ML050460233

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. License Renewal Application - Responses to NRC Requests for Additional Information Regarding Sections 2.2, 2.3.3, and 2.3.4, and Scoping and Screening Methodology
ML050460233
Person / Time
Site: Nine Mile Point  Constellation icon.png
Issue date: 01/31/2005
From: O'Connor T
Constellation Energy Group
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L 1922, TAC MC3272, TAC MC3273
Download: ML050460233 (27)
v • d • e


Text

j Constellation Energy-RO. Box 63 Nine Mile Point Nuclear Station Lycoming, New York 13093 January 31, 2005 NMP1L 1922 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 Regarding Sections 2.2, 2.3.3, and 2.3.4, and Scoping and Screening Methodology (TAC Nos. MC3272 and MC3273)

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 19, 2004, the NRC requested additional information regarding Sections 2.2, 2.3.3, and 2.3.4 of the License Renewal Application. The NMPNS responses to those requests for additional information (RAIs) were provided in NMPNS letter NMPWL 1905 dated December 22, 2004; however, only partial responses were provided for four (4) of the RAIs. Additional information is provided in Attachment 1 to complete the NMPNS responses for those four RAIs. A copy of the license renewal boundary drawings associated with one of the RAI responses is provided in Attachment 3 to aid the NRC staff in their review. These drawings are for information only and are not considered part of the application.

In a letter dated November 22, 2004, the NRC requested additional information regarding the scoping and screening methodology utilized to prepare the License Renewal Application. The NMPNS responses to six (6) of those eight (8) RAIs were provided in NMPNS letter NMP iL 1904 dated December 22, 2004. Responses to the two remaining scoping and screening methodology RAIs are provided in Attachment 2.

Page 2 NMP1L 1922 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.

Ve ruly imo J. O'Connor Plan eneral Manager TJOJDEV/jm STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Timothy J. O'Connor, being duly sworn, state that I am Nine Mile Point Plant General Manager, 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 ther Nine Mile Point employees and/or consultants. Such information has en reviewed accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the St of New York and County of Oswego, this 31 so day of 9

n 2005.

WITNESS my Hand and Notarial Seal:

Notary Public My Commission Expires:

11 /3 05o Date SANDRA A. OSWALD Notary Public, State of New York No. o0os6032276 Qualified In Oswego Cpunt Commission Expires I

S

Page 3 NMP1L 1922 Attachments:

1. Responses to Four (4) NRC Requests for Additional Information (RAI) Regarding Sections 2.2, 2.3.3, and 2.3.4 of the License Renewal Application
2. Responses to Two (2) NRC Requests for Additional Information (RAI) Regarding Scoping and Screening Methodology
3. License Renewal Boundary Drawings Associated with the Response to RAI 2.3.3.B.22-1 Regarding the NMP2 Radiation Monitoring System 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 Four (4) NRC Requests for Additional Information (RAI)

Regarding Sections 2.2. 2.3.3, and 2.3.4 of the License Renewal Application In letter NMPIL 1905 dated December 22, 2004, Nine Mile Point Nuclear Station, LLC (NMPNS) provided responses to the requests for additional information (RAIs) contained in the NRC letter dated November 19, 2004; however, only partial responses were provided for four (4) of the RAIs. This attachment provides additional information to complete the NMPNS responses to those four RAIs. Each NRC RAI is repeated, followed by the revised NMPNS response for Nine Mile Point Unit 1 (NMP 1) and/or Nine Mile Point Unit 2 (NMP2), as applicable.

Revisions to the License Renewal Application (LRA) are described where appropriate. The revisions are highlighted by shading unless otherwise noted.

RAI 2.3.3.A.4-2 The LR drawings do not show air cylinders that are the actuators for valves, as being subject for AMR. This is based on the assumption that the valves will go to their fail-safe position on loss of air pressure. This would be true for single acting air cylinders with springs. But for double acting cylinders, one of the cylinders requires air pressure to effect valve repositioning to its fail-safe position. Therefore the double acting cylinders have a pressure boundaryfutnction. Provide the basis for excluding the double acting cylinders from AMR.

Response (Revised)

NMPNS has performed a reevaluation of the functions of valve actuators with double acting cylinders for NMP1 and has concluded that one actuator requires an aging management review while six others do not. The results of this review are described below.

NMP1 has valve actuators with double acting cylinders in the Containment Spray, Reactor Building Closed Loop Cooling (RBCLC), and Spent Fuel Pool Cooling (SFP) Systems.

1. There are four subject valves in the Containment Spray System. These are the containment spray drywell inlet isolation valves whose safety function is in the open position to provide water to the primary and secondary loops of the Containment Spray System for containment cooling. These valves do not have a safety function in the closed position since the containment isolation function of the Containment Spray System is met via a water seal (see NMP1 UFSAR Section VII.B). License Renewal (LR) drawing LR-18012-C, Sheet 2, shows these valves (IV-80-15, 80-16, 80-35, and 80-36) in their normally open position and Page I of 14

indicates that Note 8 is applicable. Note 8 is located on LR drawing LR-18012-C, Sheet 1, and states these valves "fail open on loss of electrical (DC) power and fail as is on loss of air." Since these valves are normally in the open position, fail "as is" on loss of air, and are not required to change position to perform their safety function, the double acting cylinder actuators do not require an aging management review.

2. The RBCLC System contains one valve with a double acting cylinder actuator. This valve is the temperature control valve for the system and regulates the amount of cooling provided to the RBCLC System from the Service Water System. This is one of the system and component safety functions. LR drawing LR-18022-C, Sheet 2, shows this valve (TCV 137). This valve has a fail safe position of "as is," so as to continue to provide the same amount of cooling to the RBCLC System loads in the event of a loss of air pressure to the actuator. Since the RBCLC temperature control valve requires air pressure to perform its safety function (i.e., to throttle to regulate system temperature), its associated double acting cylinder actuator requires an aging management review. The associated LRA changes are provided below.
3. There are two valves in the SFP System whose actuators have double acting cylinders. They are both shown on LR drawing LR-18008-C. One (BV-54-17) is the normally open pump suction valve from the spent fuel pool surge tanks. This valve has a fail safe position of "as is" to maintain cooling of the spent fuel pool water. The second valve (BV-54-18) is the normally closed pump suction valve from the reactor internals storage cavity. The safety function of this valve is in the closed position to form part of the pressure boundary for the spent fuel pool cooling system. This valve is only used during refueling operations when the water level is raised to support refueling operations. The open position for this valve does not perform a safety function. The fail safe position of this valve is "as is." Therefore, since both valves are normally in their required safe position and do not require a change in position to perform their safety function, their associated double acting cylinder actuators do not require an aging management review.

Based upon the above-described component safety functions and the fail safe position required for the subject valves, NMPI has one double acting cylinder actuator (RBCLC System valve TCV-70-137) that requires an aging management review.

LRA Revisions LRA Table 2.3.3.A.17-1 (page 2.3-98) is revised to add a new component type of "Actuator" with an intended function of "Pressure Boundary," as follows:

Page 2 of 14

Table 2.3.3.A.17-1 NMP1 Reactor Building Closed Loop Cooling Water System Component Type Intended Functions Actuator Pressure Boundary In LRA Section 3.3.2.A. 15 (page 3.3-28), under the "Environments" heading, "Dried Air or Gas" is added.

LRA Table 3.3.2.A-15 (page 3.3-15 1) is revised to add a row for the "Actuator" component type, as shown on the following page.

Page 3 of 14

Table 3.3.2.A-15 Auxiliary Systems NMP1 Reactor Building Closed Loop Cooling Wa er System - Summary of Aging Management Evaluation Aging Effect NUREG-Component Intended Material Environment Requiring Aging Management 1801 Table 1 Notes TpFucinManagement Program Volume 2 Item Actuators PB Aluminum Air None None None Dried Air or None None None a~

Page 4 of 14

RAI 2.3.3.B.54 The LR drawings do not show tieh air cylinders as part of the license renewal boutndary. This is based on the assumption that the valves will go to theirfail-safe position on loss of air pressure.

This would be truefor single acting air cylinders with springs. Butfor double acting cylinders, one of the cylinders requires air pressure to effect valve repositioning to itsfail-safe position.

Therefore the double acting cylinders have a pressure boundary function. Please provide the basis for excluding the double acting cylinders from AMR.

Response (Revised)

NMPNS has performed a reevaluation of the functions of valve actuators with double acting cylinders for NMP2 and has concluded that these components in the Standby Gas Treatment System perform a pressure boundary intended function for license renewal. Therefore, these actuators required an aging management review. The results of this review are described below and are included in a revision to the LRA, which is also described below.

NMP2 has valve actuators with double acting cylinders in the Main Steam and Standby Gas Treatment (GTS) Systems. The applicable valves in Main Steam System are the Main Steam Isolation Valves and are addressed in the response to RAI 2.3.4.B.4-2 below.

For the GTS System, one of its safety functions is to maintain a negative pressure in the Reactor Building under accident conditions. This is accomplished by recycling a portion of the GTS fan discharge through pressure control valves. These pressure control valves (one for each division of GTS) are air operated valves with actuators having double acting cylinders. During their design basis operation, the valves modulate to control pressure, which requires air pressure on both sides of the air cylinder. Therefore, for the valve to perform its safety function, the actuator has a pressure boundary function for license renewal. As such, LRA Table 3.2.2.B-6 is being revised to add an "Actuator" component type and the corresponding results from the aging management review.

LRA Revisions LRA Table 2.3.2.B.8-1 (page 2.3-52) is revised to add a new component type of "Actuator" with an intended function of "Pressure Boundary," as follows:

Table 2.3.2.B.8-1 NMP2 Standby Gas Treatment System Component Type Intended Functions Actuator Pressure Boundary Page 5 of 14

In LRA Section 3.2.2.B.6 (page 3.2-17), under the "Environments" heading, "Dried Air or Gas" is added.

LRA Table 3.2.2.B-6 (page 3.2-107) is revised to add a row for the "Actuator" component type, as shown on the following page.

Page 6 of 14

Table 3.2.2.B-6 Engineered Safety Features Systems NMP2 Standby Gas Treatment System - Summary of Agin Management Evaluation Copnn neddAging Effect Aging NUREG-Component Material Environment Requiring Management 1801 Table 1 Notes Type Function MaaeetPormVolume 2

Item Management ProgramItem Actuator PB Carbon or Low Air Loss of Material Systems Walkdown V.E.1-b 3.2.1.B-10 A

Alloy Steel Programn (Yield Ste66g-li Dried Air or None None None

_<,1OOKsi)

Gas, Page 7 of 14

RAI 2.3.3.B.22-1 LRA Section 2.3.3.B.22 states that:

"Tile NMP2 radiation monitoring system is designed to initiate appropriate manual or automatic protective action to limiit the potential release of radioactive materials from the reactor vessel, primary and secondary containment, and fiel storage areas ifpredetennined radiation levels are exceeded in major/process effluent streams, and to provide main control room personnel with radiation level indication throughout the course of accident. The radiation monitoring system consists of a computter-based digital radiation monitoring system, a computer-based gaseous effluent monitoring system, and a main stem line radiation monitors."

LRA Section 2.3.3.B.22 regarding the NMP2 radiation monitoring system states that "portions of the system consists of off-line gas and liquid monitors which consist of piping, filters, pumps, sampler/detectors, valves; and instrument. Tile applicant did not identify the radiation monitoring system components that are in scope of license renewal due to JOUFR54.4(a)(1) and IOFUR54.4(a)(2). Furthermore, an LR drawing for tile NMP2 radiation monitoring system was not provided to show the portions of this system containing components within the scope of license renewal. Please identify the components of tie radiation monitoring system that are in-scope of license renewal in accordance with the requirements of IOCFR54.4(a)(1) and JOFR54.4(a)(2), and justify the exclusion of these components from being subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

Response (Revised)

The NMP2 Radiation Monitoring System contains components that are subject to aging management review; however, they were inadvertently omitted from the original LRA. These components are the piping, pumps, filters, flow elements, and valves that allow sampling of the process system fluid for radioactivity. The process systems that are monitored for radioactivity and whose radiation monitoring function are within the scope of license renewal are the Containment Monitoring (CMS), Control Building Ventilation (HVC), Reactor Building Ventilation (HVR), and Service Water (SWP) Systems. The results of the aging management reviews conclude that for the CMS, HVC and HVR systems, there are no aging effects since the components are made of wrought austenitic stainless steel and are exposed to an Air environment. For the radiation monitoring components in the SWP system, they are also constructed of wrought austenitic stainless steel but are exposed to a Raw Water environment.

As such, the applicable aging effect is Loss of Material due to pitting, crevice, and microbiologically influenced corrosion. The associated aging management program is the Preventive Maintenance Program. Corresponding LRA revisions are described below.

A copy of the license renewal (LR) boundary drawings showing the Radiation Monitoring System (i.e., those listed below) is provided in Attachment 3 to aid the NRC staff in their review.

These drawings are for information only and are not considered part of the application.

Page 8 of 14

LRA Revisions In Section 2.3.3.B.22 (page 2.3-163), under the "License Renewal Drawing(s)" heading, "None (see Components Subject to an AMR below)" is deleted and replaced with the following:

"Components requiring an AMR for the Radiation Monitoring System are highlighted on the following drawings:

  • LR-53, Sheet B, Control Building Ventilation
  • LR-82, Sheet A, Containment Atmosphere Monitoring
  • LR-400762, P&ID DRMS Offline Gas Monitor Control Room Ventilation
  • LR-400863, P&ID DRMS Offline Gas Particulate Monitor Containment Monitoring System" In Section 2.3.3.B.22 (page 2.3-163), under the "Components Subject to an AMR" heading, the existing paragraph is deleted and replaced with the following:

"The component types requiring an AMR for the Radiation Monitoring System and their intended functions are shown in Table 2.3.3.B.22-1. The AMR results for these component types are provided in Table 3.3.2.B-32.

Page 9 of 14

Table 2.3.3.B.22-1 NMP2 Radiation Monitoring System Component Type Intended Functions Filters Pressure Boundary, Filtration Flow Elements Pressure Boundary, Flow Restriction Piping and Fittings Pressure Boundary Pumps Pressure Boundary Valves Pressure Boundary" In Section 3.3.1 (page 3.3-3), under the "NMP2" heading, add the following:

"NMP2 Radiation Monitoring System (Section 2.3.3.B.22)"

In Section 3.3.2 (page 3.3-7), under the 'NMP2" heading, add the following:

"Table 3.3.2.B-32 Auxiliary System -NMP2 Radiation Monitoring System - Summary of Aging Management Evaluation" In Section 3.3.2 (page 3.3-10), under the "NMP2" heading, add the following:

"Section 3.3.2.B.32, NMP2 Radiation Monitoring System" New Section 3.3.2.B.32, "NMP2 Radiation Monitoring System," is added, as follows:

"3.3.2.B.32 NMP2 Radiation Monitoring System Material The material of construction for the NMP2 Radiation Monitoring System components is:

  • Wrought Austenitic Stainless Steel Environments The NMP2 Radiation Monitoring System components are exposed to the following environments:
  • Air
  • Raw Water Page 10 of 14

Aging Effect Requiring Management The following aging effect, associated with the NMP2 Radiation Monitoring System, requires management:

  • Preventive Maintenance Program" In Table 3.3.1.B (page 3.3-94), the "Discussion" column for Item Number 3.3.1.B-17 is revised to address the Radiation Monitoring System, as shown on the following pages.

New Table 3.3.2.B-32 is added to incorporate the aging management evaluation summary for the NMP2 Radiation Monitoring System components, as shown on the following pages.

Page 11 of 14

Table 3.3.1.B NMP2 Summary of Aging Management Programs for the Auxiliary Systems Evaluated in Chapter VII of NUREG-1801 Item Aging Effect!

Aging Further Number Component Mechanism Management Evaluation Discussion Programs Recommended 3.3.1.B-17 Components in or Loss of material due to Open-cycle cooling No Consistent with NUREG-1801. Additionally, serviced by open-general, pitting, crevice, water system the following components are consistent cycle cooling and galvanic corrosion, with, but not addressed in NUREG-1801:

water systems MIC, and biofouling;

  • Flow elements buildup of deposit due
  • Temperature elements Additionally, for the NMP2 Reactor Building carbon steel floor drain lines and valves, the NMP2 Control Building HVAC carbon steel valves, and the NMP2 Floor and Equipment Drains stainless steel flow elements that are in a raw water environment, the One-Time Inspection Program (Appendix B2.1.20) is credited for managing the aging effect of loss of material. For the NMP2 Reactor Building stainless steel floor drain lines and the carbon steel Control Building HVAC piping and fittings, the Preventive Maintenance Program (Appendix B2.1.32) is credited for managing the aging effect of loss of material in raw water environment.

ForMhe iMt2 Radiati Sytm Monitor associated with' the Service Water System, 'the Preventive Maintenanic'e Program is also credited for the 'aging

'management'of the associated components in lieu of the Open-Cycle Cooling Water System Program.'

Page 12 of 14

Table 3.3.2.B-32 Auxiliary Systems Monitorina System - Summary of Aaina Manaaement Evaluation NMP2 Radiation Copnn neddAging Effect Aging NUREG-Tal Typoe Functionde Material Environment Requiring Management Volum 2 aitem1 Notes TpFucinManagement Program Voemume_2_Item Filters PB Wrought Air None None None FLT Austenitic Stainless Steel Flow Elements PB Wrought Raw Water Loss of Material Preventive VII.C1.4-a 3.3.1.B-17 E,Q FR Austenitic Maintenance Stainless Steel Program Air None None None Piping and PB Wrought Raw Water Loss of Material Preventive VIL.C1.1-a 3.3.1.B-17 E

Fittings Austenitic Maintenance Stainless Steel Program Air None None None Pumps PB Wrought Raw Water Loss of Material Preventive VIL.CI.4-a 3.3.1.B-17 E, Q Austenitic Maintenance Stainless Steel Program Air None None None Valves PB Wrought Raw Water Loss of Material Preventive VII.C1.2-a 3.3.13.B-17 E

Austenitic Maintenance Stainless Steel Program Air None None None Page 13 of 14

RAI 2.3.4.B.4-2 LR drawvings LR-JE-0 and LR-JF-O show the inboard and outboard MSJVs, respectively, for each of the four main steam lines. These valves perfonn a safety-relatedfunction (system isolation) and are shown as requiring AMR on the drawings. However, the pneumatic actuators for these valves are not shown to require AMR. Since the actuators are required to effect operation of the MSIVs, the staff believes they should likewise be subject to AMR. Please justify exclusion of the MSIV actuators from requiring AMR.

Response (Revised)

NMPNS has reviewed the function of the NMP2 main steam isolation valve (MSIV) actuators and has concluded that an aging management review is not required for license renewal. The eight MSIVs are air operated valves that are normally open and have a fail safe position of closed. The actuator is a double acting cylinder and air is used to move the valve in both the open and closed directions. The valves are also equipped with a closing spring. These springs will close the valves upon loss of air pressure. While valve closure following loss of air is assisted by air from an air tank accumulator directed to the top of the actuator cylinder, the closing spring forces are sufficient to meet the accident analysis time limit (3 to 10 seconds) for MSIV closure without the air assist feature. Therefore, the air pressure boundary function of the actuators is not required for the MSIVs to travel to their fail-safe (closed) position. More information regarding the design and evaluation of the MSIVs is available in NMP2 USAR Section 5.4.5.

Page 14 of 14

ATTACHMENT 2 Nine Mile Point Nuclear Station Responses to Two (2) NRC Requests for Additional Information (RAI)

Regarding Scoping and Screening Methodologv In letter NMP1L 1904 dated December 22,2004, Nine Mile Point Nuclear Station, LLC (NMPNS) provided responses to six (6) of the eight (8) requests for additional information (RAIs) contained in the NRC letter dated November 22, 2004. This attachment provides the NMPNS responses to the two remaining RAIs. Each NRC RAI is repeated, followed by the NMPNS response for Nine Mile Point Unit 1 (NMP1) and/or Nine Mile Point Unit 2 (NMP2), as applicable.

RAI 2.1 10 CFR 54.4(a)(1) Scoping of Safety-Related SSCs 10 CFR 54.4(a)(1)(iii) requires, in part, that the applicant consider wvithin the scope of license renewal those systems, structures, and components that ensure the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in '50.34(a)(1), '50.67(b)(2), or '100.11. In Section 2.1.1.1, "Application of Safety-Related Scoping Criteria, " of the LRA, the applicant stated that, because of plant-unique considerations or preferences, some components classified as safety-related in the facility database did not perfonn any of the safety-related intendedfiunctions of 10 CFR 54.4(a)(1). The applicant stated that these components may have beemn considered outside the scope of 10 CFR 54.4(a)(1). During the audit, the applicant described the process used to evaluate components classified as safety-related that did not perfonn a safety-related intended fiunction. As part of the process, the applicant stated that the safety-classification of many safety-related components was re-evaluated in order to reconcile differences between scoping deterninations andfacility database information. Based on the audit, the staff requests a description of the process used during license renewal scoping activities to disposition components classified as safety-related that do not perform a safety-related intendedfiunction.

In particular, the staff requests the applicant provide the following infonration:

a.

A description of any components or structures classified as safety-related in the facility safety-classtfication database that wvere not included within the scope of license renewal under the 10 CFR 54.4(a)(1) criteria. This description should include the basisfor determining that these components do not perfonn a safety-related intendedfiunction.

The response should also indicate if these components wvere included within the scope of license renewal under a different scoping criteria (e.g. '54.4(a)(2) or (a)(3)).

Page 1 of 5

b.

Describe the process used to reconcile thefacility database safety classification information with scoping intendedfunction determinations. In particular, the staff requests a description of the process including the scope of the review used to re-evaluate the safety-classification of SSCs to reconcile disparities with intended function determinations.

Response

a. During the scoping and screening process for the Nine Mile Point (NMP) License Renewal Application (LRA) a small percentage of components were identified as being classified as safety-related but were not required to meet any intended function for compliance with 10 CFR 54.4(a)(1). These discrepancies were entered into the NMP correction action program for resolution. The following provides more information regarding the subject components identified for NMP1 and NMP2 and their resolution.

NMPI Several components in non-safety related (NSR) systems were classified as safety-related (SR) in the plant component database (i.e., MEL1) when the license renewal project was started, but have since been reclassified as NSR. These components were entered into the corrective action program and reclassified in accordance with the design change process.

Those components that contain liquid and are in the vicinity of SR equipment are still, however, considered within the scope of license renewal for criterion 10 CFR 54.4(a)(2).

Also, there were instances of components identified as SR during the scoping and screening process that have been removed from the plant via the modification process. These components have been moved to the plant historical database.

Both of the above situations represent administrative issues and did not result in properly classified SR components being excluded from the scope of license renewal.

There are also components in MELl classified as SR that have been abandoned in place.

These components are not within the scope of license renewal as they perform no system function and, therefore, do not perform any license renewal intended function. The reason that they have not been removed from MEL1 is that they are still installed in the plant. The reason for not reclassifying them as NSR is for historical purposes. There is, however, a comment associated with each component in the database that identifies them as being abandoned in place. This situation also represents an administrative issue and did not result in any SR components being excluded from the scope of license renewal.

There are two SR components identified in MELI associated with the Main Steam System that are not within the scope of license renewal. These components are the main steam line nozzle plugs. These plugs are tools used to support maintenance activities during refueling outages. These plugs are classified in the database as SR, but are not required to accomplish any of the system intended functions and do not meet any of the license renewal scoping Page 2 of 5

criteria. Therefore, the two MSL plugs are not considered within the scope of license renewal.

NMP2 Similar to NMP1, NMP2 also had components originally classified as SR that were reclassified as NSR during the course of the license renewal project. They were resolved in accordance with the corrective action program and the design change process. However, those components that contain water and are in the vicinity of SR equipment are within the scope of license renewal for criterion 10 CFR 54.4(a)(2). This situation represents an administrative issue and did not result in any SR components being excluded from the scope of license renewal.

The NMP2 plant database (i.e., MEL2) also contains components classified as SR that are abandoned in place. The justification for this designation is the same as provided for NMP1 above. This situation also represents an administrative issue and did not result in any SR components being excluded from the scope of license renewal.

The NMP2 plant database has two additional SR pieces of equipment that fall outside of license renewal scoping criteria. The first is the Diesel Generator Building Ventilation System spare SR fan stored in the warehouse. Since it is not installed in the plant, it supports no system intended function and, therefore, does not meet any of the license renewal scoping criteria. The second piece of equipment is an uninstalled spare pump. Similarly, since it is not installed in the plant, it supports no system intended function and does not meet any of the license renewal scoping criteria. This situation represents an administrative issue and did not result in any SR components being excluded from the scope of license renewal.

b. For those situations where a SR component was identified that did not appear to meet the 10 CFR 54.4(a)(1) criterion, NMP utilized a multi-tier review process. The process began with the identification of an apparent discrepancy. The LR team member would review the situation with a system and/or design engineer to obtain more information. If it still appeared that there was a component identified as SR that did not support a SR system function, it would be elevated to license renewal project supervision. If it could not be resolved at that point or if the plant database required a revision, then the issue was entered into the corrective action program for resolution. For any resolution that required a change to a design document or the plant database, the design and/or configuration change process was used. Both of these processes require a review and approval of the change by an individual other than the preparer. The resolutions of these discrepancies were then fed back to the LR team member for proper incorporation into the scoping and screening process.

Page 3 of 5

RAI 2.1 Evaluation of Insulation During the audit, the applicant was unable to adequately describe the evaluation that was performed to determine ifany insulation installed in the plant was required to support any system intendedfunctions identified during the scoping process. As a result, the staff requests that the applicant describe any intendedfunctions performed by insulation or the basis for determining that insulation (e.g. piping insulation) did not meet the scoping criteria described in 10 CFR 54.4 (a) (1), (a)(2) or (a)(3).

Response

NMPNS evaluated thermal insulation used at NMP1 and NMP2 to determine if any license renewal functions per 10 CFR 54.4(a)(1), (a)(2), or (a)(3) were performed. The only intended function to meet the license renewal scoping criteria was fire wrap, used for fire protection, which meets criterion (a)(3). The following provides the results of the review performed for thermal insulation for each of the license renewal scoping criteria.

10 CFR 54.4(a)(1): Insulation is not relied upon to remain functional during and following design-basis events (as defined in 10 CFR 50.49 (b)(l)) to ensure any of the following functions:

(i)

The integrity of the reactor coolant pressure boundary; (ii)

The capability to shut down the reactor and maintain it in a safe shutdown condition; or (iii) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in § 50.34(a)(1),

§ 50.67(b)(2), or § 100.11.

To meet criterion (a)(l), the insulation function must provide for maintaining safety-related structures, systems, or components (SSCs) within their accident design limits following a design basis accident, such that the SSC safety-related intended function could be performed.

Thermal insulation, other than the fire wrap, is used only to maintain SSCs in a state of operational readiness. Normal station actions, such as operator rounds, surveillances, and temperature monitoring, provide confidence that appropriate operating parameters are met.

Corrective actions are taken as needed when deviations are encountered. However, maintenance of SSCs in a state of readiness does'not meet the three functions covered under criterion 10 CFR 54.4(a)(1).

10 CFR 54.4(a)(2): No credible failure of insulation was discovered that could prevent satisfactory accomplishment of any of the functions identified in § 54.4(a)(1). To meet criterion (a)(2), the insulation would have to fail so as to prevent the fulfillment of a system intended function. Insulation was evaluated to that end in the early 1990s, relative to engineered safety systems taking suction from suppression pools, and significant changes were made to the suction strainer systems so that unacceptable consequences would not occur. Thus, insulation does not come into scope under the (a)(2) criterion.

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10 CFR 54.4(a)(3): Insulation is not relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for fire protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), or station blackout (10 CFR 50.63).

As stated above, the only intended function to meet the license renewal scoping criteria was fire wrap, used for fire protection and meeting criterion (a)(3). These structural steel fire protection coatings are in scope and subject to aging management review (AMR). They are included as Component Type "Fire Wrap in Air" in LRA Table 2.4.C.2-1. The AMR of the fire wrap is addressed in LRA Section 3.5.2.C.2 and in Table 3.5.2.C-2. Therefore, other than fire wrap, insulation is not in scope for license renewal for either NMP1 or NMP2.

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ATTACHMENT 3 Nine Mile Point Nuclear Station License Renewal Boundary Drawings Associated with the Response to RAI 2.3.3.B.22-1 Regarding the NMP2 Radiation Monitoring System The following "for information only" license renewal drawings are provided in this attachment:

  • LR-400762, P&ID DRMS Offline Gas Monitor Control Room Ventilation
  • LR-400863, P&ID DRMS Offline Gas Particulate Monitor Containment Monitoring System
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