NL-02-133, Response to Request for Additional Information Regarding Section 5.5.14 of the Improved Technical Specifications (ITS)

Response to Request for Additional Information Regarding Section 5.5.14 of the Improved Technical Specifications (ITS)

ML023100384
Person / Time
Site:	Indian Point
Issue date:	10/28/2002
From:	Dacimo F Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-02-133, TAC MB4739
Download: ML023100384 (10)

Text

Entergy Nuclear Northeast AM Entergy Nuclear Operations, Inc Indian Point Energy Center

"`-Entergy 295 Broadway, Suite 1 P0 Box 249 Buchanan, NY 10511-0249 October 28, 2002 Re: Indian Point Unit No. 2 Docket No. 50-247 NL-02-133 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station O-P1-17 Washington, DC 20555-0001

Subject:

Response to Request for Additional Information Regarding Section 5.5.14 of the Improved Technical Specifications (ITS) (TAC No. MB4739)

Reference:

1) Entergy letter (NL-02-016) to NRC, "License Amendment Request (LAR 02-005) Conversion to Improved Standard Technical Specifications," dated March 27, 2002

2) Entergy letter (NL-02-092) to NRC, "Supplement 1 to the Indian Point 2 License Amendment Request for Conversion to Improved Standard Technical Specifications," dated July 10, 2002

3) NUREG 1431, "Standard Technical Specifications Westinghouse Plants," Revision 2, dated April 2001

4) 10 CFR 50.36, "Technical Specifications," as amended

5) NRC letter to Entergy Nuclear Operations, Inc., "Request for Additional Information (RAI) Regarding Section 3.6 (Containment Systems) of the Improved Technical Specifications (ITS)

(TAC No. MB4739)," dated August 6, 2002

Dear Sir:

By letter dated March 27, 2002 (Reference 1) as supplemented by letter dated July 10, 2002 (Reference 2), Entergy Nuclear Operations, Inc. (ENO) requested to amend the Indian Point 2 (IP2) Plant Operating License, Appendices A and B, "Technical Specifications." The proposed amendment converts the IP2 Current Technical Specifications (CTS) to Improved Technical Specifications (ITS) in accordance with NUREG 1431, "Standard Technical Specifications Westinghouse Plants," (Reference 3), and the Code of Federal Regulations (CFR) (Reference 4).

&OL) I

NL-02-133 Page 2 of 3 The U.S. Nuclear Regulatory Commission (NRC) staff reviewing the request has determined that additional information is required to complete its review. The request for additional information is dated August 6, 2002 (Reference 5). A list of acronyms that may have been used in this submittal has been provided as Attachment 1 to this letter. to this letter, "Response to Request for Additional Information Regarding Section 5.5.14 of the Improved Technical Specifications (ITS)," provides ENO's response to the subject request for additional information. The IP2 Actions described in will be incorporated in a future supplement to the ITS submittal packages.

There are no commitments contained in this letter.

Should you or your staff have any questions regarding this matter, please contact the IP2 ITS Project Manager, Mr. William Blair at (914) 734-5336.

I declare under penalty of perjury that the foregoing is true and correct.

Sincerely, Executed on u o n/ Q I* L--"

Fred Dacimo Vice President - Operations Indian Point 2 Attachments cc: See page 3

NL-02-133 Page 3 of 3 cc:

Mr. Hubert J. Miller Regional Administrator-Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management U.S. Nuclear Regulatory Commission Mail Stop 0-8-2C Washington, DC 20555 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 38 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Paul Eddy NYS Department of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. William Flynn NYS ERDA Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12203

ATTACHMENT 1 TO NL-02-133 List of Acronyms That May Be Used In This Submittal Entergy Nuclear Operations, Inc.

Indian Point Unit No. 2 Docket No. 50-247

NL-02-133 Attachment 1 Page 1 of 2 List of Acronyms That May Be Used In This Submittal AC Air Conditioning or Alternating Current AOT Allowed Outage Time ASME American Society of Mechanical Engineers ASTM American Society for Testing and Materials ATWS Anticipated Transient Without Scram CFR Code of Federal Regulations CLB Current License Basis COLR Core Operating Limits Report COT Channel Operational Test CST Condensate Storage Tank CTS Current Technical Specification DB Design-Basis DBA Design-Basis Accident DC Direct Current DG Diesel Generator DOC Discussion of Change (from the CTS)

ECCS Emergency Core Cooling System EDG Emergency Diesel Generator ESF Engineered Safeguard Feature FR Federal Register GDC General Design Criteria HEPA High Efficiency Particulate Air Hz Hertz IRM Intermediate Range Monitor ISI Inservice Inspection ITS Improved (converted) Technical Specifications JFD Justification For Difference kV Kilovolt kW Kilowatt LAR Licence Amendment Request LCO Limiting Condition for Operation LOCA Loss of Coolant Accident LOOP Loss of Offsite Power LOP Loss of Power MSIV Main Steam Isolation Valve NUMAC Nclear Measurement Analysis and Control PAM Post-Accident Monitoring P/T Pressure/Temperature QA Quality Assurance RAI Request for Additional Information RCS Reactor Coolant System RG Regulatory Guide

NL-02-133 Attachment 1 Page 2 of 2 RHR Residual Heat Removal RPS Reactor Protection System RPV Reactor Pressure Vessel RTP Rated Thermal Power SDC Shutdown Cooling SDM Shutdown Margin SE Safety Evaluation SER Safety Evaluation Report SR Surveillance Requirement SRM Source Range Monitor STS Improved Standard Technical Specification(s), NUREG-1431, Rev. 2 SW Service Water TRM Technical Requirements Manual TS Technical Specifications TSTF Technical Specifications Task Force (re: generic changes to the STS)

ATTACHMENT 2 TO NL-02-133 Response to Request for Additional Information Regarding Section 5.5.14 of the Improved Technical Specifications (ITS)

Entergy Nuclear Operations, Inc.

Indian Point Unit No. 2 Docket No. 50-247

NL-02-133 Attachment 2 Page 1 of 3 Response to Request for Additional Information The NRC Staff reviewing information provided in the March 27, 2002 license amendment request as supplemented by letter dated July 10, 2002 has determined that additional information is required to complete its review. The following are the specific requests from the NRC staff and ENO's response to those requests.

NL-02-133 Attachment 2 Page 2 of 3 5.5.14 : Containment Leakage Rate Testing Program NRC RAI Number TAC Number: Date Received: Date Responded:

5.5.14- 1 MB4739 8/13/2002 NRC Request for Additional Information (RAI):

JFD CLB ITS 5.5.14 The ITS markup of ITS 5.5.14 shows a number of changes marked with a JFD CLB. The Justification for Differences for ITS 5.5.14 does not include a JFD CLB.

Comment: Provide a discussion and justification for this change.

Enterqy (IP2) Response:

Agree.

Entergy (IP2) Action:

IP2 will add JFD CLB to ITS 5.5.14 which states: "IP2 ITS 5.5.14 maintains current licensing basis by adopting NUREG-1431, Rev 2, requirements for 10 CFR 50, Appendix J, Option B. Additionally, acceptance criteria for air lock testing was modified to maintain current licensing basis."

Questions regarding this response should be directed to Dick Sense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBIair@Entergy.Corn).

NL-02-133 Attachment 2 Page 3 of 3 5.5.14 : Containment Leakage Rate Testing Program NRC RAI Number TAC Number: Date Received: Date Responded:

5.5.14-2 MB4739 8/13/2002 NRC Request for Additional Information (RAI):

CTS 4.4.A.2 ITS 5.5.14.c ITS B3.6.1 Bases - Applicable Safety Analyses CTS 4.4.A.2 and ITS B3.6.1 Bases - Applicable Safety Analyses defines La as equal to 0.1 w/o per day of containment steam air atmosphere at 47 psig and 2170 (sic) F. ITS 5.5.14.c defines La as 0.1% of containment air weight per day at Pa (47 psig) and 2710 F. The word "steam" is dropped from the ITS 5.5.14.c definition but retained in the ITS B3.6.1 Bases - Applicable Safety Analyses definition of La.

Comment: Correct this discrepancy and provide any necessary discussion and justification for the change in definition.

Entergy (IP2) Response:

IP2 will maintain criteria exactly as specified in CTS 4.4.A.2.

Entergy (IP2) Action:

Added word "steam" to ITS 5.5.14.c to maintain consistency with CTS 4.4.A.2.

Ouestions regarding this response should be directed to Dick Bense at (914) 734-5895 (RBENS90@Entergy.Com) or Bill Blair at (914) 737-4167 (WBlalr@Entergy.Com).