ML083080063

License Amendment, Issuance of Amendment No 128 Action Statement for Two Inoperable Control Room Air Conditioning Subsystems Consistent with TSTF-477

ML083080063
Person / Time
Site:	Nine Mile Point
Issue date:	11/24/2008
From:	Richard Guzman Plant Licensing Branch 1
To:	Polson K Nine Mile Point
Guzman R, NRR/DORL, 415-1030
References
TAC MD6352
Download: ML083080063 (15)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001

. November24,2008 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: ADD ACTION STATEMENT FOR TWO INOPERABLE CONTROL ROOM AIR CONDITIONING SUBSYSTEMS, CONSISTENT WITH TECHNICAL SPECIFICATION TASK FORCE-477 (TAC NO. MD6352)

Dear Mr. Polson:

The Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 128 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit No.

2 (NMP2), in response to your application dated July 30,2007, (Agencywide Documents Access Management System (ADAMS) Accession No. ML072190605), as supplemented by letters dated April 7 (ADAMS Accession No. ML083040377) and September 8, 2008 (ADAMS Accession No. ML082670890).

The amendment revises Technical Specification (TS) 3.7.3, "Control Room Envelope Air Conditioning (AC) System," by adding an Action statement to the Limiting Condition for Operation. Specifically, the new Action statement allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one control room air conditioning SUbsystem to operable status and requires verification that the control room temperature remains below 90 degrees Fahrenheit every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the period of inoperability. This amendment adopts NRC-approved Technical Specifications Task Force (TSTF)-477, Revision 3, "Add Action Statement for Two Inoperable Control Room Air Conditioning SUbsystems." The TSTF change traveler TSTF-477, Revision 3, was announced for availability in the Federal Register (FR) on March 26, 2007 (72 FR 14143) as part of the consolidated line item improvement process. By letter dated September 8,2008, you provided administrative changes to the proposed TSs and a supplemental No Significant Hazards Consideration determination.

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, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 128 to NPF-69

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 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. 128 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 letters dated April 7 and September 8, 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. 128, 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.

- 2

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

Attachment:

Changes to the License and Technical Specifications Date of Issuance: }~r 24, 2J:X'B

ATTACHMENT TO LICENSE AMENDMENT NO. 128 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET 1\10. 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 Pages Insert Pages 4 4 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages 3.7.3-1 3.7.3-1 3.7.3-2 3.7.3-2 3.7.3-3 3.7.3-3 3.7.3-4

-4 (1) Maximum Power Level Nine Mile Point Nuclear Station, LLC is authorized to operate the facility at reactor core power levels not in excess of 3467 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.

(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. 128 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) Fuel Storage and Handling (Section 9.1, SSER 4)*

a. Fuel assemblies, when stored in their shipping containers, shall be stacked no more than three containers high.

b. When not in the reactor vessel, no more than three fuel assemblies shall be allowed outside of their shipping containers or storage racks in the New Fuel Vault or Spent Fuel Storage Facility.

c. The above three fuel assemblies shall maintain a minimum edge to-edge spacing of twelve (12) inches from the shipping container array and approved storage rack locations.

d. The New Fuel Storage Vault shall have no more than ten fresh fuel assemblies uncovered at anyone time.

(4) Turbine System Maintenance Program (Section 3.5.1.3.10, SER)

The operating licensee shall submit for NRC approval by October 31, 1989, a turbine system maintenance program based on the manufacturer's calculations of missile generation probabilities.

(Submitted by NMPC letter dated October 30, 1989 from C.D. Terry and approved by NRC letter dated March 15, 1990 from Robert Martin to Mr. Lawrence Burkhardt, III).

The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.

Renewed License No. NPF 69 Amendment 117 through 125, 126, 127,128

Control Room Envelope AC System 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Control Room Envelope Air Conditioning (AC) System LCO 3.7.3 Two control room envelope AC subsystems for the areas listed below shall be OPERABLE:

a. Main Control Room area; and

b. Relay Room area.

APPLICABILITY: MODES 1, 2, and 3, During movement of recently irradiated fuel assemblies in the secondary containment, During operations with a potential for draining the reactor vessel (OPDRVs).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One control room A.1 Restore control room 30 days envelope AC subsystem envelope AC for the Main Control subsystem for the Room area inoperable. Main Control Room area to OPERABLE status.

B. One control room B.1 Restore control room 30 days envelope AC subsystem envelopeAC for the Relay Room subsystem for the area inoperable. Relay Room area to OPERABLE status.

(continued)

NMP2 3.7.3-1 Amendment Q1, 125, 128

Control Room Envelope AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two control room C.1 Verify control room Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> envelope AC subsystems envelope Main Control for the Main Control Room area temperature Room area inoperable. < gooF.

AND C.2 Restore one control 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> room envelope AC subsystem for the Main Control Room area to OPERABLE status.

D. Two control room 0.1 Verify control room Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> envelope AC subsystems envelope Relay Room for the Relay Room area temperature area inoperable. < gooF.

AND 0.2 Restore one control 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> room envelope AC subsystem for the Relay Room area to OPERABLE status.

E. Required Action and E.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Associated Completion Time of Condition A, B, AND C, or 0 not met in MODE 1,2, or 3. E.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (continued)

NMP2 3.7.3-2 Amendment 91,125, 128

Control Room Envelope AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and --------------NOTE------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition A ----------------------------------

not met during movement of recently F.1 Place OPERABLE Immediately irradiated fuel assemblies control room envelope in the secondary AC subsystem for the containment or during Main Control Room OPDRVs. area in operation.

OR F.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND F.2.2 Initiate action to Immediately suspend OPDRVs.

G. Required Action and ---------NOTE------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition B ---------------------------------------------

not met during movement of recently G.1 Place OPERABLE Immediately irradiated fuel assemblies control room envelope in the secondary AC subsystem for containment or during the Relay Room OPDRVs. area in operation.

OR G.2.1 Suspend movement of Immediately recently irradiated fuel assemblies in the secondary containment.

AND G.2.2 Initiate action to Immediately suspend OPDRVs.

(continued)

NMP2 3.7.3-3 Amendment 91, 125, 128

Control Room Envelope AC System 3.7.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. Required Action and ---------------NOTE------------

associated Completion LCO 3.0.3 is not applicable.

Time of Condition C or D not met during movement of recently irradiated fuel H.1 Suspend movement of Immediately assemblies in the recently irradiated fuel secondary containment assemblies in the or during OPDRVs. secondary containment.

AND H.2 Initiate action to suspend OPDRVs. Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 Verify each control room envelope AC 24 months subsystem has the capability to remove the assumed heat load for the Main Control Room area and the Relay Room area.

NMP2 3.7.3-4 Amendment 128

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 128 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 System (ADAMS) Accession No. ML072190605), as supplemented by letter dated April 7 (ADAMS Accession No. ML083040377) and September 8, 2008 (ADAMS Accession No. ML082670890),

Nine Mile Point Nuclear Station (NMPNS), LLC (the licensee) submitted a license amendment request for Nine Mile Point, Unit NO.2 (NMP2). The proposed amendment would revise Technical Specification (TS) 3.7.3, "Control Room Envelope Air Conditioning (AC) System," by adding an Action statement to the Limiting Condition for Operation (LCO). Specifically, the new Action statement would allow 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one control room air conditioning subsystem to operable status and would require verification that the control room temperature remains below 90 degrees Fahrenheit (OF) every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the period of inoperability.

The supplemental letter dated April 7, 2008, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's initial proposed no significant hazards consideration determination as published in the Federal Register (FR) on September 27,2007 (72 FR 54477). In its letter dated September 8, 2008, NMPNS provided administrative changes to the proposed TSs and a supplemental No Significant Hazards Consideration determination which was published in the FR on September 24,2008 (73 FR 55166). The TSTF change traveler, TSTF-477, Revision 3, was announced for availability in the FR on March 26, 2007 (72 FR 14143) as part of the consolidated line item improvement process.

This amendment would adopt Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF)-477, Revision 3, "Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems," which was proposed by the TSTF industry group in a letter dated September 8, 2006 (ADAMS Accession No. ML062510321). TSTF-477 revised Standard TS 3.7.4 "Control Room Air Conditioning (AC) System" by adding the following TS Action requirements:

-2 CONDITION REQUIRED ACTION COMPLETION TIME B. Two [control room AC] B.1 Verify control room area Once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> subsystems inoperable Temperature, < gO°F.

AND B.2 Restore one [control room AC] 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> subsystem to OPERABLE status

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TS as part of the license. The TS ensure the operational capability of structures, systems and components that are required to protect the health and safety of the public. The Commission's regulatory requirements related to the content of the TS are contained in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36. This regulation requires that the TS include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings (50.36(d)(1)); (2) LCOs (50.36(d)(2)); (3) surveillance requirements (50.36(d)(3)); (4) design features (50.36(d)(4)); and (5) administrative controls (50.36(d)(5)).

In general, there are two classes of changes to TS: (1) changes needed to reflect modifications to the design basis (TS are derived from the design basis), and (2) voluntary changes to take advantage of the evolution in policy and guidance as to the required content and preferred format of TS over time. This amendment addresses the second class of changes. In determining the acceptability of revising the Control Room Envelope AC System TSs, the NRC staff used the accumulation of generically approved guidance in NUREG-1433, "Standard Technical Specifications, Revision 3, General Electric Plants, Boiling-Water Reactor (BWR)/4,"

dated June 2004, referred to as BWR Model 4, Standard Technical Specifications (BWRl4 STS)). Licensees may revise the TS to adopt current improved STS format and content provided that a plant-specific review supports a finding of continued adequate safety because:

(1) the change is editorial, administrative or provides clarification (i.e., no requirements are materially altered), (2) the change is more restrictive than the licensee's current requirement, or (3) the change is less restrictive than the licensee's current requirement, but nonetheless still affords adequate assurance of safety when judged against current regulatory standards. The detailed application of this general framework, and additional specialized guidance, are discussed in Section 3.0 in the context of specific proposed changes.

3.0 TECHNICAL EVALUATION

The required content of the BWRl4 STS for the Control Room Envelope AC System do not contain an Actions requirement for two inoperable subsystems. During the TS conversion of the BWRl6 Plants, the BWRl6 Plants adopted Action statements for the ventilation and AC systems that contained Action Statements for 2 inoperable subsystems similar to the proposed Action Statements in TSTF-477. The STS for numerous safety-related systems also contain Action Statements for 2 inoperable subsystems. TSTF-477 adds an Action Condition for 2 inoperable

-3 Control Room AC subsystems to the BWR STS in order to be consistent with the BWRJ6 current STS. Furthermore, the consistency of the BWR STS will be enhanced since most safety-related systems presently have Action Statements in the STS to address two inoperable subsystems.

3.1 Action Requirements For 2 Inoperable Control Room Envelope AC Subsystems The proposed BWRJ4 Action statement allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore 1 subsystem to the operable status for the TS condition of 2 inoperable subsystems. During the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> completion time, the control room temperature is verified < gO°F every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If 1 control room envelope AC subsystem can not be restored to operable status or the control room temperature can not be maintained < gO°F, then the unit must be placed in at least Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Maintaining the control room temperature < gO°F assures that the safety related equipment in the control room will remain within the original licensed design operating temperature, because the maximum allowable control room temperature is unchanged by TSTF-477.

The NRC staff finds that the proposed changes in TSTF-477 are acceptable for NMP2 because the TSTF-477 changes provide TS requirements such that the control room temperature will be maintained within the original licensed design operating temperature of the control room equipment or the plant will be placed in the Cold Shutdown Mode (Mode 4, Safe Shutdown Condition).

3.2 TS 3.7.3 Deviation from TSTF-477 The proposed TS content for NMP2 adoption of TSTF-477 deviates from the TSTF based on the NMP2 design. Specifically, NMP2 TS 3.7.3, "Control Room Envelope Air Conditioning (AC)

System," contains an administrative deviation from the TS changes provided in the TSTF for the BWRJ4 model in that it specifies distinctly between the two envelope areas for the two control room envelope AC subsystems that shall be operable. The proposed LCO 3.7.3 states:

Two control room envelope AC subsystems for the areas listed below shall be OPERABLE:

a. Main Control Room area; and

b. Relay Room area.

As such, a proposed Condition A for TS 3.7.3 is for one Main Control Room area control room envelope AC subsystem inoperable, and Condition B is for one Relay Room area control room envelope AC inoperable. Similarly, paired conditions are proposed for two control room envelope AC subsystems inoperable in each area and for the required actions and completion times not being met during movement of recently irradiated fuel assemblies or operations with the potential to drain the reactor vessel (OPRDVs). In addition, the proposed revision to TS 3.7.3 removes the phrases "with safety function maintained" and "with safety function not maintained" from the previous Conditions A, D, and E.

The NRC staff finds that the proposed TS 3.7.3 deviations from the TSTF-477 model are editorial in nature, reflect the current configuration of the plant, and do not alter the TS requirements. The NRC staff finds the proposed changes are (1) technically justified, (2) are

- 4 consistent with, and improve conformance to, the industry standard, BWRl4 STSs, and (3) comply with 10 CFR 50.36. On this basis, the NRC staff concludes that the proposed changes to NMP2 TS 3.7.3 are acceptable.

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 the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. 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 the finding issued on September 24, 2008 (73 FR 55166). 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, on the basis of 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: A. Using R. Guzman Date: November 24,2008

ML083040377) and September 8,2008 (ADAMS Accession No. ML082670890).

The amendment revises Technical Specification (TS) 3.7.3, "Control Room Envelope Air Conditioning (AC) System," by adding an Action statement to the Limiting Condition for Operation. Specifically, the new Action statement allows 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to restore one control room air conditioning subsystem to operable status and requires verification that the control room temperature remains below 90 degrees Fahrenheit every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during the period of inoperability. This amendment adopts NRC-approved Technical Specifications Task Force (TSTF)-477, Revision 3, "Add Action Statement for Two Inoperable Control Room Air Conditioning Subsystems." The TSTF change traveler TSTF-477, Revision 3, was announced for availability in the Federal Register (FR) on March 26,2007 (72 FR 14143) as part of the consolidated line item improvement process. By letter dated September 8, 2008, you provided administrative changes to the proposed TSs and a supplemental No Significant Hazards Consideration determination.

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, IRA./

Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosures:

1. Amendment No. 128 to NPF-69

2. Safety Evaluation cc w/encls: Distribution via Listserv DISTRIBUTION (see next page)

ADAMS Accession No ML083080063 NRR-058 OFFICE LPLI-1/PM LPLI-1/LAOV ITSB/BC SCVB/BC OGC liD5 LPLI-1/BC NAME

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