ML17059B415
| ML17059B415 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/28/1997 |
| From: | Hood D NRC (Affiliation Not Assigned) |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| TAC-M96649, NUDOCS 9701310330 | |
| Download: ML17059B415 (12) | |
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Hr.
B. Ralph Sylvia Ej,ecutive Vice PresideOGeneration,Business,'
~ Group and Chief Nucl ear, Officer, Niagara Mohawk Power Corporation
'uclear Learning Center 450 Lake Road
- Oswego, NY 13126
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION REGARDING SURVEILLANCE PERFORMED DURING THE REFUELING OUTAGE, NINE,MILE POINT NUCLEAR STATION UNIT NO.
1 (TAC NO. H96649)
Dear Hr. Sylvia:
Your response to the enclosure is requested as soon as possible to support your current outage schedule.
If you have questions regarding, the enclosure or are unable to meet the requested response
- date, please call me at (301) 415-3049, or e-mail me at dshenrc.gov.
Sincerely,
/s/
Darl S.
Hood, Senior Project Manager Project Directorate I-l Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosure:
Request for Additional Information cc w/encl:
See next page DISTR IBUTION:
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DOCUMENT NAME: G: iNMPliNH196649. RAI n
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'IC" ='opy without attachment enclosure "E" = Co'th'ttachment enclosure',',
"N" = No co The NRC staff is reviewing your submittal of September 20, 1996, regarding the proposed technical specification change to various surveillances performed during a refueling outage.
We find that additional information is necessary to complete our review.
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t UNITED STATES t NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 201~01 January 28, 1997 Hr. B. Ralph Sylvia Executive Vice President Generation Business Group and Chief Nuclear Officer Niagara Hohawk Power Corporation Nuclear Learning Center 450 Lake Road
- Oswego, NY 13126
SUBJECT:
REQUEST FOR ADDITIONAL INFORHATION REGARDING SURVEILLANCE PERFORHED DURING THE REFUELING OUTAGE, NINE HILE POINT NUCLEAR STATION UNIT NO; 1
(TAC NO. H96649)
Dear Hr. Sylvia:
The NRC staff is reviewing your submittal of September 20, 1996, regarding the proposed technical specification change to various surveillances performed during a refueling outage.
We find that additional information is necessary to complete our review.
Your response to the enclosure is requested as soon as possible to support your current outage schedule.
If you have questions regarding the enclosure or are unable to meet the requested response
- date, please call me at (301) 415-3049, or e-mail me at dshenrc.gov.
Sincerely, D~>lk-Docket No. 50-220 Darl S.
Hood, Senior Project Hanager Project Directorate I-1 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl:
See next page
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B. Ralph Sylvia Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Unit No.
1 CC:
Hr. Richard B. Abbott Vice President and General Hanager-Nuclear Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Hr. Hartin J. McCormick, Jr.
Vice President Nuclear Safety Assessment and Support Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Ms. Denise J. Wolniak Manager Licensing Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Mr. Kim A. Dahlberg General Manager - Projects Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Hr. Norman L. Rademacher Plant Manager, Unit 1
Nine Mile Point Nuclear Station P.O.
Box 63
- Lycoming, NY 13093 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector.,
U.S. Nuclear Regulatory Commission P.O.
Box 126
- Lycoming, NY 13093 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Hr. Paul D.
Eddy State of New York Department of Public Service Power Division, System Operations 3 Empire State Plaza
- Albany, NY 12223 Hr.
F. William Valentino, President-New York State
- Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension
- Albany, NY 12203-6399 Hark J. Wetterhahn, Esquire Winston 5 Strawn 1400 L Street, NW Washington, DC 20005-3502 Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, NY 13202 Supervisor Town of Scriba Route 8, Box 382
- Oswego, NY 13126
R VEST FOR ADDITIONAL INFORMATION R GARDING SURVEILLANCES PERFORMED DURING REFUELING OU AGES N NE MILE POINT NUC EAR STATION UNIT NO.
1 DOCKET NO. 50-220 In your September 20, 1996, letter you propose that various surveillance requirement intervals be changed to "once per operating cycle."
Technical Specification (TS) 4.0. 1, "Surveillance Intervals," states that "Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval."
- However, the definition of an operating cycle as stated in TS Section 1.9 is "that portion of Station operation between reactor startups following each major refueling outage."
No nominal frequency is provided in the definition of an operating cycle.
The use of administrative controls to ensure that the interval between surveillance testing does not exceed a
maximum period of 30 months is not an acceptable resolution of the ambiguity the change would add to your Technical. Specifications.
Please revise your proposed changes to clearly indicate:
(a) The specific frequency/interval of an "operating cycle" (b)
How TS 4.0. 1 is to be applied to surveillance intervals performed "once per operating cycle" if a specific frequency interval is not included in the definition of an operating cycle.
Our records do not indicate when or how Nine Mile Point Unit 1 converted to a 24-month fuel cycle.
Was the 24-month fuel cycle and the associated increase in refueling outage surveillance intervals implemented by a TS amendment or under 10 CFR 50.59?
When was this accomplished?
In addition, was the guidance in Generic Letter 91-04, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2,
- 1991, used when evaluating an increase in the refueling outage surveillance intervals to 24 months?
Please discuss the evaluations you performed upon converting to a 24-month fuel cycle to show that the net effect on safety of increased refueling outage surveillance intervals to 24 months was small and that the assumptions in the plant licensing basis remain valid on the basis of performing refueling outage surveillances at 24 months (maximum of.30 months when including 25X extension).
Please provide the original bases and/or safety evaluation used to support a 24-month refueling outage surveillance interval for a sample of the surveillances described in
'our September 20, 1996, submittal.
Enclosure
Describe or provide the instrument drift analysis completed to support an increase in refueling outage instrumentation channel tests and channel calibrations to 24 months.
The description should indicate whether and how the effects of an increased calibration interval on instrument errors were evaluated to confirm that drift would not result in instrument errors that exceed the assumptions of the safety analysis.
For the instrumentation specified in your September 20, 1996, submittal that have refueling outage channel calibration surveillance intervals, are the associated instrumentation setpoint calculations based on a 24-
'onth drift term?
Are the setpoint calculations based on the setpoint methodology described in ISA 67.04 and Regulatory Guide 1. 105?
The proposed
- changes, with regard to the Surveillance Requirements for vacuum breakers in Section 4.3.6 of the Nine Nile Point Unit I TS, are a
relaxation of the existing TS that deviates even further from the currently acceptable testing requirements of the new Standard TS (STS).
For example, Section 3.6. 1.8 of the new BWR4 STS, "Suppression Chamber-to-Drywell Vacuum Breakers," requires a functional test of each required vacuum breaker every 31 days
~ND within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after any discharge of steam to the suppression chamber from the S/RVs AND within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following an operation that causes any of the vacuum breaker to open.
Also, Section 3.6. 1.7, "Reactor Building-to-Suppression Chamber Vacuum Breakers,"
requires a functional test of each vacuum breaker every 92 days.
(The new BWR4 STS is used as an example because the safety functions of the vacuum breakers in question are very similar).
These examples are considerably more stringent than what is currently in Section 4.3.6 of the Nine Nile Point Unit I TS.
In view of these differences, please provide further justification of your proposed changes.
Parameters I, 3, and 5 of TS Table 4.6.2b currently specify instrument channel test and channel calibration surveillance intervals of once per 3 months.
- However, parameters 6, 7, 8, and 9 currently specify instrument channel test and channel calibration surveillance intervals of once per major refueling outage.
It would appear that the channel test and channel calibration surveillance intervals can be performed quarterly.
Therefore, please justify the refueling outage channel test and channel calibration surveillance intervals for parameters 6, 7, 8, and 9.
For the category 2 and 4 surveillances, you state that evaluations have been performed for the associated surveillance intervals and it has been determined that these surveillances may be safely performed while at power.
For these surveillances, please describe the evaluations that were performed and their results.
t
The footnotes on pages 204 and 233 and the bases on page 253 of the marked-up version of the proposed TS changes state that the mode switch surveillance may be performed "as part of the plant shutdown sequence prior to a maintenance
- outage, forced shutdown, or refueling outage."
The terms "plant shutdown sequence",
"forced shutdown" and "maintenance outage" are not defined in the TS, are general, and do not adequately indicate when in a sequence of actions the mode switch surveillance is to be performed.
Please clarify the mode switch surveillance.
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