ML11270A073

Response to Request for Review of the Draft NRC Safety Evaluation Regarding the License Amendment Request for Extended Power Uprate Operation

ML11270A073
Person / Time
Site:	Nine Mile Point
Issue date:	09/23/2011
From:	Flaherty M Constellation Energy Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1476
Download: ML11270A073 (6)

Text

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 2.

Mark D. Flaherty P.O. Box 63 Plant General Manager Lycoming, New York 13093 315.349.5205 315.349.1321 Fax CENG.

a joint venture of 0ConstellaMion Ene l

eDF NINE MILE POINT NUCLEAR STATION September 23, 2011 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 Response to Request for Review of the Draft NRC Safety Evaluation Regarding Nine Mile Point Nuclear Station, Unit No. 2 - Re: The License Amendment Request for Extended Power Uprate Operation (TAC No. ME1476)

REFERENCES:

(a) Letter from K. J. Polson (NMPNS) to Document Control Desk (NRC), dated May 27, 2009, License Amendment Request (LAR) Pursuant to 10 CFR 50.90:

Extended Power Uprate (b) Letter from R. V. Guzman (NRC) to T. A. Lynch (NMPNS), dated September 7, 2011, Nine Mile Point Nuclear Station, Unit No. 2 - Transmittal of Draft Safety Evaluation - Extended Power Uprate (TAC No. ME1476)

By letter dated May 27, 2009 (Reference a), as supplemented, Nine Mile Point Nuclear Station, LLC (NMPNS) proposed an amendment to Nine Mile Point Unit 2 (NMP2) Renewed Operating License (OL)

NPF-69 that would increase the power level authorized by OL Section 2.C.(l), Maximum Power Level, from 3467 megawatts-thermal (MWt) to 3988 MWt.

As requested in the NRC letter dated September 7, 2011 (Reference b), NMPNS has reviewed the draft Safety Evaluation (SE) prepared by the NRC staff to support the proposed license amendment. provides NMPNS comments regarding information in the draft SE, and Attachment 2 provides pages of the draft SE that have been highlighted to identify information that should be marked as proprietary, in addition to the text that is already shown enclosed in double brackets.

This letter forwards proprietary information in accordance with 10 CFR 2.390. The balance of this letter may be considered non-proprietary upon removal of Attachment 2.

Document Control Desk September 23, 2011 Page 2 is considered to contain proprietary information exempt from disclosure pursuant to 10 CFR 2.390. Applications to withhold the proprietary information in this attachment from public disclosure in accordance with 10 CFR 2.390(b)(1) have been submitted in previous correspondence (identified in Reference b); therefore, this letter does not represent a new request for withholding from public disclosure.

Should you have any questions regarding the information in this submittal, please contact John J. Dosa, Director Licensing, at (315) 349-5219.

Very truly yours, STATE OF NEW YORK TO WIT:

COUNTY OF OSWEGO I, Mark'D. Flaherty, being duly sworn, state that I am the Nine Mile Point Plant General Manager, and that I am duly authorized to execute and file this supplemental information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

Subscribed and sworn before me, a Not ry P blic in and for the State of New York and County of 6-4

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_,this i~j day of 'ý 2011.

WITNESS my Hand and Notarial Seal:

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Document Control Desk September 23, 2011 Page 3 Attachments:

1. Comments Regarding Information in the Draft NRC Safety Evaluation

2. Pages of the Draft NRC Safety Evaluation Highlighted to Identify Information that Should Be Marked as Proprietary cc:

NRC Regional Administrator, Region I NRC Resident Inspector NRC Project Manager A. L. Peterson, NYSERDA (w/o Attachment 2)

-A.

ATTACHMENT 1 COMMENTS REGARDING INFORMATION IN THE DRAFT NRC SAFETY EVALUATION Nine Mile Point Nuclear Station, LLC September 23, 2011

ATTACHMENT 1 COMMENTS REGARDING INFORMATION IN THE DRAFT NRC SAFETY EVALUATION The following table provides comments prepared by Nine Mile Point Nuclear Station, LLC (NMPNS) regarding information in the draft Safety Evaluation (SE) prepared by the NRC staff to support the proposed extended power uprate (EPU) license amendment for Nine Mile Point Unit 2 (NMP2).

Note: The term "PUSAR" refers to NEDC-33351P, Safety Analysis Report for Nine Mile Point Nuclear Station Unit 2 Constant Pressure Power Uprate.

Comment f Draft SE Section No.

Draft SE Comment No.

and Title Page 2.4.1, Suitability of 63 Table 2.4-2 of the PUSAR originally indicated that for the Existing Instruments Main Steam Line (MSL) High Flow parameter, respan of the transmitters and associated loop components and revised setpoints were required to support operation at EPU conditions. Subsequent evaluation has determined that respan of the transmitters and associated loop components is not necessary. Only the setpoint change is required. The NRC staff is requested to revise the table on page 63 of the draft SE to indicate that the change for the MSL High Flow parameter is to revise setpoints.

2 2.4.1, Suitability of Existing Instruments 63 Table 2.4-2 of the PUSAR originally indicated that for the Moisture Separator Reheater (MSR) Outlet Pressure parameter, replacement of transmitters, respan of the associated loop instruments, and revised alarm setpoints were required to support operation at EPU conditions.

Subsequent evaluation has determined that transmitter replacement is not necessary. The NRC staff is requested to revise the table on page 63 of the draft SE to indicate that the change for the MSR Outlet Pressure parameter is to respan the associated loop instruments and revise alarm setpoints.

2.4.1, Suitability of Existing Instruments Table 2.4-2 of the PUSAR originally indicated that for the Condensate Polisher Low Flow Alarm parameter, revised setpoints were required to support operation at EPU conditions. Subsequent evaluation has determined that a setpoint revision is not required. The NRC staff is requested to revise the table on page 63 of the draft SE to remove the Condensate Polisher Low Flow Alarm parameter entry.

2.4.1, Suitability of Existing Instruments 63 Table 2.4-2 of the PUSAR originally indicated that for.the Condensate Polisher and Strainer AP parameter, revised setpoints were required to support operation at EPU conditions. Subsequent evaluation has determined that a setpoint revision is not required. The NRC staff is requested to revise the table on page 63 of the draft SE to remove the Condensate Polisher and Strainer AP parameter entry.

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ATTACHMENT 1 COMMENTS REGARDING INFORMATION IN THE DRAFT NRC SAFETY EVALUATION Comment Draft SE Section No.

Draft SE Comment No.

and Title Page 5

2.4.1, Suitability of 64 Table 2.4-2 of the PUSAR originally indicated that for the Existing Instruments Main Steam Inlet Header Pressure parameter, replacement of transmitters, respan of the associated loop components, and a revised alarm setpoint were required to support operation at EPU conditions. Subsequent evaluation has determined that these changes are not necessary. The NRC staff is requested to revise the table on page 64 of the draft SE to remove the Main Steam Inlet Header Pressure parameter entry.

6 2.5.1.4, Fire Protection 76, 77 In the December 23, 2009 letter from NMPNS to the NRC, the NMPNS response to NRC staff Request for Additional Information RAI D1 indicated that there were no plant modifications that represented physical changes to plant fire protection equipment or systems to support EPU conditions.

Subsequent installation scoping activities for two EPU modifications have identified the need for ancillary changes to fire protection systems. These are: (1) extending an existing sprinkler system to cover a new cable tray associated with the feedwater pump motor cable replacement modification; and (2) a minor relocation of existing sprinkler system piping to accommodate interferences associated with installation of the main transformer cooling upgrade modification. The NRC staff is requested to consider revising the SE to reflect these fire protection system changes.

7 2.5.2.3, Turbine Gland 84 Section 2.5.2.3 of the PUSAR originally stated that no Sealing System Turbine Gland Sealing System (TGSS) hardware changes were required to support operation at EPU conditions. A recent evaluation has determined that the calibrated span of the normal gland seal supply pressure indication instrument loop will need to be increased and the alarm setpoint revised. Section 2.5.2.3 of the draft SE states that no modifications are needed to support EPU conditions. The NRC staff is requested to consider revising the SE to reflect this instrumentation change.

8 2.8.4.4, Residual Heat 143 Section 2.8.4.4 of the PUSAR originally described the steam Removal System condensing mode (SCM) of operation of the residual heat removal (RHR) system. Subsequently, a plant modification has retired the SCM of RHR system operation, and the SCM is no longer available. The NRC staff is requested to revise the SE to reflect retirement of the SCM.

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