ML030230784

Request for Additional Information - Amendment Application Missed Surveillances, MB6421

ML030230784
Person / Time
Site:	Nine Mile Point
Issue date:	01/23/2003
From:	Tam P NRC/NRR/DLPM/LPD1
To:	Conway J Nine Mile Point
References
TAC MB6421
Download: ML030230784 (4)

Text

January 23, 2003 Mr. John T. Conway Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION - AMENDMENT APPLICATION RE: MISSED SURVEILLANCES (TAC NO. MB6421)

Dear Mr. Conway:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the subject proposed amendment, requested by your application dated October 7, 2002. On January 7, 2003, we held a telephone conference with Mr. John Dosa, et al. of your staff, on comments we previously e-mailed to your staff. Subsequent to the telephone conference, we sent another e-mail with essentially the same comment. Both e-mails are available in the Agencywide Documents Access and Management System under Accession No. ML023250103 and ML030090212, respectively. This letter formalizes the NRC staffs position and request for additional information (enclosed).

Please respond within 60 days of receipt of this letter.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-220

Enclosure:

As stated cc w/encl: See next page

January 23, 2003 Mr. John T. Conway Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION - AMENDMENT APPLICATION RE: MISSED SURVEILLANCES (TAC NO. MB6421)

Dear Mr. Conway:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the subject proposed amendment, requested by your application dated October 7, 2002. On January 7, 2003, we held a telephone conference with Mr. John Dosa, et al. of your staff, on comments we previously e-mailed to your staff. Subsequent to the telephone conference, we sent another e-mail with essentially the same comment. Both e-mails are available in the Agencywide Documents Access and Management System under Accession No. ML023250103 and ML030090212, respectively. This letter formalizes the NRC staffs position and request for additional information (enclosed).

Please respond within 60 days of receipt of this letter.

Sincerely,

/RA/

Peter S. Tam, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-220

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC PDI-1 R/F RLaufer PTam OGC TTjader ACRS BPlatchek, RGI SLittle Accession Number: ML030230784 OFFICE PDI-1/PM PDI-1/LA RORP RORP/SC PDI-1/SC NAME PTam SLittle TTjader RDennig RLaufer DATE 1/22/03 1/22/03 1/23/03 1/23/03 1/23/03 OFFICIAL RECORD COPY

STATEMENT OF POSITION AND REQUEST FOR ADDITIONAL INFORMATION NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 AMENDMENT APPLICATION REGARDING MISSED SURVEILLANCES

Reference:

Letter, J. T. Conway to U.S. Nuclear Regulatory commission (NRC), Application for Technical Specification [TS] Change Regarding Missed Surveillances Using the Consolidated Line Item Improvement Process, October 7, 2002 The change to the Standard Technical Specification (STS) Surveillance Requirement (SR) 3.0.3 that provides flexibility to entering a TS Required Actions based upon a risk evaluation was approved in the Consolidated Line Item Improvement Process (CLIIP) change known as Technical Specifications Task Force (TSTF)-358, Revision 6. CLIIP and TSTF changes are based upon the STS, and licensees who adopt those changes must either employ the STS, or their custom TS must be equivalent to the STS in the area of the change.

SR 3.0.3 addresses the situation of a missed surveillance, a surveillance that was not performed within its required frequency, and the resulting implications for considering the surveillance and associated limiting condition for operation not met. To accurately adopt and implement TSTF-358, Revision 6, the custom TSs must have or must establish identical requirements for what it means to meet an SR. STS SR 3.0.1 establishes those requirements.

Accordingly, for a licensee with custom TSs to adopt TSTF-358, Revision 6, it must do either of the following:

(1) Adopt STS SR 3.0.1 and associated bases, or (2) Show that its custom TSs have equivalent requirements to SR 3.0.1, and adopt the STS SR 3.0.1 Bases.

There are four sentences in STS SR 3.0.1, and each is a requirement. A custom TS licensee not adopting STS SR 3.0.1 must describe how its TSs contain these four elements.

Please supplement your application to reflect the NRC staffs position above.

Enclosure

Nine Mile Point Nuclear Station Unit No. 1 Regional Administrator, Region I Mr. James M. Petro, Jr., Esquire U.S. Nuclear Regulatory Commission Counsel 475 Allendale Road Constellation Power Source, Inc.

King of Prussia, PA 19406 111 Market Place Suite 500 Resident Inspector Baltimore, MD 21202 U.S. Nuclear Regulatory Commission P.O. Box 126 Lycoming, NY 13093 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy Electric Division NYS Department of Public Service Agency Building 3 Empire State Plaza Albany, NY 12223 Mr. William M. Flynn, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street, NW Washington, DC 20005-3502 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Mr. Michael J. Wallace President Nine Mile Point Nuclear Station, LLC c/o Constellation Energy Group 750 East Pratt Street Baltimore, MD 21201-2437