ML17059A271

Summary of 940414 Meeting W/Util in Rockville,Md Re Status of Current Licensing Issues at Plant.Attendees Listed in Encl 1

ML17059A271
Person / Time
Site:	Nine Mile Point
Issue date:	04/20/1994
From:	Menning J Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 9404270077
Download: ML17059A271 (44)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 20, 1994 Docket Nos.

50-220 and 50-410 LICENSEE:

Niagara Mohawk Power Corporation FACILITY:

Nine Mile Point Nuclear Station, Unit Nos.

1 and 2

SUMMARY

OF APRIL 14,

1994, MEETING TO DISCUSS STATUS OF CURRENT LICENSING ISSUES FOR NINE MILE POINT NUCLEAR STATION, UNIT NOS.

1 AND 2 A meeting was held in the NRC One White Flint North Office in Rockville, Maryland, with Niagara Mohawk Power Corporation (NHPC) and NRC staff representatives to discuss the status of current licensing issues for Nine Mile Point Units 1 and 2.

The licensee had requested this meeting.

Enclosure 1 is a list of meeting attendees.

Enclosure 2 is a copy of the handout material provided by NHPC.

K ~

NHPC initially discussed their Regulatory Reduction Program.

This effort is being implemented within NHPC's Nuclear Division to identify, assess, and eliminate or reduce regulatory requirements which provide little or no safety benefit but incur significant costs.

The program will ultimately result in the identification of cost beneficial licensing actions (CBLAs).

The various groups within the Nuclear Division are now in the process of identifying potential CBLAs.

NHPC anticipates that their prioritization of these potential CBLAs will be completed by the end of July 1994.

The open licensing issues for Unit 1 and NHPC's plans for near-term license amendment requests for that unit were subsequently discussed.

The licensee currently anticipates submitting seven new license amendment requests for Unit 1 by June 30, 1994.

Five of these planned Unit 1 license amendment requests are either required or desired for the 1995 Unit i refueiing outage lit,FKECM Bi-Qgo NHPC subsequently updated the staff on the status of their program to "right size" the Unit 2 Updated Safety Analysis Report (USAR).

The Unit 2 USAR has grown to more than 12,500 pages contained in 32 volumes as a result of 28 amendments and 6 update revisions.

The right size program was 'developed to improve access to information in the USAR by identifying and dispositioning similar, identical, poorly organized, inapplicable, or inappropriate information and formatting and reflowing text, tables, and figures to eliminate blank and partial pages.

USAR right-sizing began with USAR Revision 4, dated October 1992 and continued in USAR Revision 5, dated October 1994.

NHPC advised the staff during the meeting that an administrative revision to reflow various USAR sections i's scheduled to be issued in April 1994.

This administrative revision will not reflect changes to the facility, procedures,

tests, or experiments.

April 20, 1994 that is scheduled to begin in February 1995.

The attendees also discussed the open licensing issues. for Unit 2 and NHPC's plans for near-term license amendment requests for that unit.

Two new Unit 2 license amendment requests are scheduled for submittal to the NRC by June 30, 1994.

NHPC is also developing five Unit 2 license amendment requests that are desired for the 1995 Unit 2 refueling outage and will be submitted to the NRC subsequent to June;30, 1994.

The 1995 Unit 2 refueling outage is currently scheduled to begin in Hay 1995.

Enclosures:

1.

List of Attendees 2.

Licensee Handout Haterial John E. Henning, Project Hanager Project Directorate I Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation cc w(enclosures:

See next page

April 20, 1994 that is scheduled to begin in February 1995.

The attendees also discussed the open licensing issues for Unit 2 and NHPC's plans for near-'term license amendment requests for that unit.

Two new Unit 2 licensee amendment requests are scheduled for submittal to the NRC by June 30, 1994.

NHPC is also developing five Unit 2 license amendment requests that are desired for the 1995 Unit 2 refueling outage and will be submitted to the NRC subsequent to June 30, 1994.

The 1995 Unit 2 refueling outage is currently scheduled to begin in Hay 1995.

Enclosures:

1.

List of Attendees 2.

Licensee Handout Material cc w/enclosures:

See next page

• Licensee's Handout Material Distribution:

• Docket File

• NRC & Local PDRs

• PDI-1 Reading WRussell/FHiraglia, 12/G/18

LReyes, 12/G/18 S.

Varga J.

Calvo R. A. Capra Original signed by:

John E. Henning, Project Manager Project Directorate I-l Division of Reactor Projects I/II Office of Nuclear Reactor Regulation

• J. Henning

• D. Brinkman C. Vogan OGC E. Jordan, HNBB 3701 ACRS (10)

V. HcCree,

EDO, 17/G/21

• C. Cowgill, RGN-I LA:PDI-CVo an n 94 PH:PDI-1 JMennin m

'i 19 94 PH: PDI-1 DBrink an

'I Ig 94 D'PDI-1 RACa ra go 94 OFFICIAL RECORD COPY FILENAME: NH50220.HTS

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Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Unit Nos.

1 and 2

CC:

Hark J. Wetterhahn, Esquire Winston

& Strawn 1400 L Street, NW Washington, DC 20005-3502 Supervisor Town of Scriba Route 8, Box 382

Oswego, New York 13126 Hr. Louis F': Storz ""

Vice President Nuclear Generation

'Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.

Box-63

Lycoming, New York 13093 Resident Inspector U. S. Nuclear Regulatory Commission P.O.

Box 126

Lycoming, New York 13093 Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West

Syracuse, New York 13202 Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Ms. Donna Ross New York State Energy Office 2 Empire State Plaza 16th Floor

Albany, New York 12223 Mr. B. Ralph Sylvia Executive Vice. President, Nuclear Niagara Mohawk Power Corporation Nine Mile Point.:Nuclear Station P.O.

Box 63

Lycoming, New York 13093 Hr. Richard B. Abbott Unit 1 Plant Manager Nine Mile Point Nuclear Station P.O.

Box 63

Lycoming, New York 13093 Mr. John H. Hueller Plant Manager, Unit 2 Nine Mi.le Point Nuclear Station P'.O.

Box 63

Lycoming, New York 13093 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, New York 10271 Hr. Paul D. Eddy State of New York Department of Public Service Power Division, System Operations 3 Empire State Plaza

Albany, New York 12223 Mr. David K. Greene Manager Licensing Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.

Box 63

Lycoming, New York 13093 Hr. Richard Goldsmith Syracuse Universi ty, College of Law E. I. White Hall Campus

Syracuse, New York 12223 Hr. Richard H. Kessel Chair and Executive Director State Consumer Protection Board 99 Washington Avenue

Albany, New York 12210 Hr. Hartin J. HcCormick, Jr.

Vice President Nuclear Safety Assessment and Support Niagara Hohawk Power Corporation Nine Mile Point Nuclear Station P.O, Box 6X

Lycoming, New York 13093

ENCLOSURE 1

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1 il 14 99 Status of ce s

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'onald., Brinkman John Menning David Greene Denise Wolniak John Laffrey Al Reyna David'aker'---

Position-s "

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Sr. Project Hanager Project Man'ager Licensing Manager Supervisor Licensing Support FSAR Program Director Licensing Engineer Program Director

O gati O NRC/NRR/PDI-1 NRC/NRR/PDI-1'HPC NHPC NHPC NHPC NHPC

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Nuclear SBU Business Plan item 3.D.l A division effort to identify, assess and eliminate or reduce regulatory requirements which provide little or no safety benefit but incur significant implementation costs.

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IDENTIFYPOTENTIAL COST BENEFICIAL LICENSING ACTIONS (CBLAs)

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ASSESS AI'6) PRIORITIZE CBLAs J

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PROCESS HIGH PRIORITY CBLAs

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DOCUMENT AND COMMUi%CATEPROG$JAf RESULTS

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. IDENTIFYPOTENTIAL CBL4s.

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PROVIDE SOURCE DOCUMENTS FOR POTENTIAL CBLAs

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DEVELOP CBLAINPUT FORM I

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IDENTIFYPOTENTIAL-CBLAs INCLUDINGCOST SAVINGS AND POTENTIALBARRIERS (DEPARTMENTAL"BARNSTORMING")

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S COST BENEFICIAL ICENSING ACTION

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Unit Branch TITLE DESCRIFHON R ~

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'OURC OS COMRUIMIUMIRROUI Ml ttGR,, G, SS, S II<<l III,II Reg Guide, Code, Standard, etc.)

JUSHFICATION BARRIERS CHANGE TS or License Chango

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Exemption Safety Bvaluation 5089 Screening Document Rclicf Requcat WS RESPONSIBLE INDIVIDUAL (TECHNICAL)

IUCIKNSION LICENSING CONTACT CLOSURE REFERIWCES To be completed by Licensing CBLANO.

IMPLEMENTED DATE YES NO

CBLASAVINGS SUlHlKARY A. MATERIALS (Value ofmaterials saved per occurrence) x (Number ofoccurrences for remaining life ofplant)

Total Materials Savings $

B. PERSON HOURS (Number ofperson-hours saved pcr occurrence) x (Number ofoccurrences for remaining life ofplant) x (Present average value of a person-hour) $

'Total Person-Hour Savings $

Y ~c> $(1tj C. OUTAGE DAYS (Number ofoutage days saved per occurrence) x (Number ofoccurrences for retnauung life ofplant) x (Present cost ofan outage day -not including replacement power)$

Total Outage Days Savings $

D. E TllHATEDC ST FPR IN BLA Yo be complated by Li~~S (Estimated utilitycosts) $

costs) $

+ (NRC review Total Processing Costs $

NET BLASAVING A+B+C-D~

Net CBLASavings S CELA NO.

TR RED TI PR RAM.

ASSESS AND PRlORlTIZE, CBLAs

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DEVELOP PRIORITIZATION(VALUElIMPACT):

CRITERIA

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COMPLETE: VALUEIMPACT ANALYSIS:FOR POTENTIAL'BLAsAND PRIORITIZE

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SELECT HIGH PRIORITY CBLAs FOR PROCESSING Al'6) OBTAINBRANCH BUYIN

CB NO.

DATE BLA PRI RITIZATI BEET CBLA DESCRIPI'ION

~ P CRITERIA WEIGHT VALUE 0

1 3

5 NET COST SAVINGS (1994 $S)

None Low benefit $ < 100K Medium benefit $) 100K< $500K High benefit ) $500K 30%

0 1

3 5

FUEL COST DIFFERENTIALSAVINGS (I994 SSl None Low benefit <$ 100K Medium benefit >$ 100K <$500K High benefit > $500K 30%

0 1

3 5

EARLYCBLA SUCCESS Approval >24 months Approval ) 12 months <24 months Approval >3 months < 12 months Approval <3, months 20%

0 1

3 5

None Low benefit < 1 man-rem Medium benefit > 1 <5 man-rem High benefit >5 man-rem 10%

0 1

3 5

PERSONNEL PRODUCTIVITY(LABOR SAVINGS)

None Low benefit <200 man-hours/year Medium benefit ) 200 man-hours/year < 1000 man-hours/year High benefit ) 1000 man-hours/year 10%

TOTALPRIORlTY RATING=

(Scale of 0-5)

RE AT RY RED TI PR

PROCESS HIGHPMORITY CBLAs 0

2 Wpl IDENTIFYCHANGE MECHAICSMS DETE CHANGE MECHAIASMFOR HIGH PRIORITY CBLAs COMPLETE NECESSARY JUSTIFICATION FOR HIGH PRIORITY CBLAs

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DISCUSS ITEMS REQUIRING SUBMITTALWITH NRC PRIOR TO SUBMITTALTO;ASSURE PROPER PRIORITIZATION

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DIMFT CHANGE PAPERWORK AND OBTAINNMPC APPROVALS I

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COMPLETE DOCUMENTATIQNPACKAGE FOR:

COMPLETED CBLAs 2

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NMP2 USAR RIGHT SIRING PLAN OVERVIEW 1 ~

PURPOSE GOAL OBJECTIVES PUR OS To ensure that'he information contained in the USAR is

accurate, complete, and organized in a format that provides easy access.

V Revise the USAR to provide clear and concise presentations of applicable and appropriate information.

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D.

Identify and disposition similar or identical (redundant) information.

Identify and disposition disorganized information.

Identify and disposition inapplicable or inappropriate information.

Format and reflow text, tables, and figures to eliminate blank and partial pages.

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GRO Over the course of twenty-eight (28) amendments and six (6) update revisions, the UNIT 2 USAR has grown to more than 12,500 pages.

Contained in thirty-two (32) volumes, the Nine Mile Point Unit 2 Updated Safety Analysis Report is perhaps the largest USAR in the nuclear industry.

A review of the USAR has identified several factors which collectively contribute to its unique:size.

These factors are as follows:

A SZMZLAR OR ZDESTZCAL QiPORMATZON~

Duplication of information has been identified in various text, table and figure sections of the USAR.

Examples of similar or-identical information contained in the USAR include the following:

~ I 1.

Twenty-eight (28) of the general arrangement

'drawings found in USAR Section 1.'2-are"also-presented in Section 12.3 as radiation zone drawings and as shielding drawings.

2.

Forty-nine (49) isolation valve arrangement drawings contained in Section 6.2 present identical information to that shown on USAR PAID figures.

3 ~

Figures 1.1-1, 5.1-1a and 10.1-2 are heat balance diagrams.

Figure 5.1-1a is specifically recpxested by, Regulatory Guide 1.70, and Figure 10.1-2 shows the balance of plant.

However, Figure 1.1-1 provides the same information as shown on Figure 5'-1a.

4.

Table IIZ.D.3.4-1 (page 1.10-133) is redundant to Table 2.2-8.

5.

Figure 3.9B-1 is similar to Figure 5.3-4.

6.

Figure 6.4-1 is identical to Figure 11.3-2.

7.

Figure 8.3-9 Sheet 1 is similar to Figure 1.2-15 Sheet 3, except that Figure 1.2-15 Sheet 3 daes not show the area between AA and AB line.

8.

Figure 8.3-9 Sheet 2 is identical to Figure 1.2-17 Sheet 1.

9.

Figures 9.2-10, 9.2-11; 9.2-12 and 9.2-14 are redundant to Figure 1.2-29 Sheets 1,

2 and 3, and Figure 1.2-30.

10'igures 9.5-49, 9.5-50 and 9.5-51 are similar to Figures 1.2-17 and 1.2-18.

11.

Figure 15.0-2 is similar to Figure 4.4-1.

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Figure 6A.6-1 is redundant to Figure 1.2-12.

13.

Figure 6A.6-3 is redundant to Figure 3.8-14.

14.

Figure 6A.6-4 Sheet 2 is redundant to Figure 3.8-20.

15.

Figures 6A.5-6 and 6A.6-6 are identical.

16.

Figures 6A.5-7 and 6A.6-7 are identical.

17.

Figure 6A.7-1 is redundant to Figure 3.8-2.

18 HOTB!

Table 9.5-2 material is redundant to information presented in Section 9.5.3.1 and 9.5.3.2.

The above list of items reflects only a portion of.

duplicated material contained in the USAR.

B.

USAR ORGAHZSATIOH/PORMAT Several tables in the USAR are organized or formatted such that they occupy more space than necessary.

An estimated 300 pages could be eliminated by presenting certain tables in a more appropriate, space-saving format.

USAR Table 1.8, "Conformance to NRC Regulatory Guides,"

is one example.

This table is presented on 184 pages.

However, the majority of these pages contain information only on, the top one-quarter to one-half of the page.

Presenting the information on a consolidated landscaped format would eliminate approximately 100 pages.

C IHAPPLICABLB OR ZHAPPROPRIATB IHPORMATZOH USAR COHTBHT Using. the guidance provided by Generic Letter 81-06, nuclear utilities have updated their FSARs in accordance with Section 50.71 of 10 CFR Part 50.

In doing so, most utilities not only updated, but also edited and republished their FSARs as new and unique documents.

This results in a single, complete. document that serves as the baseline for future changes while preserving the original FSAR (as amended),

which is still considered to be the licensing basis for the plant.

Rather than edit and republish the USAR as a unique

document, Niagara Mohawk requested and received fr'om the'-"

NRC an exemption which allowed the initial update to be processed on a replacement page basis similar to the FSAR amendment process.

Although this alternative appeared to provide cost-saving benefits, there are no real cost-saving benefits associated with maintaining an oversized 12,500-page USAR.

D.

BLASE MD PARTIAL PAGES The Unit 2 USAR contains over 600 blank pages and over 2,000 partially filled pages.

Other utilities eliminated blank and partial pages by reflowing the document during the initial update.

Reflowing the Unit 2 USAR would eliminate approximately 1,200 pages.

3 ~

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0 ODOLOG The Unit 2 USAR will be reviewed and evaluated against the guidance contained in Regulatory Guide 1.70, Revision.

3, the information contained in NUREG-0800, and NUREG-1047, Supplements 1 through 6 inclusive.

USAR right-sizing began with USAR Revision 4, dated October 1992 and continued in USAR Revision 5, dated October 1993.

These revisions, as described in NMPC submittals to the NRC, included the removal of redundant information and moved other information to more appropriate locations.

Additional redundant, inappropriate and/or inapplicable information is currently being evaluated for removal in a future USAR revision.

I The reflow of USAR sections to consolidate information will be. accomplished as administrative revisions or will be included with annual revisions.

Administrative revisions will not reflect changes to the facility, "

procedures, tests or experiments.

An administrative revision to reflow various USAR sections is scheduled for April 1994.

11

5.

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The Right-Sized USAR will contain clear,

concise, applicable and appropriate information consistent with Regulatory Guide 1.70 Revision 3, NUREG-0800, NUREG-1047, and 10 CFR 50.71(e).-

Examples of redundant, inapplicable and inappropriate material identified during the plans'evelopment help convey the purpose and goal of Unit 2 USAR right-sizing.

These examples indicate that a significant reduction in USAR volume will be achieved by providing a clear, concise presentation of appropriate material.

EXAMPLES Ot USAR RIGHT-SIBZHQ RESULTS REORQAHISED ZHPORMATZOH USAR Revision 5, 1993, incorporated the Fire Protection {}ualityAssurance Program (FPQAP) into the NMPC {}ualityAssurance Topical Report (QATR) and incorporated the QATR into USAR Appendix B.

REMOVAL OP ZHAPPLZCABLE/ZHAPPROPRIATE IHPORMATIOH

= USAR Revision 5,

1993, removed Appendix 13A, Typical Resumes.

(64 plus, pages)

FORMAT AHD REPLY (USAR Revision 6, April 1994)

USAR Section 1.10 (Unit 2 Responses to Regulatory Issues Resulting from 'TMI) was 254 pages.

Formatted and reflowed to 157 pages.

USAR Table 1.8-1 (Conformance to NRC Regulatory Guides) was 184 pages.

Formatted and reflowed to 81 pages in USAR Rev 5.

Formatted and reflowed to 78 pages in Revision 6.

USAR Table 1.9-1 and Attachments (Standard Review Plan Conformance to Acceptance Criteria) was 112 pages.

Formatted and reflowed to 53 pages.

USAR Table 9B.8-1 (List of Safe Shutdown Equipment) was 83 pages.

Formatted and reflowed to 40 pages.

j

NO.

ITEM 1

Shutdown Cooling Water Seal SUBMITTALSTO BE COMPLETED BY 6/30/94 X

STATUS/COMMENTS Drafting, required for outage.

Revise Flow Comparator Quarterly Surveillance to Refuel IRM Range 10/Calibration from Startup to 24 Months 4-hr Allowance for Manual Isolation Valves/And Add Note Delete Hot Shutdown Requirements for Hydrostatic Testing Above 200'F or Relocate PT Curves 6

Reduce No. of SRVs X

X X

In engineering, awaiting justification for changing analytical limit. Best date for engineering input is 6/94.

Drafted, desired for outage.

Relocation of PT curves, engineering analysis is being scoped.

Desired for outage.

Drafted, desired for outage.

7 Eliminate APRMs in refuel X

Scoping amendment, desired for outage.

Reduce head bolt torquing requirements Awaiting analysis from engineering.

Moved to '97 Outage.

Liquid Poison Minimum Volume Limit 10 Remote Shutdown Panels AOT X

In Final Review, resolving CDT's comments.

UNIT2 NO ITEM SUBMITTALSTO BE COMPLETED BY 6/30/94 STATUS/COMMEYIS 1

Drawdown X

Ready for signature Eliminate excess fiow check valves with restricting orifice 3

Removal of MSL Rad Monitor X

Investigating justification, desired for outage.

Preparing for SRAB 4.

H>Q'Accident Monitoring/1.97 Drafting; Improved Tech. Spec. Item Revise clear &bright, level, AOT and 31 day sample fuel oil 6

Increased Allowable MSIV Leakage 7

Revise Type A to 1 in 10 years Submit mid-1994, Lead plant submittal approved.

Desired for outage.

8 Revise ADS test pressure Drafting, desired for outage Revise 24-hour EDG test to perform on-line 10 Revise definition of core alteration.

System Engineering investigating, desired for outage Outage desire

4 J'