NL-14-144, Revision to Proposed License Amendment Regarding Extending the Containment Type a Leak Rate Testing Frequency to 15 Years
| ML14365A038 | |
| Person / Time | |
|---|---|
| Site: | Indian Point |
| Issue date: | 12/09/2014 |
| From: | Coyle L Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-14-144 | |
| Download: ML14365A038 (4) | |
Text
--- Entergy Enteray Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 Lawrence Coyle Site Vice President NL-14-144 December 9, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738
SUBJECT:
Reference Revision to Proposed License Amendment Regarding Extending the Containment Type A Leak Rate Testing Frequency to 15 years Indian Point Unit Number 3 Docket No. 50-286 License No. DPR-64 Entergy Letter (NL-14-014) to NRC Regarding Proposed License Amendment Regarding Extending the Containment Type A Leak Rate Testing Frequency to 15 years, dated February 4, 2014
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) requested, in the referenced letter, a License Amendment to Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed TS change contained would revise Appendix A, Technical Specifications (TS), to allow extension of the ten-year plus 15-month frequency of the Type A or Integrated Leak Rate Test (ILRT) that is required by Technical Specification (TS) 5.5.15 to 15 years on a permanent basis.
In the referenced letter, Entergy evaluated the proposed change in accordance with 10 CFR 50.91(a)(1) using the criteria of 10 CFR 50.92(c) and determined that this proposed change involves no significant hazards. Entergy also provided a marked up Technical Specification page to reflect the revision. In a telecom on November 12, 2014, the NRC Staff advised Entergy that the NEI 94-01 Revision 2A was the appropriate reference for extending the Type A testing frequency.
The referenced NEI 94-01 Revision 3A is appropriate for an extension of testing frequencies for Type B and C testing. The evaluation of the proposed change in accordance with 10 CFR 50.91 (a)(1) contained in the reference letter has not been revised to reflect Revision 2A since this is primarily an editorial change. The Reference letter and this proposed Technical Specification change both adopt ANSI/ANS 56.8 - 2002 for Type A testing as well as Type B and C testing. The marked up Technical Specification page in the reference letter was affected by this change to Revision 2A and the revised page is in the attachment. The assessment of the risk impact of extending the ILRT interval is provided in the reference letter remains unchanged. A copy of this letter and the associated attachments are being submitted to the designated New York State official in accordance with 10 CFR 50.91.
NL-14-144 Docket No. 50-286 Page 2 of 2 Entergy requests approval of the proposed amendment by January 15, 2015 and an allowance of 30 days for implementation. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.
I declare under penalty of perjury that the foregoing is true and correct. Executed on December y_7h 2014.
Sincerely, LC/sp
Attachment:
Marked Up Technical Specifications Page for Proposed Changes Regarding 15 Year Containment ILRT cc:
Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. Daniel H. Dorman, Regional Administrator, NRC Region 1 NRC Resident Inspector Mr. John B. Rhodes, President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service
ATTACHMENT TO NL-14-144 MARKED UP TECHNICAL SPECIFICATIONS PAGE FOR PROPOSED CHANGES REGARDING 15 YEAR CONTAINMENT ILRT Changes indicated by lineout for deletion and Bold/Italics for additions Unit 3 Affected Page:
5.0-30 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.15 Containment Leaka-ge Rate Testinq Program A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with NEI 94-01, Revision 2A, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J, " October 2008 the guidelines co,,ntained Regulator; Guide 1. 163, "Performnance Based Containment Leak Test Program, dated September 1995", as modified by the following exception:
ANS 56.8-2002 ANS 56.8 1994, Section 3.3.1: WCCPPS isolation valves are not Type C tested.
The maximum allowable primary containment leakage rate, La, at a minimum test pressure equal to Pa, shall be 0.1% of primary containment air weight per day. Pa is the peak calculated containment internal pressure related to the design basis accident.
Leakage acceptance criteria are:
- a.
Containment leakage rate acceptance criterion is < 1.0 La. During the first unit startup following testing in accordance with this program, the leakage rate acceptance criteria are < 0.60 La for the Type B and C tests and < 0.75 La for Type A tests;
- b.
Air lock testing acceptance criteria are:
- 1) Overall air lock leakage rate is < 0.05 La when tested at > Pa,
- 2)
For each door, leakage rate is < 0.01 La when pressurized to _> Pa,
- c.
Isolation Valve Seal Water System leakage rate acceptance criterion is <
14,700 cc/hr at> 1.1 Pa.
- d.
Acceptance criterion for leakage into containment from isolation valves sealed with the service water system is < 0.36 gpm per fan (continued)
INDIAN POINT 3 5.0 -30 Amendment