ML070740131
| ML070740131 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/08/2007 |
| From: | Schimmel M Constellation Energy Group |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| Download: ML070740131 (15) | |
Text
Constellation Energy Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, NY 13093 March 8, 2007 U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attention:
Subject:
Document Control Desk Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-4 10 Application for Technical Specification Change to Add LCO 3.0.8 on the Inoperability of Snubbers Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the Technical Specifications (TSs) for Nine Mile Point, Unit 2, renewed operating license No. NPF-69. The proposed amendment would modify TS requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.
Attachment (1) provides a description of the proposed change, the requested confirmation of applicability, and plant-specific verifications. Attachment (2) provides the existing TS pages marked up to show the proposed change. Attachment (3) provides a summary of regulatory commitments made in this submittal.
Attachment (4) provides the existing TS Bases pages marked up to show the proposed change (for information only).
NMPNS requests approval of the proposed license amendment by September 28, 2007, with the amendment being implemented within the subsequent 180 days.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated New York state officials.
Document Control Desk March 8, 2007 Page 2 Should you have any questions regarding this submittal, please contact M. H. Miller, Licensing Director, at (315) 349-5219.
Very truly yours, Mark A. Schimmel Plant General Manager STATE OF NEW YORK TO WIT COUNTY OF I, Mark A. Schimmel, state that I am Plant General Manager, Nine Mile Point Nuclear Station, LLC, and that I am duly authorized to execute and file this request. 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 employees and/or consultants of Nine Mile Point Nuclear Station. Such information has been reviewed in accordance with company practice, and I believe it to be reliable.
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.i Subscribed and sworn before me, a Notary Public, in and for the State of New York
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, this &"day of MaI IfCJ 1, 2007.
I and County of WITNESS my Hand and Notarial Seal:
TONYA LJONES Notary Public In the State of New York My Commission Ex~a*Mfo County Rteg. No. 01 4106=13U My Commission Expires IL1 1,ThkJ-i Date MAS/JJD/kms Attachments:
(1)
Description and Assessment (2)
Proposed Technical Specification Changes (Mark-up)
(3)
List of Regulatory Commitments (4)
Proposed Technical Specification Bases Changes (For Information Only) cc:
D. V. Pickett, NRC S. J. Collins, NRC Resident Inspector, NRC J. P. Spath, NYSERDA
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT Nine Mile Point Nuclear Station, LLC March 8, 2007
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
The proposed amendment would modify technical specifications (TSs) requirements for inoperable snubbers by adding Limiting Condition for Operation (LCO) 3.0.8.
The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification change TSTF-372, Revision 4. The availability of this TS improvement was published in the Federal Register on May 4, 2005, as part of the consolidated line item improvement process (CLIIP).
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation Nine Mile Point Nuclear Station, LLC (NMPNS) has reviewed the safety evaluation dated May 4, 2005, as part of the CLIIP.
This review included a review of the NRC staffs evaluation, as well as the information provided to support TSTF-372. NMPNS has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to Nine Mile Point Nuclear Station, Unit 2 (NMP2) and justify this amendment for the incorporation of the changes to the NMP2 TSs.
2.2 Optional Changes and Variations NMPNS is not proposing any variations or deviations from the TS changes described in TSTF-372, Revision 4 or the NRC staff's model safety evaluation dated May 4, 2005.
NMPNS is proposing one variation to the Bases changes included in TSTF-372, Revision 4. Section 3.1.2 of the model safety evaluation contains specific restrictions to the implementation of the proposed TSs to avoid potentially high-risk configurations. To ensure proper application of LCO 3.0.8, NMPNS is proposing to state the applicable restrictions in the Bases. These additions are reflected in the TS Bases markups included in Attachment (4).
3.0 REGULATORY ANALYSIS
3.1 No Significant Hazards Consideration Determination NMPNS has reviewed the proposed no significant hazards consideration determination (NSHCD) published in the Federal Register as part of the CLIIP. NMPNS has concluded that the proposed NSHCD is applicable to NMP2 and is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.9 1(a).
3.2 Verification and Commitments As discussed in the notice of availability published in the Federal Register on May 4, 2005, for this TS improvement, plant-specific verifications were performed as follows:
NMPNS will establish TS Bases for LCO 3.0.8 that provide guidance and details on how to implement the new requirements. LCO 3.0.8 requires that risk be managed and assessed. The Bases will also state that while the industry and NRC guidance on implementation of 10 CFR 50.65(a)(4), the Maintenance Rule, does not address seismic risk, LCO 3.0.8 should be considered with respect to other plant I of 2
ATTACHMENT (1)
DESCRIPTION AND ASSESSMENT maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative assessment of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.
Additionally, NMP2 has a Bases Control Program consistent with Section 5.5 of the Standard Technical Specifications.
4.0 ENVIRONMENTAL EVALUATION NMPNS has reviewed the environmental evaluation included in the model safety evaluation dated May 4, 2005 as part of the CLIIP. NMPNS has concluded that the staff s findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.
2 of 2
ATTACHMENT (2)
NINE MILE POINT UNIT 2 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)
Nine Mile Point Nuclear Station, LLC March 8, 2007
LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2 LCO 3.0.%.- 4 C60 3 I
LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.
If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated.
LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:
- a.
MODE 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;
- b.
MODE 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and
- c.
MODE 4 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.
Exceptions to this Specification are stated in the individual Specifications.
Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.
LCO 3.0.3 is only applicable in MODES 1, 2, and 3.
LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:
- a.
When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; (continued)
NMP2 3.0-1 Amendment 94,4499
LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.7 (continued) otherwise specified, all other TS requirements remain unchanged. Compliance with Special Operations LCOs is optional. When a Special Operations LCO is desired to be met but is not met, the ACTIONS of the Special Operations LCO shall be met. When a Special Operations LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with the other applicable Specifications.
LCO 3.0.8 When one or more required snubbers are unable to perform their associated support function(s), any affected supported LCO(s) are not required to be declared not met solely for this reason if risk is assessed and managed, and:
- a. The snubbers not able to perform their associated support function(s) are associated with only one train or subsystem of a multiple train or subsystem supported system or are associated with a single train or subsystem supported system and are able to perform their associated support function within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; or
- b. The snubbers not able to perform their associated support function(s) are associated with more than one train or subsystem of a multiple train or subsystem supported system and are able to perform their associated support function within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
At the end of the specified period the required snubbers must be able to perform their associated support function(s), or the affected supported system LCO(s) shall be declared not met.
NMP2 3.0-3 Amendment 94,,4G-
ATTACHMENT (3)
LIST OF REGULATORY COMMITMENTS Nine Mile Point Nuclear Station, LLC March 8, 2007
ATTACHMENT (3)
LIST OF REGULATORY COMMITMENTS The following table identifies those actions committed to by Nine Mile Point Nuclear Station, LLC in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to M. H.
Miller, Licensing Director, at (315) 349-5219.
REGULATORY COMMITMENTS DUE DATE/EVENT Nine Mile Point Nuclear Station, LLC will establish the Implemented with the approved amendment.
Technical Specification Bases for LCO 3.0.8 as adopted with the applicable license amendment.
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ATTACHMENT (4)
PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (FOR INFORMATION ONLY)
Nine Mile Point Nuclear Station, LLC March 8, 2007
LCO Applicability B 3.0 B 3.0 LIMITING CONDITION FOR OPERATION (LCO)
APPLICABILITY BASES m
... j LCOs LCO 3.0.1 through LCO 3.0.0 establish the general requirements applicable to all Specifications in Sections 3.1 through 3.10 and apply at all times, unless otherwise stated.
I LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individual Specification as the requirement for when the LCO is required to be met (i.e., when the unit is in the MODES or other specified conditions of the Applicability statement of each Specification).
LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, the associated ACTIONS shall be met.
The Completion Time of each Required Action for an ACTIONS Condition is applicable from the point in time that an ACTIONS Condition is entered.
The Required Actions establish those remedial measures that must be taken within specified Completion Times when the requirements of an LCO are not met.
This Specification establishes that:
- a.
Completion of the Required Actions within the specified Completion Times constitutes compliance with a Specification; and
- b.
Completion of the Required Actions is not required when an LCO is met within the specified Completion Time, unless otherwise specified.
There are two basic types of Required Actions.
The first type of Required Action specifies a time limit in which the LCO must be met.
This time limit is the Completion Time to restore an inoperable system or component to OPERABLE status or to restore variables to within specified limits.
If this type of Required Action is not completed within the specified Completion Time, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable.
(Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering (continued)
NMP2 B 3. 0-1 Revisiont-Q
LCO Applicability B 3.0 BASES 4d LCO 3.0.7 (continued) operation may be performed either under the provisions of the appropriate Special Operations LCO or under the other applicable TS requirements. If it is desired to perform the special operation under the provisions of the Special Operations LCO, the requirements of the Special Operations LCO shall be followed. When a Special Operations LCO requires another LCO to be met, only the requirements of the LCO statement are required to be met regardless of that LCO's Applicability (i.e., should the requirements of this other LCO not be met, the ACTIONS of the Special Operations LCO apply, not the ACTIONS of the other LCO). However, there are instances where the Special Operations LCO's ACTIONS may direct the other LCO's ACTIONS be met. The Surveillances of the other LCO are not required to be met, unless specified in the Special Operations LCO. If conditions exist such that the Applicability of any other LCO is met, all the other LCO's requirements (ACTIONS and SRs) are required to be met concurrent with the requirements of the Special Operations LCO.
I NMP2 B 3.0-11 Revision
INSERT 1 LCO 3.0.8 LCO 3.0.8 establishes conditions under which systems are considered to remain capable of performing their intended safety function when associated snubbers are not capable of providing their associated support function(s). This LCO states that the supported system is not considered to be inoperable solely due to one or more snubbers not capable of performing their associated support function(s). This is appropriate because a limited length of time is allowed for maintenance, testing, or repair of one or more snubbers not capable of performing their associated support function(s) and appropriate compensatory measures are specified in the snubber requirements, which are located outside of the Technical Specifications (TS) under licensee control. The snubber requirements do not meet the criteria in 10 CFR 50.36(c)(2)(ii), and, as such, are appropriate for control by the licensee.
If the allowed time expires and the snubber(s) are unable to perform their associated support function(s), the affected supported system's LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.
Each use of LCO 3.0.8 requires confirmation that at least one train (or subsystem) of systems supported by the inoperable snubbers would remain capable of performing their required safety or support functions for postulated design loads other than seismic loads. LCO 3.0.8 does not apply to non-seismic snubbers. In addition, a record of the design function of the inoperable snubber (i.e., seismic vs. non-seismic), implementation of any high-risk configuration restrictions, and the associated plant configuration shall be available on a recoverable basis for inspection.
LCO 3.0.8 only can be used if one of the following two means of heat removal is available (high-risk configuration restrictions):
(1)
At least one high pressure makeup path (e.g., using HPCS or RCIC) and heat removal capability (e.g., suppression pool cooling), including a minimum set of supporting equipment required for success, not associated with the inoperable snubber(s),
OR (2)
At least one low pressure makeup path (e.g., LPCI or LPCS) and heat removal capability (e.g., suppression pool cooling or shutdown cooling),
including a miniumum set set of supporting equipment required for success, not associated with the inoperable snubber(s).
LCO 3.0.8.a applies when one or more snubbers are not capable of providing their associated support function(s) to a single train or subsystem of a multiple train or subsystem supported system or to a single train or subsystem supported system. LCO 3.0.8.a allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function and due to the availability of the redundant train of the supported system.
INSERT 1 (cont.)
LCO 3.0.8.b applies when one or more snubbers are not capable of providing their associated support function(s) to more than one train or subsystem of a multiple train or subsystem supported system. LCO 3.0.8.b allows 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to restore the snubber(s) before declaring the supported system inoperable. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable based on the low probability of a seismic event concurrent with an event that would require operation of the supported system occurring while the snubber(s) are not capable of performing their associated support function.
LCO 3.0.8 requires that risk be assessed and managed. Industry and NRC guidance on the implementation of 10 CFR 50.65(a)(4) (the Maintenance Rule) does not address seismic risk. However, use of LCO 3.0.8 should be considered with respect to other plant maintenance activities, and integrated into the existing Maintenance Rule process to the extent possible so that maintenance on any unaffected train or subsystem is properly controlled, and emergent issues are properly addressed. The risk assessment need not be quantified, but may be a qualitative awareness of the vulnerability of systems and components when one or more snubbers are not able to perform their associated support function.