ML15343A043

Request for Additional Information Regarding Bypass Leakage Paths

ML15343A043
Person / Time
Site:	Nine Mile Point
Issue date:	12/17/2015
From:	Mozafari B Plant Licensing Branch 1
To:	Bryan Hanson Exelon Nuclear, Nine Mile Point
Mozafari B
References
CAC MF5900
Download: ML15343A043 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 December 17, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear Nine Mile Point Nuclear Station, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING (CAC NO. MF5900)

Dear Mr. Hanson:

By application-dated March 23, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15082A368) Exelon Generation Company, LLC (Exelon) requested an amendment to the Technical Specifications for Nine Mile Point Nuclear Station, Unit 2 (NMP2). Specifically, the proposed change would relocate TS Table 3.6.1.3-1, "Secondary Containment Bypass Leakage Paths Leakage Rate Limits," and references to the Table to the Technical Requirements Manual. Exelon stated that the changes follow the guidance provided in Generic Letter 91-08, "Removal of Component Lists from Technical Specifications."

The NRC staff has determined that a request for additional information (RAI) is necessary to complete its review of the amendment request.

The enclosed RAI was discussed with your staff on December 8, 2015, and it was agreed that your response would be provided within 30 days from the date our call and draft RAI email dated December 8, 2015. Do not hesitate to contact me at 301-415-2020 if any clarification call is necessary.

Brenda Mozafari, Sr. Project Manag Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosure:

RAI cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION EXELON GENERATION COMPANY. LLC NINE MILE POINT NUCLEAR STATION, UNIT 2 By application dated March 23, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15082A368) Exelon Generation Company, LLC (Exelon) requested an amendment to the Technical Specifications for Nine Mile Point Nuclear Station, Unit 2 (NMP2).

Specifically, the proposed change would relocate TS Table 3.6.1.3-1, "Secondary Containment Bypass Leakage Paths Leakage Rate Limits," and references to the Table to the Technical Requirements Manual. Exelon stated that the changes follow the guidance provided in Generic Letter 91-08, "Removal of Component Lists from Technical Specifications." The NRC staff has determined that a request for additional information (RAI) is necessary to complete its review of the amendment request.

RAI STSB-1:

In the existing NMP2 TS, Table 3.6.1.3-1 specifies a numerical value for allowable leakage for each leakage path in standard cubic feet per hour. Surveillance Requirement (SR) 3.6.1.3.11 states:

Verify the leakage rate for the secondary containment bypass leakage paths is within the limits of Table 3.6.1.3-1 when pressurized to;;:: 40 psig.

The proposed change is deletion of Table 3.6.1.3-1 and revision of SR 3.6.1.3.11 to state:

Verify the leakage rate for the secondary containment bypass leakage paths is within the limits when pressurized to ;;:: 40 psig.

The staff requests additional information to explain why a numerical value limit on the secondary containment bypass leakage is not retained within the proposed SR 3.6.1.3.11 itself. Typically, the safety analysis for a facility assumes a specific amount of bypass leakage when calculating dose consequences. This leakage limit is reflected in the TS to ensure operation within the bounds of the safety analysis.

The regulation at 10 CFR 50.36(c)(3) requires TSs to include items in the category of surveillance requirements, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the Limiting Conditions for Operations will be met.

The leakage limit for the pathways to be considered operable must be specified in the TS.

The staff compared the proposed revision of SR 3.6.1.3.11 with the guidance provided in Generic Letter 91-08. The Generic Letter recommended that the limitation on containment leakage rate be revised to state:

Enclosure

A combined leakage rate of less than or equal to [0.10 La] for all penetrations that are secondary containment bypass leakage paths when pressurized to Pa.

This requirement has also been retained in the Standard TS.

Provide a technical justification for not retaining a numerical limit on allowable leakage on the secondary containment bypass pathways or propose a change to SR 3.6.1.3.11 to reflect the appropriate limit. If it is proposed to specify the leakage limit in terms of a combined leakage rate, please review LCO 3.6.1.3 Condition D and its associated Required Actions to ensure consistency with the proposed change to SR 3.6.1.3.11.

December 17, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear Nine Mile Point Nuclear Station, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

NINE MILE POINT NUCLEAR STATION, UNIT 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING (CAC NO. MF5900)

Dear Mr. Hanson:

By application dated March 23, 2015, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15082A368) Exelon Generation Company, LLC (Exelon) requested an amendment to the Technical Specifications for Nine Mile Point Nuclear Station, Unit 2 (NMP2). Specifically, the proposed change would relocate TS Table 3.6.1.3-1, "Secondary Containment Bypass Leakage Paths Leakage Rate Limits," and references to the Table to the Technical Requirements Manual. Exelon stated that the changes follow the guidance provided in Generic Letter 91-08, "Removal of Component Lists from Technical Specifications."

The NRC staff has determined that the enclosed request for additional information (RAI) is necessary to complete its review of the amendment request.

The enclosed RAI was discussed with your staff on December 8, 2015, and it was agreed that your response would be provided within 30 days from the date our call and draft RAI email dated December 8, 2015. Do not hesitate to contact me at 301-415-2020 if any clarification call is necessary.

Sincerely, IRA/

Brenda L. Mozafari, Sr. Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosure:

RAI cc w/encl: Distribution via Listserv DISTRIBUTION:

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