ML050120027

Amendment, Clarification of Instrument Channel Calibration Definition

ML050120027
Person / Time
Site:	Nine Mile Point
Issue date:	02/17/2005
From:	Tam P NRC/NRR/DLPM/LPD1
To:	Spina J Nine Mile Point
References
TAC MC4753
Download: ML050120027 (9)

Text

February 17, 2005 Mr. James A. Spina 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 - ISSUANCE OF AMENDMENT RE: CLARIFICATION OF INSTRUMENT CHANNEL CALIBRATION DEFINITION (TAC NO. MC4753)

Dear Mr. Spina:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit No. 1 (NMP-1). The amendment consists of changes to the Technical Specifications in response to your application transmitted by letter dated October 15, 2004.

The amendment revised Section 1.7, which defines the term Instrument Channel Calibration, by adding two new sentences pertaining to calibration of resistance temperature detector or thermocouple sensors.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

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

Enclosures:

1. Amendment No. 187 to DPR-63

2. Safety Evaluation cc w/encls: See next page

Mr. James A. Spina February 17, 2005 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 - ISSUANCE OF AMENDMENT RE: CLARIFICATION OF INSTRUMENT CHANNEL CALIBRATION DEFINITION (TAC NO. MC4753)

Dear Mr. Spina:

The Commission has issued the enclosed Amendment No. 187 to Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit No. 1 (NMP-1). The amendment consists of changes to the Technical Specifications in response to your application transmitted by letter dated October 15, 2004.

The amendment revised Section 1.7, which defines the term Instrument Channel Calibration, by adding two new sentences pertaining to calibration of resistance temperature detector or thermocouple sensors.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

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

Enclosures:

1. Amendment No. 187 to DPR-63

2. Safety Evaluation cc w/encls: See next page Distribution:

PUBLIC PDI R/F R. Laufer S. Little P. Tam OGC G. Hill (2) T. Boyce C. Schulten ACRS G. Matakas, RI Accession Number: ML050120027 OFFICE PDI-1\PM PDI-1\LA EEIB\SC IROB OGC PDI-1/SC NAME PTam SLittle EMarino SSchulten for TBoyce MYoung RLaufer DATE 2/15/05 1/14/05 1/19/05 1/19/05 2/14/05 2/15/05 OFFICIAL RECORD COPY

NINE MILE POINT NUCLEAR STATION, LLC (NMPNS)

DOCKET NO. 50-220 NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 187 License No. DPR-63

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nine Mile Point Nuclear Station, LLC (the licensee) dated October 15, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-63 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. 187, is hereby incorporated into this license. Nine Mile Point Nuclear Station, LLC shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Richard J. Laufer, Chief,Section I Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: February 17, 2005

ATTACHMENT TO LICENSE AMENDMENT NO. 187 TO FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains a marginal line indicating the area of change.

Remove Page Insert Page 4 4

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 187 TO FACILITY OPERATING LICENSE NO. DPR-63 NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-220

1.0 INTRODUCTION

By letter dated October 15, 2004 (Accession No. ML043010047), Nine Mile Point Nuclear Station, LLC (the licensee) submitted an application for amendment to the Nine Mile Point Nuclear Station, Unit No. 1 (NMP1) Technical Specifications (TSs). The amendment would revise Section 1.7, which defines the term Instrument Channel Calibration, by adding two new sentences pertaining to calibration of resistance temperature detector (RTD) or thermocouple sensors. The Nuclear Regulatory Commission (NRC) staffs review of the application follows.

2.0 REGULATORY EVALUATION

The licensee identified the applicable regulatory requirements in Section 5.2 of its application.

The regulatory requirement that the NRC staff considered in its review of application is 10 CFR 50.36, Technical specifications, which provides the regulatory requirements for the content required in a licensees TSs. Specifically, 10 CFR 50.36 requires that the TSs will include surveillance requirements to assure that the limiting conditions for operation will be met.

The proposed change does not affect the application of any regulatory requirement. The proposed change only clarifies the intent of existing requirements, i.e., the definition of the term Instrument Channel Calibration.

Section 1.1, Definitions, of NUREG-1433, Standard Technical Specifications General Electric Plants BWR/4, Revision 3 (STSs), has the following wording to define calibration of instrument channels with RTD or thermocouple sensors:

Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps.

The NRC staff compared the licensees proposed amendment against the guidance of NUREG-1433, Revision 3.

3.0 TECHNICAL EVALUATION

The licensee proposed to revise Section 1.7 of the TSs by adding two sentences referring to the RTD or thermocouple detectors. The revised section, with the new wording in italics, would read as follows:

1.7 Instrument Channel Calibration Instrument channel calibration means adjustment of channel output such that it responds, with acceptable range and accuracy, to known values of the parameter which the channel measures.

Calibration shall encompass the entire channel including equipment actuation, alarm, or trip. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The channel calibration may be performed by means of any series of sequential, overlapping, or total channel steps.

Most instrument channels contain an adjustable transmitter (sensor) which is subject to drift.

For most channels, instrument channel calibration includes adjustments to the sensor to establish proper input/output relationships. However, certain types of sensors, by their design, construction, and application exhibit an inherent resistance to drift. These types of sensors (such as RTDs and thermocouples) are designed such that they have a fixed input/output response which cannot be adjusted or changed once installed.

The licensee stated that if a credible mechanism that can cause change or drift in these non-adjustable sensors does not exist, it is unnecessary to test them in the same manner as the other remaining devices in the channel to demonstrate proper instrument channel operation.

The licensee further stated that since the current Section 1.7 does not have provision to treat the RTDs and thermocouples differently, the licensee had to physically remove these sensors for comparison against external standards. Such activities involved radiological exposure, but without commensurate benefit since comparison with a standard only verified functionality of the non-adjustable sensor. The licensee stated that an inplace verification on a qualitative basis would have accomplished the same finding of sensor functionality. Consequently, the licensee proposed the above italicized wording to Section 1.7.

The NRC staff reviewed the licensees technical justification for the proposed change. The proposed change affects only the method of surveillance; it does not involve any physical modification of the design, and does not change any performance criterion of the subject sensors. Under the amendment, the subject sensors will perform the same safety functions and to the same criteria as before. In addition, the NRC staff finds that the proposed wording is consistent with that of NUREG-1433. Therefore, the NRC staff concludes that the proposed change to Section 1.7 is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (69 FR 70719). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: P. Tam Date: February 17, 2005

Nine Mile Point Nuclear Station, Unit No. 1 cc:

Mr. Michael J. Wallace President Nine Mile Point Nuclear Station, LLC Mark J. Wetterhahn, Esquire c/o Constellation Energy Group Winston & Strawn 750 East Pratt Street 1400 L Street, NW Baltimore, MD 21202 Washington, DC 20005-3502 Mr. Mike Heffley Supervisor Senior Vice President and Chief Town of Scriba Nuclear Officer Route 8, Box 382 Constellation Generation Group Oswego, NY 13126 1997 Annapolis Exchange Parkway Suite 500 Mr. James M. Petro, Jr., Esquire Annapolis, MD 21401 Counsel Constellation Energy Group, Inc.

Regional Administrator, Region I 750 East Pratt Street, 5th Floor U.S. Nuclear Regulatory Commission Baltimore, MD 21202 475 Allendale Road King of Prussia, PA 19406 Ms. Deb Katz, Executive Director Nuclear Security Coalition Resident Inspector c/o Citizens Awareness Network U.S. Nuclear Regulatory Commission P.O. Box 83 P.O. Box 126 Shelburne Falls, MA 01370 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. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399