ML22033A310
| ML22033A310 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 03/04/2022 |
| From: | Richard Guzman NRC/NRR/DORL/LPL1 |
| To: | Rhoades D Constellation Energy Generation |
| Guzman R | |
| References | |
| EPID L-2021-LLA-0176 | |
| Download: ML22033A310 (33) | |
Text
March 4, 2022 Mr. David P. Rhoades Senior Vice President Constellation Energy Generation, LLC President and Chief Nuclear Officer Constellation Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
NINE MILE POINT NUCLEAR STATION, UNIT 2 - ISSUANCE OF AMENDMENT NO. 190, CHANGES TO REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL TECHNICAL SPECIFICATION REQUIREMENTS (EPID L-2021-LLA-0176)
Dear Mr. Rhoades:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has issued the enclosed Amendment No. 190 to Renewed Facility Operating License No. NPF-69 for the Nine Mile Point Nuclear Station, Unit 2 (Nine Mile Point 2). The amendment consists of changes to the Technical specifications (TSs) in response to your application dated September 30, 2021 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21273A017), as supplemented by letters dated December 16, 2021, and January 11, 2022 (ADAMS Accession No. ML21350A006 and ML22011A047, respectively).
The amendment revised the Nine Mile Point 2 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 (ADAMS Accession No. ML19240A260), the associated NRC staff safety evaluation of TSTF-582 (ADAMS Accession No. ML20219A333), and TSTF-583-T, Revision 0, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330).
D. Rhoades 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. 50-410
Enclosures:
- 1. Amendment No. 190 to NPF-69
- 2. Safety Evaluation
- 3. Notices and Environmental Findings cc: Listserv
NINE MILE POINT NUCLEAR STATION, LLC LONG ISLAND LIGHTING COMPANY CONSTELLATION ENERGY GENERATION, LLC DOCKET NO. 50-410 NINE MILE POINT NUCLEAR STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 190 Renewed License No. NPF-69
- 1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Exelon Generation Company, LLC dated September 30, 2021, as supplemented by letters dated December 16, 2021, and January 11, 2022, 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.
Enclosure 1
- 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. NPF-69 is hereby amended to read as follows:
2.C.(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 190, are hereby incorporated into this license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 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 Digitally signed by James James G. G. Danna Date: 2022.03.04 Danna 13:41:36 -05'00' 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: March 4, 2022
ATTACHMENT TO LICENSE AMENDMENT NO. 190 NINE MILE POINT NUCLEAR STATION, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-69 DOCKET NO. 50-410 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 4 4 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 1.1-4 1.1-4 3.3.5.2-1 3.3.5.2-1 3.3.5.2-2 3.3.5.2-2 3.3.5.2-3 3.3.5.2-3 3.3.5.2-4 3.3.5.2-4 3.3.5.2-5 3.3.5.2-5 3.3.6.1-3 3.3.6.1-3 3.3.6.1-4 3.3.6.1-4 3.3.8.1-1 3.3.8.1-1 3.5.1-1 3.5.1-1 3.5.2-2 3.5.2-2 3.5.2-3 3.5.2-3 3.5.2-4 3.5.2-4 3.5.2-5 3.5.2-5 3.6.1.3-1 3.6.1.3-1 3.6.1.3-9 3.6.1.3-9 3.8.2-4 3.8.2-4
(1) Maximum Power Level Constellation Energy Generation, LLC is authorized to operate the facility at reactor core power levels not in excess of 3988 megawatts thermal (100 percent rated power) in accordance with the conditions specified herein.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, as revised through Amendment No. 190 are hereby incorporated into this license. Constellation Energy Generation, LLC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3) Fuel Storage and Handling (Section 9.1, SSER 4)*
- a. Fuel assemblies, when stored in their shipping containers, shall be stacked no more than three containers high.
- b. When not in the reactor vessel, no more than three fuel assemblies shall be allowed outside of their shipping containers or storage racks in the New Fuel Vault or Spent Fuel Storage Facility.
- c. The above three fuel assemblies shall maintain a minimum edge-to-edge spacing of twelve (12) inches from the shipping container array and approved storage rack locations.
- d. The New Fuel Storage Vault shall have no more than ten fresh fuel assemblies uncovered at any one time.
(4) Turbine System Maintenance Program (Section 3.5.1.3.10, SER)
The operating licensee shall submit for NRC approval by October 31, 1989, a turbine system maintenance program based on the manufacturers calculations of missile generation probabilities.
(Submitted by NMPC letter dated October 30, 1989 from C.D. Terry and approved by NRC letter dated March 15, 1990 from Robert Martin to Mr. Lawrence Burkhardt, III).
- The parenthetical notation following the title of many license conditions denotes the section of the Safety Evaluation Report (SER) and/or its supplements wherein the license condition is discussed.
Renewed License No. NPF-69 Amendment 117 through 189 190
Definitions 1.1 1.1 Definitions (continued)
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 the top of the active fuel (TAF) seated in the RPV assuming:
a) The water inventory above the TAF 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 the TAF except:
- 1. Penetration flow paths connected to an intact closed system, or isolated by manual or automatic valves that are closed and administratively 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 the TAF 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 TAF 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.
(continued)
NMP2 1.1-4 Amendment 168, 179, 190
RPV Water Inventory Control Instrumentation 3.3.5.2 3.3 INSTRUMENTATION 3.3.5.2 Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation LCO 3.3.5.2 The RPV Water Inventory Control instrumentation for each Function in Table 3.3.5.2-1 shall be OPERABLE.
APPLICABILITY:
According to Table 3.3.5.2-1.
ACTIONS
NOTE -------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more channels A.1 Initiate action to place Immediately inoperable. channel in trip.
OR A.2.1 Declare associated Immediately penetration flow path(s) incapable of automatic isolation.
AND A.2.2 Initiate action to calculate Immediately DRAIN TIME.
NMP2 3.3.5.2-1 Amendment 168, 190
RPV Water Inventory Control Instrumentation 3.3.5.2 DELETED NMP2 3.3.5.2-2 Amendment 168, 190
RPV Water Inventory Control Instrumentation 3.3.5.2 SURVEILLANCE REQUIREMENTS
NOTES -----------------------------------------------------------
- 1. These SRs apply to each Function in Table 3.3.5.2-1.
- 2. When a channel is placed in an inoperable status solely for performance of required Surveillances, entry into associated Conditions and Required Actions may be delayed for up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> provided the associated Function or the redundant Function maintains ECCS initiation capability.
SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program NMP2 3.3.5.2-3 Amendment 168, 190
RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 1 of 2)
RPV Water Inventory Control Instrumentation DELETED NMP2 3.3.5.2-4 Amendment 168, 190
RPV Water Inventory Control Instrumentation 3.3.5.2 Table 3.3.5.2-1 (page 2 of 2)
RPV Water Inventory Control Instrumentation APPLICABLE MODES OR REQUIRED ALLOWABLE FUNCTION OTHER SPECIFIED CHANNELS VALUE CONDITIONS PER FUNCTION
- 1. RHR System Isolation (a) 2 in one 157.8 inches
- a. Reactor Vessel Trip system Water Level-Low, Level 3
- 2. Reactor Water Cleanup (RWCU) System Isolation
- a. Reactor Vessel (a) 2 in one 101.8 inches Water Level-Low Trip system Low, Level 2 (a) When automatic isolation of the associated penetration flow path(s) is credited in calculating DRAIN TIME.
NMP2 3.3.5.2-5 Amendment 168, 190
Primary Containment Isolation Instrumentation 3.3.6.1 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F. As required by F.1 Isolate the affected 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Required Action C.1 penetration flow and referenced in path(s).
Table 3.3.6.1-1.
G. As required by G.1 Isolate the affected 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Required Action C.1 penetration flow and referenced in path(s).
Table 3.3.6.1-1.
H. Required Action and H.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition F or AND G not met.
H.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> OR As required by Required Action C.1 and referenced in Table 3.3.6.1-1.
I. As required by I.1 Declare associated 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Required Action C.1 standby liquid and referenced in control (SLC)
Table 3.3.6.1-1. subsystem inoperable.
OR I.2 Isolate the Reactor 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Water Cleanup (RWCU)
System.
J. As required by J.1 Initiate action to Immediately Required Action C.1 restore channel to and referenced in OPERABLE status.
Table 3.3.6.1-1.
NMP2 3.3.6.1-3 Amendment 91, 186, 190
Primary Containment Isolation Instrumentation 3.3.6.1 DELETED NMP2 3.3.6.1-4 Amendment 91, 186, 190
LOP Instrumentation 3.3.8.1 3.3 INSTRUMENTATION 3.3.8.1 Loss of Power (LOP) Instrumentation LCO 3.3.8.1 The LOP instrumentation for each Function in Table 3.3.8.1-1 shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTE -------------------------------------------------------------
Separate Condition entry is allowed for each channel.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Place channel in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> channels inoperable. trip.
NOTE---------
Not applicable when trip capability is not maintained.
In accordance with the Risk Informed Completion Time Program B. Required Action and B.1 Declare associated DG Immediately associated Completion inoperable.
Time not met.
NMP2 3.3.8.1-1 Amendment 91, 186, 190
ECCS - Operating 3.5.1 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), RPV WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.1 ECCS - Operating LCO 3.5.1 Each ECCS injection/spray subsystem and the Automatic Depressurization System (ADS) function of six safety/relief valves shall be OPERABLE.
APPLICABILITY: MODE 1, MODES 2 and 3, except ADS valves are not required to be OPERABLE with reactor steam dome pressure 150 psig.
ACTIONS
NOTE --------------------------------------------------------------------
LCO 3.0.4.b is not applicable to High Pressure Core Spray (HPCS).
CONDITION REQUIRED ACTION COMPLETION TIME A. One low pressure ECCS A.1 Restore low pressure 7 days injection/spray ECCS injection/spray subsystem inoperable. subsystem to OPERABLE OR status.
In accordance with the Risk Informed Completion Time Program B. HPCS System B.1 Verify by administrative Immediately inoperable. means RCIC System is OPERABLE when RCIC is required to be OPERABLE.
AND B.2 Restore HPCS System 14 days to OPERABLE status.
OR In accordance with the Risk Informed Completion Time Program (continued)
NMP2 3.5.1-1 Amendment 91, 109, 168, 174, 186, 190
RPV Water Inventory Control 3.5.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME.
AND C.3 Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment (SGT) subsystem is capable of being placed in operation in less than the DRAIN TIME.
D. DRAIN TIME < 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. D.1 ----------NOTE------------
Required ECCS injection/spray subsystem or additional method of water injection shall be capable of operating without offsite electrical power.
Initiate action to establish Immediately an additional method of water injection with water sources capable of maintaining RPV water level > TAF for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
AND D.2 Initiate action to establish Immediately secondary containment boundary.
AND (continued)
NMP2 3.5.2-2 Amendment 91, 152, 168, 190
RPV Water Inventory Control 3.5.2 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be automatically or manually isolated from the control room.
AND Immediately D.4 Initiate action to verify one SGT subsystem is capable of being placed in operation.
E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to 36 Time of Condition C or hours.
D not met.
OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.2.1 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 (continued)
NMP2 3.5.2-3 Amendment 91, 152, 168, 190
RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.2 Verify, for a required low pressure ECCS In accordance with injection/spray subsystem, the suppression pool the Surveillance water level is 195 ft. Frequency Control Program SR 3.5.2.3 Verify, for a required High Pressure Core Spray In accordance with (HPCS) System, the: the Surveillance Frequency Control
- a. Suppression pool water level is 195 ft. Program OR
- b. Condensate storage tank B water level is 26.9 ft.
SR 3.5.2.4 Verify, for the required ECCS injection/spray In accordance with subsystem, locations susceptible to gas accumulation the Surveillance are sufficiently filled with water. Frequency Control Program SR 3.5.2.5 -----------------------------NOTE- ----------------------------
- 1. Operation may be through the test return line. In accordance with
- 2. Credit may be taken for normal system operation the Surveillance that satisfies this SR. Frequency Control
Program Operate the required ECCS injection/spray subsystem for 10 minutes.
(continued)
NMP2 3.5.2-4 Amendment 91, 150,152, 161, 168, 190
RPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.5.2.6 Verify each valve credited for automatically isolating In accordance with a penetration flow path actuates to the isolation the Surveillance position on an actual or simulated isolation signal. Frequency Control Program SR 3.5.2.7 -----------------------------NOTE------------------------------
Vessel injection/spray may be excluded.
Verify the required ECCS injection/spray subsystem In accordance with can be manually operated. the Surveillance Frequency Control Program NMP2 3.5.2-5 Amendment 91, 152, 168, 190
PCIVs 3.6.1.3 3.6 CONTAINMENT SYSTEMS 3.6.1.3 Primary Containment Isolation Valves (PCIVs)
LCO 3.6.1.3 Each PCIV and each Secondary Containment Bypass Leakage Valve shall be OPERABLE.
APPLICABILITY: MODES 1, 2, and 3.
ACTIONS
NOTES -----------------------------------------------------------
- 1. Penetration flow paths may be unisolated intermittently under administrative controls.
- 2. Separate Condition entry is allowed for each penetration flow path.
- 3. Enter applicable Conditions and Required Actions for systems made inoperable by PCIVs.
- 4. Enter applicable Conditions and Required Actions of LCO 3.6.1.1, "Primary Containment," when PCIV leakage results in exceeding overall containment leakage rate acceptance criteria.
CONDITION REQUIRED ACTION COMPLETION TIME A. -------------NOTE-------------- A.1 Isolate the affected 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> except Only applicable to penetration flow path for main steam penetration flow paths by use of at least line with two or more one closed and PCIVs. de-activated OR
automatic valve, closed manual valve, In accordance One or more blind flange, or with the Risk penetration flow paths check valve with flow Informed with one PCIV through the valve Completion Time inoperable except due secured. Program to leakage not within limit. AND (continued)
NMP2 3.6.1.3-1 Amendment 91, 156, 186, 190
PCIVs 3.6.1.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. (continued) E.3 Perform SR 3.6.1.3.6 Once per 92 days for the resilient following isolation seal purge exhaust valves closed to comply with Required Action E.1.
F. Required Action and F.1 Be in MODE 3. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion Time of Condition A, AND B, C, D, or E not met.
F.2 Be in MODE 4. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> NMP2 3.6.1.3-9 Amendment 91, 168, 186, 190
AC Sources - Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 -------------------------------- NOTE------------------------------
The following SRs are not required to be performed:
SR 3.8.1.3, SR 3.8.1.7, SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.14.
The following SRs are applicable for AC sources In accordance required to be OPERABLE: with applicable SRs SR 3.8.1.1 SR 3.8.1.2 SR 3.8.1.3 SR 3.8.1.4 SR 3.8.1.5 SR 3.8.1.6 SR 3.8.1.7 SR 3.8.1.8 SR 3.8.1.12 SR 3.8.1.14 NMP2 3.8.2-4 Amendment 91, 168, 190
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 190 TO FACILITY OPERATING LICENSE NO. NPF-69 CONSTELLATION ENERGY GENERATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT 2 DOCKET NO. 50-410 Application (i.e., initial and supplements) Safety Evaluation Date September 30, 2021 (ADAMS Accession March 4, 2022 No. ML21273A017) Principal Contributor to Safety December 16, 2021, and January 11, 2022 Evaluation (ADAMS Accession No. ML21350A006 and Khadijah West ML22011A047, respectively)
1.0 PROPOSED CHANGE
S Exelon Generation Company, LLC (the licensee at the time) requested changes to the technical specifications (TSs) for Nine Mile Point Nuclear Station, Unit 2 (Nine Mile Point 2) by license amendment request (LAR, application) dated September 30, 2021, as supplemented by letters dated December 16, 2021, and January 11, 2022. On February 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22032A333), Exelon Generation Company, LLC was renamed Constellation Energy Generation, LLC. 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, (TSTF-582) (ADAMS Accession No. ML19240A260), the associated U.S.
Nuclear Regulatory Commission (NRC) staff safety evaluation (SE) of TSTF-582 (ADAMS Accession No. ML20219A333), and TSTF-583-T, Revision 0, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330).
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. The TS definition of DRAIN TIME is the time it would take for the water inventory in and above the RPV to drain to the TAF.
Enclosure 2
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 2 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 1.1 would be revised to move the examples of common mode failure mechanisms to the TS Bases and delete seismic events.
In TS 1.1, DRAIN TIME definition, the exception from considering the DRAIN TIME for penetration flow paths isolated with manual or automatic valves 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 Actions of TS 3.3.5.2 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.
TS 3.3.5.2, Required Action B.2 requires calculating DRAIN TIME with a COMPLETION TIME of immediately. The Required Action would be renumbered as A.2.2 and revised to state, Initiate action to calculate DRAIN TIME.
TS 3.3.6.1, Primary Containment Isolation Instrumentation, Required Action J.2 would be deleted. This action is no longer applicable after adoption of TSTF-542.
TS 3.5.1 Actions Note, the first use of the acronym HPCS would be defined and the definition would be removed from Condition B.
In TS 3.5.2, the first use of the acronym SGT would be defined in Required Action C.3 and the acronym SGT would be used in Required Action D.4. In Required Action D.3, an option would be added to verify that a secondary containment penetration flow path automatically isolated.
TS 3.5.2 and TS 3.3.5.2 would be revised to eliminate the requirement for a manual emergency core cooling system (ECCS) initiation signal to start the required ECCS injection/spray subsystem, and to instead rely on manual valve alignment and pump start. TS 3.5.2 Surveillance Requirements (SRs) related to manual initiation using the ECCS signal (such as verifying automatic alignment of valves on an initiation signal) would be eliminated. Related to this change, the TS 3.3.5.2 functions, SRs, and Actions that only support manual initiation using an ECCS signal (including interlocks and minimum flow instruments) would be eliminated.
SR 3.5.2.6, that requires operating the required ECCS injection/spray subsystem for at least 10 minutes through the recirculation line would be modified by the addition of two Notes. The licensee proposed to delete the existing SR Note that states Not required to be met for ECCS pumps aligned for shutdown cooling. The first new Note would replace the existing SR that the ECCS subsystem be run through the recirculation line with a Note that states that operation may be through the test return line. The second
new Note would permit crediting normal operation of the low-pressure ECCS subsystem for performance of the SR.
The Applicability of TS 3.6.1.3, Primary Containment Isolation Valves (PCIVs), would be revised to delete the phrase, When associated instrumentation is required to be OPERABLE per Limiting Condition for Operation (LCO) 3.3.6.1, Primary Containment Isolation Instrumentation. This would make TS 3.6.1.3 only applicable in Modes 1, 2, and 3. Following adoption of TSTF-542, no functions in LCO 3.3.6.1 are applicable outside of Modes 1, 2, or 3. The Actions and SRs of TS 3.6.1.3 would be revised to reflect this change.
TS 3.8.2, AC [Alternating Current] Sources - Shutdown, SR 3.8.2.1, would be revised to not require SRs that test the ability of the automatic diesel generator to start in Modes 4 and 5. TSTF-542 eliminated the automatic ECCS initiation in Modes 4 and 5.
1.2 Additional Proposed TS Changes 1.2.1 Proposed TS Changes to Adopt TSTF-583-T The licensee proposed to make the following changes in accordance with TSTF-583-T, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330):
TS 3.3.8.1, Loss of Power (LOP) Instrumentation, would be revised to delete When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown. from the Applicability.
SR 3.8.2.1 would be revised to add SR 3.8.1.13 and SR 3.8.1.16 to the list of Nine Mile Point 2 TS 3.8.1 SRs that are not applicable under SR 3.8.2.1. The format of SR 3.8.2.1 would also be restructured to list the SRs that are still applicable, instead of listing the SRs that are not applicable.
1.2.2 Editorial Variations The licensee noted that Nine Mile Point 2 TSs have different numbering than standard technical specifications (STSs) for the RPV WIC related TS.
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 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 2 TSs because the Nine Mile Point 2 is a BWR/5 and the NRC staff approved the TSTF-582 changes for BWR/5 designs. The licensee meets the TSTF-582 SE provision for adoption of TSTF-582 since the licensee adopted Traveler TSTF-542 on March 28, 2018 (Accession No. ML18073A364). Therefore, the NRC staff concludes that the licensees proposed changes to the Nine Mile Point 2 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 1.1 definition and LCOs 3.3.5.2, 3.3.6.1, 3.5.2, and 3.6.1.3 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 3.3.5.2, 3.3.6.1, 3.5.2, and 3.6.13 are adequate remedial actions to be taken until each LCO can be met provide 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 TS 3.3.5.2, 3.5.2, 3.6.1.3, and 3.8.2 continue to provide 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).
The NRC staff noted that the licensees proposed deletion of the existing Note for SR 3.5.2.6 and its replacement with two Notes was not consistent with the TS changes of TSTF-582. The 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).
staff issued a request for additional information (RAI) to the licensee dated November 16, 2021 (ADAMS Accession No. ML21320A347). In their letter dated December 16, 2021, the licensee stated that the deletion of the existing Note is a variation to TSTF-582 and updated its submittal accordingly. In its response to RAI 2.a, the licensee stated that the existing Note Not required to be met for ECCS pumps aligned for shutdown cooling would be replaced by new Note 2 in TSTF-582, SR 3.5.2.6, which states credit may be taken for normal system operation that satisfies this SR. The NRC staff determined that these Notes have a similar meaning and the change aligns the plant specific TS with the TSTF-582. The NRC staff finds this variation acceptable because replacing the existing Note is an editorial, non-technical change and aligns standard TS language.
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 3.2.1 Proposed TS Changes to Adopt TSTF-583-T 3.2.1.1 TS 3.3.8.1, Applicability The licensee stated that TS 3.8.2 does not require automatic start and loading of a diesel generator (DG) within 10 seconds on an ECCS initiation signal or a loss of offsite power signal.
Currently, TS 3.3.8.1, Loss of Power (LOP) Instrumentation, is applicable in Modes 1, 2, and 3, and when the associated DG is required to be operable by TS 3.8.2. The NRC staff confirmed that TS 3.8.2 no longer requires automatic start and loading of a DG on an LOP signal. The NRC staff finds it acceptable to revise the Applicability of LCO 3.3.8.1 by deleting When the associated diesel generator is required to be OPERABLE by LCO 3.8.2, AC Sources - Shutdown, because the LOP instrumentation that generates the LOP signal does not need to be operable when the DG is required to be operable by TS 3.8.2. Therefore, the NRC staff concludes that the LCO applicability changes will continue to provide for the lowest functional capability or performance levels of equipment required for safe operation of the facility and, therefore, meet the LCO requirements of 10 CFR 50.36(c)(2).
3.2.1.2 SR 3.8.2.1 LCO 3.8.2, AC Sources - Shutdown, requires one offsite circuit and one DG capable of supplying one division of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.8, Distribution Systems-Shutdown, to be operable in shutdown conditions. The existing SR 3.8.2.1 lists the TS 3.8.1 SRs that are applicable in shutdown conditions with some exceptions.
Nine Mile Point 2 TS SR 3.8.1.13 and SR 3.8.1.18 require that the DG starts from standby or hot conditions, respectively, and achieve required voltage and frequency within 10 seconds and required steady state voltage and frequency ranges. The 10-second start requirement associated with the DG automatic start supports the assumptions in the design basis loss-of-coolant accident analysis. The NRC staff confirmed that 10-second timing is not required during a manual DG start to respond to a draining event, which has a minimum DRAIN TIME of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. In addition, SR 3.8.1.2, which requires the DG to start from standby conditions and achieve the required steady state voltage and frequency ranges, is applicable under
SR 3.8.2. The NRC staff finds that the SR 3.8.1.13 and SR 3.8.1.18 testing for the DGs capability to achieve required steady state voltage and frequency ranges will be performed in SR 3.8.1.2 since SR 3.8.1.2 provides the test for this DG capability. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.13 and SR 3.8.1.18 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
TS SR 3.8.1.16 states, Verify interval between each sequenced load block, for the Division 1 and 2 DGs only, is 90% of the design interval for each automatic load sequence time delay relay. This SR verifies that a minimum 90 percent load sequence time interval tolerance between each sequenced load block when loads are sequentially connected to the engineered safety features (ESF) bus by relay logic schemes that perform a function equivalent to a load sequencer while the DG is tied to the ESF bus. TS 3.5.2 requires manual starting of the equipment for water injection to respond to a draining event so that the DG will be manually loaded during a draining event. No other postulated events require automatic loading of the DG during shutdown conditions. The NRC staff confirmed that with respect to SR 3.8.16, the relay logic schemes that perform a function equivalent to a load sequencer are used for the automatic loading of the DG and are not used during a manual loading of the DG. Therefore, the NRC staff finds it acceptable to add SR 3.8.1.16 to the list of TS 3.8.1 SRs that are not applicable under SR 3.8.2.1.
Additionally, the licensee proposed to recast SR 3.8.2.1 from a listing of exceptions (i.e., a list of TS 3.8.1 SRs that do not need to be performed) to a listing of the SRs that need to be performed to demonstrate the operability of the offsite and onsite AC power sources during shutdown conditions. The NRC staff confirmed that the list of SRs that need to be performed during shutdown conditions are correctly listed in SR 3.8.2.1. The NRC staff finds that the proposed revision of SR 3.8.2.1 is acceptable because it is an editorial clarification and does not substantively change TS requirements.
The NRC staff finds that the proposed changes to revise SR 3.8.2.1 are acceptable because the remaining applicable SRs will continue to demonstrate the operability of the required AC power sources and, as such, ensure the availability of the AC power required to operate the plant in a safe manner and mitigate postulated events during shutdown conditions. Therefore, the NRC staff finds the proposed changes to SR 3.8.2.1 are acceptable because the changes continue to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the associated LCO will continue to be met in accordance with 10 CFR 50.36(c)(3).
3.2.2 Editorial The licensee noted that Nine Mile Point 2 TSs have different numbering than STS for the RPV WIC related TS. The NRC staff finds that the different TS numbering changes are acceptable because they are editorial clarifications and do not substantively change TS requirements.
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. 190 TO FACILITY OPERATING LICENSE NO. NPF-69 CONSTELLATION ENERGY GENERATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT 2 DOCKET NO. 50-410 Application (i.e., initial and supplements) Safety Evaluation Date September 30, 2021 (ADAMS Accession March 4, 2022 No. ML21273A017)
December 16, 2021 and January 11, 2022 (ADAMS Accession No. ML21350A006 and ML22011A047, respectively)
1.0 INTRODUCTION
By [[letter::NMP2L2780, Application to Revise Technical Specifications to Adopt TSTF-582, Revision 0, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements|letter dated September 30, 2021]], as supplemented by letters dated December 16, 2021, and January 11, 2022, Exelon Generation Company, LLC (the licensee at the time), requested changes to the technical specifications (TSs) for Nine Mile Point Nuclear Station, Unit 2, by license amendment request. On February 1, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22032A333), Exelon Generation Company, LLC was renamed Constellation Energy Generation, LLC. 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 (ADAMS Accession No. ML19240A260), the associated U.S. Nuclear Regulatory Commission (NRC, the Commission) staff safety evaluation of TSTF-582, Revision 0 (ADAMS Accession No. ML20219A333), and TSTF-583-T, Revision 0, TSTF-582 Diesel Generator Variation (ADAMS Accession No. ML20248H330).
The supplemental letters dated December 16, 2021, and January 11, 2022, 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 November 30, 2021(86 FR 67989).
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 January 31, 2022. 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 Enclosure 3
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 67989; November 30, 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.
ML22033A310 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NAME RGuzman KEntz VCusumano DATE 2/9/2022 2/7/2022 1/25/2022 OFFICE NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME JDanna RGuzman DATE 3/4/2022 3/4/2022