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MONTHYEARML0701804442007-01-29029 January 2007 Withholding from Public Disclosure, Polestar-prepared Calculation, H21C092, U1 LOCA W/Loop, AST Methodology Project stage: Other ML0714100472007-05-21021 May 2007 Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 1, Implementation of Alternative Source Term Project stage: RAI ML0715700092007-06-0808 June 2007 Meteorology Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 1, Implementation of Alterative Source Term Project stage: RAI ML0722201462007-08-0101 August 2007 License Amendment Request Pursuant to 10 CFR 50.90: Application of Alternative Source Term - Response to NRC Request for Additional Information Project stage: Response to RAI ML0726203612007-09-19019 September 2007 License Amendment Request Pursuant to 10 CFR 50.90: Application of Alternative Source Term - Supplemental Information Project stage: Supplement 2007-06-08
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Category:Letter
MONTHYEARNMP1L3570, Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-02-0101 February 2024 Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation IR 05000220/20230042024-02-0101 February 2024 Integrated Inspection Report 05000220/2023004 and 05000410/2023004 NMP1L3569, CFR 50.46 Annual Report2024-01-26026 January 2024 CFR 50.46 Annual Report ML24004A2122024-01-0808 January 2024 Senior Reactor and Reactor Operator Initial License Examinations ML23354A0012024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0059 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines NMP1L3566, Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station2023-12-14014 December 2023 Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station IR 05000410/20243012023-12-14014 December 2023 Initial Operator Licensing Examination Report 05000410/2024301 ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 NMP1L3564, Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements ML23291A4642023-12-0707 December 2023 Issuance of Amendment No. 251 Regarding the Adoption of Title 10 the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of SSC for Nuclear Power Plants ML23289A0122023-12-0606 December 2023 Issuance of Amendment No. 250 Regarding the Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b NMP1L3563, Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-12-0404 December 2023 Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) IR 05000220/20234022023-11-28028 November 2023 Security Baseline Inspection Report 05000220/2023402 and 05000410/2023402 NMP1L3557, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000220/20234202023-11-0101 November 2023 Security Baseline Inspection Report 05000220/2023420 and 05000410/2023420 ML23305A0052023-11-0101 November 2023 Operator Licensing Examination Approval IR 05000220/20230032023-10-25025 October 2023 Integrated Inspection Report 05000220/2023003 and 05000410/2023003 IR 05000220/20235012023-10-17017 October 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000220/2023501 and 05000410/2023501 IR 05000220/20230112023-10-16016 October 2023 Comprehensive Engineering Team Inspection Report 05000220/2023011 and 05000410/2023011 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans NMP1L3554, Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases2023-10-0606 October 2023 Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases C IR 05000220/20233032023-09-20020 September 2023 Retake Operator Licensing Examination Report 05000220/2023303 ML23250A0822023-09-19019 September 2023 Regulatory Audit Summary Regarding LARs to Adopt TSTF-505, Rev. 2, and 10 CFR 50.69 ML23257A1732023-09-14014 September 2023 Requalification Program Inspection IR 05000220/20230052023-08-31031 August 2023 Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2023005 and 05000410/2023005) RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs NMP2L2851, Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations2023-08-25025 August 2023 Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations ML23151A3472023-08-21021 August 2023 Issuance of Amendments to Adopt TSTF-295-A, Modify Note 2 to Actions of PAM Table to Allow Separate Condition Entry for Each Penetration NMP1L3534, License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2023-08-18018 August 2023 License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation ML23220A0262023-08-0808 August 2023 Licensed Operator Positive Fitness-for-Duty Test IR 05000220/20234012023-08-0808 August 2023 Cyber Security Inspection Report 05000220/2023401 and 05000410/2023401 (Cover Letter Only) NMP1L3545, Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems .2023-08-0404 August 2023 Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems . RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor IR 05000220/20230022023-08-0101 August 2023 Integrated Inspection Report 05000220/2023002 and 05000410/2023002 ML23207A0762023-07-14014 July 2023 EN 56557 - Update to Part 21 Report Re Potential Defect with Trane External Auto/Stop Emergency Stop Relay Card Pn: XI2650728-06 NMP1L3544, Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations2023-07-14014 July 2023 Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations ML23186A1642023-07-0606 July 2023 Operator Licensing Retake Examination Approval NMP2L2846, Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications2023-07-0505 July 2023 Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications ML23192A0622023-06-30030 June 2023 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance, Report No. 10CFR21-0136, Rev. 0 IR 05000220/20230102023-06-29029 June 2023 Biennial Problem Identification and Resolution Inspection Report 05000220/2023010 and 05000410/2023010 ML23131A4242023-06-23023 June 2023 Issuance of Amendment No. 249 Regarding the Revision to Technical Specification 3.3.1 to Adopt Technical Specifications Task Force Traveler TSTF-568 RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations NMP1L3539, Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-06-0909 June 2023 Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) ML23159A0052023-06-0505 June 2023 56557-EN 56557 - Paragon - Redlined RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling IR 05000410/20233022023-05-15015 May 2023 Initial Operator Licensing Examination Report 05000410/2023302 2024-02-01
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Keith J. Poison P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax 0 Constellation Energy Nine Mile Point Nuclear Station August 1, 2007 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Nine Mile Point Nuclear Station Unit No. 1; Docket No. 50-220 License Amendment Request Pursuant to 10 CFR 50.90: Application of Alternative Source Term - Response to NRC Request for Additional Information (TAC No.
MD3896)
REFERENCES:
(a) Letter from T. J. O'Connor (NMPNS) to Document Control Desk (NRC), dated December 14, 2006, License Amendment Request Pursuant to 10 CFR 50.90:
Application of Alternative Source Term (b) Letter from M. J. David (NRC) to T. J. O'Connor (NMPNS), dated June 8, 2007, Meteorology Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 1, Implementation of Alternative Source Term (TAC No. MD3896)
(c) Letter from K. J. Poison (NMPNS) to Document Control Desk (NRC), dated July 17, 2007, License Amendment Request Pursuant to 10 CFR 50.90: Application of Alternative Source Term - Response to NRC Requests for Additional Information (TAC No. MD3896)
Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted application for amendment to Nine Mile Point Unit 1 (NMPI) Renewed Operating License DPR-63. The initial application, dated December 14, 2006 (Reference a) proposed to revise the accident source term used in the design basis radiological consequence analyses in accordance with 10 CFR 50.67. The proposed accident source term revision would replace the current methodology that is based on Technical Information Document (TID)-14844 with the alternative source term methodology described in Regulatory Guide 1.183.
By letter dated June 8, 2007 (Reference b), the NRC requested additional information regarding the subject license amendment request. NMPNS provided responses to the request for additional information
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Document Control Desk August 1, 2007 Page 3 Attachments: (1) Nine Mile Point Unit I - Response to NRC Request for Additional Information Regarding Proposed Revision to the Accident Source Term cc: S. J. Collins, NRC M. J. David, NRC Resident Inspector, NRC J. P. Spath, NYSERDA
ATTACHMENT (1)
NINE MILE POINT UNIT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED REVISION TO THE ACCIDENT SOURCE TERM Nine Mile Point Nuclear Station, LLC August 1, 2007
ATTACHMENT (1)
NINE MILE POINT UNIT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED REVISION TO THE ACCIDENT SOURCE TERM By letter dated December 14, 2006, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted a license amendment request to implement the alternative source term methodology for Nine Mile Point Unit 1 (NMP1). The NRC requested additional information regarding this license amendment request in a letter dated June 8, 2007. NMPNS provided responses to the request for additional information by letter dated July 17, 2007, with the exception of Request AADB-8. This attachment provides the response to Request AADB-8. The NRC request is repeated (in italics), followedby the NMPNS response.
Request AADB-8 The NRC staff notes that 60.7 meter wind measurements, rather than the 9.4 meter measurements, were used in the calculation of the ground level EAB and LPZ x/Q values. In addition, the 60.7 meter wind measurements and atmospheric stability measurements between the 60.7 and 9.4 meter levels were used, to calculate the elevated release X/Q values for releases from the 106. 7 meter NMP1 stack NRC Regulatory Issue Summary 2006-04, *"ExperienceWith Implementation of Alternative Source Terms, "
dated March 7, 2006, states that when running the offsite atmospheric dispersion model PA VAN, two or more files of meteorological data representative of each potential release height should be used if X/Q values are being calculatedfor pathways with significantly different release heights. Please provide justification that use of the 60.7 meter data is adequate for generation of both the ground level and elevated releaseX/Q values used in the dose assessment.
Response
PAVAN includes a methodology for addressing differences in release height and measurement height.
The height above plant grade of the release point (HS) and the height above ground level at which the wind speed was measured (TOWERH) are model inputs. PAVAN accounts for differences in release and wind measurement height if HS in not equal to TOWERH (ADJWND subroutine) using the following relationship:
UR =UM(HR/TH)p (1) where:
UR = wind speed adjusted to the height of release (meter/sec),
UM = wind speed at the level of measurement (meter/sec),
HR = height of release (meter),
TH = height at which wind speed UM was measured (meter), and P = 0.25 for unstable and neutral atmospheric conditions and 0.50 for stable conditions.
For ground-level releases, when HR = 10 meter and TH = 60.7 meter, the adjusted wind speed is UR =
- 0. 6 37UM (unstable/neutral) and UR = 0.406UM (stable). Thus, the 60.7 meter wind measurement data is properly reduced to simulate winds at the lower release height of 10 meter. These factors were applied to the X/Q values calculated in calculation H21C076 and reported in Attachment (7) of the December 14, 2006, NMPNS submittal.
A survey of the 9.4 meter and 60.7 meter wind measurement data shows differences in wind speed and direction. At the 60.7 meter level the wind speeds are typically 1 to 3 meter/sec faster. Also, a difference I of 2
ATTACHMENT (1)
NINE MILE POINT UNIT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED REVISION TO THE ACCIDENT SOURCE TERM in the directional component occurs for lower wind speeds (< 4 meter/sec). At the 9.4 meter level most of the lower speed wind is from the land sectors (approximately 2:1 compared to the lake sectors). There is little directional variation in the lower speed wind at the 60.7 meter level. Conversely, for moderate wind speeds (> 4 meter/sec), more wind is from the lake sectors at the 9.4 meter level.
To assess the -impact on the PAVAN models, sensitivity calculations were performed using the 9.4 meter wind measurement data to determine ground level release X/Q values. Comparison of these values to the X/Q values used in performing the evaluations to support the December 14, 2006 submittal determined that the calculated X/Q values based on the 60.7 meter data were conservative (i.e., higher) relative to the values based on the 9.4 meter data, both for the exclusion area boundary (0 to 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />) and for the low population zone (LPZ) for the 0 to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time periods; however, the calculated LPZ X/Q values for the 1-4 day and 4-30 day time periods were non-conservative.
To ascertain the impact of the non-conservative LPZ X/Q values for the 1-4 day and 4-30 day periods, sensitivity calculations were performed using the RADTRAD loss of coolant accident (LOCA) models.
The dose at the LPZ was recalculated for the three ground level release pathways. The resultant LPZ TEDE doses were found to be bounded by those reported in the December 14, 2006 submittal. Therefore, the use of 60.7 meter wind measurement data for the determination of ground level release X/Q values results in bounding offsite doses and is therefore conservative.
The onsite meteorological measurement program is described in the Nine Mile Point Unit 2 (NMP2)
Updated Safety Analysis Report, Section 2.3.3, and was accepted by the NRC in their Safety Evaluation Report for NMP2 (NUREG-1047). For both the preoperational and operational measurements programs, the meteorological tower height of 200 feet was and is not suitable for collecting wind measurement data at higher elevations, such as the 350-foot tall main stack. The current stack release X/Q values were calculated with PAVAN using the 60.7 meter level wind measurement data. As described above, the PAVAN model properly accounts for the difference in release and measurement height by increasing the wind speeds using Equation (1) above.
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