NMP2L2718, Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2

Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, Revision 2

ML19346F427
Person / Time
Site:	Nine Mile Point
Issue date:	12/12/2019
From:	Rafferty-Czincila S Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP2L2718
Download: ML19346F427 (5)

Text

200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 NMP2L2718 December 12, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-41 O

Subject:

Supplemental Information No.1 for Nine Mile Point Nuclear Station, Unit 2, to Adopt TSTF-505, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," Revision 2

References:

1. Letter from D. Gudger (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, "Provide Risk- Informed Extended Completion Times - RITSTF Initiative 4b," dated October 31, 2019

2. Letter from M. Marshall (Senior Project Manager, U.S Nuclear Regulatory Commission) to R. Reynolds (Exelon Generation Company, LLC), "Nine Mile Point Nuclear Station, Unit 2 - Supplemental Information Needed for Acceptance of Requested Licensing Action Re: Adoption of Risk-Informed Completion Times (EPID L-2019-LLA-0234) " dated December 5, 2019 By letter dated October 31, 2019 (Reference 1), Exelon Generation Company, LLC (Exelon) requested to change the Nine Mile Point Nuclear Station, Unit 2 (NMP2) Technical Specifications (TS). The proposed amendment would modify TS requirements to permit the use of Risk Informed Completion Times in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," (ADAMS Accession No. ML18183A493).

In a letter dated December 5, 2019, the NRC requested Supplemental Information to support their acceptance review of Reference 1. The acceptance review is performed to determine if there is sufficient information in scope and depth to allow the NRC staff to complete its detailed technical review. The letter states that bullets e and f of the proposed TS Administrative Section

U.S. Nuclear Regulatory Commission Supplemental Information TSTF-505, Risk- Informed Extended Completion Times Docket No. 50-41 O December 12, 2019 Page 2 5.5.15, "Risk Informed Completion Time Program," provided in Attachment 2 of Reference 1 differs from the wording in the NRG-approved TSTF-505, Revision 2 and that this variation is not identified nor justified in Reference 1. This letter requests supplemental information to justify the variation. to this letter provides the revised TS markups to address the requested supplemental information. The insert for TS page 5.5-13 is revised to be aligned with the NRG-approved TSTF-505, Revision 2. The insert for TS page 5.6-4 is deleted; therefore, this TS page is removed from the application. The information provided in Attachment 1 to this letter supersedes the information provided in Attachment 2 of Reference 1 for TS pages 5.5-13 and 5.6-4 and their associated inserts. All other information in Attachment 2 of Reference 1 remains unchanged.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The supplemental information provided in this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the supplemental information provided in this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained in this response.

If you should have any questions regarding this submittal, please contact Ron Reynolds at 610-765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 121h day of December 2019.

Respectfully, Attachment 1: Revised Technical Specification Marked-Up Pages cc: USNRC Region I Regional Administrator w/attachments USNRC Senior Resident Inspector - NMP USNRC Project Manager, NRA- NMP "

A. L. Peterson, NYSERDA

ATTACHMENT 1 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License NPF-69 Docket No. 50-410 PROPOSED TECHNICAL SPECIFICATION MARKED-UP PAGES TS Pages 5.5-13

• 5.6-4

(*as a result of the supplemental information provided in this letter TS page 5.6-4 is removed from the application)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.13 Control Room Envelope Habitability Program (continued)

e. The quantitative limits on unfiltered air inleakage into the CRE. These limits shall be stated in a manner to allow direct comparison to the unfiltered air inleakage measured by the testing described in paragraph c.

The unfiltered air inleakage limit for radiological challenges is the inleakage flow rate assumed in the licensing basis analyses of OBA consequences.

Unfiltered air inleakage limits for hazardous chemicals must ensure that exposure of CRE occupants to these hazards will be within the assumptions in the licensing basis.

f. The provisions of SR 3.0.2 are applicable to the Frequencies for assessing CRE habitability, determining CRE unfiltered inleakage, and measuring CRE pressure and assessing the CRE boundary as required by paragraphs c and d, respectively.

5.5.14 Surveillance Frequency Control Program This program provides controls for the Surveillance Frequencies. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequency listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequency," Revision 1.

c. The provision of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

Insert NMP2 5.5-13 Amendment .:t-26, 152

INSERT 5.5.15 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, "Risk-Managed Technical Specifications (RMTS) Guidelines."

The program shall include the following:

a. The RICT may not exceed 30 days;

b. A RICT may only be utilized in MODE 1, 2;

c. When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3. Revising the RICT is not required If the plant configuration change would lower plant risk and would result in a longer RICT.

d. For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1. Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e. The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support License Amendment No. [xxx], or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.