ML050560199
| ML050560199 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/11/2005 |
| From: | Spina J Constellation Energy Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP1L 1927, TAC MC3272, TAC MC3273 | |
| Download: ML050560199 (19) | |
Text
Constellation Energy-P.O. Box 63 Lycoming, NY 13093 Nine Mile Point Nuclear Station February 11, 2005 NMP1L 1927 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 - Submittal of Supplemental Information for Review of the License Renewal Application (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.
This letter provides supplemental and/or clarifying information for previously submitted responses to NRC audit issues and requests for additional information, in response to NRC email requests and subsequent telephone conferences. This information is provided in Attachments 1 through 4. 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, J
esA. Spina ice President Nine Mile Point JAS/DEV/sac
Page 2 NMP1L 1927 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 e State of New York and County of Oswego, this 114 " day of 2005.
WITNESS my Hand and Notarial Seal:
Notary Public My Commission Expires'
-/ los SANDRA A. OSWALD Date Notary Public. State of New York No. 010S6032276 Qualified In Oswego County Commission Expires
.6/2, 51f Attachments:
- 1. Supplemental Information for Previous Responses to NRC Requests for Additional Information Regarding Sections 2.2, 2.3.3, and 2.3.4 of the License Renewal Application
- 2. Supplemental Information for Previous Responses to NRC Request for Additional Information Regarding Fire' Detection and Protection Systems
- 3. Supplemental Information to Resolve Follow-up Questions Identified During the NRC Review of Section 3.1 of the License Renewal Application
- 4. Revised License Renewal Boundary Drawing Associated with the Response to RAI 2.3.3.A.16-1 Regarding the NMP1 Waste Disposal 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 Supplemental Information for Previous Responses to NRC Requests for Additional Information Regarding Sections 2.2, 2.3.3, and 2.3.4 of the License Renewal Application In letter NMP 1L 1905 dated December 22, 2004, Nine Mile Point Nuclear Station, LLC (NMPNS) provided responses to requests for additional information (RAI) contained in the NRC letter dated November 19, 2004. In response to an NRC email to NMPNS on January 13, 2005 (Accession Nos. ML050240431 and ML050210376), and subsequent discussions in a telephone conference between NRC and NMPNS representatives on January 27, 2005, NMPNS provides the following supplemental and/or clarifying information for certain RAIs identified below. For each subject RAI, the NRC Staff's evaluation of the original NMPNS response is repeated (from the January 27, 2005 email), followed by the supplemental NMPNS response for Nine Mile Point Unit 1 (NMP1) and/or Nine Mile Point Unit 2 (NMP2), as applicable. Revisions to the LRA are described where appropriate. The revisions are highlighted by shading unless otherwise noted.
RAI 2.3.3.A.2-2. Staff's Evaluation Based on its review, staff is not able to find the applicant s response to RAI 2.3.3.A.2-2 acceptable because it did not describe what systems the circulating water gates finctionally support in addition to maintaining screenhouseforebay level and temperature.
Supplemental Response The circulating water gates in the intake and discharge tunnels, and their support structure, direct the flow of water from Lake Ontario (the ultimate heat sink) into and out of NMP1. These gates are normally in the full-up position. There is also a normally closed cross-tie gate (Gate E shown on NMP 1 Updated Final Safety Analysis Report Figure III-19) that allows for tempering of the intake water during cold weather conditions. This gate is throttled open to regulate the temperature in the intake tunnel. As such, the function of the gates is similar to that of valve internals.
The circulating water gates and their support structure support the safety-related functions of the emergency service water, containment spray raw water, and diesel generator cooling water systems. They also support the fire protection function for the fire water system. The gates must remain in their fully open position unless manually throttled for tempering. This function is Page 1 of 6
included in the "catch-all" function for non-safety-related (NSR) components that is termed "NSR Functional Support" in the LRA (reference LRA Table 2.0-1).
RAI 2.3.3.A.16-1. Staffs Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.A.16-1 acceptable. Although, it clarified that the both drywell equipinent drain tanks (D WEDT) and the reactor building equipment drain tank (RBEDT) are subject to aging management review (AMR), it did not adequately justify the exclusion of the piping and associated isolation valves inputs to the RBEDT and D WED Tsfrom being in scope and subject to an AMR. In addition, the applicant stated that license renewal drawing LR-18045-C, sheet 7A does not add any information to LR-18045-C, sheet 7 and should be disregarded. However, the applicant did not explain the inconsistency between these two sheets.
Supplemental Response The lines providing inputs to the DWEDT and RBEDT are non-safety-related lines. Therefore, they do not meet the 10 CFR 54.4(a)(1) criterion. However, since they contain water, at least some of the time, they do meet the 10 CFR 54.4(a)(2) criterion and are subject to aging management review (AMR). These lines are included in the component type "NSR piping, fittings, and equipment" in LRA Table 2.3.3.A.16-1.
A revised copy of license renewal boundary drawing LR-1 8045-C, Sheet 7, that correctly displays the portions of the waste disposal system that are in-scope for license renewal for criteria (a)(1) and (a)(3), is provided in Attachment 4. The NSR piping, fittings, and equipment shown on this drawing that are located in the Primary Containment, Reactor Building, Turbine Building, Radwaste Solidification and Storage Building, and Waste Disposal Building are also in-scope for license renewal under criterion (a)(2).
RAI 2.3.3.A.16-6 (Part b). Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.A. 16-6b acceptable because although it stated that the depiction of the input lines to the RBEDT on drawing LR-18045-C, Sheets 7 and 7A, are contrary to the above-referenced description due to drafting errors, it did not adequately identify which of the license renewal drawings are correct.
In addition, the applicant stated that license renewal drawing LR-18045-C, sheet 7A does not add any information to LR-18045-C, sheet 7 and should be disregarded.
Supplemental Response NMPNS acknowledges that errors were made between drawings LR-1 8045-C, Sheets 7 and 7A.
A revised copy of drawing LR-1 8045-C, Sheet 7, that correctly displays the portions of the waste disposal system that are in-scope for license renewal for criteria (a)(1) and (a)(3), is provided in. Drawing LR-18045-C, Sheet 7A, Revision 0, is now obsolete and should be disregarded.
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RAI 2.3.3.A.19-1. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.A.19-1 acceptable because 1) the applicant in its response stated that the pump oil cooler is in-scope and subject to an AMR to meet criterion 10 CFR 54.4(a)(2); however, the LRA Tables 2.3.3.A. 19 and 3.3.3.A-1 7 do not include heat exchangers with the intended finction ofPFSARE in a lubricating oil environment, 2) the applicant also stated that the drawing boundaryflags are incorrect and the `LR-CU" side of each of those flags should be solid blue. This does not appear to be correct, since the oil cooler tubes are in-scope of license renewal with the pressure boundary intendedfunction for the reactor building closed loop cooling system.
Supplemental Response The Reactor Water Cleanup (RWCU) pump oil coolers are in-scope for license renewal since they are a pressure boundary for the Reactor Building Closed Loop Cooling (RBCLC) system.
As such, only those portions of the oil coolers that are exposed to RBCLC water (the end covers, tube sheets, and tubes) are in-scope and subject to AMR. The external surfaces of the oil cooler tubes exposed to the lubricating oil are in-scope but have no aging effects requiring management.
LRA Revisions (Note that the following LRA revisions are based on the version of LRA Section 3.3 that was submitted by NMPNS letter NMP1L 1923 dated February 4, 2005.)
In LRA Section 3.3.2.A.17 (page 3.3-29), under the "Materials" heading, "Copper Alloys (Zinc
<15%)" is added. Also, under the "Environments" heading, "Lubricating Oil" is added.
LRA Table 3.3.2.A-17 (page 3.3-147) is revised to include a row for the RWCU pump oil cooler tubes, as shown on the following page.
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Table 3.3.2.A-17 Auxiliary Systems Reactor Water Cloanun Svstam - Summarv of Anina Manainpmnnt Evaluiation NMP1 Copnn neddAging Effect NUREG-l oTponent In tende Material Environment Requiring Aging Management 1801 Table I Notes Type Function MaaeetProgram Volume 2 Item ManagmentItem Bolting PB Carbon or Low Air Loss of Material Bolting Integrity V11.1.1-b 3.3.1.A-05 D, 5 Alloy Steel Program (Yield Strength 2_ 100 Ksi)
Heat PB Carbon or Low Demineralized Loss of Material Closed-Cycle N
Exchangers Alloy Steel Untreated Cooling Water (Yield Strength Water, Low System Program
< 100 Ksi)
Flow Treated Water Cumulative Fatigue Monitoring M
or Steam, Fatigue Damage Program temperature Loss of Material Flow-Accelerated M
Ž2120F, but Corrosion Program
< 4820F Copper Alloys Demineralized None None None (Zinc *15%)
Untreated Water_
Lubricating Oil None None None Wrought Demineralized None None None Austenitic Untreated Stainless Steel Water Treated Water Cracking One-Time VII.E3.4-a 3.3.1.A-04 B
or Steam, Inspection Program temperature 21400 F, but Water Chemistry
< 212 0F Control Program Page 4 of 6
RAI 2.3.3.B.17-2. Staff Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B. 17-2 acceptable because the applicant did not describe the safety-related components in the radwaste building with which hot water heating system components can interact.
Supplemental Response The methodology employed for determining those NSR systems and components in the Radwaste Building that are in-scope for license renewal was based on the building in which the system/component was located. This approach is conservative in that it brings into scope many more components than would be required if detailed walkdowns were performed. As such, NMPNS did not specifically identify the safety-related (SR) components with which the hot water heating system could interact.
RAI 2.3.3.B.25-2. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B.25-2 acceptable because 1) it does not explain why reactor water cleanup heat exchangers andpumnps are listed in NMP2 UFSAR Table 3.9B-2 as a major safety-related component in the plant, if they are not safety-related; and 2) in accordance with NMP2 UFSAR Table 3.2-1, reactor water cleanup heat exchangers and pumps are classified as ASME Safety Class 3, which differs from the applicant s response.
Supplemental Response NMPNS acknowledges that a discrepancy exists between different sections of the NMP2 Updated Safety Analysis Report (USAR). The RWCU pump and heat exchangers are non-safety-related components but were evaluated as ASME Section III, Safety Class 3 components.
NMPNS applied design criteria that exceed those required based upon the RWCU component safety classifications. USAR Section 3.9B.3.1.14 states:
"The RWCU pump and regenerative and non-regenerative heat exchangers are not part of a safety system and are not designed to Category I requirements.
The requirements of ASME Boiler and Pressure Vessel Code,Section III, Safety Class 3 components are used as guidelines in evaluating the RWCU system pump and heat exchanger components. The loading conditions, stress criteria, and calculated and allowable stresses are summarized in Tables 3.9B-2w and 3.9B-2x."
USAR Section 5.4.8 provides the description of the RWCU System and states that the portion of the system from the RPV to the outboard isolation valves is SR and the remainder of the system is NSR.
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(
The discrepancy between the USAR sections has been placed into the site corrective action program for resolution. The resolution of this issue is not considered an impact to license renewal since the components are in-scope under 10 CFR 54.4(a)(2) and subject to AMR.
RAI 2.3.4.A.3-2. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.4.A.3-2 acceptable because it does not adequately explain what intended functions "NSR Functional Support" represents and how it is applied to all the component types in the feedwvater/high pressure coolant injection system includingfilters/strainers, flow elements, flow indicators, and flow orifices.
Supplemental Response The "NSR Functional Support" is a "catch-all" function for NSR components that NMPNS recognizes has caused confusion. The following table provides clarifying information regarding the intended functions for components in the Feedwater (FW)/High Pressure Coolant Injection (HPCI) system.
NMP1 FWAIHPCI Intended Functions Component Type l LR Intended Function System/Component I_
I Function Bolting NSR Functional Support Pressure Boundary Pressure Boundary Pressure Boundary Feedwater Heaters NSR Functional Support Pressure Boundary Filters/Strainers NSR Functional Support Pressure Boundary, Filtration (Lube Oil Filters Only)
Pressure Boundary Flow Elements NSR Functional Support Pressure Boundary, Flow Restriction (FW Pumps 11 and 12 Flow Only)
Pressure Boundary Flow Indicators NSR Functional Support Pressure Boundary Flow Orifices NSR Functional Support Pressure Boundary NSR piping, fittings, and Prevent Failure from Pressure Boundary equipment affecting SR Equipment Oil Coolers NSR Functional Support Pressure Boundary Piping and Fittings NSR Functional Support Pressure Boundary Pressure Boundary Pressure Boundary Pumps NSR Functional Support Pressure Boundary Valves NSR Functional Support Pressure Boundary Pressure Boundary Pressure Boundary Page 6 of 6
ATTACHMENT 2 Nine Mile Point Nuclear Station Supplemental Information for Previous Responses to NRC Requests for Additional Information Regarding Fire Detection and Protection Systems In letter NMPIL 1899 dated December 17, 2004, Nine Mile Point Nuclear Station, LLC (NMPNS) provided responses to requests for additional information (RAI) contained in the NRC letter dated November 17, 2004, regarding fire detection and protection systems. In response to an NRC email to NMPNS on January 13, 2005 (Accession Nos. ML050240438 and ML050240424), and subsequent discussions in a telephone conference between NRC and NMPNS representatives on January 25, 2005, NMPNS provides the following supplemental and/or clarifying information for certain RAIs identified below. For each subject RAI, the NRC Staff's evaluation of the original NMPNS response is repeated (from the January 25, 2005 email), followed by the supplemental NMPNS response.
RAI 2.3.3.A.9-7. Staff's Evaluation Based on its review, the staff is not able to find the applicants response to RAI 2.3.3.A.9-7 acceptable because it does not adequately explain what intendedfunctions, WSR Functional Support"represent and how it is applied to all the component types in thefire detection and protection system including piping, valves, strainers, pumps, and orifices.
Supplemental Response The `NSR Functional Support" is a "catch-all" function for NSR components that NMPNS recognizes has caused confusion. The following table provides clarifying information regarding the intended functions for components in the Fire Detection and Protection systems.
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Fire Detection and Protection System Intended Functions Component Type LR Intended Function 1 System/Component
_Function Bolting NSR Functional Support Pressure Boundary Filters/Strainers NSR Functional Support Pressure Boundary Pressure Boundary, Filtration Fire Hydrants NSR Functional Support Pressure Boundary Flow Elements NSR Functional Support Pressure Boundary Gearbox NSR Functional Support Pressure Boundary Heat Exchangers NSR Functional Support Pressure Boundary NSR piping, fittings, and Prevent Failure from Pressure Boundary equipment affecting SR Equipment Orifices NSR Functional Support Pressure Boundary Pressure Boundary, Flow Restriction Piping and Fittings NSR Functional Support Pressure Boundary Pumps NSR Functional Support Pressure Boundary Ration Flow Proportioner NSR Functional Support Pressure Boundary, Flow Control Silencers NSR Functional Support Pressure Boundary Sluice Gate for Motor NSR Functional Support Pressure Boundary Driven Fire Pump Spray Nozzles NSR Functional Support Pressure Boundary Pressure Boundary, Flow Restriction*
Tanks and Air Receivers NSR Functional Support Pressure Boundary Valves NSR Functional Support Pressure Boundary Pressure Boundary Pressure Boundary
- These functions are for specific "open nozzles;" i.e., for specific nozzles in deluge, CO2, or Halon applications that are essentially holes drilled into a header.
RAI 2.3.3.B. 13-1. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B. 13-1 acceptable because although it explains that the trash rakes and traveling screens are addressed in the NMP Unit 2 UFSAR, they perform no intended function. The staiffinds this contrary to the NMP Unit 2 UFSAR which includes the original NMP Unit 2fire protection SER as CLB.
Page 2 of 5
Supplemental Response Please refer to NMP2 Updated Safety Analysis Report (USAR) Section 9.2.5 (pages 9.2-30, 9.2-34, 9.2-39, 9.2-40, and Figure 9.2-40). The USAR describes the bypass valves that provide a traveling water screen bypass flow path to the service water pumps and the fire water pumps.
This bypass operates automatically using safety-related, seismically qualified components, thereby assuring sufficient service water suction bay water level and adequate fire pump suction supply in the event of blockage of the trash rakes or traveling screens. Thus, the trash rakes and traveling screens do not perform or support any fire protection intended functions.
RAI 2.3.3.B.13-23. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B.13-23 acceptable because although it explains that the dry-pipe sprinkler system in question is not credited to meet the requirements of 10 CFR 50.48, the staiffinds this contrary to the UFSAR which includes the original NMP Unit 2 fire protection SER as CLB. The NMP Unit 2 UFSAR includes a description of this sprinkler system.
Supplemental Response Please refer to the following portions of the NMP2 USAR:
- Section 9A.3.1.2.5.1 (page 9A.3-9)
- Table 9A.3-3
- Section 9B.8; specifically Tables 9B.8-1 and 9B.8-2 The railroad access bay is within the Standby Gas Treatment Building. USAR Table 9A.3-3 notes that there is no safety related equipment in the railroad access bay. The USAR states that the only safety-related equipment in the Standby Gas Treatment Building is the standby gas treatment system (SGTS) units. These units are located in the SGTS rooms, which are separated from the railroad access bay by 3-hour rated fire walls and floors. In addition, the safe shutdown analysis summarized in USAR Section 9B.8 does not identify any equipment located in the railroad access bay (Fire Area 4, Zone 242 NW) that is required for safe shutdown of the plant.
Thus, the dry-pipe sprinkler system in the railroad access bay does not perform or support any fire protection intended functions.
RAI 2.3.3.B.13-25. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B.13-25 acceptable because although it explains that the interior finishes in question are not credited to meet the requirements of 10 CFR 50.48, the staiffinds this contrary to the UFSAR which includes the original NMP Unit 2 fire protection SER as CLB. The NMP Unit 2 UFSAR includes a description of the fire resistance of interiorfinishes.
Page 3 of 5
Supplemental Response Please refer to the following:
- USAR Section 9.5.1.2.16 (page 9.5-8)
- USAR Section 9A.3.5.1.7 (page 9A.3-37)
- NRC Safety Evaluation Report (NUREG-1047), dated February 1985, Section 9.5.1.4 (page 9-38)
The USAR notes that fire-resistive interior finish materials are used wherever practical. The NRC found this acceptable in their safety evaluation report (SER) because it is in accordance with Branch Technical Position (BTP) CMEB 9.5-1, Section C.5.a. The SER and the BTP state that interior finishes should be non-combustible or listed by a nationally recognized testing laboratory for flame spread, smoke, and fuel contribution of 25 or less in their use configuration.
Thus, the context of the statements regarding finish materials is their contribution to combustible loading and smoke generation. The USAR and the NRC SER do not describe finish materials as performing a fire barrier or fire proofing function. Thus, interior finish materials do not perform or support any fire protection intended functions.
RAI 2.3.3.B.13-26. Staff's Evaluation Based on its review, the staff is not able to find the applicant's response to RAI 2.3.3.B.13-26 acceptable because although it explains that the normal switchgear building and the condensate storage buildings are not credited to meet the requirements of 10 CFR 50.48, the stafffinds this contrary to the UFSAR which includes the original NMP Unit 2 fire protection SER as CLB.
The NMP Unit 2 UFSAR includes a description of these structures.
Supplemental Response (1) Normal Switchgear Building Please refer to the following portions of the NMP2 USAR:
- Section 9A.3.1.2.5.8 (pages 9A.3-20 and 9A.3-21)
- Table 3.2-1, Sheet 16a
- Table 9A.3-10 The USAR indicates that the Normal Switchgear Building is not a seismic Category I structure, does not contain any safety-related equipment, and does not contain any equipment required for safe plant shutdown. In addition, the safe shutdown analysis summarized in USAR Section 9B.8 does not identify any equipment located in the Normal Switchgear Building (Fire Areas 51, 52, 53, 77, 78, and 79) that is required for safe shutdown of the plant. Thus, the Normal Switchgear Building does not support any fire protection intended functions.
Page 4 of 5
(2) Condensate Storage Tank Structure Please refer to the following portions of the NMP2 USAR:
- Section 9.2.6 (page 9.2-41)
- Table 3.2-1, Sheets 12 and 17
- Table 9A.3-11
- Section 9B.8; specifically Tables 9B.8-1 and 9B.8-2 The USAR states that the condensate storage facility condensate makeup and drawoff system is not safety-related, is not required to effect or support safe shutdown of the reactor, and is not required to support the operation of any nuclear safety system. The USAR also indicates that the Condensate Storage Tank Building is not a seismic Category I structure and does not contain any safety-related equipment. In addition, the safe shutdown analysis summarized in USAR Section 9B.8 does not identify any equipment located in the Condensate Storage Tank Building (Fire Area 55, Zone 902 NW) that is required for safe shutdown of the plant. Thus, the Condensate Storage Tank Building does not support any fire protection intended functions.
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ATTACHMENT 3 Nine Mile Point Nuclear Station Supplemental Information to Resolve Follow-up Ouestions Identified During the NRC Review of Section 3.1 of the License Renewal Application In letter NMP1L 1888 dated November 19,2004, Nine Mile Point Nuclear Station, LLC (NMPNS) provided supplemental information regarding the BWR Vessel Internals Program described in Section B2.1.8 of the License Renewal Application (LRA). NMPNS also provided a revision to the text and tables of LRA Section 3.1 in letter NMPIL 1982 dated December 6, 2004. The NRC review of this information identified two follow-up questions, as described in an NRC email to NMPNS on January 19, 2005 (Accession No. ML050390137), and subsequently discussed in a telephone conference between NRC and NMPNS representatives on January 28, 2005. NMPNS provides the following supplemental and/or clarifying information to address each noted follow-up question.
Follow-up Question The November 19 and December 6,2004 NMPNS letters provide conflicting information regarding the Nine Mile Point Unit 1 (NMP1) reactor vessel flange leak detection (VFLD) line.
Please verify whether the NMP I VFLD line is or is not in scope for license renewal.
Response
The NMP1 VFLD line is not in scope for license renewal since it is non-safety-related (NSR) and its internal environment is air. Therefore, it does not meet the criteria for inclusion under criterion 10 CFR 54.4(a)(2). This line is NSR since it does not meet the criteria of Regulatory Guide 1.26 for being safety-related (i.e., part of reactor coolant pressure boundary, needed to safely shutdown the reactor, or prevent radiological releases). The line is not considered part of the reactor coolant pressure boundary (RCPB) since the boundary ends at the reactor vessel flange. The VFLD line also does not contain any liquid during plant operation. Therefore, there is no liquid to leak onto SR equipment should a failure be postulated. This completes the re-evaluation of the NMP1 VFLD line classification that NMPNS committed to perform in letter NMP1L 1888 dated November 19, 2004.
Based on the above, the NMPI VFLD line is not considered in-scope for license renewal. LRA Table 2.3.1.A.1-1 (page 2.3-3) is revised to delete the table entry for "Top Head (Leak Detection Lines)."
Page 1 of 4
Follow-up Question The December 6, 2004 NMPNS letter provides conflicting information regarding the credited aging management program for the NMPI Control Rod Drive (CRD) return line nozzle. Please clarify.
Response
The NMP 1 CRD return line nozzle is managed in accordance with the commitments made to NUREG-0619, as documented in Nine Mile Point letter NMPIL 1357 dated September 4, 1998 and NRC safety evaluation documented in a letter dated February 5, 1999. These commitments are captured in the NMP1 Inservice Inspection (ISI) Program Plan document as augmented inspections. As such, NMPNS considers the CRD return line nozzle to be managed under the ASME Section XI Inservice Inspection (Subsections IWB, IWC, IWD) Program. LRA Table 3.1.1.A, Item 3.1.1.A-27, and Table 3.1.2.A-1 are revised to reflect this program alignment.
LRA Revisions Tables 3.1.1.A (page 3.1-26) and 3.1.2.A-1 (page 3.1-42) are revised to incorporate the above-described clarifications, as shown on the following two pages. The revisions are highlighted by shading.
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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-1801 Item Aging Effect/
Aging Further iter Component Mechanism Management Evaluation Discussion Number Mechanism Programs Recommended 3.1.1.A-27 Feedwater and Crack initiation and Feedwater nozzle; No Consistent with NUREG-1 801 with the control rod drive growth due to cyclic CRD return line following exception: NMP1 credits the (CRD) return line loading nozzle ASME Section XI Inservice Inspection nozzles (Subsections IWB, IWC, iWD) Program (ISI Program) for management of crack initiation and growth due to cyclic loading for the control rod drive return line nozzles.
NMP doeFsnt have a formalizedi Contr-ol Rod Drive Return Line Program; however, NMP1,cobrmitments relative to NUREG' 06191are implemented under the NMP1 iSI Program Plan as augmentie inspectionsi Page 3 of 4
Table 3.1.2.A-1 Reactor Vessel, Internals, and Reactor Coolant System NMP1 Reactor Pressure Vessel - Summary of Aginc Management Evaluation Aging Effect NUREG-Copnn neddAging Management 1801 Table I oe Component Iunction material Environment Requiring Program Volume 2 Item Notes TpFuconManagement Progra Nozzles PB Carbon or Low Treated Water or Cumulative Fatigue Monitoring IV.A1.3-a 3.1.1.A-01 C, 1 Alloy Steel Steam, High Fatigue Program (Yield Strength Temperature -
Damage
< 100 Ksi)
BWR Reactor IV.A1.3-d 3.1.1.A-01 A
(Clad with Pressure Vessel Stainless Steel)
Cracking BWR Feedwater IV.A1.3-b 3.1.1.A-27 A
Nozzle Program ASME Section Xl IV.A1.3-c 3.1.1.A-27 E
Inservice Inspecti_
(Subsections IWBI iWC. IWD) Program' Page 4 of 4
ATTACHMENT 4 Nine Mile Point Nuclear Station Revised License Renewal Boundary Drawing Associated with the Response to RAI 2.3.3.A.16-1 Regarding the NMP1 Waste Disposal System A revised copy of the following "for information only" license renewal drawing is provided in this attachment:
- LR-18045-C, Sheet 7, Revision 1, Waste Disposal System
THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE THAT CANBE VIEWED AT THE RECORD -TITLED:
- DWG. NO. LN"R4i8045-C, REV. 1 aWASTE DISPOSAL SYSTEM
'P&IDIAGRAM" WITH-IN THIS PACIKAGE OR BY SEARCHING USING DWG.
O..
.LRw18045-C D=O1