ML073250135
| ML073250135 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/27/2007 |
| From: | David M NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Polson K Nine Mile Point |
| david marshall NRR/DORL 415-1547 | |
| References | |
| TAC MD6215 | |
| Download: ML073250135 (5) | |
Text
November 27, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO. 1, REVISION OF ROD WORTH MINIMIZER LIMITIMG CONDITION FOR OPERATION DURING STARTUP (TAC NO. MD6215)
Dear Mr. Polson:
By letter dated July 23, 2007, Nine Mile Point Nuclear Station, LLC requested an amendment to the Nine Mile Point Nuclear Station, Unit No. 1 (NMP1) Renewed Facility Operating License.
The proposed license amendment would revise Technical Specification (TS) Section 3.1.1, "Control Rod System," to incorporate a provision that, should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue. This provision would rely on the RWM function being performed manually and would require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. The use of this allowance would be limited to one startup in the last calendar year.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in that letter and has determined that additional information is needed to complete its review. Enclosed is the NRC staffs request for additional information (RAI). The RAI was discussed with your staff on November 15, 2007, and it was agreed that your response would be provided within 60 days from the date of this letter.
Sincerely,
/RA/
Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
RAI cc w/encl: See next page
November 27, 2007 Mr. Keith J. Polson Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO. 1, REVISION OF ROD WORTH MINIMIZER LIMITIMG CONDITION FOR OPERATION DURING STARTUP (TAC NO. MD6215)
Dear Mr. Polson:
By letter dated July 23, 2007, Nine Mile Point Nuclear Station, LLC requested an amendment to the Nine Mile Point Nuclear Station, Unit No. 1 (NMP1) Renewed Facility Operating License.
The proposed license amendment would revise Technical Specification (TS) Section 3.1.1, "Control Rod System," to incorporate a provision that, should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue. This provision would rely on the RWM function being performed manually and would require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. The use of this allowance would be limited to one startup in the last calendar year.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in that letter and has determined that additional information is needed to complete its review. Enclosed is the NRC staffs request for additional information (RAI). The RAI was discussed with your staff on November 15, 2007, and it was agreed that your response would be provided within 60 days from the date of this letter.
Sincerely,
/RA/
Marshall J. David, Project Manager Plant Licensing Branch I-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrPMMDavid RidsNrrDssSrxb RidsNrrAcrsAcnwMailCenter LPLI-1 RidsNrrLASLittle RidsOGCRp RidsRgn1MailCenter Accession Number.: ML073250135 NRR-088 OFFICE LPLI-1/PM LPLI-1/LA SRXB/BC*
LPLI-1/BC NAME MDavid SLittle GCranston MKowal DATE 11/26/07 11/26/07 11/19/07 11/27/07
- RAIs transmitted by memo dated 11/19/07.
OFFICIAL RECORD COPY
Nine Mile Point Nuclear Station, Unit No. 1 cc:
Mr. Michael J. Wallace, President Constellation Energy Nuclear Group, LLC 750 East Pratt Street, 18th Floor Baltimore, MD 21202 Mr. John M. Heffley Senior Vice President and Chief Nuclear Officer Constellation Energy Nuclear Generation Group 111 Market Place Baltimore, MD 21202 Mr. Terry F. Syrell Director, Licensing Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, NY 13093 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 126 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Paul D. Eddy New York State Department of Public Service 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mark J. Wetterhahn, Esquire Winston & Strawn 1700 K Street, NW Washington, DC 20006 Carey W. Fleming, Esquire Sr. Counsel - Nuclear Generation 750 East Pratt Street, 17th Floor Constellation Energy Nuclear Group, LLC Baltimore, MD 21202 Mr. John P. Spath New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Mr. Paul Tonko President and CEO New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399
Enclosure REQUEST FOR ADDITIONAL INFORMATION NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 REVISION OF ROD WORTH MINIMIZER LIMITIMG CONDITION FOR OPERATION DURING STARTUP The Nuclear Regulatory Commission (NRC) staff has performed its initial review of your July 23, 2007, request to revise Nine Mile Point Nuclear Station, Unit No. 1 (NMP1)
Technical Specification (TS) Section 3.1.1, "Control Rod System," to incorporate a provision that, should the rod worth minimizer (RWM) become inoperable before a reactor startup is commenced or before the first 12 control rods have been withdrawn, startup would be allowed to continue. This provision would rely on the RWM function being performed manually and would require a double check of compliance with the control rod program by a second licensed operator or other qualified member of the technical staff. As a result of that review, the NRC staff has determined that additional information is required to adequately evaluate the acceptability of the proposed changes.
- 1.
The key difference between the current TS 3.1.1.b operability requirement for the RWM during startup, and the proposed TS revision that will allow an individual to perform the function of RWM manually during startup once, in a calendar year (i.e., if not performed in the last 12 months), is that the proposed change will introduce human supervision in place of automatic supervision. The NRC staff believes that manual operation of control rods (CRs) during startup could result in withdrawal of an incorrect CR of high worth due to human error, followed by a Control Rod Drop Accident (CRDA). Therefore, state whether the introduction of the human performance factor was considered while performing the safety analysis of the proposed modification, as part of the NRC staff-approved generic General Electric Standard Application for Reactor Fuel methodology in NEDE-24011-P-A, or on a plant-specific basis. If so, explain how introduction of human performance will not significantly increase the probability of the CRDA previously evaluated.
If the human performance factor was not considered in the safety analysis of the proposed change, then explain why not.
- 2.
It was stated in proposed Insert 1 for TS 3.1.1.b(3)(b)(ii) that, A......provided that a second licensed operator or other qualified member of the technical staff verifies that the licensed operator at the reactor console is following the control rod program.@ Describe the specific qualification requirements, the training program, and the title of the member of the technical staff who will be authorized to perform independent verification of CR movement during the startup when the RWM becomes inoperable.
- 3.
It was stated in proposed Insert 1 for TS 3.1.1.b(3)(b)(iii) that, AShould the rod worth minimizer become inoperable before a startup is commenced or before the first 12 control rods have been withdrawn, the startup may continue provided that a startup with the rod worth minimizer inoperable has not been performed in the last calendar year, Y@.
Please describe the process for determining and for assuring that a startup with the
RWM inoperable has not been performed in the last calendar year. If the RWM is declared inoperable, what is the process for determining the reason for the failure of the RWM and subsequent corrective actions. Describe what NRC reporting requirements will be implemented. For example, some licensees have committed to notify NRC in a special report, within 30 days of the startup, stating the reason for the failure of the RWM, the actions taken to repair it, and the schedule for completion of the repairs.