ML072620361

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License Amendment Request Pursuant to 10 CFR 50.90: Application of Alternative Source Term - Supplemental Information
ML072620361
Person / Time
Site: Nine Mile Point 
Issue date: 09/19/2007
From: Polson K
Constellation Energy Group, Nine Mile Point
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD3896
Download: ML072620361 (5)


Text

Keith J. Polson Vice President-Nine Mile Point P.O. Box 63 Lycoming, New York 13093 31 5.349.5200 315.349.1321 Fax Constellation Energy Nine Mile Point Nuclear Station September 19,2007 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 - Supplemental Information (TAC No. MD3896)

REFERENCE:

(a) Letter from T. J. OYConnor (NMPNS) to Document Control Desk (NRC), dated December 14, 2006, License Amendment Request Pursuant to 10 CFR 50.90:

Application of Alternative Source Term 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 (T1D)-14844 with the alternative source term methodology described in Regulatory Guide 1.183. In response to a NRC staff verbal request, as discussed in a telephone conference call on August 29, 2007, NMPNS hereby supplements the December 14,2006 submittal by re-stating a commitment relating to the incorporation of Technical Specification changes that are similar in concept to those described in Technical Specification Task Force (TSTF) traveler TSTF-5 1 -A, "Revise Containment Requirements during Handling Irradiated Fuel and Core Alterations," Revision 2. This revised regulatory commitment is shown in the revisions to Sections A1-4.5.6 and A1-9 of the December 14, 2006 submittal that are provided in Attachment (1) to this letter.

This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(l), NMPNS has provided a copy of this supplemental information to the appropriate state representative.

Document Control Desk September 19,2007 Page 2 Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (3 15) 349-52 19.

Very truly yours, STATE OF NEW YORK COUNTY OF OSWEGO

TO WIT:

I, Keith J. Polson, 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 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 employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn in and for the State of New York and County of Oswego, this

( ?*day of

,2007.

li WITNESS my Hand and Notarial Seal:

My Commission Expires:

Notary Public SANDRA A. OSWALD Notary Public, Stale of New York No. 01 086032276 Qualified In Oswego County Commission Expires fo/z s /O 4

Attachment:

(1) Nine Mile Point Unit 1 - Supplemental 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 SUPPLEMENTAL INFORMATION REGARDING PROPOSED REVISION TO THE ACCIDENT SOURCE TERM Nine Mile Point Nuclear Station, LLC September 19,2007

ATTACHMENT (1)

NINE MILE POINT UNIT 1 SUPPLEMENTAL 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). In response to a NRC staff verbal request, as discussed in a telephone conference call on August 29, 2007, NMPNS hereby supplements the December 14, 2006 submittal by re-stating a commitment relating to the incorporation of Technical Specification changes that are similar in concept to those described in Technical Specification Task Force (TSTF) traveler TSTF-5 1-A, "Revise Containment Requirements during Handling Irradiated Fuel and Core Alterations," Revision 2. The revised commitment, which specifically addresses the Reviewer's Note identified as Insert E of TSTF-5 1-A, is shown in the following revisions to Sections A1-4.5.6 and Al-9 of the December 14,2006 submittal.

1. In Section A1-4.5.6 (pages 28 and 29 of 87) of the December 14, 2006 submittal, titled "TS Section 3.4.0, Reactor Building," replace the third and fourth paragraphs with the following:

The NMPNS shutdown safety procedure presently includes guidance on equipment availability during shutdown and contingency planning, as well as the requirements contained in the licensing and design basis. As a defense-in-depth measure, to assure that actions are taken to limit the potential radiological consequences of a Refueling Accident, NMPNS will revise the shutdown safety procedure to implement the guidelines of Section 11.3.6.5 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3 (Reference A1-8.22). These revisions will be incorporated prior to completing implementation of the AST license amendment and will address the following attributes:

Specify that during fuel handlinglcore alterations, the ability to filter and monitor any release should be maintained. In particular, the RBEVS and its associated radiation monitors should be available but are not required to be operable.

Specify that the ability to restore secondary containment capability during fuel handlingkore alterations should be maintained. A contingency method to immediately initiate action to close any external openings in the secondary containment should be developed.

SpecifL-that, when necessary, the Shift Manager will ensure that the necessary actions are taken to close all external openings in the secondary containment.

These revisions will be similar to those previously incorporated into the shutdown safety procedure for Nine Mile Point Unit 2 (NMP2) to implement License Amendment No. 101 (issued by NRC letter dated February 11, 2002), which revised the NMP2 TS consistent with NRC-approved TSTF-5 1, Revision 2.

2. In Section Al-9 (page 36 of 87) of the December 14, 2006 submittal, titled "Regulatory Commitments," replace the first listed regulatory commitment with the following:

ATTACHMENT (1)

NINE MILE POINT UNIT 1 SUPPLEMENTAL INFORMATION REGARDING PROPOSED REVISION TO THE ACCIDENT SOURCE TERM The NMPNS shutdown safety procedure will be revised to implement the guidelines of Section 1 1.3.6.5 of NUMARC 93-0 1, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Revision 3. These revisions will address the following attributes for Nine Mile Point Unit 1 :

Specify that during fuel handlinglcore alterations, the ability to filter and monitor any release should be maintained. In particular, the RBEVS and its associated radiation monitors should be available but are not required to be operable.

Specify that the ability to restore secondary containment capability during fuel handlingkore alterations should be maintained. A contingency method to immediately initiate action to close any external openings in the secondary containment should be developed.

Specify that, when necessary, the Shift Manager will ensure that the necessary actions are taken to close all external openings in the secondary containment.