ML072470162

Issuance of Amendment 235 Technical Specification Change Request for Pressure-Temperature and Low Temperature Protection System Limits

ML072470162
Person / Time
Site:	Indian Point
Issue date:	10/04/2007
From:	Boska J NRC/NRR/ADRO/DORL/LPLI-1
To:	Balduzzi M Entergy Nuclear Operations
Boska J, NRR, 301-415-2901
References
TAC MD4079, FOIA/PA-2016-0148
Download: ML072470162 (13)

Text

October 4, 2007Mr. Michael A. BalduzziSr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - ISSUANCE OFAMENDMENT RE: TECHNICAL SPECIFICATION CHANGE REQUEST FOR PRESSURE-TEMPERATURE AND LOW TEMPERATURE PROTECTION SYSTEM LIMITS (TAC NO. MD4079)

Dear Mr. Balduzzi:

The Commission has issued the enclosed Amendment No. 235 to Facility Operating LicenseNo. DPR-64 for the Indian Point Nuclear Generating Unit No. 3. The amendment consists of changes to the Technical Specifications (TS) in response to your application dated January 18, 2007.The amendment (1) revises the expiration time of the pressure-temperature limit curves from 20effective full-power years (EFPYs) of operation to 27.2 EFPYs, (2) revises the adjusted reference temperature to reflect the revised expiration limit, and (3) revises the low temperature overpressure protection system arming temperature from 319 F to 330 F .A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in theCommission's next regular biweekly Federal Register notice.Sincerely,/RA/John P. Boska, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-286

Enclosures:

1. Amendment No. 235 to DPR-64

2. Safety Evaluationcc w/encls: See next page October 4, 2007Mr. Michael A. BalduzziSr. Vice President & COO Regional Operations, NE Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 - ISSUANCE OFAMENDMENT RE: TECHNICAL SPECIFICATION CHANGE REQUEST FOR PRESSURE-TEMPERATURE AND LOW TEMPERATURE PROTECTION SYSTEM LIMITS (TAC NO. MD4079)

Dear Mr. Balduzzi:

The Commission has issued the enclosed Amendment No. 235 to Facility Operating LicenseNo. DPR-64 for the Indian Point Nuclear Generating Unit No. 3. The amendment consists of changes to the Technical Specifications (TS) in response to your application dated January 18, 2007.The amendment (1) revises the expiration time of the pressure-temperature limit curves from 20effective full-power years (EFPYs) of operation to 27.2 EFPYs, (2) revises the adjusted reference temperature to reflect the revised expiration limit, and (3) revises the low temperature overpressure protection system arming temperature from 319 F to 330 F.A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in theCommission's next regular biweekly Federal Register notice.Sincerely,/RA/John P. Boska, Senior Project ManagerPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-286

Enclosures:

1. Amendment No. 235 to DPR-64

2. Safety Evaluation cc w/encls: See next pageAccession Number: ML072470162OFFICELPL1-1/PMLPL1-1/LASRXB/BCOGCLPL1-1/BCNAMEJBoskaSLittleGCranstonLSubinMKowalDATE9/12/079/17/079/24/0710/02/0710/03/07Official Record Copy DATED: October 4, 2007AMENDMENT NO. 235 TO FACILITY OPERATING LICENSE NO. DPR-64 INDIAN POINTUNIT 3PUBLICLPL1-1 R/F RidsNrrDorlLpl1-1 RidsNrrLASLittle (hard copy)

RidsNrrPMJBoska RidsOGCMailCenter GHill (2) (hard copy)

RidsNrrDirsItsb RidsAcrsAcnwMailCenter ECobey, RIcc: Plant Mailing list Indian Point Nuclear Generating Unit No. 3 cc:

Mr. Michael R. KanslerPresident & CEO / CNO Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. John T. HerronSr. Vice President Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Sr. Vice PresidentEngineering & Technical Services Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Fred R. DacimoSite Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249Mr. Anthony Vitale - ActingGeneral Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249Mr. Oscar LimpiasVice President Engineering Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Joseph P. DeRoyVice President, Operations Support Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. John A. VentosaGM, Engineering Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. John F. McCannDirector, Nuclear Safety & Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Ms. Charlene D. FaisonManager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601Mr. Ernest J. HarknessDirector, Oversight Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213Mr. Patric W. ConroyDirector, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249Mr. Robert WalpoleManager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249Mr. William C. DennisAssistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Indian Point Nuclear Generating Unit No. 3 cc:

Mr. Michael BalboniDeputy Secretary for Public Safety State Capitol, Room 229 Albany, NY 12224Mr. John P. SpathNew York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399Mr. Paul EddyNew York State Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350Regional Administrator, Region IU.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406Senior Resident Inspector's OfficeIndian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511Mr. Charles Donaldson, EsquireAssistant Attorney General New York Department of Law 120 Broadway New York, NY 10271Mr. Raymond L. AlbaneseFour County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532Mayor, Village of Buchanan236 Tate Avenue Buchanan, NY 10511Mr. William DiProfioPWR SRC Consultant 48 Bear Hill Road Newton, NH 03858Mr. Garry RandolphPWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236Mr. William T. RussellPWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232Mr. Jim RiccioGreenpeace 702 H Street, NW Suite 300 Washington, DC 20001Mr. Phillip MusegaasRiverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591Mr. Mark JacobsIPSEC 46 Highland Drive Garrison, NY 10524 ENTERGY NUCLEAR INDIAN POINT 3, LLCENTERGY NUCLEAR OPERATIONS, INC.DOCKET NO. 50-286INDIAN POINT NUCLEAR GENERATING UNIT NO. 3AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 235License No. DPR-641.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Entergy Nuclear Operations, Inc. (thelicensee) dated January 18, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-64 is hereby amended to read as follows: (2)Technical SpecificationsThe Technical Specifications contained in Appendices A and B, as revisedthrough Amendment No. 235, are hereby incorporated in the license. ENO shall operate the facility in accordance with the Technical Specifications.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 30 days.FOR THE NUCLEAR REGULATORY COMMISSIONMark G. Kowal, ChiefPlant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical SpecificationsDate of Issuance: October 4, 2007 ATTACHMENT TO LICENSE AMENDMENT NO. 235FACILITY OPERATING LICENSE NO. DPR-64DOCKET NO. 50-286Replace the following page of the License with the attached revised page. The revised page isidentified by amendment number and contains marginal lines indicating the areas of change.Remove PageInsert Page 33Replace the following pages of the Appendix A Technical Specifications with the attachedrevised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.Remove PagesInsert Pages3.4.3-33.4.3-33.4.3-43.4.3-4 3.4.3-53.4.3-5 3.4.7-13.4.7-1 3.4.10-13.4.10-1 3.4.12-13.4.12-1 3.4.12-33.4.12-3 3.4.12-43.4.12-4 3.4.12-63.4.12-6 3.4.12-73.4.12-7 3.4.12-83.4.12-8 3.4.12-93.4.12-9 3.4.12-103.4.12-10 3.4.12-113.4.12-11 3.4.12-123.4.12-12 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 235 TO FACILITY OPERATING LICENSE NO. DPR-64ENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-28

61.0INTRODUCTION

By letter dated January 18, 2007, Agencywide Documents Access and Management System(ADAMS) Accession No. ML070240285, Entergy Nuclear Operations, Inc. (the licensee) submitted a request for changes to the Indian Point Nuclear Generating Unit No. 3 (IP3)

Technical Specifications (TS). The proposed changes would (1) revise the expiration time of the pressure-temperature (PT) limit curves from 20 effective full-power years (EFPYs) of operation to 27.2 EFPYs, (2) revise the adjusted reference temperature (ART) to reflect the revised expiration limit, and (3) revise the low temperature overpressure protection (LTOP) system arming temperature from 319 F to 330 F (Reference 1).The analysis of record for the vessel fluence and the corresponding PT limit curves have beenpreviously reviewed and approved by the NRC staff in License Amendment Nos. 220 (Reference 4) and 225 (Reference 5) for values up to 34.0 EFPYs. The current TS curves are valid to 20 EFPYs which corresponds to an LTOP arming temperature of 319 F. The licenseeestablished the 20 EFPY limit in the TS previously so that modifications to the LTOP arming temperature would not be required. However, due to the continued vessel fluence increase it is now necessary to update the TS curves. The requested applicability limit of 27.2 EFPYs corresponds to an LTOP arming temperature of 330 F. In addition, Entergy is proposing tomake several editorial changes to the IP3 TS.

2.0REGULATORY EVALUATION

The regulatory requirements for which the NRC staff based its acceptance are:

a. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.60, "Acceptancecriteria for fracture prevention measures for lightwater nuclear power reactors for normal operation," which requires compliance with 10 CFR Part 50 Appendix G, "Fracture Toughness Requirements." b. 10 CFR 50.61, "Fracture toughness requirements for prevention against pressurizedthermal shock events"; c. Generic Letter (GL) 88-11, "NRC Position on Radiation Embrittlement Of Reactor VesselMaterials And Its Impact On Plant Operations," dated July 12, 1988;d. GL 92-01, Revision 1, "Reactor Vessel Structural Integrity," dated March 6, 1992, andSupplement 1 dated May 19, 1995; e. Regulatory Guide (RG) 1.99, Revision 2, "Radiation Embrittlement of Reactor VesselMaterials," May 1988;f. RG 1.190, "Calculational and Dosimetry Methods for Determining Pressure VesselNeutron Fluence," March 2001;g. Standard Review Plan (SRP) Section 5.3.2, "Pressure-Temperature Limits."

Appendix G to 10 CFR Part 50 requires that PT limit curves for the reactor pressure vessel(RPV) be at least as conservative as those obtained by applying the methodology of Appendix G to Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code). The licensee has currently incorporated the 1989 Edition of the ASME Code into the IP3 licensing basis for defining the ASME Code requirements which apply to the facility's ASME Code,Section XI program, except for repair and replacement activities which are governed by the 2001 Edition through the 2003 Addenda. Hence, with respect to the requirements of Appendix G to 10 CFR Part 50, it is the 1989 Edition of Appendix G to Section XI of the ASME Code which currently applies to the PT limits in the IP3 TSs.The Nuclear Regulatory Commission (NRC) staff has approved RPV fluence calculationmethodologies which satisfy the requirements of 10 CFR Part 50 Appendix A, General Design Criteria (GDC) 14, "Reactor coolant pressure boundary," GDC 30, "Quality of reactor coolant pressure boundary," and GDC 31, "Fracture prevention of reactor coolant pressure boundary,"

and adhere to the guidance in RG 1.190. In this regard, the staff's position is that fluence calculations are acceptable if they are done with approved methodologies or with methods which are shown to conform to the guidance in RG 1.190.SRP Section 5.3.2 provides an acceptable method of determining the PT limit curves for ferriticmaterials in the beltline of the RPV based on the linear elastic fracture mechanics (LEFM) methodology of Appendix G to Section XI of the ASME Code. The basic parameter of this methodology is the stress intensity factor, K I, which is a function of the stress state and flawconfiguration. Appendix G to Section XI of the ASME Code requires a safety factor of 2.0 on stress intensities resulting from reactor pressure during normal and transient operating conditions, and a safety factor of 1.5 on stress intensities resulting from hydrostatic testing.

Appendix G to Section XI of the ASME Code also requires a safety factor of 1.0 on stress intensities resulting from thermal loads for normal and transient operating conditions as well as for hydrostatic testing. The methods of Appendix G postulate the existence of a sharp surface flaw in the RPV that is normal to the direction of the maximum stress (i.e., of axial orientation).

This flaw is postulated to have a depth that is equal to 1/4 of the RPV beltline thickness and a length equal to six times its depth. The critical locations in the RPV beltline region for calculating heatup and cooldown PT limit curves are the 1/4 thickness (1/4T) and 3/4 thickness (3/4T) locations, which correspond to the maximum depth of the postulated inside surface and outside surface defects, respectively. The methodology found in Appendix G to Section XI of the ASME Code requires that licensees determine the ART or adjusted RT NDT at the 1/4T and 3/4T locations. The ART is defined as the sum of the initial (unirradiated) referencetemperature (initial RT NDT), the mean value of the adjustment in reference temperature causedby irradiation (RT NDT), and a margin term.Guidance on the determination of RT NDT and the margin term is given in RG 1.99, Revision 2. RT NDT is a product of a chemistry factor (CF) and a fluence factor. The CF is dependent uponthe amount of copper and nickel in the material and may be determined from tables in RG 1.99, Revision 2, or from surveillance data. The fluence factor is dependent upon the neutron fluence at the maximum postulated flaw depth. The margin term is dependent upon whether the initial RT NDT is a plant-specific or a generic value and whether the CF was determined usingthe tables in RG 1.99, Revision 2, or surveillance data. The margin term is used to account for uncertainties in the values of the initial RT NDT, the copper and nickel contents, the fluence, andthe calculational procedures.10 CFR 50.61 establishes the applicability of RTPTS screening criterion. The relationshipbetween the LTOP enable temperature and the PT period of validity is a function of the material properties at the end of the proposed period of applicability.

3.0TECHNICAL EVALUATION

3.1 Fluence Calculational Methodology The NRC staff review for the issuance of IP3 License Amendment Nos. 220 and 225 (References 4 and 5) reviewed the vessel fluence calculations and found them acceptable, i.e.,

satisfying guidance in RG 1.190, for fluence levels up to 34.0 EFPYs. That value is not a subject for this review because it has not changed. The proposed extension to 27.2 EFPYs is bounded by the approved vessel fluence value of 34.0 EFPYs, therefore, it is acceptable. 3.2TS PT Limit Curves and ART The licensee is proposing to change the current TS PT limit curve applicability from 20.0 to 27.2EFPYs. The change is required because the current applicability limit is estimated to bereached by December 2007. The reason for the staged PT limit and LTOP limit setting is the licensee's previous effort to avoid modifying the LTOP arming temperature by restricting the TS PT limit curve to the 20 EFPY level. The PT limits and the LTOP arming temperature have corresponding values, i.e., if the PT limit curves change the arming temperature should change appropriately. The proposed extension to 27.2 EFPYs is bounded by the approved vessel fluence value of 34.0 EFPYs, therefore, it is acceptable. The ART values for 27.2 EFPYs at the 1/4T and 3/4T locations are being revised to 241.1 F and 198.1 F, respectively. The ARTvalues were also part of the licensee's submittal for License Amendment No. 220 (Reference 6) which were previously reviewed and approved by the NRC and are, therefore, acceptable.3.3Editorial Changes to the TS The licensee identified that several places in TS 3.4.12 associated with comparisons betweenthe reactor coolant system temperature and the LTOP arming temperature do not match the standard TS in the use of the symbols for "less than," "less than or equal to," "greater than,"

and "greater than or equal to." These are being revised to match the Standard TS, NUREG- 1431. The changes will add clarity to the TSs and match the standard TS, and do not alter themeaning of the IP3 specifications, therefore, they are acceptable.3.4Vessel Heatup, Cooldown, and Hydrostatic Testing Curves TS Figures 3.4.3-1, 3.4-3.2, and 3.4.3-3, regarding vessel heatup, cooldown and hydrostatictesting respectively, changed the period of applicability from 20.0 to 27.2 EFPYs. As stated above, these changes are acceptable because the proposed applicability range of 27.2 EFPYs is bounded by the approved value of 34.0 EFPYs.3.5LTOP Arming Temperature The LTOP arming temperature is that temperature at which the LTOP system must be inservice, with the lift setpoint of the pressurizer power-operated relief valves reduced to avoid overpressure of the reactor vessel at low temperatures. As irradiation embrittles the material of the vessel, the LTOP arming temperature becomes higher. The licensee is proposing to increase the arming temperature from 319 F to 330 F to correspond with increasing the PTlimit curve applicability to 27.2 EFPYs. TS 3.4.12 uses the LTOP arming temperature to determine when the LTOP system is required to be operable. Note that the LTOP arming temperature is also called the Overpressure Protection System (OPS) enable temperature in Figure 3.4.12-1. This arming temperature is also used in TS 3.4.7 and TS 3.4.10. The new value corresponds to the limiting PT curves for 27.2 EFPYs and is calculated using the methodology approved by the NRC in Reference 4. For this reason, the new arming temperature is acceptable.3.6Conclusion The NRC staff has previously reviewed and approved the analysis of record for IP3 vesselneutron fluence. The conditions and assumptions underlying the validity of the current PT limit curves and LTOP limits are still valid, and the new LTOP arming temperature has been calculated in accordance with an NRC-approved methodology. The editorial changes for the use of "less than," "less than or equal to," "greater than," and "greater than or equal to" symbols are in accordance with standard TS and do not alter the meaning of the TSs.

Therefore, the proposed changes are acceptable.

4.0STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of theproposed issuance of the amendment. The State official had no comments.

5.0ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed findingthat the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 17946). Accordingly, the amendment meets theeligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there isreasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

7.0REFERENCES

1.Letter from Fred Dacimo, Entergy Nuclear Northeast, to U.S. NRC, "Proposed Changeto Indian Point 3 Technical Specifications Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits" dated January 18, 2007 (ML070240285).2.Appendix A to 10 CFR 50, General Design Criterion 30, "Quality of Reactor CoolantPressure Boundary," and General Design Criterion 31, "Fracture Prevention of Reactor Coolant Pressure Boundary".3.NRC Regulatory Guide RG 1.190, "Calculational and Dosimetry Methods forDetermining Pressure Vessel Neutron Fluence," March, 2001.4.NRC Letter to Entergy for amendment 220, "Indian Point Nuclear Generating Unit No. 3- Issuance of Amendment Re: Changes to Pressure-Temperature Curves (TAC No.

MB9133)," dated December 3, 2003 (ML033370869).5.NRC Letter to Entergy for amendment 225, "Indian Point Nuclear Generating Unit No. 3- Issuance of Amendment Re: 4.85 Percent Stretch Power Uprate and Relocation of Cycle-Specific Parameters (TAC No. MC3552)," dated March 24, 2005 (ML050600380).6.Letter from Michael Kansler, Entergy Nuclear Northeast, to U.S. NRC, "ProposedChange to Indian Point 3 Technical Specifications: Pressure-Temperature and Overpressure Protection System Limits For Up To 20 Effective Full Power Years" dated May 28, 2003 (ML031550595).Principal Contributors: Lambros Lois, John Boska Date: October 4, 2007