ML080860492
| ML080860492 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/08/2008 |
| From: | Richard Guzman NRC/NRR/ADRO/DORL/LPLI-1 |
| To: | Polson K Nine Mile Point |
| Guzman R | |
| References | |
| TAC MD7062 | |
| Download: ML080860492 (15) | |
Text
April 8, 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: TECHNICAL SPECIFICATION IMPROVEMENT TO ELIMINATE REQUIREMENTS FOR HYDROGEN RECOMBINERS AND HYDROGEN/OXYGEN MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MD7062)
Dear Mr. Polson:
The Commission has issued the enclosed Amendment No. 124 to Renewed Facility Operating License (FOL) No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated October 22, 2007.
The amendment revises TSs by deleting the TS requirements related to the hydrogen recombiners and hydrogen and oxygen monitors. A notice of availability for this TS improvement using the consolidated line item improvement process was published in the Federal Register on September 25, 2003 (68 FR 55416). In addition, the amendment revises FOL No. NPF-69 by deleting paragraph 2.C.(11a) from the FOL, and retaining the current licensing basis hydrogen monitoring requirements in the NMP2 Updated Safety Analysis Report.
A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Richard V. Guzman, Senior 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. 124 to NPF-69
- 2. Safety Evaluation cc w/encls: See next page
April 8, 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: TECHNICAL SPECIFICATION IMPROVEMENT TO ELIMINATE REQUIREMENTS FOR HYDROGEN RECOMBINERS AND HYDROGEN/OXYGEN MONITORS USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (TAC NO. MD7062)
Dear Mr. Polson:
The Commission has issued the enclosed Amendment No. 124 to Renewed Facility Operating License (FOL) No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No. 2 (NMP2). The amendment consists of changes to the Technical Specifications (TSs) in response to your application transmitted by letter dated October 22, 2007.
The amendment revises TSs by deleting the TS requirements related to the hydrogen recombiners and hydrogen and oxygen monitors. A notice of availability for this TS improvement using the consolidated line item improvement process was published in the Federal Register on September 25, 2003 (68 FR 55416). In addition, the amendment revises FOL No. NPF-69 by deleting paragraph 2.C.(11a) from the FOL, and retaining the current licensing basis hydrogen monitoring requirements in the NMP2 Updated Safety Analysis Report.
A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Richard V. Guzman, Senior 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. 124 to NPF-69
- 2. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
(See next page)
Package No.: ML080860519 Amendment No.: ML080860492 Tech Spec No.: ML080860510
- SE provided by memo. No substantial changes made.
OFFICE LPLI-1/PM LPLI-1/LA ITSB/BC DSS/SCVB/BC LPLI-1/BC NAME RGuzman SLittle TKobetz* RDennig MKowal DATE 4/2/08 4/2/08 1/4/08 SE DTD 4/2/08 4/8/08 OFFICIAL RECORD COPY
DATED: April 8, 2008 AMENDMENT NO. 124 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT, UNIT NO. 2 PUBLIC LPLI-1 SLittle RidsNrrLASLittle RGuzman RidsNrrPMRGuzman OGC RidsOGCRp GHill (2)
TKobetz RidsNrrDirsItsb RDennig RidsNrrDssScvb ALising RLobel ACRS RidsNrrAcrsAcnwMailCenter GDentel, RI RidsRgn1MailCenter cc: Plant Service list
Nine Mile Point Nuclear Station, Unit No. 2 cc:
Mr. Michael J. Wallace, President Mr. Paul D. Eddy Constellation Energy Nuclear Group, LLC New York State Department of 750 East Pratt Street, 18th Floor Public Service Baltimore, MD 21202 3 Empire State Plaza, 10th Floor Albany, NY 12223 Mr. John M. Heffley Senior Vice President and Chief Mark J. Wetterhahn, Esquire Nuclear Officer Winston & Strawn Constellation Energy Nuclear Generation 1700 K Street, NW Group Washington, DC 20006 111 Market Place Baltimore, MD 21202 Carey W. Fleming, Esquire Sr. Counsel - Nuclear Generation Mr. Terry F. Syrell Constellation Energy Nuclear Group, LLC Director, Licensing 750 East Pratt Street, 17th Floor Nine Mile Point Nuclear Station Baltimore, MD 21202 P.O. Box 63 Lycoming, NY 13093 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. Paul Tonko Resident Inspector President and CEO U.S. Nuclear Regulatory Commission New York State Energy, Research, and P.O. Box 126 Development Authority Lycoming, NY 13093 17 Columbia Circle Albany, NY 12203-6399 Supervisor Town of Scriba Mr. James R. Evans Route 8, Box 382 LIPA Oswego, NY 13126 P.O. Box 129 Lycoming, NY 10393 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271
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. 124 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 October 22, 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 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. 124 , 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:
ATTACHMENT TO LICENSE AMENDMENT NO. 124 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 Replace the following pages of the Renewed Facility Operating License with the attached revised pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages 4 4 6 6 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment numbers and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages iii iii 3.3.3.1-3 3.3.3.1-3 3.3.3.1-4 3.3.3.1-4 3.6.3.1-1 3.6.3.1-1 3.6.3.1-2 ---
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 124 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 October 22, 2007 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML072960625), Nine Mile Point Nuclear Station, LLC (NMPNS, or the licensee) submitted a license amendment request (LAR) for changes to the Nine Mile Point Nuclear Station Unit No. 2 (NMP2) Technical Specifications (TSs) and the Renewed Facility Operating License (FOL). The proposed amendment would delete the TS requirements related to the hydrogen recombiners and hydrogen/oxygen monitors.
Specifically, the proposed amendment would delete NMP2 TS 3.6.3.1, Primary Containment Hydrogen Recombiners, and the references to the hydrogen and oxygen monitors in NMP2 TS 3.3.3.1, Post Accident Monitoring (PAM) Instrumentation. The proposed amendment would also delete paragraph 2.C.(11a), Additional Condition 3, of the Renewed Facility Operating License (FOL) No. NPF-69 and retain the current licensing basis hydrogen monitoring requirement in the NMP2 Updated Safety Analysis Report (USAR). FOL paragraph 2.C.(11a) requires establishing containment hydrogen monitoring within 90 minutes of initiating emergency core cooling following a loss-of-coolant accident (LOCA).
The Nuclear Regulatory Commission (NRC) has revised Title 10 of the Code of Federal Regulations (10 CFR) Section 50.44, "Combustible gas control for nuclear power reactors." The amended standards eliminated the requirements for hydrogen recombiners and relaxed the requirements for hydrogen and oxygen monitoring. In letters dated December 17, 2002, and May 12, 2003, the Nuclear Energy Institute (NEI) Technical Specification Task Force (TSTF) proposed to remove requirements for hydrogen recombiners and hydrogen and oxygen monitors from the standard technical specifications (STS) (NUREGs 1430 - 1434) on behalf of the industry to incorporate the amended standards. This proposed change is designated TSTF-447.
The NRC staff prepared this model safety evaluation (SE) for the elimination of requirements regarding containment hydrogen recombiners and the removal of requirements from TS for containment hydrogen and oxygen monitors and solicited public comment (67 FR 50374, published August 2, 2002) in accordance with the Consolidated Line Item Improvement Process (CLIIP). The use of the CLIIP in this matter is intended to help the NRC to efficiently process amendments that propose to remove the hydrogen recombiner and hydrogen and oxygen
monitor requirements from TS. Licensees of nuclear power reactors to which this model applies were informed (68 FR 55416; September 25, 2003) that they could request amendments conforming to the model, and, in such requests, should confirm the applicability of this SE to their reactors and provide the requested plant-specific verifications and commitments.
2.0 BACKGROUND
Regulatory Issue Summary 2000-06, "Consolidated Line Item Improvement Process for Adopting Standard Technical Specification Changes for Power Reactors," was issued on March 20, 2000. The CLIIP is intended to improve the efficiency of NRC licensing processes.
This is accomplished by processing proposed changes to the STS in a manner that supports subsequent license amendment applications. The CLIIP includes an opportunity for the public to comment on proposed changes to the STS following a preliminary assessment by the NRC staff and finding that the change will likely be offered for adoption by licensees. The NRC staff evaluates any comments received for a proposed change to the STS and either reconsiders the change or proceeds with announcing the availability of the change for proposed adoption by licensees. Those licensees opting to apply for the subject change to TS are responsible for reviewing the NRC staff's evaluation, referencing the applicable technical justifications, and providing any necessary plant-specific information. Each amendment application made in response to the notice of availability would be processed and noticed in accordance with applicable rules and NRC procedures.
The Commissions regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36. This regulation requires that the TSs include items in five specific categories.
These categories include 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation (LCO), 3) surveillance requirements, 4) design features, and 5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plants license.
Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether an LCO is required to be included in the TSs. These criteria are as follows:
- 1. Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
- 2. A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that assumes either the failure of or presents a challenge to the integrity of a fission product barrier.
- 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
- 4. A structure, system or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.
Existing LCOs and related surveillances included as TS requirements which satisfy any of the criteria stated above must be retained in the TSs. Those TS requirements which do not satisfy these criteria may be relocated to other licensee-controlled documents.
As part of the rulemaking that revised 10 CFR 50.44, the Commission retained requirements for ensuring a mixed atmosphere, inerting Mark I and II containments, and providing hydrogen control systems capable of accommodating an amount of hydrogen generated from a metal-water reaction involving 75 percent of the fuel cladding surrounding the active fuel region in Mark III and ice condenser containments. The Commission eliminated the design-basis LOCA hydrogen release from 10 CFR 50.44 and consolidated the requirements for hydrogen and oxygen monitoring to 10 CFR 50.44 while relaxing safety classifications and licensee commitments to certain design and qualification criteria. The Commission also relocated without change the hydrogen control requirements in 10 CFR 50.34(f) to 10 CFR 50.44 and the high point vent requirements from 10 CFR 50.44 to 10 CFR 50.46a.
3.0 TECHNICAL EVALUATION
The ways in which the requirements and recommendations for combustible gas control were incorporated into the licensing bases of commercial nuclear power plants varied as a function of when plants were licensed. Plants that were operating at the time of the Three Mile Island (TMI), Unit 2 accident are likely to have been the subject of confirmatory orders that imposed the combustible gas control functions described in NUREG-0737, "Clarification of TMI Action Plan Requirements," as requirements. The issuance of plant-specific amendments to adopt these changes, which would remove hydrogen recombiner and hydrogen and oxygen monitoring controls from TS, supersede the combustible gas control specific requirements imposed by post-TMI confirmatory orders.
3.1 Hydrogen Recombiners The revised 10 CFR 50.44 no longer defines a design-basis LOCA hydrogen release, and eliminates requirements for hydrogen control systems to mitigate such a release. The installation of hydrogen recombiners and/or vent and purge systems required by 10 CFR 50.44(b)(3) was intended to address the limited quantity and rate of hydrogen generation that was postulated from a design-basis LOCA. The Commission has found that this hydrogen release is not risk-significant because the design-basis LOCA hydrogen release does not contribute to the conditional probability of a large release up to approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the onset of core damage. In addition, these systems were ineffective at mitigating hydrogen releases from risk-significant beyond design-basis accidents. Therefore, the Commission eliminated the hydrogen release associated with a design-basis LOCA from 10 CFR 50.44 and the associated requirements that necessitated the need for the hydrogen recombiners and the backup hydrogen vent and purge systems. As a result, the NRC staff finds that requirements related to hydrogen recombiners no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in the TSs and the existing TSs requirements may, therefore, be eliminated for all plants.
3.2 Hydrogen Monitoring Equipment Section 50.44(b)(1), the STS, and plant-specific TS currently contain requirements for monitoring hydrogen. Licensees have also made commitments to design and qualification criteria for hydrogen monitors in Item II.F.1, Attachment 6 of NUREG-0737 and Regulatory Guide (RG) 1.97, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident." The hydrogen monitors are required to assess the degree of core damage during a beyond design-basis accident and confirm that random or deliberate ignition has taken place. If an explosive mixture that could threaten containment integrity exists during a beyond design-basis accident, then other severe accident management strategies, such as purging and/or venting, would need to be considered.
The hydrogen monitors are needed to implement these severe accident management strategies.
With the elimination of the design-basis LOCA hydrogen release, hydrogen monitors are no longer required to mitigate design-basis accidents and, therefore, the hydrogen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends classifying the hydrogen monitors as Category 1. RG 1.97 Category 1, is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events and, therefore, are items usually addressed within the TSs. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that the hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. The Commission concluded that Category 3, as defined in RG 1.97, is an appropriate categorization for the hydrogen monitors because the monitors are required to diagnose the course of beyond design-basis accidents. Hydrogen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Section 4 of Attachment 2 to SECY-00-0198, "Status Report on Study of Risk-Informed Changes to the Technical Requirements of 10 CFR Part 50 (Option 3) and Recommendations on Risk-Informed Changes to 10 CFR 50.44 (Combustible Gas Control)," found that the hydrogen monitors were not risk-significant. Therefore, the NRC staff finds that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(c)(2)(ii) for retention in the TSs and, therefore, may be relocated to other licensee-controlled documents. However, because the monitors are required to diagnose the course of beyond design-basis accidents, each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.
The elimination of Post-Accident Sampling System requirements from some plant-specific TS (and associated CLIIP notices) indicated that during the early phases of an accident, safety-grade hydrogen monitors provide an adequate capability for monitoring containment hydrogen concentration. The NRC staff has subsequently concluded that Category 3 hydrogen monitors also provide an adequate capability for monitoring containment hydrogen concentration during the early phases of an accident.
The deletion of the requirements for the hydrogen recombiner and hydrogen monitors resulted in numbering and formatting changes to other TSs, which were otherwise unaffected by the proposed amendments. The NRC staff has confirmed that the related changes are appropriate
and do not affect the technical requirements. The licensee included in its submittal possible changes to the affected TS Bases pages. The licensee will formally address the changes to the TS Bases in accordance with its Bases Control Program.
3.3 Oxygen Monitoring Equipment STS and plant-specific TS currently require oxygen monitoring to verify the status of the inert containment. Combustible gases produced by beyond design-basis accidents involving both fuel-cladding oxidation and core-concrete interaction would be risk-significant for plants with Mark I and II containments if not for the inerted containment atmospheres. If an inerted containment was to become de-inerted during a beyond design-basis accident, then other severe accident management strategies, such as purging and venting, would need to be considered. The oxygen monitors are needed to implement these severe accident management strategies. Monitoring oxygen concentration also appears extensively in the emergency procedure guidelines/severe accident guidelines of plants with inerted containment atmospheres.
With the elimination of the design-basis LOCA hydrogen release, the oxygen monitors are no longer required to mitigate design-basis accidents and, therefore, the oxygen monitors do not meet the definition of a safety-related component as defined in 10 CFR 50.2. RG 1.97 recommends that, for inerted containment plants, the oxygen monitors be Category 1 which is intended for key variables that most directly indicate the accomplishment of a safety function for design-basis accident events. As part of the rulemaking to revise 10 CFR 50.44, the Commission found that Category 2, as defined in RG 1.97, is an appropriate categorization for the oxygen monitors, because the monitors are required to verify the status of the inert containment. Oxygen monitoring is not the primary means of indicating a significant abnormal degradation of the reactor coolant pressure boundary. Oxygen monitors have not been shown by a probabilistic risk assessment to be risk-significant. Therefore, the NRC staff finds that oxygen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(d)(2)(ii) for retention in TS and, therefore, may be relocated to other licensee controlled documents.
However, for plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inerted containment. In addition, separate requirements for primary containment oxygen concentration will be retained in TS for plant designs with an inerted containment. The basis for retention of this requirement in TS is that it meets Criterion 2 of 10 CFR 50.36(d)(2)(ii) in that it is a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. This is based on the fact that calculations typically included in Chapter 6 of Updated Final Safety Analysis Reports assume that the primary containment is inerted, that is, oxygen concentration < 4.0 volume percent, when a design-basis LOCA occurs.
The deletion of the requirements for the hydrogen recombiner, and hydrogen and oxygen monitors resulted in numbering and formatting changes to TS Surveillance Requirements 3.3.3.1.2 and 3.3.3.1.3, which were otherwise unaffected by this proposed amendment. The NRC staff has confirmed that the related changes are appropriate and do not affect the TSs.
3.4 Renewed FOL Paragraph 2.C.(11a)
The licensee proposed to delete paragraph 2.C.(11a) from the FOL, and retain the current licensing basis hydrogen monitoring requirement in the NMP2 USAR. FOL paragraph 2.C.(11a), Additional Condition 3, states:
The operating licensee shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating emergency core cooling (safety injection) following a loss of coolant accident.
The licensees proposed revision is a plant-specific change that is in addition to the TS changes identified in TSTF-447. The above license condition was added to the NMP2 Operating License by Amendment No. 102, dated February 25, 2002 (ADAMS Accession No. ML020370424) to change the licensing basis time requirement for establishing containment hydrogen monitoring (after initiation of safety injection) from 30 minutes to 90 minutes.
As stated in Section 3.2 of this SE, the revised 10 CFR 50.44 eliminated the design-basis LOCA hydrogen release. Hydrogen monitors are no longer required to mitigate design-basis accidents and therefore, do not meet the definition of a safety-related component as defined in 10 CFR 50.2. As part of the rulemaking to revise 10 CFR 50.44, the Commission also concluded that hydrogen monitors no longer meet the definition of Category 1 in RG 1.97. In addition, the NRC staff determined that hydrogen monitoring equipment requirements no longer meet any of the four criteria in 10 CFR 50.36(d)(2)(ii) for retention in the TSs and, therefore, may be relocated to other licensee-controlled documents. The NRC staff considers the proposed change to relocate paragraph 2.C.(11a) to be consistent with the revision of 10 CFR 50.44. The NRC staff has verified that the licensee maintains the 90-minute containment hydrogen monitoring initiation requirement as part of its licensing basis, and is currently retained in the NMP2 USAR, Sections 1.9 and 1.10. Based on the above, the NRC staff finds it acceptable to delete paragraph 2.C.(11a) from the NMP2 Operating License.
4.0 VERIFICATIONS AND COMMITMENTS As requested by the NRC staff in the notice of availability for this TS improvement, the licensee has addressed the following plant-specific verifications and commitments.
4.1 Each licensee should verify that it has, and make a regulatory commitment to maintain, a hydrogen monitoring system capable of diagnosing beyond design-basis accidents.
The licensee has verified that it has a hydrogen monitoring system capable of diagnosing beyond design-basis accidents. The licensee has committed to include the hydrogen monitors within the post accident monitoring instrument program described in the NMP2 USAR. The licensee will revise the USAR at the next scheduled update following implementation of these amendments.
4.2 For plant designs with an inerted containment, each licensee should verify that it has, and make a regulatory commitment to maintain, an oxygen monitoring system capable of verifying the status of the inert containment.
The licensee has verified that it has an oxygen monitoring system capable of verifying the status of an inerted containment. The licensee has committed to maintain the oxygen monitors within the NMP2 Technical Requirements Manual (TRM). The licensee will implement this commitment within 60 days from the date of the approval of this proposed amendment.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.
The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements which would require prior NRC approval of subsequent changes. The NRC staff has agreed that NEI 99-04, Revision 0, "Guidelines for Managing NRC Commitment Changes,"
provides reasonable guidance for the control of regulatory commitments made to the NRC staff.
(See Regulatory Issue Summary 2000-17, "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff," dated September 21, 2000.) The commitments should be controlled in accordance with the industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.
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 amendments change 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 change the surveillance requirements. The NRC staff has determined that the amendments involve 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding [72 FR 68217]. Accordingly, the amendments meet 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 amendments.
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 Contributors: A. Jason Lising R. Guzman Date: April 8, 2008