ML072640103

License Amendment Request for Adoption of TSTF-484, Revision 0, Use of TS 3.10.1 for Scram Time Testing Activities.

ML072640103
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
Download: ML072640103 (14)

Text

Keith J. Polson P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CarwtelRation~

Nine Mie Point Nudear 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. 2; Docket No. 50-4 10 License Amendment Request for Adoption of TSTF-484, Revision 0, "Use of TS 3.10.1 for Scram Time Testing Activities" In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR 50.90), Nine Mile Point Nuclear Station, LLC (NMPNS) is submitting a request for an amendment to the technical specifications (TS) for Nine Mile Point Unit 2 (NMP2), Renewed Operating License No.

NPF-69.

The proposed amendment would revise Limiting Condition for Operation (LCO) 3.10.1 to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27,2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

Attachment (1) provides an evaluation of the proposed change. Attachment (2) provides the existing TS pages marked up to show the proposed changes. Attachment (3) provides the existing TS Bases pages marked up to show the changes associated with the proposed amendment (for information only). The TS Bases changes will be processed in accordance with the NMP2 TS Bases Control Program (TS 5.5.10).

NMPNS requests approval of the proposed license amendment by February 29, 2008, with the amendment being implemented within the subsequent 60 days.

In accordance with 10 CFR 50.9 1, a copy of this application, with attachments, is being provided to the designated New York state official.

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) 349-5219.

Very truly yours,

$kff.Pk-STATE OF NEW YORK

TO WIT:

COUNTY OF OSWEGO 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 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 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 m a Notary Public in and for the State of New York and County of Oswego, this I 7 *day of 2007.

n WITNESS my Hand and Notarial Seal:

/

LJLLNotary Public A&&

My Commission Expires: SANDRA A. OSWALD Notary Public, State of New York No. 01086032276

,- Quarifled rn Osweao Cotlniu I omrnrssion Expires

Document Control Desk September 19,2007 Page 3 Attachments: (1) Evaluation of Proposed Change (2) Proposed Technical Specification Changes (Mark-up)

(3) Proposed Technical Specification Bases Changes (Mark-up) cc: M. J. David, NRC S. J. Collins, NRC Resident Inspector, NRC J. P. Spath, NYSERDA

ATTACHMENT (1)

EVALUATION OF PROPOSED CHANGE TABLE OF CONTENTS

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS DETERMINATION 5.2 APPLICABLE REGULATORY REQUIREMENTS / CRITERIA

7.0 REFERENCES

8.0 REGULATORY COMMITMENTS Nine Mile Point Nuclear Station, LLC September 19,2007

ATTACHMENT (1)

EVALUATION OF PROPOSED CHANGE

1.0 DESCRIPTION

The proposed amendment would revise Nine Mile Point Unit 2 (NMP2) Limiting Condition for Operation (LCO) 3.10.1 to expand its scope to include provisions for temperature excursions greater than 200°F as a consequence of inservice leak and hydrostatic testing, and as a consequence of scram time testing initiated in conjunction with an inservice leak or hydrostatic test, while considering operational conditions to be in Mode 4. This change is consistent with NRC approved Revision 0 to Technical Specification Task Force (TSTF) Improved Standard Technical Specification Change Traveler, TSTF-484, "Use of TS 3.10.1 for Scram Time Testing Activities." The availability of the TS 3.10.1 revision was announced in the Federal Register on October 27, 2006 (71 FR 63050) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

Consistent with the NRC approved Revision 0 of TSTF-484, the proposed TS changes include a revised TS 3.10.1, "System Leakage and Hydrostatic Testing Operation." Proposed revisions to the TS Bases are also included in this application. Adoption of the TS Bases associated with TSTF-484, Revision 0 is an integral part of implementing this TS amendment. The changes to the affected TS Bases pages will be incorporated in accordance with the TS Bases Control Program (TS 5.5.10).

This application is being made in accordance with the CLIIP. Nine Mile Point Nuclear Station, LLC (NMPNS) is not proposing variations or deviations from the NRC staffs model safety evaluation (SE) published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. NMPNS is proposing the following variation from the TS changes described in TSTF-484, Revision 0:

The TS and TS Bases changes described in TSTF-484, Revision 0, are modified by replacing the term "inservice leak" with "system leakage," consistent with the terminology used in current NMP2 TS 3.10.1.

3.0 BACKGROUND

The background for this application is adequately addressed by the NRC Notice of Availability published on October 27,2006 (71 FR 63050).

4.0 TECHNICAL ANALYSIS

NMPNS has reviewed the SE published on October 27,2006 (71 FR 63050) as part of the CLIIP Notice of Availability. NMPNS has concluded that the technical justifications presented in the SE prepared by the NRC staff are applicable to NMP2 and therefore justifL this amendment for the incorporation of the proposed changes to the NMP2 TS.

ATTACHMENT (1)

EVALUATION OF PROPOSED CHANGE 5.0 REGULATORY SAFETY ANALYSIS NO SIGNIFICANT HAZARDS DETERMINATION NMPNS has reviewed the no significant hazards determination published on August 21,2006 (71 FR 48561) as part of the CLIIP Notice for Comment. The no significant hazards determination was made available on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. NMPNS has concluded that the determination presented in the notice is applicable to NMP2 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

APPLICABLE REGULATORY REOUIREMENTS / CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements was provided in the NRC Notice of Availability published on October 27, 2006 (71 FR 63050).

6.0 ENVIRONMENTAL CONSIDERATION

NMPNS has reviewed the environmental evaluation included in the SE published on October 27, 2006 (71 FR 63050) as part of the CLIIP Notice of Availability. NMPNS has concluded that the staffs findings presented in that evaluation are applicable to NMP2 and the evaluation is hereby incorporated by reference for this application.

7.0 REFERENCES

1. Federal Register Notice, Notice of Availability published on October 27,2006 (71 FR 63050)

2. Federal Register Notice, Notice for Comment published on August 21,2006 (7 1 FR 4856 1)

3. TSTF-484 Revision 0, "Use of TS 3.10.1 for Scram Times Testing Activities" 8.0 REGULATORY COMMITMENTS The following table identifies those actions committed to by NMPNS in this submittal. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

None None

ATTACHMENT (2)

PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

TS Page 3.10.1-1 Nine Mile Point Nuclear Station, LLC September 19,2007

System Leakage and Hydrostatic Testing Operation 3.10.1 3.10 SPECIAL OPERATIONS 3.10.1 System Leakage and Hydrostatic Testing Operation The average reactor cool ant temperature specified in Table 1 .l-1 for MODE 4 may be changed to "NA," and operation

a. LC0 3.3.6.2, "Secondary Containment Is01 ati on Instrumentation," Functions 1, 3, and 4 o f Table 3.3.6.2-1;

b. LC03.3.8.2, "Reactor Protection System (RPS) Electric Power Monitoring-Logic";

c. LC0 3.6.4.1, "Secondary Containment" ;

d. LC0 3.6.4.2, "Secondary Containment Is01 at i on Val ves (SCIVs)" ; and

e. : LC0 3.6.4.3, "Standby Gas Treatment (SGT) System."

APPLICABILITY: MODE 4 with average reactor coolant temperature > 200°F.

Amendment 3-

INSERT 1 (for TS page 3.10.1- 1)

For performance of a system leakage or hydrostatic test, As a consequence of maintaining adequate pressure for a system leakage or hydrostatic test, or As a consequence of maintaining adequate pressure for control rod scram time testing initiated in conjunction with a system leakage or hydrostatic test, provided the following MODE 3 LCOs are met:

ATTACHMENT (3)

PROPOSED TECHNICAL SPECIFICATION BASES CHANGES (MARK-UP)

The current versions of the following Technical Specification Bases pages have been marked-up by hand to reflect the proposed changes. These Bases pages are provided for information only and do not require NRC approval.

TS Bases Papes Nine Mile Point Nuclear Station, LLC September 19,2007

System Leakage and Hydrostatic Testing Operation B 3.10.1 B 3.10 SPECIAL OPERATIONS B 3.10.1 System Leakage and Hydrostatic Testing Operation BASES BACKGROUND The purpose of this Special Operations LC0 is to allow certain reactor coolant pressure tests to be performed in MODE 4 when the metallurgical characteristics of the reactor pressure vessel (RPV) require the pressure testing at temperatures > 200°F (normally corresponding to MODE 3 Hydrostatic testing and system leakage pressure tests required by Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code (Ref. 1) are performed prior to the reactor going critical after a refueling outage. Recirculation pump operation, decay heat, and a water solid RPV (except for a gas bubble for pressure control) are used to achieve the necessary temperatures and pressures required for these tests. The minimum temperatures (at the required pressures) allowed for these tests are determined from the RPV pressure and temperature (PIT) limits required by LC0 3.4.11, "Reactor Coolant System (RCS) Pressure and Temperature (PK) Limits." These limits are conservatively based on the fracture toughness of the reactor vessel, taking into account anticipated vessel neutron fluence.

With increased reactor vessel fluence over time, the minimum allowable vessel temperature increases for a given pressure.

Periodic updates to the RCS PIT limit curves are performed as necessary, based on the results of analyses of irradiated reactor vessel material data. Hydrostatic and system leakage eventually be required with minimum reactor coolant temperatures > 200°F.

<1Gzz)

APPLICABLE Allowing the reactor to be considered in MODE 4 -

SAFETY ANALYSES when the reactor coolant temperature is > 200°F,keffectively provides an _

exception to MODE 3 requirements, including OPERABILITY of primary containment and the full complement of redundant Emergency Core Cooling Systems (ECCS). Since the tests are performed nearly water solid (except for a gas bubble for pressure control),

at low decay heat values, and near MODE 4 conditions, the stored energy in the reactor core will be very low. Under (continued)

NMP2 B 3.10.1-1 Revision 0,#

1

INSERT A (for TS Bases page B 3.10.1-1) or to allow completing these reactor coolant pressure tests when the initial conditions do not require temperatures > 200°F. Furthermore, the purpose is to allow continued performance of control rod scram time testing required by SR 3.1.4.1 or SR 3.1.4.4 if reactor coolant temperatures exceed 200°F when the control rod scram time testing is initiated in conjunction with a system leakage or hydrostatic test. These control rod scram time tests would be performed in accordance with LC0 3.10.4, "Single Control Rod Withdrawal - Cold Shutdown," during MODE 4 operation.

INSERT B (for TS Bases page B 3.10.1-1)

However, even with required minimum reactor coolant temperatures < 200°F, maintaining RCS temperatures within a small band during the test can be impractical. Removal of heat addition from recirculation pump operation and reactor core decay heat is coarsely controlled by control rod drive hydraulic system flow and reactor water cleanup system non-regenerative heat exchanger operation. Test conditions are focused on maintaining a steady state pressure, and tightly limited temperature control poses an unnecessary burden on the operator and may not be achievable in certain instances.

The hydrostatic and/or RCS system leakage tests require increasing pressure to approximately 1025 psig. Scram time testing required by SR 3.1.4.1 and SR 3.1.4.4 requires reactor pressures

> 800 psig.

Other testing (e.g., excess flow check valve testing) may be performed in conjunction with the allowances for system leakage or hydrostatic tests and control rod scram time tests.

INSERT C (for TS Bases page B 3.10.1- 1) during, or as a consequence of, hydrostatic or system leakage testing, or as a consequence of control rod scram time testing initiated in conjunction with a system leakage or hydrostatic test,

System Leakage and Hydrostatic Testing Operation B 3.10.1 BASES LC0 > 200°F, while performance of system leakage and hydrostatic (continued) t e s t i n g results in inoperability of subsystems required when

> 200°F (i.e.,

3 ) - ~ 1 x ? 3 I f i t i s desired t o perform these t e s t s while complying with t h i s Special Operations LCO, then the MODE 4 appl i c a b l e LCOs and specified MODE 3 LCOs must be met. This Special Operations LC0 a1 1ows changing Table 1.1-1 temperature l i m i t s for MODE 4 t o "NA" and suspending the requirements of LC0 3.4.10, "Residual Heat Removal (RHR) Shutdown Cool i ng System-Cold Shutdown. " The additional requirements f o r secondary containment LCOs t o be met will provide s u f f i c i e n t protection for operations a t reactor cool a n t temperatures

> 200°F for the purposes of performing a system leakage or hydrostatic testol

~IXE This LC0 allows primary containment t o be open f o r frequent unobstructed access t o perform inspections, and f o r outage a c t i v i t i e s on various systems t o continue consistent with APPLICABILITY The MODE 4 requirements may only be modified f o r leakage or hydrostatic be considered as in MODE temperature i s > 200°F. The additional requi rement for secondary contai nment OPERABILITY according t o the imposed MODE 3 requirements provides conservatism in the response of the unit t o any event t h a t may occur.

Operations in all other MODES are unaffected by t h i s LCO.

ACT IONS A Note has been provided t o modify the ACTIONS re1 ated t o system leakage and hydrostatic testing operation.

Section 1.3, Completion Times, specifies once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered t o be inoperable or n o t within 1imits, w i l l not r e s u l t i n separate entry into the Condition. Section 1.3 also specifies Required Actions of the Condition continue t o apply for each additional f a i l u r e , with Completion Times based on initial entry i n t o the Condition. However, the Required Actions f o r each requirement of the LC0 not met provide appropriate compensatory measures for separate requirements t h a t are not met. As such, a Note has been provided t h a t allows separate Condition entry f o r each requirement of the LCO.

(continued)

Revision 4+9

INSERT D (for TS Bases page 3.10.1-3)

Additionally, even with required minimum reactor coolant temperatures < 200°F, RCS temperatures may drift above 200°F during the performance of system leakage and hydrostatic testing or during subsequent control rod scram time testing, which is typically performed in conjunction with system leakage and hydrostatic testing. While this Special Operations LC0 is provided for system leakage and hydrostatic testing, and for scram time testing initiated in conjunction with a system leakage or hydrostatic test, parallel performance of other tests and inspections is not precluded.

INSERT E (for TS Bases page 3.10.1-3) and for control rod scram time testing initiated in conjunction with a system leakage or hydrostatic test.

INSERT F (for TS Bases page 3.10.1-3)

, or as a consequence of control rod scram time testing initiated in conjunction with a system leakage or hydrostatic test,