ML21110A511

Request for Additional Information Review of License Amendment Request to Revise Technical Specifications to Adopt TSTF-582

ML21110A511
Person / Time
Site:	Nine Mile Point
Issue date:	04/20/2021
From:	Marshall M Plant Licensing Branch 1
To:	Reynolds R Exelon Nuclear, Exelon Generation Co
Marhsall M, NRR/DORL/LPL, 415-2871
References
EPID L-2020-LLA-0276, TSTF-582
Download: ML21110A511 (2)

Text

From: Marshall, Michael To: [Licensee] Ron Reynolds (Exelon)

Cc: Wolniak, Denise J:(Exelon Nuclear); Danna, James

Subject:

NINE MILE POINT NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: REVIEW OF LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-582 (EPID L-2020-LLA-0276)

Date: Tuesday, April 20, 2021 1:27:00 PM Hello Ron:

By letter dated December 18, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20353A401), Exelon Generation Company, LLC (the licensee) requested changes to the technical specifications (TS) for Nine Mile Point Nuclear Station, Unit 1 (Nine Mile Point 1) by license amendment request (LAR). The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force (TSTF) Traveler TSTF582, Revision 0, RPV WIC Enhancements (TSTF-582) (ADAMS Accession No. ML19240A260), and the associated NRC staff safety evaluation of TSTF582 (ADAMS Accession No. ML20219A333).

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in the LAR and has determined that additional information is needed to complete its review.

The request for additional information was discussed with you on April 16, 2021, and it was agreed that your response would be provided within 45 days of the date of this email.

RAIs The regulation Section 50.36(c)(2) of Title 10 of the Code of Federal regulations (10 CFR) requires that TS include limiting conditions for operation (LCOs). Per 10 CFR 50.36(c)(2)

(i), LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

The regulation at 10 CFR 50.36(c)(3) requires that TS include items in the category of surveillance requirements, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the LCOs will be met.

1. The adaptation of the TSTF582, which is based on the standard TS (STS), to the custom TSs used at Nine Mile Point 1 is unclear in the LAR. Please provide a comparison (e.g., crosswalk) of the changes in the STS found in TSTF582 versus the proposed changes to Nine Mile Point 1 custom TS. This should include discussion of items that are in TSTF582 but are not proposed in this LAR, as well as items that are specific to Nine Mile Point 1 TS but not in TSTF582. Clearly identify the location of the changes in each document (e.g., LCO number and items changed.)

2. Section 2.2 of Attachment 1 to the LAR describes optional changes and variations.

However, there are other variations in the TS markup pages that are not listed. For those items not included in Section 2.2 of the LAR, please identify and explain all variations from TSTF582, including:

a. Editorial or administrative variations (all numbering/ wording that differs from

TSTF582 but does not change requirements)

b. Design variations (explain where Nine Mile Point 1s design does not match the design assumed in TSTF582 and why it is applicable)

c. Technical variations (a requirement that differs from that in TSTF582 or in the current Nine Mile Point 1 TS.)

3. In the LAR, a list of improvements from TSTF582 was discussed on pages 2 and 3 of Attachment 1. For numbers 5 and 6, please provide more detail of the proposed changes to Nine Mile Point 1 TS and how they compare to what is stated in TSTF582.

4. On Nine Mile Point 1 TS markup page 247c, please explain why Manual is a separate parameter from primary coolant isolation. Also, there are no annotations next to it like the other parameters. Which Table 3.6.2m notes apply to Manual when it is inoperable?

5. LAR appears to be missing information identified in TSTF582. In the LAR, it appears that the equivalent for TSTF582 STS 3.3.5.2 Action A is proposed TS 3.6.2m Table Note (c) which states:

With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement, either

1. Place the inoperable channel(s) in the trip condition, or

2. Take the Action required by Specification 3.6.2 a for that parameter.

Please explain the apparent discrepancy between TSTF582 STS 3.3.5.2 and proposed TS 3.6.2m Table Note (c). Additionally, correct or provide technical justification for this variation from TSTF582.

Best Regards, Michael L. Marshall, Jr.

Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-2871 Docket No. 50-220