ML100430366

License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NEI 94-01, Rev. 2-A, and Extension of Primary Containment Integrated Leakage Rate Test Interval to Fifteen (15) Years - Response to NRC Request For...

ML100430366
Person / Time
Site:	Nine Mile Point
Issue date:	02/03/2010
From:	Belcher S Constellation Energy Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1650
Download: ML100430366 (43)

Text

Sam Belcher P.O. Box 63 Vice President-Nine Mile Point Lycoming, New York 13093 315.349.5200 315.349.1321 Fax CENG a joint venture of 0Constellation iEnergy, eDF NINE MILE POINT NUCLEAR STATION February 3, 2010 U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear Station Unit No. 2; Docket No. 50-410 License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NEI 94-01, Revision 2-A, and Extension of Primary Containment Integrated Leakage Rate Test Interval to Fifteen (15) Years - Response to NRC Request for Additional Information (TAC No. ME1650)

REFERENCES:

(a) Letter from S. Belcher (NMPNS) to Document Control Desk (NRC), dated June 29, 2009, License Amendment Request Pursuant to 10 CFR 50.90: Adoption of NEI 94-01, Revision 2, and Extension of Primary Containment Integrated Leakage Rate Test Interval to Fifteen (15) Years - Technical Specification 5.5.12, 10 CFR 50 Appendix J Testing Program Plan (b) Letter from S. Belcher (NMPNS) to Document Control Desk (NRC), dated August 13, 2009, License Amendment Request Supplement Pursuant to 10 CFR 50.90: Adoption of NEI 94-01, Revision 2-A, and Extension of Primary Containment Integrated Leakage Rate Test Interval to Fifteen (15) Years -

Technical Specification 5.5.12, 10 CFR 50 Appendix J Testing Program Plan (c) Letter from R. V. Guzman (NRC) to S. L. Belcher (NMPNS), dated January 6, 2010, Request for Additional Information Regarding Nine Mile Point Nuclear Station, Unit No. 2 (NMP2) - Re: Adoption of NEI-94-01, Revision 2-A, and Extension of Primary Containment Integrated Leakage Rate Test Interval to 15 Years (TAC No. ME1 650)

Document Control Desk February 3, 2010 Page 2 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 2 (NMP2)

Renewed Operating License NPF-69. The amendment request, dated June 29, 2009 (Reference a), as supplemented by letter dated August 13, 2009 (Reference b), proposed to revise Technical Specification (TS) 5.5.12, "10 CFR 50 Appendix J Testing Program Plan," by replacing the reference to Regulatory Guide 1.163 with a reference to Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 2-A, as the implementation document used by NMPNS to develop the NMP2 performance-based leakage testing program in accordance with Option B of 10 CFR 50, Appendix J. The supplemental information, provided in the Attachment to this letter, responds to the request for additional information (RAI) documented in the NRC's letter dated January 6, 2010 (Reference c).

This supplemental information does not affect the No Significant Hazards Determination analysis provided by NMPNS in Reference (b). 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, Sam Belcher, being duly sworn, state that I am Vice President Nine Mile Point, 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

,I9Q 0 this '*1 day of F_ 2010.

WITNESS my Hand and Notarial Seal:

/-Not-ary Piu~lic -

My Commission Expires:

TONYA L :ONES Notary Public Inthe State of New Yok V l7DAte Oswego County ReIg. No. 01J .34 IF My Commission Expires /A

Document Control Desk February 3, 2010 Page 3 SB/DEV

Attachment:

Nine Mile Point Unit 2 - Response to NRC Request for Additional Information Regarding the Proposed Adoption of NEI 94-01, Revision 2-A, and Extension of the Primary Containment Integrated Leakage Rate Test Interval cc: S. J. Collins, NRC R. V. Guzman, NRC Resident Inspector, NRC A. L. Peterson, NYSERDA

-I ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Nine Mile Point Nuclear Station, LLC February 3, 2010

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL By letter dated June 29, 2009, as supplemented by letter dated August 13, 2009, Nine Mile Point Nuclear Station, LLC (NMPNS) requested an amendment to the Nine Mile Point Unit 2 (NMP2) Renewed Facility Operating License NPF-69. The proposed amendment would revise Technical Specification (TS) 5.5.12, "10 CFR 50 Appendix J Testing Program Plan," by replacing the reference to Regulatory Guide 1.163 with a reference to Nuclear Energy Institute (NEI) topical report NEI 94-01, Revision 2-A, as the implementation document used by NMPNS to develop the NMP2 performance-based leakage testing program in accordance with Option B of 10 CFR 50, Appendix J. This attachment provides supplemental information in response to the request for additional information documented in the NRC's letter dated January 6, 2010. Each individual NRC question is repeated (in italics), followed by the NMPNS response.

Mechanical and Civil Engineering

RAI-1

In orderfor the NRC staff to assess the proper and effective implementation of the Type B and Type C local leak rate testingprogram, the licensee is requested to provide:

(a) A table of all containmentpressure boundary components at NMP2 that are subject to the Type B and Type C testing, under the Primary Containment Leakage Rate Testing Program,with the currenttest frequency and the approximate dates (or refueling outage) of the last test and the next scheduled test.

(b) A summary table of LLRT results of those containment penetrations (including their test schedule intervals) that have not demonstrated acceptable performance history in accordance with the Primary ContainmentLeakage Rate Programand a discussion of the causes and corrective actions taken.

(c) A discussion of whether there have been any refueling outages since the last Type A test in which the combined leakage from Type B and Type C tests did not meet the acceptance criteria.Provide a discussion of the results, cause(s), and corrective actions taken.

Response

(a) Containment pressure boundary components that are tested under the NMP2 10 CFR 50 Appendix J, Option B, testing program are listed in Table 1 for Type B tested components and in Table 2 for Type C tested components. For each listed component, these two tables show the current test interval under 10 CFR 50 Appendix J, Option B, the last test date, and the next scheduled test date together with the corresponding refueling outage number.

(b) Containment penetration components that have experienced Appendix J local leak rate test failures and their test schedule intervals are listed in Table 3, beginning with the 2000 refueling outage (N2R7) when the last integrated leakage rate test (ILRT) was performed. A test failure represents leakage that exceeds the administrative criteria established in accordance with 10 CFR 50, Appendix J, Option B. When the administrative leakage limit is exceeded during as-found tests, the test failure is captured in the site corrective action program. If the component is on an extended test interval, the test interval is returned to 30 months.

1 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Comments summarizing the cause and corrective actions taken for each test failure are provided in Table 3. Most failures were due to valve seat imperfections, with one failure due to a failed torque switch. Twelve test failures were experienced during refueling outage N2R9 (Spring 2004), seven of which were check valves (four feedwater system check valves and three emergency core cooling system (ECCS) check valves). Each feedwater line penetrating primary containment (penetrations Z-004A and Z-004B) has three containment isolation valves in series: two check valves (one inside and one outside primary containment) and a motor-operated valve (MOV) located upstream of the outboard check valve. Both check valves in each of the two feedwater containment penetrations experienced test failures; however, for both penetrations, the MOV had acceptable leakage test results. As part of the corrective actions taken, the leakage test method was evaluated and enhanced for future outages. No test failures have occurred for these feedwater check valves during the last two outages. For the three ECCS check valves, seat maintenance was performed and the valves then successfully tested. As a result of a design change implemented after N2R9, these ECCS check valves are no longer leak rate tested under the Appendix J testing program. Presently, one Appendix J component (valve 2DFR*MOV 140) is in Maintenance Rule (a)(1) status. With a successful as-found local leak rate test (LLRT) during the upcoming N2R 12 refueling outage, this valve can be returned to (a)(2) status.

(c) The NMP2 combined Type B and Type C leakage acceptance criterion (0.6 La) is 494.6 scfh. The maximum and minimum pathway leak rate summary totals for each refueling outage since the last ILRT was performed (N2R7 in 2000) are shown in Table 4. The test results in Table 4 show that the combined leakage from Type B and C tests has been maintained significantly below the 0.6 La requirement for both the minimum and maximum pathway totals. A review of the as-found minimum pathway totals for each of these refueling outages was also performed and determined that there were no penetrations where both isolation valves experienced gross test failures.

RAI-2

It is stated in Section 3.2.5.1 of the LAR that, "Type C penetrations have had generally good performance and are typically tested on a 60-month interval."

(a) Given that NMP2 is on a 24-month operating cycle, discuss how a 60-month interval was implemented in the current 10 CFR Appendix J Testing ProgramPlan using Regulatory Guide (RG) 1.163 (September 1995) as the implementing document. In addition, discuss how a 60-month interval will be implemented using NEI 94-01, Revision 2-A, "Industry Guideline for Implementing Performance-BasedOption of 10 CFR Part50, Appendix J, " as the implementing document.

(b) Provide a summary ofperformance resultsfor Type C penetrations that would support the statement of "generally goodperformance " of these penetrations.

Response

(a) As required by NMP2 TS 5.5.12, the current 10 CFR 50 Appendix J Testing Program Plan has been implemented in accordance with the guidance provided in RG 1.163 dated September 1995, which endorses NEI 94-01, Revision 0, subject to certain provisions described in Section C (Regulatory 2 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Position) of the RG. As discussed in Section 11.3 of NEI 94-01, Revision 0, performance factors were evaluated when establishing test intervals greater than 30 months. Type C tested components that are on a performance-based 60-month test schedule are actually scheduled and tested approximately every 48 months (i.e., every other refueling outage). The test interval for these components is entered into the surveillance tracking database as 1825 days (60 months), with no interval extension (grace period) allowed, so that the test interval will not exceed 60 months. This is consistent with the guidance in Regulatory Position C.2 of RG 1.163. NMPNS is not using the 25% grace period (not to exceed 15 months) stated in NEI 94-01, Revision 0, as a permanent interval extension to allow testing every third refueling outage.

Adoption of NEI 94-01, Revision 2-A, as the implementation document for the 10 CFR 50 Appendix J Testing Program Plan will not alter scheduling and testing of the Type C tested components that are on a performance-based 60-month test schedule. Like the current program, these components will continue to be scheduled and tested approximately every 48 months, with the scheduled test interval not to exceed 60 months.

(b) As outlined in NEI 94-01, when eligible based on good performance, the test interval for Type C tested components may be increased up to a maximum of 60 months. One measure of the performance of Type C tested components is the percentage of eligible components that are on extended intervals. For NMP2, out of a possible 142 Type C performance-based components, 92.3%

(131) are currently on a 60-month extended test interval. Additionally, since 10 CFR 50 Appendix J, Option B, was adopted for NMP2 in 1996, there have not been significant increases in the combined Type B and Type C leak rate summary totals. As illustrated in Table 4, the combined Type B and Type C leak rate has been maintained significantly below the 0.6 La acceptance criterion. These leak rate test results demonstrate "generally good performance" of the Type C tested components at NMP2.

RAI-3

In Section 3.2.2 of the LAR, the table entitled, "NMP2 Containment Inservice Inspection Periods (IWE/IWL), " only provides an inspection schedule that is based on Subsection IWE of the ASME Code,Section X, and applies to the Class MC containment metallic liner and its attachments. Indicate and clarify the schedule of inspections that were, or will be, performed on the concrete containment structure in accordance with Subsection IWL, and explain how it meets the requirements in Section 9.2.3.2 of NEI 94-01, Revision 2-A, and Condition 2 in Section 4.1 of the NRC safety evaluation (SE)for topical report NEI 94-01, Revision 2-A.

Response

As correctly noted by the NRC staff, the table entitled "NMP2 Containment Inservice Inspection Periods (IWE/IWL)" in Section 3.2.2 of the license amendment request (LAR) applies only to the Subsection IWE inspection periods. Since a 15-year Type A test interval spans at least four IWE inspection periods, performance of examinations in accordance with Subsection IWE assures that at least three general visual examinations of metallic containment components will be conducted before the next Type A test if the 3 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Type A test interval is extended to 15 years. This meets Section 9.2.3.2 of NEI 94-01, Revision 2-A, and Condition 2 in Section 4.1 of the NRC safety evaluation for NEI 94-01, Revision 2 (Reference 1).

Visual examinations of accessible concrete containment components in accordance with the American Society of Mechanical Engineers (ASME) Code,Section XI, Subsection IWL, are performed every five years, resulting in at least two IWL examinations being performed during a 15-year Type A test interval.

In addition to the IWL examinations, NMPNS conducts the following general visual inspections to identify potential degradation of containment components:

• Suppression chamber - Accessible exterior concrete surfaces, every 24 months (each refueling outage).

• Drywell - Accessible exterior concrete surfaces, at least three times within a 10-year period.

These visual inspections include the following:

• Structural discontinuities in the vicinity of exterior penetrations, hatchways, and airlocks.

• Support attachments, brackets, and bolting to the containment structure for cracked welds, loose bolting, or any other types of deterioration.

• Exterior concrete surface area for any apparent changes in appearance or other abnormal degradation.

The following attributes are included in these visual inspections:

- Surface abrasion

- Visible cracks (other than hairline cracks in concrete)

- Evidence of spalling or scaling of the concrete surface

- Evidence of rust bleeding, staining, or discoloration

- Damage due to vibrating equipment

- Evidence of the presence of any rebar corrosion

- Evidence of wall movement

- Coating degradation These inspections are conducted in accordance with approved plant procedures to satisfy TS Surveillance Requirement (SR) 3.6.1.1.1 and the requirements of the 10 CFR 50 Appendix J Testing Program Plan.

They are coordinated with the IWL examinations to the extent practical. Together, these inspections and the IWL examinations assure that at least three general visual examinations of concrete containment components will be conducted before the next Type A test if the Type A test interval is extended to 15 years, thereby meeting Section 9.2.3.2 of NEI 94-01, Revision 2-A, and Condition 2 in Section 4.1 of the NRC safety evaluation for NEI 94-01, Revision 2 (Reference 1).

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL

RAI-4

Sections 3.2.2 and 3.2.3 of the LAR provides generic statements of the NMP-2 IWE/IWL ISI program.

Discuss historic highlights of importantfindings from IWE and IWL examinationsperformed since the last Type A test on the containmentpressure retainingstructures and components, in accordancewith the NMP2 containment CISIprogram,and actions taken to disposition them. In the response,providefactual information that would demonstrate proper and effective implementation of the ISI program in monitoring and managing degradation to ensure that containment structuraland leak-tight integrity has been, and will continue to be, maintainedthrough the service life of the plant. Include relevant highlights of examinationsperformed on the containmentpenetrations (with seals, gaskets, bolted connections, and bellows), the vent system, the metallic liner, and the reinforced concrete containment structure. Also, discuss highlights of findings from recent inspections from the NMP2 Drywell Coatings Inspection Programand actions taken.

Response

To date, there have been no findings identified from the IWL examinations. The only significant finding identified during the IWE examinations was areas of blistered coatings with evidence of ongoing rust behind the blistered coatings on the containment wall liner plate near the drywell floor. These areas of degraded coatings were identified during the 2000 refueling outage (N2R7) and were entered into the corrective action program. Areas of the degraded coatings were scraped to bare metal and ultrasonic (UT) thickness readings were taken at several locations around the circumference of the liner. All thickness readings confirmed that the liner had experienced negligible, if any, reduction in thickness, as all readings were equal to or greater than the nominal liner thickness of 1-1/4" at these areas. The degraded coatings identified on the containment liner near the drywell floor were stabilized (scraped to bare metal) under the Drywell Coatings Program during the 2000 refueling outage, and the areas were re-coated using qualified coatings during the 2002 refueling outage (N2R8).

Examinations of containment penetrations with seals, gaskets, and bolted connections have been performed as directed by the IWE program plan when these types of connections are disassembled or when the bolting is removed. The vent system, consisting of the stainless steel downcomers and the vacuum breakers in the drywell, has also been inspected in accordance with the IWE program plan. These examinations have not identified any issues or findings.

The only containment penetrations with bellows are the traversing incore probe (TIP) drive guide tube penetrations. These bellows were inspected during the 2008 refueling outage (N2R1 1), as described in Section 3.2.5.4 of the LAR (an aging management inspection), with no indications identified. In addition, the results of Type B leak rate tests for these penetrations have been acceptable (see the response to RAI-7).

NMP2 drywell coatings inspections are performed every refueling outage to identify evidence of degraded coatings throughout the drywell. The purpose of the coating inspections is to identify and quantify the total amount of degraded coatings because they are a potential debris source for the emergency core cooling system suction strainers following a loss of coolant accident. Newly identified areas of degraded coatings are evaluated and scheduled for repair, replacement, or removal, as needed.

These activities are tracked under the corrective action program. Inspections performed during the 2008 5 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL refueling outage characterized the condition of the coatings on the drywell liner as generally good to very good. Small isolated areas of degraded coatings have been identified during these inspections, but the only time that indications of ongoing corrosion have been noted was in the 2000 refueling outage (N2R7),

as discussed above.

RAI-5

Provide information of instances during implementation of the containment CISI program in accordance with IWE/IWL at NMP2, where existence of or potentialfor degraded conditions in inaccessible areas of the concrete containment structure and metallic liner were identified and evaluated based on conditions found in accessible areas, as requiredby 10 CFR 50.55a(b)(2)(viii)(E) and 10 CFR 50.55a(b)(2)(ix)(A).

If there were any instancesof such conditions, discuss the findings and actions taken.

Response

The only areas of the containment that the NMP2 IWE/IWL inservice inspection program identifies as inaccessible for examination are the steel drywell floor liner, the steel suppression chamber floor liner, and those portions of the drywell and suppression chamber wall liners that are behind the insulating concrete layer covering the floor liners (see the response to RAI-6 below). To date, there have been no instances under either the IWE or IWL examinations where conditions were identified in accessible areas that could indicate the presence of or result in degradation in these inaccessible areas. The NMP2 IWE/IWL inservice inspection program contains requirements to evaluate the acceptability of the inaccessible areas if such conditions were identified, in accordance with 10 CFR 50.55a(b)(2)(ix)(A) and 10 CFR 50.55a(b)(2)(viii)(E).

RAI-6

Item 3 of the table on page 6 of 21 of the LAR states that the NMP2 containment system does not employ any moisture barriers. In the absence of a moisture barrier,relative to NRC InformationNotice 2004-09, "Corrosion of Steel Containment and Containment Liner," discuss the operating experience and evaluation results, if any, of the potentialfor, or presence of corrosive conditions on the inaccessible drywellfloor and suppressionpoolfloor liner.

Response

The drywell floor is covered with a carbon steel liner which is then covered with 5 to 9 inches of insulating concrete. The insulating concrete thickness varies because it slopes away from the liner on the drywell wall and towards the drywell floor drains, to keep water from collecting in the comer where the drywell wall liner and the floor insulating concrete layer meet. No moisture barrier was ever installed at this interface, and no standing water has been noted on the drywell floor. Inspections of this area as part of the evaluation of the degraded coating conditions identified during the 2000 refueling outage (N2R7),

discussed in the response to RAI-4 above, confirmed that the concrete remained tightly adherent to the drywell wall. The evaluation performed at the time of discovery of the degraded coating conditions in 6 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL 2000 concluded that the identified conditions were not indicative of the presence of degradation in the inaccessible drywell floor liner and would not result in degradation of the drywell floor liner.

The steel suppression pool floor liner is covered with 12 inches of insulating concrete. A welded stainless steel liner is installed over the insulating concrete to serve as a waterproof membrane for that concrete layer, with all seams and corners seal-welded. Thus, there is no need for a moisture barrier at the suppression pool floor.

RAI-7

Provide information on the operating experience or testing results with regard to detection of leakage through containment penetrations 2NMT*Z31A, B, C, D and E with bellows. Confirm whether or not thesepenetrations use 2-ply bellows.

Response

Containment penetrations 2NMT*Z3 1A, B, C, D and E use single-ply metal bellows. Type B leak rate tests are applicable to these five penetrations. Test results for each refueling outage since the last ILRT was performed (N2R7 in 2000) are shown in Table 5. For all five penetrations, the measured leak rate has been significantly below the established administrative leakage limits. For the majority of the tests, a leak rate of 0.046 scfh was recorded, which is the minimum reading based on the calibration and capability of the leak rate test monitors. For two penetrations (2NMT*Z31B and C), the measured leakage has increased but is still small. As described in Section 3.2.5.3 of the LAR, these penetrations are tested together with their associated solenoid-operated isolation ball valve. Changes in leak test results are likely due to differences in seating characteristics for the isolation ball valve (an active component) rather than a change in the condition of the bellows/penetration (a passive component). In addition, as noted in the response to RAI-4, an aging management inspection of these bellows was performed during the 2008 refueling outage (N2R1 1), with no indications identified.

RAI-8

Condition 3 in Section 4.1 of the NRC SE for NEI 94-01, Revision 2-A, requires that licensees address the areas of containment structurepotentially subject to degradation. Section 3.1.3 of the NRC SE, in part, states that licensees referencing NEI 94-01, Revision 2-A, in support of a request to amend their TS should also explore/consider such inaccessible degradation-susceptible areas in plant-specific inspections, using viable, commercially available non-destructive examination (NDE) methods (such as boroscopes, guided wave techniques, etc.- see Report ORANL/NRC/LTR-02/02 "Inspection of Inaccessible Regions of Nuclear Power Plant Containment Metallic Pressure Boundaries," June 2002 (ADAMS Accession No. ML061230425), for recommendations to support plant-specific evaluations). The staff's intent of this statement in the SE is that licensees should explore and considerNDE techniques such as those discussed in the reference or other methods for inspections of inaccessible degradation-susceptible areas of the containment pressure boundary to supportplant-specific evaluations of inaccessible areas, as these advanced technologies become commercially available and viablefor implementation in practice in the future. While the staff understands that these techniques may not be commercially viable at the 7 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL present time, the licensee is requested to identify areas in the NMP2 containment that are inaccessible and degradation-susceptible,and acknowledge that these NDE technologies would be explored and considered in the future for the examination of inaccessible degradation-susceptible areas of the containment,as these technologies become commercially viable.

Response

As noted in the response to RAI-5 above, the only areas of the containment that the NMP2 IWE/IWL inservice inspection program identifies as inaccessible for examination are the steel drywell floor liner, the steel suppression chamber floor liner, and those portions of the drywell and suppression chamber wall liners that are behind the insulating concrete layer covering the floor liners. Containment examinations performed to date have not identified any conditions in accessible areas that could indicate the presence of or result in degradation in these inaccessible areas. Thus, NMPNS has not needed to implement any new technologies to inspect the inaccessible areas.

Constellation Energy Nuclear Group (CENG) actively participates in various nuclear utility owners groups, ASME Code committees, and with NEI to maintain cognizance of ongoing developments within the nuclear industry. Industry operating experience is also continuously reviewed to determine its applicability to NMPNS. Adjustments to inspection plans and availability of new, commercially available technologies for the examination of the inaccessible areas of the containment would be explored and considered as part of these activities.

RAI-9

In response to Condition 4 in Section 4.1 of the NRC SE for topical report NEI 94-01, Revision 2-A, the NMP2 response in Item 4 of the Table on page 6 of 21 of the LAR states that, "The station design change process would address testing requirementsfor any future containment structuremodifications."

(a) Describe how the above statement addresses the requirements of Condition 4 of Section 4.1 and as discussed in Section 3.1.4 of the NRC safety evaluationfor NEI 94-01, Revision 2-A, with regard to major and minor containment repairsand modifications.

(b) Address why it is appropriateto make reference to a "station design change process," which is not subject to NRC review, in an applicationfor a licensing action.

(c) Clarify whether the repair/replacementprogram, which includes associatedpost modification testing for the NMP2 containment structure, is performed as partof the CISIprogram in accordance with 10 CFR 50.55a(g)(4) or as partof the "station design change process. "

(d) Clarify and confirm NMPNS's understanding of the distinction between major and minor containment repairand modifications with regard to post-modification testing.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL

Response

(a) & (b)

As noted in Section 9.2.4 of NEI 94-01, Revision 2-A, repairs and modifications that affect the containment leakage integrity require the performance of appropriate testing following the repair or modification to provide assurance of containment integrity. This testing could consist of an ILRT, local leak rate testing, or a short duration structural test. The testing to be performed is dependent on the nature of the repair or modification and is established based on reviews performed in accordance with the station design change process and/or the ASME Section XI Repair/Replacement Program.

The design change process and the Repair/Replacement Program are implemented in accordance with approved station procedures that provide the managerial and administrative controls for performance of repair/replacement and modification activities. Reviews performed in accordance with these procedures assure that all applicable post-repair/replacement or post-modification examination and testing requirements to be performed, and their associated acceptance criteria, are identified. Suitable regulatory controls governing the performance of these activities exist, including:

" The design change process requires performance of a review of proposed facility modifications in accordance with 10 CFR 50.59. The 10 CFR 50.59 review determines if a license amendment request must be submitted in accordance with 10 CFR 50.90 because either:

- A change to the plant technical specifications is required; or

- One or more of the eight criteria listed in 10 CFR 50.59(c)(2) applies.

• The Repair/Replacement Program requires preparation of a repair/replacement plan whenever such an activity is to be performed. The plan must identify the applicable examination, test, and acceptance criteria to be used to verify acceptability. If any alternatives to or relief from the ASME Code examination or testing requirements are proposed, the appropriate NRC review and acceptance would be obtained in accordance with either 10 CFR 50.55a(a)(3) or 10 CFR 50.55a(g)(5).

The distinction between major and minor containment repairs and modifications is addressed in the response to Item (d) below.

(c) The ASME Section XI Repair/Replacement Program provides the requirements for repair/replacement activities associated with pressure retaining components and their supports, including appurtenances, subassemblies, parts of a component, core support structures, metal containment and their integral attachments, and metallic portions of Class CC containment and their integral attachments, and provides requirements for repair/replacement activities performed on concrete containments, as specified in IWL-4000. This program is separate from, but is referenced by, the IWE/IWL ISI program. The Repair/Replacement Program is also separate from, but is applied in conjunction with, the station design change process to assure that all applicable requirements for the design, installation, and examination and testing of rePairs/replacements or modifications are identified.

(d) NMPNS understands the distinction between major and minor containment repairs and modifications, as described in Section 3.1.4 of the NRC safety evaluation for NEI 94-01, Revision 2 (Reference 1).

9 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Based on the discussion provided in the NRC safety evaluation and consistent with Section 9.2.4 of NEI 94-01, Revision 2, testing following containment repairs or modifications will be performed as follows:

• For major repairs or modifications (e.g., cutting of large openings for equipment removal/replacement, or replacement of large penetrations) - Either an ILRT or a short duration structural test.

• For minor repairs or modifications (e.g., those items defined as minor in IWE-5220) - A local leak rate test.

As noted in the response to Items (a) and (b) above, proposed testing that involves alternatives to or relief from the ASME Code testing requirements would be submitted to the NRC for review and acceptance pursuant to 10 CFR 50.55a.

Probabilistic Risk Assessment (PRA)

RAI-1O Discuss the reasonsfor the decision to estimate the NMP population dose based on scaling of Peach Bottom population doses, given that: (1) Electric PowerResearch Institute Topical Report 1009325 Rev 2A indicates that the order of preference for determining population dose "shall be plant-specific best estimate, Severe Accident Mitigation Alternative (SAMA) for license renewal, and scaling of a reference plant population dose '" and (2) plant-specific population dose estimates were available as part of the NMP SAMA analysis.

Response

As noted in Section 4.2 (page 10) of the risk impact assessment performed for the LAR (Attachment 2 of the LAR), the approach of scaling a reference plant (Peach Bottom) population dose was used in lieu of the level 3 PRA model that was developed for the NMP2 License Renewal Application severe accident mitigation alternative (SAMA) analysis because the level 3 model has not been maintained since its creation. It has not been updated to the same level of quality as the level 1 and level 2 PRA and has not been updated since submittal of the License Renewal Application, for which the level 3 model was developed. This same approach was recently utilized for the Nine Mile Point Unit 1 license amendment for a one-time extension of the ILRT interval to 15 years, and was accepted by the NRC in their safety evaluation dated March 11, 2009 (Reference 2).

In addition, the calculated increase in the 50-mile population dose for those accident sequences influenced by increasing the ILRT interval from 3 years to 15 years is 3.7E-02 person-rem/year (reference Table 15 of Attachment 2 to the LAR). Thus, there is significant margin to the value of < 1.0 person-rem/year that Electric Power Research Institute (EPRI) Report No. 1009325, Revision 2-A, defines as a very small population dose increase.

10 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL

RAI-11

The assessment of corrosion-inducedleakage of the steel liner in Section 4.4 of Attachment 2 was based on two observed corrosion events (at North Anna 2 and Brunswick Unit 2). There have been additional instances of liner corrosion that are relevant to this assessment, including a recentfinding at Beaver Valley Unit 1 (LER 2009-003-00). Provide a more comprehensive assessment of corrosion-induced leakage of the steel liner to include all observed corrosionevents relevant to the NMP2 containment, and an evaluation of the impact on risk results when all relevant corrosion events are included in the risk assessment.

Response

The assessment of the impact of the proposed ILRT interval extension on detection of steel liner corrosion presented in Section 4.4 of Attachment 2 of the LAR is based on the methodology developed by the Calvert Cliffs plant (Reference 3). Two liner corrosion events (one at North Anna Unit 2 and one at Brunswick Unit 2) were used to estimate the liner flaw probability in the Calvert Cliffs analysis. The Calvert Cliffs analysis then calculated an historical liner flaw likelihood based on: (1) 70 units with steel-lined containments; and (2) the two liner corrosion events occurring over a period of 5.5 years, which represents the period of time from September 1996 (when 10 CFR 50.55a started requiring visual inspections of containment surfaces) until March 2002 (when Calvert Cliffs submitted their analysis for NRC review in Reference 3), as follows:

Historical Liner Flaw Likelihood = 2 / (70

• 5.5) = 5.2E-3/year An operating experience review has identified two additional relevant liner corrosion events involving concealed corrosion (corrosion initiated on the inaccessible liner surface) that were not included in the Calvert Cliffs analysis. The review included the additional 7.75-year time period since the Calvert Cliffs analysis was submitted in 2002. These events were:

• Beaver Valley Unit 1 (Reference 4) - Through-wall pitting type liner corrosion originating from the concrete side was found during an ASME XI, Subsection IWE, general visual examination. The corrosion appeared to have initiated from a 2" x 4" x 6" piece of wood embedded in the concrete.

• D. C. Cook Unit 2 (Reference 5) - A localized loss of liner material on the concrete side was found during inspections performed around a previously-repaired through-wall liner hole. The corrosion appeared to have initiated from a piece of wood (a wire brush with a wooden handle) embedded in the concrete immediately behind the liner. The reduced liner thickness did not exceed established acceptance criteria for the liner.

Based on this additional data, the calculated historical liner flaw likelihood is:

Historical Liner Flaw Likelihood = (2 + 2) / [70 * (5.5 + 7.75)] = 4.3E-3/year Since this historical liner flaw likelihood is smaller than the value of 5.2E-3 used in the NMP2 risk assessment, the risk assessment results are conservative, and the overall conclusion that extending the ILRT interval from 10 to 15 years results in a very small change to the NMP2 risk profile is not altered.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL

RAI-12

The discussion of PRA quality relies on a self assessment of the NMP2 PRA prior to the most recent PRA update, peer review findingsfor the NMP1 PRA, and the considerationof the NMP1 peer review findings during the most recent PRA update for NMP2. For the NMP2 PRA model used to support the application, provide (1) a list of findings from the NMPJ PRA peer review and NMP2 PRA self assessment that remain open for the NMP2 PRA model, and (2) the impact of these open items on this application.

Response

An industry peer review team has completed a review of the updated NMP2 PRA model. Table 6 contains a summary of the findings from the peer review, the status of the resolution for each finding, and the potential impact of each finding on the NMP2 ILRT interval extension risk assessment. In summary, a majority of the findings are related to documentation and have no material impact on the ILRT interval extension risk assessment. Resolution of the peer review findings to date has had a minor impact on the model and its quantitative results, with the internal events CDF decreasing slightly since the ILRT risk assessment was performed. Assessment of the remaining open peer review findings has determined that required model changes would result in minor reductions in model quantification results and, therefore, would have a negligible, if any, impact on the conclusions of the ILRT interval extension risk assessment.

References

1. Letter from M. J. Maxin (NRC) to J. C. Butler (NEI), dated June 25, 2008, Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report (TR) 94-01, Revision 2, "Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J" and Electric Power Research Institute (EPRI) Report No. 1009325, Revision 2, August 2007, "Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals" (TAC No. MC9663)

2. Letter from R. V. Guzman (NRC) to K. J. Polson (NMPNS), dated March 11, 2009, Nine Mile Point Nuclear Station, Unit No. 1 - Issuance of Amendment Regarding One-Time Extension of Primary Containment Integrated Leakage Rate Test Interval (TAC No. MD9453)

3. Letter from C. H. Cruse (CCNPP) to Document Control Desk (NRC), dated March 27, 2002, Response to Request for Additional Information Concerning the License Amendment Request for a One-Time Integrated Leakage Rate Test Extension

4. Letter from P. P. Sena III (FENOC) to Document Control Desk (NRC), dated June 18, 2009, Beaver Valley Power Station, Unit No. 1, Docket No. 50-334, License No. DPR-66, LER 2009-003-00, "Containment Liner Through Wall Defect Due to Corrosion"

5. Letter from J. E. Pollock (AEP Indiana Michigan Power) to Document Control Desk (NRC), dated March 16, 2001, submitting LER 316/2000-001-01, "Through-Liner Hole Discovered in Containment Liner" 12 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Table 1 (RAI-la)

NMP2 Components Subject to Appendix J Type B Testing Component ID Penetration No.I FTTest o.

Test Interval n Last Test Date Next Scheduled Date 2PCB*Personnel Lock N2R13 (North) Hatch 4/2012 2PCB*DRA6 DRA6 30f 11/15/2008 N2R12 (DW Equip. Hatch S) 4/2010 2PCB*DRA4A 2PBDAADRA4A 30f 4/8/2008 N2R 2I12 (Supp Pool N.E. Hatch) 4/2010 2PCB*DRA4B DRA4B 30f 4/8/2008 N2R 12 (Supp Pool S.W. Hatch) 4/2010 2PCB*DRA3 2C*R3DRA3 30f 4/11/2008 N2R12 21 (CRD Removal Hatch) 4/2010 2PCB*HD1 2PBHIHD1 30f 4/13/2008 N2R12 2I (DW Head) 4/2010 N2R15 42016 2CES*ZO1E Z-201 120 3/11/2008 4/2016 2CES*ZO2E Z-202 120 3/10/2008 N2R15 4/2016 N2R15 2CES*ZO3E Z-203 120 3/11/2008 42016 4/2016 N2R 420 15 1

2CES*ZO4E Z-204 120 3/11/2008 4/2016 N2R15 42016 2CES*ZO5E Z-205 120 3/11/2008 4/2016 Z-206 120 3/11/2008 42016 2CES*ZO6E 4/2016 N2R15 2CES*ZO7E Z-207 120 3/11/2008 42016 4/2016 N2R15 Z-208 120 3/11/2008 42016 2CES*Z08E 4/2016 N2R15 42016 2CES*Z09E Z-209 120 3/11/2008 4/2016 N2R15 N2R15 4/2016 42010 2CES*Z10E Z-211 120 3/11/2008 4/2016 42010 2CES*Z11E Z-212 120 3/11/2008 N2R 15 4/2010 42010 2CES*Z12E Z-213 120 3/13/2002 N2R15 N2R12 4/2010 2CES*Z14E Z-216 120 120 3/13/2002 3/13/2002 21 42010 2CES*Z13E Z-215 I 1 1 4/2010 13 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval l Last Test Date Next Scheduled Test Date Z-217 120 3/13/2002 N2R12 2CES*Z17E 4/2010 N2R12 4/2010 2CES*Z18E Z-218 120 3/13/2002 N2R12 Z-219 120 3/14/2002 42010 2CES*Z19E 4/2010 N2R12 42010 2CES*Z20E Z-220 120 3/14/2002 4/2010 Z-221 120 3/14/2002 42010 2CES*Z21E 4/2010 N2R12 Z-222 120 3/14/2002 42010 2CES*Z22E N2R12 4/2010 Z-223 120 3/14/2002 42012 2CES*Z23E 4/2010 N2R123 Z-224 120 3/14/2002 42012 2CES*Z24E 4/2010 N2R12 Z-225 120 3/9/2004 42010 2CES*Z25E 4/2012 N2R13 Z-226 120 3/9/2004 42012 2CES*Z26E 4/2012 Z-227 120 3/9/2004 42012 2CES*Z27E 4/2010 N2R13 Z-228 120 3/9/2004 42012 2CES*Z28E 4/2012 N2R12 2CES*Z29E Z-229 120 4/7/2008 4/2014 N2R13 42012 2CES*Z30E Z-230 120 3/9/2004 4/2012 3/9/2004N2R14 Z-231 120 3/9/2004 42012 2CES*Z31E 4/2012 Z-232 120 3/9/2004 N2R13 2CES*Z32E N2R13 4/2012 Z-233 120 3/9/2004 42012 2CES*Z33E N2R13 4/2012 Z-234 120 3/9/2004 42012 2CES*Z34E N2R13 4/2012 2CES*Z35E Z-235 120 3/9/2004 21 4/2012 120 3/9/2004 N2R13 21 2CES*Z36E Z-236 4/2012 Z-237 120 3/14/2006 N2R13 21 2CES*Z37E 4/2012 2CES*Z38 E Z-238 120 3/14/2006 21 4/2012 2CES*Z39E Z-239 120 3/14/2006 21 4/2012 2CES*Z40E Z-240 120 3/14/2006 21 4/2012 14 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval Last Test Date Next Scheduled

0. Test Date N2R1 420144 2CES*Z41E Z-241 120 3/15/2006 4/2014 Z-242 120 3/15/2006 N2R14 2CES*Z42E 4/2014 N2R14 42014 2CES*Z43E Z-243 120 3/12/2008 4/2014 N2R14 42014 2CES*Z44E Z-244 120 3/15/2006 4/2014 Z-245 120 3/15/2006 N2R14 2CES*Z45E 4/2014 N2R14 42014 2CES*Z46E Z-246 120 3/15/2006 4/2014 N2R14 42014 2CES*Z47E Z-247 120 3/15/2006 4/2014 Z-248 120 3/15/2006 42014 2CES*Z48E 4/2014 N2R14 Z-249 120 3/12/2008 42014 2CES*Z49E 4/2014 N2R14 Z-250 120 3/12/2008 42014 2CES*Z50E N2R14 4/2014 Z-251 120 3/12/2008 N2R14 2CES*Z51E 4/2014 Z-252 120 3/15/2006 42014 2CES*Z52E N2R14 4/2014 Z-253 120 3/12/2008 42014 2CES*Z53E N2R14 4/2014 Z-254 120 3/12/2008 N2R14 2CES*Z54E 4/2014 Z-255 120 3/12/2008 42016 2CES*Z55E 4/2016 N2R15 Z-256 120 3/12/2008 42016 2CES*Z56E N2R15 4/2016 Z-257 120 3/12/2008 42016 2CES*Z57E 4/2016 N2R15 42016 2CES*Z58E Z-258 120 3/12/2008 4/2016 N2R15 Z-259 120 3/12/2008 42010 2CES*Z59E 4/2016 N2R15 Z-260 120 3/12/2008 42010 2CES*Z60E 4/2016 N2R15 42010 2NMT*Z31A Z-31A(A) 24 3/30/2008 4/2010 N2R12 Z-31B(A) 24 3/30/2008 42010 2NMT*Z31B 4/2010 24 3/30/2008 N2R12 21 2NMT*Z31C Z-31C(A) 4/2010 2NMT*Z31D Z-31D)(A) 24 3/30/2008 21 4/2010 15 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. 1 Test ntervalT) Last Test Date Next Scheduled Test Date Z-3 1E(A) 24 3/30/2008 N2R12 2NMT*Z31E 4/2010 N2R12 42010 2GSN*Z32 Z-32 120 4/6/2004 4/2010 N2R12 42010 2FPW*Z46C Z-46C 120 4/2/2002 4/2010 N2R12 42010 2PCB*Z74 Z-74 30f 4/7/2008 4/2010 2PCB*Personnel Lock DRA5 30f 4/6/2008 N2R12 40# Test Flange/Overall 4/2010 2PCB*Escape Hatch 40# DRA9 30f 3/30/2008 N2R12 Test Flange/Overall 4/2010 NOTES: (1) Option "B" Interval Key:

24 = IST required test, performed every 24 months 30f = 30 month fixed interval 120 = 120 month performance-based interval 16 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Table 2 (RAI-la)

NMP2 Components Subject to Appendix J Type C Testing Component ID e Penetration No.ITestTest Interval o Last Test Date Next Scheduled Date N2R 42012 13 2AAS*HCV134 Z-37 60 3/29/2008 4/2012 Z-37 60 3/29/2008 42012 2AAS*HCV136 4/2012 N2R 13 Z-44F 60 3/26/2008 42012 2AAS*HCV135 N2R13 4/2012 Z-44F 60 3/26/2008 42012 2AAS*HCV137 4/2012 N2R13 42012 2CCP*MOV94A Z-33A 60 4/2/2008 4/2012 N2R13 42012 2CCP*RV1019A Z-33A 60 4/2/2008 4/2012 Z-33A 60 4/2/2008 42012 2CCP*MOV17A N2R13 4/2012 Z-33B 60 3/25/2008 42012 2CCP*MOV94B N2R13 4/2012 Z-33B 60 3/25/2008 42012 2CCP*MOV17B 4/2012 N2R13 Z-33B 60 3/25/2008 N2R13 2CCP*RV170 4/2012 N2R13 42012 2CCP*MOV16A Z-34A 60 3/25/2008 4/2012 N2R13 N2R13 4/2012

/2012 2CCP*MRV12A Z-34A 60 3/25/2008 N2R13 N2R13 Z-34A 60 3/24/2008 42012 2CCP*MOV15A 4/2012 4/2012 Z-34B 60 3/26/2008 42012 2CCP*MOV16B 4/26/2008 21 2CCP*MOV15B Z-346A 60 N2R13 2CCP*RV 1721 Z-346A 30 4/26/2008 2I N2R12 4/2010 4/2012 N2R 13 2CCP*MOV1273 Z-46A 30p 4/5/2008 22 4/2010 Z-47 60 4/5/2008 42012 2CCP*MOV126 4/2012 2CCP*MOV 122 Z-47 60 4/5/2008 21 4/2012 17 ofR39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval Last Test Date Scheduled Test DateestDate N2R12.,

Z-60A 60 3/13/2006 42010 2CMS*SOV60A 4/2010 Z-60A 60 3/13/2006 N2R12 2CMS*SOV61A 4/2010 N2RI3 Z-60B 60 3/29/2008 42012 2CMS*SOV24A 4/2012 N2R13 Z-60B 60 3/29/2008 42012 2CMS*SOV24C 4/2012 Z-60C 60 3/14/2006 N2R12 2CMS*SOV62A 4/2010 N2R12 42010 2CMS*SOV63A Z-60C 60 3/14/2006 4/2010 N2R13 Z-60D 60 3/19/2008 42012 2CMS*SOV32A 4/2012 N2R13 Z-60D 60 3/19/2008 42012 2CMS*SOV33A 4/2012 Z-60E 60 3/16/2006 N2R12 2CMS*SOV60B 4/2010 N2R12 Z-60E 60 3/16/2006 42010 2CMS*SOV61B 4/2010 N2R13 Z-60F 60 3/24/2008 42012 2CMS*SOV24B 4/2012 N2R13 Z-60F 60 3/24/2008 42012 2CMS*SOV24D 4/2012 Z-60G 60 3/17/2006 42010 2CMS*SOV63B 4/2010 N2R12 Z-60G 60 3/17/2006 42012 2CMS*SOV62B 4/2010 N2R12 N2R13 2CMS*SOV32B Z-60H 60 3/20/2008 4/2012 4/2012 N2R13 4/2010 Z-61B 60 3/29/2006 42010 2CMS*SOV26A N2R12 4/2010 Z-61B 60 3/29/2006 42010 2CMS*SOV26C 2CMS*SOV34A Z-61C 60 3/19/2008 N2R13 N2R13 4/2012 4/2012 2CMS*SOV35A Z-61C 60 3/19/2008 42012 N2R13 2CMS*SOV26B Z-61E 60 3/24/2008 4/2012 N2R 13 Z-61E 60 3/24/2008 N2R13 2CMS*SOV26D 4/2012 4/2012 N2R 13 2CMS*SOV34B Z-61F 60 3/20/2008 42012 Z-61F 60 3/20/2008 42012 2CMS*SOV35B 4/2012 18 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval ) Last Test Date Next Scheduled Test Date 2CPS*AOV104 Z-49 Quarterly 12/18/2009 3/15/2010 2CPS*AOV106 Z-49 Quarterly 12/18/2009 3/15/2010 2CPS*AOV105 Z-50 Quarterly 12/18/2009 3/15/2010 2CPS*AOV107 Z-50 Quarterly 12/18/2009 3/15/2010 2CPS*AOV108 Z-48 Quarterly 12/19/2009 3/15/2010 2CPS*AOV110 Z-48 Quarterly 12/19/2009 3/15/2010 2CPS*AOV 109 Z-51 Quarterly 12/19/2009 3/15/2010 2CPS*AOV 111 Z-51 Quarterly 12/19/2009 3/15/2010 N2R12 42010 2CPS*SOV120 Z-58 60 3/28/2006 4/2010 N2R12 42010 2CPS*SOV122 Z-58 60 3/28/2006 4/2010 N2R12 42010 2CPS*SOV119 Z-59 60 3/29/2006 4/2010 N2R 4201012 2CPS*SOV121 Z-59 60 3/29/2006 4/2010 N2R13 2CPS*SOV133 Z-92 60 4/3/2008 42012 4/2012 N2R12 42010 2CPS*V51 Z-92 24 4/3/2008 4/2010 2CPS*SOV132 Z-96 60 4/2/2008 N2R13 4/2012 N2R12 42010 2CPS*V50 Z-96 24 4/2/2008 4/2010 N2R13 42012 2CSIH*MOV1 11 Z-13 60 4/8/2008 4/2012 Z-13 60 3/27/2008 42012 2CSH*MOV105 N2R13 4/2012 Z-14 60 3/30/2008 42012 2CSL*MOV107 N2R13 4/2012 Z-16 60 3/27/2008 42012 2CSL*MOV 104 N2R 4/2012 13 Z-40 60 3/29/2008 42012 2DER*MOV 119 N2R 13 4/2012 Z-40 60 3/29/2008 42012 2DER*RV344 N2R13 4/2012 2DER*MOV 120 Z-40 60 3/29/2008 21 4/2012 19 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval () Last Test Date Next Scheduled

0. F~et intTest Date N2RI2 Z-45 60 3/30/2006 42010 2DER*MOV130 4/2010 Z-45 60 4/2/2008 N2R13 2DER*MOV131 4/2012 N2R13 Z-39 60 3/29/2008 42012 2DFR*MOV120 4/2012 N2R12 Z-39 60 3/30/2006 42010 2DFR*MOV121 4/2010 N2R12 Z-39 30p 3/29/2008 42010 2DFR*RV228 4/2010 N2R13 42012 2DFR*MOV139 Z-43 60 3/26/2008 4/2012 N2R12 Z-43 30p 4/2/2008 42010 2DFR*MOV140 4/2010 Z-04A 30f 3/29/2008 N2R12 2FWS*MOV21A 4/2010 2FWS*V23A Z-04A 24 3/27/2009 N2R12 4/2010 N2R12 2FWS*V12A Z-04A 24 3/27/2008 42010 N2R12 2FWS*MOV21B Z-04B 30f 3/29/2008 42010 4/2010 N2R 12 4/2010 2FWS*V23B Z-04B 24 3/28/2008 42010 4/2012 4/2012 2FPW*S0V218 Z-42A 60 3/28/2008 4/2012 N2R 13 2FPW*S*V212 Z-42B 60 3/28/2008 N2R13 4/2012 4/2012 N2R13 2FPW*SOV221 Z-42B 60 3/28/2008 42012 2FPW*SOV219 Z-42A 60 3/28/2008 42012 N2R13 4/2010 4/2012 2GSN*V270 Z-32 24 3/25/2008 42010 N2R13 4/2012 Z-55A 60 3/7/2008 N2R13 2HCS*MOV16 4/2012 4/2012 N2R13 N2R13 2HCS*MOV1B Z-55B 60 3/1/2008 4/2012 24/2012 2HCS*MOV3A Z-56A 60 3/21/2008 42012 4/2012

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval ) Last Test Date Next Scheduled Test Date 2HCS*MOV6A Z-56A 60 4/2/2008 N2R13 4/2012 N2R13 2HCS*MOV3B Z-56B 60 3/7/2008 42012 4/2012 N2R13 42012 2HCS*MOV6B Z-56B 60 4/1/2008 4/2012 N2R13 2HCS*MOV2A Z-57A 60 3/21/2008 42012 4/2012 Z-57A 60 3/21/2008 42012 2HCS*MOV5A 4/2012 N2R13 Z-57B 60 3/6/2008 42012 2HCS*MOV2B N2R13 4/2012 Z-57B 60 3/6/2008 42010 2HCS*MOV5B 4/2012 N2R13 2IAS*SOV164 Z-53A 60 4/7/2008 42012 4/2012 N2R13 Z-53A 24 4/7/2008 42010 2IAS*V448 4/2010 N2R12 Z-53B 60 4/2/2008 42012 2IAS*SOV165 4/2012 Z-53B 24 4/2/2008 42010 2IAS*V449 4/2010 N2R13 Z-53C 60 4/1/2008 42012 2IAS*SOV166 4/2012 Z-53C 60 4/1/2008 42012 2IAS*SOV184 4/2012 N2R13 2IAS*SOV167 Z-91A 60 3/23/2008 42010 4/2012 N2R13 Z-91A 30p 3/23/2008 42012 2IAS*SOV185 4/2010 Z-91B 60 4/7/2008 42012 2IAS*SOV168 N2R13 4/2012 Z-91B 60 4/7/2008 42012 2IAS*SOV180 4/2012 N2R12 Z-218 60 4/1/2008 42010 2ICS*MOV143 4/2012 N2R13 2ICS*MOV 122 Z- 19 60 3/22/2006 21 N2R13 4/2010 Z-21 60 3/25/2008 42012 2ICS*MOV121 N2R13 4/2012 2ICS*MOV128 Z-21 60 11/6/2007 21 4/2012 60 3/25/2008 N2R13 21 2ICS*MOV 170 Z-21 4/2012 21CS*MOV126 Z-22 30p 3/29/2008 21 4/2010 21CS*V288 Z-22 60 3/29/2008 21 1 4/2012 21 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No.I Test Interval

• Last Test Date Next Scheduled Test Date N2R13 2ICS*MOV164 Z-90 60 4/1/2008 42012 4/2012 Z-90 60 4/1/2008 42012 2ICS*MOV148 N2R13 4/2012 2LMS*SOV152 Z-89A 60 3/23/2008 42012 N2R 13 4/2012 Z-89A 60 3/23/2008 42010 2LMS*SOV153 4/2012 Z-89C 60 3/28/2006 42010 2LMS*SOV156 4/2010 N2R12 2LMS*SOV 157 Z-89C 60 3/28/2006 N2R12 N2R12 4/2010 2MSS*MOV208 Z-1A/D 60 3/29/2006 42012 4/2010 N2R12 42010 2MSS*MOV111 Z-02 60 3/29/2006 4/2010 N2R12 Z-02 60 4/10/2008 42010 2MSS*MOV112 4/2012 N2R13 2NMS*SOV1A Z-31A 24 3/30/2008 N2R12 4/2010 Z-31B 24 3/30/2008 42010 2NMS*SOV1B 4/2010 N2R12 2NMS*SOV1C Z-31C 24 3/30/2008 42010 4/2010 N2R12 Z-31D 24 3/30/2008 42010 2NMS*SOV1D 4/2010 N2R12 42010 2NMS*SOV1E Z-31E 24 3/30/2008 4/2010 N2R12 42010 2RCS*V59A Z-38A 24 3/25/2008 4/2010 N2R12 2RCS*V60A Z-38A 24 3/25/2008 42010 4/2010 N2R12 N2R12 4/2010 Z-38B 24 3/28/2008 42010 2RCS*V90B 2RCS*V59B Z-38B 24 3/28/2008 42012 24 3/28/2008 N2R 21 12 4/2010 2RCS*V60B Z-38B 2RCS*SV90B Z-38B 60 3/25/2008 21 4/2010 4/2012 N2R12 2RCS* SOV 104 Z-41 60 3/25/2008 21 4/2012 N2R 12 2RCS*SOV 105 ZD-41 60 3/29/2008 2I 4/2010 2RDS*AOV130 SDV-DRN 60 3/23/2006 42010 4/2010 22 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST-INTERVAL Penetration No. Test Interval Last Test DateScheduled Component ID PT I Test Date N2R12 SDV-VENT 60 3/29/2008 42010 2RDS*AOV124 4/2010 2RDS*AOV132 SDV-VENT 60 3/23/2006 2I N2R12 4/2010 2RHS*MOV30B Z-06A 60 3/29/2006 42010 4/2010 N2R13 2RHS*MOV30A Z-06B 60 3/27/2008 4/2012 2RHS*MOV33A Z-07A 60 10/14/2008 On-line test 10/2012 On-line test 2RHS*MOV33B Z-07B 60 3/5/2008 3/2012 3/2012 2RHS*MOV15A, Z-08A 60 3/26/2008 N2R13 2RHS*RV57A 4/2012 2RHS*MOV15B, Z08B 30 4/6/2008 N2R12 2RHS*RV57B 4/2010 2RHS*MOV24A Z-09A 60 3/27/2008 N2R13 4/2012 N2R12 2RHS*MOV24B Z-09B 60 3/25/2006 42010 4/2010 N2R12 2RHS*MOV24C Z-09C 60 3/25/2006 42010 4/2010 N2R12 2RHS*MOV40A Z-10A 30p 3/31/2008 42010 4/2010 N2R12 2RHS*MOV40B Z-101B 60 3/26/2006 42010 4/2010 N2R 12 2RHS*MOV112 Z-11 60 4/2/2006 42010 4/2010 N2R12 2RHS*RV152 Z-11 30p 4/7/2008 42010 4/2010 N2R12 2RHS*MOV104 Z-22 60 3/28/2006 42010 4/2010 N2R13 2RHS*V192 Z-90 60 4/1/2008 42012 4/2012 N2R13 2SAS*HCV161 Z-36 60 4/6/2008 42012 4/2012 2SAS*HCV163 Z-36 60 4/6/2008 N2R12 4/20 10 N2R13 2SAS*HCV160 Z-44E 60 3/23/2008 4/2012 2SAS*11CV162 Z-44E 60 3/23/2008 .N2R13 N2R13 4/2012 4/2012 2SFC*V203 Z-80 60 3/23/2008 42012 N2R13 4/2012 2SFC*V204 Z-80 60 3/23/2008 42012 N2R13 2SLS*V1O Z-29 60 3/31/2008 42012 4/2012 23 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Component ID Penetration No. Test Interval ) Last Test Date Next Scheduled P NTest Date N2R12 42010 2SLS*MOV5A Z-29 60 3/23/2006 4/2010 2SLS*MOV5B Z-29 60 3/23/2006 N2R12 4/2010 N2R13 2WCS*MOV200 Z-04A,B 60 3/31/2008 42012 4/2012 N2RI2 2WCS*MOV102 Z-23 60 3/28/2008 42010 4/2010 2WCS*MOV 112 Z-23 60 3/28/2008 21 N2R12 4/2010 2MSS*AOV6A Z-01A 30f 4/10/2008 42010 N2R12 4/2010 Z-01A 30f 4/5/2008 42010 2MSS*AOV7A 4/2010 N2R 12 2MSS*AOV6B Z-01B 30f 4/4/2008 42010 4/2010 N2R12 2MSS*AOV7B Z-01B 30f 4/4/2008 42010 4/2010 N2R12 2MSS*AOV6C Z-01C 30f 4/4/2008 N2R12 4/2010 2MSS*AOV7C Z-01C 30f 4/5/2008 42010 4/2010 N2R12 NOTES: (1) Option "B" Interval Key:

24 = Inservice Testing (IST) program required test, performed every 24 months Quarterly = Technical Specification required test, performed every quarter 30f 30 month fixed interval 30p = 30 month performance-based interval 60 = 60 month performance-based interval 24 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Table 3 (RAI-ib) 10 CFR 50 Appendix J Local Leak Rate Test Failure History N2R7, Spr ng 2000 Refueling Outage (When Last ILRT Performed)

Penetration Component ID System Test Test Result Test Schedule Comments (2)

No. Type (scfh) ") Interval Z-004B 2FWS*V23B Feedwater C 14.512 (AF) 30 month fixed Check valve seat maintenance performed to obtain 8.31 (AL) leakage below secondary containment Technical Specification (TS) leakage limit.

SUBSEQUENT PERFORMANCE Failed in N2R9.

Z-023 2WCS*MOV102 Reactor C 4.139 (AF) Kept at 30 Valve seat maintenance performed to obtain leakage Water 2.289 (AL) months below secondary containment TS leakage limit.

Cleanup SUBSEQUENT PERFORMANCE Failed in N2R9.

N2R8, Spring 2002 Refueling Outage Penetration Component ID System Test Test Result Test Schedule Comments (2)

No. Type 1 (scfh) " ) Interval Z-043 2DFR*MOV140 Rx Bldg C 1.593 (AF) Kept at 30 Minor valve seat cleaning needed to obtain leakage Drains 0.123 (AL) months below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE Failed in N2R9, had satisfactory AF test results in N2R1O, and failed again in N2R 1I due to failed actuator torque switch.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL N2R9 Spring 2004 Refueling Outage Penetration Component ID System Test Test Result Test Schedule Comments (2)

No. Type (scfh) ('1) Interval I Z-004A 2FWS*V12A Feedwater C 20.771 (AF) 30 month fixed Check valve seat maintenance performed to obtain 1.127 (AL) leakage below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE LLRT procedure enhanced for future outages to improve check valve closure method. N2R1O and N2R1 1 results were satisfactory.

Z-004A 2FWS*V23A Feedwater C Gross (AF) 30 month fixed Unquantified gross leakage, check valve seat 7.224 (AL) maintenance including alignment performed to obtain leakage below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE LLRT procedure enhanced for future outages to improve check valve closure method. N2R10 and N2R1 1 results were satisfactory.

Z-004B 2FWS*V12B Feedwater C Gross (AF) 30 month fixed Unquantified gross leakage, check valve seat 1.013 (AL) maintenance including alignment performed to obtain leakage below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE LLRT procedure enhanced for future outages to improve check valve closure method. N2Rl10 and N2R 11 results were satisfactory.

Z-004B 2FWS*V23B Feedwater C Gross (AF) 30 month fixed Unquantified gross leakage, check valve seat 0.060 (AL) maintenance including alignment performed to obtain leakage below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE LLRT procedure enhanced for future outages to improve check valve closure method. N2R1O and N2R11 results were satisfactory.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL N2R9_ Spring 2004 Refueling Outage Penetration Component ID System Test Test Result Test Schedule Comments (2)

No. I Type (scfh) () Interval Z-023 2WCS*MOV102 Rx Wtr C Gross (AF) Kept at 30 Unquantified gross leakage, new valve installed. Valve Cleanup 0.055 (AL) months has low secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE Satisfactory AF results during N2R10 and N2R1 1, component test interval increased to 60 months.

Z-038B 2RCS*V59B Rx Recirc C Gross (AF) 24 months Unquantified gross leakage, new valve installed.

0.055 (AL) fixed SUBSEQUENT PERFORMANCE

- N2R1O, new style valve installed, AL test satisfactory.

- N2R1 1, satisfactory AF test results.

Z-039 2DFR*MOV120 Rx Bldg C 15.595 (AF) Changed from Valve seat maintenance needed to obtain leakage below Drains 0.046 (AL) 60 to 30 secondary containment TS leakage limit.

months SUBSEQUENT PERFORMANCE Satisfactory AF results during N2R1O and N2R1 1, component test interval increased to 60 months.

Z-043 2DFR*MOV139 Rx Bldg C 3.221 (AF) Changed from Minor valve seat cleaning needed to obtain leakage Drains 0.053 (AL) 60 to 30 below secondary containment TS leakage limit.

months SUBSEQUENT PERFORMANCE Satisfactory AF results during N2R1O and N2R1 1, component test interval increased to 60 months.

Z-043 2DFR*MOV140 Rx Bldg C 31.577 (AF) Kept at 30 Repeat failure, placed in Maintenance Rule (a)(1).

Drains 0.048 (AL) months Minor valve seat cleaning needed to obtain leakage below secondary containment TS leakage limit.

SUBSEQUENT PERFORMANCE

- N2R1O, satisfactory AF results, needs additional satisfactory AF to return to (a)(2) status.

- N2R1 1, failed AF LLRT due to failed actuator torque switch.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL N2R9, Spring 2004 Refueling Outage Penetration Component ID E System Test Test Result Test Schedule Comments (2)

No. Type . (scfh) (" Interval Z-014 2CSH*V108 High Press. C Gross (AF) Returned to 30 Valve disc stack setup adjustment required along with Core Spray 10.364 (AL) months disc and valve seat lapping to obtain acceptable leak test results.

SUBSEQUENT PERFORMANCE Leak rate testing under Appendix J program for 2CSH*V 108 is no longer required.

Z-010A 2RHS*V39A Shutdown C Gross (AF) Kept at 30 Valve disc and seat lapping needed to obtain acceptable Cooling 3.722 (AL) months leak test results.

SUBSEQUENT PERFORMANCE Leak rate testing under Appendix J program for 2RHS*39A is no longer required.

Z-0 1OB 2RHS*V39B Shutdown C Gross (AF) Kept at 30 Valve disc and seat lapping needed to obtain acceptable Cooling 16.93 (AL) months leak test results.

SUBSEQUENT PERFORMANCE Leak rate testing under Appendix J program for 2RHS*V39B is no longer required.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL N2R10 Spring 2006 Refueling Outag Penetration Component ID E System Test Test Result Test Schedule Comments (2)

No. Type (scfh) (1) Interval I Z-038A 2RCS*V90A Reactor C Gross (AL) 24 months Initial post-maintenance test failure after new style valve Recirc 0.046 (AL-2) fixed installed. Second AL test satisfactory after valve maintenance.

SUBSEQUENT PERFORMANCE I Satisfactory AF results during N2R1 1.

N2Rll, Spring 2008 Refueling Outage Penetration Component ID System Test Test Result Test Schedule Comments (2)

No. Type (scfh) J1) Interval Z-043 2DFR*MOV140 Reactor Bldg C Gross (AF) Kept at 30 Valve gross leakage due to failed actuator torque switch, Drains 0.184 (AL) months torque switch replaced with satisfactory AL LLRT results. Component remains in Maintenance Rule (a)(1) requiring an additional satisfactory AF leak test.

Z-001A 2MSS*AOV6A Main Steam C Gross (AF) 24 months Unquantified gross leakage, valve seat and disc 2.572 (AL) fixed maintenance required. TS leakage requirement for secondary containment bypass leakage. MSIVs are not included in the Type B and C Summary Total.

Z-001D 2MSS*AOV6D Main Steam C Gross (AF) 24 months Unquantified gross leakage, valve seat and disc 9.824 (AL) fixed maintenance required. TS leakage requirement for secondary containment bypass leakage. MSIVs are not included in the Type B and C Summary Total.

NOTES: (1) AF = As-found leak test; AL = As-left leak test (2) Administrative limits are: Type B Tests - 20.6 scfh; Type C Tests - 41.2 scfh; Secondary Containment Bypass Leakage - per Technical Specification 3.6.1.3.

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A ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Table 4 (RAI-lc)

NMP2 Type B and Type C Summary Totals Maximum Pathway Minimum Pathway Date (Refueling  % of 0.6 La  % of 0.6 La Outage) Leakage (scfh) (494.6) Leakage (scfh) (494.6)

Spring 2008 (N2R11) 132.47 26.8% 82.3 16.6%

Spring 2006 (N2R1O) 102.97 20.8% 85.9 17.4%

Spring 2004 (N2R9) 148.65 30.0% 61.53 12.4%

Spring 2002 (N2R8) 147.27 29.8% 56.53 11.4%

Spring 2000 (N2R7) 140.25 28.4% 71.92 14.5%

Table 5 (RAI-7)

Leakage Testing Results for NMP2 Containment Penetrations with Bellows Penetration Leakage Testing Results (scfh)

No. Spring 2000 Spring 2002 Spring 2004 Spring 2006 Spring 2008 (N2R7) j (N2R8) (N2R9) (N2R10) (N2Rll) 2NMT*Z31A 0.046 0.046 0.046 0.046 0.046 2NMT*Z31B 0.173 0.276 0.302 0.502 0.462 2NMT*Z31C 0.046 0.046 0.073 0.129 0.216 2NMT*Z31D 0.046 0.046 0.046 0.046 0.047 2NMT*Z31E 0.062 0.046 0.048 0.046 0.046 30 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL Table 6 (RAI-12)

Peer Review Findings for the NMP2 PRA Model Update F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact F&

I~II Peer Review Team Include demands from the Open - Minor Impact (Reduction)

Demands from causes other than four causes listed in the Slightly conservative and not considered surveillance tests were not included in SR requires all types SR. Perhaps use MSPI significant to estimate using surveillance 1-1 the collection of plant-specific data. DA-C6 of demands be counted estimates for MSPI procedures. Note that MSPI no longer counts DA-C7 or estimated. components because that actual events; they are estimate the same way as (This F&O originated from program includes all for the PRA. This will have a minor reduction on SR DA-C6) demands (except post model quantification results. Deferred for maintenance test). consideration during next major update.

Maintenance Rule unavailability data were used, which include Either exclude unavailability during plant shutdowns Maintenance Rule if that component is required to be unavailability data while Closed - Minor Impact (Reduction) operable. SR states that only at power SR specifically says to the plant is shut down, or Section 3 of the DA Notebook and the model were unavailability should be used. include UA events provide more justification updated with a maintenance unavailability 1-2 N iJREGtCRE-689 Vol. G 2, Table A-2, DA-C13 only occurring while why using such data does calculation that does not include unavailability data indicate that EDG unavailability the plant is at power. not significantly affect the during non-power operation. This has a minor higherthanduring sd ow itopatims er results if only at power impact on model quantification results.

higher than during power operation. unavailability were to be (This F&O originated from used.

SR DA-C-13) 31 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL 11 1 Peer Review Team F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 IULRT Impact The selection of a failure probability of 1.OE-4 for the low-pressure system More realistic failure Closed - Minor Impact (Increase) component(s) rupturing given Section 5 of the DA Notebook was revised to exposure to RCS pressure and 0.01 would increase failure probability or provide a more detailed evaluation of the NMP2 i-9 temperature is optimistic given the LE-04 the frequencies of provide detailed piping and heat exchanger fragilities. As a result, information provided in the referenced NUREG/CR-5603. thef e o f these ISLOCA providecdtile justification the probability of rupture was revised in the NUE/R50.sequences by a factor probability. for such a low moewihvesfracsytmrm0.5o model, which varies for each system from 0.05 to of 100 to 1000. 0.003. This has a minor impact on model (This F&O originated from quantification results.

SR LE-D4)

Closed - Minor Impact (Increase)

Reviewed the IF Notebook Main Report and Appendix B for potential spray events and Several spray events identified (for frequency. The following changes were required:

example, FDSWCB1 and FDSWCB2 Use the spray frequencies (1) Initiators FDSWCB1, FDSWCB2 and in Table 5.1 of the IF Notebook) use frequencies Usethrsra FDSWCB5 were changed to spray frequency flood frequencies rather than spray (too low) were used Check other internal initiating events because there is no detection and 1-11 frequencies from EPRI Report IFEV-A5 for these internal flood flooding initiators for no propagation from these rooms. This has a 10 13141. There could be others. initiators. correct 1crecuetype and and. minor impact (2) North on model Auxiliary Bayquantification results. in panel impact corrected (This F&O originated from frequency. Appendix B (no PRA impact).

SR IFEV-A5) (3) Sections 4.3, 4.5, 4.6 and 5.4 of the IF Notebook were updated to include the screened spray events where PRA equipment was affected.

Documentation only.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL 1 ] Peer Review Team I F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact P. 2-7 of the DA Notebook states that a Bayesian analysis was not done when there are no plant-specific failures. This is unacceptable for Category II or Category III. Perform Bayesian update The discussion justifying not when data is available and performing such updates on p. 2-6 and zero plant-specific failures Closed - Minor Impact (Decrease) 2-7 of the DA Notebook2-7 ofthe is msleadng DANotebok is misleading It It iss not cceptale to not acceptable to alternatively, are observed, show or, that it udtdwt Section 2 of theaeinaayi DA Notebook and o model eoeet were because of the very small failure skip performing a is unlikely to get the updated with Bayesian analysis for zero events 2-5 probabilities involved in the example DA-DI Bayesian update when r down to failure rates on the order of 1E-3. The given zero plant-specific emands to significan conservatism of not performing this update for failures are observed. th failure change the fi antly lower failure rates is shown to be minor. This has Based on NUREG/CR-6928 probability for specific a minor impact on model quantification results.

parameters for distributions with as few as 200 to 1000 demands, the equipment showing zero posterior mean could drop by a factor of 2.

(This F&O originated from SR DA-D 1) 33 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL 1[ [Peer Review Team i F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact A critical test of the posterior that is suggested in this Supporting Requirement is:

(c) examination of inconsistencies between the prior distribution and the plant-specific evidence to confirm that they are appropriate.

There is at least one case in which Consistency between Closed - Minor Impact (Increase) data is inconsistent--MOV (lake) fails the plant-specific data Section 2.7 of DA Notebook updated to include to open. There were 6 failures in 150 the prior wat test of key distributions with documentation of demands. The prior from and the prior was not Perform recommended methodology. A few distributions were identified 2-6 NUREG/CR-6928 for MOV FTO/C DA-D4 representative example consistency analyses for as potentially inconsistent (prior versus posterior has a mean of 1.07 E-3. The method of such an all data. and plant data). As a result, the uncertainty in the from NUREG/CR-6823, Sections inconsistency is prior distribution was increased to be more 6.2.3.5 & 6.3.3.4, describe a method provided.representative of plant data. This has a minor for consistency evaluation that impact on model quantification results.

suggests that greater than or equal to 2 failures would be inconsistent and that another prior should be used.

There is no documentation of any NMP2 analysis like this.

(This F&O originated from SR DA-D4) 34 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL r ~ Peer Review Team F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact Section 2.12 of the SWS System Notebook, which deals with This is an isolated Component Spatial Information, needs example of weakness a small improvement. It is stated that in the treatment of SWS is credited for operation after spatial effects. They Provide discussion of Closed - Documentation Only 2-9 containment failure, but no SY-B8 are treated well in effects on SWS of Section 2.12 of SY.04 was corrected to address the justification is given for why it would other notebooks, containment failureW fact that SWS is not affected by containment be available, given spatial effects from However, treatment of failure. No impact on model.

containment failure, spatial effects is a clear requirement of (This F&O originated from the Standard.

SR SY-B8)

This is an isolated The list of sources of uncertainty has occurrence of failing been omitted from Section 3.5 of the to provide this Discuss sources of Closed - Documentation Only 125information; however, uncertainty in the 125 Vdc A potential important uncertainty is associated requirements of the SY Notebook. with battery life, which was added to the (This F&O originated from ASME Standard to list Notebook. No impact on model.

SR SY-C3) sources of uncertainty are clear.

This SR requires identification of Closed - Documentation Only contributors to CDF. To satisfy Support system initiating event fault trees have Category II (and III) requires Since Category II been added to the model. The IE Notebook refers including SSCs and operator actions requires including Identify CDF contribution to this. SY.OO Notebook provides methodology.

that contribute to IE frequencies. SSCs and operator from SSCs and operator 2-16 These are not included for NMP2, so QU-D6 actions that contribute actions that contribute to -- Documentation-Only only Category I has been met. to IE frequencies, this IE frequencies. Open - Documentation Only is a finding. Equipment and operator contributions will be (This F&O originated from developed in QU Notebook.

SR QU-F&6) The IE Notebook will be updated with correction factors. No impact on model or results.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL T[ ] Peer Review Team I F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact The lack of signatures was widespread Obtain signatures from the At the time of the Peer Review, throughout the PRA Obtain sionatre various PRA documentation notebooks. The designated preparer, notebooks were not signed by preparer, reviewer, reviewer, or approver. Open - Documentation Only 35 and approver The final post peer review issuance of all performers, reviewers, or approvers.

-5 MU-F 1 signatures normally Add lines for signature notebooks will be signed off as Rev 0. This is a implythattheyhave dates. Ensure (This F&O originated from imply that they have documentation (PRA documentation issue only.

SR MU-F l) concurred notebooks) reflects proper statements made in the assocatedrevision reviectsmpr.

number.

associated documentation.

The IF Notebook describes a plant feature important in mitigation of flooding that could disable Div 1 and Div 2 switchgear - "There is an open door that is held open by a latch, This feature has a which actuates to close door on a fire significant impact on Revise documentation Tl IFo Notebook The Doumnato sedwas revised Onlyto t indicate that alarm." (pg 4.1-6). This is cited IF results. The IF (and flooding model, if doors are currently held open by door stop and 3-6 throughout the IF notebook in IFSO-B 1 Notebook and model required) to accurately there is a future modification, which will hold multiple places. This design change should accurately reflect current plant doors open by latch. This was a documentation has not actually been installed, but an reflect current plant configuration. issue only.

interim measure to block the door configuration.

open has been taken.

(This F&O originated from SRIFSO-B 1) 36 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL I F Peer Review Team F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact This modification has a significant impact on core damage An important plant modification frequency, and associated with an internal flood event tracking of the 3-8 that could disable Div I and Il MU-Al modification is Enter and track this issue Closed - Documentation Only 38required is not entered into the Switchgear anqird CNGCMby this1.01-SR innteCRPdtbs.

the CRvP database. CRMP 376 issued. Nooipc CRP36ise. impact onnmoe model orrrsls results.

CRMP database. and CNG-CM- 1.01-3003, "Probabilistic Risk Assessment Configuration Control."

Several system notebooks do not have Closed - Documentation Only aScomletersystem n oksdonot hProvide completed system Only 3 SY Notebooks (ADS, Vapor Suppression 4-7 cYeA4 There are only 3 walkdown checklist for and Reactor Recirc) did not have documented (This F&O originated from systems. those systems in walkdowns (NA was included) and it is stated that SR SY-A4) Appendix C. they are in the Drywell (inaccessible). This is a documentation issue only.

Closed - Documentation Only Routine system alignments Include routine system Routine alignments are already included in the contributing to initiating event Does not meet IE-A6 alignments in the average initiating event frequency development.

5-2 frequencies are not included. IE-A6 Category II calculation of initiating Considered to be state of the art.

(This F&O originated from requirements. event frequencies, where s I-6 applicable. Open - Overall Neutral Impact SR 1E-A6) Will consider adding more detailed modeling in the future - which is expected to risk neutral.

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ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL 11 1 Peer Review Team F&O F&O Description Assoc. SR Basis for Significance Suggested Resolution NMP2 ILRT Impact In some cases the assignment of a conservative screening HEP value may not have been appropriate given the risk significance of the operator action it represents. In particular, the Open - Minor Impact (Reduction) use of a conservative screening value Section 1 of HRA Notebook updated to explicitly of 1E-02 assigned to the HEP Failure to perform a Identify risk-significant identify HEPs based on screening, the basis for ZHS05_HSROOMCOL, "Operator detai n f HF~s in te PRaimod screening, and their importance. Detailed HRA 6-1 Fails to open HPCS ROOM Doors and HR-G1 the estimation of HEPs and perform detailed will be considered in future updates as HVC my uc,othvebenthat represent analysis using appropriate HVAC Duct," may not have been appropriate. This will have a minor impact on appropriate given the risk significance significant HFEs. HRA methodology(ies). model results and screening HEPs are of the HPCS room cooling support conservative.

system.

(This F&O originated from SR HR-G1)

The most significant operator action in terms of importance (RRW = 2, RAW Perform a review of all

= 11) is ZZOHX, "Failure to Recover significant operator Closed - Documentation Only Heat Removal before Containment recovery actions, and ZZOHX is not an operator action. The modeling Failure." There does not appear to be a ensure that a detailed of recovery term ZZOHX includes an operator detailed analysis of this operator analysis is presented action ZOHO 1, which is a direct dependency for action with regard to procedure Failure to satisfy HR- which includes operators performing containment heat removal.

availability and operator training (nor H2 criteria for consideration of procedure ZZOHX is an equipment recovery value for 6-4 is justification given for omission), HR-H2 Capability Category availability and operator failure to recover loss of containment heat nor were shaping factors and 1/11/II for significant training (or justification removal, given ZOHO 1 was previously successful.

sufficiency of manpower for operator action. given for omission), as Agree that the basis for ZZOHX in Section 5 of performing this recovery action well as consideration of the DA Notebook needs improvement and this has included in the evaluation which the shaping factors and been updated. Also, sufficiency of manpower for documents this recovery action. sufficiency of manpower actions required after one day is not considered an for performing the issue. This is a documentation issue only.

(This F&O originated from recovery actions.

SR HR-H2) 38 of 39

ATTACHMENT NINE MILE POINT UNIT 2 RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOSED ADOPTION OF NEI 94-01, REVISION 2-A, AND EXTENSION OF THE PRIMARY CONTAINMENT INTEGRATED LEAKAGE RATE TEST INTERVAL F&O F&O[

F&O Description Assoc.

Assoc. SR 1Basis for Significance Sugg~esedResouion Peer ReviewsTea NMTeaTmmpc NMP2 ILRT Impact The AS Notebook does not contain the The AS analysis Revise the AS Notebook Open - Documentation Only event tree top event fault trees, which documentation does are necessary for understanding the not provide sufficient to include all applicable The final post peer review issuance of the AS 6-5 accident sequence logic. AS-C1 information to top-logic fault trees, and Notebook will have all the documentation in the facilitate PRA additional description in AS Notebook as suggested versus external (This F&O originated from applications, upgrades, the notebook to explain (facilitates review etc). This is a documentation SR AS-C 1) and peer review, the top event logic, issue only.

Table 4-14 indicates that the South Aux Based on a review of the design Service Bldg can be Closed - Documentation Only features, detection and response tereene ofsflupon Footnote (1) was added to the "Yes" which states section, this supporting requirement the presence of flood Revise Table 4-14 to "There is no detection in the South Aux Service appears to have been met for the The NMP2 change YES to NO under Building. However, there is no PRA equipment 6-10 above areas except for the Aux IFSN-A14 IF Notebook, Section the column for Criteria #3 here, the piping is relatively small and there is Service Bldg.4.2.6, does not for the South Aux Service reliable detection, isolation and significant time detection for this area. Bldg. available when propagation occurs to Turbine and (This F&O originated from The responsible or Control buildings." This was a documentation SR IFSN-A 14) Constellation engineer issue only.

corroborated this conclusion.

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