ML060310372

Application for Technical Specification Improvement to Eliminate Requirements for the Hydrogen Monitors Using the Consolidated Line Item Improvement Process

ML060310372
Person / Time
Site:	Nine Mile Point
Issue date:	01/18/2006
From:	O'Connor T Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L 2010
Download: ML060310372 (9)

Text

Constellation Energy P.O. Box 63 Lycoming, NY 13093 K Nine Mile Point Nuclear Station January 18, 2005 NMP1L 2010 U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555

SUBJECT:

Nine Mile Point Unit 1 Docket No. 50-220 Facility Operating License No. DPR-63 Application for Technical Specification Improvement to Eliminate Requirements for the Hydrogen Monitors Using the Consolidated Line Item Improvement Process Gentlemen:

Pursuant to 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) hereby requests an amendment to the Technical Specifications (TS) for Nine Mile Point Unit 1.

The proposed amendment will delete the TS requirements related to the hydrogen monitors. The proposed TS changes support implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003. The changes are consistent with Revision 1 of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the Federal Register on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

Post-accident hydrogen recombiners are not installed at Nine Mile Point Unit 1 and there are no oxygen monitoring instrumentation requirements in the Nine Mile Point Unit 1 TS.

Consequently, not applicable portions of the CLIIP will not be requested in this proposed amendment. provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications and commitments. Attachment 2 provides the pou

Page 2 NMP1L 2010 existing TS pages marked-up to show the proposed change. Implementation of TSTF-447 also involves changes to the TS Bases. The TS Bases changes will be submitted with a future update in accordance with the TS 6.5.6, "Technical Specifications (TS) Bases Control Program."

NMPNS requests approval of the proposed license amendment by July 28, 2006, with the amendment being implemented within 60 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York State Official.

If you should have any questions regarding this submittal, please contact Terry Syrell, Principal Engineer Licensing, at (315) 349-7198.

S inc ely,,

J. O'Connor Vic esident Nine Mile Point TJO/RF

Page 3 NMP1L 2010 STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Timothy J. O'Connor, being duly sworn, slate that I am the Vice President Nine Mile Point, and that I am duly authorized to execute and file this request on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document 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 employ's and/or consultants. Such information has been reviewed in accordance with company ptactice and I believe it to be reliable.

Subscribed and sworn before me, a Notary Public in and for the New York and County of Oswego, this Ij day of B y, 2006.

WITNESS my Hand and Notarial Seal:

Notar Publi Notary Public My Commission Expires:

SANDRA A. OSWALD I I I,00 (,

Notary Public, State of New York No. 010S6032276) ate Qualified In Oswego CDntY Commission Expires e..4s109_

Attachments:

1. Description and Assessment

2. Proposed Technical Specification Changes (Mark-up) cc: Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. L. M. Cline, NRC Senior Resident Inspector Mr. T. G. Colburn, Senior Project Manager, NRR (2 copies)

Mr. John P. Spath, NYSERDA

ATTACHMENT 1 DESCRIPTION AND ASSESSMENT

1.0 INTRODUCTION

The proposed License amendment deletes references to the hydrogen monitors in Technical Specification (TS) 3.6.11, "Accident Monitoring Instrumentation." The proposed TS change supports implementation of the revisions to 10 CFR 50.44, "Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," that became effective on October 16, 2003.

The changes are consistent with Revision I of NRC-approved Industry/Technical Specification Task Force (TSTF) Standard Technical Spec ification Change Traveler, TSTF-447, "Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors." The availability of this TS improvement was announced in the FederalRegister on September 25, 2003 as part of the consolidated line item improvement process (CLIIP).

2.0 DESCRIPTION

OF PROPOSED AMENDMENT Consistent with the NRC-approved Revision I of TSTF-447, the proposed TS changes include:

Table 3.6.11 - 1 Item 6, Containment Hydrogen Monitor Deleted Table 4.6.11 Item 6, Containment Hydrogen Monitor Deleted The Nine Mile Point Unit I (NMP I) custom TS contain specifications that are different than the model TS changes contained in the CLIIP. The model TS are based on the Improved Standard TS. The differences between the NMP1 custom TS and the CLIIP model TS are primarily in the area of TS that exist in the CLIIP model TS that do not exist in the NMP1 TS.

As described in NRC-approved Revision 1 of TSTF-447, the changes to TS requirements result in changes to a section of TS Bases. The TS Bases changes will be submitted with a future update in accordance with TS 6.5.6, "Technical Specifications (TS) Bases Control Program."

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

4.0 REGULATORY REOUIREMENTS AND GUIDANCE The applicable regulatory requirements and guidance associated with this application are adequately addressed by the NRC Notice of Availability published on September 25, 2003 Page 1 of 3

(68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

5.0 TECHNICAL ANALYSIS

Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation (SE) published on September 25, 2003 (68 FR 55416) as part of the CLIIP Notice of Availability.

This verification included a review of the NRC staff's SE, as well as the supporting information provided to support TSTF-447. NMPNS has concluded that the justifications presented in the TSTF proposal and the SE prepared by the NRC staff are applicable to Nine Mile Point Unit 1 and justify this amendment for the incorporation of the changes to the Nine Mile Point Unit 1 TS.

6.0 REGULATORY ANALYSIS

A description of this proposed change and its relationship to applicable regulatory requirements and guidance was provided in the NRC Notice of Availability published on September 25, 2003 (68 FR 55416), TSTF-447, the documentation associated with the 10 CFR 50.44 rulemaking, and other related documents.

6.1 Verification and Commitments As discussed in the model SE published in the FederalRegister on September 25, 2003 (68 FR 55416) for this TS improvement, NMPNS is making the following verifications and regulatory commitments:

1. NMPNS has verified that a hydrogen monitoring system capable of diagnosing beyond design-basis accidents is installed at Nine Mile Point Unit 1 and is making a regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Nine Mile Point Unit 1 Updated Final Safety Analysis Report. This regulatory commitment will be implemented within 60 days from the date of the approval of the proposed amendment.

2. Nine Mile Point Unit 1 has an inerted containment. NMPNS has verified that an oxygen monitoring system capable of verifying the status of the inerted containment is installed at Nine Mile Point Unit 1 and is making a regulatory commitment to maintain that capability. The oxygen monitors will be included in the Nine Mile Point Unit 1 Updated Final Safety Analysis Report. This regulatory commitment will be implemented within 60 days from the date of the approval of the proposed amendment.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION NMPNS has reviewed the proposed no significant hazards consideration determination published on September 25, 2003 (68 FR 55416) as part of the CLIIP. NMPNS has concluded that the proposed determination presented in the notice is applicable to Nine Mile Point Unit 1 and the Page 2 of 3

determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

8.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model SE published on September 25, 2003 (68 FR 55416) as part of the CLIIP. NMPNS has concluded that the staffs findings presented in that evaluation are applicable to Nine Mile Point Unit 1 and the evaluation is hereby incorporated by reference for this application.

9.0 PRECEDENT This application is being made in accordance with the CLIIP. NMPNS is not proposing variations or deviations from the applicable I'S changes described in TSTF-447 or the NRC staff's model SE published on September 25, 2003 (68 FR 55416).

10.0 REFERENCES

Federal Register Notice: Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Hydrogen Recombiner Requirement, and Relax the Hydrogen and Oxygen Monitor Requirements for Light Water Reactors Using the Consolidated Line Item Improvement Process, published September 25, 2003 (68 FR 55416).

Page 3 of 3

ATTACHMENT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

TABLE 4.6.11 ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENT Parametgr Instrument Channel Test Instrument Channe;l Calbration (1) Relief valve position indicator (Primary - Once per quarter Once during each major refueling outage Acoustic)

Relief valve position indicator (Backup - Once per quarter Once during each major refueling outage Thermocouple)

(2) Safety valve position indicator (Primary - Once per quarter Once during each major refueling outage Acoustic)

Safety valve position indicator (Backup - Once per quarter Once during each major refueling outage Thermocouple)

(3) Reactor vessel water level Once per quarter Once during each major refueling outage (4) Drywell Pressure Monitor Once per month Once during each major refueling outage (5) Suppression Chamber Water Level Monitor Once per quarter Once during each major refueling outage (6) containmc nt H'droann Monitor enee0 e1 Ere. per euarter I

(7) Containment High Range Radiation Monitor Once per month Once during each major refueling outage (8) Suppression Chamber Water Temperature Once per month Once during each major refueling outage AMENDMENT NO. t42!2 272n

TABLE 3.6.11-1 ACCIDENT MONITORING INSTRUMENTATION Minimum Number of Operable Total Number of Channels Sensors or Channels Action USee Table 3.6.11-2)

Patranters 2/Valve I Nalve I 1

1) Relief Valve Position Indication 2NValve 1/Valve 1

2) Safety Valve Position Indication 10 2

3) Reactor Vessel Water Level 2 2 1 4

4) Drywall Pressure Monitor 1 4

5) Suppression Chamber Water 2 Level I

2 1 3

7) Containment High Range Radiation Monitor 2 1 2

8) Suppression Chamber Water Temperature for required surveillance provided at least one Operable channel is

• A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> monitoring that Parameter.

2 269 AMENDMENT NO.