ML043650311
| ML043650311 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/17/2004 |
| From: | Spina J Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMPIL 1900, TAC MC0691, TAC MC0692 | |
| Download: ML043650311 (14) | |
Text
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I If Constellation Energy, P.O. Box 63 Nine Mile Point Nuclear Station Lycoming, New York 13093 December 17, 2004 NMPIL 1900 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Nine Mile Point Units 1 and 2 Docket Nos. 50-220 and 50-410 Facility Operating License Nos. DPR-63 and NPF-69 License Renewal Application - Responses to NRC Requests for Additional Information from the Reactor Systems Branch Review (TAC Nos. MC0691 and MC0692)
Gentlemen:
By letter dated May 26, 2004, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted an application to renew the operating licenses for Nine Mile Point Units 1 and 2.
In a letter dated November 17, 2004, the NRC requested additional information resulting from the Reactor Systems Branch review of the License Renewal Application. The NMPNS responses to these requests for additional information are provided in Attachments 1 and 2. This letter contains no new regulatory commitments.
If you have any questions about this submittal, please contact Peter Mazzaferro, NMPNS License Renewal Project Manager, at (315) 349-1019.
Very truly yours, Ja s A. Spina ice President Nine Mile Point JAS/DEV/jm
Page 2 NMP1L 1900 STATE OF NEW YORK
- TO WIT:
COUNTY OF OSWEGO I, James A. Spina, being duly sworn, state that I am Vice President Nine Mile Point, and that I am duly authorized to execute and file this supplemental information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this submittal are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this 17t dayof 2
2004.
WITNESS my Hand and Notarial Seal:
Notary Public My Commission Expires:
/:Z//7 /a 7
Date SANDRA A. OSWALD No. 010S6032276 Qualified in Oswego Copnly Commission Expires iL/oS Attachments:
- 1. Responses to NRC Requests for Additional Information (RAI) Resulting from the Reactor Systems Branch Review of the License Renewal Application
- 2. Nine Mile Point Unit 1 License Renewal Drawing LR-18000-C, Sheets 1 and 2 cc:
Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR Mr. N. B. Le, License Renewal Project Manager, NRR Mr. J. P. Spath, NYSERDA
ATTACHMENT 1 Nine Mile Point Nuclear Station Responses to NRC Requests for Additional Information (RAI)
Resultine from the Reactor Systems Branch Review of the License Renewal Application This attachment provides Nine Mile Point Nuclear Station, LLC (NMPNS) responses to the requests for additional information, contained in the NRC letter dated November 17, 2004, resulting from the Reactor Systems Branch review of the License Renewal Application (LRA).
Each NRC RAI is repeated, followed by the NMPNS response for Nine Mile Point Unit I (NW 1) and/or Nine Mile Point Unit 2 (NMP2), as applicable. Revisions to the LRA are described where appropriate.
Note: Section, table, and page numbers cited for LRA Section 3.1 refer to the revised version of LRA Section 3.1 that was submitted byNMPNS letter NMPIL 1892 dated December 6, 2004.
RAI-I For NAMP, please indicate whether the thermal sleevesfor core spray and recirculation inlet nozzles or the liquidpoison and core differentialpressure lines are consideredpart of the reactor pressure vessel nozzles, safe ends, attachments and instrument penetrations requiring an AMI4
Response
The following thermal sleeves are in-scope for License Renewal (LR) and subject to aging management review (AMR): Core Spray, Feedwater, and Control Rod Drive Return Line. These thermal sleeves are addressed as part of the NMPI Reactor Pressure Vessel under the component type "Thermal Sleeves." See LRA Sections 2.3.l.A.1 and 3.1.2.A.1 for scoping and screening and aging management review results, respectively.
The recirculation inlet nozzle and the liquid poison/core differential pressure nozzle do not have thermal sleeves at NMP 1.
RAI-2
For NMPJ, please indicate whether low-pressure coolant injection couplings ought to be included in the scope of license renewal. Please provide explanation.
Page 1 of9
Response
Low pressure coolant injecti6n couplings are installed in three BWR/4 plants and all BWR/5 and BWR/6 plants. NMIP1 is a BWR/2 plant. Therefore, there are no low pressure coolant injection (LPCI) couplings installed inNMNP1.
The closest analogous system at NMP1 is the Core Spray System, which is evaluated in LRA Sections 2.3.2.A.3 and 3.2.2.A.2. However, this system does not have similar couplings.
RAI-3
For AMPJ, please indicate whether the nozzles connecting the reactor recirculation system to the connecting piping should be iden If ed as reactor recirculation system components requiring AMR. Please provide explanation.
Response
The reactor recirculation nozzles are included in the Reactor Pressure Vessel evaluation. The system boundary is at the point where the safe end and the piping meet. Refer to LRA Section 2.3.1.A. 1, Table 2.3.1.A. 1-1 (page 2.3-3), and Table 3.1.2.A-1 (page 3.142; Note 1) for the identification and discussion of the reactor recirculation system nozzles. Note that LRA Table 3.1.2.A-1 was revised by NMPNS letterNMPlL 1892 dated December 6, 2004.
RAI4 For both units, the steam separator assembly consists of a base into which are welded an array of standpipes, with a steam separator located at the top of each standpipe. Are these standpipes included in the two plants= scopes of license renewal? Please provide explanation.
Response
The NMP 1 and NMP2 steam separators, including their standpipes, are not in-scope for LR.
They are non-safety-related (NSR) components that perform no LR intended function. This conclusion is consistent with the evaluation presented in BWRVIP-06-A, which does not assign any safety significance to these components.
RAI-5
For both units, please indicate where the feedwater sparger is identified as a reactor vessel internal component requiring AMR
Response
The feedwater spargers are not in-scope for LR. The feedwater spargers were evaluated as part of the NMIP1 and NMP2 Reactor Vessel Intemals Systems. Refer to LRA Sections 2.3.1.A.2 and 2.3. 1.B.2, respectively, for Scoping and Screening results. Per BWRVIP-06-A, "The sole Page 2 of 9
purpose of the feedwater spargers is to control thermal mixing and extend the life of the vessel and internals. The failure of feedwater spargers or associated brackets would not prevent injection of coolant makeup anid are not required to safely shut down the reactor." Therefore, the feedwater sparger was determined to not meet any of the LR scoping criteria defined in 10 CFR 54.4.
RAI-6
For NMP], please indicate whether the liquid poison sparger should be identified as a reactor vessel internal component requiring AMR. Please provide explanation.
Response
The liquid poison sparger is in-scope for LR and subject to AMR as described in LRA Section 2.3.l.A.2. However, LRA Table 2.3.1.A.2-1 contains no specific listing for this component. It is, however, equivalent to "Core Spray Lines and Spargers" and is treated similarly (the Liquid Poison sparger's only intended function is "Direct Flow"). The LRA (Table 2.3.1.A.2-1; Table 3.1.1.A, and Table 3.1.2.A-2) will be revised to include the Liquid Poison spray line and sparger.
The aging management programs assigned to these components will be the Water Chemistry Control and BWR Vessel Internals Programs. Note that the BWR Vessel Internals Program basis document (BWRVIP-27-A, "BWR Vessel and Internals Project BWR Standby Liquid Control System/Core Plate AP Inspection and Flaw Evaluation Guidelines") does not recommend any inspections be performed on this line. The reactor vessel penetration associated with this line, however, is inspected and is addressed as part of the NMIP1 Reactor Pressure Vessel in LRA Sections 2.3.1.A. 1 and 3.1.2.A. 1.
LRA Revisions LRA Table 2.3.1 A.2-1 is revised to add the Liquid Poison spray lines and spargers, as follows:
l Component Type l
Intended Function Liquid Poison Spray Line and Sparger Direct Flow LRA Table 3.1..A is revised to add the Liquid Poison spray line and sparger in the "Discussion" column for Item 3.1.1.A-3 1. In Table 3.1.2.A-2, a new line item is added for the Liquid Poison spray line and sparger. These table revisions are shown on the following page. The revisions are highlighted by shading.
Page 3 of 9
Table 3.1.1.A NMP1 Summary of Aging Management Programs for the Reactor Vessel, Internals, and Reactor Coolant Systems Evaluated in Chapter IV of NUREG-1 801 Item Aging Effect/
Aging Further Number Component Mechanism Management Evaluation Discussion
________Programs Recommended 3.1.1.A-31 Core shroud and Crack initiation and BWR vessel No Consistent with NUREG-1801 with core plate, growth due to SCC, intemals; water exceptions (see Appendix B2.1.2).
support structure, IGSCC, and/or IASCC chemistry Additionally, the following components are top guide, core consistent with, but not addressed in, spray lines and NUREG-1801:
spargers, jet Control Rod Guide tubes pump assemblies, Core Shroud clamps, spacers, support control rod drive rings, and tie rods housing, and Core Shroud head bolts and collars nuclear _
instrumentation Steam Dryers guide tubes Table 3.1.2.A-2 Reactor Vessel, Internals, and Reactor Coolant System NMP1 Reactor Pressure Vessel Internals - Summary of Aging Management Evaluation Aging Effect NRG Component Intended Material AgEnvironment Requiring Management 1801 Table I Notes Type Function Management Program Volume 2 Item Liquid Poison DF Wrought Treated Water or Cracking BWR Vessel IV.B13.3-a 3.1.1.A-31 D
Spray Line and Austenitic Steam, High Internals Program Sparger Stainless Steel temperature, Neutron Fluence Water Chemistry
< Sx1 020 n/cm2. -
Control Program BWR Reactor Vessel Intemals Page 4 of 9
RAT-7 For NMP1, please indicate whether the core shroud stabilizers should be identified as reactor vessel internal components requiring AMR Please provide explanation.
Response
The core shroud stabilizer components are part of the "Core Shroud Support Structures" (Tie Rod Assemblies) listed in LRA Table 2.3. 1.A.2-1. The AMR for these components is described in LRA Table 3.1.2.A-2 (pages 3.1-51 and 3.1-52; Note 15).
RAI-8
For AMP], please indicate whether the core shroud vertical weld repair should be identified as a reactor vessel internal component requiring AIM. Please provide explanation.
Response
The core shroud vertical weld repair components are part of the "Core Shroud Support Structures" (Clamps) listed in LRA Table 2.3.1.A.2-1. The AMR for these components is described in LRA Table 3.1.2.A-2 (page 3.1-52; Note 57).
RAI-9
For NMPJ, please provide dwg no. LR-18000-C, sheets I and 2.
Response
Hard (paper) copies of LR drawings LR-18000-C, Sheets 1 and 2 are provided in Attachment 2 to this letter. Note that these drawings were previously transmitted byNMPNS letter NMPIL 1834 dated May 26, 2004, in both hard (paper) and electronic (PDF) formats.
RAI-10
For NMPJ, please indicate whether access hole covers should be identified as reactor vessel internal components requiring AMR. Please provide explanation.
Response
NMP1 does not have access hole covers in the core support structure. Therefore, there are none identified as part of the NMP1 reactor vessel internals.
Page 5 of 9
RAI-11
For AMP], please indicate whether incore instrumentation guide tubes should be identified as reactor vessel internal components requiring AMR Please provide explanation.
Response
As noted in LRA Section 2.3.1.A.2 and Table 2.3.1.A.2-1 (page 2.3-5), the in-core instrumentation guide tubes are in-scope for LR and subject to AMR. AMR results for these components are given in LRA Table 3.1.2.A-2 (page 3.1-52).
RAT-12 For NMP, please indicate whether restriction orifices, radiation collars, or vacuum breakers should be identified as reactor pressure vessel instrumentation system components requiring AMR Please provide explanation
Response
NMPI is a BWR/2 design and does not, therefore, have the listed component types in the Reactor Vessel Instrumentation System. The only component types in-scope for LR are those listed in LRA Table 2.3.1.A.3-1. LRA Section 3.1.2.A.3 and Table 3.1.2.A-3 provide the AMR results.
RAI-1 3 For NAMP2, please indicate whether temperature equalizing columns should be identified as reactor pressure vessel instrumentation system components requirintgAMR. Please provide explanation.
Response
This component is not part of the Reactor Pressure Vessel Instrumentation System due to NMP2 being a BWR15 design. The only component types in-scope for LR are those listed in LRA Table 2.3.1.B.3-1. LRA Section 3.1.2.B.3 and Table 3.1.2.B-3 provide the AMR results.
RAT-14 For NMP2, please indicate whether pump seal flanges should be identified as reactor recirculation system components requiring AMR Please provide explanation.
Response
Pump seal flanges are in-scope for LR and subject to AMR. These components are addressed as part of the NMP2 Reactor Recirculation System under the "Pumps" component type. Refer to Page 6 of 9
LRA Section 2.3.1.B.4 for Scoping and Screening results. Refer to LRA Section 3.1.2.B.4 (page 3.1-17) and Table 3.1.2.B-4 (page 3.1-99) for AMR results.
RAMI 5 For NMP], please indicate whether restriction orifices, radiation collars, or seal coolers should be identified as reactor recirculation system components requiring AMR. Please provide explanation.
Response
Restriction orifices are in-scope for LR and subject to AMR. They are addressed as part of the NMP1 Reactor Recirculation System under the "Flow Elements" component type. Refer to LRA Section 2.3.1.A.4 for Scoping and Screening results. Refer to LRA Section 3.1.2.A.4 and Table 3.1.2.A-4 for AMR results.
Seal coolers are in-scope for LR and subject to AMR. They are addressed as part of the NMP 1 Reactor Building Closed Loop Cooling Water System under the "Heat Exchangers" component type. Refer to LRA Section 2.3.3.A. 17 for Scoping and Screening results. Refer to LRA Section 3.3.2.A.15 and Table 3.3.2.A-15 for AMR results.
The NMPI Reactor Recirculation System does not contain any radiation collars; therefore, none are in-scope for LR or subject to AMR.
RAI-1 6 For NIMP, please indicate whether CRD hydraulic control units, flow elements and indicators, pumps, and rupture discs should be identified as control rod drive system components requiring AMR Please provide explanation.
Response
Each of the Control Rod Drive (CRD) components listed in the RAI is in-scope for LR and subject to AMR with the exception of flow indicators, since they are considered active components. Referring to the LRA sections that address the CRD System for Scoping and Screening (Section 2.3.1.A.5 and Table 2.3.1.A.5-1) and AMR (Section 3.1.2.A.5 and Table 3.1.2.A-5), the hydraulic control units are included in the "Accumulators" component type.
Flow elements and pumps are included with the "NSR piping, fittings and equipment" component type, and rupture disks are included with the "Valves" component type.
RAI-17
For NMPJ, please indicate whetherfloor and equipment drain system components should be identified as components requiring AMR Please provide explanation.
Page 7 of 9
Response
Floor and equipment drain system components are in-scope foi LR and subject to AMR. These components are addressed as part of the NMP1 Miscellaneous Non-Contaminated Vents and Drains System (drains in the Turbine Building and Screen and Pump House) and the NMPI Radioactive Waste System (Drywell and Reactor Building floor and equipment drain systems).
Refer to LRA Sections 2.3.3.A.12 and 2.3.3.A.16, respectively, for Scoping and Screening results. The AMR for the components in the NMP1 Miscellaneous Non-Contaminated Vents and Drains System is described in LRA Section 3.3.2.A. 11 and Table 3.3.2.A-1 I. The AMR for the components in the NMP 1 Radioactive Waste System is described in LRA Section 3.3.2.A. 14 and Table 3.3.2.A-14.
RAT-1 8 Fior NMP2, please indicate whether sampling system components should be identified as components requiring AMR. Please provide explanation.
Response
The NMP2 Process Sampling System does not have components in-scope for LR and subject to AMR that meet the 10 CFR 54.4(a)(1) or (a)(3) criteria. The components that are in-scope for LR and subject to AMR include NSR piping, fittings, and equipment that meet the 10 CFR 54(a)(2) criterion. Consistent with the convention adopted for the LR drawings, components that are in-scope and subject to AMR for the (a)(2) criterion only are not shown in red on LR drawings. There was noi, therefore, an LR drawing created for this system. Refer to LRA Section 2.3.3.B.21 for the system Scoping and Screening results. The AMR results for these components are described in LRA Section 3.3.2.B.21 and Table 3.3.2.B-21.
RAI-19 For NAMP2, please indicate whether heat exchangers and nozzles should be identified as core spray system components requiring AMR Please provide explanation.
Response
The NMP2 High Pressure Core Spray and Low Pressure Core Spray Systems nozzle components are in-scope for LR and subject to AMR. These components are addressed as part of the NMP2 Reactor Pressure Vessel System. Refer to LRA Section 2.3.1.B.1 (page 2.3-15) for Scoping and Screening results. The AMR for these components is described in LRA Section 3.1.2.B.1 (page 3.1-12) and Table 3.1.2.B-1 (page 3.1-79).
The NMP2 High Pressure Core Spray and Low Pressure Core Spray Systems do not have heat exchanger components. Heat exchangers are not part of the design of these NMP2 systems.
Refer to LRA Sections 2.3.2.B.3 (page 2.3-40) and 2.3.2.B.4 (page 2.3-42), respectively, for Scoping and Screening results.
Page 8 of 9
RAI-20
For NMP], please indicate wvhelerfilters or strainers, flow elements, and temperature elements, should be identified as liquidpoison system components requiringAMR. Please provide explanation.
Response
The NMP 1 Liquid Poison System does not contain filters, strainers, or flow elements in its design. Therefore, these components are not identified as requiring AMR.
With respect to temperature elements, the Liquid Poison System contains two elements that monitor the Liquid Poison Storage Tank temperature. One of these components is in-scope for LR since it is a safety-related component. The other component is non-safety-related and has no LR intended function. The in-scope temperature element itself is an active component and, therefore, not subject to AMR. However, the temperature sensor is housed in a thermowell that is subject to AMR. Since the thernowell is of the same material and exposed to the same environment as the storage tank it is included with the storage tank under the component type "Tanks" in Table 2.3.3.A-1 1 (page 2.3-84). See LRA Table 3.3.2.A-10 (page 3.3-142) for the AMR results for the Liquid Poison Storage Tank, including the in-scope thermowell, under the component type "Tanks."
RAI-21
For NMPI, please indicate whether bellows should be identified as neutron monitoring system components requiring AMR Please provide explanation.
Response
There are no bellows in the design of the NMP1 Neutron Monitoring System. The system is accurately described in LRA Section 2.3.3.A.13 (page 2.3-86). AMR results are given in LRA Table 3.3.2.A-12 (page 3.3-145).
Page 9 of 9
ATTACHMENT 2 Nine Mile Point Nuclear Station Nine Mile Point Unit 1 License Renewal Drawing LR-18000-C, Sheets 1 and 2
THIS-:PAGE IS AN OVERSIZED
-DRAWING OR FIGURE,-
THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG. NO. LR-1 8000-C LICENSE RENEWAL BOUNDARY DRAWING
- SYMBOLS,'NOTES, AND ACRONYMS" Sht 1, Rev 0 WITHIN -THIS PACKAGE..
OR BY SEARCHING USING DWG. NO. LR-18000-C 1D)O1
y; x
l
- -
t' Ili 4.
THIS PAGE IS AN OVERSIZED DRAWING OR
- FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED:
DWG...NO.. LR-1 8000-C.
"LICENS.E ^.RENEWAL.
BOUNDARYDRAWING.'-
SYMBOLS, NOTES, AND.,..
ACRONYMS" Sht '2, Rev 0 WITHIN THIS PACKAGE..
OR BY SEARCHING USING DWG., NO. LR-1 8000-C
- D-02 1<
-d