ML080170139

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License Amendment 122 Revision to Drywell Spray Nozzle Testing Frequency
ML080170139
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 02/11/2008
From: David M
NRC/NRR/ADRO/DORL/LPLI-1
To: Polson K
Nine Mile Point
david marshall NRR/DORL 415-1547
Shared Package
ML080170156 List:
References
TAC MD6280
Download: ML080170139 (11)


Text

February 11, 2008 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: REVISION TO DRYWELL SPRAY NOZZLE TESTING FREQUENCY (TAC NO. MD6280)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 122 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (NMP-2).

The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated July 30, 2007, as supplemented by letter dated January 3, 2008.

The amendment changes the NMP2 TSs by changing the testing frequency for drywell spray nozzles specified in Surveillance Requirement 3.6.1.6.3 from "10 years" to "following maintenance that could result in nozzle blockage."

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. 122 to NPF-69
2. Safety Evaluation cc w/encls: See next page

February 11, 2008 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: REVISION TO DRYWELL SPRAY NOZZLE TESTING FREQUENCY (TAC NO. MD6280)

Dear Mr. Polson:

The Commission has issued the enclosed Amendment No. 122 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (NMP-2).

The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated July 30, 2007, as supplemented by letter dated January 3, 2008.

The amendment changes the NMP2 TSs by changing the testing frequency for drywell spray nozzles specified in Surveillance Requirement 3.6.1.6.3 from "10 years" to "following maintenance that could result in nozzle blockage."

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. 122 to NPF-69
2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

(See next page)

Package No.: ML080170156 Amendment No.: ML080170139 Tech Spec No.: ML080520616 NRR-058 OFFICE LPLI-1/PM LPLI-1/LA SCVB/BC*

ITSB/BC(A)

OGC LPLI-1/BC NAME MDavid SLittle RDennig GWaig BMizuno MKowal DATE 1/28/08 1/28/08 01/09/08 1/31/08 2/4/08 2/8/08

  • SE transmitted by memo on date shown.

OFFICIAL RECORD COPY

DATED: February 11, 2008 AMENDMENT NO. TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT, UNIT NO. 2 PUBLIC LPLI-1 SLittle RidsNrrLASLittle MDavid RidsNrrPMMDavid OGC RidsOGCRp GHill (2)

RDennig RidsNrrDssScvb RLobel RKaripineni TKobetz RidsNrrDirsItsb ACRS RidsNrrAcrsAcnwMailCenter GDentel, RI RidsRgn1MailCenter cc: Plant Service list

Nine Mile Point Nuclear Station, Unit No. 2 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 Constellation Energy Nuclear Group, LLC 750 East Pratt Street, 17th Floor 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 Mr. James R. Evans LIPA P.O. Box 129 Lycoming, NY 10393

NINE MILE POINT NUCLEAR STATION, LLC (NMPNS)

DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT NO. 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 122 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 30, 2007, as supplemented by letter dated January 3, 2008, 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 I; 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 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. 122, 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 30 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: February 11, 2008

ATTACHMENT TO LICENSE AMENDMENT NO. 122 TO 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 3.6.1.6-2 3.6.1.6-2

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 122 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 30, 2007 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML072150049), as supplemented by letter dated January 3, 2008 (ADAMS Accession No. ML080030300), Nine Mile Point Nuclear Station, LLC (the licensee) submitted a license amendment request (LAR) for changes to the Nine Mile Point Nuclear Station Unit No. 2 (NMP2), Technical Specifications (TSs). The requested change would revise the testing frequency for drywell spray nozzles specified in Surveillance Requirement (SR) 3.6.1.6.3 from "10 years" to "following maintenance that could result in nozzle blockage."

In the LAR, the licensee stated that the current surveillance is done by air flow testing and visual inspections. The licensee also stated that the proposed surveillance, which would require a flow test only in special circumstances, would reduce outage dose and improve personnel safety.

The supplement dated January 3, 2008, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staffs initial proposed no significant hazards consideration determination noticed in the Federal Register on September 11, 2007 (72 FR 51864).

2.0 REGULATORY EVALUATION

The regulatory requirements and guidance that the NRC staff considered in its review of the application include the following:

Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix A, General Design Criterion (GDC) 38, Containment heat removal, requires that a system to remove heat from the reactor containment shall be provided. The system safety function is to rapidly reduce containment pressure and temperature. The drywell spray is one mode of operation of the residual heat removal system, which performs this function.

10 CFR Part 50, Appendix A, GDC 39, Inspection of containment heat removal system, requires that the containment heat removal system be designed to permit periodic inspection. The NMP2 drywell spray system permits verification that the spray nozzles are unobstructed.

10 CFR Part 50, Appendix A, GDC 40, Testing of containment heat removal system, requires that the containment heat removal system be designed for periodic functional testing. The current NMP2 TSs require periodic testing of the drywell spray system nozzles to demonstrate that they are unobstructed at a frequency of 10 years.

3.0 TECHNICAL EVALUATION

The drywell spray system is designed to mitigate the consequences of steam in the drywell as a consequence of a loss-of-coolant accident (LOCA) bypassing the suppression pool and pressurizing the suppression chamber air space. Credit is also taken for the turbulence in the drywell atmosphere generated by the action of the spray to mix the drywell atmosphere to prevent non-uniform hydrogen and oxygen concentrations. The drywell spray also provides for heat removal from the drywell atmosphere and fission product control following a large-break LOCA; however, the licensee stated that no credit is taken for these functions.

The NMP2 containment has two drywell spray spargers. One sparger has 64 nozzles and the other has 59. The NMP2 drywell spray nozzles are made of corrosion resistant Type 304 stainless steel. The drywell spray nozzle orifices are designed to pass particles up to 1 inch in diameter. The piping to the nozzles is Type SA 106 Grade B carbon steel. The licensee stated that the drywell spray system is normally kept dry by the motor operated isolation valves located outside of the drywell to the spray nozzles. However, a small amount of water enters the system during quarterly stroke testing of the isolation valves.

The licensee air flow-tested the spray nozzles during pre-operational testing in 1986 and, subsequently, in 1992 and 1998. Nozzle blockage was not observed during these tests. No maintenance has been performed on the drywell spray piping or nozzles since the last air flow test was performed in 1998. However, the licensee stated that at the initiation of previous air flow tests, a momentary fine dark orange cloud (assumed to be rust particles) was observed exiting the nozzles. The licensee attributes this to rust as a result of the small amount of water entering the system during the quarterly stroke testing of the isolation valves. To reduce the potential for corrosion product generation, the licensee will revise the method for stroke testing to ensure that the drywell spray system remains dry. This new procedure is described in the licensees January 3, 2008, response to an NRC staff request for additional information (RAI).

The January 3, 2008, RAI response also stated that the revised method of stroke testing will be implemented prior to revising the drywell spray nozzle surveillance frequency. The licensee stated that there have been no inadvertent spray actuations that would have wetted the piping or nozzles. If a spray actuation were to occur, the licensee stated that an outage would be necessary to assess the operability of equipment in the drywell and the spray lines would be drained before startup.

The NRC staffs review of industry experience found that spray systems of similar design are highly reliable (i.e., not susceptible to plugging). The NRC staff also found that, in general, once tested after construction, containment spray nozzles have not been subject to blockage. In the case of one pressurized-water reactor, debris was discovered in this piping. The debris was

identified as construction material. The fraction of blockage was not significant and the sprays remained functional. The debris was found by visual observation, not by an air flow test.

Due to their location at the top of the containment, introduction of foreign material from inside the piping to the nozzles is unlikely. In addition, the nozzles are oriented downward. Because maintenance that could introduce foreign material is the most likely cause for obstruction, flow testing or inspection following maintenance or testing in which a breakdown of the foreign material exclusion (FME) program occurs would suffice to verify the absence of nozzle blockage and the systems capability to perform its safety function.

The licensees July 30, 2007, LAR described the NMP2 FME program. The licensees program is based on industry guidance and operating experience. The licensee stated that:

If any material is unaccounted for in an FME area or a general FME concern is observed, a condition report is initiated in the corrective action program which would provide for a determination of the scope of the issue, the actions necessary to return the area to the required level of cleanliness, and whether testing is necessary.

For these reasons, the NRC staff considers the potential for nozzle obstruction very low and, therefore, the 10-year test frequency may be relaxed. Verifying that the nozzles are not obstructed following maintenance that could introduce foreign materials internal to the spray ring headers is an acceptable surveillance.

The NRC staff concludes that the licensees proposal to revise the SR 3.6.1.6.3 frequency from 10 years to following maintenance that could result in nozzle blockage is acceptable, because the licensee maintains an effective FME program and will take steps to maintain the system dry in order to eliminate corrosion of the metal piping. This surveillance maintains the drywell spray systems capability to satisfy GDCs 38, 39, and 40.

4.0 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.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, and changes an SR.

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 previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (72 FR 51864). 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.

6.0 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 Contributors: R. Lobel R. Karipineni Date: February 11, 2008