NMP2L2634, Emergency License Amendment Request - Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications

Emergency License Amendment Request - Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications

ML16333A001
Person / Time
Site:	Nine Mile Point
Issue date:	11/26/2016
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP2L2634
Download: ML16333A001 (21)

Text

Exelon Generation© NMP2L2634 November 26, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRG Docket No. 50-410 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 10 CFR 50.91 (a)(5)

SUBJECT:

Emergency License Amendment Request - Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications Pursuant to 1 O CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2). The proposed changes are being requested on an emergency basis pursuant to 1 O CFR 50.91 (a)(5).

The proposed changes modify the High Pressure Core Spray (HPCS) system and Reactor Core Isolation Cooling (RCIC) system actuation instrumentation TS by reinserting a footnote that was unintentionally removed from the original TS during the conversion to Improved Technical Specifications for NMP2. The reinserted footnote will again provide clarification that the injection functions of Drywall Pressure - High (HPCS only) and Manual Initiation (HPCS and RCIC) are not required to be operable under low reactor pressure conditions. The original footnote was previously approved by the NRC for NMP2 with issuance of NUREG-1253, "Technical Specifications Nine Mile Point Nuclear Stations, Unit No. 2," dated July 1987. These proposed changes will resolve a U.S. Nuclear Regulatory Commission (NRC) inspection finding documented in the second quarter 2016 inspection report for NMP2 which was the result of removing the note from the TS.

Therefore, this request is not subject to "forward fit" considerations as discussed in a letter from S. G. Burns (NRC, General Counsel) to E. C. Ginsberg (NEI), dated July 14, 2010 (ML101960180). In response to the inspection finding, this issue was being tracked in the Exelon Corrective Action Program (CAP) and Exelon had developed a License Amendment Request (LAA) to support the upcoming refueling outage in the spring of 2018. Exelon planned to submit this LAA in the fourth quarter of 2016 to support a normal review and approval process, until the current forced outage required the submittal of this emergency LAA.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O November 26, 2016 Page 2 As further detailed in Attachment 1 of this letter, on November 23, 2016, NMP2 experienced an unexpected degradation of the "A" Reactor Recirculation Pump motor bearings. Repairs required a plant shutdown on November 24, 2016. The need for a forced shutdown was not expected.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 1 O CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the NMP Plant Operations Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

This emergency LAR contains no regulatory commitments. provides the evaluation of the proposed changes and justification for the need for the emergency LAR per 10 CFR 50.91 (a)(5). Attachment 2 provides a copy of the marked up TS pages that reflect the proposed changes and Attachment 3 provides a copy of the marked up TS Bases pages for reference only.

Exelon requests approval of this emergency LAR by 1800 on November 29, 2016, to support the earliest mode change from the forced outage.

In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Ron Reynolds at (610) 765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 26th day of November 2016.

~~:"~) I. 4~;0--

D~T. Gudger Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages

3. Markup of Proposed Technical Specifications Bases Pages cc:

Regional Administrator - NRC Region I NRC Senior Resident Inspector - NMP NRC Project Manager, NRR - NMP A.L. Peterson, NYSERDA w/ attachments

Subject:

ATTACHMENT 1 Emergency License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket Nos. 50-410 EVALUATION OF PROPOSED CHANGES Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusions

7.0 REFERENCES

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Page 1 of 11 Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2). The proposed changes are being requested on an emergency basis pursuant to 1 O CFR 50.91 (a)(5). The reason that this License Amendment Request (LAR) is being submitted on an emergency basis and the justification why this situation could not be avoided is further discussed in Section 3 below.

The proposed changes modify the High Pressure Core Spray (HPCS) system and Reactor Core Isolation Cooling (RCIC) system actuation instrumentation TS by reinserting a footnote that was unintentionally removed from the original TS during the conversion to Improved Technical Specifications for NMP2 (License Amendment 91 dated February 15, 2000, ML003686855). The reinserted footnote will again provide clarification that the injection functions of Drywall Pressure - High (HPCS only) and Manual Initiation (HPCS and RCIC) are not required to be operable under low reactor pressure conditions. The original footnote was previously approved by the NRC for NMP2 with issuance of NUREG-1253, "Technical Specifications Nine Mile Point Nuclear Stations, Unit No. 2," dated July 1987 (Reference 1 ). These proposed changes will resolve a U.S. Nuclear Regulatory Commission (NRC) inspection finding documented in the second quarter 2016 inspection report for NMP2, which was the result of removing the note from the TS. Therefore, this request is not subject to "forward fit" considerations as discussed in a letter from S. G.

Burns (NRC, General Counsel) to E. C. Ginsberg (NEI), dated July 14, 2010 (ML101960180) (Reference 2). In response to the inspection finding, this issue was being tracked in the Exelon Corrective Action Program (CAP) and Exelon had developed a LAR to support the upcoming refueling outage in the spring of 2018. Exelon planned to submit this LAR in the fourth quarter 2016 to support a normal review and approval process, until the current forced outage required the submittal of this emergency LAR.

Exelon requests approval of this emergency license amendment request by 1800 on November 29, 2016, to support the earliest mode change from the forced outage.

2.0 DETAILED DESCRIPTION The following information is a summary discussion from the Updated Safety Analysis Report (USAR) provided for completeness. There have been no changes to the instrumentation or systems affected by reinserting this footnote.

The HPCS system consists of a motor-driven centrifugal pump, an independent spray sparger in the reactor vessel located above the core (separate from the Low Pressure Core Spray sparger) and associated system piping, valves, controls and instrumentation.

The HPCS system provides coolant to the reactor vessel following a small break Loss of Coolant Accident (LOCA) until reactor pressure is below the pressure at which the low pressure coolant injection systems, i.e., the Low Pressure Core Spray (LPCS) system or the Low Pressure Coolant Injection (LPCI) mode of the Residual Heat Removal (RHR) system.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes Page 2of11 In addition, the HPCS system is designed to automatically start on primary containment (drywall) high pressure. Primary containment high pressure is an indication that a breach of the nuclear process barrier has occurred inside the drywall. The system can also be initiated manually.

The RCIC system uses a steam-driven turbine-pump unit and automatically operates to maintain adequate water level in the reactor vessel. The RCIC system provides makeup water to the reactor vessel when the vessel is isolated. The RCIC system is designed to ensure that sufficient reactor water inventory is maintained in the reactor vessel to permit adequate core cooling in the event of a loss of normal feedwater flow. The system can also be initiated manually.

HPCS and RCIC system controls automatically start the systems from the receipt of a reactor vessel low-low water level signal (Level 2). In all actuation modes, the systems are prevented from injecting above high reactor vessel water level (Level 8) using one-out-of-two twice logic that originates from wide range reactor vessel level instrumentation.

The HPCS and RCIC system controls function to provide design makeup water flow to the reactor vessel until the amount of water delivered to the reactor vessel is adequate (Level 8), at which time the HPCS and RCIC systems automatically stop injecting into the reactor vessel. The HPCS and RCIC systems are designed to automatically cycle between the low-low (Level 2) and high (Level 8) reactor vessel water levels.

TS Table 3.3.5.1-1 requires HPCS Drywall Pressure-High and Manual Initiation actuation instrumentation to be operable in various operational conditions. Any challenge to the reactor coolant pressure boundary that results in a high drywell pressure condition will result in an automatic actuation of the HPCS system actuation logic; however, the system will not automatically inject with the Level 8 signal present. The system will automatically inject, without operator intervention, when a demand for inventory is sensed at low-low reactor vessel water level (Level 2). Or, the system can be started manually if the Level 8 signal clears or is overridden. This operation is the same for a high reactor vessel water level occurring at rated pressure and temperature, or at low reactor vessel pressures and temperatures.

Similar to HPCS, TS Table 3.3.5.2-1 requires RCIC Manual Initiation actuation instrumentation to be operable in various operational conditions. However, as a result of the level instrumentation condition, a high reactor vessel water level signal is present for the RCIC system at low reactor pressures (up to 600 psig), but above the pressure at which the RCIC system is required to be operable, and the system will not manually inject with the Level 8 signal present. The system will automatically inject, without operator intervention, when a demand for inventory is sensed at low-low reactor vessel water level (Level 2). Or, the system can inject manually if the Level 8 signal clears or is overridden.

This operation is the same for a high reactor vessel water level occurring at rated pressure and temperature, or at low reactor vessel pressures and temperatures.

Therefore, Exelon proposes to change the HPCS system actuation instrumentation Limiting Condition for Operation requirements specified in TS Table 3.3.5.1-1, "Emergency Core Cooling System Instrumentation," to add a footnote indicating that the

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes Page 3of11 injection functions of Drywall Pressure - High and Manual Initiation are not required to be operable under low reactor pressure conditions. In addition, Exelon proposes to change the RCIC system actuation instrumentation Limiting Condition for Operation requirements specified in TS Table 3.3.5.2-1, "Reactor Core Isolation Cooling System Instrumentation,"

to add a footnote indicating that the injection function of Manual Initiation is not required to be operable under low reactor pressure conditions.

In particular, the following changes are proposed for NMP2:

1. TS Table 3.3.5.1-1 will be revised on TS page 3.3.5.1-12 to add notation (d) to the end of Function 3.b., "Drywell Pressure - High," and Function 3.i, "Manual Initiation," listed under Function 3, "High Pressure Core Spray (HPCS) System."

Notation "(d)" will read as follows: "The injection functions of Drywall Pressure -

High and Manual Initiation are not required to be OPERABLE with reactor steam dome pressure less than 600 psig."

2. TS Table 3.3.5.2-1 will be revised on TS page 3.3.5.2-4 to add notation (a) to the end of Function 5, "Manual Initiation." Notation "(a)" will read as follows: "The injection function of Manual Initiation is not required to be OPERABLE with reactor steam dome pressure less than 600 psig."

By reinstating the footnote in the cited TS tables literal compliance will be ensured.

See Attachment 2 for a copy of the marked up TS pages that reflect the proposed changes described above. Attachment 3 provides a copy of the TS Bases markups for reference only.

3.0 BACKGROUND

Description of Events NMP2 experienced an unexpected degradation of the "A" Reactor Recirculation Pump motor bearings at 0530 on November 23, 2016. Troubleshooting required a drywall entry, which was performed on November 24, 2016, at 1002 when the extent of equipment failure to the motor bearing oil cooler was determined. Subsequently, it was determined that the recirculation pump seal required replacement due to oil intrusion. Repair to the motor bearing oil cooler, bearings, and pump seal required a plant shutdown, which started on November 24, 2016, at 1312.

Reason the Amendment is Requested on an Emergency Basis These proposed changes will allow for compliance with TS 3.3.5.1 for HPCS and 3.3.5.2 for RCIC to support startup from the current forced outage and future outages. Prior to the previous refueling outage, NMP2 remained at full power for 412 days. Therefore, based on improved equipment reliability, processing the LAR to coincide with the 2018 outage was commensurate with Exelon's expected need.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes Reason Emergency Situation Has Occurred Page 4of11 The unexpected failure of the "A" Reactor Recirculation Pump motor bearing oil cooler required a conservative decision to shut down the plant for repairs. The station's power history since startup from the spring 2016 refueling outage has been at normal power, with the exception of TS required surveillances and the associated power reductions. The "A" Reactor Recirculation Pump motor performance has been monitored from August 27, 2016, due to temperatures for the upper guide, upper thrust, and lower thrust bearings being lower than normal (100 degrees Fahrenheit versus 135-160 degrees Fahrenheit).

Historically, this pump and motor had good performance. From August 27 to November 22, 2016, parameters were consistent. On November 22, 2016, an unexpected low oil level alarm for the upper bearing oil reservoir was received leading to the conservative shutdown of the plant for repairs.

Reason the Situation Could Not Have Been Avoided Increased monitoring of the "A" Reactor Recirculation Pump and motor parameters began on November 22, 2016, due to a low oil level alarm for the upper bearing oil reservoir.

Motor bearing vibrations and temperature degradation worsened after the low oil level alarm was received, requiring plant operators to secure the pump in accordance with the adverse condition monitoring plan on November 23, 2016. Failure of the motor bearing oil cooler was discovered during drywell entry on November 24, 2016, which led to the subsequent plant shutdown for repairs.

Risk Assessment The proposed changes are administrative in nature and there is no change in the station's baseline risk from 1.BE-06/yr CDF and 2.6E-07/yr LERF.

4.0 TECHNICAL EVALUATION

The following information is provided to support this emergency LAR. There have been no changes to the instrumentation or systems affected by this footnote.

Reactor vessel low-low water level is monitored by four level sensors that sense the difference between the pressure of the water column in a constant reference leg (which is independent of reactor water level and density) and the pressure of the water column in the variable leg which varies linearly with the reactor vessel water level but is also dependent on the reactor water density. Each level sensor provides input to a trip unit and the four trip units are connected in a one-out-of-two twice logic to provide an automatic HPCS and RCIC actuation signal. Reactor vessel low-low water level is an indication that reactor coolant is being lost and that the fuel is in danger of being overheated. The reactor vessel low-low water level setting for HPCS and RCIC TS Allowable Value 0:?101.8 inches of water level (Level 2) is selected high enough above the active fuel to start the HPCS and RCIC systems in time both to prevent excessive fuel cladding temperatures.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes Page 5of11 The same four wide range reactor vessel water level sensors that provide the HPCS and RCIC low water level actuation signals also provide the HPCS and RCIC high reactor vessel water level signals. Each sensor is connected to a trip unit and the four trip units are connected in a one-out-of-two twice logic to automatically stop the HPCS and RCIC systems from injecting into the reactor vessel. High water level in the reactor vessel indicates that the HPCS and RCIC systems have performed satisfactorily in providing makeup water to the reactor vessel and core cooling requirements are satisfied. The reactor vessel high water level setting that stops HPCS and RCIC is TS Allowable Value S209.3 inches of water (Level 8) is near the top of the steam separators and is sufficient to prevent flooding the reactor vessel above the main steam lines and prevent gross moisture carry over to the RCIC turbine.

Due to the undesirable effects of flooding the reactor vessel above the main steam lines, the HPCS and RCIC systems are prevented from injecting above the high reactor vessel water level (Level 8) setting in all actuation modes. Once actuated, the HPCS high reactor vessel water level signal is sealed in and will inhibit automatic (or manual) system actuation until indicated water level drops below the Level 8 setting and the high reactor vessel water level signal is manually reset, or the signal is automatically reset when indicated reactor vessel water level reaches the Level 2 actuation setting. For RCIC, there is no seal-in circuit for the Level 8 signal, so once reactor vessel water level drops below the Level 8 setting, the RCIC system can be manually initiated, or the system is automatically initiated when indicated reactor vessel water level reaches the Level 2 actuation setting.

The NMP2 wide range reactor vessel level instruments are differential pressure type instruments that are reactor coolant density sensitive and are calibrated to be most accurate at normal reactor operating conditions. As a result, at low reactor coolant temperatures and pressures, because the reactor vessel water density is higher than at calibration conditions, these instruments read higher than actual water level. As a result of this level instrumentation condition, a high reactor vessel water level (Level 8) signal is present for the HPCS and RCIC systems at low reactor pressures (up to 600 psig), but above the pressure at which the systems are required to be operable.

The HPCS and RCIC wide range off-calibration condition is not an operational or safety concern for the following reasons described below:

1. The plant response for LOCA and loss of feedwater flow events is governed by the liquid mass inventory in the reactor vessel. The difference between the indicated level in the vessel and the actual level in the vessel does not reflect a change in the liquid mass inventory in the downcomer region of the vessel because the level indication is a function of the total mass above the variable leg level tap elevation (approximately liquid density times height). This makes the level indication effectively self-compensating with respect to tracking the liquid mass inventory. Therefore, there is approximately the same liquid mass in the downcomer region at the same indicated level, regardless of the vessel pressure conditions. At the very low reactor powers considered in the off-calibrated conditions, the liquid mass inventory in the vessel is higher than the vessel inventory in the full power analyses of record because there is substantially less steam voiding in the core and upper plenum regions of the vessel.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O Evaluation of Proposed Changes Page 6of11 Because the HPCS and RCIC Level 2 system actuations occur on indicated level, the overall plant response for LOCA and loss of feedwater flow events at the low reactor pressure off-calibration events is bounded by the full power analyses of record.

2. HPCS and RCIC are systems designed to mitigate events such as LOCA or loss of feedwater flow, and assure that the reactor vessel water level stays high enough to provide adequate core cooling. According to the boiling water reactor design base, HPCS and RCIC are only required to inject water into the reactor when the reactor vessel water level decreases to Level 2. For NMP2, the Level 2 TS Allowable Value is

101.8 inches. Because the HPCS and RCIC level actuations come from the same wide range level instrumentation, the Level 8 signal clears and the HPCS and RCIC systems are automatically inject into the reactor vessel when the Level 2 actuation occurs, regardless of the off-calibration condition. When the off-calibration condition (due to low reactor pressure) is present, then for the same level loss scenario, the Level 2 actuation is reached at a later time than it would under calibrated conditions; however, the actual level is still well above the top of active fuel. Since the Level 2 actuation occurs, and HPCS and RCIC systems automatically initiate at that time, adequate core cooling is assured.

The NMP2 wide range reactor vessel level instruments are differential pressure type instruments that are reactor coolant density sensitive and are calibrated to be most accurate at normal reactor operating conditions. As a result, at low reactor coolant temperatures and pressures, because the reactor vessel water density is higher than at calibration conditions, these instruments read higher than actual water level. As a result of this level instrumentation condition, a high reactor vessel water level (Level 8) signal is present for the HPCS and RCIC systems at low reactor pressures (up to 600 psig), but above the pressure at which the systems are required to be operable.

3. Once the reactor vessel water level reaches Level 2, the HPCS and RCIC actuation logic is designed to automatically trigger HPCS and RCIC injection. Depending upon the accident scenario and size of break, this injection could start to raise the water level inside the reactor, so the HPCS and RCIC logic is designed to automatically stop HPCS and RCIC injection if the reactor vessel water level reaches Level 8 in order to protect the RCIC turbine. If level decreases below Level 8, the Level 8 signal is lifted, and when the level reaches Level 2, the HPCS and RCIC logic functions automatically to assure HPCS and RCIC injection. Thus, if the break is such that the HPCS and RCIC systems can provide enough water to raise the reactor vessel water level above Level 2, the HPCS and RCIC actuation logic is designed to allow the system to automatically maintain level between Level 2 and Level 8 with no operator intervention. If the break is such that HPCS and RCIC cannot provide enough water to maintain level, then the low pressure Emergency Core Cooling Systems (ECCS)

(ADS, Core Spray, and LPCI) are initiated when the indicated reactor vessel water level drops to Level 1 (TS Allowable Value ;::10.8 inches). Once the low pressure systems are initiated, HPCS and RCIC are not needed, although they would continue to inject (assuming the vessel pressure was high enough to drive the RCIC turbine) until the reactor vessel water level recovered sufficiently to Level 8.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O Evaluation of Proposed Changes Page 7of11

4. When the reactor vessel water level is sensed by wide range level indication to be above Level 8, the HPCS and RCIC systems will not inject without operator action.

See the discussion on density compensation in Item 2 above. With level sensed above Level 8 during normal and off-calibration conditions, injection is not required for adequate core cooing since level will be well above the top of active fuel. To maintain adequate core cooling as level lowers, manual action is not required, since the systems automatically cycle and maintain the reactor vessel water level between Level 2 (above the top of active fuel) and Level 8. Furthermore, the systems can be manually initiated between Level 2 and Level 8 at any time with simple Operator actions; and, at any high reactor water level by defeating the Level 8 signal using approved procedures. Procedures are available to the Operators to defeat the Level 8 signal from Control Room back panels to maintain RCIC or HPCS injection in case of a false or high reactor water level indication. For HPCS, this requires turning a keylock override switch. For RCIC, this requires removing a trip logic device. If level drops below Level 8, the systems can be manually initiated by the operator with simple front panel actions before auto-initiation at Level 2. When below Level 8, the HPCS sealed-in signal can be cleared by pushing the reset button, and then the HPCS system can be manually initiated by pushing the manual initiate button or by manually aligning the system for injection. There is no seal-in circuit for the RCIC Level 8 signal, so once the level decreases below Level 8 the RCIC system can be manually initiated by pushing the manual initiate button or by manually aligning the system for injection.

5. When the HPCS and RCIC systems are injecting between Level 2 and Level 8, injection into the reactor vessel from the systems can be manually stopped regardless of what level signals are present. HPCS injection can be manually stopped by closing the injection valve or stopping the pump. RCIC injection can be manually stopped by closing the injection valve or tripping the turbine.

6. With a Level 8 signal, HPCS and its associated diesel generator will initiate on high drywell pressure LOCA actuation signal. The Level 8 setpoint, however, maintains the injection valve closed. Above the Level 8 setpoint the HPCS pumps and associated diesel generator remain in service on minimum flow available for manual injection or injection when reactor vessel water level reaches Level 2. The wide range off-calibration condition does not affect reaching Level 2, and therefore, HPCS injection will occur as assumed in the safety analysis. Note: The NMP2 Appendix K limiting small break Peak Cladding Temperature (PCT) is based on the single failure of the HPCS diesel generator, and therefore, HPCS is not credited for defining maximum PCT.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O Evaluation of Proposed Changes Conclusion Page 8of11 The proposed changes make the NMP2 TS consistent with the plant design and licensing basis. Further, they clarify that the required initiation functions of the HPCS (high drywell pressure and manual) and RCIC (manual) actuation instrumentation are not required to be operable below 600 psig, and that the wide range off-calibration condition of high reactor vessel water level due to instrumentation design and calibration requirements do not affect the safe operation of the plant. In addition, there is no change to the baseline plant risk assessment associated with these proposed changes (1.BE-06/yr CDF and 2.6E-07/yr LERF).

5.0 REGULA TORY EVALUATION 5.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, "Technical specifications," in which the Commission established its regulatory requirements related to the contents of the TS. Specifically, 10 CFR 50.36(c)(2) states, in part, "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility."

The proposed changes to the HPCS and RCIC actuation instrumentation requirements do not affect compliance with these regulations.

The applicable 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," was considered as follows:

Criterion 13 - Instrumentation and control. Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

The proposed changes would retain the necessary safety function on low-low reactor vessel water level at reactor coolant system pressures below 600 psig because the measurement condition in reactor vessel water level decreases as the reactor vessel water level decreases and actuation of HPCS and RCIC would still occur. By reinstating the footnote in the cited TS tables literal compliance will be ensured.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O Evaluation of Proposed Changes 5.2 Precedent Page 9of11 This footnote was approved for NMP2 as part of initial licensing, as documented in NUREG-1253. The proposed changes will restore the note that was mistakenly removed during the conversion to Improved Technical Specifications.

A similar change, to add a footnote to the High Pressure Core Spray (HPCS) system actuation instrumentation TS indicating that the injection functions of Drywell Pressure -

High and Manual Initiation are not required to be operable when the indicated reactor vessel water level on the wide range instrument is greater than Level 8 coincident with low reactor pressure conditions, was requested by Mississippi Power & Light Company for Grand Gulf Nuclear Station, Unit 1 and was approved by the NRC in 1983 (References 3 and 4), and then again in 1986 (References 5 and 6). The 1983 change was initially a one-time change which was made permanent in 1986.

5.3 No Significant Hazards Consideration Exelon Generation Company, LLC (Exelon), proposes changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2.

The proposed changes modify the High Pressure Core Spray (HPCS) system and Reactor Core Isolation Cooling (RCIC) system actuation instrumentation TS by adding footnotes indicating that the injection functions of Drywell Pressure - High (HPCS only) and Manual Initiation (HPCS and RCIC) are not required to be operable under low reactor pressure conditions.

Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1.

Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes involve the addition of clarifying footnotes to the HPCS and RCIC actuation instrumentation TS to reflect the as-built plant design and operability requirements of HPCS and RCIC instrumentation as described in the NMP2 Updated Safety Analysis Report (USAR).

HPCS and RCIC are not an initiator of any accident previously evaluated. As a result, the probability of any accident previously evaluated is not increased. In addition, the automatic start of HPCS on high drywell pressure and the manual initiation of HPCS and RCIC are not credited to mitigate the consequences of design basis accidents within the current NMP2 design and licensing basis.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-410 Evaluation of Proposed Changes Page 10of11 Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not alter the protection system design, create new failure modes, or change any modes of operation. The proposed changes do not involve a physical alteration of the plant, and no new or different kind of equipment will be installed. Consequently, there are no new initiators that could result in a new or different kind of accident.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Do the proposed changes involve a significant reduction in a margin of safety?

Response: No.

The proposed changes have no adverse effect on plant operation. The plant response to the design basis accidents does not change. The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Exelon concludes that the proposed emergency LAR presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Emergency License Amendment Request HPCS and RCIC Actuation Instrumentation Docket Nos. 50-41 O Evaluation of Proposed Changes

6.0 ENVIRONMENTAL CONSIDERATION

Page 11 of 11 A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. NUREG-1253, Technical Specifications Nine Mile Point Nuclear Station, Unit No. 2, July 1987.

2. Letter from S. G. Burns (NRC, General Counsel) to E. C. Ginsberg (NEI), dated July 14, 2010(ML101960180).

3. Letter from L. F. Dale, Mississippi Power & Light Company, to H. R. Denton, U.S.

Nuclear Regulatory Commission, "Transmittal of Proposed Changes to Grand Gulf Technical Specifications," dated August 1, 1983.

4. Letter from A. Schwencer, U.S. Nuclear Regulatory Commission, to J. P. McGaughy, Mississippi Power & Light Company, "Amendment No. 1 Oto Facility Operating License No. NPF Grand Gulf Nuclear Station, Unit 1," dated September 23, 1983.

5. Letter from 0. D. Kingsley, Jr., Mississippi Power & Light Company, to H. R. Denton, U.S. Nuclear Regulatory Commission, "Proposed amendment to the Operating License," dated January 29, 1986.

6. Letter from L. L. Kintner, U.S. Nuclear Regulatory Commission, to 0. D. Kingsley, Jr.,

Mississippi Power & Light Company, "Change to Technical Specifications and Operating License Condition," dated October 17, 1986.

ATTACHMENT 2 Emergency License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket No. 50-410 Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications Markup of Proposed Technical Specifications Pages TS Pages 3.3.5.1-12 3.3.5.2-4

ECCS Instrumentation 3.3.5.1 Table 3.3.5.1-1 (page 4 of 5)

Emergency Core Cooling System Instrumentation APPLICABLE CONDITIONS MODES OR REFERENCED OTHER REQUIRED FROM SPECIFIED CHANNELS PER REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS FUNCTION ACTION A.1 REQUIREMENTS VALUE

3. High Pressure Core Spray (HPCS) System

a.

Reactor Vessel Water 1,2,3, 4(b)

B SR 3.3.5.1.1

~ 101.8 Level - Low Low, SR 3.3.5.1.2 inches Level2 4(a),5(a)

SR 3.3.5.1.3 Drywell Pressure - Hig~,3 SR 3.3.5.1.5 SR 3.3.5.1.6

b.

4(b)

B SR 3.3.5.1.1 s 1.88 psig SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

c.

Reactor Vessel Water 1,2,3, 4

c SR 3.3.5.1.1

$ 209.3 Level - High, Level 8 SR 3.3.5.1.2 inches 4(a),5(a)

SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

d.

Pump Suction 1,2,3, 2

D SR 3.3.5.1.1

~ 94.5 inches Pressure - Low SR 3.3.5.1.2 H20 4(c),5(c)

SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

e.

Pump Suction 1,2,3, D

SR 3.3.5.1.2 s 5.5 seconds Pressure - Timer SR 3.3.5.1.5 4(C),5(C)

SR 3.3.5.1.6

f.

Suppression Pool Water 1,2,3 2

D SR 3.3.5.1.1

$ 200.7 ft Level-High SR 3.3.5.1.2 SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

g.

HPCS Pump Discharge 1,2,3, E

SR 3.3.5.1.1

~ 220 psig Pressure - High SR 3.3.5.1.2 (Bypass) 4(a),5(a)

SR 3.3.5.1.3 SR 3.3.5.1.5 SR 3.3.5.1.6

h.

HPCS System Flow 1,2,3, E

SR 3.3.5.1.1

~ 580 gpm and Rate - Low (Bypass)

SR 3.3.5.1.2 s 720 gpm 4(a),5(a)

SR 3.3.5.1.3 Manual Initiation~

SR 3.3.5.1.5 SR 3.3.5.1.6

i.

1,2,3, 2

c SR 3.3.5.1.6 NA 4(a),5(a) continued (a)

When associated ECCS subsystem(s) are required to be OPERABLE per LCO 3.5.2.

(b)

Also required to initiate the associated DG.

(c)

When HPCS is OPERABLE for compliance with LCO 3.5.2 and aligned to the condensate storage tank while tank water level is not within the limit of SR 3.5.2.2.

3.3.5.1-12 Amendment 91 (d) The injection functions of Drywell Pressure-High and Manual Initiation are not required to be OPERABLE with reactor steam dome pressure less than 600 psig.

1.

2.

3.

4.

5.

FUNCTION Reactor Vessel Water Level - Low Low, Level 2 Reactor Vessel Water Level - High, Level 8 Pump Suction Pressure - Low Pump Suction Pre'5"re-Tim~

Manual lnitiatio (a)

Table 3.3.5.2-1 (page 1 of 1)

RCIC System Instrumentation 3.3.5.2 Reactor Core Isolation Cooling System Instrumentation CONDITIONS REQUIRED REFERENCED CHANNELS PER FROM REQUIRED SURVEILLANCE ALLOWABLE FUNCTION ACTIONA.1 REQUIREMENTS VALUE 4

B SR 3.3.5.2.1

~ 101.8 inches SR 3.3.5.2.2 SR 3.3.5.2.3 SR 3.3.5.2.4 SR 3.3.5.2.5 4

B SR 3.3.5.2.1 s 209.3 inches SR 3.3.5.2.2 SR 3.3.5.2.3 SR 3.3.5.2.4 SR 3.3.5.2.5 2

D SR 3.3.5.2.1

<! 101 inches Wg SR 3.3.5.2.2 SR 3.3.5.2.3 SR 3.3.5.2.4 SR 3.3.5.2.5 D

SR 3.3.5.2.2 s 12.3 seconds SR 3.3.5.2.4 SR 3.3.5.2.5 2

c SR 3.3.5.2.5 NA (a) The injection function of Manual Initiation is not required to be OPERABLE with reactor steam dome pressure less than 600 psig.

NMP2 3.3.5.2-4 Amendment 91

ATTACHMENT 3 Emergency License Amendment Request Nine Mile Point Nuclear Station, Unit 2 Docket No. 50-410 Proposed Changes to the High Pressure Core Spray System and Reactor Core Isolation Cooling System Actuation Instrumentation Technical Specifications Markup of Proposed Technical Specifications Bases Pages TS Bases Pages B 3.3.5.1-17 B 3.3.5.1-22 B 3.3.5.2-6

BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY

. except when reactor steam dome pressure is less than 600 psig due to the hot calibration/cold operation level error NMP2 ECCS Instrumentation B 3.3.5.1 3.a. Reactor Vessel Water Level-Low Low. Level 2 (continued) assumed to fail will be sufficient to avoid initiation of low pressure ECCS at Reactor Vessel Water Level - Low Low Low, Level 1.

Four channels of Reactor Vessel Water Level - Low Low, Level 2 Function are only required to be OPERABLE when HPCS is required to be OPERABLE to ensure that no single instrument failure can preclude HPCS initiation. Refer to LCO 3.5.1 and LCO 3.5.2 for HPCS Applicability Bases.

3.b. Drywell Pressure - High High pressure in the drywell could indicate a break in the RCPB. The HPCS System and associated DG are initiated upon receipt of the Drywell Pressure - High Function in order to minimize the possibility of fuel damage. Although no credit is taken for the Drywell Pressure - High Function to start the HPCS System in any OBA or transient analyses, credit is taken for this Function to start the associated DG; that is, HPCS is assumed to be initiated on Reactor Water Level - Low Low, Level 2 while the associated DG is assumed to be initiated on Drywell Pressure - High. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 1 O CFR 50.46.

rywell Pressure - High signals are initiated from four p ssure transmitters that sense drywell pressure. The All wable Value was selected to be as low as possible and be indi tive of a LOCA inside primary containment.

ell Pressure - High Function is required to be OPERA E when HPCS is required to be OPERABLE in conjunction with times 1\\"{hen the primary containment is required to be OPERABLE:!. Thus, four channels of the HPCS Drywell Pressure - High Function are required to be OPERABLE in MODES 1, 2, and 3, to ensure that no single instrument failure can preclude ECCS initiation. In MODES 4 and 5, the Drywell Pressure - High Function is not required since there is insufficient energy in the reactor to pressurize the drywell to the Drywell Pressure - High Function setpoint.

Refer to LCO 3.5.1 for the Applicability Bases for the HPCS System.

(continued)

B 3.3.5.1-17 Revision 0

ECCS Instrumentation B 3.3.5.1 BASES

, except when reactor steam dome pressure

---

1is less than 600 psig APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY NMP2 3.i. Manual Initiation (continued) due to the hot calibration/cold There is no Allowable Value for this Function since th operation level error channels are mechanically actuated based solely on position of the switch and push button. Two channel Manual Initiation Function are only required to be OP RABLE when the HPCS System is required to be OPERABL. Refer to LCO 3.5.1 and LCO 3.5.2 for HPCS Applicability Bases.

Automatic Depressurization System 4.a. 5.a. Reactor Vessel Water Level - Low Low Low. Level 1 Low RPV water level indicates that the capability to cool the fuel may be threatened. Should RPV water level decrease too far, fuel damage could result. Therefore, ADS receives one of the signals necessary for initiation from this Function. The Reactor Vessel Water Level - Low Low Low, Level 1 is one of the Functions assumed to be OPERABLE and capable of initiating the ADS during the accidents analyzed in Reference 2. The core cooling function of the ECCS, along with the scram action of the RPS, ensures that the fuel peak cladding temperature remains below the limits of 1 O CFR 50.46.

Reactor Vessel Water Level - Low Low Low, Level 1 signals are initiated from four differential pressure transmitters that sense the difference between the pressure due to a constant column of water (reference leg) and the pressure due to the actual water level (variable leg) in the vessel. The Reactor Vessel Water Level - Low Low Low, Level 1 Allowable Value is chosen high enough to allow time for the low pressure core spray and injection systems to initiate and provide adequate cooling.

Four channels of Reactor Vessel Water Level - Low Low Low, Level 1 Function are only required to be OPERABLE when ADS is required to be OPERABLE to ensure that no single instrument failure can preclude ADS initiation. (Two channels input to ADS trip system A while the other two channels input to ADS trip system B). Refer to LCO 3.5.1 for ADS Applicability Bases.

B 3.3.5.1-22 (continued)

Revision 0

BASES APPLICABLE SAFETY ANALYSES, LCO, and APPLICABILITY ACTIONS NMP2 RCIC System Instrumentation B 3.3.5.2

3. 4. Pump Suction Pressure - Low and Pump Suction Pressure - Timer (continued) is low enough such that the automatic suction swap from the CST to the suppression pool will occur before adequate pump suction head is lost.

Two channels of Pump Suction Pressure - Low Function are available and are required to be OPERABLE when RCIC is required to be OPERABLE to ensure that no single instrument failure can preclude RCIC swap to suppression pool source.

In addition, one channel of the Pump Suction Pressure - Timer is required to be OPERABLE when RCIC is required to be OPERABLE. Refer to LCO 3.5.3 for RCIC Applicability Bases.

5. Manual Initiation The Manual Initiation switch and push button channels introduce a signal into the RCIC System initiation logic that is redundant to the automatic protective instrumentation and provides manual initiation capability.

There is one switch and push button (with two channels) for the RCIC System.

The Manual Initiation Function is not assumed in any accident or transient analyses in the USAR. However, the ~-------~

Function is retained for overall redundancy and diversity of

• except when reactor the RCIC function as required by the NRC in the plant steam dome pressure licensing basis.

is less than 600 psig due to the hot There is no Allowable Value for this Function s*

e the calibration/cold channels are mechanically actuated bas olely on the operation level error position of the switch and push butt

. Two channels of Manual Initiation are required t e OPERABLE when RCIC is required to be OPERABLE.

efer to LCO 3.5.3 for RCIC Applicability Bases.

A Note has been provided (Note 1) to modify the ACTIONS related to RCIC System instrumentation channels.

Section 1.3, Completion Times, specifies that once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition discovered to be inoperable or not within limits will not result in separate entry into the Condition.

B 3.3.5.2-6 (continued)

Revision 0