ML14071A242

NMP Unit 2, MF3056, 2nd Round of Draft RAIs - LAR License Amendment Request- Maximum Extended Load Line Limit Analysis Plus (Mellla+)

ML14071A242
Person / Time
Site:	Nine Mile Point
Issue date:	03/12/2014
From:	Bhalchandra Vaidya Plant Licensing Branch 1
To:	Darling T, Kristensen K, Perkins E Constellation Energy Group, Nine Mile Point
Vaidya B, NRR/DORL/LPL1-1, 415-3308
References
TAC MF3056
Download: ML14071A242 (4)

Text

From: Vaidya, Bhalchandra Sent: Wednesday, March 12, 2014 11:07 AM To: everett.perkins@cengllc.com; Darling, Theresa H (Theresa.Darling@cengllc.com); Kristensen, Kenneth J (Kenneth.Kristensen@cengllc.com)

Cc: Beasley, Benjamin; Stattel, Richard; Thorp, John; Bucholtz, Kristy; Elliott, Robert; Dozier, Jerry; Shoop, Undine; Guzzetta, Ashley; Huang, Tai; Jackson, Christopher; Karipineni, Nageswara; Dennig, Robert; Panicker, Mathew; Dean, Jeremy; Weerakkody, Sunil

Subject:

NMP Unit 2, MF3056, 2nd Round of DRAFT RAIs - LAR RE: License Amendment Request- RE: Maximum Extended Load Line Limit Analysis Plus (MELLLA+)

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT NO. 2; DOCKET NO. 50-410, LICENSE AMENDMENT REQUEST PURSUANT TO 10 CFR 50.90: Maximum Extended Load Line Limit Analysis Plus (MELLLA+) (TAC NO. MF3056)

By letter dated November 1, 2013 2013 (Agencywide Document Access and Management System (ADAMS) Package Accession No. ML13316B090), as supplemented by letters dated January 21, February 14, and February 25, 2014 (ADAMS Accession Nos. ML14023A654, ML14051A155(package),

and ML14064A317 (package), respectively), Nine Mile Point Nuclear Station, LLC (the Licensee) submitted a license amendment request for Nine Mile Point Nuclear Station, Unit 2. The proposed amendment would allow operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLLA+) domain; 2) use of the Detect and Suppress Solution - Confirmation Density (DSS-CD) stability solution, 3) use of the TRACG04 analysis code; 4) increase the isotopic enrichment of boron-10 in the sodium pentaborate solution used to prepare the neutron absorber solution in the Standby Liquid Control System (SLS); and 5) increase the Safety Limit Minimum Critical Power Ratio (SLMCPR) for two recirculation loops in operation.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in your LAR and has determined that additional information is needed to complete its review. The NRC staffs DRAFT request for additional information (RAI) is provided below.

SECOND ROUND - DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST RE: MAXIMUM EXTENDED LOAD LINE LIMIT ANALYSIS PLUS CONSTELLATION ENERGY NINE MILE POINT NUCLEAR STATION UNIT 2 DOCKET NO. 50-410 By letter dated November 1, 2013 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13316B090), Nine Mile Point Nuclear Station, LLC (NMPNS, the licensee) submitted a license amendment request regarding Nine Mile Point Nuclear Station Unit 2 (NMP2) Facility Operating License. The proposed amendment would revise the technical specifications to allow plant operation in the expanded Maximum Extended Load Line Limit Analysis Plus (MELLA+) domain.

Basis for the Request

On January 11, 2013, the NRC safety evaluation (ML12320A415) approved topical report NEDC-33075P. In our safety evaluation we stated the following conclusion:

Section 8 of NEDC-33075P, Revision 7 [1] provides a description of required changes to Technical Specifications, and an example is provided in Appendix A. The proposed Technical Specifications are an acceptable implementation of DSS-CD. (See above note in Section 3.2.5.)

However, if you reference the note in Section 3.2.5 of the safety evaluation, you will find that note states:

The NRC staff agrees with the technical intent provided in the example Technical Specifications; however, the example Technical Specifications are not written consistent with the improved Standard Technical Specifications format. When applying for this Topical Report, licensees should submit Technical Specifications that are consistent with their current approved Technical Specifications and the improved Standard Technical Specification use and application section.

This note was placed into the safety evaluation because TS 3.3.1.1 Condition I was not found to be acceptable because its structure is not consistent with NUREG-1430 through NUREG-1434 use and application section.

There are three specific problems with the Technical Specifications in NEDC-33075:

First, is the numbering of Condition I, required actions. They should be numbered I.1, I.2, and I.3. The I.2.1 and I.2.2 nomenclature is used not used correctly.

Secondly, the completion time for required action I.2.2 is not correctly stated, 90 days is an error in structure, it should state, immediately. Licensees should immediately initiate action in accordance with specification 5.6.6. Specification 5.6.6 then tells them that they have within the following 90 days to submit the report.

Thirdly, specification 5.6.6 is not stated correctly. It should not state, within 90 days of entering Condition I, it should state, within the following 90 days.

The proposed changes do not incorporate the correct usage and structure of technical specifications. The corrections stated above are consistent with the approved use and application section in NUREG-1434 and NMP2s current technical specifications. An example in NUREG-1434 that shows this structure is TS 3.3.3.1, Post Accident Monitoring Instrumentation, Conditions B and F, and TS 5.6.5, Post Accident Monitoring Report. An example in NMP2s TS is also TS 3.3.3.1, Post Accident Monitoring (PAM) Instrumentation, Conditions B and F and TS 5.6.6, Post Accident Monitoring (PAM) Instrumentation Report.

RAI STSB #1 The proposed change to TS 3.3.1.1 Condition F, required actions and TS 5.6.8 are not consistent with NMP2s current approved Technical Specifications and the improved Standard Technical Specification use and application section. In addition, new proposed note e refers to required action F.2.1. The problems stated above are applicable to the proposed TSs for NMP2.

Please provide TSs that are consistent with NMP2s current approved Technical Specifications and the improved Standard Technical Specification use and application section.

Basis for the Request NMP2s TS Limiting Conditions for Operation (LCO) 3.4.1 states:

Two recirculation loops with matched flows shall be in operation, OR One recirculation loop shall be in operation with the following limits applied when the associated LCO is applicable:

a. LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR),"

single loop operation limits specified in the COLR;

b. LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," single loop operation limits specified in the COLR; and

c. LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Function 2.b (Average Power Range Monitors Flow Biased Simulated Thermal Power - Upscale), Allowable Value of Table 3.3.1.1-1 is reset for single loop operation.

NMPNS proposes to add item d to the LCO for TS 3.4.1, Recirculation Loops Operating. Item d would state:

d. Intentional operation with only one recirculation loop in operation is prohibited while operating in the MELLLA domain or MELLLA+ domain as defined in the COLR.

However, the LCO requires that limits be applied when using single recirculation loop operation.

Proposed item d does not apply new limits to this LCO and therefore, its proposed placement is not appropriate in TS LCO 3.4.1. Proposed item d applies a restriction to single recirculation loop operation and should be appropriately incorporated directly into the LCO. For example:

One recirculation loop shall be in operation provided the plant is not operating in the MELLA or MELLLA+ domain defined in the COLR and provided the following limits are applied when the associated LCO is applicable:

RAI STSB #2 The proposed change to TS LCO 3.4.1 is not incorporated correctly into NMP2s TSs. Please provide a TS change that incorporates the restriction into the LCO for TS 3.4.1.

Regulatory Analysis Basis 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit states:

Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and

manufacturing license under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission, as specified in

§§ 50.4 or 52.3 of this chapter, as applicable, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

The NRC staff would like to receive the responses to the RAIs within 30 days from the date of this communication. Please contact me, ASAP, to schedule a telephone conference between the licensee and the NRC staff to ensure that the licensee clearly understands the RAIs and also, to obtain a firm commitment/ confirmation from the licensee for the Responses to these RAIs.

Please contact me, if you have any questions.

Thanks, Bhalchandra K. Vaidya Licensing Project Manager NRC/NRR/DORL/LPL1-1 (301)-415-3308 (O) bhalchandra.vaidya@nrc.gov