ML17059C669
| ML17059C669 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/18/1999 |
| From: | Hood D NRC (Affiliation Not Assigned) |
| To: | Mueller J NIAGARA MOHAWK POWER CORP. |
| References | |
| TAC-MA3822, NUDOCS 9905250209 | |
| Download: ML17059C669 (18) | |
Text
Mr. John H. Mueller Chief Nuclear Officer Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Operations Building, Second Floor P.O. Box 63 Lycoming, NY 13093 Nay 18, 1999
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION REGARDING SECTIONS 3.0, 3.5 AND 5.0 OF IMPROVED TECHNICALSPECIFICATIONS, NINE MILEPOINT NUCLEAR STATION, UNIT NO. 2 (TAC NO. MA3822)
Dear Mr. Mueller.
The NRC staff is reviewing your application for license amendment dated October 16, 1998, to change the format and content of the current Technical Specifications (TSs) for Nine Mile Point Nuclear Station, Unit 2 (NMP2) to be generally consistent with NUREG-1434, Revision 1, "Standard Technical Specifications for General Electric Plants, BWR 6," and extend surveillance requirements from 18 to 24 months.
On the basis of our review of the changes proposed for TS Sections 3.0, 3.5 and 5.0, we find that additional information, identified in the enclosure, is needed.
In accordance with the "NMP2 ITS Review Schedule" jointly established by Niagara Mohawk Power Corporation and NRC, the mutually agreeable response date is June 15, 1999.
'f you have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-3049 or by electronic mail at dsh@nrc.gov.
Docket No. 50-410 Since'rely, Original signed by:
E Darl S. Hood, Sr. Project Manager, Section 1
Project Directorate I
Division of Licensing Project Management Office of Nuclear Reactor Regulation I
DISTRIBUTION:
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Enclosure:
Request for Additional Information on ITS 3.0, 3.5 and 5.0 cc w/encl: See next page
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UNITED STATES NUCLEAR REGULATORY COIVIMISSION WASHINGTON, D.C. 20555-000I
'Ny 18, 1999 Mr. John H. Mueller Chief Nuclear Officer Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station Operations Building, Second Floor P.O. Box 63 Lycoming, NY 13093
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION REGARDING SECTIONS 3.0, 3.5 AND 5.0 OF IMPROVED TECHNICALSPECIFICATIONS, NINE MILE POINT'UCLEAR STATION, UNIT NO. 2 (TAC NO. MA3822)
Dear Mr. Mueller:
The NRC staff is reviewing your application for license amendment dated October 16, 1998, to change the format and content of the current Technical Specifications (TSs) for Nine Mile Point Nuclear Station, Unit 2 (NMP2) to be generally consistent with NUREG-1434, Revision 1, "Standard Technical Specifications for General Electric Plants, BWR 6," and extend surveillance requirements from 18 to 24 months.
On the basis of our review of the changes proposed for TS Sections 3.0, 3.5 and 5.0, we find that additional information, identified in the enclosure, is needed.
In accordance with the "NMP2 ITS Review Schedule" jointlyestablished by Niagara Mohawk Power Corporation and NRC, the mutually agreeable response date is June 15, 1999.
Ifyou have questions regarding this letter or are unable to meet this response schedule, please contact me by phone on (301) 415-3049 or by electronic mail at dsh@nrc.gov.
Sincerely, DMX/~
Darl S. Hood, Sr. Project Manager, Section 1
Project Directorate I
Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-410
Enclosure:
Request for Additional Information on ITS 3.0, 3.5 and 5.0 ccw/encl: See next page
Nine Mile Point Nuclear Station Unit No. 2 Regional Administrator, Region I
U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector Nine Mile Point Nuclear Station P.O. Box 126 Lycoming, NY 13093 Mr. Jim Rettberg NY State Electric 8 Gas Corporation Corporate Drive Kirkwood Industrial Park P.O. Box 5224 Binghamton, NY 13902-5224 Mr. John V. Vinquist, MATS Inc.
P.O. Box 63 Lycoming, NY 13093 Supervisor Town of Scriba Route 8, Box 382 Oswego, NY 13126.
Mr. Richard Goldsmith Syracuse University College of Law E.l. White Hall Campus
- Syracuse, NY 12223 Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Mr. Timothy S. Carey Chair and Executive Director State Consumer Protection Board 5 Empire State Plaza, Suite 2101 Albany, NY 12223 Mark J. Wetterhahn, Esquire Winston & Strawn 1400 L Street, NW.
Washington, DC 20005-3502 Gary D. Wilson, Esquire Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, NY 13202 Mr. F. Will)am Valentino, President New York State Energy, Research, and Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399
0
RAI 3.0-1 Nine Mile Point-2 Improved TS Review Comments Section 3.0, LCO And SR Applicability ITS SR 3.0.1 Surveillance Requirement Applicability The approved TSTF-8 R1 affects STS SR 3.0.1.
Comments:
Incorporate TSTF-8 R1, or provide JDF for not incorporating this generic change into the ITS SR 3.0.1.
Enclosure
4 Nine Mile Point 2 Improved TS Review Comments Section 3.5, ECCS 3.5.1 ECCS-0 eratin 3.5.1.-1 CTS 4.5.1.b & 4.5.2.1 DOC 3.5.1-A.5 ITS SR 3.5.1.4 & SR 3.5.2.5 JFD 1 CTS 3.5.1.4 and 4.5.2.1 require the ECCS pumps to develop a specified flow rate against a test line pressure specified as a gauge pressure value (psig).
ITS SR 3.5.1.4 and SR 3.5.2.5 require the ECCS pumps develop the same specified flow rate against a "total developed head"
'pecified asadifferentialvalue(psid).
STS SR3.5.1.4requires the ECCSpumpsdevelop the specified flow rate against a system head corresponding to the specified reactor pressure.
Comments:
JFD 1 is generic and indicates that the ITS values are proper plant-specific values, although this is not immediately apparent.
The ITS does not use either the CTS wording or the STS wording for this surveillance.
In addition, it doesn't appear that the ITS Bases have been revised to reflect this proposed change.
Either retain the CTS or STS wording for this surveillance and provide corresponding Bases or explain the need for the proposed revised wording and provide corresponding Bases.
While DOC A.5 explains what was done in the proposed change, it does not explain why it was done.
In addition, the staff notes that you did not use the same proposed wording for the identical SRs in ITS SRs 3.5.3.3 and3.5.3.4; please explain why.
NMPC response:
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No comments.
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3.5.3 RCIC S stem No comments.
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Be ondSco e Issues 3.5-1 CTS 3.5.1 DOC L.1 ITS 3.5.1 JFD 1 CTS 3.5.1 requires that seven ADS valves be operable to support operability of ECCS Divisions I and II. ITS 3.5.1 requires the operability of only six ADS valves.
DOC L.1 states that two ADS valves out of service was approved by the NRC as documented in the initial "Safety Evaluation Report Related to the Operation of NMP2," Docket No. 50-410, Supplement No. 4.
3.5-2 CTS 4.5.1.e.2.b DOC L.7 ITS SR 3.5.1.7.
JFD 5 CTS 4.5.1.e.2.b requires that ADS operability be demonstrated by manually opening each ADS valve.
ITS SR 3.5.1.7 requires verification that each ADS valve actuator strokes when manually actuated.
This change would permit testing of the ADS valves using an alternate approach whereby the disk is not lifted off its seat at power.
3.5-3 CTS 4.3.3.3 DOCs 3.5.1-L.8 & 3.5.2-L.5 ITS SR 3.5.1.8 & SR 3.5.2.7 JFDs 3.5.1-5 & 3.5.2-3 CTS 4.3.3.3 requires that the ECCS response time of each required ECCS System be demonstrated to be within the limitand that each test include at least one channel per Trip System.
ITS SRs 3.5.1.8 and 3.5.2.7 require verification that the ECCS response time for each ECCS injection/spray subsystem is within limits. These ITS SRs also contain a note that states that instrumentation response time may be assumed to be the design instrumentation response time. The associated DOCs state that deletion of the response time testing for these instruments was evaluated in NEDO-32291 and the DOCs discuss NMPC's compliance with the additional requirements outlined in the NRC SER for NEDO-32291.
Comment:
These proposed changes to the CTS are beyond the scope of the conversion review and have been forwarded to the appropriate NRC technical staff for review. Any questions concerning these changes will'be forwarded to you separately.
No action on your part is required at this time.
Nine Mile Point-2 Improved TS Review Comments Section 5.0, Administrative Controls 5.2-01 DOC A.6 CTS 6.2.4 ITS 5.2.2.g STS 5.2.2.g JFD 6 CTS 6.2.4 and STS 5.2.2.g have been changed to revise wording from "Shift Supervisor" to "operating shift" in the context of to whom the STA shall provide advisory technical support.
As per NUREG-0737, the STA should have clear lines of reporting and communication with the Shift Supervisor.
DOC A.6 explains the change as being acceptable because there may be multiple instances of supervision in the control room.
DOC A.6 also states that "This includes the Station Shift Supervisor and the ASSS, both of whom are members of the operating shift."
This change may include these two positions but is not clearly limiting the reporting to only them.
Comments:
Revise the submittal to either include the STS wording for this instance or modify CTS/STS/DOC to explicitly outline site specific STA requirements as it relates to NUREG-0737.
NMPC Response:
5.5-01 DOC A.2 CTS 6.8.4.a Note: SR.3.0.2 JFD 4 STS 5.5.2.b Note: SR 3.0.2 A note has been added to STS 5.5.2 which states "The provisions of SR 3.0.2 are applicable to the 24 month frequency for performing integrated system leak test activities." This provision for this activity does not appear to be consistent with 10 CFR 50 Appendix J.
Comments:
The use of this provision in reference to integrated system leak test activities for Primary Coolant Sources outside containment, is proposed in TSTF-299.
NMPC Response:
No response required; TSTF-299 is being evaluated by the NRC staff.
~4 Nine Mile Point-2 Improved TS Review Comments Section 5.0, Administrative Controls 5.5-02 ITS 5.5.4
'TS 5.5.4 The STS/ITS 5.5.4 "Radioactive Effluent Control Program" has been changed to partially adopt parts of TSTF 258 Rev.3.
Part of TSTF 258 Rev.3 has been omitted in the editing process.
This part includes reference to the provisions to SR 3.0.2 and SR 3.0.3.
Comments:
Revise the submittal to include all of TSTF 258 Rev.3.
NMPC Response:
5.5-03 DOC None CTS 4.6.5.3.b JFD 12 ITS 5.5.7 STS 5.5.8 Insert 5.5.7-A STS 5.5.7 Insert 5.5.7-A is essentially consistent with CTS 4.6.5.3.b as edited to fit the ITS.
The word "significant" has been added to describe at what point to perform certain tests.
This term was not used in the CTS and there is not discussion of change for the less restrictive change.
Comments:
Revise the submittal to either not use the phrase "significant" or provide less restrictive discussion for this change in the CTS.
NMPC Response:
5.5-04 DOC None CTS 4.6.5.3/4.7.3 JFD 8 ITS 5.5.7.e STS 5.5.8.e ITS 5.5.7.e uses the additional term "nominal" in reference to the "value specified below..."
JFD 8 states that this change has been done to ensure that the proper plant specific information/nomenclature is correctly provided.
CTS 4.6.5.3 and CTS 4.7.3 does not use the term.
Comments:
Either remove the term "nominal" or provide discussion of change to justify this change in the CTS and the STS.
Nine Mile Point-2 Improved TS Review Comments Section 5.0, Administrative Controls NMPC Response:
5.5-05 DOC A.4 CTS 6.8.4.e.1.a JFD 20 ITS 5.5.9.1.a STS 5.5.10 CTS 6.8.4.e.1.a and STS 5.5.10 have been changed to include a new phrase in reference to acceptability of new fuel oil. This new phrase, "a specific gravity" is based upon information contained in the TS Bases 3.8.3 and has been identified as a beyond scope issue and in addition has an associated RAI 3.8.3-03.
Comment:
The acceptability of this wording willbe based on the resolution of the 3.8.3 Diesel Fuel Oil Testing Program beyond scope issue and RAI 3.8.3-03.
NMPC Response:
No response required; under NRC review.
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