ML101230727

Acceptance Review Determination of License Amendment Request Extension of Completion Time for Inoperable Diesel Generator

ML101230727
Person / Time
Site:	Nine Mile Point
Issue date:	05/11/2010
From:	Richard Guzman Plant Licensing Branch 1
To:	Belcher S Nine Mile Point
Guzman R, NRR/DORL, 415-1030
References
TAC ME3736
Download: ML101230727 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 11,2010 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO.2 - ACCEPTANCE REVIEW OF REQUESTED LICENSING ACTION RE: EXTENSION OF COMPLETION TIME FOR INOPERABLE DIESEL GENERATOR (TAC NO. ME3736)

Dear Mr. Belcher:

By letter dated March 30, 2010, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted a license amendment for Nine Mile Point, Unit NO.2 (NMP2). The proposed amendment would modify NMP2 Technical Specification (TS) Section 3.8.1, "AC Sources - Operating," to extend the Completion Time for an inoperable Division 1 or Division 2 diesel generator (DG) from 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> to 14 days. The proposed amendment represents a risk-informed licensing change. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this amendment request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an amendment to the license (including the TSs) must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. 10 CFR 50.34 addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.

The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment.

In order to make the application complete, the NRC staff requests that NMPNS supplement the application to address the information requested in the enclosure by June 1, 2010. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.

S. L. Belcher -2 The information requested and associated time frame in this letter were discussed with Mr. John Dosa of your staff on May 4, 2010.

If you have any questions, please contact me at (301) 415-1030.

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

Enclosure:

As stated cc w/encl: Distribution via Listserv

NRC STAFF ACCEPTANCE REVIEW COMMENTS REQUESTED LICENSING ACTION RE: EXTENSION OF COMPLETION TIME FOR INOPERABLE DIESEL GENERATOR RENEWED FACILITY OPERATING LICENSE NO. NPF-69 NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO.2 DOCKET NO. 50-410 By letter dated March 30, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100900460), Nine Mile Point Nuclear Station, LLC (NMPNS, or licensee) submitted a license amendment request (LAR) for Nine Mile Point, Unit NO.2 (NMP2).

The Nuclear Regulatory Commission (NRC) staff has reviewed NMPNS's application and concluded that the information listed below is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment request in terms of regulatory requirements and the protection of public health and safety and the environment.

Probabilistic Risk Assessment (PRA) Licensing Review

1. The submittal identifies that 'fire and seismic risk are included in the PRA model. A single paragraph referring to the individual plant examination for external events (IPEEE) submittal and to the NRC IPEEE evaluation is provided, along with a table of the NRC review comments and their disposition 'from the IPEEE. The purpose of the IPEEE and the NRC Research Office staff evaluation was to identify significant plant vulnerabilities, not to establish that the analyses were state-of-the art risk analyses to support licensing actions. This level of quality is not acceptable to support a risk-informed Technical Specification (TS) change. The licensee will need to submit PRA quality information on its fire and seismic risk models consistent with Regulatory Guide (RG) 1.200, Revision 2, Section 1.2.4 (fires) and 1.2.6 (seismic) to demonstrate that these quantitative models are adequate for this application. The licensee should also submit confirmation that the existing fire and seismic models, stated to be based on the IPEEE, still adequately reflect the current plant configuration with regards to mitigation of these events.

2. Other plant hazards are not identified as included in the quantitative risk analyses, nor are qualitative dispositions provided to determine that the risk from these hazard groups is insignificant. This is inconsistent with RG 1.174 which requires all hazards to be addressed. The licensee will need to address these external hazards unless they are included in the quantitative results; if so, then the technical adequacy of these PRA models will then need to be addressed per RG 1.200 Section 1.2.

Enclosure

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3. The evaluation of the internal events PRA model using RG 1.200 and the applicable PRA standard does not identify the relevant capability category(ies) associated with this application, nor is the capability category(ies) of the PRA model identified in the submittal. This is inconsistent with RG 1.200 Section 4.2. The licensee will need to supplement their submittal to address the capability category(ies) of the standard applicable to this analysis.

4. There is no statement regarding any permanent plant changes implemented but not incorporated into the PRA model used to support this risk analysis. This is inconsistent with RG 1.200 Section 4.2. The licensee will need to supplement their submittal to address this issue.

5. The submittal makes extensive commitments to Tier 2 equipment restrictions (Section 3.2.5) which are credited in the risk analyses. These restrictions are to be incorporated into plant procedures and the TS bases, but not into the TS action requirements. There is no sensitivity analyses provided to allow the NRC staff to determine which, if any, of these restrictions are critical to the acceptance of this change. The licensee will need to provide appropriate sensitivity analyses to permit NRC staff review of the acceptability of these restrictions and their control in procedures and TS bases, rather than in the TS actions.

6. The risk analyses are dependent upon the once-per-2-year use of the extended completion times (CTs), but there is no justification as to why this assumption is valid.

The licensee proposes to control voluntary use of the CT to once-per-2-years, but this is to be addressed in the TS bases, not in the TS action. Emergent repairs may result in additional use of the extended CT. The licensee will need to provide a technical justification for this assumption, and will need to provide sensitivity studies to address emergent repair use of the extended CT considering the increased probability of common cause failures (consistent with RG 1.177, Appendix A).

Electrical Engineering Review

7. In the LAR, the licensee did not provide adequate justification for amending TS Section 3.8.1 to extend the CT for an inoperable Division 1 or 2 diesel generator (DG) from 72 hours3 days <br />0.429 weeks <br />0.0986 months <br /> to 14 days. Specifically, the licensee states, "the 2-year DG inspections (which typically require 5 days to complete) and the 6-year DG overhauls (which typically require 7 days to complete)." Provide the basis for the proposed extended CT of 14 days.

8. It appears that the capacity of the proposed alternate alternating current (AC) power source (High Pressure Core Spray Emergency DG) to replace the inoperable Emergency DG (Division 1 or 2) is not adequate to support a loss-of-offsite power (LOOP) event with a unit trip. Considering the changes in electric grid performance post-deregulation, the duration of LOOP events has increased, and the probability of a LOOP as a consequence of a reactor trip has increased. As a deterministic measure to ensure adequate defense-in-depth, given the changes in the electric grid performance

-3 post-deregulation, the NRC staff requires the replacement power source has adequate capacity of handling station blackout (S80) and LOOP loads, to supplement the existing EDGs during the extended 14-day allowed outage time. Provide justification to demonstrate that the proposed diesel is adequate to maintain the defense-in-depth philosophy of the emergency power system.

S. L. Belcher -2 The information requested and associated time frame in this letter were discussed with Mr. John Dosa of your staff on May 4, 2010.

If you have any questions, please contact me at (301) 415-1030.

Sincerely, IRA!

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

Enclosure:

As stated cc wtencl: Distribution via Listserv Distribution:

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