ML21256A179
| ML21256A179 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/02/2021 |
| From: | Richard Guzman Plant Licensing Branch 1 |
| To: | Rhoades D Exelon Nuclear, Exelon Generation Co |
| Marhsall M, Guzman R | |
| References | |
| EPID L-2020-LLA-0276 | |
| Download: ML21256A179 (15) | |
Text
November 2, 2021 Mr. David P. Rhoades Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT 1 - ISSUANCE OF AMENDMENT NO. 246, CHANGES TO REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL TECHNICAL SPECIFICATION REQUIREMENTS (EPID L-2020-LLA-0276)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 246 to Renewed Facility Operating License No. DPR-63 for the Nine Mile Point Nuclear Station, Unit 1 (Nine Mile Point 1). The amendment consists of changes to the Technical specifications (TSs) in response to your application dated December 18, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20353A401), as supplemented by letter dated June 4, 2021 (ADAMS Accession No. ML21155A136).
The amendment revised the Nine Mile Point 1 TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force Traveler 582, Revision 0, RPV WIC Enhancements (ADAMS Accession No. ML19240A260) and the associated NRC staff safety evaluation (ADAMS Accession No. ML20219A333).
A copy of the related Safety Evaluation is enclosed. Notice of Issuance will be included in the Commissions monthly Federal Register notice.
Sincerely,
/RA/
Richard V. Guzman, Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosures:
- 1. Amendment No. 246 to DPR-63
- 2. Safety Evaluation
- 3. Notices and Environmental Findings cc: Listserv
EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, LLC DOCKET NO. 50-220 NINE MILE POINT NUCLEAR STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 246 Renewed License No. DPR-63
- 1.
The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Exelon Generation Company, LLC (Exelon, the licensee) dated December 18, 2020, as supplemented by letter dated June 4, 2021, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-63 is hereby amended to read as follows:
2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. 246, is hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION James G. Danna, Chief Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to the License and Technical Specifications Date of Issuance: November 2, 2021 James G.
Danna Digitally signed by James G. Danna Date: 2021.11.02 14:29:07 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NO. 246 NINE MILE POINT NUCLEAR STATION, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-63 DOCKET NO. 50-220 Replace the following page of the Renewed Facility Operating License with the attached revised page. The revised page is identified by amendment number and contains marginal lines indicating the areas of change.
Remove Page Insert Page 3
3 Replace the following pages of Appendix A, Technical Specifications, with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages 8a 8a 79a 79a 79b 79b 79c 79c 109 109 247b 247b 247c 247c 247d 247d 247e 247e 247f 247f Renewed License No. DPR-63 Amendment No. 191 to 245, 246 (2)
Exelon Generation pursuant to the Act and 10 CFR Part 70, to receive, possess and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (3)
Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)
Exelon Generation pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument and equipment calibration or associated with radioactive apparatus or components.
(5)
Exelon Generation pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:
Part 20, Section 30.34 of Part 30; Section 40.41 of Part 40; Section 50.54 and 50.59 of Part 50; and Section 70.32 of Part 70. This renewed license is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect and is also subject to the additional conditions specified or incorporated below:
(1)
Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 1850 megawatts (thermal).
(2)
Technical Specifications The Technical Specifications contained in Appendix A, which is attached hereto, as revised through Amendment No. 246, is hereby incorporated into this license. Exelon Generation shall operate the facility in accordance with the Technical Specifications.
(3)
Deleted
AMENDMENT NO. 236, 8a 1.34 Drain Time The drain time is the time it would take for the water inventory in and above the Reactor Pressure Vessel (RPV) to drain to
-10 inches indicator scale (74 inches above the top of the active fuel seated in the RPV) assuming:
a.
The water inventory above -10 inches indicator scale is divided by the limiting drain rate; b.
The limiting drain rate is the larger of the drain rate through a single penetration flow path with the highest flow rate, or the sum of the drain rates through multiple penetration flow paths susceptible to a common Mode failure for all penetration flow paths below -10 inches indicator scale except:
- 1. Penetration flow paths connected to an intact closed system, or isolate by manual or automatic valves that are closed and administrative controlled in the closed position, blank flanges, or other devices that prevent flow of reactor coolant through the penetration flow paths;
- 2. Penetration flow paths capable of being isolated by valves that will close automatically without offsite power prior to the RPV water level being equal to -10 inches indicator scale when actuated by RPV water level isolation instrumentation; or
- 3. Penetration flow paths with isolation devices that can be closed prior to the RPV water level being equal to the
-10 inches indicator scale by a dedicated operator trained in the task, who is in continuous communication with the control room, is stationed at the controls, and is capable of closing the penetration flow path isolation device without offsite power.
c.
The penetration flow paths required to be evaluated per paragraph b are assumed to open instantaneously and are not subsequently isolated, and no water is assumed to be subsequently added to the RPV water inventory; d.
No additional draining events occur; and e.
Realistic cross-sectional areas and drain rates are used.
A bounding drain time may be used in lieu of a calculated value.
246
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT 3.1.9 Reactor Pressure Vessel (RPV) Water Inventory Control Applicability:
Applies to the operating status of the core spray systems and Reactor Water Inventory Control when the reactor coolant temperature is less than or equal to 212F.
Objective:
To assure the RPV water inventory is maintained -10 inches indicator scale.
Specification:
a.
Whenever irradiated fuel is in the reactor vessel and the reactor coolant temperature is less than or equal to 212F, drain time of RPV water inventory to
-10 inches indicator scale shall be 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and one core spray subsystem shall be operable except as specified in Specifications b through f below.
b.
If the required core spray subsystem becomes inoperable, the component shall be returned to an operable condition within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
c.
If Specifications a and b are not met, then immediately initiate action to establish a method of water injection capable of operating without offsite electrical power.
4.1.9 Reactor Pressure Vessel (RPV) Water Inventory Control Applicability:
Applies to the periodic testing requirements for the core spray system and RPV water inventory.
Objective:
To verify the operability of the core spray system and RPV water inventory.
Specification:
a.
Verify drain time 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> in accordance with the Surveillance Frequency Control Program.
b.
Verify, for a required core spray subsystem, the downcomers in the suppression chamber have greater than or equal to three and one half foot of submergence or the condensate storage tank inventory is not less than 300,000 gallons, in accordance with the Surveillance Frequency Control Program.
AMENDMENT NO. 236, 79a 246
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT d.
If drain time <36 hours and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> perform the following actions:
(1)
Verify secondary containment boundary is capable of being established in less than the drain time, and (2)
Verify each secondary containment penetration flow path is capable of being isolated in less than the drain time, and (3) Verify one Reactor Building Emergency Ventilation System (RBEVS) circuit is capable of being placed in operation in less than the drain time.
e.
If drain time <8 hours, immediately perform the following actions:
(1) Initiate action to establish an additional method of water injection with water sources capable of maintaining RPV water level above -10 inches indicator scale for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> without offsite electrical
- power, and (2) Initiate action to establish secondary containment
- boundary, and (3) Initiate action to isolate each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room, and (4) Initiate action to verify one RBEVS circuit is capable of being placed in operation.
c.
Verify each valve credited for automatically isolating a penetration flow path actuates to the isolation position on an actual or simulated isolation signal, in accordance with the Surveillance Frequency Control Program.
d.
Verify the required core spray subsystem can be manually operated, in accordance with the Surveillance Frequency Control Program. Vessel spray may be excluded.
AMENDMENT NO. 236, 79b 246
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT f.
Specifications d or e not met, or drain time is
<1 hour, immediately initiate action to restore drain time to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AMENDMENT NO. 236, 79c 246
LIMITING CONDITION FOR OPERATION SURVEILLANCE REQUIREMENT c.
If Specifications 3.2.7a and b above are not met, initiate normal orderly shutdown within one hour and have reactor in the cold shutdown condition within ten hours.
c.
In accordance with the Surveillance Frequency Control Program the feedwater and main-steam line power-operated isolation valves shall be exercised by partial closure and subsequent reopening.
d.
In accordance with the INSERVICE TESTING PROGRAM the feedwater and main steam line power-operated isolation valves shall be fully closed and reopened.
AMENDMENT NO. 142, 197, 222, 233, 236, 109 246
TABLE 3.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Limiting Condition for Operation THIS PAGE WAS LEFT INTENTIONALLY BLANK AMENDMENT NO. 236, 247b 246
TABLE 3.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Limiting Condition for Operation Parameter Minimum No.
of Tripped or Operable Trip Systems Minimum No. of Operable Instrument Channels per Operable Trip System Set Point Reactor Mode Switch Position in Which Function Must Be Operable Shutdown Refuel Startup Run PRIMARY COOLANT ISOLATION (1)
Low-Low Reactor Water Level (a) Cleanup 2
1(c) 5 inches (Indicator Scale)
(a) (b)
(a) (b)
(b) Shutdown Cooling 2
1(c) 5 inches (Indicator Scale)
(a) (b)
(a) (b)
AMENDMENT NO. 236, 239, 247c 246
TABLE 4.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement THIS PAGE WAS LEFT INTENTIONALLY BLANK AMENDMENT NO. 236, 247d 246
TABLE 4.6.2m RPV WATER INVENTORY CONTROL INSTRUMENTATION Surveillance Requirement Parameter PRIMARY COOLANT ISOLATION (Cleanup and Shutdown Cooling)
(2)
Low-Low Reactor Water Level Sensor Check Note 1 Instrument Channel Test Note 1 Instrument Channel Calibration AMENDMENT NO. 236, 239, 247e 246
NOTES FOR TABLES 3.6.2m AND 4.6.2m (a)
The Parameters in this table are only applicable in the Shutdown Condition - Cold and Refuel. See Table 3.6.2b or Table 3.6.2d for Parameter applicability in the Shutdown Condition - Hot.
(b)
Applicable when automatic isolation of the associated penetration flow path(s) is credited in calculating drain time.
(c)
With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement, immediately either 1.
Place the inoperable channel(s) in the trip condition, or 2.
- a. Declare associated penetration flow path(s) incapable of automatic isolation, and
- b. Initiate action to calculate drain time, and c.
Take the Action required by Specification 3.6.2a for that parameter.
Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2m.
AMENDMENT NO. 236, 247f 246
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 246 TO FACILITY OPERATING LICENSE NO. DPR-63 EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, UNIT 1 DOCKET NO. 50-220 Application (i.e., initial and supplements)
Safety Evaluation Date December 18, 2020 (ADAMS Accession No. ML20353A401)
June 4, 2021 (ADAMS Accession No. ML21155A136)
November 2, 2021 Principal Contributors to Safety Evaluation K. West G. Singh C Jackson
1.0 PROPOSED CHANGE
S Exelon Generation Company, LLC (the licensee) requested changes to the technical specifications (TSs) for Nine Mile Point Nuclear Station, Unit 1 (Nine Mile Point 1) by license amendment request (LAR, application) dated December 18, 2020, as supplemented by letter dated June 4, 2021. The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force Traveler (TSTF) 582, Revision 0, RPV WIC Enhancements, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A260), and the associated U.S.
Nuclear Regulatory Commission (NRC) staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333).
The boiling-water reactor (BWR) RPV design includes multiple penetrations located below the top of active fuel (TAF). These penetrations provide entry for control rods, recirculation flow, reactor water cleanup, and shutdown cooling. Since these penetrations are below the TAF, this creates a potential to drain the reactor vessel water inventory and lose effective core cooling.
The loss of water inventory and effective core cooling can potentially lead to fuel cladding failure and radioactive release. Drain time is the time it would take for the water inventory in and above the RPV to drain to the TAF.
1.1 Proposed TS Changes to Adopt TSTF-582 In accordance with NRC staff-approved TSTF-582, the licensee proposed changes that would revise the TSs related to RPV WIC to incorporate operating experience and to correct errors and omissions that the licensee incorporated into the Nine Mile Point 1 TS previously, when it adopted TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). Specifically, the licensee has proposed the following changes to adopt TSTF-582:
The drain time definition in TS 1.34 would be revised to move the examples of common mode failure mechanisms to the TS Bases and delete seismic events.
In TS 1.34, drain time definition, the exception from considering the drain time for penetration flow paths isolated with manual or automatic valves that are that are locked, sealed, or otherwise secured would be revised to apply the exception for manual or automatic valves that are closed and administratively controlled.
The notes for limiting condition for operation (LCO) Table 3.6.2m and Surveillance Requirement (SR) Table 4.6.2m would be revised to permit placing an inoperable isolation channel in trip as an alternative to declaring the associated penetration flow path incapable of automatic isolation.
In LCO Table 3.6.2m, the action in Note b.2 requires calculating drain time with a Completion Time of immediately. The action would be renumbered as new Note c.2.b and revised to state, Initiate action to calculate drain time.
In LCO 3.1.9, the first use of the acronym RBEVS (Reactor Building Emergency Ventilation System) would be defined in Specification d.3 and the addition of circuit after RBEVS would be used in Specifications d.3 and e.4.
LCO 3.1.9 and LCO Table 3.6.2m would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required core spray subsystem, and to instead rely on manual valve alignment and pump start.
The Table 4.6.2m SR related to manual initiation using the ECCS signal would be eliminated. Related to this change, the Tables 3.6.2m and 4.6.2m functions, SRs, and actions that only support manual initiation using an ECCS signal would be eliminated.
The Applicability of LCO 3.2.7, Reactor Coolant System Isolation Valves (Similar to Standard TS (STS) 3.6.1.3) would be revised by deleting the specifications related to shutdown which include the phrase, when reactor coolant temperature is less than or equal to 212 °F [degrees Fahrenheit]. This would make LCO 3.2.7 applicable only in Nine Mile Point 1 Reactor Operating Conditions Power Operating Condition and Shutdown Condition - Hot (> 212 °F) (similar to STS Modes 1, 2, and 3.)
Specifications d, e, and f of LCO 3.2.7 would be revised to reflect this change.
1.2 Additional Proposed TS Changes Several STS requirements are not applicable and thus not proposed for the Nine Mile Point 1 TS due to plant design differences from the design assumptions in TSTF-582. In its June 4, 2021, letter, Attachment 1, the licensee noted these differences in the crosswalk table. Many of the design differences were indicated by N/A in the Nine Mile Point 1 TS column. For example, the Nine Mile Point 1 ECCS does not include a low pressure core injection system (LPCI). Nine Mile Point 1 has four core spray subsystems, while TSTF-582 assumes a low pressure ECCS design consisting of two LPCI subsystems and two core spray subsystems.
The licensee proposed the following variations from TSTF-582, Revision 0:
Variation 1 - Table 3.6.2m, Primary Coolant Isolation parameter, Low-Low Reactor Water Level: The minimum number of operable instrument channels per operable trip system is changed from 2 to 1 for cleanup and shutdown cooling systems. This change aligns the system channel logic of one-out-of-two taken twice. The licensee stated that the change corrects an error in Amendment 236.
Variation 2 - LCO Table 3.6.2m renumbered Note (b): The licensee proposed to add Note (b) to the shutdown and refuel columns for the Reactor Mode Switch Position in Which Function Must Be Operable. The requirements in renumbered Note (b) are part of current Note (c). The proposed Note (b) will be separated and attached to the mode applicability column.
Variation 3 - LCO 3.1.9, Specification f: This TS currently states in part, Specifications d and e not met The licensee states this is an error introduced in Amendment 236 to adopt TSTF-542. The proposed change corrects the logic from d and e to d or e.
This change will align with STS LCO 3.5.2, Condition E in TSTF-542.
Variation 4 - LCO Table 3.6.2m and 4.6.2 Note (c).2.c: In the letter dated June 4, 2021, new Note (c) has been revised to modify the LCO requirement for shutdown cooling and reactor water cleanup isolation instrumentation. This change is equivalent to TSTF-582 new Condition A in STS 3.3.5.2. The variation in Nine Mile Point 1 Note (c) is Action (c).2.c, which proposes to take the Action required by Specification 3.6.2a for that parameter. This action requires evaluation and potential actions of LCO 3.1.9 based on calculated drain time.
2.0 REGULATORY EVALUATION
The regulation at Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2) requires that TSs include limiting condition for operations (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 TSs include items in the category of SRs, 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.
The NRC staffs guidance for the review of TSs is provided in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision 3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP),
March 2010 (ADAMS Accession No. ML100351425). As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STSs for each of the light water reactor nuclear designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with NUREG-14331, as modified by NRC-approved travelers.
Traveler TSTF-582 revised the STSs related to RPV WIC to incorporate operating experience and to correct editorial errors in TSTF-542, Revision 2, Reactor Pressure Vessel Water Inventory Control (ADAMS Accession No. ML16074A448). The NRC approved TSTF-542, Revision 2, on December 20, 2016 (ADAMS Package Accession No. ML16343B066). The NRC staff subsequently approved TSTF-582 in its letter dated August 13, 2020 (ADAMS Accession No. ML20219A333). The TSTF-582 SE states that a licensee may adopt the STS changes approved in TSTF-582, if the licensee has already adopted the STS changes approved in TSTF-542.
3.0 TECHNICAL EVALUATION
3.1 Proposed TS Changes to Adopt TSTF-582 The NRC staff compared the licensees proposed TS changes identified in Section 1.1 of this SE against the changes approved in TSTF-582. In accordance with the SRP Chapter 16.0, the NRC staff determined that the STS changes approved in TSTF-582 are applicable to Nine Mile Point 1 TSs because the Nine Mile Point 1 is a BWR/2 and the NRC staff approved the TSTF-582 changes for BWR/4 designs (NUREG-1433), which is the most similar of the STS NUREGs to Nine Mile Point 1. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since the licensee adopted Traveler TSTF-542 on January 22, 2019 (Accession No. ML19008A454.) Therefore, the NRC staff concludes that the licensees proposed changes to the Nine Mile Point 1 TSs identified in Section 1.1 of this SE are acceptable in that they are consistent with TSTF-582 and the terms for use stated in the NRC staffs SE of TSTF-582.
The NRC staff finds that proposed changes to TS 1.34 definition and LCOs 3.1.9, 3.2.7, and Table 3.6.2m correctly specify the lowest functional capability or performance levels of equipment required for safe operation of the facility in accordance with 10 CFR 50.36(c)(2)(i).
Also, the NRC staff finds that proposed changes to the Actions of LCOs 3.1.9, LCO 3.2.7, and Table 3.6.2m are adequate remedial actions to be taken until each LCO can be met and provide adequate protection to the health and safety of the public, thereby satisfying 10 CFR 50.36(c)(2)(i).
The NRC staff finds that the proposed revisions to the SRs in SR 4.1.9 and SR Table 4.6.2m continue to provide acceptable 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 in accordance with 10 CFR 50.36(c)(3).
Thus, the proposed changes continue to meet the requirements of 10 CFR 50.36(c)(2)(i) and 10 CFR 50.36(c)(3) as discussed in Section 3.0 of the NRC staffs SE of TSTF-582.
3.2 Additional Proposed TS Changes Variation 1 - Table 3.6.2m, Primary Coolant Isolation parameter, Low-Low Reactor Water Level: The minimum number of operable instrument channels per operable trip system is 1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, General Electric, BWR/4 Plants, NUREG-1433, Volume 1, Specifications, and Volume 2, Bases, Revision 4.0, April 2012 (ADAMS Accession Nos. ML12104A192 and ML12104A193, respectively).
changed from 2 to 1 for cleanup and shutdown cooling systems. This change aligns the system channel logic of one-out-of-two taken twice. The licensee stated that the change corrects an error in Amendment 236.
This will apply for isolation valves that are credited for automatic isolation where credit is taken for isolation to prevent drain down. The reactor protection system trip has two channels and each channel has two identical subchannels. The outputs of the two subchannels are combined in a one-out-of-two logic, that is, an input signal on either or both of the independent subchannels will produce a logic channel trip. The outputs of the remaining two subchannels are likewise combined in a one-out-of-two logic, independent of the other logic channel. The outputs of the two logic channels are combined so that they both must be tripped to initiate a reactor trip or other protective action. Table 3.6.2m requires that the low-low reactor vessel water level instrumentation that initiates isolation of the main steam and cleanup and shutdown cooling system be operable with the reactor mode switch in the shutdown or refuel position. In the shutdown condition both trip systems (one channel in each) must be operable so long as shutdown cooling system integrity is maintained. If one channel is inoperable, the change is still is still acceptable because the other channel ensures availability of trip and isolation function for TSTF-582 conditions; therefore, the NRC staff finds Variation 1 acceptable.
Variation 2 - LCO Table 3.6.2m renumbered Note (b): The licensee proposed to add Note (b) to the shutdown and refuel columns for the Reactor Mode Switch Position in Which Function Must Be Operable. The requirements in renumbered Note (b) are part of current Note (c). The proposed Note (b) will be separated and attached to the mode applicability column. The NRC staff reviewed Variation 2 and finds the change acceptable because Note (b) referenced in the table aligns with TSTF-582 STS Table 3.3.5.2-1 new Footnote (a) and clarifies the applicability for the primary coolant isolation parameter.
Variation 3 - LCO 3.1.9, Specification f: This LCO currently states in part, Specifications d and e not met This is an error introduced in Amendment 236 to adopt TSTF-542. The proposed change corrects the logic from d and e to d or e. This change will align with STS LCO 3.5.2, Condition E in TSTF-542. The NRC staff reviewed Variation 3 and finds the change acceptable as it corrects a requirement reflecting the original intent per TSTF-542.
Variation 4 - LCO Table 3.6.2m and 4.6.2 Note (c).2.c: In the letter dated June 4, 2021, new Note (c) has been revised to modify the LCO requirement for shutdown cooling and reactor water cleanup isolation instrumentation. This change is equivalent to TSTF-582 new Condition A in STS 3.3.5.2. The variation in Nine Mile Point 1 Note (c) is Action (c).2.c, which proposes to take the action required by Specification 3.6.2a for that parameter. This action requires evaluation and potential actions of LCO 3.1.9 based on calculated drain time. The NRC staff reviewed this variation and found it to be consistent with the style and formatting of the Nine Mile Point 1 TS. The NRC staff finds Variation 4 acceptable because the addition directs the licensee to appropriate requirements in LCO 3.1.9 regarding appropriate actions for drain time calculations.
3.2.2 Editorial TS Changes The licensee noted that Nine Mile Point 1 TSs are custom and have different numbering and wording than the STS for the RPV WIC related TS. The NRC staff finds that the different TS numbering changes are acceptable because they are editorial revisions and do not substantively change TS requirements.
The following requirements were renumbered due to moved or deleted requirements:
SR 4.1.9 Specifications d and e become c and d. (page 79b of Nine Mile Point 1 TSs)
Table 3.6.2m parameter 2 is renumbered 1 (page 247c of Nine Mile Point 1 TSs)
Table 4.6.2m parameters 2 and 3 are renumbered 1 and 2, respectively (page 247e of Nine Mile Point 1 TSs)
Notes for Tables 3.6.2m and 4.6.2m: revised current Note (c) is renumbered (b) and a new Note (c) is added (page 247f of Nine Mile Point 1 TSs)
Finally, the NRC staff reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16.0 of the SRP and are therefore acceptable.
4.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
NOTICES AND ENVIRONMENTAL FINDINGS RELATED TO AMENDMENT NO. 246 TO FACILITY OPERATING LICENSE NO. DPR-63 EXELON GENERATION COMPANY, LLC NINE MILE POINT NUCLEAR STATION, UNIT 1 DOCKET NO. 50-220 Application (i.e., initial and supplements)
Safety Evaluation Date December 18, 2020 (ADAMS Accession No. ML20353A401)
June 4, 2021 (ADAMS Accession No. ML21155A222)
November 2, 2021
1.0 INTRODUCTION
By letter dated December 18, 2020, as supplemented by letter dated June 4, 2021, Exelon Generation Company, LLC (the licensee) requested changes to the technical specifications (TSs) for Nine Mile Point Nuclear Station, Unit 1, by license amendment request. The proposed changes would revise the TSs related to reactor pressure vessel (RPV) water inventory control (WIC) based on Technical Specifications Task Force Traveler (TSTF) 582, Revision 0, RPV WIC Enhancements (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML19240A260) and the associated Nuclear Regulatory Commission (NRC) staff safety evaluation of TSTF 582, Revision 0 (ADAMS Accession No. ML20219A333).
The supplement dated June 4, 2021, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC) staffs initial proposed no significant hazards consideration determination noticed in the Federal Register on May 18, 2021(86 FR 26955).
2.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment on September 6, 2021. The State official had no comments.
3.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in Title 10 of the Code of Federal Regulations (10 CFR) Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (86 FR 26955; May 18, 2021). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
ML21256A179 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LAiT NRR/DORL/LPL2-1/LA NAME RGuzman KEntz KGoldstein DATE 9/28/2021 9/14/2021 9/16/2021 OFFICE NRR/DSS/STSB/BC(A)
NRR/DSS/SNSB/BC NRR/DEX/EICB/BC NAME NJordan SKrepel MWaters DATE 9/3/2021 9/21/2021 10/1/2021 OFFICE OGC - NLO NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME STurk JDanna RGuzman DATE 10/25/2021 11/1//2021 11/2/2021