NMP1L3551, License Amendment Request - Modification of Technical Specifications Surveillance Requirements 4.3.6.a with Correction to Fully Adopt TSTF-425, Revision 3
| ML23291A246 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 10/18/2023 |
| From: | David Gudger Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NMP1L3551 | |
| Download: ML23291A246 (1) | |
Text
200 Exelon Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 NMP1L3551 October 18, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220
SUBJECT:
License Amendment Request - Modification of Technical Specifications Surveillance Requirement 4.3.6.a with Correction to Fully Adopt TSTF-425, Revision 3 In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR 50.90), "Application for amendment of license, construction permit, or early site permit,"
Constellation Energy Generation, LLC (CEG) is submitting a request for an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No.
DPR-63 for Nine Mile Point Nuclear Station Unit 1 (NMP1).
The proposed amendment would modify NMP1 TS by relocating Surveillance Requirement (SR) 4.3.6.a to the licensee-controlled Surveillance Frequency Control Program (SFCP).
The SFCP was previously implemented at NMP1 by Amendment 222. SR 4.3.6.a was within the scope of Amendment 222; however, it was not fully revised in the adoption of TSTF-425, Revision 3, to meet the SFCP in accordance with Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, and Risk-Informed Method for Control of Surveillance Frequencies." provides a description and evaluation of the proposed change. Attachment 2 provides the existing NMP1, TS page marked up to show the proposed change. The TS Bases page was previously revised to reflect Amendment 222 and is provided in Attachment 2 for information only.
There are no regulatory commitments contained in this letter.
CEG requests approval of the proposed license amendment by October 30, 2024. Once approved, the amendment shall be implemented within 60 days.
The proposed changes have been reviewed and approved by the Plant Operations Review Committee, in accordance with the CEG Quality Assurance Program.
License Amendment Request Modification to SR 4.3.6.a Docket No. 50-220 October 18, 2023 Page 2 In accordance with 10 CFR 50.91, "Notice for Public Comment; State Consultation," a copy of this application, with attachments, is being provided to the designated State Official.
Should you have any questions or require additional information regarding this submittal, please contact Ron Reynolds at (267) 533-5698.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of October 2023.
Respectfully, David T. Gudger Senior Manager, Licensing Constellation Energy Generation, LLC Attachments: 1. Evaluation of Proposed Change
- 2. Proposed Technical Specification Page Change cc:
USNRC Region I Regional Administrator w/attachments USNRC Senior Resident Inspector - NMP USNRC Project Manager, NRR - NMP A. L. Peterson, NYSERDA B. Frymire, NYSPSC
ATTACHMENT 1 License Amendment Request Nine Mile Point Nuclear Station, Unit 1 Docket No. 50-220 EVALUATION OF PROPOSED CHANGE CONTENTS
Subject:
Modification of Technical Specifications Surveillance Requirement 4.3.6.a with Correction to Fully Adopt TSTF-425, Revision 3 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusions
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
License Amendment Request Modification to SR 4.3.6.a Page 1 of 4 Docket No. 50-220 Evaluation of Proposed Change 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Constellation Energy Generation, LLC (CEG) requests an amendment to Renewed Facility Operating License No. DPR-63 for Nine Mile Point Nuclear Station, Unit 1 (NMP1).
The proposed amendment would modify NMP1 TS by relocating Surveillance Requirement (SR) 4.3.6.a to the licensee-controlled Surveillance Frequency Control Program (SFCP). Exelon submitted a License Amendment Request (LAR) on May 12, 2015 (ML15134A232) (Reference
- 1) to adopt TSTF-425, Revision 3 (Reference 2), and received approved Amendment 222 (ML16081A256) (Reference 3) on May 31, 2016. SR 4.3.6.a was within the scope of Reference 3; however, it was not fully revised in Reference 1 for the adoption of TSTF-425 to meet the SFCP in accordance with Nuclear Energy Institute (NEI) 04-10, "Risk-Informed Technical Specifications Initiative 5b, and Risk-Informed Method for Control of Surveillance Frequencies" (Reference 4).
2.0 DETAILED DESCRIPTION SR 4.3.6.a Currently, NMP1 TS SR 4.3.6.a, Vacuum Relief, states:
In accordance with the Surveillance Frequency Control Program and following any release of energy to the suppression chamber, each suppression chamber-drywell vacuum breaker shall be exercised. Operability of valves, position switches, and position indicators and alarms shall be verified monthly and following any maintenance on the valves and associated equipment.
This SR was revised and implemented into NMP1 TS as part of Reference 3. The change incorporated the SFCP into the first sentence. However, the associated change to the second sentence of the SR was inadvertently missed. As a result, the first sentence states, "In accordance with the Surveillance Frequency Control Program" and the second sentence of SR 4.3.6.a contains the phrase, "shall be verified monthly" The proposed amendment would revise SR 4.3.6.a to read as follows:
"In accordance with the Surveillance Frequency Control Program and following any release of energy to the suppression chamber, each suppression chamber-drywell vacuum breaker shall be exercised. Operability of valves, position switches, and position indicators and alarms shall be verified in accordance with the Surveillance Frequency Control Program and following any maintenance on the valves and associated equipment.
contains TS page 153 marked-up to show the proposed change to SR 4.3.6.a.
License Amendment Request Modification to SR 4.3.6.a Page 2 of 4 Docket No. 50-220 Evaluation of Proposed Change
3.0 TECHNICAL EVALUATION
The control of changes to the relocated Surveillance Frequencies will be in accordance with the SFCP approved for use at NMP1 by Reference 3. The proposed change in this License Amendment Request (LAR) to SR 4.3.6.a will complete the partial change made to the SR by Reference 3. The inclusion of SR 4.3.6.a to the SFCP ensures that Surveillance Requirements specified in the TS are performed at intervals sufficient to ensure the associated Limiting Conditions for Operation are met and that the frequency is fully relocated to a licensee-controlled document. In addition,
- a. The SFCP contains a list of Frequencies of those SRs for which the Frequency is controlled by the program.
- b. Changes to the Frequencies listed in the SFCP shall be made in accordance with Reference 4.
Reference 4 provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria A description of the proposed change and its relationship to applicable regulatory requirements is provided in TSTF-425, Revision 3, (ML090850642) and the NRCs Safety Evaluation in NMP1 Amendment 222. CEG has concluded that the relationship of the proposed change to the applicable regulatory requirements is applicable to NMP1.
4.2 Precedent NMP1 License Amendment 222, dated May 31, 2016 (Reference 2) (ML16081A256) 4.3 No Significant Hazards Consideration CEG has evaluated the proposed change, using the criteria in 10 CFR 50.92, and has determined that the proposed change does not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration.
- 1.
Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No The proposed change relocates the specified Frequencies for periodic Surveillance Requirements to licensee control under the Surveillance Frequency Control Program.
Surveillance Frequencies are not an initiator to any accident previously evaluated. As a
License Amendment Request Modification to SR 4.3.6.a Page 3 of 4 Docket No. 50-220 Evaluation of Proposed Change result, the probability of any accident previously evaluated is not significantly increased.
The systems and components required by the Technical Specifications for which the Surveillance Frequencies are relocated are still required to be operable, meet the acceptance criteria for the Surveillance Requirements, and be capable of performing any mitigative function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly increased.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2.
Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No No new or different accidents result from utilizing the proposed change. The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. In addition, the change does not impose any new or different requirements.
The change does not alter assumptions made in the safety analysis. The proposed change is consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3.
Does the proposed change involve a significant reduction in a margin of safety?
Response: No The proposed change is administrative in nature, does not negate any existing requirement, and does not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analysis. As such, there are no changes being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. Margins of safety are unaffected by relocation of the surveillance test intervals to a licensee-controlled program.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, CEG concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c),
and accordingly, a finding of no significant hazards consideration is justified.
License Amendment Request Modification to SR 4.3.6.a Page 4 of 4 Docket No. 50-220 Evaluation of Proposed Change 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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 the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
CEG has determined that the proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or would change an inspection or surveillance requirement. However, the proposed change does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed change.
6.0 REFERENCES
- 1. Letter from J. Barstow, Exelon Generation Company, LLC (Exelon), to Document Control Desk, Nuclear Regulatory Commission, "Application for Technical Specifications Change regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated May 12, 2015 (ML15134A232).
- 2. TSTF-425, Revision 3, "Relocate Surveillance Frequencies to Licensee Control -
RITSTF Initiative 5b," dated March 18, 2009 (ML090850642).
- 3. Letter from B. Mozafari (Senior Project Manager Nuclear Regulatory Commission) to B. Hanson (President and CNO Exelon), "Nine Mile Point Nuclear Station, Unit 1 -
Issuance of Amendment RE: Adoption of Technical Specification Task Force Traveler 425, Revision 3 (CAC No. MF6061)," dated May 31, 2016 (ML16081A256).
- 4. NEI 04-10, Revision 1, "Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies," dated April 2007 (ML071360456).
ATTACHMENT 2 License Amendment Request Nine Mile Point Nuclear Station, Unit 1 Docket No. 50-220 PROPOSED TECHNICAL SPECIFICATION PAGE CHANGE TS Page 153 (TS Bases page 158 is attached for information only to provide clarity of change to SR 4.3.6.a approved by Amendment 222)
3.3.6 LIMITING CONDITION FOR OPERATION VACUUM RELIEF Applicability:
Applies to the operational status of the primary containment vacuum relief system.
Objective:
To assure the capability of the vacuum relief system in the event of a loss-of-coolant accident to:
- a.
Equalize pressures between the drywell and suppression chamber, and
- b.
Maintain containment pressure above the vacuum design values of the drywell and suppression chamber.
Specification:
- a.
When primary containment is required, all suppression chamber - drywell vacuum breakers shall be operable except during testing and as stated above. Suppression chamber - drywell vacuum breakers shall be considered operable if:
(1) The valve is demonstrated to open fully with the applied force at all valve positions not exceeding that equivalent to 0.5 psi acting on the suppression chamber face of the valve disk.
AMENDMENT NO. 442, 222 4.3.6 SURVEILLANCE REQUIREMENT VACUUM RELIEF Applicability:
Applies to the periodic testing of the vacuum relief system.
Objective:
To assure the operability of the containment vacuum relief system to perform its intended functions.
Specification:
- a.
Periodic Operability Tests In accordance with the Surveillance Frequency Control Program and following any release of energy to the suppression chamber, each suppression chamber -
drywell vacuum breaker shall be exercised.
Operability of valves, position switches, and position indicators and alarms shall be verified monthly and following any maintenance on the valves and associated equipment.
153 in accordance with the Surveillance Frequency Control Program
BASES FOR 3.3.6 AND 4.3.6 VACUUM RELIEF Each drywell-suppression chamber vacuum breaker is equipped with two independent switches to indicate the opening of the valve disk.
Redundant control room alarms are provided to permit detection of any drywell-suppression chamber vacuum breaker opening in excess of the described allowable limits. The containment design has been examined to establish the allowable bypass area between the drywell and suppression chamber as 0.053 square feet.
The limit on each individual valve will be set such that with all valves at their limit, the maximum value of cumulative leakage will not exceed the maximum allowable. The value will be at approximately 0.06 inch of disk travel off its seat and will be alarmed in the control room.
The purpose of the vacuum relief valves is to equalize the pressure between the drywell and suppression chamber and between the suppression chamber and reactor building so that the structural integrity of the containment is maintained.
The vacuum relief system from the pressure suppression chamber to the reactor building consists of three vacuum relief breakers (3 parallel sets of 2 valves in series). Operation of either system will maintain the pressure differential less than 1 psig; the external pressure is 2 psig.
The leak rate testing program is based on AEC guidelines for development of leak rate testing and surveillance schedules for reactor containment vessels.
Surveillance of the suppression chamber-reactor building vacuum breakers consists of operability checks and leakage tests (conducted as part of the containment leak-tightness tests). These vacuum breakers are normally in the closed position and open only during tests or an accident condition. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
In accordance with the Surveillance Frequency Control Program, a leak rate test shall be performed to verify that significant leakage flow paths do not exist between the drywell and suppression chamber. The drywell pressure will be increased by approximately 1 psi with respect to the suppression pool pressure and then held constant. The subsequent suppression chamber transient will be monitored with a sufficiently sensitive pressure instrument. If the drywell pressure cannot be increased by 1 psi over the suppression chamber pressure, it would indicate existence of a significant leakage path which will be identified and eliminated before further drywell vacuum breaker testing.
AMENDMENT NO. -142, Revision 41 (222) 158