ML17055C315

Informs That Encl Draft Staff Comments on SER & Suppls 1 & 2 Provided to Util on 860830 to Assist in Responding to NRC Concerns

ML17055C315
Person / Time
Site:	Nine Mile Point
Issue date:	09/02/1986
From:	Adensam E, Haughey M Office of Nuclear Reactor Regulation
To:	Mcknight J NRC
References
NUDOCS 8609030369
Download: ML17055C315 (18)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SEP 8 tg86 Docket No. 50-410 NOTE TO:

Jim McKnight, Document Control FROM:

Mary Haughey, Project Manager for Nine Mile Point, Unit 2 BWR Project Directorate No.

3 Division of BWR Licensing

SUBJECT:

DRAFT INFORMATION PROVIDED TO NIAGARA MOHAWK POWER CORPORATION ON NINE MILE POINT, UNIT 2 The enclosed information was provided to Niagara Mohawk on August 30, 1986 to assist them in responding to NRC concerns on Nine Mile Point, Unit 2.

By copy of this note the enclosed information should be placed in the PDR and the LPDR.

ary Hau ey, Project anager BWR Project Directorate No.

3 Division of BWR Licensing cc:

PDR LPDR Noted:

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UNITEDSTATES NUCLEAR REGULATORYCOMMISSION WASHINGTON,D. C. 20555 STAFF RESPONSE TO NIAGARA MOHAWK POWER CORPORATION COMMENTS ON THE NINE MILE POINT UNIT 2 SER AND SUPPLEMENTS I 5 2 SECTION I SER COMMENTS In our'ER we stated that there are no non-seismic or non-tornado missile protected Category I vessels, pipes, or tanks located outside of plant build-ings.

Hence, since the seismic Category I water retaining components are limited to areas within plant buildings, their failure will not lead.to exter-nal flooding of safety related structures or components.

'The applicant has performed an analysis of the potential for causing external flooding due to failures of non-seismic Category I or non-tornado missile protected water retaining components:

The results of this analysis indicate

'hat safety related components or structures will not be adversely affected by external flooding due to the failure of non-seismic Category I or non-tornado miss i 1 e protected water retaining components.

In view of the above considerations, we conclude that the information contained t

SER i 1 t f t g.

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2.

The staff's'SER states that the "unidentified leakage from the Reactor Coolant 8

Pressure Boundary (RCPB) is detected by high pressure and temperature within

33. the pri'mary containment, drywall equipment and floor drainage sump level,

, y~,/iizgaseous radiation level in primary containment, and airborne particulate

+) radioactivity monitoring.

These leakage-detection systems are seismic Category I and are designed to be capable of performing their function following an SSE."

As stated in Amendment 5 to the FSAR, all leakage detection systems are designed to be capable of performing their functions following an seismic events which do not require a plant shutdown; i.e., at or about the severity of an operational basis earthquake.

As identified in FSAR Amendment 19, the drywell equipment drain tank collects piped drainage from the pump seal leakoff

'nd the reactor vessel head flange vent drain.

Therefore, the drywell equip-ment drain tank collects only identified leakage.

The unidentified leakage is to be monitored, as specified in the FSAR Amendment 5, by the floor drainage sump, the airborne particulate radioactivity monitoring system, and the gaseous radioactivity monitoring system.

As secondary monitoring systems, the contain-ment atmosphere temperature and pressure monitors are to detect gross leakage.

FSAR Table 3.2-1 identifies the primary containment radiation monitors (con-tainment.aetiitoring system) as the seismic Category I, Class 1E powered RCPB leakage detection systems.

The primary containment radiation monitors, as discussed

$n FSAR Section 12.3 and Table 12.3-2, are the airborne particulate radioactivity monitors and the gaseous radioactivity monitors. 'aving these monitors as seismic Category I, Class lE powered, meets the guidelines of Regulatory Guide 1.45, Position C.6.

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The drywell equipment and floor drain tanks level instrumentation:and ithe...'".:=--."';-"::-'I'-. ~

gaseous radioactivity and the airborne particulate,.radioactivity monitoring, '..",>>',':;

systems have the accuracy and the sensitivity'n accordance,with;the,guidelines;-::";;,;";

'f Regulatory Guide 1.45.

The sensitivity and accuracy:,of.these monitoring

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systems are specified in FSAR Table 5.2-8.

On.the basis of.the coriformance'f';",-,"$-';~

-'hese systems to the Regulatory Guide 1.45 in terms of-accuracy and sensitivi<<':-",;,.'".,"~';,'>.:

ty, the RCPB leakage detection systems meets We guidelines of Position'.C.S:;-iif,,'-.,-."",;".:.j.':;

Regulatory Guide 1.45, ~

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p'>>ll XF The above material ~~ be included,in,>an SER supplement.-."',': '",,">>.: "<<";",'-'.,,~,-'.~";,;','-

gpss'l(=;b~',.'jgyIsaof.

Acceptab1e for clarification.

- res'I Acceptable for clarification.

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According to FSAR Fig. 9.2-10, the top of:the highest intake:structure,"n>>ot'-:.--:

including the manhole cover, is at elevation 232.5 ft.:Lake 'Survey Datum of..=-

1935.

The normal lake level is at elevation ',246 ft." ',Hence, there is approx)-.

mately 12 feet of water between normal lake level,.and the top of the -intake,'...

structures.

The SER is correct as written.'. '",'-.',"".-,"",,

Acceptable.

Based on up-to-date information in".-FSAR 'Amendment No. 25; 'W~

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Rejected.

Table 11-4 on SER page 11-'16 is the staff's calculated. values

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CODE) and may not be consistent with the applicant's Icalculated values,"and ".,

does not a1ter the SER conclusion.

SECTION II SER COMMENTS Differences in X/g values reflect data and-model,assumptions used by.the staff,;,-

in the SER and in the FSAR by the licensee.

'~5ER is 'acceptable, as written.'.-.

Discussion of extremes of temperature

.and precipita'tions n@inals is'ubject'to,','.-:

revision periodically with the collection,.o',:more:data.

The general discussion"',...-":.

in section 2.3.1 of the SER provides an;overview o',meteorological conditions.,':"

that may'be observed in the region containing<the'plant."

".SER 'is accep'table as',:,'ritten.

Discussion of air pollution in the region'serves

'to describe the regional atmospheric conditions that exist and.can -influence 'the'.dispersion of gaseous effluents from the plant.

SER is acceptable as'written.

See response to comnent 3 response a ove.=',,>>.:;",-.'='.;-'.',-..=

'cceptable editorial change.

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11.

This change has,been reflected in a supplement fo t e SER..

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It is not clear as to exactly what<

believes is in error in the staff's SER Section 2.4.11 relating to cooling water.

Any suggested rewording by the applicant should, as a minimum, address every issue addressed by the staff in the paragraph(s) to be replaced.

In this case these issues include:

total average withdrawal, fish diversion withdrawal, blowdown and other discharges, and minimum operating water level.

9b. The correction referred to in the FSAR is a correction for Lake Survey Datum of 1935 as is stated.

There is a slight difference between MSL (National Geodetic Vertical Datum of 1929) which the SER refers to and Lake Survey Datum at

Oswego, N.Y.

The SER is acceptable as written.

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I Additional information is needed from applicant before any changes can be agreed

upon, and any potential changes in staff conclusions should be resolved prior to initial criticality.

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11a. Acceptable minor change.

~ fZAs lib. Acceptable minor change.

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11c. Acceptable minor change.

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>'2.

The information contained in the NMP-2 SER relative to site stratigraphy was obtained from geologic cross sections, bedrock elevation maps and other site specific information contained in FSAR Section 2.4 and 2.5.

The FSAR sections referred to in the applicant's comment refer to average properties of the overburden and rock in the site area.

Therefore, there is no contradiction between the FSAR and the SER in regard to this issue.

The SER is correct as written.

18.

33.

37.

Section 9.5.4.1 of the SER identified the need for the applicant to provide additional information concerning the details of the 1-inch',vent line between the diesel fuel storage tank and the day tank.

This information was provided by the applicant in Amendment 20 to the FSAR.

As documented in Supplemental SER number 2, this information was reviewed and found acceptable in that there is an acceptable means to vent and fuel oil storage tank in the event that the normal vent line is damaged by a tornado generated missile.

Since the facili-ties identified in the alternative method are protected from tornado generated

missiles, Section -3.5.2 -of the SER is correct in stating that "All other safety-related systems and components and stored fuel are located within tornado-generated-missile-protected structures or are provided with barriers against tornado-generated missiles."

The SER is correct as written.

See comnent 2 SER is correct as written since Amendment P5 was issued after SER was pub-lished.

+ditional changes to Table 6.1-3 on unqualified coatings inside containment>u+~

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38. Acceptable for clarification.

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40.

Acceptable for clarification.

Acceptable for clarification.

was made after SER was issued.

is change

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41. Acceptable for clarification.

was made after SER was issued PE Yi'his change 42.

43.

44.

Acceptable for clarification.

was made after SER was issued.

Acceptable - editorial change.

Acceptable for clarification.

was made after SER was issued.

This change 78'aic uh r ada,we~~seg

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46.

51.

Acceptable; see'comment 46.

47.

48. Acceptable editorial comment.

49.

50.

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52. Acceptable editorial change.

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57. Acceptable for clarification.

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88. The applicant's reference to FSAR page 9.1-15a on high energy pipe breaks does not support the requested word changing.

Furthermore, there is no wording or the results of any analysis which could be found in Section 9.1.3 of the FSAR which could support the requested word change.

Based n the lack of support information, we conclude that the SER, as written, ma e correct and should remain unchanged at this time.

This is an open item since the differences in staff and applicants conclusions involve an important safety issue.

Acceptable for clarification.'hange was made after SER was issued.

Changes were made in SSER-2 except for reactor building inleakage which was increased from 3160 ft~/min to 3190 ft3/min.

This increase was due to an increase in reactor building volume from 4,547,204 ft3 to 4,593,600 ft3 to reflect the as-built plant configuration.

Therefore, it is acceptable.

The increased 3190 ft3/min inleakage is included in the final Technical Specifica-tion.

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r Carr'cceptable for clarification.

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Acceptable for clarification.

Wr KWMC ~re revel.

SSER-3 addresses this comnent except for the inclusion of She main steam system as conforming to the 10 CFR 50, Appendix J, Type A test criteria.

This is acceptable since the main steam lines are flooded during of Type A testin and cannot be vented to the primary containment.

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89.

I The SER was prepared prior to receipt of Amendment 19 to the FSAR.

In Amend-ment 19 the applicant changed the results of their analysis of the heat.rejec-tion capability of the spent fuel pool cooling system.

The SER cannot be change without. the applicant providing a complete refueling schedule and data for the staff to perform a revised evaluation.

If the numbers specified in the SER do not pose any undue burden to the'; applicant, the most expedient solution is for h

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90. The SER states:

"No connectionsi are provided to the spent fuel pool below the normal water level that may cause the pool to be drained and, therefore, the fuel would not be uncovered should these lines fail."

The applicant has requested that this sentence end< with"... below the normal water level of the fuel." If our SER is not correct, then the applicant does not meet the re-quirements of General Design Criterion 44, "Cooling Water " and this, then, is an open item.

The applicant's reference to FSAR Page 9.1-7 does not support the requested change.

Furthermore, the sentence that was proposed makes little or no sense.

Based on the above~,

we conclude that the SER, as written, should remain unchanged, and the applicant should confirm that they.do not meet the hi t

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44.

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98. Acceptable.

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99. The applicant proposed an acceptable minor change that does not affect meeting th id 4

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101. The applicant's coment to revise the wording from "nonseismic Category I" to simply "nonseismic" is a meanin 9ess coment.

From the Staff's point of view, either the component is "seismic( Category I" or it is "nonseismic Category I".

There are no categories of "seismic" and "nonseismic".

The SER, as written, is correct and should not be modified. ~,/( ~ rev

106. This coment is acceptable.

The'ER I

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91. Acceptable minor detail changes applicant made after SER was published.

Me azure 94a.

~y// Qw wwci 94b. Acceptable.

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95. Acceptable.

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96. The safety-related portions of the reactor building closed-loop cooling water (RBCLCW) system are quality class B.

The mon-safety-related portions are not specifically addressed in the SER.

Only the safety-related portions are required to met the requirements, of General Design Criterion 2 and the guide-lines on Regulatory Guide 1.29.,'hus, we conclude that the

SER, as written, is.

correct and should not be revised.

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107. This comment is rejected on the basis that the staff could not find the comnit-ment in the reference given.

This is an open item 108. This covalent is acceptable.

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109. This comment is acceptable in principle except the SER change will drop any reference to illumination level and state instead that the operator must have sufficient light to see, to perform the necessary emergency functions. ~

. *110. This comment is acceptable.

The proper references are FSAR pages 9.2-28 8 29, and figure 1.2-29.

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111. This covalent is acceptable.

7me 114."The applicant requested that our SER be revised to reflect a lower storage capacity for the seven day fuel oil storage tanks.

The SER states that the capacity of these tanks for diesel generators I 5 II are 53,150 and 46,850 gallons, respectively.

The applicant desires these values to be revised to 52,664 and 36,173 gallons, respectively.

Based on the information provided by

'the applicant in Amendment 25 to the FSAR, the required capacity for the seven day storage tank would be 68,712 and 47,376 gallons, respectively.

These figures are derived from the one hour fuel consumptions provided in th'e FSAR.

Based on the manufactures data for Division III diesel generator, the seven day storage tank would need a capacity of 45,360 gallons.

Furthermore, the fuel consumption rate for the Division III diesel generator stated in the FSAR, as amended by Amendment 25, is only 75K of the fuel consupmtion rate specified by the manufacturer.

The applicant must provide justification for not using

.the'anufacturer's fuel consumption rates, for requesting approval for storage of less than the currently acceptable amounts of fuel oil, and for reconciliation of the specified fuel consumption rates specified in Amendment 25 and the one hour fuel operating consumption.

Me note that all of the above information is based'on the same assumptions as was the applicant's analysis and specified in the FSAR.

Based on the inconsistences and the unsupportable assertions made by the applicant, we conclude Chat the

SER, as written, may be'correct and must not be changed without adequate justification and information from the applicant.

This is an open item 118. Acceptable.

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2 122. Acceptable.

This change has already been incorporated in SSER No. 3 issued in July 1986.

123a.

Rejected.

Since the staff's evaluation was based on the use of all process equipment available at NAP-2 Liquid Radwaste System.

The applicant may bypass certain equipment if radioactivity and/or impurities in the streams are suffi-"

ently low to meet Appendix I "ALARA" criteria and Technical Specification.

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t system to meet the ALARA intent of Appendix I to 10 CFR 50.

123b.

The staff's system description (not evaluation) includes only normal process pathways (not all possible and conceivable pathways).

No change in the SER is considered necessary.

123c, The 'staff's numbers are more conservative based on the applicant's original dIme data and information provided to NRC.

No SER change required.

124. Acceptable.

Revised SER page 11-5 225.2 tty ptht.

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126. Acceptable.

127. Accepted for clarification.

128. Rejected.

Wordings are consistent is attached.

A'nformationFSAR Amendment No. 26.

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rZire with NUREG-0737, Item II.F.1, Attachment 1

129. Rejected.

~ Table 11-2 on SER page 11-4 is the staff's independently calculated values and need not be consistent with applicant's calculated values.

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130.

Acce ted.

Based on informationW FSAR Amendment Ko. 23. ~~.

131.

132.

133.

134.

135.

In Section 12'of the SER all references to Reg.

Guide 8.8, Revision 3, are correct since, in our evaluation we compared the applicant's FSAR against Revisions 3.

Please note that Revision 4 has not yet been issued in its final form.

As its heading states, Table 12.3-1 (AMD 24) represents "Area Radiation Monitor Locations."

There are 58 locations at NMP-2 which are monitored.

There are two high range area monitors at each7of the four locations in the drywell to cover the full desired range of 1-10 R/hr.

(2 RMS*RElA(-G); 2 RMS*RE18(-Y); 2 RMS*RElC(-G); and 2 RMS*REID(-Y).

The sentence in the SER &&be revised Q4 indicatet got:uH~

W~ill The first sentence (on page 12-9) which states "Currently, operating BWR's average 848 person-rems per unit annually, with particular plants experiencing an average lifetime annual dose as high as 1850 person-rem."

The 848 person-rem dose is an NRC computed value based on average reported annual plant personnel exposures at the time of writing the SER. It is not based on the NMP-2 FSAR, and no SER change is required.

First paragraph on page 12-1 has only one sentence and has nothing in common with Section 12.5-2 nor a list of calibration facilities.

In reference to Section 12.5.2, on page 12-10, which we assumed was the intended reference, we are aware of the fact that the calibration facilities are located at nearby NMP-1 and will be used jointly for both Unit 1 and Unit 2.

FSAR, Section 12.5.3.3.7, first sentence states that:

"Plant employees, con-

tractors, and visitors are required to wear film badge, a TLD, and a personal dosimeter when in the restricted area, in accordance with 10 CFR 20."

There-fore, based on the FSAR, all three are required; a film badge is not a substi-tute for the other two personal monitors.

The applicant apparently understands differently, and the issue 143. Acceptable.

148. Acceptable.

149. Acceptable.

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136. Applicant's coments is noted,

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