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| | issue date = 07/02/2012 | | | issue date = 07/02/2012 |
| | title = NRC Acceptance Review of Indian Point 3 Adv License Amendment | | | title = NRC Acceptance Review of Indian Point 3 Adv License Amendment |
| | author name = Pickett D V | | | author name = Pickett D |
| | author affiliation = NRC/NRR/DORL/LPLI-1 | | | author affiliation = NRC/NRR/DORL/LPLI-1 |
| | addressee name = Prussman S G | | | addressee name = Prussman S |
| | addressee affiliation = Entergy Nuclear Operations, Inc | | | addressee affiliation = Entergy Nuclear Operations, Inc |
| | docket = 05000286 | | | docket = 05000286 |
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| | document type = E-Mail, Acceptance Review Letter | | | document type = E-Mail, Acceptance Review Letter |
| | page count = 2 | | | page count = 2 |
| | | project = TAC:ME8750 |
| | | stage = Acceptance Review |
| }} | | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:From: Pickett, Douglas Sent: Monday, July 02, 2012 11:35 AM To: 'Prussman, Stephen G'; 'rwalpol@entergy.com' Cc: Casto, Greg; Wilson, George; Parks, Benjamin; Miranda, Samuel; Gray, Mel; Gardocki, Stanley; Lingam, Siva; Davis, Jack |
| | |
| | ==Subject:== |
| | NRC Acceptance Review of Indian Point 3 ADV License Amendment Bob/Steve - |
| | The staff has performed an acceptance review of Indian Point Unit 3s proposed change to Technical Specification 3.7.4 (i.e., your letter dated May 23, 2012, TAC No. ME8750) in accordance with LIC-109, Appendix B, Guide for Performing Acceptance Reviews. |
| | Specifically, the staff finds the amendment does not meet the following acceptance review criteria: |
| | * Completeness of Scope - Significant analyses/evaluation necessary for staff review are missing from the license amendment request. |
| | * Sufficiency of Information - Information provided in the LAR lacks a level of detail that is appropriate and necessary for the staff to perform an acceptance review. |
| | * Regulatory Basis - Applicable regulations and criteria consistent with regulatory vehicles were not properly applied in the licensee request, as provided in the amendment request. |
| | In regard to the LIC-109 criteria cited above, specific issues with the Indian Point amendment request is described as follows: |
| | The staff finds that the license amendment request does not provide an adequate evaluation for determining the appropriate Technical Specification Limiting Condition for Operation based upon a complete safety analysis encompassing the most limiting single failure. |
| | In accordance with 10 CFR 50.36, Technical Specifications are derived from analyses and evaluation and continues to specify that limiting conditions for operation shall define the lowest functional capability required for safe operation. 10 CFR 50 Appendix A defines a single failure. |
| | In FSAR, Section 1.3, Criterion 34, Residual Heat Removal, the licensee states it will ensure system safety function can be accomplished assuming a single failure. |
| | In FSAR Section 14.2.4, Steam Generator Tube Rupture, the licensee states that in the event of a loss of off-site power (LOOP), the licensee credits the use of the steam generator power-operated relief valves (ADVs) on the intact steam generators to cooldown the reactor coolant system (RCS) as rapidly as possible prior to depressurizing the RCS in order to stop the primary to secondary leakage. |
| | In the amendment request letter dated May 23, 2012, the licensee states under the first paragraph in their Technical Analysis, When the TS were revised for the power uprate (Reference 2), the SG tube rupture analysis assumed that three ADVs were available to reduce pressure and allow isolation of the ruptured generator. An LCO of 4 ADVs is required for three to be available since the ADV on the ruptured SG is not considered available. No additional ADV is assumed to fail consistent with the analysis (Reference 3) that was submitted in Reference 4. Since the plant only has four ADVs and the ADV on the ruptured steam generator is not credited for use, and assuming at least one ADV is lost due to a single failure, |
| | |
| | then only two ADVs are available to perform the cooldown in the required period of time to prevent an over fill condition and limit the radiological release. |
| | In order to meet the requirements of LIC-109, the licensee needs to provide an analysis, considering dose, mass release, and overfill, for a steam generator tube rupture by taking into account the unavailability of the ADV on the ruptured steam generator and the loss of additional ADVs due to the most limiting single failure. |
| | Therefore, the staff concludes that your application is unacceptable with the opportunity to supplement.. |
| | We request a telephone conference call to discuss the deficiencies in your application and how you intend to respond. As stated in LIC-109, you will be expected to provide a written response within 13 working days following the phone call. While we normally schedule a phone call within five working days of this email, we understand that due to the holiday week, it may be difficult to schedule a call this week. Please let me know when you and your staff are available to discuss the staffs findings. |
| | |
| | ==References:== |
| | |
| | The staff issued a Task Interface Agreement (TIA) 2010-002, dated December 20, 2010 (ML103230177), to address the licensing basis for single failure at the Bryon Station. Within this TIA, the staff explained to the licensee of Bryon Station the requirement to address the most limiting single failure when evaluating a steam generator tube rupture. At Bryon, an electrical failure was found to make two ADVs unavailable. |
| | WCAP-10698, SGTR Analysis Methodology to Determine the Margin to Steam Generator Overfill, was evaluated and approved by the staff for industry use. The report identified the worse single failure for the reference plant was failure of an ADV to open on an intact steam generator. |
| | Douglas V. Pickett, Senior Project Manager Indian Point Nuclear Generating Unit U.S. Nuclear Regulatory Commission 301-415-1364 Email: douglas.pickett@nrc.gov}} |
Letter Sequence Acceptance Review |
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MONTHYEARML1218506972012-07-0202 July 2012 NRC Acceptance Review of Indian Point 3 Adv License Amendment Project stage: Acceptance Review ML12193A5162012-07-19019 July 2012 Supplemental Information Needed for Acceptance of Requested Licensing Action Operability of Atmospheric Dump Valves Project stage: Acceptance Review ML12241A3022012-09-0505 September 2012 Acceptance Review for Amendment Regarding Atmospheric Dump Valves - Indian Point Nuclear Generating Unit No. 3 - Project stage: Acceptance Review ML13088A2042013-04-15015 April 2013 Issuance of Amendment Operability of Atmospheric Dump Valves Project stage: Approval 2012-07-02
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Category:E-Mail
MONTHYEARML23341A2002023-12-0707 December 2023 Email - Indian Point Energy Center Generating Units 1, 2, and 3 Implementation Notice of Amendment No. 67, 300 and 276 to Independent Spent Fuel Storage Installation Only Emergency Plan (Ioep) ML23332A0802023-11-0808 November 2023 Email from State of New York on the Revised License Amendment for Indian Point Energy Center ISFSI Only Emergency Plan ML23325A1632023-11-0808 November 2023 State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23331A9542023-11-0808 November 2023 Email - State of New York Comments on the Revised License Amendment for Indian Point Unit 2 and 3 Technical Specification Changes Reflecting Permanent Removal of Spent Fuel ML23144A3452023-05-25025 May 2023 Adam Kahn of Monsey, New York Email Against Treated Water Release from Indian Point Site ML23144A3442023-05-25025 May 2023 Peggy Kurtz of Rockland County, New York Email Against Treated Water Release from Indian Point Site ML23144A3392023-05-25025 May 2023 David Morris of New City, New York Email Against Treated Water Release from Indian Point Site ML23144A3502023-05-25025 May 2023 Dan Kwilecki of Montebello, New York Email Against Treated Water Release from Indian Point Site ML23144A3422023-05-25025 May 2023 Peter Duda of Pearl River, New York Email Against Treated Water Release from Indian Point Site ML23144A3382023-05-25025 May 2023 Dawn Giambalvo of Jersey City, New Jersey Email Against Treated Water Release from Indian Point Site ML23136B1622023-05-15015 May 2023 Town of North Salem, County of Westchester, New York Board Resolution Letter Regarding Treated Water Release from Indian Point Site ML23109A0632023-04-17017 April 2023 Email Acceptance Review for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML23055A1112023-02-23023 February 2023 Alyse Peterson Email- NYSERDA No Comments on Indian Point Unit 2 - Regarding Holtec License Amendment Request to Revise Permanently Defueled Technical Specifications and Staffing Requirements with Spent Fuel Transfer to ISFSI (Dockets 50-24 ML23049A0032023-02-14014 February 2023 NRC Acceptance Email to Holtec for License Amendment Request for Approval of New ISFSI-Only Emergency Plan and Associated EAL Scheme ML22313A1682022-11-0909 November 2022 NRC Response to Updates to the Proposed Amended IP2 Master Trust ML22308A0912022-11-0303 November 2022 Email Acknowledgement for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML22276A1642022-09-29029 September 2022 New York State Revised Draft EA Response E-Mail ML22271A8492022-09-28028 September 2022 E-Mail Transmitting Revised Indian Point Exemption Draft EA ML22269A3452022-09-22022 September 2022 Email Objection to Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2, EPID L-2022-LLA-0072 ML22259A1992022-09-0202 September 2022 Acceptance for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22265A0142022-08-31031 August 2022 Email Acknowledgement for Amended and Restated Holtec IP3 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 3 ML22242A2592022-08-19019 August 2022 E-mail from K. Sturzebecher, NRC, to B. Noval, HDI, Acknowledgement for Amended and Restated Holtec IP2 Master Decommissioning Trust Agreement for Indian Point Nuclear Generating Facility Unit 1 and 2 ML22228A1332022-08-0909 August 2022 Acknowledgement for License Amendment Request to Modify Staffing Requirements Following SFP Transfer to Dry Storage ML22215A0432022-08-0101 August 2022 E-Mail Transmitting NYS NSA Exemption Comments & Draft EA Review Completion ML22208A0292022-07-19019 July 2022 E-Mail Transmitting Indian Point Exemption Draft EA ML22168A0072022-06-16016 June 2022 Acceptance Review for License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML22112A0102022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance ML22112A0122022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance for Indian Point Energy Center ML22103A2432022-04-13013 April 2022 E-mail - Request for Additional Information - License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme for Permanently Defueled Condition for Indian Point Energy Center ML22104A0342022-04-13013 April 2022 E-mail from Z. Cruz, NRC to J. Fleming, Holtec - Request for Additional Information Related to Request for Exemption from Portions of 10 CFR 50.47 and Part 50 Appendix E for Indian Point Energy Center ML22038A2572022-02-0707 February 2022 E-mail from Z. Cruz, NRC, to J. Fleming, HDI - Acceptance Review: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme to Address Permanently Defueled Condition for Indian Point Energy Center ML22035A1862022-02-0404 February 2022 E-mail to J. Fleming, Holtec, from Z. Cruz Perez, NRC - Acceptance Review: Exemption Requests from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E, Section IV for Indian Point Energy Center ML22028A1032022-01-28028 January 2022 E-mail Dated 1/28/2022, Transmittal of Draft Safety Evaluation for Proposed License Amendment Revision to Licensing Basis to Incorporate the Installation and Use of of New Auxiliary Lifting Device ML22038A1592022-01-24024 January 2022 NRR E-mail Capture - (External_Sender) 2021 IPEC Annual Sturgeon Impingement Report ML22006A0442022-01-0505 January 2022 Email from Z Cruz to J Fleming Request for Additional Information - HDI Indian Point Post-Shutdown Decommissioning Activities Report ML21337A2952021-12-0303 December 2021 Subsequent Request for Additional Information License Amendment Request to Revise Licensing Basis for New Auxiliary Lifting Device (E-mail Dated 12/3/2021) ML21335A3692021-12-0101 December 2021 Acceptance Review: Indian Point Energy Center - Exemption Request from 10 CFR Part 20 App G Section Iii.E ML21266A2972021-08-18018 August 2021 8/18/2021 E-mail from H. Specter to R. Guzman Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting on July 29, 2021 ML21225A6142021-08-0909 August 2021 Email from NRC to the Tuscarora Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5682021-08-0909 August 2021 Email from NRC to the Stockbridge-Munsee Community Band of Mohican Indians Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5012021-08-0909 August 2021 Email from NRC to the Shinnecock Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21224A3032021-08-0909 August 2021 Email from NRC to the Mashantucket Pequot Tribe of Connecticut Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4252021-08-0909 August 2021 Email from NRC to the Oneida Nation of Wisconsin Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A3142021-08-0606 August 2021 Email from NRC to the Oneida Indian Nation Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A4402021-08-0606 August 2021 Email from NRC to the Onondaga Nation of Wisconsin Announcing the IPEC PSDAR Meeting on August 18, 2021 ML21225A5462021-08-0606 August 2021 Email from NRC to the St. Regis Mohawk Tribe Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21225A5352021-08-0606 August 2021 Email from NRC to the Tonawanda Band of Seneca Announcing the IPEC PSDAR Public Meeting on August 18, 2021 ML21266A2942021-07-25025 July 2021 E-mail from Paul Blanch to NRC (N. Sheehan, D. Screnci) Public Comments to NRC, Indian Point Post-Shutdown Decommissioning Activities Report Public Meeting, July 29, 2021 ML21197A2002021-07-16016 July 2021 (E-mail 7/16/2021) NRC Staff Assessment and RAI Closeout HDI Fleet Decommissioning Quality Assurance Program and Indian Point Energy Center Quality Assurance Program Manual ML21194A4082021-07-13013 July 2021 (7-13-2021) E-mail NRR Review Hour Estimate Change Supporting the Hi-Lift Crane Proposed License Amendment Request Review 2023-05-25
[Table view] Category:Acceptance Review Letter
MONTHYEARML23109A0632023-04-17017 April 2023 Email Acceptance Review for IP2 and IP3 Amended Facility License and Technical Specification to Reflect Permanent Removal of Spent Fuel from Spent Fuel Pits ML22168A0072022-06-16016 June 2022 Acceptance Review for License Amendment Request to Revise License Condition to Eliminate Cyber Security Plan Requirements ML22112A0102022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 50.54(w)(1) Concerning Indian Point Energy Center Onsite Property Damage Insurance ML22112A0122022-04-21021 April 2022 Acceptance Review: Request for Exemption from 10 CFR 140.11(a)(4) Concerning Primary and Secondary Liability Insurance for Indian Point Energy Center ML22038A2572022-02-0707 February 2022 E-mail from Z. Cruz, NRC, to J. Fleming, HDI - Acceptance Review: License Amendment Request to Revise Emergency Plan and Emergency Action Level Scheme to Address Permanently Defueled Condition for Indian Point Energy Center ML22035A1862022-02-0404 February 2022 E-mail to J. Fleming, Holtec, from Z. Cruz Perez, NRC - Acceptance Review: Exemption Requests from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E, Section IV for Indian Point Energy Center ML21335A3692021-12-0101 December 2021 Acceptance Review: Indian Point Energy Center - Exemption Request from 10 CFR Part 20 App G Section Iii.E ML21188A2112021-07-0707 July 2021 Acceptance of Submittal Post-Shutdown Decommissioning Activities Report ML20211L7952020-07-29029 July 2020 Acceptance Review Determination (E-mail Dated 7/29/20) License Amendment Request to Revise Provisional Operating License and TS to Reflect IPEC Permanently Defueled Condition ML20188A3832020-07-0606 July 2020 Updated Completion Date for IP2 Rescission Request from Interim Compensatory Measure 8.1, Order EA-02-026 ML20149K6992020-05-28028 May 2020 Acceptance Review Determination (E-mail Dated 5/28/20) License Amendment Request for Permanently Defueled Technical Specifications ML20108E9482020-04-17017 April 2020 Acceptance Review Determination for Proposed License Amendment to Revise the Licensing Basis to Incorporate the Installation and Use of a New Auxiliary Lifting Device ML20079M2492020-03-19019 March 2020 Acceptance Review Determination (E-mail Dated 3/19/20) Holtec Exemption Request from 10CFR50.82(a)(8)(i)(A) and 10CFR50.75(h)(1)(iv) ML20021A3802020-01-21021 January 2020 Updated E-mail 1/21/2020; Acceptance Review Determination: Proposed License Amendment City Water and Condensate Storage Tank Technical Specifications ML20002A0102019-12-30030 December 2019 Acceptance Review Determination: Proposed License Amendment City Water and Condensate Storage Tank Technical Specifications ML19295E3132019-10-22022 October 2019 Acceptance Review Determination: (E-mail 10/22/19) Relief Request IP3-IST-RR-001 for Extension of 4th 10-year IST Interval ML19267A3822019-09-24024 September 2019 Acceptance Review Determination: Rescission Request from Interim Compensatory Measure 8.1, Order EA-02-026 (Epids: L-2019-LLL-0025 and L-2019-LLL-0029) ML19141A1032019-05-20020 May 2019 Acceptance Review Determination: LAR to Revise Emergency Plan for Permanently Shut Down and Defueled Condition(05/20/2019 E-mail) EPID: L-2019-LLA-0080 ML19141A1052019-05-20020 May 2019 Acceptance Review Determination: Administrative Controls for Permanently Defueled Condition(05/20/2019 E-mail) EPID: L-2019-LLA-0081 ML19141A1072019-05-20020 May 2019 Acceptance Review Determination: Certified Fuel Handler Training Program(05/20/2019 E-mail) EPID: L-2019-LLL-0015 ML19141A1092019-05-20020 May 2019 Acceptance Review Determination: Exemption Request from Certain Provisions of 10 CFR 73.55 (05/20/2019 E-mail) EPID: L-2019-LLE-0010 ML19141A1152019-05-20020 May 2019 Acceptance Review Determination - LAR Permanently Defueled Technical Specifications (05/20/2019 E-mail) EPID: L-2019-LLA-0079 ML19059A1782019-02-28028 February 2019 Acceptance Review Results for Relief Request No. EN-19-RR-1 to Use ASME Code Case N-831-1 for Entergy Fleet ML18219A9212018-08-0707 August 2018 Acceptance Review Determination: Relief Request IP3-ISI-RR-14, Proposed Alternative to ASME Code Case N-729-4 ML18212A3482018-07-31031 July 2018 Acceptance Review Determination - LAR LAR - Deletion of License Conditions Related to Decommissioning Trust Provisions (07/31/2018 E-mail) EPID: L-2018-LLA-0180 ML18024B0232018-01-24024 January 2018 E-mail Acceptance Review Determination, Proposed License Amendment, Spent Fuel Criticality and Storage Technical Specifications ML18022A2562018-01-22022 January 2018 E-mail Acceptance Review Determination, LAR for One-Time Extension Containment Type a ILRT ML18019A0522018-01-19019 January 2018 E-mail Acceptance Review Determination, Relief Request IP2-ISI-RR-05 Alternative Examination Volume Code Case N-729-4 ML17321A5542017-11-17017 November 2017 Acceptance Review E-mail Dated November 17, 2017: Relief Requests Associated with Extension of Fourth Interval Reactor Vessel and Piping Weld Inspections and 10-year ISI Extension; (EPID: L-2017-LLR-0124, 0127, 0128) ML17142A4122017-05-22022 May 2017 Acceptance Review for Indian Point Units 1, 2 & 3 - License Amendment Request Cyber Security Plan Milestone 8 Implementation Schedule ML17123A1932017-05-0303 May 2017 Acceptance Review for Indian Point 2 Amendment to Connect Non-Seismic Piping to the RWST Seismic Piping (CAC No. MF9578) - 2017/05/03 E-mail from R.Guzman to M.Mirzai ML17115A0482017-04-26026 April 2017 Acceptance of Requested Licensing Action Amendment of Inter-Unit Transfer of Spent Fuel ML15037A5252015-02-13013 February 2015 Acceptance Review for Spent Fuel Pool Criticality Analysis ML1226503642012-09-21021 September 2012 Acceptance Review for Indian Point 3 TAC ME9263 ML1226206062012-09-18018 September 2012 Acceptance Review for Indian Point 3 Diesel Fuel Oil System Amendment ML12241A3022012-09-0505 September 2012 Acceptance Review for Amendment Regarding Atmospheric Dump Valves - Indian Point Nuclear Generating Unit No. 3 - ML1221604302012-08-0303 August 2012 Acceptance Review to Revise Appendix H Rv Capsule Surveillance Schedule ML1220212602012-07-20020 July 2012 Acceptance Review for Indian Point Cyber Security Amendment ML1218506972012-07-0202 July 2012 NRC Acceptance Review of Indian Point 3 Adv License Amendment ML12143A4892012-05-25025 May 2012 Acceptance Review for Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Cooling System Is Out of Service - Indian Point Nuclear Generating Unit No. 3 ML1210802052012-04-18018 April 2012 Acceptance Review for Proposed License Amendment to Allow Use of the Backup Spent Fuel Pool Cooling System While the Spent Fuel Pool Cooling System Is Out of Service - Indian Point Nuclear Generating, Unit No. 3 ML1205800432012-02-27027 February 2012 Relief Request RR-05, ME7940, Acceptance Review ML1202607432012-01-26026 January 2012 ANO 1 & 2, Big Rock, FitzPatrick, GGNS, Indian Point 1, 2, and 3, Palisades, Pilgrim, RBS, Vermont Yankee, and Waterford - Acceptance Review Email, Amendment to Revise Quality Assurance Program Manual and Staff Qualification Technical Speci ML0931703722009-11-13013 November 2009 Acceptance Review of Entergy'S Request to Extend Orders (TAC ME1515 - ME2522) ML0914704832009-05-27027 May 2009 Acceptance Review for Entergy'S Request to Extend Effectiveness of July 28, 2008, Orders ML0913200592009-05-12012 May 2009 Entergy - Acceptance Review for License Amendment Request (TAC Nos. ME1198 - ME1207) 2023-04-17
[Table view] |
Text
From: Pickett, Douglas Sent: Monday, July 02, 2012 11:35 AM To: 'Prussman, Stephen G'; 'rwalpol@entergy.com' Cc: Casto, Greg; Wilson, George; Parks, Benjamin; Miranda, Samuel; Gray, Mel; Gardocki, Stanley; Lingam, Siva; Davis, Jack
Subject:
NRC Acceptance Review of Indian Point 3 ADV License Amendment Bob/Steve -
The staff has performed an acceptance review of Indian Point Unit 3s proposed change to Technical Specification 3.7.4 (i.e., your letter dated May 23, 2012, TAC No. ME8750) in accordance with LIC-109, Appendix B, Guide for Performing Acceptance Reviews.
Specifically, the staff finds the amendment does not meet the following acceptance review criteria:
- Completeness of Scope - Significant analyses/evaluation necessary for staff review are missing from the license amendment request.
- Sufficiency of Information - Information provided in the LAR lacks a level of detail that is appropriate and necessary for the staff to perform an acceptance review.
- Regulatory Basis - Applicable regulations and criteria consistent with regulatory vehicles were not properly applied in the licensee request, as provided in the amendment request.
In regard to the LIC-109 criteria cited above, specific issues with the Indian Point amendment request is described as follows:
The staff finds that the license amendment request does not provide an adequate evaluation for determining the appropriate Technical Specification Limiting Condition for Operation based upon a complete safety analysis encompassing the most limiting single failure.
In accordance with 10 CFR 50.36, Technical Specifications are derived from analyses and evaluation and continues to specify that limiting conditions for operation shall define the lowest functional capability required for safe operation. 10 CFR 50 Appendix A defines a single failure.
In FSAR, Section 1.3, Criterion 34, Residual Heat Removal, the licensee states it will ensure system safety function can be accomplished assuming a single failure.
In FSAR Section 14.2.4, Steam Generator Tube Rupture, the licensee states that in the event of a loss of off-site power (LOOP), the licensee credits the use of the steam generator power-operated relief valves (ADVs) on the intact steam generators to cooldown the reactor coolant system (RCS) as rapidly as possible prior to depressurizing the RCS in order to stop the primary to secondary leakage.
In the amendment request letter dated May 23, 2012, the licensee states under the first paragraph in their Technical Analysis, When the TS were revised for the power uprate (Reference 2), the SG tube rupture analysis assumed that three ADVs were available to reduce pressure and allow isolation of the ruptured generator. An LCO of 4 ADVs is required for three to be available since the ADV on the ruptured SG is not considered available. No additional ADV is assumed to fail consistent with the analysis (Reference 3) that was submitted in Reference 4. Since the plant only has four ADVs and the ADV on the ruptured steam generator is not credited for use, and assuming at least one ADV is lost due to a single failure,
then only two ADVs are available to perform the cooldown in the required period of time to prevent an over fill condition and limit the radiological release.
In order to meet the requirements of LIC-109, the licensee needs to provide an analysis, considering dose, mass release, and overfill, for a steam generator tube rupture by taking into account the unavailability of the ADV on the ruptured steam generator and the loss of additional ADVs due to the most limiting single failure.
Therefore, the staff concludes that your application is unacceptable with the opportunity to supplement..
We request a telephone conference call to discuss the deficiencies in your application and how you intend to respond. As stated in LIC-109, you will be expected to provide a written response within 13 working days following the phone call. While we normally schedule a phone call within five working days of this email, we understand that due to the holiday week, it may be difficult to schedule a call this week. Please let me know when you and your staff are available to discuss the staffs findings.
References:
The staff issued a Task Interface Agreement (TIA) 2010-002, dated December 20, 2010 (ML103230177), to address the licensing basis for single failure at the Bryon Station. Within this TIA, the staff explained to the licensee of Bryon Station the requirement to address the most limiting single failure when evaluating a steam generator tube rupture. At Bryon, an electrical failure was found to make two ADVs unavailable.
WCAP-10698, SGTR Analysis Methodology to Determine the Margin to Steam Generator Overfill, was evaluated and approved by the staff for industry use. The report identified the worse single failure for the reference plant was failure of an ADV to open on an intact steam generator.
Douglas V. Pickett, Senior Project Manager Indian Point Nuclear Generating Unit U.S. Nuclear Regulatory Commission 301-415-1364 Email: douglas.pickett@nrc.gov