ML20116D812

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Proposed Tech Specs Re Option B of App J to 10CFR50
ML20116D812
Person / Time
Site: Nine Mile Point Constellation icon.png
Issue date: 07/26/1996
From:
NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML20116D806 List:
References
NUDOCS 9608020335
Download: ML20116D812 (18)
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         .                                                                                         1 ATTACHMENT A NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50 410 Revised Pronosed Chanae to License, Technical Soecifications and Bases Replace existing change pages of the proposed license amendment with the attached       i revised pages. These pages have marginal markings to indicate the change as proposed in Niagara Mohawk's letter dated February 7,1996 and as revised by this letter.

Ooeratina License Technical Soecifications Bases i 6 3/4 6-2 B 3/4 6-1 3/4 6-3 6-17a i 6-17b i i 1 9608020335 960726 PDR P ADOCK 05000410 PDR

l . . ! i) An exemption from the criticality alarm requirements of 10 CFR Part 70.24 was granted in the Special Nuclear Materials License No. SNM-1895 dated November 27,1985. This exemption is described in Section 9.1 of Supplement 4 to the SER. This previously granted exemption is continued in this operating license. l li) Exemptions to certain requirements of Appendix J to 10 CFR Part 50 are described in Supplements 3,4, and 5 to the SER. These include (a) (this item left l intentionally blank); (b) an exemption from the requirement of Option B of Appendix l J, exempting main steam isolation valve measured leakage from the combined leakage rate limit of 0.6 La. (Section 6.2.6 of SSER 5)*: (c) an exemption from Option B of Appendix J, exempting the hydraulic control system for the reactor recirculation flow control valves from Type A and Type C leak testing Cection l 6.2.6 of SSER 3); (d) an exemption from Option B of Appendix J, exempting Type l l C testing on traversing incore probe system shear valves. (Section 6.2.6, SSER 4) iii) An exemption to Appendix A to 10 CFR Part 50 exempting the Control Rod Drive (CRD) hydraulic lines to the reactor recirculation pump seal purge aquipment from - General Design Criterion (GDC) 55. The CRD hydraulic lines to the reactor ! recirculation pump seal purge equipment use two simple check valves for the ! isolation outside containment (one inside). (Section 6.2.4, SSER 3)

iv) A schedular exemption to GDC 2, Appendix A to 10 CFR Part 50, until the first

! refueling outage, to demonstrate the adequacy of the downcomer design under the ! plant faulted condition. .This exemption permits additional analysis and/or i modifications, as necessary, to be completed by the end of the first refueling l outage. (Section 6.2.1.7.4, SSER 3) ! v) A schedular exemption to GDC 50, Appendix A to 10 CFR'Part 50 to allow Niagara Mohawk Power Corporation until start-up following the " mini-outage," which is to occur within 12 months of commencing power operation (entering Operational Condition 1), to install redundant fuses in circuits that use transformers for redundant penetration protection in accordance with their letter of August 29,1986 (NMP2L 0860). (Section 8.4.2, SSER 5) i l

  • The parenthetical notation following the discussion of each exemption denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the safety evaluation of the exemption is discussed.

1 ) Amendment No.

i CONTAINMENT SYSTEMS PRIMARY CONTAINMENT PRIMARY CONTAINMENT LEAKAGE l 1 l LIMITING CONDITIONS FOR OPERATION 3.6.1.2 Primary containment leakage rates shall be limited to:

a. An overall integrated leakage rate of less than La,1.1% by weight of the containment air every 24 hours at Pa,39.75 psig.
b. A combined leakage rate on a minimum pathway basis of less than 0.60 La for all penetrations and all Primary Containment isolation Valves, except for main steam line isolation valves * (and Primary Containment isolation Valves which are hydrostatically leak I tested), subject to Type B and C tests when pressurized to Pa,39.75 psig. j
c. A combined leakage rate of less than or equal to 1 gpm times the total number of containment isolation valves in hydrostatically tested lines which penetrate the primary ,

containment, when tested at 1.10 Pa,43.73 psig.

d. Less than or equal to that specified in Table 3.6.1.2-1 through valves in lines that are potential bypass leakage pathways when tested at 40.0 psig.

1 APPLICABILITY: When PRIMARY CONTAINMENT INTEGRITY is required per Specification j 3.6.1.1. ACTION:  ! With:

a. The measured overall integrated primary containment leakage rate equating or exceeding f 1.0 La or 4

l 1 Exemption to Appendix J of 10 CFR 50 NINE MILE POINT - UNIT 2 3/4 6-2 Amendment No. d/ l

CONTAINMENT SYSTEMS 

 ~

PRIMARY CONTAINMENT PRIMARY CONTAINMENT LEAKAGE l LIMITING CONDITIONS FOR OPERATION 3.6.1.2 (Continued) ACTION:

b. The measured combined leakage rate on a minimum pathway basis for all penetrations and l all Primary Containment isolation Valves, except for main steam line isolation valves
  • and l valves which are hydrostatically leak tested, subject to Type B and C tests equaling or l

( exceeding 0.60 La, or

c. The measured combined leakage rate for all containment isolation valves in hydrostatically  :

tested lines which penetrate the primary containment exceeding 1 gpm times the total  ! l number of such valves, or  ;

d. The measured leakage rate through any valve that is part of a potential bypass leakage ,

pathway exceeding the limit specified in Table 3.6.1.2-1 Restore: l

a. The overall integrated leakage rate to less than 1.0 La, and l ;

l

b. The combined leakage rate on a minimum pathway basis for all penetrations and all l l Primary Containment Isolation Valves, except for main steamline isolation valves
  • and i I

valves which are hydrostatically leak tested, subject to Type B and C tests to less than 1 0.60 La, and l l c. The combined leakage rate for all containment isolation valves in hydrostatically tested l lines which penetrate the primary containment to less than or equal to 1 gpm times the l total number of such valves, and

d. The leakage rate to less than or equal to that specified in Table 3.6.1.2-1 for any valve

! that is part of a potential bypass leakage path. I l i i Exemption to Appendix J to 10 CFR 50 NINE MILE POINT - UNIT 2 3/4 6-3 Amendment No. $/ l - .

ADMINISTRATIVE CONTROLS PROCEDURE AND PROGRAMS PROGRAMS 6.8.4 (Continued)

e. Diesel Fuel Oil Testina Prooram A diesel fuel oil testing program to implement required testing of both new fusi oil and stored fuel oil shall be established. The program shallinclude sampling and testing requirements, and acceptance criteria, allin accordance with applicable ASTM Standards.

The purpose of the program is to establish the following: i

1. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:
a. an API gravity or an absolute specific gravity within limits, ,
b. a flash point and kinematic viscosity within limits, and .
c. a clear and bright appearance;
2. Other properties for ASTM fuel oil are within limits within 31 days fo!!owing '

addition to storage tanks; and l

3. Total particulate concentration of the fuel oil is < 10 mg/l when tested every 31 '

days in accordance with ASTM D-2276, Method A.

f. 10 CFR 50 Annendix J Testina Proaram Plan A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B with the exemptions  ;

stated in Section 2.D(ii) of the Operating License. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, entitled, " Performance-Based 4 Containment Leak-Test Program," dated September 1995 with the following exceptions: f i

1. Main steam isolation valves' measured leakage is excluded from the combined leakage rate of 0.6 La, and as-found testing is not required to be performed on the main steam isolation valves. ,
2. Primary containment airlocks' door seals are tested prior to re-establishing containment integrity when something has been done that would bring into question the validity of the previous airlock door seal test.

l The peak calculated containment internal pressure (Pa) for the design basis loss of coolant  ! accident is 39.75 psig. The maximum allowable primary containment leakage rate (La) at Pa shall be 1.1% of primary containment air weight per day. NINE MILE POINT - UNIT 2 6-17a Amendment No. /d  ;

ADMINISTRATIVE CONTROLS i PROCEDURE AND PROGRAMS PROGRAMS 6.8.4.f (Continued) Leakage Rate acceptance criteria are:

1. Primary Containment leakage rate testing acceptance criterion is less than 1.0 La.

The combined leakage rate for Type B and C tests on a minimum pathway basis, except for main steam line isolation valves

  • and Primary Containment isolation valves which are hydrostatically tested, is less than O.6 La.

l During the first unit startup following testing in accordance with this program, the as-left leakage rate acceptance criteria are less than 0.6 La for the Type B and C tests on a maximum pathway basis, except for main steam line isolation valves' and Primary Containment isoiation valves which are hydrostatically tested, and less than or equal to 0.75 La for Type A tests;

2. Air lock testing acceptance criteria are:
a. Overall air lock leakage rate is less than or equal to 0.05 La when tested at

! greater than or equal to Pa,

b. For each door, leakage rate is less than or equal to 5 scfh when the gap between the door seals is pressurized to greater than or equal to 10 psig.
3. Hydrostatic testing acceptance criterion is a combined leakage rate of less than or equal to 1 gpm times the total number of containment isolation valves in l hydrostatically tested lines which penetrate primary containment, when tested at 1.10 Pa,43.73 psig.

The provisions of SR 4.0.2 do not apply to the test frequencies specified in the 10 CFR 50 Appendix J Testing Program Plan. The provisions of SR 4.0.3 are applicable to the 10 CFR 50 Appendix J Testing Program Plan. l l [ i

  • Exemption to Appendix J to 10 CFR 50 NINE MILE POINT - UNIT 2 6-17b Amendment No.

3/4.6 CONTAINMENT SYSTEMS BASES 3/4.6.1 PRIMARY CONTAINMENT 3/4.6.1.1 PRIMARY CONTAINMENT INTEGRITY PRIMARY CONTAINMENT INTEGRITY ensures that the release of radioactive materials from the containment atmosphere will be restricted to those leakage paths and associated leak rates assumed in the accident analyses. This restriction, in conjunction with the leakage rate limitation, will limit the control room and site boundary radiation doses to within the limits of General Design Criterion (GDC) 19 and 10 CFR 100 during accident conditions. 3/4.6.1.2 PRIMARY CONTAINMENT LEAKAGE ' The limitations on primary containment leakage rates ensure that the total containment leakage l volume will not exceed the value assumed in the accident analyses at a pressure of 39.75 psig, l Pa. Updated analysis results in a maximum expected pressure of less than 39.75 psig. As an I added conservatism, the measured overall integratad leakage rate is further limited to less than or l equal to 0.75 La during performance of the periodic tests to account for possible degradation of l the containment leakage barriers between leakage tests. l Operating experience with the main steam line isolation valves has indicated that degradation has I occasionally occurred in the leak tightness of the valves; therefore, the special requirement for ) 

         ' testing these valves.

l The surveillance testing for measuring leakage rates is consistent with the requirements of Option B of Appendix J of 10 CFR 50 with the exception of an exemption granted for main steam isolation valve testing. Leak testing of valves in potential bypass leakage pathways is performed at a test pressure of 40.00 psig rather than Pa,39.75 psig, for consistency with the accident analysis. l The leakage rates specified for the main steam line isolation valves, the main steam drain line isolation valves, and the postaccident sampling system gas sample and return line block valves are used to quantify the maximum amount of primary containment atmosphere that could bypass i l secondary containment and leak directly to the environment after a design-basis loss-of-coolant j i accident. These data are used to determine the radiological consequences of this accident and  ; l ( ensure that the resultant doses are within the limits of GDC 19 and 10 CFR 100. 3/4.6.1.3 PRIMARY CONTAINMENT AIR LOCKS The limitations on closure and leak rate for the primary containment air locks are required to meet the restrictions on PRIMARY CONTAINMENT INTEGRITY arid the primary containment leakage rate given in Specifications 3.6.1.1 and 3.6.1.2. The specification makes allowances for the fact ! that there may be long periods of time when the air locks will be in a closed and secured position during reactor operation. Only one closed door in each air lock is required to maintain the integrity of the containment. I i NINE MILE POINT - UNIT 2 B3/4 6-1 Amendment No. dd _ 4

ATTACHMENT B NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 Hand Marked Un Version of Revised Proposed Channes The current version of the Operating License, the Technical Specifications, and the Bases have been marked up to reflect the change proposed in Niagara Mohawk's letter dated February 7,1996 and as revised by this letter. The marked-up pages are as follows: Ooeratina License Technical Soecifications Bases 6 3/4 6-2 B 3/4 6-1 3/4 6-3 6-17a

  • A revised two r., age insert is provided for Page 6-17a.

l i i l

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                                                                                                                   )

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! 1) An exemption from the criticality alarm requirements of 10 CF l Part 70.24 was granted in the Special Nuclear Materials License l No. SNM-1895 dated Novemter 27, 1985. This exemption is described ' i in Section 9.1 of Supplement 4 to the SER. This previously I granted exemption is continued in this operating . license. i

. i l 11) Exemptions to certain requirements of Appendix J to 10 CFR Part 50 are described in Supplements 3, 4, and 5 to the SER. These include (a)
n ex:=ptica 'rer the requir: :nt Of Paragraph  !

I!!.0.2(b)(ii) Of Appendix J. :::...pting :;;r:ll : nt:ir:nt :f r- l 

                                      '10:k 1 :k:g: t:: ting unl :: =interen          h:: been perf:- d en the     I co    =              cir10k(S:: tion 5.2.5OfSSER5)k:(:b)anexemptionfromthe
                        'B             reouirement_of,,P:r:gr:ph !!!.C.? of Appendix J, exempting main steam       I isolation valve measured leakage from th           bined leakage rate limit of 0.6 La. (Section 6.2.6 of SSER            c) an exemption from
                                  / P r;;r:Ph-H4 of Appendix J exempting the hydraulic control system
                      'ME for the reactor recirculation flow control valves from Type A and           i Type C leak testing (Section 6.2.6 of SSER 3); (d) an exemption fro                                                     Type C testing on OM Peregr ersing     ph II!.0.3 incore        of Appendix probe system           J, exemptinfSection 6.2.6, shear valves.

SSER 4)

( -

iii) An exemption to Appendix A to 10 CFR Part 50 exempting the Control , ' Rod Drive (CRD) hydraulic lines to the reactor recirculation pump l seal purge equipment from General Design Criterion (GDC) 55. The CRD hydraulic lines to the reactor recirculation pump seal purge equipment use two simple check valves for the isolation outside containment (one inside). (Section 6.2.4, SSER 3) iv) A schedular exemption to GDC 2, Appendix A to 10 CFR Part 50, until the first refueling outage, to demonstrate the adequacy of the downcomer design under the plant faulted condition. This exemption permits additional analysis and/or modifications, as necessary, to be completed by the end of the first refueling outage. (Section 6.2.1.7.4, SSER 3) v) A schedular exemption to GDC 50, Appendix A to 10 CFR Part 50 to allow Niagara Mohawk Power Corporation until start-up following the " mini-outage," which is to occur within 12 months of commencing l power operation (entering Operational Condition 1), to install i redundant fuses in circuits that use transformers for redundant penetration protection in accordance with their letter of August 29, 1986 (NMP2L 0860). (Section 8.4.2, SSER 5) c *The parenthetical notation following the discussion of each exemption denotes 4 the section of the Safety Evaluation Report (SER) and/or its supplements wherein the safety evaluation of the exemption is discussed. 

                                                                                             % vdre,4 96.

< 1 i l , 

  ~

I CONTAINMENT SYSTEMS PRIMARY CONTAINMENT f( PRIMARY CONTAINMENT LEAKAGE l LIMITING CONDITIONS FOR OPERATION 3.6.1.2 Primary containment leakage rates shall be limited to:

a. An overall integrated leakage rate of less than er equ_

La, 1.1% by weight of the containment air every 24 hours at Pa,  ! ( (39.75 psig g e i . e, .. , u:ight Of th: : ntsi= nt f r :v;ry 24 heur; t : 1 __a.__; n., n , e- m 

                                                 ,.     .o. . . n., ,. 4.. ,,. .

_Q i 

                        ..m     m. y.-..__ . . .    ..                                                        l
b. A combined leakage rate (f less than Or c';u:1 .: .O a for all pene-trations and all Primary Containment Isolation Valves, except for main steam line isolation valves * (and Primary Containment Isolation Valves which are hydrostatically leak tested), subject to Type B and C tests when I

pressurized to Pa, 39.75 psig. ,

c. A combined leakage rate of less than or equal to 1 gpm times the total l t number of containment isolation valves in hydrostatically tested lines l
   ,              which penetrate the primary containment, when tested at 1.10 Pa,                            '

( 43.73 psig. ! d. , Less than or equal to that specified in Table 3.6.1.2-1 through valves  ; in lines that are potential bypass leakage pathways when tested at l 40.0 psig. l APPLICABILITY: When PRIMARY CONTAINMENT INTEGRITY is required per Specifica-tion 3.6.1.1. ACTION: With: #V" "7 ^ l l , a. The measured overall integrated primary containment leakage rate" exceeding La er 0.75 Lt, :: ppli:21 or l l l j 

                           ~
.
  • Exemption to Appendix J of 10 CFR 50.

Amendment No. NINE MILE POINT - UNIT 2 3/4 6-2 1 I 

  ^

l- CONTAINMENT SYSTEMS PRIMARY CONTAINMENT 

             .                                                                                                       i
                  . PRIMARY CONTAINMENT LEAKAGE
                                                                                                                    .i
                  ~LIMITING CONDITIONS FOR OPERATION
.3.6.1.2 (Continued)
                                                                                         .      .m-ACTION:                                                   m ( AMr.-
b. The measured combined leakage rate for all penetrations and all Primary Containment Isolation Valves, except for main steam line isolation valves
  • and valves which are hydrostatically leak tested, subject to Type B and l C tests exceeding _0.60 La, or
c. The measure ed leakage rate for all containment isolation valves in hydrostatically tested lines which penetrate the primary containment exceeding-1.gpm times the total number of such valves, or ,
d. The measured leakage rate through any valve that is part of a potential bypass leakage pathway exceeding the limit specified in Table 3.6.1.2-1 I

l Restore:  : l l /

a. The overall integrated leakage rateM to less than :r :;u:1 t: . . 5 La -e*-

O.75 Lt, :: :pplic:ble, and ,g  : , b. The combined leakage rate for all penetrations and al r maryr l Containment Isolation Valves, except for main steamline isolation valves *

and valves which are hydrostatically' leak tested, subject to Type B and C l tests to less than er
q::1 t:4 600 La,' and
c. The combined leakage rate for all containment isolation valves in hydro-l statically tested lines which pentrate the primary containment to less l- than or equal to 1 gpm times the total number of such valves, and I

( d. The leakage rate to less than or equal to that specified in Table 3.6.1.2-1 l for any valve that-is part of a potential bypass leakage path. pri r to inere::ing r:::t:r :::1:nt :y:t ; temperaturi ebeve 200"T. 3 j(

  • Exemption to Appendix J to 10 CFR 50.

NINE MILE POINT - UNIT 2 3/4 6-3 AmendmentNo.f

ADMINISTRATIVE CONTROLS _ PROCEDURE AND PROGRAMS ( PROGRAMS 6.8.4 (Continued)

e. Diesel Fuel Oil Testina Proaram A diesel fuel oil testing program to implement required testing of both new fuel oil and stored fuel oil shall be established. The program shall include sampling and testing
      -                requirements l and acceptance criteria, all in accordance with applicable ASTM Standards.

The purpose of the program is to establish the following:

1. Acceptability of new fuel oil for use prior to addition to storage tanks by determining that the fuel oil has:
a. an API gravity or an absolute specific gravity within limits,
b. a flash point and kinematic viscosity within limits, and
c. a clear and bright appearance:
2. Other properties for ASTM fuel oil are within limits within 31 days following .

addition to storage tanks; and 

   ,                   3. Total particulate concentration of the fuel oil is < 10 mg/l when tested every 31          l i                          days in accordance with ASTM D-2276, Method A.

4, IN M A/T 4 

    ?
,  'V NINE MILE POINT - UNIT 2                         6-17a                                Amendment No.

i INSERTFOR PAGE 6-17A 10 CFR 50 Appendix J Testing Program Plan A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(o) and 10 CFR 50, Appendix J, Option B with the exemptions stated in Section 2.D(ii) of the Operating License. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, entitled " Performance-Based Containment Leak-Test Program," dated September 1995 with the following exceptions:

1. Main steam isolation valves' measured leakage is excluded from the combined leakage rate of 0.6 La, and as-found testing is not required to be performed on the main steam isolation valves.
2. Primary containment airlocks' door seals are tested prior to re-establishing containment integrity when something has been done that would bring into question the validity of the previous airlock door seal test.

The peak calculated containment internal pressure (Pa) for the design basis loss of coolant accident is 39.75 psig. l The maximum allowable primary containment leakage rate (La) at Pa shall be 1.1% of prima y ! containment air weight per day. Leakage Rate acceptance criteria are:

1. Primary Coritainment leakage rate testing acceptance criterion is less than 1.0 La. The l combined leakage rate for Type B and C tests on a minimum pathway basis, except for
main steam line isolation valves
  • and Primary Containment isolation valves which are hydrostatically tested, is less than 0.6 La.

During the first unit startup following testing in accordance with this program, the as-left leakage rate acceptance criteria are less than 0.6 La for the Type B and C tests on a maximum pathway basis, except for main steam line isolation valves

  • and Primary Containment isolation valves which are hydrostatically tested, and less than or equal to 1 0.75 La for Type A tests; l
2. Air lock testing acceptance criteria are:
a. Overall air lock leakage rate is less than or equal to 0.05 La when tested at greater than or equal to Pa, l
b. For each door, leakage rate is less than or equal to 5 scfh when the gap between j the door seals is pressurized to greater than or equal to 10 psig.
  • Exemption to Appendix J to 10 CFR 50

i l l* . INSERT FOR PAGE 6-17A (cont'd.) 1

3. Hydrostatic testing acceptance criterion is a combined leakage rate of less than er equal to 1 gpm times the total number of containment isolation valves in j

hydrostatically tested lines which penetrate primary containment, when tested at 1.10 Pa,43.73 psig. The provisions of SR 4.0.2 do not apply to the test frequencies specified in the 10 CFR 50 Appendix J Testing Program Plan. l The provisions of SR 4.0.3 are poplicable to the 10 CFR 50 Appendix J Testing Program l Plan.

l l

l l l 1  ! l i l i I

l' * 

                               , 3/4.6 CpMTAINMENT SYSTEMS

! BATER jI  : j 3/4.6.1 PRIMARY CONTAINMENT l i j 3/4.6.1.1 PRIMARY CONTAINMENT INTEGRITY PRIMARY CONTAINMENT INTEGRITY ensures that the release of:=dianreive materials from the ! ===i==== ==amphare will be resencted to those leakage paths and =ww4*ad leak rates assumed in j the accident analyses. His restriction, in = 0 '= with the leakage rate limitation, will limit the control room and site boundary saliation doses to within the limbs of General Design Criteriop - l (GDC) 19 and 10 CFR 100 during accident mmlitiam. 1 j 3/4.6.1.2 PRIMARY CONTAINMENT LEAKAGE f he 13=lemiana on My mar =in= ant leakage rates ensure that the total marnin=aat leakage volume l wBl not exceed the value assumed in the accident analyses at a pressure of 39.75 psig, Pa. Updated analysis results in a marin== expected pressure ofless shan 39.75 psig. As an added conservatism, j the measured overall integrated leakage rate is further limited to las than or equal to 0.75 La during 1 performance of the periodic tests to account for possible degradation of the co=mi==a= leakage barriers between leakage tests. Operating experience with the main steam line isolstion valves has indicated that degradation has 

                                 ==iammily occurred in the leak tigLtness of the valves; therefore, the special requirement for                          ~

these valves. ,S ( De survamance testing for enkage rates is -l===t with the requiremens of ix J of 10 CFR 50 with the exception of granted for main steam iaalmi= valve 4eak testing, 

                                     ;- _g ;;;;; ea - - " 7 ' -

testing of valves in potential bypass leakage pathways is performed at a test pressure [40.00 psig rather than Pa, 39.75 psig, for connierancy with the accident analysis. 1 De leakage rates specified for the main steam line isolation valves, the main steam drain line I iaalmiaa valves, and the pr==Wr sampling system gas sample and return line block valves are used to quantify the .. '.c ". amount of primary mnrni==aar ==aaphare the could bypass secondary marniamaat and leak diredly to the envirn==== after a daign basis loss of coolant l 

                                =cr4dar.'   Dese data are used to determine the radiological -anp- of this accident and ensure                                     i tha the resultant doses are within the limits of GDC 19 and 10 CPR 100.

l 3/4.6.1.3 PRIMARY CONTAINMENT AIR LOCTE ' he limiemia= on closure and leak rate for the primary .. ~ % - air locks are required to meet the restrictions on PRIMARY CONTAINMENT INTEGRTIY and the primary mnrain= ant leakage rate given in Specificatmos 3.6.1.1 and 3.6.1.2.~ De : +i'c3'e makes allowances for the fact that there may be long periods of time when the air locks will be in a closed and secured position during reactor operation. Only one closed door in each air lock is required to =vmenia the integrity of the m nemin = ant NINE MILE POINT - UNIT 2 B3/4 6-1 AmendmaatNo.f

ATTACHMENT C 

                                                         . NIAGARA MOHAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410                                                          J l

Additional Information Reauested by the NRC and Discussion of Revised Proposed Change l By a letter dated February 7,1996, Niagara Mohawk proposed a License Amendment which would convert NMP2 from Option A of Appendix J to Option B of Appendix J for ' Type A, B and C testing. Subsequently, the Staff and NMPC discussed several topics regarding this proposed License Amendment. The topics, associated information and the l revised proposed change to the License, Technical Specifications and Bases are provided boiow.  ; l Exemotion to Anoendix J  ; I The following information regarding an exemption to Appendix J supplements item 2 on [ pages 3 and 4 and item 1 on page 5 of Attachment C of the proposed license amendment. , Section 2.D(ii)(b) of the Operating License is revised to retain the exemption of Main Steam isolation Valve (MSIV) leakage from the requirements of Appendix J. Specifically, measured MSIV leakages would continue to be excluded from the requirement that the. sum of the leakage rates at accident pressure of Type B tests, and pathway leakagu rates from Type C tests, be less than the performance criterion (La) with margin, as specified in the Technical Specification. l l Consistent with the revision of Section 2.D(ii)(b), the application of the single asterisk footnote on page 6 of the Operating License is revised from Section 2.D(ii)(c) to Section 2.D(ii)(b). l Section 2.D(ii) of the Operating License is also revised to eliminate specific references to l paragraphs of Option A of Appendix J. References to Option B of Appendix J are provided for Sect 2.D(ii). I Accordingly, page 6 of the Operating License, pages 3/4 6-2 and 3/4 6-3 of the Technical Specifications, and page B3/4 6-1 of the Bases are revised to reflect these changes. Radiological Evaluation of MSIV Leakage l The following information regarding the radiological evaluation of MSIV leakage

supplements item 5 on pages 15 and 16 of Attachment C of the proposed license )

! amendment. i 4 Page 1 of 3

1 MSIV leakage is added onto the assumed leakage of La of the primary containment. Specifically, each of the MSIV's is assumed to leak at its Technical Specification limit as described on Table 3.6.2.1-1 for the duration of the accident as a ground level unfiltered release. Leakage from the MSIV's is assumed to bypass secondary containment during the duration of a design basis accident -loss of coolant accident. Primary Containment intearity The following information regarding primary containment integrity supplements item 5 on pages 6 and 7 of Attachment C of the proposed license amendment. Definition 1.31, entitled " PRIMARY CONTAINMENT INTEGRITY" states that PRIMARY CONTAINMENT INTEGRITY shall exist when primary containment leakage rates are within the limits of Specification 3.6.1.2, entitled " Primary Containment Leakage." Therefore, the action statement of LCO 3.6.1.1 is applicable whenever the requirements of LCO 3.6.1.2 are not satisfied. Accordingly, failure to satisfy the requirements of LCO 3.6.1.2 would place the unit in the action statement associated with LCO 3.6.1.1. Primary Containment Air Locks -l The following information regarding primary containment air locks supplements item 19 on , page 11 and item 21 on pages 11,12 and 13 of Attachment C of the proposed hcense l amendment. l The proposed license amendment revises Surveillance Requirement (SR) 4.6.1.3.a to f include time intervals for single and multiple entries of primary containment which are equivalent to or more restrictive than the requirements of Section 10.2.2.1 of NEl 94-01. Specifically, a 7 day time limit, which is equivalent to the requirements of NEl 04-01, is adopted for a single entry into primary containment. However, a 7 day time limit, which is , more restrictive than the 30 day limit allowed by NEl 94-01, is adopted for multiple entries. NMPC has selected a time limit which is identical for single and multiple entries so as to simplify the tracking of the performance of this SR. The proposed license amendment also revises the interval at which SR 4.6.1.3.c. is performed to verify operability of the primary containment air locks' interlocks. Niagara Mohawk has reviewed the available surveillance results for this SR for both airlocks spanning a time interval of approximately 10 years. NMPC has determined that during this time interval there were two unsatisfactory performances of this SR. In both cases these failures were associated with the performance of SR 4.6.1.3.c following restoration of the interlocks which were defeated to facilitate entry into primary containment during a plant outage. In each case, the interlocks were adjusted and SR 4.6.1.3.c was performed satisfactorily prior to requiring PRIMARY CONTAINMENT INTEGRITY to be operable. 7 Based on the results of this review, Niagara Mohawk has concluded that the historical ' surveillance results for SR 4.6.1.3.a support the proposed change in testing interval for the airlocks' interlocks. Page 2 of 3

m . ! a l . Clarification of NEl 94-01 , The following information regarding the clarification of NEl 94-01 supplements item 4 on i page 15 of Attachment C of the proposed license amendment. Niagara Mohawk continues I to advocate its technical position regarding the testing of primary containment air lock seals during periods of plant shutdown where primary containment integrity is not required by the Technical Specifications. Specifier.ily, seal testing should be performed prior to establishing primary containment integrity in those circumstances where something has been done that would bring into question the validity of a previous air lock seal test. However, this technical position is revised from being a clarification to an exception to NEl 94-01. The basis of the acceptability of this technical position as an exception or as a clarification to NEl 94-01 is the same. Specifically, the air lock seals will continue to perform their safety function if nothing has been done to invalidate the previous air lock seal test. The following information regarding the clarification of NEl 94-01 Supplements item 5 on pages 15 and 16 of Attachment C of the proposed license amendment. Niagara Mohawk , continues to advocate its technical position that as-found testing is not required of the l main steam isolation valves. However, this technical position is revised from being a clarification to an exception to NEl 94-01. The basis of the acceptability of this technical position as an exception or as a clarification to NEl 94-01 is the same. Specifically, the radiological analysis assumes that the main steam isolation valves leak at the maximum allowable rate specified on Technical  ! l Specification Table 3.6.1.2-1 and the primary containment leaks at a rate of La. l j Furthermore, the main steam isolation valves will be tested on a nonperformance basis and at least once per 30 months in accordance with Regulatory Guide 1.163. Accordingly, the description of the 10 CFR 50 Appendix J Testing Program Plan on Technical Specification page 6-17a is revised to reflect this exception to Regulatory Guide 1.163. 10 CFR 50 Anoendix J Testina Proaram Plan The following information regarding the 10 CFR 50 Appendix J Testing Program Plan supplements item 6 on page 7 of Attachment C of the proposed license amendment. The description of the 10 CFR 50 Appendix J Testing Program Plan is revised to eliminate the reference to NMPC's letter dated February 7,1996. A brief discussion of each exception to Regulatory Guide 1.163 is provided in the description of the Program Plan. The description of the 10 CFR 50 Appendix J Testing Program Plan is also revised to be l consistent with the retention of the exemption of MSIV leakage from the requirements of Appendix J (as discussed above). The word testing is inserted after Primary Containment leakage rate to clarify that this acceptance criterion applies to testing. Accordingly, pages 6-17a and 6-17b of the Technical Specifications are revised to reflect these changes. The supplementalinformation described above continues to support Niagara Mohawk's no sign;ficant hazards consideration provided to the Staff in a proposed license amendment j dated February 7,1996. Page 3 of 3 

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