ML13064A495
| ML13064A495 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/15/2013 |
| From: | Ventosa J A Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-13-045, TAC ME9263 | |
| Download: ML13064A495 (12) | |
Text
SREntergyEnterav Nuclear NortheastIndian Point Energy Center450 Broadway, GSBP.O. Box 249Buchanan, NY 10511-0249Tel 914 254 6700John A VentosaSite Vice PresidentNL-13-045February 15, 2013U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001
SUBJECT: Response to Request for Additional Information on Proposed License AmendmentRegarding Connection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263)Indian Point Unit Number 3Docket No. 50-286License No. DPR-64REFERENCES: 1. Entergy Letter NL-12-090 to NRC Regarding Proposed LicenseAmendment Regarding Connection of Non Seismic Purification Line toRefuel Water Storage Tank, dated August 14, 20122. Entergy Letter NL-12-143 to NRC Regarding Response to Request forAdditional Information on Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263), dated October 25, 20123. Entergy Letter NL-12-154 to NRC Regarding Response to Request forAdditional Information on Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263), dated November 14, 20124. Entergy Letter NL-12-155 to NRC Regarding Response to Request forAdditional Information on Proposed License Amendment RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTank (TAC No. ME9263), dated December 13, 2012
Dear Sir or Madam:
Entergy Nuclear Operations, Inc, (Entergy) requested a License Amendment, Reference 1, toOperating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3(IP3). Entergy responded to previous requests for information in References 2, 3 and4. Theproposed amendment would revise Technical Specification 3.5.4, to allow the non-seismicallyqualified piping of the Spent Fuel Pool (SFP) purification system to be connected to the Refueling0oo(0 4ý-
NL-13-045Docket 50-286Page 2 of 2Water Storage Tanks (RWST) seismic piping by manual operation of a RWST seismically qualifiedboundary valve under administrative controls for a limited period of time. On January 29, 2013Entergy and the NRC staff discussed the need to provide additional information to supportapproval of the requested amendment. Entergy is providing the additional information in theAttachment.There are no new commitments being made in this submittal. If you have any questions or requireadditional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 254-6710. A copy of this response is being submitted to the designated New York State official inaccordance with 10 CFR 50.91.I declare under penalty of perjury that the foregoing is true and correct. Executed on February ._,2013.
Sincerely,JAV/sp
Attachment:
Information In Response to Discussion with the NRC Staff RegardingConnection of Non Seismic Purification Line to Refuel Water StorageTankcc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORLMr. William Dean, Regional Administrator, NRC Region 1NRC Resident InspectorsMr. Francis J. Murray, Jr., President and CEO, NYSERDAMs. Bridget Frymire, New York State Dept. of Public Service ATTACHMENT TO NL-13-045INFORMATION IN RESPONSE TO DISCUSSION WITH THE NRC STAFFREGARDING CONNECTION OF NON SEISMICPURIFICATION LINE TO REFUEL WATER STORAGE TANKENTERGY NUCLEAR OPERATIONS, INC.INDIAN POINT NUCLEAR GENERATING UNIT NO. 3DOCKET NO. 50-286 NL-13-045Docket 50-286Page 1 of 9By letter dated August 14, 2012 (Accession No. ML12234A098), and subsequent letters, EntergyNuclear Operations, Inc, (Entergy) submitted a license amendment request for U.S. NuclearRegulatory Commission (NRC) review that would revise the Technical Specifications (TSs), forIndian Point Unit No. 3 (IP3). The changes would revise TS 3.5.4, "Refueling Water Storage Tank[RWST]," such that the non seismically qualified piping of the Spent Fuel Pool (SFP) purificationsystem may be connected to the RWST's seismic piping by manual operation of a RWSTseismically qualified boundary valve under administrative controls for a limited period of time forfiltration for removal of suspended solids from the RWST water. In discussions with the NRC staff,the need for additional confirming information was discussed and is being provided as follows:Issue 1The issue was whether a single failure could result in increased leakage. There are no singlefailures to be taken after the valves are opened for RWST recirculation that result in the leakageexceeding allowable.There are two possible scenarios where sump fluid leakage could be seen after an accident. Oneis when using the recirculation pumps for low head to high head recirculation and the second iswhen using the residual heat removal pumps for cold leg or hot leg recirculation. The first method,using the recirculation pumps, is preferred and is at issue here. The low head to high headinjection using the recirculation pumps is the normal low head to high head pathway following thecold leg recirculation phase of a large break Loss of Coolant Accident (LOCA). During the cold legrecirculation phase (after about 20 minutes) the internal recirculation pumps keep all fluid insidecontainment for the large break LOCA and do not send fluid outside containment until hot legrecirculation (recirculation pumps send fluid from containment to the suction of the high headsafety injection pumps). This flow path is isolated from the Refueling Water Storage Tank suctionline (16-SI-151 R, line #155 on drawing 9321-F-27503) by check valve SI-847 and motor operatedvalve SI-1810. Valve SI-1810 and valve AC-727A are boundary valves when performing leakagetest 3-PT-R178. Valves SI-847 and SI-1810 are also subjected to external leakage testing by 3-PT-R067 which pressurizes the SI pumps and piping for detection of leakage per TechnicalSpecification 5.5.2 and uses these valves as a boundary.Test 3-PT-R178 is intended to measure the potential for leakage through valve SI-846. DuringRWST purification, a single failure of valve AC-727A to close could occur and provide an additionalleakage path (this would be restricted by the refueling water purification pump and valve AC-725which are downstream and seismic but not leak tested). Therefore, when using the refueling waterstorage purification loop, the potential exists for leakage of sump fluid (during low head to highhead recirculation) through boundary valves SI-847 and SI-1 810 equivalent to the allowableleakage of test 3-PT-R178. This can then be postulated to leak out solely through failed openvalve AC-727A but would be limited to 5.0 gallons per hour (gph) since that is the test 3-PT-R178acceptance criteria. If valve SI-1810 were assumed to fail the system leakage would be boundedby test 3-PT-R178 because valve AC-727A would not fail to close.
NL-13-045Docket 50-286Page 2 of 9Requested information on valves for proposed amendment is:Valve Safety Required to Leak tested Powered Automatically Credited inrelated be operable by actuated DBA analysisby TS & TS emergencynumber powerSI-847 Yes TS 5.5.2 3-PT-R067 check By flow Yes (open on(as suction fromdiscussed) RWST)S1-1810 Yes TS 5.5.2 3-PT-R067 MOV Manual Yes (closedand 3-PT- powered duringR178 transfer tohigh headrecirculation)SI-842 Yes TS 5.5.2 3-PT-R182 MOV Manual Yes (closedpowered duringtransfer tohigh headrecirculation)SI-843 Yes TS 5.5.2 3-PT-R182 MOV Manual Yes (closedpowered duringtransfer tohigh headrecirculation)AC-727A Yes TS 5.5.2 3-PT-R178 Manual Manual Yes -closedAC-725 Yes No No Manual Manual No -closedFurther, it should be noted that prior to operation for purification, valves AC-727A and AC-725 willbe cycled (open -close). This provides reasonable assurance of operability.Issue 2The second issue was to explain the apparent contradiction between the 2 gph leakage postulatedfrom the ECCS boundary and the 7 gph leakage from the RWST (or 9 gph from the RWST and SI-842/843 in ML12335A616). Also compare the valve AC-727A leakage doses (e.g., release point tothe release points in the calculation of leakage from the ECCS boundary) to the allowable.RG 1.183 (Appendix A "Assumptions for Evaluating the Radiological Consequences of a LWRLoss-of Coolant Accident," Section 5) requires "ESF systems that recirculate sump water outsideof the primary containment are assumed to leak during their intended operation. This releasesource includes leakage through valve packing glands, pump shaft seals, flanged connections, andother similar components. This release source may also include leakage through valves isolatinginterfacing systems (Ref. A-7). The radiological consequences from the postulated leakage shouldbe analyzed and combined with consequences postulated for other fission product release paths todetermine the total calculated radiological consequences from the LOCA."
NL-13-045Docket 50-286Page 3 of 9WCAP-16212-P was submitted to the NRC (Reference ML041620506) and addressed this issue.Section 6.11.9.7.1 says "The analysis considered the release of activity from the damaged core tothe containment via containment leakage. In addition, it was assumed that once externalrecirculation of the ECCS was established, activity in the sump solution would be released to theenvironment by means of leakage from the ECCS equipment outside containment in the AuxiliaryBuilding. The total offsite and control room doses are the sum of the doses resulting from each ofthe postulated release paths." The same section discusses that leakage: "Initially, the ECCSrecirculation would be internal to the containment and there would be no potential for leakageoutside containment. However, the switch to external recirculation was assumed to occur at 6.5hours because of the need to switch from cold-leg recirculation mode to hot-leg recirculation mode.With external ECCS recirculation established following the LOCA, leakage was assumed to occurfrom ECCS equipment outside containment. The leakage goes into the Auxiliary Building and nofiltration or holdup was credited with this release. The ECCS leakage was modeled as 4.0 gallonsper hour which, consistent with RG 1.183 (Reference 5), is double the plant allowable leakagevalue of 2.0 gallons per hour."The above ECCS leakage is determined per Technical Specification 5.5.2 and includes thefollowing systems:a. Residual Heat Removal System;b. Cross Connect Between Low Head Recirculation System and High Head Safety InjectionSystem;c. High Head Safety Injection system (partial);d. Reactor Coolant Sampling System;e. Post Accident Containment Air Sampling System;f. Volume Control Tank (including Reactor Coolant Pump seal return line);g. Containment Hydrogen Monitoring system.As noted earlier, the RWST isolation valve (846) is tested by procedure 3-PT-R178 and the currentacceptance criterion is 5.0 gph. The SI-842 and SI-843 valves are tested by 3-PT-R182 and thecurrent acceptance criterion is 1.0 gph -these valves and their acceptance criteria are governed bythe 2.0 gph limit for ECCS leakage. The details of this are explained below.1. RG 1.183 Appendix A stated that "Consideration should also be given to design leakagethrough valves isolating ESF recirculation systems from tanks vented to atmosphere, e.g.,emergency core cooling system (ECCS) pump miniflow return to the refueling water storagetank." The submittal to comply with RG 1.183 was based on the conclusion that the doseconsequences of this leakage was insignificant. The secondary means of achieving hot legrecirculation is using the RHR pumps to draw suction from the reactor sump and deliveringwater through the RWST suction line. This requires a passive failure, which is not postulatedto occur for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The leakage associated with this pathway is not part of the TS 5.5.2program because that program does not assume the single failure. Likewise, the RG 1.183guidance does not impose any additional single failure to determine this leakage path. The IP3design is fairly unique in having internal recirculation pumps as well as residual heat removal(RHR) pumps. In a design with just the RHR pumps to perform the low head to high headrecirculation pathway, the suction line to the RWST would likely be used and would be part ofthis leakage program. The program for testing the ECCS leakage to the 2.0 gph criteria fromthe low head to high head lineup is found in procedure 3-PT-R067 and 3-PT-R182.2. Although not required by RG 1.183 or the TS 5.5.2, the plant design includes the capability toprovide hot leg (low head to high head) recirculation using the RHR pumps and pumping sump NL-1 3-045Docket 50-286Page 4 of 9fluid to the suction of the high head safety injection pumps using the suction line from theRWST. Therefore an analysis was done and this was added to the FSAR using the 10 CFR50.59 process to consider a 5.0 gph ECCS back-leakage to the RWST via valve 846. Thisdose is in addition to the dose from the containment leakage / shine and the leakage fromECCS that was included in the prior analyses. The release point for the ECCS back-leakagethrough the 846 valve is from the RWST.To evaluate the case postulated in the first issue, a dose assessment was done of the correctionfactors that would have to be applied to the RWST dose analysis if it was to be performed forleakage through failed open valve AC-727A (this would be restricted by the refueling waterpurification pump and valve AC-725 which are downstream and seismic but they are not creditedsince they are not leak tested). This evaluation is discussed below.The Indian Point Unit 3 (IP3) dose consequences licensing basis includes the Emergency CoreCooling System (ECCS) back-leakage of 5.0 gallons per hour (gph) through Valve 846 to theRefueling Water Storage Tank (RWST) during the external recirculation phase of a large breakloss-of-coolant accident (LOCA). For purposes of when the purification loop is used, it may bepostulated that this 5.0 gph is conservatively assumed to leak from AC-727A. This leakage wouldbe in the Primary Auxiliary Building (PAB) and the dose consequences would be released throughthe containment vent. The release through the containment vent is the same release point as theECCS leakage, and so it is appropriate to use the PAB x/Q for the purification loop release asdiscussed below. The impact of this release through the PAB instead of the RWST may beevaluated by accounting for differences in atmospheric dispersion factors (X/Q's) between the PABand the RWST and by accounting for iodine release fractions as shown below.1) The information for the X/Q's from the PAB and RWST releases to the Control Room (CR)is shown in Table 1. [Appendix A shows details of input parameters to X/Q for the RWSTreleases]. The information for the X/Q's from the PAB release to the CR is from Reference 1and was previously reviewed by the NRC [Reference 3]. [Appendix B shows details of inputparameters to x/Q for the PAB releases]. A comparison of the X/Q's is shown in the lastcolumn of Table 1, which shows that the atmospheric dispersion factors from the PABreleases bound those from the RWST releases. Consequently the dose from the RWSTrelease for the 5.0 gph leakage of 0.0096 rem is multiplied by the highest ratio of x/Q's (i.e.,1.89) and resulted in a dose of 0.01814 rem if released from the PAB.2) This dose is then adjusted to account for the iodine release fraction from the RWST (2%)and the PAB (10%) resulting in a CR dose of 0.0907 rem (= 0.01814 x 10% / 2%).3) Since all the ECCS back-leakage is assumed to be from AC-727A in the PAB, the dosecomponent of the ECCS back-leakage to the RWST is removed from the total CR dose.,The total large break LOCA CR dose is 4.98 rem [Reference 2], which is rounded up from4.9733 rem, and subtracting the contribution from the ECCS back-leakage to the RWST of0.0096 rem, the total CR dose is 4.9637 rem. By adding the CR dose from above to this,the total CR dose is 5.0 rem. Therefore, the CR dose still meets the acceptance criterionset forth in 10 CFR 50.67.4) The ECCS leakage to the Primary Auxiliary Building and the ECCS back-leakage to theRefueling Water Storage Tank occur during the external recirculation phase of a largebreak LOCA, which is 6.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into the event. In this evaluation, the worst 2-hourExclusion Area Boundary (EAB) dose contribution from the ECCS back-leakage to the NL-13-045Docket 50-286Page 5 of 9RWST, which is 0.006 rem, is conservatively added to the existing EAB dose. The EABdose due to the ECCS back-leakage to RWST is adjusted to 0.057 rem (= 0.006 x 1.89 x10% / 2%) accounting for the X/Q ratio and the iodine release fraction ratio. Since the largebreak LOCA EAB dose is reported as 23.6 rem, the worst 2-hour EAB dose is 23.7 rem.Therefore the worst 2-hour EAB dose is still below the 25 rem limit of 10 CFR 50.67.Further, the low population zone (LPZ) dose is reported as1 3.0 rem, which is well below the25 rem limit in 10 CFR 50.67. Similar to the CR dose above, the LPZ dose is also adjustedbased on the X/Q ratio (i.e., 1.89) and the iodine release fraction ratio (i.e., 10% / 2%) toaccount for the PAB release. The LPZ dose from the ECCS back-leakage to the RWST is0.0116 rem, and is adjusted to 0.1096 rem (= 0.0116 x 1.89 x 10% / 2%). Therefore, theLPZ dose is 13.1 rem and meets the 10 CFR 50.67 acceptance criterion.Table 1. Comparison of Atmospheric Dispersion FactorsControl Room Atmospheric Dispersion Factors [sec/me]PAB Release RWST Release Ratio0-2 hours 6.OOE-04 4.84E-04 1.242-8 hours 5.20E-04 2.92E-04 1.788-24 hours 2.12E-04 1.12E-04 1.891-4 days 1.76E-04 1.OOE-04 1.764-30 days 1.30E-04 8.05E-05 1.611) Ratio = PAB Release / RWST ReleaseReferences1. Letter from Fred R. Dacimo (Entergy) to the NRC, "Reply to RAI Regarding Indian Point 3License Amendment Requests for Stretch Power Uprate (TAC MC3552) and AlternateSource Term (TAG MC3551 )," NL-05-020, dated February 11, 2005 (NRC AgencywideDocuments Access and Management System accession No. ML050550202).2. Letter from Fred R. Dacimo (Entergy) to the NRC, "Additional Information Regarding IndianPoint 3 License Amendment Request Alternate Source Term (TAG MC3551 )," NL-05-036,dated March 14, 2005 (NRC Agencywide Documents Access and Management Systemaccession No. ML050810450).3. Letter from Patrick D. Milano (NRC) to Michael Kansler (Entergy), "Indian Point NuclearGenerating Unit No. 3 -Issuance of Amendment RE: Full Scope Adoption of AlternativeSource Term (TAC No. MC3351 )," dated March 22, 2005 (NRC Agencywide DocumentsAccess and Management System accession No. ML0507504311).
NL-13-045Docket 50-286Page 6 of 9Appendix A. Control Room X/Q Input Parameters from RWST ReleaseParame terIPEC Met. DataPosition (ft)RWSTIP3 CRTSCSource DistanceIP3 CRTSCSource DirectionIP3 CRTSCBuilding Wake AreaRWSTRelease ElevationRWSTGradeCR Intake ElevationTSC Intake ElevationRelease HeightRWSTCR Intake HeightTSC Intake HeightSurface Roughness LengthAveraging Sector Width ConstantV a 1 u e(1995-1997)North6033.05783.86312.0East1704.41476.01373.25103.05 m131.98 m81.070168.670169.65 m2128.71825.579.8333.742.2918.850.14.0ftftftftmmmm NL-1 3-045Docket 50-286Page 7 of 9ParameterInitial diffusion coefficientsRWSTMinimum Wind SpeedWind Direction WindowNorth AdjustmentRWST DiameterV a lu e2Y22.03 m0.00.0 m0.5 m/sec90038. 56'40' NL-13-045Docket 50-286Page 8 of 9Appendix B. Control Room x/Q Input Parameters(Excerpt from Attachment 2 of Reference 1)Position, ftLocation N E ElevationContainment Surface 5997.0 1475.1 150.1Containment Vent 6023.0 1475.0 268.0Auxiliary Boiler Feed Building Side 5991.7 1410.1 66.5Auxiliary Boiler Feed Building OrganPipes 5995.5 1395.6 97.0Auxiliary Boiler Feed Building Silencers 6012.9 1390.1 113.1Control Room Intake 5783.8 1476.0 , 25.5Table I. Source and receptor locations on plant grid.Distance Directionto Intake to Release Release BuildingReceptor Height Source Type Height AreaLocation m m 0 Flag I IContainment Surface 65.01 2.21 38.32 1 40.25 3059.33Containment Vent 72.92 2.2ý 38.32 1 76.21 3059.33Auxiliary Boiler Feed Building Side 66.49 2.2 20.98j 1 14.7 3059.33Auxiliary Boiler Feed Building Organ Pipes 68.88 2.29 17.71 1 24.08 3059.33Auxiliary Boiler Feed Building Silencers 73.7q 2.2. 18.011 1 29.00 3059.33Table 2. ARCON96 geometric input data.
NL-13-045Docket 50-286Page 9 of 9Initial PlumeVertical Stack Stack DimensionsVelocity Flow Radius InLocation m/s m 3/ A Ir I Cr,Containment Surface 1 0.0( 0.00 0.00 13.311Containment Vent 0.0 0.00 0.00 0.2 0.0Auxiliary Boiler Feed Building Side 0.0 0.00 0.0( 0.9 2.3Auxiliary Boiler Feed Building Organ 0.0T 0.00 0.0( 0.0 0.0Pipes SeeAuxiliary Boiler Feed Building Silencers 0.0q 0.0q 0.0q o.oq 00.oTable 3. ARCON96 flow and plume dimension data.n~ade genet in riad-1, je~vt -___ __ -ISN-zct Musmn 31561Lower Met Height 10Upper Met Heoght 60,Minimum Wind Speed. m/s 0,5Averagina Sector Width 4Wind Direction Window., 90Elevation Difference 0Table 4. ARCON96 miscellaneous data.