ML080980135
| ML080980135 | |
| 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 MD6942 | |
| Download: ML080980135 (5) | |
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:
REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO. 1, REVISED OPERABILITY REQUIREMENTS FOR REACTOR COOLANT SYSTEM ISOLATION VALVES (TAC NO. MD6942)
Dear Mr. Polson:
By letter dated September 27, 2007, Nine Mile Point Nuclear Station, LLC requested an amendment to the Nine Mile Point Nuclear Station, Unit No. 1 Renewed Facility Operating License. The requested license amendment would revise the operability requirements in Technical Specification (TS) Section 3.2.7, Reactor Coolant System Isolation Valves, and TS Section 3.6.2, Protective Instrumentation.
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 February 28 and April 7, 2008, and it was agreed that your response would be provided within 60 days from the date of this letter.
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. 50-220
Enclosure:
RAI cc w/encl: 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:
REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO. 1, REVISED OPERABILITY REQUIREMENTS FOR REACTOR COOLANT SYSTEM ISOLATION VALVES (TAC NO. MD6942)
Dear Mr. Polson:
By letter dated September 27, 2007, Nine Mile Point Nuclear Station, LLC requested an amendment to the Nine Mile Point Nuclear Station, Unit No. 1 Renewed Facility Operating License. The requested license amendment would revise the operability requirements in Technical Specification (TS) Section 3.2.7, Reactor Coolant System Isolation Valves, and TS Section 3.6.2, Protective Instrumentation.
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 February 28 and April 7, 2008, and it was agreed that your response would be provided within 60 days from the date of this letter.
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. 50-220
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrPMRGuzman RidsNrrDssScvb RidsNrrAcrsAcnw&mMailCenter LPLI-1 RidsNrrLASLittle RidsOGCRp RidsRgn1MailCenter RKaripineni Accession Number.: ML080980135 OFFICE LPLI-1/PM LPLI-1/LA SCVB/BC LPLI-1/BC NAME RGuzman SLittle RDennig MKowal DATE 4/7/08 4/7/08 4/7/08 4/8/08 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 Mr. James R. Evans LIPA P.O. Box 129 Lycoming, NY 10393
Enclosure REQUEST FOR ADDITIONAL INFORMATION NINE MILE POINT NUCLEAR STATION, UNIT NO. 1 (NMP-1)
REVISED OPERABILITY REQUIREMENTS FOR REACTOR COOLANT SYSTEM ISOLATION VALVES (RCSIVs)
The Nuclear Regulatory Commission (NRC) staff has performed its initial review of your September 27, 2007, license amendment request (LAR) to revise NMP-1 Technical Specification (TS) Section 3.2.7, Reactor Coolant System Isolation Valves, and TS Section 3.6.2, Protective Instrumentation. The NRC staff has determined that additional information requested below will be needed to complete its review.
- 1.
The LAR states (see Section 3, page 4 of 10) that the differences in the requirements of the TS Sections 3.2.7.a and 3.3.4.a have caused uncertainty in applying the requirements since the RCSIVs also perform a primary containment isolation function following a design basis loss-of-coolant accident. The LAR further states that Nine Mile Point Nuclear Station, LLC (NMPNS) has been applying the requirements of both TS sections to the RCSIVs. The proposed change would make it clear that the RCSIVs are required to be operable in both the power operating condition and the hot shutdown condition.
(a) Explain how the proposed requirements differ from the requirements as presently applied. For instance, is it correct that operability requirements as presently applied to RCSIVs cover hot shutdown conditions only when reactor coolant system temperature is greater than 215 degrees Fahrenheit (°F) and that no operability requirements have been applied when reactor coolant temperature is above 212 °F but less than 215 °F?
(b) If correct, please confirm that the proposed requirements will also cover the period(s) when the reactor coolant temperature is above 212 °F but less than or equal to 215 °F.
- 2.
The NRC staff requests clarification regarding the proposed addition of operability requirements in TS Section 3.2.7.d for the RCSIVs in the shutdown cooling (SDC) system. The LAR states that the proposed changes would require these valves to be operable whenever fuel is in the reactor vessel and the reactor coolant temperatures are less than or equal to 212 °F. If an SDC system isolation valve becomes inoperable, proposed TS Section 3.2.7.e requires that, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, at least one valve in each line having an inoperable valve is in the mode corresponding to the isolated conditions.
However, if the SDC function is needed to provide core cooling, proposed TS Section 3.2.7.f.(1) allows the SDC line to remain unisolated provided action is immediately initiated to suspend operations having potential to drain the reactor vessel (OPDRVs). If suspending the OPDRVs would result in closing the SDC system isolation valves, an alternative action is proposed in TS Section 3.2.7.f.(2) to immediately initiate action to restore the valve(s) to operable status.
From the Updated Final Safety Analysis Report, Figure X-1, it appears that suspending OPDRVs will result in closing the SDC system isolation valves, and, therefore, would result in the alternative action of proposed TS Section 3.2.7.f.(2).
The alternative action in TS Section 3.2.7.f.(2) is open ended, in that it is not time constrained to resolve the issue associated with the inoperable RCSIV. While it is not the NRC staffs intent to imply that the issue would not be fixed, the proposed TS does offer an avenue to operate the SDC system while the problem remains unresolved. The SDC is a system that could be potentially called upon to operate more than once during a refueling outage.
(a) Explain what precautions would be taken, procedurally or otherwise, to preclude the potential for draining the reactor vessel during times when one of the RCSIV in the SDC system is inoperable and the plant is alternating between proposed TS action statements 3.2.7.e and 3.2.7.f due to the need to intermittently operating the SDC system.
(b) The LAR proposes to revise Table 3.6.2.b (low-low reactor water level function) to be consistent with the proposed RCSIV operability requirements described under TS Section 3.2.7. Please provide in your response, an explanation as requested in RAI 2(a) above, as it applies to the proposed TS Table 3.6.2.b.