Text

Unit Number 2 - Response to Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-seismic Piping Under Administrative Controls
	ML13253A138
Person / Time
Site:	Indian Point
Issue date:	09/04/2013
From:	Ventosa J; Entergy Nuclear Northeast
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-13-115, TAC MF1440
	Download: ML13253A138 (71)
	v • d • e

Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 S=Entergy Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President Administration NL-13-115 September 4, 2013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Response to Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-seismic Piping under Administrative Controls (TAC NO. MF1440)

Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

REFERENCES:

1. Entergy Letter NL-13-015 to NRC, Proposed License Amendment Regarding Connection of Non Seismic Boric Acid Recovery System to the Refueling Water Storage Tank, dated April 15, 2013

2. NRC Letter to Entergy, Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-Seismic Piping under Administrative Controls (TAC NO. MF1440), dated August 7, 2013

Dear Sir or Madam:

Entergy Nuclear Operations, Inc (Entergy) requested a License Amendment, Reference 1, for Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed amendment would revise Technical Specification 3.5.4, to allow connection of the non-seismically qualified piping of the temporary Boric Acid Recovery System to the Refueling Water Storage Tank under administrative controls for a limited period of time. On August 7, 2013, the NRC staff identified the need for additional information to complete their review (Reference 2). Entergy is providing additional information in response to this request in Attachment 1 and Enclosure 1.

b0l 01 V

NL-13-115 Docket No. 50-247 Page 2 of 2 A copy of this response is being submitted to the designated New York State official in accordance with 10 CFR 50.91.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Licensing at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on September J, 2013.

Sincerely, JAV/ai

Attachment:

1. Response to Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-Seismic Piping under Administrative Controls

Enclosure:

1. Indian Point Calculation IP-CALC-1 1-00091, AST Analysis of IP2 to address the impact of Containment sump solution back-leakage to the RWST after LOCA cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspector Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-13-115 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT TO TEMPORARILY CONNECT SEISMIC TO NON-SEISMIC PIPING UNDER ADMINISTRATIVE CONTROLS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

Attachment 1 NL-13-115 Docket No. 50-247 Page 1 of 10 Response To Request For Additional Information Accident Dose Branch Questions and Responses Question 1 Final Safety Analysis Report (FSAR) Section 14.3.6.6, "External Recirculation," provides a description of the analyses used to justify the proposed change (2.0 gallon per hour limit for Emergency Core Cooling System (ECCS) leakage).

FSAR Section 14.3.6.6 states:

Since the leakage is initiated at 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months after the LOCA [loss of coolant accident],

it does not contribute to the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months site boundary dose [exclusion area boundary dose or EAB].

Standard Review Plan (SRP) 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," states:

The methodology and assumptions for calculatingthe radiologicalconsequences should reflect the regulatorypositions of RG-1. 183 [Regulatory Guide 1.183].

Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," Regulatory Position 4.1.5, states:

The TEDE should be determined for the most limiting person at the EAB. The maximum EAB TEDE for any two-hour period following the start of the radioactivity release should be determined and used in determining compliance with the dose criteriain 10 CFR50.67.14 The maximum two-hour TEDE should be determined by calculatingthe postulated dose for a series of small time increments andperforming a "sliding"sum over the increments for successive two-hour periods. The maximum TEDE obtained is submitted. The time increments should appropriatelyreflect the progression of the accident to capture the peak dose interval between the start of the event and the end of radioactivityrelease (see also Table 6).

This is consistent with Title 10 of the Code of FederalRegulations [10 CFR], Section 50.67, "Accident Source Term," that states:

An individuallocated at any point on the boundaryof the exclusion area for any

[emphasis added] 2-hour periodfollowing the onset of the postulatedfission product release, would not receive a radiation dose in excess of 0.25 Sv (25 rem)2 total effective dose equivalent (TEDE).

a) Please confirm whether the dose due to ECCS leakage is excluded from the FSAR Section 14.3.6.6 EAB dose calculation.

Attachment 1 NL-13-115 Docket No. 50-247 Page 2 of 10 b) If so, please explain how this is consistent with 10 CFR 50.67. SRP 15.0.1 and 10 CFR 50.67 both state that the worst dose for any 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months period is to be used to determine the EAB dose. This would typically mean the ECCS dose should be added to the time dependent EAB dose and the worst 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months dose should be determined from this time dependent dose profile. Please justify why the ECCS leakage is not considered in the determination of the EAB dose, or include the ECCS leakage in the EAB dose calculation.

Response to Question 1 a) Any ECCS leakage for the first 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months following a LOCA is internal to the containment and inherently accounted for in the offsite dose contribution for containment leakage. In order to identify the worst two hour period, the computer runs included time steps to provide EAB 2-hour doses at 0.2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months intervals. As shown below, the worst two-hour dose is 16.91 rem over the 0.6 to 2.6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months interval (this dose was increased by a factor of 1.05 for conservatism and rounded to 17.8 rem as reported in FSAR Section 14.3.6.8). The dose gets reduced to16.47 rem in the 0.8 to 2.8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period, and further reduced in the 1.0 to 3.0 hour0 days 0 hours 0 weeks 0 months period. After 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , when ECCS leakage begins outside of containment, the EAB dose rate from containment airborne leakage is so low that the added radiological contribution from the ECCS leakage pathway is not sufficient to change the maximum 2-hour dose from the peak value set earlier in the accident.

Exclusion Area Boundary Dose (rem TEDE) 0.24h 16.59 0.6- 2.hr 0.

16.91 0-2.hr10-30h 16.47 15.36 b) See response to a) above.

Question 2 UFSAR Section 14.3.6.6 states:

The releases would be subject to filtration by the filtered ventilation system provided for the primary auxiliary building which houses the portions of the ECCS located outside containment. However, filtration of the releases is not credited in the analysis.

a) Are releases from non-seismic piping (postulated to fail) subject to the filtered ventilation system in the primary auxiliary building?

Response to Question 2 a) Any break in non-seismic piping in the primary auxiliary building would be subject to the filtered ventilation system.

Attachment 1 NL-13-115 Docket No. 50-247 Page 3 of 10 Question 3 The Nuclear Regulatory Commission's safety evaluation, which reviewed the conversion to 10 CFR 50.67, reviewed an analysis which appears to have different assumptions than those provided in FSAR Section 14.3.6.6.

a) Has the NRC staff reviewed the analysis provided in FSAR Section 14.3.6.6 or were these changes made using 10 CFR 50.59, "Changes, tests and experiments"? If a staff evaluation of this analysis has not been performed, please provide the inputs, assumptions, methodology and results of the analysis that is to be used to support the proposed change.

b) FSAR Section 14.3.6.6 provides design basis dose values for two different assumptions (assuming a boundary layer effect and assuming no boundary layer effect). Which assumption is used for the licensing basis calculation?

Response to Question 3 a) FSAR Section 14.3.6.6 was revised using 10 CFR 50.59, "Changes, tests and experiments", to include potential ECCS back-leakage to the RWST. A copy of the calculation used to support the change is provided in Enclosure 1 as requested.

b) The licensing basis calculation is based on no boundary layer effect resulting in a Control Room Dose of 4.9 rem. This was reviewed and approved by the NRC in the Safety Evaluation for SPU (NRC Letter to Entergy, Indian Point Nuclear Generating Unit No. 2- Issuance of Amendment Re: 3.26 Percent Power Uprate (TAC NO. MC1865),

October 27, 2004).

Question 4 Page 3 of 8 of the submittal states:

The RWPP [Refueling Water Purification Pump] will take suction through manual isolation valve 855 on line ...

a) Please confirm whether this sentence should state valve 845 or whether valve 855 is correct.

Response to Question 4 a) The sentence on page 3 of 8 of the submittal contains a typographical error and should state:

The RWPP [Refueling Water Purification Pump] will take suction through manual isolation valve 845 on line ...

Attachment 1 NL-13-115 Docket No. 50-247 Page 4 of 10 Question 5 RG 1.183, Regulatory Position 5.1.2 states:

5.1.2 Credit for EngineeredSafeguard Features Credit may be taken for accident mitigation features that are classified as safety related,are requiredto be operableby technical specifications, are powered by emergency power sources, and are either automaticallyactuated or, in limited cases, have actuationrequirements explicitly addressed in emergency operating procedures. The single active component failure that results in the most limiting radiologicalconsequences should be assumed. Assumptions regardingthe occurrence and timing of a loss of offsite power should be selected with the objective of maximizing the postulated radiologicalconsequences.

a) Please describe how the valves credited to isolate the non-seismic pathways after a design basis accident meet the above regulatory position. For those valves that do not meet the regulatory position please explain the differences between the design features, analytical techniques and procedural methods proposed and the regulatory position and justify how the proposed alternatives to the regulatory position proved an acceptable method for complying with the NRC regulations (10 CFR 50.67).

Response to Question 5 a) As noted in the submittal, a dedicated operator would isolate suction from the RWST to BARS by closing valves 845 and 727A. This pair of valves is seismic 1 and in series and the single failure of one of the valves would be mitigated by the other valve. The dedicated operator would also isolate the return line from the BARS to the RWST by closing valve 350. Any leakage through valve 350 would be limited to leakage past MOV 842/843. This pair of valves is in series and tested with a leakage limit of 0.5 gph, which is accounted for in the radiological analysis.

Question 6 Page 4 of 8 of the submittal states:

Another potential for sump fluid leakage to impact BARS would be leakage through the 2 inch SI mini-flow line back to the RWST that is connected to valve 350.

However, this would be limited to leakage through MOV 842/843, which are tested by 2-PT-R048 and have an acceptance criterion of 0.5 gallons per hour (gph).

a) Are MOV 842/843 always closed when the potential for this leakage pathway exists? If not, explain the timing involved for closing MOV 842/843 and valve 350. Can the

Attachment 1 NL-13-115 Docket No. 50-247 Page 5 of 10 timing of the closure of these valves cause the 0.5 gph leakage limit to the non-seismic piping to be exceeded for any time period after the start of the postulated accident.

Response to Question 6 a) MOV 842/843 would always be closed when the potential for this leakage pathway exists. For hot leg recirculation, Procedure 2-ES-1.4, "Transfer to Hot Leg Recirculation", requires SI pump mini-flow valves MOV-842/843 to be closed. Similarly, for cold leg recirculation with the SI pumps taking suction from the recirculation pumps, 2-ES-1.3, "Transfer to Cold leg Recirculation", requires verifying MOV-842/843 are closed.

Question 7 Page 4 of 8 of the submittal states:

Following the injection phase of a large break LOCA (about 20 minutes) the preferred[emphasis added] means of cold leg recirculationis to use the internal recirculationpumps. This results in the fluid being kept inside containment until hot leg recirculation[at 6.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months s].

RG 1.183, Regulatory Position 5.1.3 states:

The numeric values that are chosen as inputs to the analyses requiredby 10 CFR 50.67 should be selected with the objective of determining a conservative postulated dose.

a) Confirm that plant procedures do not allow the recirculation of sump fluids outside containment prior to 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months .

b) If plant procedures do allow the recirculation of sump fluids outside of containment prior to 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months why aren't these methods of recirculation considered in the determination of the ECCS leakage dose calculation?

c) RG 1.183, Regulatory Position 1.3 defines the scope of required analyses which include post accident access shielding (NUREG-0737, "Clarification of TMI Action Plan Requirements," Action Item ll.B.2, "Post-Accident Access Shielding"). If plant procedures do allow the recirculation of sump fluids outside of containment prior to 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months please state whether vital area access (Action Item ll.B.2) necessary to close valves 845, 727A and 350 and trip the refueling water storage tank (RWST) purification pump is maintained.

Response to Question 7 a) Plant procedure 2-ES-1.3, "Transfer to Cold leg Recirculation", provides instructions for transferring the safety injection system and containment spray system to the recirculation mode. The Procedure requires manually starting one internal recirculation

Attachment 1 NL-13-115 Docket No. 50-247 Page 6 of 10 pump, and if it cannot be started then manually starting the other internal recirculation pump. If neither internal recirculation pump can be started then the procedure requires establishing cold leg recirculation using RHR pumps which results in sump fluid going outside containment. It should be noted that Emergency Operating Procedures address all potential contingencies to mitigate an accident.

b) The IP2 design is fairly unique in having two internal recirculation pumps as well as two RHR pumps. There is no single active failure that would require using RHR pumps.

Further, IP2 licensing basis does not postulate a passive failure to occur for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Consequently, recirculation of sump fluid outside containment would only occur at 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months for hot leg recirculation. RG 1.183 guidance does not impose postulating a passive failure and consequently ECCS leakage dose is not calculated prior to 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months .

c) Not Applicable - see response to b) above.

Attachment 1 NL-13-115 Docket No. 50-247 Page 7 of 10 Response To Request For Additional Information Component Performance, NDE, and Testing Branch

RAI 1

In the referenced letter it is indicated that valves 845, 727A and 350 will be part of the Inservice Test Program with a test frequency of two years. Will these valves be classified as manual, active valves and, therefore, be subject to ASME OM Code exercise testing requirements? Will these valves be further classified as Category A and, therefore, be subject to ASME OM Code leakage testing requirements? (The discussion of post-accident dose consequences indicates that these valves could be exposed to sump fluid.)

Response to RAI 1 Valves 845, 727A and 350 will be classified as manual active valves with open and close ASME OM Code exercise stroke requirements on a two year frequency. Valves 845 and 727A will be classified as Category A, therefore requiring leak testing every two years.

Valve 350 will not require leak testing. The potential for sump fluid leakage to impact BARS through valve 350 would be leakage through the 2 inch SI mini-flow line back to the RWST that is connected to valve 350. However, this would be limited to leakage through MOV 842/843, which are in series and tested by Procedure 2-PT-R048, "Leak Test of 842 and 843", and have an acceptance criterion of 0.5 gallons per hour, and accounted for in the radiological analysis.

Attachment 1 NL-13-115 Docket No. 50-247 Page 8 of 10 Response To Request For Additional Information Health Physics and Human Performance Branch Question 1

1.0 INTRODUCTION

By letter dated April 15, 2013 (ADAMS Accession Number ML13116A007), Entergy Nuclear Northeast (Entergy), licensee for Indian Point Nuclear Generating Unit 2 (IP2), submitted a license amendment request (LAR) to revise Technical Specification (TS) 3.5.4, "Refueling Water Storage Tank (RWST)". The proposed change would revise the TS to allow the non-seismically qualified piping of the temporary Boric Acid Recovery System (BARS) to be connected to, and isolated from, the RWST's seismically qualified piping by manual operation of RWST seismically qualified boundary valves. This would be done under administrative controls and only for limited periods of time. These limited periods are specified as up to 30 days per fuel cycle for filtration for removal of suspended solids from the RWST water. This change will only be applicable until Refueling Outage R22 (Spring 2016) ends. Manual connection of the RWST seismically qualified piping to non-seismically qualified piping shall not be allowed after the end of R22. The Health Physics and Human Performance Branch (AHPB) has done a preliminary review of the LAR regarding the operator performance aspects and finds that the following additional information is required to complete the review.

1. As described in Section 2 of the licensee's submittal, the change requested for TS 3.5.4 is a proposed Note, that states," The RWST isolation valves 350, 727A and 845 connected to non-safety related piping may be opened under administrative controls for up to 30 days per fuel cycle for filtration until the end of refuel outage 22." Later in Section 3, it is stated that, "Prior to refueling outage (RO) 2R20 the RWST was recirculated for a duration of 13 days. After recirculation the total concentration of silica was less than 1.1 ppm. Prior to RO 2R19 the RWST was recirculated for a duration of 11 days. A sample taken after recirculation had total concentration of silica of 1.3 ppm." Based on this statement the NRC staff assumes that clarity was sufficient after, at most, 13 days, and at a silica concentration of 1.3 ppm.

a. What concentration of silica/clarity is acceptable for operators to perform their required tasks during shutdown? Why isn't this criterion included in the proposed TS? How will operators know when it is okay to disengage the BARS?

b. If prior to the previous two refueling outages, it only took 11 days and 13 days to achieve acceptable clarity, why is the licensee requesting allowance for up to 30 days?

In order to minimize the time spent in a seismically vulnerable configuration, why wouldn't a duration of 15 days be sufficient?

Response to Question 1

a. The fuel vendor has specified guidelines for implementing zinc addition. For IP2, Chemistry Procedures specify a silica concentration of <;2 ppm to reduce zinc silicate precipitation on fuel surfaces. This is a fuel vendor guidance value, and not a limiting condition for operation. Exceeding this limit would result in fuel exams. Chemistry

Attachment 1 NL-13-115 Docket No. 50-247 Page 9 of 10 monitors silica and boron every six hours during the clean up, and is able to predict completion time a day or two ahead of reaching the target value.

b. The 11 days and 13 days in the prior two outages was BARS system operation time.

Time is also required for setup and removal of the BARS skid, which is typically one or two days each. Plus there is a period when the BARS unit is secured but still connected to allow the vendor some time off. The 30 days request provides margin in consideration of any delays or equipment issues that might arise with the vendor skid.

Since the BARS skid is rented, typically for 21 days, it is only used for the amount of time it is needed.

Question 2 Does IP2 have a Time-critical Action Program to protect high-risk, time-limited actions from inadvertent change? If yes, is the proposed task sequence included in that program? If no, what controls are used to prevent inadvertent changes to the proposed operator actions or the time available to perform them? Does the licensee's configuration control system have a way to identify Tech-Spec-related actions in procedures?

Response to Question 2 IPEC has a Time-critical Action Program, OAP-1 15,"Operations Commitments and Policy Details". Specific IP2 actions are listed in Attachment 4, however, the proposed task sequence is currently not included in that program. Licensing Request LR-LAR-2013-00113 CA#12 has been initiated to update OAP-1 15 prior to implementing BARS to include an action to isolate BARS in 31 minutes in the event of a seismic occurrence or an accident requiring injection from the RWST. Further, a CAUTION in 2-OSP-10.1.1, "Support Procedure - Safety Injection Accumulators and Refueling Water Storage Tank Operations", specifies the time available to the dedicated operator to isolate the RWST Silica Cleanup System in the event of a failure such that RWST level will be maintained above the Technical Specification limit. Revisions to Procedures require a Process Applicability Determination be performed which would evaluate the affect or potential affect of the change.

Question 3 In the general discussion of the ingress/egress paths taken by the operators to accomplish the isolation of seismic from non-seismic systems, the licensee states that a card reader is in the intended path.

a. Does this card reader require a different card than an operator would have for plant access? If yes, will the dedicated operator routinely keep this other card on his person?

If no, where will it be stored?

b. Did the simulation that was performed to ascertain required time vs. available time include accessing the card reader?

c. Is the card reader designed to work under seismic conditions? SBO? How much additional time would be involved if the operator had to deal with a non-operational card reader?

Attachment 1 NL-13-115 Docket No. 50-247 Page 10 of 10 Response to Question 3

a. No. The card reader uses the employee ID card (security badge), which is the same card as an operator would have for plant access. When at work, company policy requires all employees to wear their ID card on the outside clothing, between the neck and waist.

b. Yes. The simulation included accessing the card reader.

c. No. The security access card reader system is not seismic and will not work under SBO. Operators have keys in their possession to provide manual override in the event of a non-functional card reader and would result in minimal additional time to open the door. As noted in the submittal, a simulation performed by Operations demonstrated substantial margin in the time available to shutdown the BARS and maintain RWST level within the TS value.

Question 4 What method(s) will be used to monitor the continuing effectiveness and safety of the current method of purification of reactor water until the final resolution is implemented in 2016? Will the Corrective Action Program be used to track the status and effectiveness of current process?

Response to Question 4 The continuing effectiveness and safety of the current method of purification of reactor water is monitored by the work control and temporary alteration processes. The Corrective Action Program is used to document and resolve issues that may arise during the campaign.

ENCLOSURE 1 TO NL-13-115 INDIAN POINT CALCULATION IP-CALC-1 1-00091 AST ANALYSIS OF IP2 TO ADDRESS THE IMPACT OF CONTAINMENT SUMP SOLUTION BACK-LEAKAGE TO THE RWST AFTER LOCA ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

CALCULATION CONTINUATION SHEET SHEET NO.I of 33

-Et CALC. TITLE: AST Analysis of IP2 to Address the MEntergy, to the of Impact RWSTContainment after LOCA Sump Solution Back-Leakage

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 1 0 ATTAC1UaENT 9. 2 ENGINEERING CALCULATION COVER PAGE Sheet 1 of 1 E] ANO-1 El ANO-2 El GGNS U IP-2 fl IP-3 CJAF C] PNPS E] RBS El y E] W3 CALCULATION No: EC # 32007 Page I1 Of 33n:

COVER PAGE (3) Design Basis Calc. N YES []NO () *CALCULATION []EC Markup IP-CALC-11-00091Reion 0 17 ) alculation No:

(7)

Title:

AST Analysis of IP2 to Address the Impact of '"' Editorial Containment Sump Solution Back-Leakage to the RWST after LOCA El YES

NO (9) System(s): RWST (10) Review Org (Department): FNA (11) Safety Class: (12) Component/Equipment/Structure Type/Number:

U Safety / Quality Related El Augmented Quality Program El Non-Safety Related (13) Document Type:

CALCULATION

14) Keywords (Description/Topical Codes): RADTRAD 3.03 REVIEWS (15) Name/Signature/Date (16) Name/Signature/Date (17) Name/Signature/Date M. Gols i/ Jm E!.,Chang / ! A. Irani ( .

Responit-ý Engineer []

Design Verifier Supervisor/Approval El Reviewer Comments Attached El Comments Attached

CALCULATION CONTINUATION SHEET SHEET No.2 of 33 CALC. TITLE: AST Analysis of IP2 to Address the ME Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 1 0 ATTACHMENT 9.3 CALCULATION REFERENCE SHEET Sheet 1 of 1 CALCULATION REFERENCE CALCULATION NO: IP-CALC-11-00091 SHEET REVISION: 0 I. EC Markups Incorporated

1. None.

II. Sht Rev Input Output Impact Tracking Relationships: Doc Doc Y/N No.

CN-CRA-03-55 - 0 U 0 N N/A PU2-E-03-20 - - U 0 N N/A CN-CRA-11-25 - 0 U 0 N N/A PU2-E-03-20 - - U 0 N N/A CN-REA-03-4 - - U 0 N N/A IP-RPT-I1-00025 - 0 U 0 N N/A NEA-00023 - 0 U 0 N N/A IP-CALC-11-00063 - 0 0 E N N/A III. CROSS

REFERENCES:

1. RG 1.183

2. NUREG/CR-5950

3. MURE.G/CR-6604 IV. SOFTWARE USED: Yes, See Method of Analysis

Title:

RADTRAD Version/Release: 3.03 Disk/CD No.

V. DISK/CDS INCLUDED: None

Title:

Version/Release Disk/CD No.

VI. OTHER CHANGES: None

CALCULATION CONTINUATION SHEET SHEET No.3 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 1 0 ATTACHMENT 9.4 RECORD OF REVISION Sheet 1 of 1 Revision Record, of Revision.

Initial issue.

CALCULATION CONTINUATION SHEET SHEET No.4 of 33 CALC. TITLE: AST Analysis of IP2 to Address the AA Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 jREVISION NO. I 0 TABLE OF CONTENTS Section Sheet No.

Calculation Cover Page ............................. 1 Calculation Reference Sheet .......................... 2 Record of Revision ................................. 3 Table of Contents .................................. 4

1. Purpose and Background ......................... 5

2. Summary of Results & Conclusion ................ 6

3. Design Inputs .................................. 9

4. Acceptance Criteria ........................... 10

5. Method of Analysis ............................ 11

6. Calculation/Analysis ........................... 12 6.1 Fission Product Inventory .................. 12 6.2 Iodine Partition Factor in the RWST ........ 17 6.3 Determination of Elemental Iodine Fractions based on RWST pH ........................... 23 7 . Results ...................................... 32

8. References 33 Attachment A 3 Pages Attachment B 1 Page Attachment C 10 Pages

CALCULATION CONTINUATION SHEET jSHEET No.5 of 33 a n CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 IREVISION NO. 0 1.0 Purpose and Background The radiological dose consequences of a large break Loss-Of-Coolant Accident (LOCA) provided by Westinghouse in Reference 1 for Indian Point Unit 2 (IP2) did not include the dose contribution resulting from the postulated back-leakage of containment sump water to the Refueling Water Storage Tank (RWST). The dose from this back-leakage was considered to be negligible.

This calculation is being performed to quantify the allowable sump back-leakage to the RWST and evaluate the doses at IP2 Control Room (CR) and offsite in the event of a design basis LOCA.

Two allowable back-leakage flow rates were considered:

1) An allowable back-leakage which does not result in an increase in the dose specified in the FSAR (Sec. 14.3.6.8). This is able to be accomplished by using up the additional conservatism that was included in the FSAR values.

2) An allowable back-leakage which does not result in an increase in the dose acceptance limit of 10 CFR50.67 (e.g., 5 rem CR TEDE)

The analysis is performed based on the Alternative Source Term (AST) methodology described in Reg. Guide 1.183 (Ref. 2) and using the RADTRAD 3.03 computer code (Ref. 3).

CALCULATION CONTINUATION SHEET ISHEET No.6 of 33

-E~t* CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA ICALC. NO.: IP-CALC-11-00091 IREVISION NO. 0 2.0 Summary of Results & Conclusion The IP2 doses resulting from the back-leakage to the RWST in the IP2 Control Room (CR), Exclusion Area Boundary (EAB) and Low Population Zone (LPZ) were calculated in the event of a design basis LOCA. The CR doses were calculated for allowable back-leakage to remain below the CR dose reported in the FSAR and to calculate allowable back-leakage value for less than the 10CFR50.67 limit of 5 rem CR TEDE.

Tables 2.1 and 2.2 show the summary of results. The results of analysis in Table 2.1 indicate that the EAB, LPZ and CR doses are less than reported in the FSAR for the back-leakage flow rate of 20 gph. The results of the analysis in Table 2.2 for 29 gph flow rate are also indicated that doses are below the 10 CFR 50.67 limit of 5 rem CR TEDE.

CALCULATION CONTINUATION SHEET SHEET No.7 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Table 2.1 IP2 LOCA TEDE Doses (rem) [20 gph Back-Leakage]

C a s e CR EAB LPZ Back-Leakage 0.1701 --- 0.09263 To RWST Calculated Containment

& ECCS leakage (Ref. 1)

4.7263 16.91 12.93 Total 4.896 16.91 13.02 Reported Dose 4.9 17.8 13.6 (Refs. 1 & FSAR)

TEDE Limit 5.0 25.0 25.0

An additional external dose to the CR is also included.

CALCULATION CONTINUATION SHEET SHEET No.8 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 IREVISION NO. 0 Table 2.2 XP2 LOCA TEDE Doses (rem) [29 gph Back-Leakage]

C a s e CR MAB LPZ Back-Leakage 0.2655 0.1481 To RWST Calculated Containment

& ECCS leakage (Ref. 1 )* 4.7263 16.91 12.93 Total 4.99 16.91 13.08 TEDE Limit 5.0 25.0 25.0

An additional external dose to the CR is also included.

CALCULATION CONTINUATION SHEET SHEET No.9 of 33 CALC. TITLE: AST Analysis of IP2 to Address the ao

ý-Entery Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-I1-00091 REVISION NO. 0

3. Design Inputs Design Input Data Parameter Value Plant Power 3,280.3* MWt Core Inventories Table 6.1 Release Fraction & Timing Table 6.2 (R.G. 1.189)

Chemical Form Release to Sec. 6.1 (R.G. 1.189)

Containment See Attachment C for all other design input data.

Core power of 3216 MWt with a reactor power uncertainty of 2%

CALCULATION CONTINUATION SHEET SHEET No.10 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 REVISION NO. 0

4. Acceptance Criteria The radiological criteria for the CR, EAB and LPZ are in 10 CFR 50.67 and Reg. Guide 1.183.

CR Dose Acceptance Criterion: 5.0 rem TEDE EAB Dose Acceptance Criterion: 25.0 rem TEDE LPZ Dose Acceptance Criterion: 25.0 rem TEDE

CALCULATION CONTINUATION SHEET SHEET No.11 of 33 CALC. TITLE: AST Analysis of IP2 to Address the go Impact of Containment Sump Solution Back-Leakage

z-Enter y to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0

5. Method of Analysis Post-accident LOCA radiation exposures from the postulated back-leakage of containment sump water to the RWST in the IP2 CR, EAB and LPZ were computed using the following:

(a) The methodology and assumptions in Regulatory Guide 1.183 (Ref. 2),

(b) Appropriate source terms, release pathways, and other assumptions, as described in the section which follows, (c) Post-accident atmospheric dispersion factors, and (d) The following Computer Code:

RADTRAD 3.03 (Ref. 3) The NRC sponsored code RADTRAD, Version 3.03 was used to model the DB LOCA and estimate the dose consequences. The CR, EAB and LPZ doses in terms of TEDE were calculated for the LOCA.

Section 6 and Attachment C present details of the assumptions, data and results associated with the accident analyzed.

CALCULATION CONTINUATION SHEET ISHEET No.12 of 33

E~t* CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage

-Entergy to the RWST after LOCA JCALC. NO.: IP-CALC-11-00091 REVISION NO, _F 01

6. Calculation/Analysis Release pathways and contributing radiation sources, which should be analyzed in the design-basis LOCA, are the followings:

(1) Containment leakage, (2) ECCS recirculation leakage, (3) External dose cloud, and (4) Back-leakage of sump water to the RWST.

Doses resulting from activity released through the first three pathways were calculated in Reference 1. The last release pathway was not addressed in previous dose analyses for IP2 (Reference 1).

Therefore, this calculation is being performed to evaluate the doses at IP2 Control Room (CR) and offsite from the back-leakage to the RWST in the event of a design basis LOCA.

The source term and basic assumptions for evaluating the TEDE dose associated with a postulated back-leakage to the RWST during the design-basis LOCA were selected to be consistent with Regulatory Guide 1.183 (Ref. 2).

6.1 Fission Product Inventory The fission product inventory in the core is based on full power operation (3216 MWt + 2% uncertainty, i.e., 3280.3 MWt).

The core inventory of radionuclides of interest is shown in Table 6.1 from Ref. 5. The reactor core inventory release fractions, for each radionuclide group and for the gap release and early in-vessel

CALCULATION CONTINUATION SHEET SHEET No.13 of 33 CALC. TITLE: AST Analysis of IP2 to Address the as Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. I 0 damage phases for the DBA LOCA are shown in Table 6.2 (Ref. 2). The chemical form of the radionuclide released to the containment should be assumed to be 95% cesium iodine, 4.85% elemental iodine and 0.15% organic iodine (Reg. Guide 1.183). Since the 0.15% of the iodine released from the core is assumed to be in the organic form and thus is not subject to removal by sprays or deposition and would remain the containment air space. Therefore, the corrected fraction of 0.05 and 0.35 for halogens from Table 2 of Reg. Guide 1.183 should be adjusted to 0.05 x (1-0.0015) = 0.049925 and 0.35 x (1-0.0015) = 0.349475 in RADTRAD input file. The iodine release fraction is also specified as 97% elemental and 3% organic from Reg. Guide 1.183 when iodine is released from liquid. The release fractions for all other nuclide groups are set at zero since they are not subject to release by the containment sump back-leakage pathway to the RWST.

CALCULATION CONTINUATION SHEET SHEET No.14 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Table 6.1 Core Inventories of Nuclides for use in Radiological Design-Basis Applications Nuclide Activity Nuclide Activity Halogens (Ci) Alkali (Ci/Mut)

I 130 3.80E+06 Cs134 2.06E+07 I 131 9.16E+07 Cs136 6.01E+06 I 132 1. 33E+08 Cs 137 1. 19E+07 I 133 1.88E+08 Cs138 1. 71E+08 I 134 2.06E+08 Rb86 2.38E+05 I 135 1. 75E+08 Tellurium Te 127 9.84E+06 Te 127m 1.29E+06 Te 129 2. 92E+07 Te 129m 4.30E+06 Te 131m 1. 33E+07 Noble Gases Te 132 1. 31E+08 Sb 127 9.95E+06 Kr 83m 2. 93E+03 Sb 129 2. 97E+07 Kr 85m 2.43E+07 Kr 85 1. 10E+06 Ba, Sr Kr 87 4.66E+07 Kr 88 6.56E+07 Ba 139 1.67E+08 Ba 140 1.61E+08 Xe 131m 1. 01E+06 Sr 89 8.83E+07 Xe 133m 5. 87E+06 Sr 90 8.75E+06 Xe 133 1. 80E+08 Sr 91 1.11E+08 Xe 135m 3. 68E+07 Sr 92 1.20E+08 Xe 135 4. 77E+07 Xe 138 1. 55E+08

CALCULATION CONTINUATION SHEET SHEET No.15 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-1I-00091 jREVISION NO. I 0 Table 6.1 (continued)

Core Inventories of Nuclides for use in Radiological Design-Basis Applications Nuclide Activity Nuclide Activity Noble Metals (Ci/MWt) Cerium (Ci/MWt)

Ru 103 1.40E+08 Ce 141 1. 52E+08 Ru 105 9. 62E+'07 Ce 143 1. 42E+08 Ru 106 4.89E+07 Ce 144 1.20E+08 Rh 105 8.86E+07 Pu 238 4. 13E+05 Mo 99 1.75E+08 Pu 239 3. 50E+04 Tc 99m 1.53E+08 Pu 240 5. 23E+04 Pu 241 1. 18E+07 Np 239 1. 88E+09 Lanthanides La 140 1. 73E+08 La 141 1.53E+08 La 142 1. 48E+08 Zr 95 1.54E+08 Zr 97 1.55E+08 Nd 147 6. 11E+07 Nb 95 1.56E+08 Y 90 9. 11E+06 Y 91 1. 14E+08 Y 92 1 20E+08 Y 93 1. 39E+08 Cm 242 3. 52E+06 Cm 244 3.82E+05 Pr 143 1 37E+08 Am 241 1.41E+04

CALCULATION CONTINUATION SHEET SHEET No.16 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage Eer to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Table 6.2 Core Inventory Fraction Released into Containment Release (Table 2 of Regulatory Guide 1.183) 2 Group Gap Release1 Early In-Vessel Total Noble Gases 0.05 0.95 1.0 Halogens 0.05 0.35 0.4 Alkali Metals 0.05 0.25 0.3 Tellurium Metals 0.00 0.05 0.05 Ba, Sr 0.00 0.02 0.02 Noble Metals 0.00 0.0025 0. 0025 Cerium Group 0.00 0.0005 0.0005 Lanthanides 0.00 0.0002 0.0002 Note: (Ref. 1) 1. Gap release in 30 seconds and 0.5 hr duration

2. Early In-Vessel release in 0.5 hr and 1.3 hr d uration

CALCULATION CONTINUATION SHEET SHEET No.17 of 33 a n CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-II-00091 REVISION NO.I 0 6.2 Iodine Partition Factor in the RWST Two flow rates (20 and 29 gal/hr) to the RWST were selected: one for an allowable back-leakage which does not result in an increase in the dose specified in the FSAR (Table 12.1) and the second one, an allowable back-leakage which does not result in an increase in the dose acceptance limit of 10 CFR50.67 (5 rem CR TEDE). (In order to find these two flow rates a few flow rates were assumed and run RADTRAD.)

The potential leak path of the sump solution to the RWST is from the Emergency Core Cooling System (ECCS) pump(s) to the RWST water by the way of the piping volume. This is modeled by the transfer of a portion of the flow going to the RWST air and a portion to the RWST water in order to meet the iodine partition factor.

The following Equation from Section 3.3.1 of NUREG/CR-5950 (Ref. 6) was used for equilibrium partition coefficient:

Log 1 o PC(1 2 ) = 6.29 - 0.0149T (Where T = temperature in K)

Using the maximum RWST solution temperature of 114'F (318.71 K) during a 30 day accident period from the input data, the equilibrium partition coefficient was calculated to be 34.77. This factor is defined in terms of concentration, not in terms of activity. Because of the RWST volumes of 13,900 gallons in the liquid space and 38,6000 gallons in the air space, there is a factor of 386000/13900 = 27.77 adjustment that needs taken into account to convert the partition coefficient to a volume basis:

CALCULATION CONTINUATION SHEET SHEET No.18 of 33 CALC. TITLE: AST Analysis of IP2 to Address the go Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA 1 CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 34.77/27.77 = 1.25.

Therefore, if x = gpm to the RWST liquid space and y = gpm to the RWST air space, then x + y = 0.33333 For 20 gph or 0.16667 gpm x / y = 1.25 x + y = 0.48334 For 29 gph or 0.33333 gpm x / y = 1.25 Where y and x are calculated to be:

Y= 0.14815 gpm and x = 0.18518 gpm for flow rate of 20 gph Y= 0.21482 gpm and x = 0.26852 gpm for flow rate of 29 gph However, the volume of liquid and air will be changing with time (starting at 6.5 hrs 20 or 29 gallons per hour will be added to the RWST water volume and subtracted from the air volume). As a result, the partition factor will also change with time. Tables 6.3 and 6.4 below from the spread sheet show the results for 20 and 29 gph.

CALCULATION CONTINUATION SHEET SHEET No.19 of 33 aEn -Eteg CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Table 6.3 Flow to the RWST (20 gph)

Flow Eq. Par.

rate 20 Coef 34.77 RWST Ratio of Flow to Flow to Flow to Flow to Time air air water RWST AIR water Partition air water Volume volume (hr) (gal) (gal) to water Factor (gal/min) (gal/min) (cfm) (cfm) 6.5 386000 13900 27.7698 1.25 0.14801 0.18532 0.01979 0.02478 75 384630 15270 25.1886 1.38 0.14003 0.19330 0.01872 0.02584 100 384130 15770 24.3583 1.43 0.13732 0.19601 0.01836 0.02621 150 383130 16770 22.8462 1.52 0.13217 0.20116 0.01767 0.02689 200 382130 17770 21.5042 1.62 0.12738 0.20596 0.01703 0.02754 300 380130 19770 19.2276 1.81 0.11869 0.21464 0.01587 0.02870 400 378130 21770 17.3693 2.00 0.11104 0.22229 0.01485 0.02972 500 376130 23770 15.8237 2.20 0.10425 0.22908 0.01394 0.03063 600 374130 25770 14.5180 2.39 0.09819 0.23515 0.01313 0.03144 720 371730 28170 13.1960 2.63 0.09170 0.24163 0.01226 0.03231 Table 6.4 Flow to the RWST (29 gph)

Flow 29 Eq. Par. 34.77 rate Coef RWST Ratio of Flow to Flow to Flow to Flow to Time RWST AIR water air Partition air water air water Volume volume (hr) (gal) (gal) to water Factor (gal/min) (gal/min) (cfm) (cfm) 6.5 386000 13900 27.7698 1.25 0.21462 0.26872 0.02869 0.03593 60 384448.5 15451.5 24.8810 1.40 0.20160 0.28173 0.02695 0.03767 75 384448.5 15886.5 24.1997 1.44 0.19835 0.28499 0.02652 0.03810 100 383288.5 16611.5 23.0737 1.51 0.19280 0.29053 0.02578 0.03884 150 381838.5 18061.5 21.1410 1.64 0.18276 0.30058 0.02443 0.04019 200 380388.5 19511.5 19.4956 1.78 0.17364 0.30969 0.02322 0.04141 300 377488.5 22411.5 16.8435 2.06 0.15773 0.32560 0.02109 0.04353 400 374588.5 25311.5 14.7991 2.35 0.14430 0.33903 0.01929 0.04533 500 371688.5 28211.5 13.1751 2.64 0.13282 0.35052 0.01776 0.04686 600 368788.5 31111.5 11.8538 2.93 0.12288 0.36045 0.01643 0.04819 720 365308.5 34591.5 10.5606 3.29 0.11260 0.37073 0.01505 0.04957

CALCULATION CONTINUATION SHEET SHEET No.20 of 33 CALC. TITLE: AST Analysis of IP2 to Address the go Impact of Containment Sump Solution Back-Leakage

~Enter to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 There is no transport of activity into the RWST was assumed to occur until 81.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months for 20 gph and 66.5 for 29 gph after accident due to delay of 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months to initiate back-leakage and 75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months or 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months delay imposed by the piping volume from input data [1750 gal (see page 2 of input data)/20 = 87.5 ; 75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months and 1750/29 = 60.3 - 60]. For the 81.5 hrs time step, the flows determined at 75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months and for the 66.5 hrs time step, the flows determined at 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months can be used since the impact of the additional 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months are not significant.

A transfer from the RWST liquid space to the RWST air space should be used, in order to maintain the partition factors that are calculated above due to the release of activity from the RWST air to the environment. For 20 gph flow rate, the flowing transfers from the RWST water to the RWST air as a function of time were selected:

Time(hr) Flow(gal/min) 8.15E+01 0.09 3.50E+02 0.2 5.OOE+02 0.15 6.50E+02 0.30 These leakages must be shown to be close agreement with the values calculated in the Table 6.3 by running RADTRAD. See Table below from RADTRAD output of IP2RWST20.O0

CALCULATION CONTINUATION SHEET SHEET No.21 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump'Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Time RWST gas space RWST liquid Effective Partition fac.

(hr) 1-131 inventory 1-131 inventory Partition factor From Table 6.4 (Ci) (Ci) (col.3/col.2) 100 2.2269E+02 3.1674E+02 1.42 1.43 300 8.4169E+02 1.5220E+03 1.81 1.81 400 7.7482E+02 1.5584E+03 2.01 2.00 500 6.6138E+02 1.4110E+03 2.13 2.20 600 4.7272E+02 1.1368E+03 2.40 2.39 720 2.8779E+02 7.5745E+02 2.63 2.63 For 29 gph flow rate, the flowing transfers from the RWST water to the RWST air as a function of time were selected:

Time (hr) Flow (gal/min)

8. 15E+01 0.09

3. 50E+02 0.15 These leakages must be shown to be close agreement with the values calculated in the Table 6.4 by running RADTRAD. See Table below from RADTRAD output of IP2RWST29.O0

CALCULATION CONTINUATION SHEET SHEET No.22 of 33 CALC. TITLE: AST Analysis of IP2 to Address the is Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-I1-00091 REVISION NO. 1 0 Time RWST gas space RWST liquid Effective Partition fac.

(hr) 1-131 inventory 1-131 inventory Partition factor From Table 6.4 (Ci) (Ci) (col.3/col.2) 75 2.4210E+02 3.4459E+02 1.42 1.44 100 5.7103E+02 8.5178E+02 1.49 1.51 300 1.3154E+03 2.5391E+03 1.93 1.81 400 1.1355E+03 2.5524E+03 2.25 2.06 500 9.1766E+02 2.3094E+03 2.52 2.64 600 6.4718E+02 1.8015E+03 2.78 2.93 720 3.6115E+02 1.2190E+03 3.37 3.29 The minimum and maximum Tech Spec temperature range for the RWST is 40'F to 110'F (see the input data), but the tank would not have the potential of seeing this kind of temperature swing on a daily basis. A maximum temperature swing of 40'F is used, which is equivalent to having the tank reach 110'F in the day and then drop to 70°F during the night (using high end of the temperature range (i.e., 70°F to 110°F).

The flow rate would be calculated from the following Equation.

PjVj/Tj = P 2V2 /T 2 3 and T, and T2 Where, P1 = P2, vi is 386000 gal x 0.1337 = 51600 ft are 529.67°R and 569.67°R.

Therefore, the volume change can be determined to be:

CALCULATION CONTINUATION SHEET ISHEET No.23 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 REVISION NO. I 0 3

V2 -V1 =3897 ft If the low end of the temperature range is used (i.e., 40'F to 80 0 F), the volume change can be determined to be:

0 3 (51600 ft 3) (539.67 0 R)/(499.67 R) -51600 = 4131 ft The average flow rate over a full day (higher number is conservative) would be 4131/60x24 = 2.869 cfm. Therefore, 2.9 cfm was used in RADTRAD.

6.3 Determination of Elemental Iodine Fractions based on RWST pH Both plants IP2 and IP3 have the same rated thermal power and the source inventory of the core is almost the same. Therefore the amount of iodine source in the core for both plants IP2 and IP3 should be almost the same. Therefore, the iodine inventory in the core of 26121g from Reference 7 was used in this calculation. The mass of iodine in the sump water would be 26121 g x 0.40 (40% of iodine released from the core, Reg. Guide 1.183) = 10,448 g Iodine concentration in the sump water = 10,448/374000 gal = 2.79E-2 g/gal = 7.37E-3 g/L.

The minimum sodium tetraborate decahydrate (Na 2 B4O7 -10H 2 0) is 8096 lb (TS 3.6.7.1b). Sodium tetraborate in solution reverts to a combination of boric acid and sodium hydroxide (NaOH). The equivalent mass of NaOH is found by taking in the fraction of the

CALCULATION CONTINUATION SHEET SHEET No.24 of 33 a EnteW CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 1 0 mass that would exist as NaOH. The molecular weight of NaOH is 39.998 and the molecular weight for sodium tetraborate decahydrate (Na 2 B4 O7 -10H 20) is 381.38. Thus, the effective mass of NaOH is:

(8096 lb)x(39.998)/(381.38) = 849.1 lb = 3.85E+05 grams Taking the mass of NaOH and dividing by the sump volume gives the concentration of NaOH in the sump:

3.85E05 g NaOH /374000 GAL =1.0294 g NaOH/gal (1.0294 g/gal)/(3.7854 1/gal) = 0.2719 g/l The Tech Spec limit for the boron concentration in the RWST and the accumulators is 2600 ppm (TS 3.5.4.3). Thus, it is conservative to assume that the containment sump solution would also have a boron concentration of 2600 ppm.

Using the data from Reference 7 for 2500 ppm boron and 3000ppm boron, the initial RWST pH is between 4.57 and 4.62 (Reference 7).

Two RADTRAD cases were run for each flow rate (20 and 29 gph). One for iodine concentration and the other for NaOH concentration (The only changes made to the source term input .nifl and .rft 2 ) . Tables below show the iodine concentration (see RADTRAD output conc-iodineip220.oO for 20 gph and conc-iodineip229.o0 for 29 gph) and 1 The .nif files (conc-iodineip2.nif for iodine concentration and conc-naohip2.nif for NaOH concentration) are revised to set the inventory iodine or the mass NaOH.

2 The .rft files (loca-i.rft for iodine concentration and con-naohip2.rft for NaOH concentration) are revised to set the 40% inventory for iodine and all of the NaOH needs to be modeled as going to the sump.

CALCULATION CONTINUATION SHEET SHEET No.25 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 IREVISION NO. 0 the NaOH concentration in the RWST water (see RADTRAD output conc-naohip220.oO for 20 gph and conc-naohip229.oO for 29 gph).

CALCULATION CONTINUATION SHEET SHEET No.26 of 33

,auk CALC. TITLE: AST Analysis of IP2 to Address the MR Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA I CALC. NO.: IP-CALC-I1-00091 REVISION NO. I 0 Table 6.5 Iodine Concentration in RWST 20 gph Flow Rate Iodine Concentration Iodine Iodine

Water (g/L)** Concentration (gram) (gal) (g-atoms/L)÷ 350 1.3878E+02 20770 1.765E-03 1.37E-05 400 1.6602E+02 21770 2.015E-03 1.56E-05 450 1.9329E+02 22770 2.243E-03 1.74E-05 500 2.2054E+02 23770 2.451 E-03 1.90E-05 550 2.4776E+02 24770 2.642E-03 2.05E-05 600 2.7493E+02 25770 2.818E-03 2.18E-05 650 3.0204E+02 26770 2.981 E-03 2.31 E-05 720 3.3988E+02 28170 3.187E-03 2.47E-05 29 gph Flow Rate Iodine Iodine Time Iodine + Water Concentration Concentration (hr) (gram) (gal) (g/L)** (g-atoms/L)÷ 350 2.1945E+02 23861.5 2.430E-03 1.88E-05 400 2.6082E+02 25311.5 2.722E-03 2.11E-05 450 3.0104E+02 26761.5 2.972E-03 2.30E-05 500 3.4064E+02 28211.5 3.190E-03 2.47E-05 550 3.7988E+02 29661.5 3.383E-03 2.62E-05 600 4.1886E+02 31111.5 3.557E-03 2.76E-05 650 4.5765E+02 32561.5 3.713E-03 2.88E-05 720 5.1167E+02 34591.5 3.908E-03 3.03E-05

From RADTRAD computer output: con-iodineip220.oO

- (col.2/col.3)/(3.7854 1/gal)

+ The concentration is converted to gram-atoms of 1-129 (more than 75% of iodine inventory is from 1-129) by dividing the concentration (col. 4) by 129 (1-129)

++ From RADTRAD computer output: con-Idineip229.oO

CALCULATION CONTINUATION SHEET SHEET No.27 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 0 Table 6.6 NaOH Concentration in RWST 20 gph Flow Rate Time (hr) NaOH water (gal) NaOH (gram) Concentration (g/L) 350 5.1214E+03 20770 6.514E-02 400 6.1266E+03 21770 7.435E-02 450 7.1328E+03 22770 8.276E-02 500 8.1387E+03 23770 9.045E-02 550 9.1432E+03 24770 9.752E-02 600 1.0146E+04 25770 1.040E-01 650 1.1 146E+04 26770 1.100E-01 720 1.2543E+04 28170 1.176E-01 29 gph Flow Rate Time (hr) NaOH+ Water(gal) NaOH (gram) Concentration (g/L)**

350 8.0983E+03 23861.5 8.966E-02 400 9.6250E+03 25311.5 1.005E-01 450 1.1109E+04 26761.5 1.097E-01 500 1.2571E+04 28211.5 1.177E-01 550 1.4019E+04 29661.5 1.249E-01 600 1.5457E+04 31111.5 1.313E-01 650 1.6889E+04 32561.5 1.370E-01 720 1.8882E+04 34591.5 1.442E-01

From RADTRAD computer output: con-naohip220.oO

- (col.2/col.3)/(3.7854 1/gal)

+ From RADTRAD computer output: con-naohip229.oO

CALCULATION CONTINUATION SHEET SHEET No.28 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA CALC. NO.: IP-CALC-11-00091 REVISION NO. I 0 For determining the pH at low NaOH concentration, Reference 7 used the titration curves for trisodium phosphate (TSP) instead. NaOH is a stronger caustic than TSP and the TSP curves thus provides conservatively low estimates of the pH for the NaOH solution. A pH of 7.75 shown for 1.0 g/L of NaOH in 2500 ppm boron solution in Reference 7 vs. of a pH of 7.2 for 1.0 g/L of TSP at the same boron concentration from Reference 8.

A table below from Table 3 of Reference 8 shows the TSP concentration as function of pH base on 3000 ppm boron solution (Table 3 is attached to Ref. 7).

TSP Conc. (g/L) Solution pH 0 4.57 0.025846852 5.62 0.038731624 5.73 0.051590729 5.83 0.064424244 5.91 0.077232245 5.98 0.082348318 6.00 0.092568274 6.05 0.102772008 6.10 0.115503922 6.16 0.128210624 6.19 0.253907314 6.47

CALCULATION CONTINUATION SHEET SHEET No.29 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 REVISION NO. 1 0 Therefore the pH at a given RWST NaOH concentration is found by linear interpolating between the above values, as appropriate.

Tables below show the RWST water pH as a function of time.

CALCULATION CONTINUATION SHEET ISHEET No.30 of 33 CALC. TITLE: AST Analysis of !P2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 IREVISION NO. I 0 Table 6.7 RWST Water pH vs. Time 20 gph Flow Rate Time RWST Water pH RWST Water (hr) NaOH Conc. Interpolation pH (g/L) Range 350 6.514E-02 5.91 - 5.98 5.92 400 7.4359E-02 5.91 - 5.98 5.96 450 8.276E-02 6.00 - 6.05 6.01 500 9.045E-02 6.00 - 6.05 6.04 550 9.752E-02 6.05 - 6.10 6.08 600 1.040E-01 6.10 - 6.16 6.11 650 1.100E-01 6.10 - 6.16 6.14 720 1.176E-01 6.16 - 6.19 6.17 29 gph Flow Rate Time RWST Water pH RWST Water (hr) NaOH Conc. Interpolation pH (g/L) Range 350 8.966E-02 6.00 - 6.05 6.03 400 1.005E-01 5.10 - 6.05 6.10 450 1.097E-01 6.10 - 6.16 6.15 500 1.177E-01 6.16 - 6.19 6.17 550 1.249E-01 6.16 - 6.19 6.18 600 1.313E-01 6.19 - 6.47 6.21 650 1.370E-01 6.19 - 6.47 6.23 720 1.442E-01 6.19 - 6.47 6.25

CALCULATION CONTINUATION SHEET SHEET No.31 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 IREVISION NO. 1 0 Figure 3.1 of Reference 6 (NUREG/CR-5950) was used to determine the amount of iodine converting to the elemental form based on solution pH and iodine concentration. At a pH of 5.2 and a concentration of 10-5, the fraction of iodine (12) as elemental iodine is about 0.02.

As shown in above Table, the RWST pH increases to approximately 6.04 at 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months at which point the iodine concentration is 1.9E-5 g-atom/L for 20 gph flow rate. For 29 gph flow rate, the RWST pH increases to approximately 6.19 at 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months at which point the iodine concentration is 2.5E-5 g-atom/L. Until the pH reaches 1 6, the fraction of the iodine converting to the elemental form will be assumed to be based on a pH of 5.2 (a conservative assumption).

From Figure 3.1 of NUREG/CR-5950 (Reference 6) and considering the iodine concentration above, this fraction is conservatively selected to be 2% for both flow rates.

After 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months , the RWST liquid pH will exceed 5.8 and the indicated conversion to elemental iodine is essentially zero for the iodine concentrations calculated above. The fraction converting to elemental form after 500 hours0.00579 days 0.139 hours 8.267196e-4 weeks 1.9025e-4 months is conservatively assumed to be 0.5% for both flow rates.

CALCULATION CONTINUATION SHEET SHEET No.32 of 33 CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 IREVISION NO. 1 0

7. Results The offsite and CR doses were evaluated due to dose contribution resulting from postulated back-leakage of containment sump water to the Refueling Water Storage Tank (RWST). Combining the doses resulting from the activity that calculated in Reference 1 from the containment leakage and the ECCS leakage give total offsite and CR doses. The doses were calculated; 1) An allowable back-leakage which does not result in an increase in the dose specified in the FSAR (Table 12.1). 2) An allowable back-leakage which does not result in an increase in the dose acceptance limit of 10 CFR50.67 (5 rem CR TEDE).

There is no EAB dose indicated for the back-leakage to the RWST because back-leakage would not occur until after the identified worst 2-hour interval.

Tables 2.1 and 2.2 present the TEDE in the CR, EAB and LPZ. Refer to Sec. 2 for a summary of the exposures.

It should be noted that the TSC dose was also calculated for information only and the results are in Attachment B.

CALCULATION CONTINUATION SHEET SHEET No.33 of 33 a e CALC. TITLE: AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA

_CALC. NO.: IP-CALC-11-00091 IREVISION NO. j 0 8.0 References

1. CN-CRA-03-55, "Indian Point 2 - LOCA Doses for Stretch Power Uprate Program," Revision 0, (10/31/03)

2. US NRC Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors", (July 2000)

3. NUREG/CR-6604, RADTRAD, "A Simplified Model for Radionuclide Transport and Removal and Dose Estimation," USNRC, Apr. 1998

4. Entergy Letter, PU2-E-03-20, "Entergy Nuclear Northeast -

Indian Point2 - Power Uprating Program - Inputs Approved by the Technical Review Committee," 4/15/03

5. CN-REA-03-4, "Core Radiation Sources to Support the Indian Point 2 Power Uprate Project," Rev. 0, 4/3/03

6. NUREG/CR-5950,"Iodine Evolution and PH Control," Dec. 1992

7. CN-CRA-11-25, "Indian Point 3 LOCA Doses including Contribution from Back-Leakage to RWST," IP-CALc-1I-00080, (9/23/2011)

8. CN-CDME-00-10, "Boric Acid Trisodium Phosphate Titration Curves," Revision 0, May 23, 2000 (copy of Table 3 is attached in Ref. 7)

9. NEA-00023, "Unit 2 TSC Personnel Doses from RG 1.183/NUREG-1465 Design Basis Loss-OF-Coolant-Accident," Rev. 0, (3/22/05)

10. IP-CALC-11-00063, "IPEC Unit 2 SIS & RHR Selected Internal Piping Volumes," Revision 0, (9/7/11)

Calculation No. IP-CALC-11-00091, Rev. 0 Attachment A, Page 1 ATTACHMENT A COMPUTER INPUTS & OUTPUTS Included in the EC 32007 is RADTRAD input and output files pertinent to section 6 of this calculation.

The following computer runs were considered in these analyses:

RADTRAD 3.03 Run # 1 Calculate of mass of iodine in the RWST (20 gph)

Input Output Inventory Conc-iodineip220.psf Conc-iodineip220.o0 conc-iodineip2.nif Release Cony. Fac.

Loca-i.rft dcfs.inp Run # 2 Calculate of mass of iodine in the RWST (29 gph)

Input Output Inventory Conc-iodineip229.psf Conc-iodineip229.oO conc-iodineip2.nif Release Cony. Fac.

Loca-i.rft dcfs.inp Run # 3 Calculate of mass of NaOH in the RWST (20 gph)

Calculation No. IP-CALC-II-00091, Rev. 0 Attachment A, Page 2 Input Output Inventory Conc-naohip220.psf Conc-naohip220.o0 con-naohip2.nif Release Cony. Fac.

Con-naohip2.rft dcfs.inp Run # 4 Calculate of mass of NaOH in the RWST (29 gph)

Input Output Inventory Conc-naohip229.psf Conc-naohip229.oO con-naohip2.nif Release Cony. Fac.

Con-naohip2.rft dcfs. inp Run # 5 Calculate CR & offsite doses from RWST back-leakage (20 gph)

Input Output Inventory Release Conv.Fac Ip2rwst2O.psf ip2rwst20.oO ip2-core.nif eccsr.rft dcfs.inp Run # 6 Calculate CR & offsite doses from RWST back-leakage (29 gph)

Input Output Inventory Release Cony. Fac Ip2rwst29.psf ip2rwst29.oO ip2-core.nif eccsr.rft dcfs. inp

Calculation No. IP-CALC-II-00091, Rev. 0 Attachment A, Page 3 Run # 7 Calculate TSC doses from RWST back-leakage (20 gph)

Input Output inventory Release cony. Fac Ip2tscrwst20.psf ip2tscrwst20.oO ip2-core.nif eccsr.rft cfs.inp Run # 8 Calculate TSC doses from RWST back-leakage (29 gph)

Input Output Inventory Release Cony. Fac Ip2tscrwst29.psf ip2tscrwst29.oO ip2-core.nif eccsr.rft cfs.inp

Calculation No. IP-CALC-11-00091, Rev. 0 Attachment B, Page 1 ATTACHMENT B TSC Doses IP2 LOCA TSC TEDE Doses (rem) for 20 & 29 gph Flow Rate C a s e 29 gph Back-Leakage 0.0407 0.0635 To RWST Calculated Containment

& ECCS leakage (Ref. 9) 2.482 2.482 Total 2.52 2.55 TEDE Limit 5.0 5.0 See RADTRAD output ip2tscrwst20.oO and ip2tscrwst29.oO

Calculation No. IP-CALC-Il-00091, Rev. 0 Attachment C, Page 1 ATTACHMENT C Supporting Documentation: Design Inputs (Total 9 Pages)

EN-DC-141, Design Inputs Page l of 9 ATTACHMENT 9.1 DESIGN INPUT RECORD Sheet I of I Design Input Revision:

aPage 0 of r9

-DESIGN INPUT RECORD Document Type: Calculation Document Number: IP-CALC-11-OO 1 A16,- Document Revision: -0 Problem Summary: (Attach additional sheets as reqruired)

The high head safety injection (HHSI) system and the low head injection/residual heat removal (RHR) system are connected to the refueling water storage tank (RWST) through multiple valves. The potential doses resulting from leakage of the emergency core cooling system (ECCS) back to the RWST through these valves need to be quantified based on alternate source term (AST) analyses for a large break loss-of-coolant accident (LOCA).

Desicm objective: (Attach additional sheets as reauired)

This analysis will calculate the Indian Point Unit 2 (IP2) Control Room (CR), offsite and the Technical Support Center (TSC) doses resulting from the identified emergency core cooling system (ECCS) back leakage to the IP2 Refueling Water Storage Tank (RWST) during a large break Loss-Of-Coolant Accident (LOCA). The calculated dose due to the ECCS back leakage to the RWST will be combined with the calculated dose resulting from releases via the containment leakage and the ECCS recirculation leakage pathways.

Discipline Review:

Contributing Disciplines:

Prepared Reviewed Prepared By Reviewed By:

By By:

OMechanical C]Electrical 0*I & C F]Civil/Structural N Other _ J.E. Chan OEngineering (Nuclear) Goshll .0*".**. Programs Outside Design Agency_________ ODA Responsible Engineer (Print/Sign/Date)

The contributing discipline engineer shall provide his/her name beside the appropriate block.

Lead Discipline Fuels & Nuclear Analysis gg- ao3 u Dat RE: (Print/Sign) Mehdi Golshani - 10/1-0 Date Engineering Supervisor: Ardesar Irani Date 1 O/ J/AI EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 2 of 9 Input ý,Value 'Input Source (Source Document)

ECCS Back Leakage to 6.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months

Reference:

CN-LIS-03-8, Rev. 0, "Indian Point Unit 2 (IPP) Uprate the RWST - start of Post-LOCA Calculations."

leakage Sump Water Volume 374,000 From Page 56 of Reference , CN-CRA-03-55, "Indian Point 2 - LOCA gallons Doses for Stretch Power Uprate Program," Revision 0, (10/31/03)

Density of RWST water 61.86 lb/ft3 Density of water at maximum temperature of 110 OF, from Reference CN-CRA-03-55, "Indian Point 2 - LOCA Doses for Stretch Power Uprate Program," Revision 0, (10/31/03), Page 56 Flow Rate of ECCS Back 20 & 29 gallons Calculate allowable back leakage to remain below the FSAR CR TEDE Leakage to the RWST- per hour (gph) dose limit. Also calculate value which does not result the dose below the water level acceptance limit.

Flow Rate of ECCS Back Not Applicable The ECCS back leakage to the RWST above the water level will be Leakage to the RWST - considered as part of the ECCS leakale in the Primary Auxiliary above the water level Building via the containment vent in CN-CRA-03-55, Revision 0. Note that the RWST releases are bounded by the Primary Auxiliary Building releases since the atmospheric dispersion factors of the PAB releases (via containment vent) are greater than those of the RWST releases.

[See inputs for atmospheric dispersion factors (X/Q's)]

Volume of Water 1,880 gallons

Reference:

IP-CALC-11-00063, Table 2. The minimum water volume Associated with ECCS is estimated to be 2,094 (1943 + 151) gallons between the high head Back Leakage to the safety injection pump suction and the valve 846 to the RWST RWST 2094 gallons x 0.9 (10% margin) =

1,884.6 gallons 1,880 gallons Mass of iodine in sump 26,121 g

Reference:

CN-CRA-11-25, "Indian Point 3 LOCA Doses including Contribution from Back-Leakage to RWST," IP-CALC-11-00080, (9/23/2011)

Both plants IP2 and IP3 have the same rated thermal power and the source inventory of the core is almost the same. Therefore the amount of iodine source in the core for both plants IP2 and IP3 should be almost the same.

EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 3 of 9 Input . valueI 'Input Source (Source Document)

ECCS Back Leakage to 75 hours8.680556e-4 days 0.0208 hours 1.240079e-4 weeks 2.85375e-5 months

Reference:

IP-CALC-11-00063, Table 2. The horizontal section the RWST-time delay volume of the piping associated with the ECCS back leakage to the of the sump water 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months RWST is estimated to be 1,931 gallons between the high head safety reaching the RWST. injection pump suction and the valve 846 to the RWST. Since the Based on 20 and 29 gph sump water temperature is higher than the RWST and its associated assumption piping temperatures, and the sump water is located at lower elevation, the vertical sections of piping are neglected due to the buoyancy-driven thermal mixing. Therefore, the time delay of the ECCS back leakage of 20 or 29 gallons per hour (gph) to reach the RWST is conservatively estimated to be 75 or 60 hours6.944444e-4 days 0.0167 hours 9.920635e-5 weeks 2.283e-5 months after the start of ECCS external recirculation.

Horizontal Sections of 1A and 1B:

429+51+1304+78+3+3+40+25+30+19+10 gallons=

1992 gallons Horizontal Sections of 2A and 2B:

429 + 51 + 1304 + 78 +36 + 283 +47 + 217+ 17 gallons

= 2462 gallons 1992 gallons x 0.9 (10% margin) = 1,792.8 gallons 1,750 gallons 1,750 gallons 20 gph (assume)= 87.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months 75 hours 1,750 gallons / 29 gph (assume)= 60.3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months 60 hours Iodine species in All iodine is assumed to have converted to stable form in the sump containment sump water.

water Elemental: 0 Organic: 0 Particulate: 100 EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 4 of 9 Input ,' Value:. Input Source (Source.Document)

Volume of Water 13900 gallons Lowest RWST Water Level = 1.49 ft Remaining in the RWST after Recirculation

Reference:

CR-IP2-2002-04498 Switchover Per IP-PRT-09-00014, Rev. 1, page 45 shows the actual lowest RWST water level is 1.74 and page 42 of this reference says "if RWST level decreases to less than 1.5 ft then stop all pumps taking suction from the RWST." Therefore, using 1.49 is conservative.

RWST volume:

H= 41'-3" Dia.= 40.0' Drawing No: F.P. No. 9321-01-20339-4 Thickness = 0.227" =0.018917' Volume= TT R2 h = 3.14 x (20 - 0.018917)2 x 41.25 = 51738.27 ft3 =

387054.0 gal RWST Water Volume per Foot = 387054.0 / 41.25 = 9383 gal/ft Remaining Water Volume = 1.49 ft x 9383 gal/ft

= 13980 gallons 13,900 gallons RWST Minimum 40°F SR 3.5.4.1 Temperature Section 3.5.4 "Refueling Water Storage Tank (RWST)" of Indian Point Unit 2, Improved Technical Specifications (ITS).

RWST Maximum 110 OF SR 3.5.4.1 Temperature Section 3.5.4 "Refueling Water Storage Tank (RWST)" of Indian Point Unit 2, Improved Technical Specifications (ITS).

Post-LOCA RWST 114 OF

Reference:

CN-CRA-11-25, "Indian Point 3 LOCA Doses including Maximum Temperature Contribution from Back-Leakage to RWST," IP-CALC-11-00080, due to the ECCS Back (9/23/2011)

Leakage to the RWST The post-LOCA maximum RWST temperature was estimated in Appendix B (pages 79 and 80) of CN-CRA-11-25 for IP3. A review of the IP2 containment sump temperature and the estimated ECCS back-leakage rate concluded that 114 OF is still bounding.

EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 5 of 9 Input-~' [ Value> [ > lnputSource,(Source Document)

Volume of Air in the 386,000 Height of the RWST = 41' - 3" RWST after Recirculation gallons Switchover Drawing No: F.P. No. 9321-01-20339-4 RWST Volume at 41'- 3" = 13820 gallons + (41' - 3") x 9383 gallons/ft

= 400,874 gallons Remaining Air Volume = 400,874 gallons - 13,980 gallons

= 386,894 gallons 386,000 gallons Maximum Boron 2600 parts per SR 3.5.4.3 Concentration of RWST million [ppm]

Section 3.5.4 "Refueling Water Storage Tank (RWST)" of Indian Point Unit 2, Improved Technical Specifications (ITS).

Minimum Boron 2400 parts per SR 3.5.4.3 Concentration of RWST million [ppm]

Section 3.5.4 "Refueling Water Storage Tank (RWST)" of Indian Point Unit 2, Improved Technical Specifications (ITS).

Maximum Diurnal 40 OF A review of the four (4) year Indian Point meteorological data shows Temperature Variation the maximum diurnal temperature variation does not exceed 40 °F.

[See page 81 of IP-CALC-11-00080, Revision 0, (CN-CRA-11-25, Revision 0), "Indian Point 3 LOCA Doses including Contribution from Back-Leakage to RWST."]

Minimum Sodium 8,096 pounds SR 3.6.7.1.b Tetraborate [Ibm]

Decahydrate for Post- Section 3.6.7 "Recirculation pH Control System" of Indian Point Unit LOCA pH Control 2, Improved Technical Specifications (ITS).

EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 6 of 9 Inpt :...;.Value, Input Source (Source Docurn*nt)y Atmospheric Dispersion Factors [X/Ql for the IP2 Table 2.1 of IP-CALC-11-00060, Revision 0, "Analysis of IP2 Control Control Room (CR) Air Room and Technical Support Center Atmospheric Dispersion Factors Intake Associated with due to Releases from the IP2 FSB & RWST." (9/28/11) the IP2 RWST Release

[sec/m 3]

0- 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s: 5.62E-04 2- 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s: 3.72E-04 8- 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: 1.35E-04 1- 4 days: 1.IOE-04 4- 30 days: 9.02E-05 Control Room Volume 102,400 ft 3 Consistent with analysis in Reference, CN-CRA-03-55, "Indian Point 2 - LOCA Doses for Stretch Power Uprate Program,"

Revision 0, (10/31/03)

CR Normal Operation Consistent with analysis in Reference, CN-CRA-03-55, "Indian flow rates (cfm) Point 2 - LOCA Doses for Stretch Power Uprate Program,"

Revision 0, (10/31/03)

Filtered Makeup: 0 Filtered Recirculation: 0 Unfiltered Makeup: 920 Unfiltered inleakage: 700 Time to switch CR HVAC 60 sec. Consistent with analysis in Reference, CN-CRA-03-55, "Indian to emergency operation Point 2 - LOCA Doses for Stretch Power Uprate Program,"

mode Revision 0, (10/31/03)

CR HVAC emergency Consistent with analysis in Reference, CN-CRA-03-55, "Indian operation flow (cfm) Point 2 - LOCA Doses for Stretch Power Uprate Program,"

Revision 0, (10/31/03)

Filtered Makeup: 1800 Unfiltered Makeup: 0 Unfiltered inleakage: 700 EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 7 of 9 Input Value Input S6urce (Source Documene7t) 7 CR HVAC Filter Consistent with analysis in Reference, CN-CRA-03-55, "Indian efficiencies (%) Point 2 - LOCA Doses for Stretch Power Uprate Program,"

Revision 0, (10/31/03)

Elemental iodine: 95 Organic iodine: 90 Particulates: 99 CR Breathing rate 3.5E-04 Ref. Reg. Guide 1.183 and also consistence with analysis in (m3/sec) Reference, CN-CRA-03-55, "Indian Point 2 - LOCA Doses for Stretch Power Uprate Program," Revision 0, (10/31/03)

CR Occupancy Factors Ref. Reg. Guide 1.183 and also consistence with analysis in Reference, CN-CRA-03-55, "Indian Point 2 - LOCA Doses for 0-2 hours: 1.0 Stretch Power Uprate Program," Revision 0, (10/31/03) 1-4 days: 0.6 4-30 days: 0.4 Offsite Meteorological Consistence with analysis in Reference, CN-CRA-03-55, "Indian Dispersion Factors Point 2 - LOCA Doses for Stretch Power Uprate Program,"

(sec/m 3) Revision 0, (10/31/03)

EAB 0-2 hours: 7.5E-04 LPZ 0-8 hours: 3.5E-04 8-24 hours: 1.2E-04 1-4 days: 4.2E-05 4-30 days: 9.3E-06 Offsite breathing rate Ref. Reg. Guide-1.183 and also consistence with analysis in (m3/sec) Reference, "Indian Point 2 - LOCA Doses for Stretch Power Uprate Program," Revision 0, (10/31/03) 0-8 hours: 3.5E-04 8-24 hours: 1.8E-04 1-30 days: 2.3E-04 Technical Support Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from Center (TSC) Net-free 860.9 m3 RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

Volume EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 8 of 9 Input n Souce ut urceocument) ?

Atmospheric Dispersion Table 2.2 of IP-CALC-11-00060, Revision 0, "Analysis of IP2 Control Factors [X/Q] for the Room and Technical Support Center Atmospheric Dispersion Factors Technical Support due to Releases from the 1P2 FSB & RWST." (9/28/11)

Center (TSC) Air Intake Associated with the IP2 RWST Release [sec/iM]

0 - 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months s: 3.58E-04 2- 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months s: 1.24E-04 8- 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: 5.66E-05 1- 4 days: 4.77E-05 4- 30 days: 3.94E-05 Technical Support 12,870 cfm 8620 cfm + 4250 cfm = 12,870 cfm Center (TSC) Unfiltered Intake Flow Rate This value is greater than 11,230 cfm [damper flow rate] and 12,500

[Normal Operation] cfm [air-handling fan flow rate] for conservatism.

A226586, Revision 6, "Technical Support Center HVAC Flow Diagram Elev. 72'-0", Elev. 88'-6" (Unit #2)."

A226587, Revision 3, "Technical Support Center HVAC Flow Diagram El. 33'-0", 37'-0" & 53'-0" (Unit #2)."

Technical Support Filtered Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from Center (TSC) Ventilation pressurized RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

Mode [Incident intake Operation]

Technical Support 3400 standard 3492 to 4268 cfm:

Center (TSC) Filtered cubic feet per Intake Flow Rate minute (scfm) 2-PT-EM001, Revision 0, "TSC Filtration System."

[Incident Operation] [conservatively lowered from 3492 cfm] 3770 scfm:

Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

EN-DC-141 Rev. 10

EN-DC-141, Design Inputs Page 9 of 9 Input j Value: Input.Source (Source:Document),

Technical Support 0 scfm [No Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from Center (TSC) Recirculation] RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

Recirculation Flow Rate

[Both Normal and Incident Operation]

Technical Support 60 minutes The Technical Support Center (TSC) and the Operations Support Center (TSC) Ventilation [maximum Center (OSC) will be staffed within 60 minutes, and the OSC Radiation Mode Change from delay time for Protection Coordinator will request the Control Room to align the Normal to Incident conservatism] TSC ventilation system for incident operation.

Operation IP-EP-210, Revision 9, "Central Control Room."

IP-EP-220, Revision 10, "Technical Support Center."

IP-EP-230, Revision 7, "Operations Support Center."

Technical Support 500 scfm Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from Center (TSC) Unfiltered RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

Inleakage Flow Rate

[Both Normal and Incident Operation]

Technical Support 3900 scfm 3400 scfm [filtered intake] + 500 scfm [unfiltered inleakage]

Center (TSC) Exhaust = 3900 scfm Flow Rate [Incident Operation]

Technical Support Page 11 of NEA-00023, Revision 0, "Unit 2 TSC Personnel doses from Center (TSC) Filter RG 1.183/NUREG-1456 Design Basis Loss-of-Coolant Accident."

Efficiencies [Incident Operation]

Particulate: 99%

Inorganics (elemental): 95%

Organics: 90%

Noble gases: 0%

EN-DC-141 Rev. 10

Page 1 of 10 ATTACHMENT 9.1 DESIGN VERIFICATION COVER PAGE Sheet 1 of I DESIGN VERIFICATION COVER PAGE El ANO-1 [] ANO-2 Z IP-2 [I IP-3 E] JAF [_ PLP

[E PNPS V EJVY GGNS E-RBS El W3 El NP Document No.: IP-CALC-11-00091 Revision No.: 0 1 Page 1 of 10

Title:

AST Analysis of IP2 to Address the Impact of Containment Sump Solution Back-Leakage to the RWST after LOCA 0 Quality Related [I Augmented Quality Related DV Method: E3 Design Review El Alternate Calculation D] Qualification Testing VERIFICATION REQUIRED DISCIPLINE VERIFICATION COMPLETE AND COMMENTS RESOLVED (DV print, sign, and date)

Electrical

-- Mechanical

-- Instrument and Control

_ _ __ _ _ Civil/Structural Nuclear Jong E. Chang /14.i--* A/l El Originator: Mehdi Golshani _"__ _, ____,___

Print/Sign/Date After Comments Have Been Resolved EN-DC-1 34 REV 4

Page 2 of 10 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet I of 3 IDENTIFICATION: DISCIPLINE:

DocumentTitle: AST Analysis of IP2 to Address the Impact of Containment Sump -]Civil/Structural Solution Back-Leakage to the RWST after LOCA [--Electrical Doc. No.: IP-CALC-1 1-00091 Rev. 0 QA Cat. [-I &C E nMechanical /Jo Vei

Print e Veife:_oq _.Chn __ Sign / " Dat6 4/* 1f Nuclear

[]7Other Manager authorization for supervisor performing Verification.

[ A N/A Print Sign Date METHOD OF VERIFICATION:

Design Review [ Alternate Calculations U Qualification Test El The following basic questions are addressed as applicable, during the performance of any design verification. [ANSI N45.2.11-1974] [NP QAPD, Part II, Section 3] [NP NQA-1 -1994, Part I, BR 3, Supplement 3S-1]

NOTE The reviewer can use the "Comments/Continuation sheet' at the end for entering any comment/resolution along with the appropriate question number. Additional items with new question numbers can also be entered.

1. Design Inputs - Were the inputs correctly selected and incorporated into the design?

(Design inputs include design bases, plant operational conditions, performance requirements, regulatory requirements and commitments, codes, standards, field data, etc.

All information used as design inputs should have been reviewed and approved by the responsible design organization, as applicable.

All inputs need to be retrievable or excerpts of documents used should be attached.

See site specific design input procedures for guidance in identifying inputs.)

Yes 9 No E] N/A 0

2. Assumptions - Are assumptions necessary to perform the design activity adequately described and reasonable? Where necessary, are assumptions identified for subsequent re-verification when the detailed activities are completed? Are the latest applicable revisions of design documents utilized?

Yes 0 No E] N/A D

3. Quality Assurance - Are the appropriate quality and quality assurance requirements specified?

Yes 9 No 0 N/A 0 EN-DC-134 REV 4

Page 3 of 10 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet 2 of 3

4. Codes, Standards and Regulatory Requirements - Are the applicable codes, standards and regulatory requirements, including issue and addenda properly identified and are their requirements for design met?

Yes 0 No E] N/A [I

5. Construction and Operating Experience - Have applicable construction and operating experience been considered?

Yes 0 No [] N/A 0

6. Interfaces - Have the design interface requirements been satisfied and documented?

Yes Z No ED N/A El

7. Methods - Was an appropriate design or analytical (for calculations) method used?

Yes Z No D N/A D

8. Design Outputs - Is the output reasonable compared to the inputs?

Yes g NoEJ N/A D

9. Parts, Equipment and Processes - Are the specified parts, equipment, and processes suitable for the required application?

Yes ED No [] N/A Z

10. Materials Compatibility - Are the specified materials compatible with each other and the design environmental conditions to which the material will be exposed?

Yes D No 0 N/A 0

11. Maintenance requirements - Have adequate maintenance features and requirements been specified?

Yes 0 No D N/A 0

12. Accessibility for Maintenance -Are accessibility and other design provisions adequate for performance of needed maintenance and repair?

Yes E] No D N/A 0

13. Accessibility for In-service Inspection - Has adequate accessibility been provided to perform the in-service inspection expected to be required during the plant life?

Yes 0 No [] N/A 0

14. Radiation Exposure - Has the design properly considered radiation exposure to the public and plant personnel?

Yes 0 No D N/A El

15. Acceptance Criteria - Are the acceptance criteria incorporated in the design documents sufficient to allow verification that design requirements have been satisfactorily accomplished?

Yes 0 No 0 N/A D-

16. Test Requirements - Have adequate pre-operational and subsequent periodic test requirements been appropriately specified?

Yes 0 No 0 N/A 10 EN-DC-1 34 REV 4

Page 4 of 10 ATTACHMENT 9.6 DESIGN VERIFICATION CHECKLIST Sheet 3 of 3

17. Handling, Storage, Cleaning and Shipping -Are adequate handling, storage, cleaning and shipping requirements specified?

Yes El No [I N/A 0

18. Identification Requirements - Are adequate identification requirements specified?

Yes 0 No D N/A 0

19. Records and Documentation - Are requirements for record preparation, review, approval, retention, etc., adequately specified? Are all documents prepared in a clear legible manner suitable for microfilming and/or other documentation storage method? Have all impacted documents been identified for update as necessary?

Yes 0 No 0 N/A El

20. Software Quality Assurance- ENN sites: For a calculation that utilized software applications (e.g., GOTHIC, SYMCORD), was it properly verified and validated in accordance with EN- IT-1 04 or previous site SQA Program?

ENS sites: This is an EN-IT-1 04 task. However, per ENS-DC-1 26, for exempt software, was it verified in the calculation?

Yes 0 No 0 N/A [

21. Has adverse impact on peripheralcomponents and systems, outside the boundary of the document being verified, been considered?

Yes 0 No [3 N/A 0 EN-DC-1 34 REV 4

Page 5 of 10 ATTACHMENT 9.7 DESIGN VERIFICATION COMMENT SHEET Sheet I of 1 Comments / Continuation Sheet Question Comments Resolution Initial/Date 1 Various editorial comments were N/A identified and addressed. No response required. / ,

2 [Section 6.2] The potential ECCS N/A back-leakage flow to the RWST via Valve 846 is below the RWST water level as identified in Attachment C, ((//'"I Design Inputs (page 2 of 9). Hence, the flow to "air" is an artificial flow path to match the iodine partition factor between the RWST water and the RWST air. This is not the potential ECCS leakage to the RWST via MOV-842 and MOV-843, which is above the RWST water level. No response required.

3 [Section 6.3] The equivalent mole of N/A sodium hydroxide (NaOH) was used to determine the delivered sump water. /* /

Then the titration curve of boric acid/trisodium phosphate (TSP) was used to estimate the RWST pH.

However, the actual sump solution is based on sodium tetraborate (STB),

which is also a weak base. Therefore, it is not obvious that the titration curve using TSP is always conservative to estimate the RWST pH for the elemental iodine fraction.

The following post-LOCA sump pH values are found based on TSP and STB:

12,000 Ibm of TSP (trisodium phosphate dodecahydrate, TSP-10H20) in the post-accident IP2 containment sump at 2000 ppm boron resulted in pH of 7.61 (page 10 of CN-CRA-96-005, Revision 2). If the mass is adjusted to 10,000 Ibm of TSP, the resulting pH is approximately 7.53.

1 10,000 Ibm of STB (sodium EN-DC-1 34 REV 4

Page 6 of 10 Question Comments Resolution Initial/Date

I tetraborate decahydrate, STB-12H 20) in the post-accident IP2 containment sump at 2000 ppm born resulted in pH of 7.4 (Figure 3 of IP-CALC 00129, Revision 2).

The molar mass of TSP-10H20 is 380.1234 g/mol and STB-12H20 is 381.38 g/mol so they are very comparable in weight. Thanks to the TSP titration curve, the estimated RWST pH could be higher as much as pH = 0.13, which is non-conservative.

While determining the elemental iodine fraction in page 31 of the calculation, the elemental iodine fraction in the RWST was selected based on pH of 6.04 instead of 5.2, which gives a margin of pH = 0.84.

Therefore, although the TSP titration curve results in slightly non-conservative RWST pH, the elemental iodine fraction was chosen such that the inputs to RADTRAD are still conservative.

No response required.

4 [Design Inputs] The maximum RWST N/A temperature was reviewed not just for the final temperature but for the whole 1(11611(

accident duration, i.e., 30 days. As shown in the following Attachment 1, the maximum RWST temperature maintains below 114 OF at 20 gph of the back-leakage flow rate. No resoonse reauired.

resoonse reauired.

____ +/-________________ I EN-DC-134 REV 4

Page 7 of 10 . Maximum RWST Water Temperature due to the Sump Water Back-Leakage INPUTS t initial = start of ECCS leakage to RWST 6.5 hours : Section 2.0 of CN-LIS-30-8, Revision 0 23,400 seconds : Section 3.1 of CN-CRA-03-55, Revision 0 t final = accident duration 30 days : Regulatory Guide 1.183 2,592,000 seconds V_pipe = piping volume 1880 gallons : Design Input

RHR Suction Line V_rwst = RWST water volume 13900 gallons : Design Input T rwst = RWST water temperature 110 deg F : SR 3.5.4.1 of IP3 Improved Technical Specifications Q_leakage ECCS leakage to RWST 20 gallons per hour : Design Input Maximum ECCS Temperature

Minimum ECCS w/ NUREG-1465 Time ECCS Temperature pages 61 - 63, CN-CRA-03-12, Revision 0

[sec] [deg F] Sump Temperature 23,199 196.31 25,599 191.26 26,799 188.97 29,199 184.86 31,599 191.28 36,399 175.45 41,599 170.68 61,199 160.83 80,799 156.51 85,599 155.78 EN-DC-1 34 REV 4

Page 8 of 10 90,399 155.11 99,999 153.84 101,999 151.64 104,999 148.76 106,999 147.11 109,999 144.94 114,999 142.05 119,999 139.84 128,999 137.05 138,999 135.06 158,999 132.81 199,999 130.53 201,999 129.66 206,999 127.71 216,999 125.11 236,999 122.59 275,999 120.89 314,999 120.09 353,999 119.46 401,999 118.54 411,999 117.4 431,999 116.32 470,999 115.67 548,999 115.21 626,999 114.87 782,999 114.27 1,008,999 111.09 1,094,999 107.04 1,251,999 106.82 1,854,999 106.62 3,750,999 106.09 CALCULATION ECCS Back Leakage to RWST

[gallon- [gallon- [gallons] [deg F]

[sec] [deg F]

deg F] deg F]

23400 196.31 2398.3 2398.3 12.2 110.1..

25599 191.26 1275.1 3673.3 18.9 110.1 26799 188.97 2519.6 6192.9 32.2 110.2 29199 184.86 2464.8 8657.7 45.6 110.2 31599 191.28 5100.8 13758.5 72.2 110.4 36399 175.45 5068.6 18827.1 101.1 110.5 41599 170.68 18585.2 37412.2 210.0 110.9 EN-DC-1 34 REV 4

Page 9 of 10 61199 160.83 17512.6 54924.8 318.9 111.2 80799 156.51 4173.6 59098.4 345.6 111.3.4 85599 155.78 4154.1 63252.6 372.2 11.4.

90399 155.11 8272.5 71525.1 425.6 99999 153.84 1709.3 73234.4 436.7 111.6 101999 151.64 2527.3 75761.8 453.3 111.6' 1652.9 77414.7 464.4 111i.6*

104999 148.76 106999 147.11 2451.8 79866.5 481.1 111.7 109999 144.94 4026.1 83892.6 508.9 111.7 114999 142.05 3945.8 87838.4 536.7 111.8 119999 139.84 6992.0 94830.4 586.7 111.9 128999 137.05 7613.9 102444.3 642.2 111l.9 138999 135.06 15006.7 117451.0 753.3 112.1 158999 132.81 30251.2 147702.2 981.1 1121.4 199999 130.53 1450.3 149152.5 992.2 112.4 201999 129.66 3601.7 152754.2 1020.0 112.4 206999 127.71 7095.0 159849.2 1075.6 112.5 216999 125.11 13901.1 173750.3 1186.7 112.5 236999 122.59 26561.2 200311.4 1403.3 112.7 112.8::

275999 120.89 26192.8 226504.3 1620.0 314999 120.09 26019.5 252523.8 1836.7 112.9 353999 119.46 31856.0 284379.8 2103.3 113.0 401999 118.54 6585.6 290965.3 2158.9 113.0 411999 117.4 13044.4 304009.8 2270.0 113.0 25202.7 329212.4 2486.7 113.0 431999 116.32 470999 115.67 50123.7 379336.1 2920.0 113.1.,

11l~3.2..

548999 115.21 49924.3 429260.4 3353.3 99554.0 528814.4 4220.0 .113.2 626999 114.87 782999 114.27 143472.3 672286.8 5475.6 113.3.

1008999 111.09 53076.3 725363.1 5953.3 .113.2 1094999 107.04 93362.7 818725.8 6825.6 .113.0 1251999 106.82 357847.0 1176572.8 10175.6 112.2 1854999 106.62 436550.3 1613123.0 14270.0 111.4 2592000 106.09 V_total = total water volume Back Leakage 14270 gallons 1613123 gallon-deg F Piping 1880 gallons 206800 gallon-deg F RWST 13900 gallons 1529000 gallon-deg F Total = 30050 gallons 3348923 gallon-deg F EN-DC-134 REV 4

Page 10 of 10 T final = final RWST temperature 111.445 deg F 112 deg F The final RWST temperature is conservatively increased to 114 *F.

EN-DC-1 34 REV 4

v t e Letter Sequence Response to RAI
TAC:MF1440, (Approved, Closed)
Initiation Acceptance Administration Questions 7 August 2013 Answers 4 September 2013 Results Approval Other: ML14002A431, ML17104A041, ML17104A042, NL-13-015, Proposed License Amendment Regarding Connection of Non Seismic Boric Acid Recovery System to the Refueling Water Storage Tank, NL-17-035, Proposed License Amendment Regarding Connection of Non-Seismic Boric Acid Recovery System to the Refueling Water Storage Tank
MONTHYEAR2013-05-30 [Table View]

NL-13-115, Unit Number 2 - Response to Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-seismic Piping Under Administrative Controls

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NL-13-115, Unit Number 2 - Response to Request for Additional Information Regarding Proposed License Amendment to Temporarily Connect Seismic to Non-seismic Piping Under Administrative Controls

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