NL-19-078, Supplement to Technical Specifications Proposed Change - Permanently Defueled Technical Specifications

Supplement to Technical Specifications Proposed Change - Permanently Defueled Technical Specifications

ML19295G018
Person / Time
Site:	Indian Point
Issue date:	10/22/2019
From:	Gaston R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-19-078
Download: ML19295G018 (18)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.90 NL-19-078 October 22, 2019 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Supplement to Technical Specifications Proposed Change - Permanently Defueled Technical Specifications Indian Point Nuclear Generating Unit 2 NRC Docket No. 50-247 Renewed Facility Operating License No. DPR-26 In Reference 1, Entergy Nuclear Operations, Inc. (Entergy) proposed an amendment to Renewed Facility Operating License (FOL) DPR-26 for Indian Point Nuclear Generating Unit 2 (IP2) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license or construction permit." This proposed license amendment revised the IP2 FOL and the Technical Specifications (TSs) in Appendix A to Permanently Defueled Technical Specifications (PDTS) and included related conforming changes to the Environmental Technical Specification Requirements in Appendix B of the OL and the Inter-Unit Transfer Technical Specifications in Appendix C of the OL. The proposed changes are consistent with the permanent cessation of reactor operation and permanent defueling of the reactor as described in Reference 2.

In Reference 3, as supplemented by Reference 4, Entergy submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) to modify the IP2 TSs regarding spent fuel storage requirements. The IP2 spent fuel storage LAR was approved by the NRC on September 4, 2019, and the license amendment and associated revisions to the IP2 OL, TS 3.7.13, "Spent Fuel Pit Storage," and TS 4.0, "Design Features," were issued in Amendment No. 290 (Reference 5).

The purpose of this letter is to update the pages of the IP2 PDTS originally submitted in Reference 1 by incorporating the PDTS changes into the current, recently approved TS pages that were issued in Amendment No. 290 (Reference 5). The affected pages of the IP2 PDTS are those pages where the originally submitted PDTS changes were applied to the IP2 OL and TSs 3.7.13 and 4.0 pages that were later revised by the spent fuel storage amendment or, in the case of the TS Bases, where the originally submitted TS 3.7.13 Bases pages were revised by

NL-19-078 Page 2 of 3 Entergy to reflect the approved amendment. This supplement to the IP2 PDTS submittal is provided at the request of the NRC.

Entergy has reviewed this supplement to the IP2 PDTS submittal in accordance with 10 CFR 50.92 and determined that the previous conclusion of no significant hazards consideration is not changed.

In accordance with 10 CFR 50.91, copies of this letter, with attachments, are being provided to the New York State Department of Health and Emergency Management Agency. to this letter contains a mark-up of the affected IP2 FOL and TSs 3.7.13 and 4.0 pages of the PDTS. Attachment 2 contains the affected IP2 TS 3.7.13 Bases mark-up pages, and is provided for information only. Attachment 3 contains the retyped affected IP2 FOL and TSs 3.7.13 and 4.0 pages of the PDTS. Note that TS 4.2 is shown in Attachments 1 and 3 as it was revised in the IP2 Administrative Controls LAR (Reference 6) that was submitted to the NRC on April 15, 2019 and is currently in review.

It is intended that the pages provided in Attachments 1 and 3 of this submittal be used to replace the corresponding pages originally provided in Attachments 1 and 2 to the Enclosure of the IP2 PDTS submittal (Reference 1). In Attachment 2, the PDTS changes are incorporated into the appropriate retyped TS 3.7.13 Bases pages that were revised by Entergy to reflect the approved Amendment No. 290 (Reference 5).

There are no new regulatory commitments made in this letter.

If you have any questions regarding this submittal, please contact Ms. Mahvash Mirzai, Acting Manager, Regulatory Assurance, at (914) 254-7714.

I declare under penalty of perjury that the foregoing is true and correct. Executed on October 22, 2019.

Respectfully, Ron Gaston RWG/cdm

NL-19-078 Page 3 of 3 Attachments: 1.

Indian Point Nuclear Generating Unit No. 2 - Mark-up of Affected Pages of Renewed Facility Operating License and Technical Specifications 3.7.13 and 4.0

2.

Indian Point Nuclear Generating Unit No. 2 - Mark-up of Affected Pages of Technical Specification 3.7.13 Bases (Information Only)

3.

Indian Point Nuclear Generating Unit No. 2 - Retyped (Clean) Affected Pages of Renewed Facility Operating License and Technical Specifications 3.7.13 and 4.0

References:

1.

Entergy Nuclear Operations, Inc. (Entergy) letter to U.S. Nuclear Regulatory Commission (NRC), "Technical Specifications Proposed Change - Permanently Defueled Technical Specifications," (Letter No.

NL-19-026) (ADAMS Accession No. ML19105B241), dated April 15, 2019

2.

Entergy letter to NRC, "Notification of Permanent Cessation of Power Operations," (Letter No. NL-17-021) (ADAMS Accession No. ML17044A004), dated February 8, 2017

3.

Entergy letter to NRC, "Indian Point Nuclear Generating Unit No. 2, Proposed License Amendment Regarding Spent Fuel Storage," (Letter No.

NL-17-144) (ADAMS Accession No. ML17354A014), dated December 11, 2017

4.

Entergy letter to NRC, "Response to Request for Additional Information (RAI) - Proposed License Amendment Request Regarding Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool," (Letter No.

NL-19-023) (ADAMS Accession No. ML19157A309), dated June 6, 2019

5.

NRC letter to Entergy, "Indian Point Nuclear Generating Unit No. 2 -

Issuance of Amendment No. 290 RE: Storage of Fresh and Spent Nuclear Fuel in the Spent Fuel Pool (EPID L-2017-LLA-0408)," (Letter No. RA 087) (ADAMS Accession No. ML19209C966), dated September 4, 2019

6.

Entergy letter to NRC, "Technical Specifications Proposed Change -

Administrative Controls for Permanently Defueled Conditions," (Letter No.

NL-19-013) (ADAMS Accession No. ML19105B236), dated April 15, 2019 cc:

NRC Senior Project Manager, NRC NRR DORL Regional Administrator, NRC Region I NRC Senior Resident Inspector, Indian Point Energy Center President and CEO, NYSERDA New York State (NYS) Public Service Commission NYS Department of Health - Radiation Control Program NYS Emergency Management Agency

NL-19-078 Indian Point Nuclear Generating Unit No. 2 Mark-up of Affected Pages of Renewed Facility Operating License and Technical Specifications 3.7.13 and 4.0 Affected Facility Operating License Page:

3 Affected Technical Specification Pages:

3.7.13-1 3.7.13-2 4.0-1 4.0-2

Amendment No. 290 Amdt. 42 10-17-78 Amdt. 220 09-06-01 Amdt. 241 10-27-04 (3)

ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use, at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5)

ENO pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level ENO is authorized to operate the facility at steady state reactor core power levels not in excess of 3216 megawatts thermal (2)

Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. 290, are hereby incorporated in the renewed license. ENO shall operate the facility in accordance with the Technical Specifications.

(3)

The following conditions relate to the amendment approving the conversion to Improved Standard Technical Specifications:

1.

This amendment authorizes the relocation of certain Technical Specification requirements and detailed information to licensee controlled documents as described in Table R, "Relocated Technical Specifications from the CTS," and Table LA, "Removed Details and Less Restrictive Administrative Changes to the CTS" attached to the NRC staff's Safety Evaluation enclosed with this amendment. The relocation of requirements and detailed information shall be completed on or before the implementation of this amendment.

Amdt. 42 10-17-78 that were used calibration of that were used are used in the calibration of that were Deleted per Amendment

[###]

maintain Deleted per Amendment

[###]

Spent Fuel Pit Storage 3.7.13 INDIAN POINT 2 3.7.13 - 1 Amendment No. 290 3.7 PLANT SYSTEMS 3.7.13 Spent Fuel Pit Storage LCO 3.7.13 IP2 fuel assemblies stored in the Spent Fuel Pit shall be categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-2.

IP3 fuel assemblies stored in the Spent Fuel Pit shall be categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-3.

IP2 and IP3 fuel assembly storage locations within the Spent Fuel Pit shall be restricted to locations allowed by Figure 3.7.13-1 and its associated notes.

---

Note-----------------------------------------------

Regarding Category 5 fuel assemblies that are required by Figure 3.7.13-1 to contain a full length RCCA - The RCCA must not be placed in or removed while the assembly is in an RCCA required location unless all 8 adjacent cells are empty.

APPLICABILITY:

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

SPENT FUEL PIT REQUIREMENTS

Spent Fuel Pit Storage 3.7.13 INDIAN POINT 2 3.7.13 - 2 Amendment No. 290 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO not met.

A.1

- NOTE -

LCO 3.0.3 is not applicable.

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

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Verify by administrative means that the IP2 fuel assembly has been categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-2 and meets the requirements for the intended storage location.

OR Verify by administrative means that the IP3 fuel assembly has been categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-3 and meets the requirements for the intended storage location.

Prior to storing the fuel assembly in the Spent Fuel Pit.

Prior to storing the fuel assembly in the Spent Fuel Pit.

- NOTE -

Separate Condition entry is allowed for each fuel assembly.

Design Features 4.0 INDIAN POINT 2 4.0 - 1 Amendment No. 290 4.0 DESIGN FEATURES 4.1 Site Location Indian Point 2 is located on the East bank of the Hudson River at Indian Point, Village of Buchanan, in upper Westchester County, New York. The site is approximately 24 miles north of the New York City boundary line. The nearest city is Peekskill which is 2.5 miles northeast of Indian Point.

The minimum distance from the reactor center line to the boundary of the site exclusion area and the outer boundary of the low population zone, as defined in 10 CFR 100.3, is 520 meters and 1100 meters, respectively. For the purpose of satisfying 10 CFR Part 20, the Restricted Area is the same as the Exclusion Area shown in UFSAR, Figure 2.2-2.

4.2 Deleted 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

the Defueled Safety Analysis Report (DSAR)

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued)

INDIAN POINT 2 4.0 - 2 Amendment No. 290

a.

Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent, and poisons, if necessary, to meet the limit for

keff,

b.

keff 0.95 when flooded with borated water, keff 1.0 if fully flooded with unborated water, and

c.

Each fuel assembly categorized based on initial enrichment, burnup, cooling time, averaged assembly peaking factor, and number of Integral Fuel Burnable Absorbers (IFBA) rods with individual fuel assembly storage location within the spent fuel storage rack restricted as required by Technical Specification 3.7.13.

4.3.1.2 The new fuel storage racks are designed and shall be maintained with:

a.

Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent, and poisons, if necessary, to meet the limit for

keff,

b.

keff 0.95 if fully flooded with unborated water, and

c.

A 20.5 inch center to center distance between fuel assemblies placed in the storage racks to meet the limit for keff.

4.3.2 Drainage The spent fuel pit is designed and shall be maintained to prevent inadvertent draining of the pit below a nominal elevation of 88 feet, 6 inches.

4.3.3 Capacity The spent fuel pit is designed and shall be maintained with a storage capacity limited to no more than 269 fuel assemblies in Region I and 1105 fuel assemblies in Region II.

NL-19-078 Indian Point Nuclear Generating Unit No. 2 Mark-up of Affected Pages of Technical Specification 3.7.13 Bases (Information Only)

Affected Technical Specification Bases Pages:

B 3.7.13-1 B 3.7.13-7

Spent Fuel Pit Storage B 3.7.13 INDIAN POINT 2 B 3.7.13 - 1 Revision 8 B 3.7 Plant Systems B 3.7.13 Spent Fuel Pit Storage BASES BACKGROUND The Spent Fuel Pit (SFP) is used to store IP2 spent fuel removed from the reactor and new fuel ready for insertion into the reactor. It is also used to store IP3 fuel that has been transferred from the IP3 SFP prior to it being placed into dry cask storage (Refs 1 and 2). Spent fuel racks (SFRs) are erected on the SFP floor to hold the fuel assemblies. The SFRs have been evaluated to meet the requirements of option (b) of 10 CFR 50.68, Criticality Accident Requirements (Ref. 3).

IP2 compliance with 10 CFR 50.68(b)(4) was confirmed by an analysis documented in Curtiss-Wright Nuclear Division, NETCO report NET-28091-003-01, Rev. 0 Criticality Safety Analysis for the Indian Point Unit 2 Spent Fuel Pool with No Absorber Panel Credit (Ref. 4) and was approved by the NRC in Amendment 290 (Ref. 5). This analysis demonstrates that 10 CFR 50.68(b)(4) will be met during normal SFP operation and all credible accident scenarios if the following requirements are met:

a)

The SFP boron concentration is maintained within the limits of LCO 3.7.12, Spent Fuel Pit Boron Concentration, whenever fuel is stored in the SFP; and, b)

Fuel assembly storage location within the SFP is restricted in accordance with LCO 3.7.13, Spent Fuel Pit Storage, based on the fuel assemblys initial enrichment, burnup, decay of Plutonium-241 (i.e., cooling time), averaged assembly peaking factor, and number of Integral Fuel Burnable Absorbers (IFBA) rods. Note that historic fuel assemblies have been pre-categorized (Tables 3.7.13-2 and 3.7.13-3).

Fuel assembly storage location within the Spent Fuel Pit is an essential element of the criticality analysis. The storage racks in the areas designated Region 1 have a different design than the storage racks in the areas designated Region 2 and this design difference has a significant impact on criticality calculations. Regions 1 and 2 are shown on the insert to Figure 3.7.13-1.

Region 1 consists of three racks that use the flux trap design and has 269 cell locations for the storage of fuel assemblies. The flux trap design used in Region 1 uses spacer plates in the axial direction to separate the cells.

Boraflex panels are held in place adjacent to each side of the cell by picture frame sheathing. In addition, due to a damaged cell, there is one cell blocker in Region 1.

SPENT FUEL PIT REQUIREMENTS

INDIAN POINT 2 B 3.7.13 - 7 Revision 8 Spent Fuel Pit Storage B 3.7.13 BASES ACTIONS (continued)

A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

When the configuration of fuel assemblies stored in the Spent Fuel Pit is not in accordance with the rules established by LCO 3.7.13, the immediate action is to initiate action to make the necessary fuel assembly movement(s) to bring the configuration into compliance with the rules established by LCO 3.7.13.

If unable to move irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not be applicable. If unable to move irradiated fuel assemblies while in MODE 1, 2, 3, or 4, the action is independent of reactor operation.

Therefore, inability to move fuel assemblies is not sufficient reason to require a reactor shutdown.

SURVEILLANCE SR 3.7.13.1 REQUIREMENTS This SR verifies by administrative means that the IP2 fuel assembly has been classified based on initial enrichment, burnup, cooling time, averaged assembly peaking factor, and number of IFBA rods in the fuel assembly in accordance with Figure 3.7.13-1, Figure 3.7.13-2, Figure 3.7.13-3, or Figure 3.7.13-4 and that the fuel assembly meets the requirements for the intended storage location defined on Figure 3.7.13-5. This SR also verifies by administrative means that the IP3 fuel assembly meets the requirements for storage in the IP2 SFP. This administrative verification must be completed prior to placing any fuel assembly in the SFP. This SR ensures that this LCO and Specification 4.3.1.1 will be met after the fuel assembly is inserted in the SFP.

REFERENCES

1.

Safety Evaluation by the Office of Nuclear Reactor Regulation Related to Amendment No. 268 to Facility Operating License No.

DPR-26, July 13, 2012.

2.

Holtec Report HI-2094289, Licensing Report on the Inter-Unit Transfer of Spent Nuclear Fuel at Indian Point Energy Center, Revision 6.

3.

10 CFR 50.68, Criticality Accident Requirements.

NL-19-078 Indian Point Nuclear Generating Unit No. 2 Retyped (Clean) Affected Pages of Renewed Facility Operating License and Technical Specifications 3.7.13 and 4.0 Affected Facility Operating License Page:

3 Affected Technical Specification Pages:

3.7.13-1 3.7.13-2 4.0-1 4.0-2

Amendment No.

(3)

ENO pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess and use, at any time any byproduct, source and special nuclear material as sealed neutron sources that were used for reactor startup, sealed sources that were used for reactor instrumentation and are used in the calibration of radiation monitoring equipment, and as fission detectors in amounts as required; (4)

ENO pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (5)

ENO pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials that were produced by the operation of the facility.

C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Deleted per Amendment [###]

(2)

Technical Specifications The Technical Specifications contained in Appendices A, B, and C, as revised through Amendment No. [###], are hereby incorporated in the renewed license. ENO shall maintain the facility in accordance with the Technical Specifications.

(3)

Deleted per Amendment [###]

Amdt. 42 10-17-78

Spent Fuel Pit Storage 3.7.13 INDIAN POINT 2 3.7.13 - 1 Amendment No.

3.7 SPENT FUEL PIT REQUIREMENTS 3.7.13 Spent Fuel Pit Storage LCO 3.7.13 IP2 fuel assemblies stored in the Spent Fuel Pit shall be categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-2.

IP3 fuel assemblies stored in the Spent Fuel Pit shall be categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-3.

IP2 and IP3 fuel assembly storage locations within the Spent Fuel Pit shall be restricted to locations allowed by Figure 3.7.13-1 and its associated notes.

---

Note-----------------------------------------------

Regarding Category 5 fuel assemblies that are required by Figure 3.7.13-1 to contain a full length RCCA - The RCCA must not be placed in or removed while the assembly is in an RCCA required location unless all 8 adjacent cells are empty.

APPLICABILITY:

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

Spent Fuel Pit Storage 3.7.13 INDIAN POINT 2 3.7.13 - 2 Amendment No.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO not met.

A.1 Initiate action to move the noncomplying fuel assembly to an acceptable location.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.13.1 Verify by administrative means that the IP2 fuel assembly has been categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-2 and meets the requirements for the intended storage location.

OR Verify by administrative means that the IP3 fuel assembly has been categorized in accordance with Table 3.7.13-1 or, if pre-categorized, Table 3.7.13-3 and meets the requirements for the intended storage location.

Prior to storing the fuel assembly in the Spent Fuel Pit.

Prior to storing the fuel assembly in the Spent Fuel Pit.

- NOTE -

Separate Condition entry is allowed for each fuel assembly.

Design Features 4.0 INDIAN POINT 2 4.0 - 1 Amendment No.

4.0 DESIGN FEATURES 4.1 Site Location Indian Point 2 is located on the East bank of the Hudson River at Indian Point, Village of Buchanan, in upper Westchester County, New York. The site is approximately 24 miles north of the New York City boundary line. The nearest city is Peekskill which is 2.5 miles northeast of Indian Point.

The minimum distance from the reactor center line to the boundary of the site exclusion area and the outer boundary of the low population zone, as defined in 10 CFR 100.3, is 520 meters and 1100 meters, respectively. For the purpose of satisfying 10 CFR Part 20, the Restricted Area is the same as the Exclusion Area shown in the Defueled Safety Analysis Report (DSAR), Figure 2.2-2.

4.2 Deleted 4.3 Fuel Storage 4.3.1 Criticality 4.3.1.1 The spent fuel storage racks are designed and shall be maintained with:

Design Features 4.0 4.0 DESIGN FEATURES 4.3 Fuel Storage (continued)

INDIAN POINT 2 4.0 - 2 Amendment No.

a.

Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent, and poisons, if necessary, to meet the limit for

keff,

b.

keff 0.95 when flooded with borated water, keff 1.0 if fully flooded with unborated water, and

c.

Each fuel assembly categorized based on initial enrichment, burnup, cooling time, averaged assembly peaking factor, and number of Integral Fuel Burnable Absorbers (IFBA) rods with individual fuel assembly storage location within the spent fuel storage rack restricted as required by Technical Specification 3.7.13.

4.3.2 Drainage The spent fuel pit is designed and shall be maintained to prevent inadvertent draining of the pit below a nominal elevation of 88 feet, 6 inches.

4.3.3 Capacity The spent fuel pit is designed and shall be maintained with a storage capacity limited to no more than 269 fuel assemblies in Region I and 1105 fuel assemblies in Region II.