Letter Sequence Response to RAI |
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TAC:ME0817, Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR (Approved, Closed) |
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MONTHYEARML0932701012009-11-23023 November 2009 Request for Additional Information Relocation of Pressure and Temperature Limit Curves to PTLR Project stage: RAI ML0935700972009-12-17017 December 2009 Submittal of Response to Request for Additional Information on License Amendment Request Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report Project stage: Response to RAI ML0933700022010-01-21021 January 2010 Issuance of Amendment Relocation of Pressure and Temperature Curves to the Pressure Temperature Limits Report Project stage: Approval ML1006301202010-03-10010 March 2010 Correction to Amendment No. 204 - License Amendment Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report Project stage: Other 2009-12-17
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Category:Letter
MONTHYEARNMP1L3570, Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2024-02-0101 February 2024 Supplemental Information Letter - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation IR 05000220/20230042024-02-0101 February 2024 Integrated Inspection Report 05000220/2023004 and 05000410/2023004 NMP1L3569, CFR 50.46 Annual Report2024-01-26026 January 2024 CFR 50.46 Annual Report ML24004A2122024-01-0808 January 2024 Senior Reactor and Reactor Operator Initial License Examinations ML23354A0012024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0059 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines NMP1L3566, Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station2023-12-14014 December 2023 Radiological Emergency Plan Document Revision. Includes EP-AA-1013, Revision 10, Radiological Emergency Plan Annex for Nine Mile Point Station IR 05000410/20243012023-12-14014 December 2023 Initial Operator Licensing Examination Report 05000410/2024301 ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 NMP1L3564, Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements2023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements ML23291A4642023-12-0707 December 2023 Issuance of Amendment No. 251 Regarding the Adoption of Title 10 the Code of Federal Regulations Section 50.69, Risk-Informed Categorization and Treatment of SSC for Nuclear Power Plants ML23289A0122023-12-0606 December 2023 Issuance of Amendment No. 250 Regarding the Revision to Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b NMP1L3563, Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-12-0404 December 2023 Submittal of Relief Request I5R-12, Revision 0, Concerning the Installation of a Full Structural Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) IR 05000220/20234022023-11-28028 November 2023 Security Baseline Inspection Report 05000220/2023402 and 05000410/2023402 NMP1L3557, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000220/20234202023-11-0101 November 2023 Security Baseline Inspection Report 05000220/2023420 and 05000410/2023420 ML23305A0052023-11-0101 November 2023 Operator Licensing Examination Approval IR 05000220/20230032023-10-25025 October 2023 Integrated Inspection Report 05000220/2023003 and 05000410/2023003 IR 05000220/20235012023-10-17017 October 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000220/2023501 and 05000410/2023501 IR 05000220/20230112023-10-16016 October 2023 Comprehensive Engineering Team Inspection Report 05000220/2023011 and 05000410/2023011 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans NMP1L3554, Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases2023-10-0606 October 2023 Submittal of Revision 28 to the Final Safety Analysis Report (Updated), Fire Protection Design Criteria Document, 10CFR50.59 Evaluation Summary Report, 10CFR54.37(b) Aging Management Review, and Technical Specifications with Revised Bases C IR 05000220/20233032023-09-20020 September 2023 Retake Operator Licensing Examination Report 05000220/2023303 ML23250A0822023-09-19019 September 2023 Regulatory Audit Summary Regarding LARs to Adopt TSTF-505, Rev. 2, and 10 CFR 50.69 ML23257A1732023-09-14014 September 2023 Requalification Program Inspection IR 05000220/20230052023-08-31031 August 2023 Updated Inspection Plan for Nine Mile Point Nuclear Station, Units 1 and 2 (Report 05000220/2023005 and 05000410/2023005) RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs NMP2L2851, Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations2023-08-25025 August 2023 Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations ML23151A3472023-08-21021 August 2023 Issuance of Amendments to Adopt TSTF-295-A, Modify Note 2 to Actions of PAM Table to Allow Separate Condition Entry for Each Penetration NMP1L3534, License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation2023-08-18018 August 2023 License Amendment Request - Revision to the Technical Specifications Design Features Sections to Remove the Nine Mile 3 Nuclear Project, LLC, Designation ML23220A0262023-08-0808 August 2023 Licensed Operator Positive Fitness-for-Duty Test IR 05000220/20234012023-08-0808 August 2023 Cyber Security Inspection Report 05000220/2023401 and 05000410/2023401 (Cover Letter Only) NMP1L3545, Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems .2023-08-0404 August 2023 Supplemental Information Letter to Adopt TSTF-505, Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2 and 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems . RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor IR 05000220/20230022023-08-0101 August 2023 Integrated Inspection Report 05000220/2023002 and 05000410/2023002 ML23207A0762023-07-14014 July 2023 EN 56557 - Update to Part 21 Report Re Potential Defect with Trane External Auto/Stop Emergency Stop Relay Card Pn: XI2650728-06 NMP1L3544, Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations2023-07-14014 July 2023 Fifth Inservice Inspection Interval, First Inservice Inspection Period 2023 Owner'S Activity Report for RFO-27 Inservice Examinations ML23186A1642023-07-0606 July 2023 Operator Licensing Retake Examination Approval NMP2L2846, Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications2023-07-0505 July 2023 Nine Mire Point Nuclear Station, Units 1 and 2, General License 30-day Cask Registration Notifications ML23192A0622023-06-30030 June 2023 Engine Systems, Inc., 10CFR21 Reporting of Defects and Non-Compliance, Report No. 10CFR21-0136, Rev. 0 IR 05000220/20230102023-06-29029 June 2023 Biennial Problem Identification and Resolution Inspection Report 05000220/2023010 and 05000410/2023010 ML23131A4242023-06-23023 June 2023 Issuance of Amendment No. 249 Regarding the Revision to Technical Specification 3.3.1 to Adopt Technical Specifications Task Force Traveler TSTF-568 RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations NMP1L3539, Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208)2023-06-0909 June 2023 Day Commitment Response - Relief Request I5R-11 Concerning the Installation of a Weld Overlay on Reactor Pressure Vessel Recirculation Inlet Nozzle N2E Safe End-to-Nozzle Dissimilar Metal Weld (32-WD-208) ML23159A0052023-06-0505 June 2023 56557-EN 56557 - Paragon - Redlined RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling IR 05000410/20233022023-05-15015 May 2023 Initial Operator Licensing Examination Report 05000410/2023302 2024-02-01
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Thomas A. Lynch P.O. Box 63 Plant General Manager Lycoming, New York 13093 315.349.5205 315.349.1321 Fax CENG a joint venture of 0 Consel~io OE=natiff 0Je Nine Mile Point Nuclear Station December 17, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk
SUBJECT:
Nine Mile Point Nuclear Station Unit No. 1; Docket No. 50-220 License Amendment Request Pursuant to 10 CFR 50.90: Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report -
Response to NRC Request for Additional Information (TAC No. ME0817)
REFERENCES:
(a) Letter from K. J. Polson (NMPNS) to Document Control Desk (NRC), dated March 3, 2009, License Amendment Request Pursuant to 10 CFR 50.90:
Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report (b) Letter from R. V. Guzman (NRC) to S. L. Belcher (NMPNS), dated November 23, 2009, Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 1, Relating to License Amendment Request Re: Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report (TAC No. ME0817)
Nine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits supplemental information requested by the NRC in support of a previously submitted request for amendment to Nine Mile Point Unit 1 Renewed Facility Operating License DPR-63. The initial request, dated March 3, 2009 (Reference a), proposed to modify Technical Specification (TS) Sections 3.2.1 and 3.2.2 by replacing the existing reactor vessel heatup and cooldown rate limits and the pressure and temperature limit curves with references to the Pressure and Temperature Limits Report (PTLR). The proposed amendment would also add a new TS
Document Control Desk.
December 17, 2009 Page 2 definition for the PTLR and would revise the Administrative Controls section of the TS to add new administrative requirements for the PTLR. The supplemental information, provided in Attachments 1 and 2 to this letter, responds to the request for additional information documented in the NRC's letter dated November 23, 2009 (Reference b).
This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (a). Pursuant to 10 CFR 50.91(b)(1), NMPNS has provided a copy of this supplemental information to the appropriate state representative. This letter contains no new regulatory commitments.
Should you have any questions regarding the information in this submittal, please contact T. F. Syrell, Licensing Director, at (315) 349-5219.
Very truly yours, STATE OF NEW YORK TO WIT:
COUNTY OF OSWEGO I, Thomas A. Lynch, being duly sworn, state that I am the Nine Mile Point Plant General Manager, and that I am duly authorized to execute and file this supplemental information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.
Subscribed and sworn before me a Notary Public in and for the State of New York and County of I*Lq.O ,this L day of 1, 2009.
WITNESS my Hand and Notarial Seal: j______( ____i____ "
" -NotaVublic My Commission Expires: TONYA L.JONES at Notary Public inthe State of New York IIOswego County Rg. No.01J baere My Commission Expires =
TAL/DEV
Document Control Desk December 17, 2009 Page 3 Attachments: 1. Nine Mile Point Unit 1 - Response to NRC Request for Additional Information Regarding the Proposed Relocation of Pressure and Temperature Limit Curves to the Pressure and Temperature Limits Report
- 2. Revision to Proposed Change to Technical Specification Page 358 (Markup) cc: S. J. Collins, NRC R. V. Guzman, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA
ATTACHMENT 1 NINE MILE POINT UNIT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED RELOCATION OF THE PRESSURE AND TEMPERATURE LIMIT CURVES TO THE PRESSURE AND TEMPERATURE LIMITS REPORT Nine Mile Point Nuclear Station, LLC December 17, 2009
ATTACHMENT 1 NINE MILE POINT UNIT 1 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED RELOCATION OF THE PRESSURE AND TEMPERATURE LIMIT CURVES TO THE PRESSURE AND TEMPERATURE LIMITS REPORT By letter March 3, 2009, Nine Mile Point Nuclear Station, LLC (NMPNS) requested an amendment to the Nine Mile Point Unit 1 (NMP1) Renewed Operating License DPR-63. The proposed amendment would modify the Technical Specifications (TSs) by relocating the pressure and temperature limit curves to the Pressure and Temperature Limits Report (PTLR). This attachment provides supplemental information in response to the request for additional information (RAI) documented in the NRC's letter dated November 23, 2009. The NRC request is repeated (in italics), followed by the NMPNS response.
RAI The Nuclear Regulatory Commission (NRC) staff has reviewed the Nine Mile Point Nuclear Station (NMPNS) submittal dated March 3, 2009. The NRC staff has determined that additional information requested below will be needed to complete its review. As indicated in NRC letter dated November 2, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML092151016),
to the Technical Specification (TS) Task Force Traveler (TSTF) regardinga staffposition taken on TSTF-419, Revision 0, there is a generic concern related to the inclusion of revision numbers and dates in the Pressure and Temperature Limits Report (PTLR) References Section of the TSs. Specifically, the removal of the Topical Report revision numbers or approval dates from the TS in accordance with the subject TSTF Travelers does not provide a direct link to specific TS numerical values relocated to the PTLR, since there is no reference to a specific methodology. The NRC staff has determined that relaxationof TS Topical Report documentation from the guidance provided in Generic Letter 96-03 is not appropriate.
Therefore, the NRC staff no longer supports the position reflected in TSTF Traveler 419, Revision 0.
In light of the November 2, 2009, letter, and in light of the fact that NMPNS is requesting to implement TSTF-419 during continued generic discussions regarding TSTF-419, the NRC staff requests NMPNS to provide a revised TS page(s) for NMP1 providing the PTLR References Section, citing NRC-approved methodology that includes revision numbers and dates.
Response
The revised TS page requested by the NRC is provided in Attachment 2. In the "Insert 2" for TS page 358, the reference to document SIR-05-044-A is revised by adding the revision number and date, thereby fully identifying the specific methodology used to develop the NMP1 PTLR. The revision is indicated by a vertical bar drawn in the right hand margin of the Insert 2 page.
The methodology described in SIR-05-044-A, Revision 0, dated April 2007, has previously been reviewed and accepted by the NRC, as discussed in the NMPNS license amendment request letter dated March 3, 2009.
1 of 1
ATTACHMENT 2 REVISION TO PROPOSED CHANGE TO TECHNICAL SPECIFICATION PAGE 358 (MARKUP)
Nine Mile Point Nuclear Station, LLC December 17, 2009
- b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:
- 1. NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel," U.S. Supplement, (NRC approved version specified in the COLR).
- c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as shutdown margin (SDM), transient analysis limits, and accident analysis limits) of the safety analysis are met.
- d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.
6.6.6 Special Reports Special reports shall be submitted within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification:
a.-f. (Deleted)
- g. Sealed Source Leakage In Excess Of Limits, Specification 3.6.5.2 (Three months).
- h. Accident Monitoring Instrumentation Report, Specification 3.6.11.a (Table 3.6.11-2, Action 3 or 4) (Within 14 days following the event).
AMENDMENT NO. 142, 157, 162, 181, -+-8+3 358
INSERT 2 (for TS Page 358; New Section 6.6.7) 6.6.7 Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)
- a. RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and inservice leakage and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:
- 1. Limiting Condition for Operation Section 3.2.1, "Reactor Vessel Heatup and Cooldown Rates."
- 2. Limiting Condition for Operation Section 3.2.2, "Minimum Reactor Vessel Temperature for Pressurization."
- 3. Surveillance Requirement Section 4.2.2, "Minimum Reactor Vessel Temperature for Pressurization."
- b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:
- 1. SIR-05-044-A, "Pressure-Temperature Limits Report Methodology for Boiling Water Reactors,"
Revision 0, April 2007.
- c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.