ML072910203

Issuance of Amendment Technical Specification Change for New Banked Position Withdrawal Sequence for Control Rod Insertion, Using the Consolidated Line Item Improvement Process

ML072910203
Person / Time
Site:	Nine Mile Point
Issue date:	10/26/2007
From:	David M NRC/NRR/ADRO/DORL/LPLI-1
To:	Polson K Nine Mile Point
david marshall NRR/DORL 415-1547
References
TAC MD6205
Download: ML072910203 (9)

Text

October 26, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION CHANGE FOR NEW BANKED POSITION WITHDRAWAL SEQUENCE FOR CONTROL ROD INSERTION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MD6205)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 120 to Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The amendment consists of changes to the Technical Specification (TS) 3.3.2.1, Control Rod Block Instrumentation, in response to your application dated July 23, 2007. .

The amendment modifies a footnote in NMP2 TS Table 3.3.2.1-1, thereby allowing a new banked position withdrawal sequence for shutdown, using the Consolidated Line Item Improvement Process.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 120 to NPF-69

2. Safety Evaluation cc w/encls: See next page

October 26, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 2 - ISSUANCE OF AMENDMENT RE: TECHNICAL SPECIFICATION CHANGE FOR NEW BANKED POSITION WITHDRAWAL SEQUENCE FOR CONTROL ROD INSERTION, USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MD6205)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 120 to Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The amendment consists of changes to the Technical Specification (TS) 3.3.2.1, Control Rod Block Instrumentation, in response to your application dated July 23, 2007. .

The amendment modifies a footnote in NMP2 TS Table 3.3.2.1-1, thereby allowing a new banked position withdrawal sequence for shutdown, using the Consolidated Line Item Improvement Process.

A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's next regular biweekly Federal Register notice.

Sincerely,

/RA/

Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 120 to NPF-69

2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC RidsNrrPMMDavid RidsNrrDirsItsb RidsNrrAcrsAcnwMailCenter LPLI-1 SLittle RidsOGCRp RidsRgn1MailCenter GHill (2) ALising Package No.: ML072990277 Amendment No.: ML072910203 Tech Spec No.: ML072990500 NRR-058 OFFICE LPLI-1\PM LPLI-1\LA ITSB/BC

• OGC LPLI-1/BC NAME MDavid SLittle TKobetz EWilliamson MKowal DATE 10/18/07 10/18/07 10/18/07 10/24/07 10/26/07

• SE transmitted by memo of 10/18/07.

OFFICIAL RECORD COPY

Nine Mile Point Nuclear Station, Unit No. 2 cc:

Mr. Michael J. Wallace, President Mark J. Wetterhahn, Esquire Constellation Generation Group Winston & Strawn 750 East Pratt Street 1700 K Street, NW Baltimore, MD 21202 Washington, DC 20006 Mr. Mike Heffley Carey W. Fleming, Esquire Senior Vice President and Chief Senior Counsel Nuclear Officer Constellation Generation Group, LLC Constellation Generation Group 750 East Pratt Street, 17th Floor 1997 Annapolis Exchange Parkway Baltimore, MD 21202 Suite 310 Annapolis, MD 21401 Mr. John P. Spath New York State Energy, Research, and Regional Administrator, Region I Development Authority U.S. Nuclear Regulatory Commission 17 Columbia Circle 475 Allendale Road Albany, NY 12203-6399 King of Prussia, PA 19406 Mr. Michael Balboni Resident Inspector Deputy Secretary for Public Safety U.S. Nuclear Regulatory Commission State Capitol, Room 229 P.O. Box 126 Albany, NY 12224 Lycoming, NY 13093 Mr. James R. Evans Supervisor LIPA Town of Scriba P.O. Box 129 Route 8, Box 382 Lycoming, NY 10393 Oswego, NY 13126 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy Electric Division NYS Department of Public Service Agency Building 3 Empire State Plaza Albany, NY 12223

NINE MILE POINT NUCLEAR STATION, LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 120 Renewed License No. NPF-69

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nine Mile Point Nuclear Station, LLC (the licensee) dated July 23, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter 1; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-69 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 120 are hereby incorporated into this license.

Nine Mile Point Nuclear Station, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Mark G. Kowal, Chief Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the License and Technical Specifications Date of Issuance: October 26, 2007

ATTACHMENT TO LICENSE AMENDMENT NO. 120 RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 4 4 Replace the following page of Appendix A, Technical Specifications, with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.

Remove Page Insert Page 3.3.2.1-6 3.3.2.1-6

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 120 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO. 2 DOCKET NO. 50-410

1.0 INTRODUCTION

By letter dated July 23, 2007 (Agencywide Documents and Management System (ADAMS)

Accession No. ML072120592), Nine Mile Point Nuclear Station, LLC (the licensee) requested a change to the Technical Specifications (TSs) for Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The requested change is the adoption of Technical Specification Task Force (TSTF) change traveler TSTF-476, Revision 1, Improved BPWS [Banked Position Withdrawal Sequence] Control Rod Insertion Process (NEDO-33091-A), to the Boiling Water Reactor (BWR) Standard Technical Specifications (STS; NUREG-1433 and NUREG-1434), which was proposed by the TSTF by letter dated January 9, 2007. This TSTF involves changes to NUREG-1433 and NUREG-1434, Section 3.1.6, Rod Pattern Control, Section 3.3.2.1, Control Rod Block Instrumentation, and Table 3.3.2.1-1. The proposed TSTF would allow the use of the improved BPWS during shutdowns if the conditions of Licensing Topical Report NEDO-33091-A, Revision 2, Improved BPWS Control Rod Insertion Process, dated July 2004, have been satisfied. A notice announcing the availability of this proposed TS change using the consolidated line item improvement process (CLIIP) was published in the Federal Register on May 23, 2007 (72 FR 29004).

2.0 REGUATORY EVALUATION The control rod drop accident (CRDA) is the design-basis accident for the subject TS changes.

In order to minimize the impact of a CRDA, the BPWS process was developed to minimize control rod reactivity worth for BWR plants. The proposed improved BPWS further simplifies the control rod insertion process and, in order to evaluate it, the Nuclear Regulatory Commission (NRC) staff followed the guidelines of Standard Review Plan Section 15.4.9, and referred to General Design Criterion (GDC) 28 of Appendix A to Title 10 of the Code of Federal Regulations (10 CFR) Part 50 as its regulatory requirement. GDC 28 states that the reactivity control systems shall be designed with appropriate limits on the potential amount and rate of reactivity increase to assure that the effects of postulated reactivity accidents can neither (1) result in damage to the reactor coolant pressure boundary greater than limited local yielding, nor (2) sufficiently disturb the core, its support structures, or other reactor pressure vessel internals to impair significantly the capability to cool the core.

3.0 TECHNICAL EVALUATION

In its June 16, 2004, safety evaluation (SE) for NEDO-33091-A (ADAMS Accession No. ML041700479), the NRC staff determined that the methodology described in TSTF-476, Revision 1, to incorporate the improved BPWS into the STS, is acceptable.

TSTF-476, Revision 1 states that the improved BPWS provides the following benefits: (1) allows the plant to reach the all-rods-in condition prior to significant reactor cool down, which reduces the potential for re-criticality as the reactor cools down; (2) reduces the potential for an operator reactivity control error by reducing the total number of control rod manipulations; (3) minimizes the need for manual scrams during plant shutdowns, resulting in less wear on control rod drive (CRD) system components and CRD mechanisms; and, (4) eliminates unnecessary control rod manipulations at low power, resulting in less wear on reactor manual control and CRD system components.

NMP2 has been approved to use the improved BPWS, and the potential for a CRDA with power below the low power set point (LPSP) has been eliminated. The SE for NEDO-33091-A explained that the potential for the CRDA will be eliminated by the following changes to operational procedures, which NMP2 has committed to make prior to implementation:

1. Before reducing power to the LPSP, operators shall confirm control rod coupling integrity for all rods that are fully withdrawn. Control rods that have not been confirmed coupled and are in intermediate positions must be fully inserted prior to power reduction to the LPSP. No action is required for fully-inserted control rods.

If a shutdown is required and all rods, which are not confirmed coupled, cannot be fully inserted prior to power dropping below the LPSP, then the original/standard BPWS must be adhered to.

2. After reactor power drops below the LPSP, rods may be inserted from notch position 48 to notch position 00 without stopping at the intermediate positions. However, General Electric Nuclear Energy recommends that operators insert rods in the same order as specified for the original/standard BPWS as much as reasonably possible. If a plant is in the process of shutting down following improved BPWS with the power below the LPSP, no control rod shall be withdrawn unless the control rod pattern is in compliance with standard BPWS requirements.

In addition to the procedure changes specified above, the NRC staff previously verified during its review of NEDO-33091-A, Revision 2 that no single failure of the BWR CRD mechanical or hydraulic system can cause a control rod to drop completely out of the reactor core during the shutdown process. Therefore, the proper use of the improved BPWS will prevent a CRDA from occurring while power is below the LPSP.

The NRC staff finds the proposed TS change in the NMP2 request properly incorporates the improved BPWS procedure into the STS, and that NMP2 accurately adopted TSTF-476 and has committed to make the requisite procedural changes. Therefore, the NRC staff approves the NMP2 request to adopt TSTF-476, Revision 1.

4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION On October 9, 2007, the licensee verbally informed the NRC staff that it had made the decision to shut down NMP2 in early November 2007 for a 2-week period; the licensee requested that this amendment be issued to implement the new BPWS shutdown process for the outage. The Commission had previously issued a proposed finding that the amendment involves no significant hazards consideration; the finding was published on September 25, 2007 (72 FR 54477). This amendment is being issued prior to the expiration of the 60-day period.

The Commission may issue a license amendment before the expiration of the 60-day period provided that its final determination is that the amendment involves no significant hazards consideration. Therefore, a final finding of no significant hazards consideration follows.

The Commission has made a final determination that the amendment request involves no significant hazards consideration. Under the Commissions regulations in 10 CFR 50.92, this means that operation of the facility in accordance with the proposed amendment does not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. In its request dated July 23, 2007, the licensee incorporated by reference the proposed no significant hazards consideration determination published in the Federal Register on May 23, 2007 (72 FR 29004) as part of the CLIIP, to satisfy the requirements of 10 CFR 50.91(a). The subject proposed no significant hazards consideration determination is presented below.

Criterion 1--The Proposed Change Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated.

The proposed changes modify the TS to allow the use of the improved banked position withdrawal sequence (BPWS) during shutdowns if the conditions of NEDO-33091-A, Revision 2, Improved BPWS Control Rod Insertion Process, July 2004, have been satisfied. The [NRC] staff finds that the licensees justifications to support the specific TS changes are consistent with the approved topical report and TSTF-476, Revision 1.

Since the change only involves changes in control rod sequencing, the probability of an accident previously evaluated is not significantly increased, if at all. The consequences of an accident after adopting TSTF-476 are no different than the consequences of an accident prior to adopting TSTF-476. Therefore, the consequences of an accident previously evaluated are not significantly affected by this change. Therefore, this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Criterion 2--The Proposed Change Does Not Create the Possibility of a New or Different Kind of Accident from any [Accident] Previously Evaluated.

The proposed change will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated. The control rod drop accident (CRDA) is the design basis accident for the subject TS changes. This change does not create the possibility of a new or different kind of accident from [any] accident previously evaluated.

Criterion 3--The Proposed Change Does Not Involve a Significant Reduction in the [a]

Margin of Safety.

The proposed change, TSTF-476, Revision 1, incorporates the improved BPWS, previously approved in NEDO- 33091-A, into the improved TS. The control rod drop accident (CRDA) is the design basis accident for the subject TS changes. In order to minimize the impact of a CRDA, the BPWS process was developed to minimize control rod reactivity worth for BWR plants. The proposed improved BPWS further simplifies the control rod insertion process, and in order to evaluate it, the [NRC] staff followed the guidelines of Standard Review Plan Section 15.4.9, and referred to General Design Criterion 28 of Appendix A to 10 CFR Part 50 as its regulatory requirement. The TSTF stated the improved BPWS provides the following benefits: (1) Allows the plant to reach the all-rods-in condition prior to significant reactor cool down, which reduces the potential for re-criticality as the reactor cools down; (2) reduces the potential for an operator reactivity control error by reducing the total number of control rod manipulations; (3) minimizes the need for manual scrams during plant shutdowns, resulting in less wear on control rod drive (CRD) system components and CRD mechanisms; and (4) eliminates unnecessary control rod manipulations at low power, resulting in less wear on reactor manual control and CRD system components. The addition of procedural requirements and verifications specified in NEDO-33091-A, along with the proper use of the BPWS will prevent a control rod drop accident (CRDA) from occurring while power is below the low power setpoint (LPSP). The net change to the margin of safety is insignificant.

Therefore, this change does not involve a significant reduction in a margin of safety.

The NRC staff has reviewed the licensees analysis, incorporated by reference. Based on this review, the NRC staff has found that the three standards of 10 CFR 50.92(c) are satisfied.

Therefore, the NRC staff has determined that the amendments involve no significant hazards consideration.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.

6.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final no significant hazards consideration determination with respect to this amendment. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: A. Jason Lising Date: October 26, 2007