. The training exercise shall not be conducted with irradiated fuel. The training exercise may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The training exercise shall include, but is not limited to the following:

a) Moving the STC into the IP3 spent fuel pool.

b) Preparation of the HI-TRAC for STC loading.

c) Selection and verification of specific fuel assemblies and non-fuel hardware to ensure type conformance.

d) Loading specific assemblies and placing assemblies into the STC (using a single dummy fuel assembly), including appropriate independent verification.

e) Remote installation of the STC lid and removal of the STC from the spent fuel pool.

f) Placement of the STC into the HI-TRAC with the STC centering assembly.

g) STC closure, establishment of STC water level with steam, verification of STC water level, STC leakage testing, and operational steps required prior to transfer, as applicable.

h) Establishment and verification of HI-TRAC water level.

i) Installation of the HI-TRAC top lid.

j) HI-TRAC closure, leakage testing, and operational steps required prior to transfer, as applicable.

k) Movement of the HI-TRAC with STC from the IP3 fuel handling building to the IP2 fuel handling building along the haul route with designated devices.

I) Moving the STC into the IP2 spent fuel pool.

m) Manual crane operations for bare STC movements including demonstration of recovery from a crane hang-up with the STC suspended from the crane.

INDIAN POINT 3 2 Amendment

APPENDIX C TO FACILITY OPERATING LICENSE FOR ENTERGY NUCLEAR INDIAN POINT 3, LLC (ENIP3)

AND ENTERGY NUCLEAR OPERATIONS, INC. (ENO)

INDIAN POINT NUCLEAR GENERATING UNIT No. 3 INTER-UNIT FUEL TRANSFER TECHNICAL SPECIFICATIONS PART II: TECHNICAL SPECIFICATIONS FACILITY LICENSE NO. DPR-64 DOCKET NO. 50-286 Amendment No.

TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1 Definitions 1.2 Logical Connectors 1.3 Completion Times 1.4 Frequency 2.0 NOT USED 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.1 INTER-UNIT FUEL TRANSFER 3.1.1 Boron Concentration 3.1.2 Shielded Transfer Canister (STC) Loading 3.1.3 Shielded Transfer Canister (STC) Initial Water Level 3.1.4 Shielded Transfer Canister (STC) Pressure Rise 3.1.5 Shielded Transfer Canister (STC) Unloading 4.0 DESIGN FEATURES 4.1 Inter-Unit Fuel Transfer 5.0 PROGRAMS 5.1 Transport Evaluation Program 5.2 Metamic Coupon Sampling Program 5.3 Technical Specifications Bases Control Program 5.4 Radiation Protection Program INDIAN POINT 3 i Amendment

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions


I~jI~ J 1 r -- - -- -- -

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

INTACT FUEL ASSEMBLIES INTACT FUEL ASSEMBLIES are fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks, and which can be handled by normal means. Fuel assemblies without fuel rods in fuel rod locations shall not be classified as INTACT FUEL ASSEMBLIES unless dummy fuel rods are used to displace an amount of water greater than or equal to that displaced by the original fuel rod(s).

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an STC while it is being loaded with fuel assemblies and while the STC is being placed in the HI-TRAC. LOADING OPERATIONS begin when the first fuel assembly is placed in the STC and end when the HI-TRAC is suspended from or secured on the TRANSPORTER.

NON-FUEL HARDWARE (NFH) NFH is defined as Burnable Poison Rod Assemblies (BPRAs), Thimble Plug Devices (TPDs), Wet Annular Burnable Absorbers (WABAs), Rod Cluster Control Assemblies (RCCAs), Neutron Source Assemblies (NSAs), Hafnium Flux Suppressors, and Instrument Tube Tie Rods (ITTRs).

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities performed on a HI-TRAC loaded with one or more fuel assemblies when it is being moved after LOADING OPERATIONS or before UNLOADING OPERATIONS.

TRANSFER OPERATIONS begin when the HI-TRAC is first suspended from or secured on the TRANSPORTER and end when the TRANSPORTER is at its destination and the HI-TRAC is no longer secured on or suspended from the TRANSPORTER.

TRANSPORTER TRANSPORTER is the device or vehicle which moves the HI-TRAC. The TRANSPORTER can either support the HI-TRAC from underneath or the HI-TRAC can be suspended from it.

(continued)

INDIAN POINT 3 1.1-1 Amendment

Definitions 1.1 1.1 Definitions (continued)

Term Definition UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an STC or HI-TRAC while it is being unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the HI-TRAC is no longer suspended from or secured on the TRANSPORTER and end when the last fuel assembly is removed from the STC.

ZR ZR means any zirconium-based fuel cladding authorized for use in a commercial nuclear power plant reactor.

INDIAN POINT 3 1.1-2 Amendment

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action).

The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

(continued)

INDIAN POINT 3 1.2-1 Amendment

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 VERIFY...

AND A.2 Restore...

In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed.

(continued)

INDIAN POINT 3 1.2-2 Amendment

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A. 1 Stop...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove ...

This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three ACTIONS may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

INDIAN POINT 3 1.2-3 Amendment

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the Spent Fuel Shielded Transfer Canister and Transfer Cask System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the Spent Fuel Shielded Transfer Canister and Transfer Cask System is not within the LCO Applicability.

Once a Condition has been entered, subsequent subsystems, components, or variables expressed in the Condition, discovered to be not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition.

(continued)

INDIAN POINT 3 1.3-1 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Perform Action B.1 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met. B.2 Perform Action B.2 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND complete action B.2 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

(continued)

INDIAN POINT 3 1.3-2 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system A.1 Restore system 7 days not within limit, to within limit.

B. Required B.1 Complete 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and action B.1.

associated Completion AND Time not met.

B.2 Complete 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> action B.2.

When a system is determined not to meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

INDIAN POINT 3 1.3-3 Amendment

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS k I1fr r

-- ----------------- li Jli' Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> compliance with LCO.

B. Required B.1 Complete action 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Action and B. 1.

associated Completion AND Time not met.

B.2 Complete action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> B.2.

The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis.

When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

IMMEDIATE When "Immediately" is used as a Completion Time, the Required Action COMPLETION should be pursued without delay and in a controlled manner.

TIME INDIAN POINT 3 1.3-4 Amendment

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR)

Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

(continued)

INDIAN POINT 3 1.4-1 Amendment

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is not in a condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the specified condition. Failure to do so would result in a violation of SR 3.0.4.

(continued)

INDIAN POINT 3 1.4-2 Amendment

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES (continued) EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting activity AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting the activity.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND").

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity.

INDIAN POINT 3 1.4-3 Amendment

Not Used 2.0 2.0 NOT USED This section is intentionally left blank INDIAN POINT 3 2.0-1 Amendment

LCO Applicability 3.0 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5.

Ifthe LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.

LCO 3.0.3 Not applicable.

LCO 3.0.4 When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS or that are related to the unloading of an STC.

LCO 3.0.5 Equipment removed from service or not in service in compliance with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate it meets the LCO or that other equipment meets the LCO. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing.

INDIAN POINT 3 3.0-1 Amendment

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met ifthe Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as "once,"the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with Actions or that are related to the unloading of an STC.

INDIAN POINT 3 3.0-2 Amendment

Boron Concentration 3.1.1 3.1 INTER-UNIT FUEL TRANSFER 3.1.1 Boron Concentration LCO 3.1.1 The boron concentration of the water in the Spent Fuel Pit and the STC shall be > 2000 ppm.

APPLICABILITY: Whenever one or more fuel assemblies are in the STC.

Only applicable to the spent fuel pit when the STC is in the spent fuel pit ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. Boron concentration not A.1 Suspend LOADING Immediately within limit. OPERATIONS or UNLOADING OPERATIONS.

AND A.2 Suspend positive reactivity Immediately additions.

AND A.3 Initiate action to restore boron Immediately concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY


NOTE ------------------ --------- Once, within 4 This surveillance is only required to be performed if the STC is hours prior to submerged in water in the spent fuel pool or if water is added to, or recirculated through, the STC when the STC is in the HI-TRAC. Any Applicability of this added water must meet the boron concentration requirement of LCO LCO.

3.1.1.

-AND -

SR 3.1.1.1 Verify the boron concentration is within limit using two Once per 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> separate measurements. thereafter.

INDIAN POINT 3 3.1.1-1 Amendment

STC Loading 3.1.2 3.1 INTER-UNIT FUEL TRANSFER 3.1.2 Shielded Transfer Canister (STC) Loading LCO 3.1.2 INTACT FUEL ASSEMBLIES placed into the Shielded Transfer Canister (STC) shall be classified in accordance with Table 3.1.2-1 based on initial enrichment and burnup and shall be restricted based on the following:

a. INTACT FUEL ASSEMBLIES classified as Type 2 may be placed in the STC basket (see Figure 3.1.2-1) with the following restrictions:
1. Post-irradiation cooling time, initial enrichment, and allowable average burnup shall be within the limits for the cell locations as specified in Table 3.1.2-3;
2. Decay heat including NON FUEL HARDWARE < 650 Watts (cells 5 through 12);
3. Decay heat including NON FUEL HARDWARE < 1105 Watts (cell 1, 2, 3 or 4);
4. Post-irradiation cooling time and the maximum average burnup of NON FUEL HARDWARE shall be within the cell locations and limits specified in Table 3.1.2-2. In accordance with Table 3.1.2-2 RCCAs and Hafnium Flux Suppressors cannot be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket.

- NOTE -

If one or more Type 1 fuel assemblies are in the STC, cells 1, 2, 3, AND 4 must be empty, with a cell blocker installed that prevents inserting fuel assemblies and/or NON-FUEL HARDWARE.

b. INTACT FUEL ASSEMBLIES classified as Type 1 or Type 2 may be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket (see Figure 3.1.2-1) with the following restrictions:
1. Post-irradiation cooling time, initial enrichment, and allowable average burnup shall be within the limits for the cell locations as specified in Table 3.1.2-3;
2. Decay heat including NON FUEL HARDWARE < 650 Watts;
3. Post-irradiation cooling time and the maximum average burnup of NON FUEL HARDWARE shall be within the cell locations and limits specified in Table 3.1.2-2. In accordance with Table 3.1.2-2 RCCAs and Hafnium Flux Suppressors cannot be placed in locations 5, 6, 7, 8, 9, 10, 11, 12 of the STC basket.
c. Only INTACT FUEL ASSEMBLIES with initial average enrichment a 3.2 and < 4.4 wt% U-235 and discharged prior to IP3 Cycle 12 shall be placed in the STC basket.

INDIAN POINT 3 3.1.2-1 Amendment

STC Loading

3.1.2 APPLICABILITY

Whenever one or more fuel assemblies are in the STC.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more fuel A.1.1 Initiate action to Immediately assemblies or NON restore compliance FUEL HARDWARE in with LCO 3.1.2.

the STC do not meet the LCO limits. OR A.1.2 Initiate action to move fuel to the IP3 spent fuel pit in accordance with IP3 Appendix A Technical Specification LCO 3.7.16.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify by administrative means that the fuel Prior to placing the fuel assembly and NON FUEL HARDWARE meets the assembly in the STC.

requirements specified in the LCO for placement in the STC.

SR 3.1.2.2 Verify by visual inspection that a cell blocker which Prior to placing a Type 1 prevents inserting fuel assemblies and/or NON- fuel assembly in the STC.

FUEL HARDWARE into cells 1, 2, 3, and 4 of the STC is installed.

INDIAN POINT 3 3.1.2-2 Amendment

STC Loading 3.1.2 Figure 3.1.2-1 Shielded Transfer Canister Layout (Top View)

INDIAN POINT 3 3.1.2-3 Amendment

STC Loading 3.1.2 Table 3.1.2-1 Minimum Burnup Requirements at Varying Initial Enrichments(a)

Configuration A(c) Configuration B(d)

Maximum Assembly Minimum Assembly Minimum Assembly Average Burnup Average Burnup (wt% U235) (MWD/MTU)(b) (MWD/MTU)(b) 2.0 5,400 6,000 2.5 13,800 18,800 3.0 22,100 28,600 3.5 30,000 37,300 4.0 36,900 44,600 4.5 42,700 52,500 5.0 48,700 Note (e)

(a) Fuel that does not meet the minimum assembly average burnup at a given initial enrichment is classified as Type 1 fuel. Fuel that meets the minimum assembly average burnup at a given initial enrichment is classified as Type 2 fuel.

(b) Linear interpolation between enrichment levels to determine minimum burnup requirements is permitted.

(c) Assemblies that have not been located in any cycle under a control rod bank that was permitted to be inserted during full power operation or where it can be shown that the insertion did not exceed 8 inches below the top of the active fuel.

(d) Assemblies that have been located under a control rod bank that was permitted to be inserted during full power operation and where the insertion was more than 8 inches below the top of the active fuel. This configuration also applies to fuel assemblies that have contained a Hafnium Flux Suppressor.

(e) Configuration B assemblies with enrichment greater than 4.5 are classified as Type 1 fuel.

(f) Natural or enriched uranium blankets are not considered in determining the fuel assembly average enrichment for comparison to the maximum allowed initial average enrichment.

(g) Rounding to one decimal place to determine initial enrichment is not permitted.

INDIAN POINT 3 3.1.2-4 Amendment

STC Loading 3.1.2 Table 3.1.2-2 NON FUEL HARDWARE(a) Post Irradiation Cooling Times and Allowable Average Burnup Maximum Burnup Post-irradiation (MWD/MTU)

Cooling Time (years) BPRAs and TPDs(b)(c) RCCAs Hafnium Flux WABAs(b) Suppressors

>6 < 20000 N/A S 630000 < 20000

>7 - 20000 - -

a8 < 30000 - < 30000

>9 <540000 < 30000 - -

>10 < 50000 < 40000 - -

>11 < 60000

  • 45000 - -

> 12 - !50000 - -

->13 < 60000 - -

>14 -- -

>Ž15 - 90000 - -

> 16 - 5630000 - -

> 20 ---

Allowed Up to twelve Up to twelve Up to four (4) Up to four (4)

Quantity and (12) per (12) per per transfer in per transfer in Location transfer in any transfer in Cells 1, 2, 3, Cells 1, 2, 3, location any location and/or 4 and/or 4 (a) NON-FUEL HARDWARE burnup and cooling time limits are not applicable to Instrument Tube Tie Rods (ITTRs), since they are installed post-irradiation. NSAs are not authorized for loading in the STC.

(b) Linear interpolation between points is only permitted for BPRAs, WABAs, and TPDs, with the exception that interpolation is not permitted for TPDs with burnups greater than 90 GWd/MTU and cooling times greater than 15 years.

(c) N/A means not authorized for loading at this cooling time.

INDIAN POINT 3 3.1.2-5 Amendment

STC Loading 3.1.2 Table 3.1.2-3 Allowable STC Loading Configurations Configuration(c) Cells 1,2, 3, 4 (a)(b) Cells 5, 6, 7, 8, 9, 10, 11, 12 (a)(b)

Burnup 5 55,000 MWD/MTU Burnup 5 40,000 MWD/MTU 1 Cooling time > 10 years Cooling time > 25 years Initial Enrichment a 3.4 wt% U-235 Initial Enrichment a 2.3 wt% U-235 Burnup 5 45,000 MWD/MTU Burnup <45,000 MWD/MTU 2 Cooling time a 10 years Cooling time a 20 years Initial Enrichment > 3.2 wt% U-235 Initial Enrichment a 3.2 wt% U-235 Burnup 5 55,000 MWD/MTU Burnup 5 45,000 MWD/MTU 3 Cooling time a 10 years Cooling time a 20 years Initial Enrichment a 3.4 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup 5 45,000 MWD/MTU Burnup 5 40,000 MWD/MTU 4 Cooling time > 10 years Cooling time > 12 years Initial Enrichment > 3.6 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup 5 45,000 MWD/MTU Burnup 5 40,000 MWD/MTU 5 Cooling time > 14 years Cooling time > 12 years Initial Enrichment ? 3.4 wt% U-235 Initial Enrichment > 3.2 wt% U-235 Burnup *45,000 MWD/MTU Burnup 5 40,000 MWD/MTU 6 Cooling time > 20 years Cooling time > 20 years Initial Enrichment ? 3.2 wt% U-235 Initial Enrichment > 2.3 wt% U-235 (a) Initial enrichment is the assembly average enrichment. Natural or enriched uranium blankets are not considered in determining the fuel assembly average enrichment for comparison to the minimum allowed initial average enrichment.

(b) Rounding to one decimal place to determine initial enrichment is permitted.

(c) Fuel with five middle Inconel spacers are limited to cells 1, 2, 3, and 4 for all loading configurations except loading configuration 6 which allows fuel with Inconel spacers in all cells.

INDIAN POINT 3 3.1.2-6 Amendment

STC Initial Water Level 3.1.3 3.1 INTER-UNIT FUEL TRANSFER 3.1.3 Shielded Transfer Canister (STC) Initial Water Level LCO 3.1.3 The established water level in the STC shall be 9.0+0.5/-1.5 inches below the bottom of the STC lid.

APPLICABILITY: Prior to TRANSFER OPERATIONS when the STC is in the HI-TRAC and the STC lid has been installed.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. STC water level not within ------------ NOTE ------------ Immediately limit. Water used for level restoration must meet the boron concentration requirement of LCO 3.1.1.

A.1 Initiate action to restore STC water level.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify the initial STC water level is within limit by Once prior to verifying the following during STC water level TRANSFER establishment: OPERATIONS.

a. steam is emitted from the STC drain tube; and
b. the volume of water removed is > 35.4 gallons and < 47.9 gallons.

INDIAN POINT 3 3.1.3-1 Amendment

STC Pressure Rise 3.1.4 3.1 INTER-UNIT FUEL TRANSFER 3.1.4 Shielded Transfer Canister (STC) Pressure Rise LCO 3.1.4 The pressure rise in the STC cavity shall be < 0.2 psi/hr averaged over a rolling 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period.

APPLICABILITY: Over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period after successful completion of LCO 3.1.3 and prior to TRANSFER OPERATIONS when the STC is in the HI-TRAC and the STC lid has been installed.

ACTIONS COMPLETION TIME CONDITION REQUIRED ACTION TIME A. Rate of STC cavity A.1.1 Establish a vent path on the Immediately pressure rise not within STC.

limit.

AND


NOTE-Water used for recirculation must meet the boron concentration requirement of LCO 3.1.1.

A.1.2 Begin circulation of borated water in the STC to establish and maintain the STC water exit temperature < 180 0 F.

AND A.1.3 Begin actions to determine the reason for exceeding the pressure rise limit.

(continued)

INDIAN POINT 3 3.1.4-1 Amendment

STC Pressure Rise 3.1.4 ACTIONS (continued)

COMPLETION TIME CONDITION REQUIRED ACTION TIME B. Required Action A.1.3 B.1.1 Return the STC to the spent 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> indicates a fuel misload. fuel pool and remove the STC lid.

AND B.1.2 Return any misloaded fuel to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the IP3 spent fuel pit in accordance with IP3 Appendix A Technical Specification LCO 3.7.16.

C. Required Action A.1.3 C.1 Develop and initiate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> does not indicate a fuel corrective actions necessary misload. to return the STC to compliance with LCO 3.1.3 and LCO 3.1.4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 ---------- NOTE--------- Once priorto TRANSFER Pressure measurements shall be taken once upon ORATIONS establishing required water level AND hourly OPERATIONS.

thereafter for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Pressure may initially drop during pressure stabilization.

Verify by direct measurement that the rate of STC cavity pressure rise is within limit.

SR 3.1.4.2 Verify that an ASME code compliant pressure relief During valve or rupture disc and two channels of pressure performance of SR instrumentation with a range of at least 0.1 psia to 15 3.1.4.1.

psia and calibrated to within 1% accuracy within the past 12 months are installed on the STC.

INDIAN POINT 3 3.1.4-2 Amendment

STC Unloading 3.1.5 3.1 INTER-UNIT FUEL TRANSFER 3.1.5 Shielded Transfer Canister (STC) Unloading


NOT I -

1. Only IP3 spent fuel assemblies are permitted to be in the STC.
2. Once each IP3 spent fuel assembly removed from the STC has been placed in an IP2 spent fuel rack location and disconnected from the spent fuel pit bridge crane, it may not be returned to the STC.

LCO 3.1.5 IP3 spent fuel assemblies transferred to IP2 via the STC must be either in an approved IP2 spent fuel pit storage rack location per IP2 Appendix A Technical Specification LCO 3.7.13, in their authorized STC fuel basket cell, or be in transit between these two locations.

APPLICABILITY: Whenever the STC is in the Unit 2 spent fuel pit.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more fuel A.1 Initiate action to Immediately assemblies not in the restore compliance required location, with LCO 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify by administrative means that a fuel Once, after each re-loaded assembly returned to the STC has been re- fuel assembly is retumed to loaded into the same STC cell from which it was the STC.

removed.

INDIAN POINT 3 3.1.5-1 Amendment

Design Features 4.0 4.0 DESIGN FEATURES 4.1 Inter-Unit Fuel Transfer 4.1.1 Fuel Assemblies Fuel assemblies selected for inter-unit transfer of fuel shall meet the fuel characteristics specified in Table 4.1.1-1.

4.1.2 Criticality 4.1.2.1 The Shielded Transfer Canister (STC) is designed and shall be maintained with:

a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent;
b. ke f< 0.95 if fully flooded with unborated water;
c. A nominal 9.218 inch center-to-center distance between fuel assemblies placed in the STC basket;
d. Basket cell ID: 8.79 in. (nominal);
e. Basket cell wall thickness: 0.28 in. (nominal);
f. B4C in the Metamic neutron absorber: > 31.5 wt.% and < 33.0 wt.%;
g. The B4C in the Metamic neutron absorber will contain boron with an isotopic B-1 0 content of at least 18.4%;
h. Metamic panel thickness: > 0.102 in.;
i. The size and location of the neutron absorber panels shall be in accordance with drawing 6015, revision 6, which can be found in the Licensing Report (Holtec International Report HI-2094289).

4.1.2.2 Drainage The STC is designed and shall be maintained to prevent inadvertent draining.

4.1.2.3 Capacity The STC is designed and shall be maintained with a capacity of no more than 12 fuel assemblies.

(continued)

INDIAN POINT 3 4.0-1 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued) 4.1.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2004 Edition, is the governing Code for the STC, as clarified below, except for Code Sections V and IX.The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 2004 Edition, is performed. Table 4.1.3-1 lists approved alternatives to the ASME Code for the design of the STC.

4.1.4 Geometric Arrangements and Process Variables The following are geometric arrangements and process variables that require a one time verification as part of each inter-unit fuel transfer operation:

1. LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures

> 0OF.

2. LOADING OPERATIONS shall only be conducted when the spent fuel pit water temperature and the fuel handling building ambient temperatures are both <

I 00°F.

3. LOADING OPERATIONS shall only be conducted when the IP3 spent fuel pit contains no unirradiated fuel assemblies.
4. LOADING OPERATIONS shall only be conducted when the irradiated fuel assemblies in the IP3 spent fuel pit have been subcritical for at least 90 days.
5. TRANSFER OPERATIONS shall only be conducted when the outside air temperature is < 100 0 F.
6. TRANSFER OPERATIONS shall only be conducted when the STC trunnions are offset from the HI-TRAC trunnions in the azimuthal direction by at least 30 degrees.
7. TRANSFER OPERATIONS shall only be conducted after STC seal leak tests have demonstrated no detected leakage when tested to a sensitivity of 1x10-3 ref-cm 3/s in accordance with the "pre-shipment" test requirements of ANSI N14.5.
8. Prior to installing the HI-TRAC lid the HI-TRAC water level shall be verified by two separate inspections to be within +00-1 inch of the top of the STC lid.

(continued)

INDIAN POINT 3 4.0-2 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued)

9. TRANSFER OPERATIONS shall only be conducted after the combined leak rate through the HI-TRAC top lid and vent port cover seals are confirmed to be water tight using an acceptable leak test from ANSI N14.5 and the pool lid seal is verified to be water tight by visual inspection.
10. TRANSFER OPERATIONS shall not occur with a TRANSPORTER that contains > 50 gallons of diesel fuel.

Table 4.1.1-1 Fuel Assembly Characteristics Fuel Assembly Class 15xl 5(a)

No. of Fuel Rod Locations 204 Cladding Type ZR Guide/Instrument Tube Type ZR Design Initial U (kg/assembly) < 473 Fuel Rod Clad O.D. (in) >0. 422 Fuel Rod Clad I.D. (in) *0. 3734 Fuel Pellet Diameter (in) <0. 3659 Fuel Rod Pitch (in) < 0.563 Active Fuel Length (in) < 144 Fuel Assembly Length (in) *160 Fuel Assembly Width (in) < 8.54 No. of Guide and/or Instrument Tubes 21 Guide/Instrument Tube Thickness (in) > 0. 017 Axial Blanket Enrichment (wt % U-235) (b) < 3.2 Axial Blanket Length (in)(b) >6 (a) All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within the 15x1 5 class.

(b) Applicable only if axial blankets are present.

INDIAN POINT 3 4.0-3 Amendment

Design Features 4.0 (continued) 4.0 DESIGN FEATURES (continued)

Table 4.1.3-1 (page 1 of 2)

List of ASME Code Alternatives for the STC Component Reference ASME Code Requirement Alternative, Justification &

Code Compensatory Measures Section/Article STC ND-1000 Statement of Cask confinement boundary is designed, and will Confinement requirements for Code be fabricated in accordance with ASME Code, Boundary stamping of Section III, Subsection ND to the maximum components. practical extent, but Code stamping is not required.

STC ND-2000 Requires materials to be Holtec approved suppliers will supply materials Confinement supplied by ASME- with CMTRs per ND-2000.

Boundary approved material supplier.

STC and STC ND-3100 Provides requirements These requirements are not applicable. The basket NG-3100 for determining design Licensing Report, serving as the Design assembly loading conditions, such Specification, establishes the service conditions as pressure, and load combinations for fuel transfer.

temperature, and mechanical loads.

STC ND-7000 Vessels are required to No overpressure protection is provided. Function Confinement have overpressure of cask vessel is as a radionuclide confinement Boundary protection. boundary under normal and hypothetical accident conditions. Cask is designed to withstand maximum internal pressure and maximum accident temperatures.

STC ND-8000 States requirement for STC to be marked and identified in accordance Confinement name, stamping and with drawing 6013(a). Code stamping is not Boundary reports per NCA-8000 required. QA data package prepared in accordance with Holtec's approved QA program.

INDIAN POINT 3 4.0-4 Amendment

Design Features 4.0 4.0 DESIGN FEATURES (continued)

Table 4.1.3-1 (page 2 of 2)

List of ASME Code Alternatives for the STC Component Reference ASME Code Requirement Alternative, Justification &

Code Compensatory Measures Section/Article STC Basket NG-4420 NG-4427(a) requires a Modify the Code requirement (intended for core Assembly fillet weld in any single support structures) with the following text prepared to continuous weld may accord with the geometry and stress analysis be less than the imperatives for the fuel basket: For the longitudinal specified fillet weld STC basket fillet welds, the following criteria apply:

dimension by not 1) The specified fillet weld throat dimension must be more than 1/16 inch, maintained over at least 92 percent of the total weld provided that the total length. All regions of undersized weld must be less undersize portion of than 3 inches long and separated from each other by the weld does not at least 9 inches. 2) Areas of undercuts and porosity exceed 10 percent of beyond that allowed by the applicable ASME Code the length of the weld. shall not exceed 1/2 inch in weld length. The total Individual undersize length of undercut and porosity over any 1-foot weld portions shall not length shall not exceed 2 inches. 3) The total weld exceed 2 inches in length in which items (1) and (2) apply shall not length. exceed a total of 10 percent of the overall weld length. The limited access of the STC basket panel longitudinal fillet welds makes it difficult to perform effective repairs of these welds and creates the potential for causing additional damage to the basket assembly (e.g., to the neutron absorber and its sheathing) if repairs are attempted. The acceptance criteria provided in the foregoing have been established to comport with the objectives of the basket design and preserve the margins demonstrated in the supporting stress analysis.

From the structural standpoint, the weld acceptance criteria are established to ensure that any departure from the ideal, continuous fillet weld seam would not alter the primary bending stresses on which the design of the fuel baskets is predicated. Stated differently, the permitted weld discontinuities are limited in size to ensure that they remain classifiable as local stress elevators ("peak stress", F, in the ASME Code for which specific stress intensity limits do not apply).

STC Basket NG-8000 States requirements STC basket to be marked and identified in Assembly for nameplates, accordance with drawing 6015(a). No Code stamping stamping and reports is required. The STC basket data package is to be in per NCA-8000. conformance with Holtec's QA program.

(a) Holtec International Report HI-2094289 INDIAN POINT 3 4.0-5 Amendment

Programs 5.0 5.0 PROGRAMS The following programs shall be established, implemented and maintained.

5.1 Transport Evaluation Program

a. For lifting of the loaded STC or loaded HI-TRAC using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.
b. This program is not applicable when the loaded HI-TRAC is in the fuel building or is being handled by equipment providing support from underneath (e.g., on air pads).
c. The loaded HI-TRAC may be lifted to any height necessary during TRANSFER OPERATIONS provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.
1. The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.
2. The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. This includes applicable stress limits from ANSI N14.6.
3. The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.
d. The lift height of the loaded HI-TRAC above the transport route surface or other supporting surface shall be limited to 6 inches, except as provided in Specification 5.1.c.

5.2 Metamic Coupon Sampling Program A coupon surveillance program shall be implemented to maintain surveillance of the Metamic neutron absorber material under the radiation, chemical, and thermal environment of the STC.

The surveillance program will be implemented to monitor the performance of Metamic by installing a minimum of four bare coupons near the maximum gamma flux elevation (mid height) at no less than four circumferential downcomer areas around the STC fuel basket. At any time during its use the STC must have a minimum of one coupon installed in each quadrant. Metamic coupons used for testing must have been installed during the entire fuel loading history of the STC.

The following specifications apply:

(i) Coupon size will be nominally 4" x 6". Each coupon will be marked with a unique identification number.

(continued)

INDIAN POINT 3 5.0-1 Amendment

Programs 5.0 5.0 PROGRAMS (continued)

(ii) Pre-characterization testing: Before installation, each coupon will be measured and weighed. The measurements shall be taken at locations pre-specified in the test program. Each coupon shall be tested by neutron attenuation before installation in the STC. The weight, length, width, thickness, and results of the neutron attenuation testing shall be documented and retained.

(iii) Four coupons shall be tested at the end of each inter-unit fuel transfer campaign. A campaign shall not last longer than two years. The coupons shall be measured and weighed and the results compared with the pre-characterization testing data. The results shall be documented and retained.

(iv) The coupons shall be examined for any indication of swelling, delamination, edge degradation, or general corrosion. The results of the examination shall be documented and retained.

(v) The coupons shall be tested by neutron attenuation and the results compared with the pre-characterization testing data. The results of the testing shall be documented and retained. Results are acceptable if the measured value is within +/-2.5% of the value measured for the same coupon at manufacturing.

(vi) The coupons shall be returned to their locations in the STC unless anomalous material behavior is found. If the results indicate anomalous material behavior, evaluation and corrective actions shall be pursued.

5.3 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.
b. Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:
1. a change in the TS incorporated in the license; or
2. a change to the updated FSAR or Bases that requires NRC approval pursuant to 10 CFR 50.59.
c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.
d. Proposed changes that do not meet the criteria of Specification 5.3.b above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).

(continued)

INDIAN POINT 3 5.0-2 Amendment

Programs 5.0 5.0 PROGRAMS (continued) 5.4 Radiation Protection Proqram 5.4.1 The radiation protection program shall appropriately address STC loading and unloading conditions, including transfer of the loaded TRANSFER CASK outside of facilities govemed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA).

The actions and criteria to be included in the program are provided below.

5.4.2 Total (neutron plus gamma) measured dose rates shall not exceed the following:

a. 1400 mrem/hr on the top of the STC (with lid in place).
b. 5 mrem/hr on the side of the TRANSFER CASK 5.4.3 The STC and TRANSFER CASK surface neutron and gamma dose rates shall be measured as described in Section 5.4.6 for comparison against the limits established in Section 5.4.2.

5.4.4 If the measured surface dose rates exceed the limits established in Section 5.4.2, then:

a. Administratively verify that the correct contents were loaded in the correct fuel basket cell locations.
b. Perform a written evaluation to determine whether TRANSFER OPERATIONS can proceed without exceeding the dose limits of 10 CFR 72.104 or 10 CFR 20.1301.

5.4.5 If the verification and evaluation performed pursuant to Section 5.4.4 show that the fuel is loaded correctly and the dose rates from the STC and TRANSFER CASK will not cause the dose limits of 10 CFR 72.104 or 10 CFR 20.1301 to be exceeded, TRANSFER OPERATIONS may occur. Otherwise, TRANSFER OPERATIONS shall not occur until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.4.6 STC and TRANSFER CASK surface dose rates shall be measured at approximately the following locations:

a. The dose rate measurement shall be taken at the approximate center of the STC top lid. Two (2) additional measurements shall be taken on the STC lid approximately 180 degrees apart and 12 to 18 inches from the center of the lid, avoiding the areas around the inlet and outlet ports. The measurements must be taken when the STC is in the HI-TRAC after the steam space is established and prior to HI-TRAC lid installation.

(continued)

INDIAN POINT 3 5.0-3 Amendment

Programs 5.0 5.0 PROGRAMS (continued)

b. A minimum of four (4) dose rate measurements shall be taken on the side of the TRANSFER CASK approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket.

INDIAN POINT 3 5.0-4 Amendment

ATTACHMENT 3 TO NL-12-047 Indian Point Unit 2 - Proposed Revision to Appendix A TS Affected Tech Spec Pages: 3.7.13-1 3.7.13-2 3.7.13-3 3.7.13-4 3.7.13-5 3.7.13-6 Entergy Nuclear Operations, Inc.

Indian Point Unit 2 Docket No. 50-247

Spent Fuel Pit Storage 3.7.13 3.7 PLANT SYSTEMS 3.7.13 Spent Fuel Pit Storage RP2 fuel I

[CO 3.7.13 Ftiel, assemblies stored in the Spent Fuel Pit shall be classified in accordance with Figure 3.7.13-1, Figure 3.7.13-2, Figure 3.7.13-3, and Figure 3.7.13-4, based on initial enrichment, burnup, cooling time and number of Integral Fuel Burnable Absorbers (IFBA) rods; and, Fuel assembly storage location within the Spent Fuel Pit shall be restricted to Regions identified in Figure 3.7.13-5 as follows:

a. Fuel assemblies that satisfy requirements of Figure 3.7.13-1 may be stored in any location in Region 2-1, Region 2-2, Region 1-2 or Region 1-1;
b. Fuel assemblies that satisfy requirements of Figure 3.7.13-2 may be stored in any location in Region 2-2, Region 1-2 or Region 1-1;
c. Fuel assemblies that satisfy requirements of Figure 3.7.13-3 may be stored in any location in Region 1-2, Region 1-1, or in locations designated as "peripheral" cells in Region 2-2; and
d. Fuel assemblies that satisfy requirements of Figure 3.7.13-4 may be stored:
1) In any location in Region 1-2, or
2) In a checkerboard loading configuration (1 out of every two cells with every other cell vacant) in Region 1-1; or
3) In locations designated as "peripheral" cells in Region 2-2.

APPLICABILITY: / Whenever any fuel assembly is stored in the Spent Fuel Pit.

IP3 fuel assemblies shall be stored in Region 1-2 of the Spent Fuel Pit.

Only assemblies with initial enrichment > 3.2 and < 4.4 w/o U235 and discharged prior to IP3 Cycle 12 shall be stored in the Spent Fuel Pit.

INDIAN POINT 2 3.7.13- 1 Amendment No. 238

Spent Fuel Pit Storage 3.7.13 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the A.1 LCO not met. - NOTE -

LCO 3.0.3 is not applicable.

Initiate action to move the Immediately noncomplying fuel assembly to an acceptable location.

F1P2f SURVEILLANCE REQUIREMENTS _

SURVEILLANCE FREQUENCY SR 3.7.13.1 Verify by administrative means that the fuel Prior to storing the assembly has been classified in accordance with fuel assembly in Figure 3.7.13-1, Figure 3.7.13-2, Figure 3.7.13-3, or the Spent Fuel Pit.

Figure 3.7.13-4 and meets the requirements for the intended storage location.

  • ~ _D;1" .

OR Prior to storing the Verify by administrative means that the fuel assembly in IP3 fuel assembly meets the the Spent Fuel Pit.

requirements for the intended storage location.

INDIAN POINT 2 3.7.13-2 Amendment No. 238

Spent Fuel Pit Storage 3.7.13 0 Years Cooling 60 ...... 5 Yr Cooling -

-- 10 Yr. Cooling

....- 15Yr Cooling 50 7. 20 Yr. Cooling Acceptable for Storage in Region 2-1 - - - - -

40 I-30 ci nC 20 Not Acceptable for Storage in Region 2-1 10 0

1 2 4 5 Initial Enrichment, W/o U 235 JIP2 Fuel Assemblyl Figure 3.7.13-1 Limiting Burnup and Cooling Time versus Initial Enrichment:

Acceptable for Storage in Any Location in Region 2-1, Region 2-2, Region 1-2 or Region 1-1 INDIAN POINT 2 3.7.13-3 Amendment No. 238

Spent Fuel Pit Storage 3.7.13 40 30

(.9 20 10 0

1 2 3 4 5 2 35 Initial Enrichment, W/o U IP2 Fuel Assembly I Figure 3.7.13-2 Limiting Bumup and Cooling Time versus Initial Enrichment:

Acceptable for Storage in Any Location in Region 2-2, Region 1-2 or Region 1-1 INDIAN POINT 2 3.7.13 -4 Amendment No. 238

Spent Fuel Pit Storage 3.7.13 40 30 F-0 CL 20 10 0

1 2 3 4 Initial Enrichment, W/o U235 IP2 Fuel Assembly Figure 3.7.13-3 Limiting Burnup versus Initial Enrichment:

Acceptable for Storage in Any Location in Region 1-2, Region 1-1, or in locations designated as "peripheral" cells in Region 2-2.

INDIAN POINT 2 3.7.13-5 Amendment No. 238

Spent Fuel Pit Storage 3.7.13 25 20 Acceptable for Storage Oin Region 1-2 or Checkerboard

  • D "0 Loading in Region 1-1

< 15 U-0 I1,...

M 10 Z Not Acceptable for Storage in Region 1-2 or Checkerboard Loading in Region 1-1 5

4.5 4.6 4.7 4.8 4.9 5 Initial Enrichment, W/o U235 lIP2 Fuel AssemblyI Figure 3.7.13-4 Minimum number of IFBA rods versus Initial Enrichment:

1) Acceptable for Storage in Any Location in Region 1-2, or
2) Acceptable for Storage In a checkerboard loading configuration in Region 1-1, or
3) Acceptable for Storage in locations designated as "peripheral" cells in Region 2-2.

INDIAN POINT 2 3.7.13-6 Amendment No. 238

ATTACHMENT 4 TO NL-12-047 No Significant Hazards Consideration for Indian Point Unit 2 Pertaining to Inter-Unit Fuel Transfer Entergy Nuclear Operations, Inc.

Indian Point Unit 2 Docket No. 50-247

NL-12-047 Attachment 4 Page 1 of 7 Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for IP2 by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No.

The proposed amendment proposes to modify Operating License (OL) Conditions 2.B.(5) and 2.C.(2), and to add a new OL Condition 2.P that together allow the transfer to and possession of IP3 fuel in the IP2 spent fuel pit subject to the conditions listed in a new Appendix C to the IP2 Operating License. The new Appendix C Inter-Unit Fuel Transfer Technical Specifications is common to both IP2 and IP3 and controls inter-unit fuel transfer operations via LCOs, Design Features, and Programs as follows:

LCO 3.1.1 Boron Concentration LCO 3.1.2 Shielded TransferCanister(STC) Loading LCO 3.1.3 Shielded Transfer Canister(STC) Initial Water Level LCO 3.1.4 Shielded TransferCanister(STC) PressureRise LCO 3.1.5 Shielded Transfer Canister(STC) Unloading Design Feature 4.1 Inter-Unit Fuel Transfer 4.1.1 FuelAssemblies 4.1.2 Criticality 4.1.3 Codes and Standards 4.1.4 GeometricArrangements and Process Variables Program 5.1 TransportEvaluation Program Program 5.2 Metamic Coupon Sampling Program Program 5.3 Technical Specifications (TS) Bases ControlProgram Program 5.4 Radiation ProtectionProgram The proposed amendment also proposes to revise IP2 Appendix A LCO 3.7.13 Spent Fuel Pit Storage The proposed amendment adds Appendix C LCO 3.1.1 Boron Concentration.The purpose of the LCO and associated Action and Surveillance Requirement is to place controls on the spent fuel pit boron concentration and the STC boron concentration whenever fuel is in the STC to ensure compliance with the accident analysis assumptions during loading, transfer, and unloading operations.

The proposed amendment adds Appendix C LCO 3.1.2 Shielded Transfer Canister(STC)

Loading. The purpose of the LCO and associated Action and Surveillance Requirements are to place controls on the loading of the STC within the IP3 spent fuel pit to ensure compliance with accident analysis assumptions and to take immediate action to restore compliance should the LCO not be met. The LCO also ensures that fuel loaded into the STC meets IP2 LCO 3.7.13 requirements for storage in the IP2 spent fuel pit. The proposed amendment also adds a new Appendix C Design Feature 4.1.2 Criticalitythat ensures the design of the STC is in compliance with the criticality analysis, prevents inadvertent drainage of the STC, and restricts the

NL-12-047 Attachment 4 Page 2 of 7 maximum capacity of the STC to 12 fuel assemblies. In addition, a new Appendix C Program 5.2 Metamic Coupon Sampling Program is proposed to ensure that the characteristics of Metamic assumed in the criticality analysis are preserved.

The proposed amendment adds Appendix C LCO 3.1.3 Shielded Transfer Canister(STC) Initial Water Level. The purpose of the LCO and associated Action and Surveillance Requirement is to place controls on the STC water level to ensure compliance with the accident analysis assumptions during transfer and unloading operations.

The proposed amendment adds Appendix C LCO 3.1.4 Shielded Transfer Canister(STC)

Pressure Rise. The purpose of the LCO and associated Action and Surveillance Requirements are to detect an accidental misloading of a high decay heat fuel assembly or misloading of multiple assemblies within the IP3 fuel handling building and to take appropriate actions prior to transfer operations.

The proposed amendment adds Appendix C LCO 3.1.5 Shielded Transfer Canister(STC)

Unloading. The purpose of the LCO and associated Action and Surveillance Requirement is to place controls on the unloading of the STC within the IP2 spent fuel pit to ensure compliance with accident analysis assumptions and to take immediate action to restore compliance should the LCO not be met. The proposed amendment also adds a new Appendix C Design Feature 4.1.2 Criticalitythat ensures the design of the STC is in compliance with the criticality analysis, prevents inadvertent drainage of the STC, and restricts the maximum capacity of the STC to 12 fuel assemblies. In addition, a new Appendix C Program 5.2 Appendix C Metamic Coupon Sampling Program is proposed to ensure that the characteristics of Metamic assumed in the criticality analysis are preserved.

The proposed amendment also proposes to revise Appendix A LCO 3.7.13 Spent Fuel Pit Storage. The revision adds the restriction that IP3 fuel assemblies must be stored in Region 1-2 of the Spent Fuel Pit, that the fuel assembly initial enrichment > 3.2 and < 4.4 w/o U235 , and the fuel assembly discharge Cycle > 1 and < 11. These restrictions ensure that the IP3 fuel assemblies loaded into the IP2 spent fuel pit are bounded by the results of the IP2 spent fuel pit criticality analysis.

The previously evaluated accidents that must be considered are a criticality accident, a boron dilution accident in the spent fuel pit, a fuel handling accident (FHA), a loss of spent fuel pit cooling and natural events.

Criticality Accidents The probability of a criticality accident at IP2 is not increased because proposed Appendix C LCO 3.1.5 Shielded Transfer Canister(STC) Unloading requires that the IP3 spent fuel assemblies transferred to IP2 via the STC must be either in an approved IP2 spent fuel pit storage rack location per IP2 Appendix A LCO 3.7.13 Spent Fuel Pit Storage, in their authorized STC fuel basket cell, or be in transit between these two locations. Administrative controls will be established to assure fuel movement under the requirements of this LCO are in compliance with the criticality analyses described in this amendment request, and, therefore, these fuel movements do not significantly increase the probability of a criticality accident. The probability for a criticality event due to neutronic coupling, while the STC is in the spent fuel pit, is negligible because of the STC steel and lead vessel walls and the minimum distance between the STC and the nearest spent fuel rack will be maintained by procedure. In addition, from a criticality

NL-12-047 Attachment 4 Page 3 of 7 perspective, the IP3 and IP2 fuel assemblies are neutronically equivalent when fuel design and operating history are considered. The IP3 fuel assemblies to be stored in the IP2 spent fuel pit will be restricted in accordance with the proposed revision to Appendix A LCO 3.7.13, which requires in part, that the IP3 assemblies be stored in Region 1-2. These regions are qualified for higher reactivity fuel and offset differences in fuel design, reactor operation, and criticality methodology.

The consequences of a criticality accident within the spent fuel pit are not changed because the fuel assemblies are spaced in a pattern within the STC and the spent fuel pit that continue to preserve criticality accident analyses assumptions.

Boron Dilution Accident The probability of a boron dilution event remains the same because the proposed change does not alter the manner in which the IP2 spent fuel cooling system or any other plant system is operated, or otherwise increase the likelihood of adding significant quantities of unborated water into the spent fuel pit. In addition, the STC is loaded in the IP3 spent fuel pit, where the boron concentration in the STC is controlled by the new Appendix C LCO 3.1.1 Boron Concentration that imposes a minimum boron concentration limit of 2000 ppm. The boron concentration in the IP2 spent fuel pit is also controlled to a minimum of 2000 ppm by existing IP2 Appendix A LCO 3.7.12 Spent Fuel Pit Boron Concentration.

The consequences of the boron dilution event remains as described in the IP2 UFSAR because the minimum concentration of soluble boron in the spent fuel pit required by the IP2 Appendix A Technical Specifications remains the same (2,000 ppm). The reactivity of the STC filled with the most reactive combination of approved fuel assemblies in unborated water results in a keff less than 0.95. Thus, even in the unlikely event of a complete dilution of the spent fuel pit water, the STC will remain safely subcritical.

Fuel Handling Accident The probability of an FHA which includes a fuel assembly drop accident and a fuel cask drop accident remains very remote because of the many administrative controls and physical limitations imposed on fuel-handling operations. The probability of an FHA will not increase significantly due to the proposed changes because the individual fuel assemblies will be moved from the STC to the spent fuel pit racks in the same manner, using the same equipment, procedures, and other administrative controls (i.e. fuel move sheets) that are currently used.

The fuel basket design in the STC emulates that of a spent fuel rack, making the individual fuel assembly movement operation the same as in current practice.

The consequences of the existing fuel handling accident remain bounding because the IP3 fuel assembly design is essentially the same as the IP2 design and the IP3 fuel assemblies to be transferred to IP2 will be cooled a minimum of 10 years. This compares with a cooling time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> used in the existing FHA radiological analysis. The 10-year cooling time results in a significant reduction in the radioactive source term available for release from a damaged fuel assembly compared to the source term considered in the design basis FHA radiological analysis. The consequences of the previously analyzed fuel assembly drop accident, therefore, continue to provide a bounding estimated offsite dose for this accident. In addition, the consequences of a dropped fuel assembly on the STC has been evaluated from a criticality perspective and it has been determined that the fuel storage array remains subcritical.

NL-1 2-047 Attachment 4 Page 4 of 7 The probability of an STC drop in the truck bay, during transit to the spent fuel pit, or into the spent fuel pit is highly improbable because of the many administrative controls and physical limitations imposed on handling operations and will not increase significantly due to the proposed changes because the STC will be moved into, and removed from, the spent fuel pit using the existing IP2 single failure proof lifting system and procedures similar to those already in use for dry cask storage activities at IP2. The lifting system includes the IP2 cask handling crane, special lifting devices, and interfacing lift points on the STC and HI-TRAC. The vertical drop of a HI-TRAC 100D containing a STC is considered sufficiently unlikely as not to increase the overall probability of a FHA due to the short period of time when suspended from the VCT after the redundant drop protection design features are removed. In addition, the VCT lifting equipment is designed in accordance with the requirements of Appendix C Program 5.1 Transport Evaluation Program.

The consequences of the existing fuel cask drop accident inside the FSB as described in the UFSAR remain bounding because the STC and HI-TRAC will only be lifted using a single failure proof lifting system inside the FSB, as described above. A drop of the HI-TRAC containing a fuel-loaded STC while suspended from the VCT was analyzed for the short period of time outdoors when the VCT does not have its redundant drop protection design features installed.

The physical design of the STC and HI-TRAC 100D effectively precludes significant effluent releases as demonstrated by analysis of the HI-TRAC 100D vertical drop accident that demonstrates that the drop event would not result in any unacceptable consequence for the transfer cask and its contents.

Loss of Spent Fuel Pool Cooling The probability of a loss of spent fuel pit cooling remains the same because the proposed change does not alter the manner in which the IP2 spent fuel cooling loop is operated, designed or maintained.

The consequences of a loss of spent fuel pit cooling remains the same because the thermal design basis for the spent fuel pit cooling loop provides for all fuel pit rack locations to be filled at the end of a full core discharge and therefore the design basis heat load effectively includes any heat load associated with the assemblies within the STC.

Natural Events The consequences of a seismic event with an STC in the spent fuel pit, with the STC loaded into the HI-TRAC 100D, and with the HI-TRAC loaded into the vertical cask transporter have been evaluated and it has been determined that these components will not tip over during a design basis earthquake, nor will the fuel be damaged as a result of a postulated seismic event.

Therefore, there are no significant dose consequences associated with this event.

The consequences of extreme environmental events such as high winds, tomado, and tornado

-borne missiles have also been considered and in fact are part of the certification of HI-TRAC 100D in Docket No. 72-1014, where it is shown that the fuel is protected. In addition, should the water jacket of the HI-TRAC 100D be penetrated by a missile and all jacket water lost, analyses have demonstrated that no design limits would be exceeded. Therefore, there are no significant dose consequences associated with these events. A lightning strike could ignite the fuel in the vertical cask transporter resulting in engulfment of the HI-TRAC 100D, however, analyses have

NL-12-047 Attachment 4 Page 5 of 7 demonstrated that no design limits are exceeded. Therefore, there are no significant dose consequences associated with this event. The design basis flood event results in a water level below the elevation of the heavy haul path, therefore, there are no significant dose consequences associated with this event.

The breakdown of a loaded vertical cask transporter leaving HI-TRAC 100D exposed to potential high ambient temperatures for a prolonged period of time has been analyzed with all design criteria satisfied. Therefore, there are no significant dose consequences associated with these events.

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

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

Response: No.

The IP2 spent fuel pit is designed to accommodate fuel having certain characteristics as well as an overall heat load that is commensurate with the capability of the spent fuel pit cooling system's ability to remove the decay heat. The IP3 fuel assemblies selected for storage in the IP2 spent fuel pit are required to meet the IP2 Appendix A LCO 3.7.13 Spent Fuel Pit Storage limits for storage as discussed above. The fuel basket design in the STC emulates that of a spent fuel rack, making the individual fuel assembly movement operation the same as in current practice using appropriate procedural controls to ensure each fuel assembly is moved safely and into the correct fuel cell location in the racks as specified on the fuel move sheet . There are no changes proposed to the spent fuel pit storage racks or the manner in which spent fuel is moved from the reactor to the spent fuel pit or within the spent fuel pit. All limits for spent fuel storage in the IP2 spent fuel pit will remain the same and will continue to be complied with, including consideration of the additional IP3 fuel assemblies. The vertical drop of a HI-TRAC 100D containing a STC when suspended from the VCT after the redundant drop protection design features are removed has been evaluated and is bounded by the existing FHA. Thus, the existing fuel handling accident bounds the STC unloading operation and a HI-TRAC vertical drop and, therefore, no new or different fuel handling accident is created.

The proposed amendment does not alter the operation of any plant cooling systems nor does it create a new source of unborated water that could be injected into the spent fuel pit or affect the ability of systems to mitigate a boron dilution event. The STC has been designed and its contents so limited that even if fully de-borated, the content would not reach criticality, with keff remaining less than 0.95. Appendix C LCO 3.1.1 Boron Concentrationensure the boron concentration of the water in the STC meets the boron concentration requirements of the IP2 spent fuel pit.

The collapse of the roadway during transport resulting in cask rollover and potential loss of water inventory and potential large radioactive release is not a credible accident because of the structural stability of the VCT and the measures taken to ensure that the haul path is structurally sound. These measures include an evaluation of the haul path that includes ground penetrating radar and/or soil compaction studies. In addition, a non-mechanistic tipover analysis of the loaded HI-TRAC transfer cask demonstrates that there is no degradation in the margin of safety engineered in the STC and the HI-TRAC. In addition, as a defense in depth measure, the non-

NL-1 2-047 Attachment 4 Page 6 of 7 mechanistic tipover of a loaded STC within the HI-TRAC during transfer operations has been evaluated. The analyses demonstrate structural integrity, radiological confinement, sufficient shielding, fuel integrity and sufficient thermal performance.

The inadvertent loading and subsequent transport of a high decay heat assembly or misload of multiple assemblies in the STC is precluded by robust fuel handling procedures and safety features. In addition a new Appendix C LCO 3.1.4 Shielded Transfer Canister(STC) Pressure Rise and associated actions and surveillance would detect an accidental misloading of a high decay heat fuel assembly within the IP3 fuel handling building and appropriate actions would be taken prior to transfer operations.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed amendment ensures that the IP3 spent fuel to be transferred to the IP2 spent fuel pit racks will meet all requirements for fuel storage at IP2. The storage racks and the spent fuel pit cooling system meet the design requirements for the IP3 fuel from a criticality, thermal, shielding, and material perspective because the fuel designs and operating parameters are very similar. The proposed STC loading TS 3.1.2 Shielded Transfer Canister(STC) Loading and the associated fuel selection procedures used to control the loading of the STC at IP3 will ensure that all fuel to be transferred meets IP2 requirements for storage in the IP2 spent fuel pit racks.

The presence of the STC in the IP2 spent fuel pit has been analyzed and found to be acceptable. The spent fuel pit was originally designed to accommodate a spent fuel shipping cask and the STC is similar in physical dimensions to a shipping cask. Administrative controls will be in place during STC handling operations to ensure that the spent fuel pit water level is maintained within limits. Any criticality event caused by neutronic coupling between the STC and the fuel in the spent fuel racks is precluded due to the thick steel and lead walls of the STC and the distance between the STC and the nearest spent fuel in the racks.

The proposed amendment does not involve changes to any plant operating systems used to cool the spent fuel pit water or respond to unanticipated events or accidents.

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 IP2 Operating License and Technical Specifications 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.

Environmental Considerations Entergy has evaluated the proposed changes and determined the changes do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released off-site, or (3) a significant increase in

NL-1 2-047 Attachment 4 Page 7 of 7 individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria 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 5 TO NL-12-047 No Significant Hazards Consideration for Indian Point Unit 3 Pertaining to Inter-Unit Fuel Transfer Entergy Nuclear Operations, Inc.

Indian Point Unit 3 Docket No. 50-286

NL-12-047 Attachment 5 Page 1 of 6 Entergy has evaluated whether or not a significant hazards consideration is involved with the proposed amendment for IP3 by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of Amendment," as discussed below:

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

Response: No.

The proposed amendment proposes to modify Operating License (OL) Condition 2.C.(2), and to add a new OL Condition 2.AE that together allow the transfer of IP3 fuel to the IP2 spent fuel pit subject to the conditions listed in a new Appendix C to the IP3 Operating License. The new Appendix C Inter-UnitFuel Transfer Technical Specifications is common to both IP2 and IP3 and controls inter-unit fuel transfer operations via LCOs, Design Features, and Programs as follows:

LCO 3.1.1 Boron Concentration LCO 3.1.2 Shielded Transfer Canister(STC) Loading LCO 3.1.3 Shielded Transfer Canister (STC) Initial Water Level LCO 3.1.4 Shielded Transfer Canister (STC) PressureRise LCO 3.1.5 Shielded TransferCanister(STC) Unloading Design Features 4.1 Inter-Unit Fuel Transfer 4.1.1 Fuel Assemblies 4.1.2 Criticality 4.1.3 Codes and Standards 4.1.4 Geometric Arrangements and Process Variables Program 5.1 Transport Evaluation Program Program 5.2 Metamic Coupon Sampling Program Program 5.3 Technical Specifications Bases (TS) ControlProgram Program 5.4 Radiation ProtectionProgram The proposed amendment adds Appendix C LCO 3.1.1 Boron Concentration.The purpose of the LCO and associated Action and Surveillance Requirement is to place controls on the spent fuel pit boron concentration and the STC boron concentration whenever fuel is in the STC to ensure compliance with the accident analysis assumptions during loading, transfer, and unloading operations.

The proposed amendment adds Appendix C LCO 3.1.2 Shielded Transfer Canister(STC)

Loading. The purpose of the LCO and associated Action and Surveillance Requirement are to place controls on the loading of the STC within the IP3 spent fuel pit to ensure compliance with accident analysis assumptions and to take immediate action to restore compliance should the LCO not be met. The LCO also ensures that fuel loaded into the STC meets IP2 LCO 3.7.13 requirements for storage in the IP2 spent fuel pit. The proposed amendment also adds a new Appendix C Design Feature 4.1.2 Criticalitythat ensures the design of the STC is in compliance with the criticality analysis, prevents inadvertent drainage of the STC, and restricts the maximum capacity of the STC to 12 fuel assemblies. In addition, a new Appendix C Program

NL-12-047 Attachment 5 Page 2 of 6 5.2 Metamic Coupon Sampling Program is proposed to ensure that the characteristics of Metamic assumed in the criticality analysis are preserved.

The proposed amendment adds Appendix C LCO 3.1.3 Shielded Transfer Canister (STC) Initial Water Level. The purpose of the LCO and associated Action and Surveillance Requirement is to place controls on the STC water level to ensure compliance with the accident analysis assumptions during transfer and unloading operations.

The proposed amendment adds Appendix C LCO 3.1.4 Shielded Transfer Canister (STC)

PressureRise. The purpose of the LCO and associated Action and Surveillance Requirements are to detect an accidental misloading of a high decay heat fuel assembly or misloading of multiple assemblies within the IP3 fuel handling building and to take appropriate actions prior to transfer operations.

The proposed amendment also proposes to modify Appendix A LCO 3.7.15 Spent Fuel Pit Boron Concentration.The revision adds a note to LCO 3.7.15 that states that during inter-unit transfer of fuel the spent fuel pit boron concentration must also meet Appendix C LCO 3.1.1, "Boron Concentration.

The previously evaluated accidents that must be considered are a criticality accident, a boron dilution accident in the spent fuel pit, a fuel handling accident (FHA), a loss of spent fuel pit cooling and natural events.

Criticality Accidents The probability of a criticality accident at IP3 is not increased because proposed Appendix C LCO 3.1.2 Shielded Transfer Canister(STC) Loading requires that the IP3 spent fuel assemblies transferred to the STC must be in an approved STC cell location. In addition the note added to LCO 3.7.15 that states that during inter-unit transfer of fuel the spent fuel pit boron concentration must also meet Appendix C LCO 3.1.1 ensures that the spent fuel pit boron concentration will not be reduced below LCO 3.1.1 requirements during loading operations.

Administrative controls will be established to ensure fuel movement under the requirements of this LCO are in compliance with the criticality analyses described in this amendment request and, therefore, these fuel movements do not significantly increase the probability of a criticality accident. The probability for a criticality event due to neutronic coupling while the STC is in the spent fuel pit is negligible because of the STC steel and lead vessel walls and the minimum distance between the STC and the nearest spent fuel rack will be maintained by procedure.

The consequences of a criticality accident within the spent fuel pit are not changed because the fuel assemblies are spaced in a pattern within the STC and the spent fuel pit that continue to preserve criticality accident analyses assumptions.

Boron Dilution Accident The probability of a boron dilution event remains the same because the proposed change does not alter the manner in which the IP3 spent fuel cooling system or any other plant system is operated or otherwise increase the likelihood of adding significant quantities of unborated water into the spent fuel pit. In addition, the STC is loaded in the IP3 spent fuel pit, where the boron

NL-12-047 Attachment 5 Page 3 of 6 concentration in the STC is controlled by the new Appendix C LCO 3.1.1 Boron Concentration that imposes a minimum boron concentration limit of 2000 ppm.

The consequences of the boron dilution event remain unchanged because the minimum concentration of soluble boron in the spent fuel pit required by the IP3 Technical Specifications remains unchanged (1,000 ppm). The reactivity of the STC filled with the most reactive combination of approved fuel assemblies in unborated water results in a keff less than 0.95.

Thus, even in the unlikely event of a complete dilution of the spent fuel pit water, the STC will remain safely subcritical.

Fuel Handling Accident The probability of an FHA which includes a fuel assembly drop accident and a fuel cask drop accident remain remote because of the many administrative controls and physical limitations imposed on fuel-handling operations and will not increase significantly due to the proposed changes because the individual fuel assemblies will be moved from the spent fuel pit racks to the STC in the same manner, using the same equipment, procedures, and other administrative controls (i.e. fuel move sheets) that are currently used. The fuel basket design in the STC emulates that of a spent fuel rack, making the individual fuel assembly movement operation the same as in current practice.

The consequences of the existing fuel handling accident remain bounding because only IP3 fuel is being moved in the IP3 spent fuel pit. Moreover, the IP3 fuel assemblies to be transferred to the STC must have a post-irradiation cooling time of greater or equal to 10 years. This compares with a cooling time of 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> used in the existing FHA radiological analysis. The 10-year cooling time results in a significant reduction in the radioactive source term available for release from a damaged fuel assembly compared to the source term considered in the design basis FHA radiological analysis. The consequences of the previously analyzed fuel assembly drop accident, therefore, continue to provide a bounding estimated offsite dose for this accident.

In addition, the consequences of a dropped fuel assembly on the STC has been evaluated from a criticality perspective and it has been determined that the fuel storage array remains subcritical.

The probability of an STC drop in the truck bay, into the spent fuel pit, or in transit between these two locations is highly improbable because of the many administrative controls and physical limitations imposed on handling operations and will not increase significantly due to the proposed changes because the STC will be moved into, and removed from, the spent fuel pit using a single failure proof lifting system and procedures similar to those already in use for dry cask storage activities at IP2. A single failure proof lifting system includes the 40-ton IP3 upgraded cask handling crane, special lifting devices, and interfacing lift points on the STC. The vertical drop of a HI-TRAC 100D containing a STC is considered sufficiently unlikely as not to increase the overall probability of a FHA due to the short period of time when suspended from the VCT before the redundant drop protection design features are installed. In addition, the VCT lifting equipment is designed in accordance with the requirements of Appendix C Program 5.1 TransportEvaluation Program.

The consequences of the existing fuel cask drop accident inside the FSB as described in the UFSAR remain bounding because the STC will only be lifted using a single failure proof lifting system inside the FSB, as described above. A drop of the HI-TRAC containing a fuel-loaded

NL-12-047 Attachment 5 Page 4 of 6 STC while suspended from the VCT was analyzed for the short period of time outdoors when the VCT does not have its redundant drop protection design features installed. The physical design of the STC and HI-TRAC 100D effectively precludes significant effluent releases as determined by the analysis of the HI-TRAC 100D vertical drop accident that demonstrates that the drop event would not result in any unacceptable consequence for the transfer cask and its contents.

Loss of Spent Fuel Pool Cooling The probability of a loss of spent fuel pit cooling remains the same because the proposed change does not alter the manner in which the IP3 spent fuel cooling loop is operated, designed or maintained.

The consequences of a loss of spent fuel pit cooling remains the same because the thermal design basis for the spent fuel pit cooling loop provides for all fuel pit rack locations to be filled at the end of a full core discharge and therefore the design basis heat load effectively includes any heat load associated with the assemblies within the STC.

Natural Events The consequences of a seismic event with an STC in the spent fuel pit, with the STC loaded into the HI-TRAC 100D, and with the HI-TRAC loaded into the vertical cask transporter have been evaluated and it has been determined that these components will not tip over during a design basis earthquake, nor will the fuel be damaged as a result of a postulated seismic event.

Therefore, there are no significant dose consequences associated with this event.

The consequences of extreme environmental events such as high winds, tornado, and tornado

-borne missiles have also been considered and in fact are part of the certification of HI-TRAC 100D in Docket No. 72-1014, where it is shown that the fuel is protected. In addition, should the water jacket of the HI-TRAC 100D be penetrated by a missile and all jacket water lost, analyses have demonstrated that no design limits would be exceeded. Therefore, there are no significant dose consequences associated with these events. A lightning strike could ignite the fuel in the vertical cask transporter resulting in engulfment of the HI-TRAC 100D, however, analyses have demonstrated that no design limits are exceeded. Therefore, there are no significant dose consequences associated with this event. The design basis flood event results in a water level below the elevation of the heavy haul path, therefore, there are no significant dose consequences associated with this event.

The breakdown of a loaded vertical cask transporter leaving HI-TRAC 100D exposed to potential high ambient temperatures for a prolonged period of time has been analyzed with all design criteria satisfied. Therefore, there are no significant dose consequences associated with these events.

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

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

NL-1 2-047 Attachment 5 Page 5 of 6 Response: No.

The IP3 fuel assemblies selected for loading into the STC in the IP3 spent fuel pit are required to meet the proposed new Appendix C LCO 3.1.2 Shielded Transfer Canister(STC) Loading.

The fuel basket design in the STC emulates that of a spent fuel rack, making the individual fuel assembly movement operation the same as in current practice using appropriate procedural controls to ensure each fuel assembly is moved safely and into the correct STC cell location as specified on the fuel move sheet. There are no changes proposed to the spent fuel pit storage racks or the manner in which spent fuel is moved from the reactor to the spent fuel pit or within the spent fuel pit. All limits for spent fuel storage in the IP3 spent fuel pit will remain the same and will continue to be complied with. The vertical drop of a HI-TRAC IOOD containing a STC when suspended from the VCT prior to the redundant drop protection design features being installed has been evaluated and is bounded by the existing FHA. Thus, the existing fuel handling accident bounds the STC loading operation and a HI-TRAC vertical drop and, therefore, no new or different fuel handling accident is created.

The transfer of selected IP3 spent fuel assemblies to IP2 does not adversely alter the design, analysis, or operation of the IP3 spent fuel pit. This amendment involves the removal of IP3 fuel from the IP3 spent fuel pit as part of needed fuel management and to restore fuel core offload capability in the IP3 spent fuel pit. No changes to the spent fuel pit capacity or cooling system design are involved.

The proposed amendment does not alter the operation of any plant cooling systems nor does it create a new source of unborated water that could be injected into the spent fuel pit or affect the ability of systems to mitigate a boron dilution event. The STC has been designed and its contents so limited that even iffully de-borated, the content would not reach criticality, with keff remaining less than 0.95. Appendix C LCO 3.1.1 Boron Concentrationensure the boron concentration of the water in the STC meets the boron concentration requirements of the IP2 spent fuel pit.

The collapse of the roadway during transport resulting in cask rollover and potential loss of water inventory and potential large radioactive release is not a credible accident because of the structural stability of the VCT and the measures taken to ensure that the haul path is structurally sound. These measures include an evaluation of the haul path that includes ground penetrating radar and/or soil compaction studies. In addition, a non-mechanistic tipover analysis of the loaded HI-TRAC transfer cask demonstrates that there is no degradation in the margin of safety engineered in the STC and the HI-TRAC. In addition, as a defense in depth measure, the non-mechanistic tipover of a loaded STC within the HI-TRAC during transfer operations has been evaluated. The analyses demonstrate structural integrity, radiological confinement, sufficient shielding, fuel integrity and sufficient thermal performance.

The inadvertent loading and subsequent transport of a high decay heat assembly or misload of multiple fuel assemblies in the STC is precluded by robust fuel handling procedures and safety features. In addition a new Appendix C LCO 3.1.4 Shielded Transfer Canister(STC) Pressure Rise and associated actions and surveillance would detect an accidental misloading of a high decay heat fuel assembly or misload of multiple fuel assemblies within the IP3 fuel handling building and appropriate actions would be taken prior to transfer operations.

NL-12-047 Attachment 5 Page 6 of 6 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed STC loading Appendix C TS 3.1.2 Shielded Transfer Canister(STC) Loading and the associated fuel selection procedures used to control the loading of the STC at IP3 will ensure that all fuel to be loaded into the STC meets the requirements of the accident analyses.

The presence of the STC in the IP3 spent fuel pit has been analyzed and found to be acceptable. The spent fuel pit was originally designed to accommodate a spent fuel shipping cask and the STC is similar in physical dimensions to a shipping cask. Administrative controls will be in place during STC handling operations to ensure that the spent fuel pit water level is maintained within limits. Any criticality event caused by neutronic coupling between the STC and the fuel in the spent fuel racks is precluded due to the thick steel and lead walls of the STC and the distance between the STC and the nearest spent fuel in the racks.

The proposed amendment does not involve changes to any plant operating systems used to cool the spent fuel pit water or respond to unanticipated events or accidents.

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 IP3 Operating License and Technical Specifications 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.

Environmental Considerations Entergy has evaluated the proposed changes and determined the changes do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released off-site, or (3) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet the eligibility criteria 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.

ENCLOSURE 3 TO NL-12-047 Affidavit executed pursuant to 10 CFR 2.390 governing the proprietary information included in the Holtec reports and evaluations.

Entergy Nuclear Operations, Inc.

Indian Point Units 2 and 3 Docket Nos. 50-247 and 50-286

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 1775045 Non-Proprietary Attachment AFFIDAVIT PURSUANT TO 10 CFR 2.390 I, Tyrone S. Tonkinson, being duly sworn, depose and state as follows:

(1) I have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld are all the Holtec reports and documents contained in the Attachments to Holtec letter Document ID 1775045, containing Holtec Proprietary information.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies upon the exemption from disclosure set forth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for "trade secrets and commercial or financial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes of FOIA Exemption 4 in, respectively, Critical Mass Energy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992),

and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir.

1983).

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 1775045 Non-Proprietary Attachment AFFIDAVIT PURSUANT TO 10 CFR 2.390 (4) Some examples of categories of information which fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by Holtec's competitors without license from Holtec International constitutes a competitive economic advantage over other companies;
b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

C. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies of Holtec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;
e. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs 4.a, and 4.b above.

(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of a sort customarily held in confidence by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have 2 of 5

U.S, Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 1775045 Non-Proprietary Attachment AFFIDAVIT PURSUANT TO 10 CFR 2.390 been made, or must be made, pursuant to regulatory provisions or proprietary agreements which provide for maintenance of the information in confidence. Its initial designation as proprietary information, and the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge.

Access to such documents within Holtec International is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager of the cognizant marketing function (or his designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation.

Disclosures outside Holtec International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information classified as proprietary was developed and compiled by Holtec International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations performed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Document ID 1775045 Non-Proprietary Attachment AFFIDAVIT PURSUANT TO 10 CFR 2.390 (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.

The research, development, engineering, and analytical costs comprise a substantial investment of time and money by Holtec International.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

The value of this information to Holtec International would be lost if the information were disclosed to the public. Making such information available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

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U.S."Nuclear:Regliatory Commission ATTN: ,Documeni Contro01!esk Document ID . 775045 Nond'roprietary Aftachment

-AFFIDAVIT PURSU ANT TO 10 CFR 2.390.

STATEOF NEW JERSEY )

'CONTY OF: BURLINGTON)

Tyronie .Tonkinson, being duly sworn, deposes and sayS:

That he has read the, foregoing affidavit and the matters, stated therein areitrue and correct tothe-bst of hisý knowIedJe, piformation, and belief Executed at Marltoný, New. Jersey; this :16tlhday of April, 2012.

Tyrone S'. Tonkinson Project Manager Hoeltc International:

Subscribed and swomrnbeforeme this. k idcay of., K . 2012,

)T: F.un. . p.......016-t~IOTAWPU.e ....

5 of 5"

Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053 Telephone (856) 797-0900 HOLTEC INTERNATIONAL Fax (856) 797-0909 April 16, 2012, Mr. Roger Waters Licensing Indian Point Energy Center 450 Broadway GSB Second Floor Licensing Buchanan, NY 10511-0249 Document ID: 1775045

Subject:

Information to Support Licensing Submittal on Inter-Unit Fuel Transfer

Dear Mr. Waters:

Holtee is pleased to approve the release of the following information to the United States Nuclear Regulatory Commission (USNRC):

Attachment A - HI-2094289R6, "Licensing Report for the Inter Unit Fuel Transfer" (Proprietary)

Attachment B - HI-2084176R8, "Shielded Transfer Canister Criticality Calculation" (Proprietary)

We require that you include this letter along with the attached affidavit pursuant to I OCFR2.390 when submitting Attachment I to the USNRC.

Please do not hesitate to contact me at 856-797-0900 x 3654 if you have any questions.

Sincerely, Tyrone S. Tonkinson Project Manager Holtec International Document ID: 1775045 Page I of I