NMP2L2894, Exemption Request from Certain Requirements of 10 CR 50, Appendix J
| ML25029A181 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/29/2025 |
| From: | Knowles J Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NMP2L2894 | |
| Download: ML25029A181 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.12 10 CFR 50.90 NMP2L2894 January 29, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410
Subject:
Exemption Request from Certain Requirements of 10 CFR 50, Appendix J, for Nine Mile Point Nuclear Station, Unit 2 License Amendment Request to Revise Surveillance Requirement (SR) 3.6.1.3.12 to a Reduced Test Pressure and Corresponding Leakage Rate for Main Steam Isolation Valves In accordance with 10 CFR 50.12, "Specific exemptions," Constellation Energy Generation, LLC (CEG) requests an exemption from the requirements of 10 CFR 50, Appendix J, Paragraph III.C.2 for the Nine Mile Point Nuclear Station, Unit 2 (NMP2). Paragraph III.C.2 requires leak rate testing of the Main Steam Isolation Valves (MSIV's) at the peak calculated containment pressure related to the design basis accident. Continued compliance results in undue costs, and increased dose and industrial hazards that are significantly more than those incurred by other similarly situated plants. An exemption is requested to allow leak rate testing of the MSIV's at a reduced pressure.
In addition, and in accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," CEG requests approval of proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for NMP2.
The proposed TS change will revise the MSIV test pressure value from 40 psig to 25 psig in TS Surveillance Requirement (SR) 3.6.1.3.12. The proposed reduction in test pressure would also require an adjustment to the maximum allowable leakage through each MSIV to account for the change in test pressure. The current TS maximum allowable leakage through each MSIV of 50 standard cubic feet per hour (SCFH) when tested at 40 psig.
The proposed change will adjust the maximum allowable leakage to 39 SCFH when tested at 25 psig. This change will allow for MSIV testing by pressurizing between the inboard and outboard MSIVs simultaneously at the lower pressure of 25 psig to allow test conditions to be met and will provide an alternative to testing the inboard valves in the forward (accident) direction. Additionally, testing of the inboard MSIVs in the accident direction would require the local leak rate test (LLRT) to be conducted inside the drywell as opposed to outside the drywell in the MSIV room, subjecting personnel conducting the test to higher radiation doses.
Nine Mile Point, Unit 2 10 CFR 50, Appendix J, Exemption Request 10 CFR 50.90, License Amendment Request January 29, 2025 Page 2 This submittal contains the following two enclosures: Enclosure 1 provides the Request for Exemption to 10 CFR 50, Appendix J, Paragraph III.C.2. Enclosure 2 provides the License Amendment Request which includes the evaluation supporting the proposed change, proposed TS markup, and proposed TS Bases markup.
CEG request approval of the requested exemption and License Amendment Request by January 30, 2026, to support the upcoming refuel outage N2R20.
The proposed change has been reviewed by the NMP Plant Operations Review Committee in accordance with the requirements of the CEG Quality Assurance Program.
There are no regulatory commitments contained in this submittal.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), CEG is notifying the State New York of this application for exemption and license amendment by transmitting a copy of this letter and its enclosures to a designated State Official.
If you have any questions or require additional information, please contact Ron Reynolds at (267) 533-5698.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of January 2025.
Respectfully, Justin W. Knowles Sr. Manager, Licensing Constellation Energy Generation, LLC
Enclosures:
- 1. Constellation Request for Exemption from Certain Requirements of 10 CFR 50, Appendix J, for Nine Mile Point, Unit 2
- 2. Constellation Request for License Amendment to Revise Surveillance Requirement (SR) 3.6.1.3.12, for Nine Mile Point, Unit 2 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 A. Kauk, NYSPSC
-05'00'
ENCLOSURE 1 CONSTELLATION REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION, UNIT2
ENCLOSURE 1 CONSTELLATION REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION UNIT 2 Page 1 of 5 I. SPECIFIC EXEMPTION REQUEST Pursuant to 10 CFR 50.12, "Specific exemptions," Constellation Energy Generation, LLC (CEG) requests an exemption from the requirements of 10 CFR 50, Appendix J, Paragraph III.C.2, for the Nine Mile Point Nuclear Station, Unit 2 (NMP2). Paragraph III.C.2 requires leak rate testing of the Main Steam Isolation Valves (MSIV's) at the peak calculated containment pressure related to the design basis accident. An exemption is requested to allow leak testing of the MSIV's at reduced pressure. Continued compliance results in a increased dose to workers and industrial hazards that are significantly more than those incurred by others similarly situated plants.
The purpose of 10 CFR 50, Appendix J, tests are to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases; and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment. The alternative measures proposed in the discussion below, in lieu of the applicable Appendix J, Type C test, will meet the purpose of the regulation.
II. BASIS FOR EXEMPTION REQUEST In accordance with 10 CFR 50.12(a)(1), the NRC may, upon application by an interested person or upon its own initiative, grant exemptions from the requirements of the regulations of this part as it determines authorized by law and will not present an undue risk to the public and are consistent with the common defense and security.
a) Authorized by Law If the criteria established in 10 CFR 50.12(a) are satisfied, and if no other prohibition of law exists to preclude the activities which would be authorized by the requested exemption, the Commission is authorized by law to grant the exemption request. Since, as demonstrated herein, the requested exemption meets the applicable criteria and there is no legal prohibition to its grant, the Commission is authorized by law to grant the exemption.
b) Will not Present an Undue Risk to the Public Health and Safety The proposed local leak rate testing of the MSIV's, in lieu of the specified Appendix J requirements, does not present undue risk to the public health and safety because the proposed alternative testing will equally determine the condition of the MSIV's and their ability to maintain containment isolation integrity during an accident.
ENCLOSURE 1 CONSTELLATION REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION UNIT 2 Page 2 of 5 c) Consistent with the Common Defense and Security The common defense and security are not endangered by this exemption request.
The following NMP2-specific information is being provided to demonstrate that this exemption is otherwise in the public interest.
In contrast, approval of the referenced exemption request supports the continued safe, efficient, and cost-effective operation of NMP2 and is therefore in the publics interest.
Technical Justification Two special circumstances of the type described in 10 CFR 50.12(a)(2) are present in the request under consideration in that:
(a) the application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule [10 CFR 50.12(a)(2)(ii)], and (b)
The exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption [10 CFR 50.12(a)(2)(iv)].
Special Circumstance (a)(2)(ii) is met because application of the testing requirements in Appendix J in for NMP2 would not serve the underlying purpose of the rule and is not necessary to achieve the underlying purpose of the rule. The purpose of 10 CFR 50, Appendix J tests are to assure that (a) leakage through the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases; and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment, and systems and components penetrating primary containment. The alternative measures proposed in the discussion below, in lieu of the applicable Appendix J, Type C test, will meet the purpose of the regulation.
10 CFR 50, Appendix J, Paragraph III.C.2, requires leak rate testing of the MSIVs at the peak calculated containment pressure related to the design basis accident. An exemption is requested to allow leak testing of the MSIVs at reduced pressure. The MSIV's (Y-pattern, globe valve) for NMP2 are as follows:
ENCLOSURE 1 CONSTELLATION REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION UNIT 2 Page 3 of 5 Penetration #
Inboard Valve #
Outboard Valve #
Z-1A 2MSS*AOV6A 2MSS*AOV7A Z-1B 2MSS*AOV6B 2MSS*AOV7B Z-1C 2MSS*AOV6C 2MSS*AOV7C Z-1D 2MSS*AOV6D 2MSS*AOV7D Two MSIVs are welded in a horizontal run of each of the four Main Steam Lines. One valve is as close as possible to the inside of primary containment and the other is just outside the containment. The MSIVs are angled in the main steam line to afford better sealing in the direction of the accident.
Due to the orientation of the MSIVs on the Main Steam Lines, when inboard MSIVs at NMP2 are tested in the forward (accident) direction with the reactor vessel head removed, installation of plugs at the inside steam nozzle penetrations is required and involves draining and then pressurizing that volume to the peak calculated containment pressure related to the design basis accident (Pa). Currently, the test pressure is 40 psig in accordance with NMP2 Technical Specifications Surveillance Requirement 3.6.1.3.12.
Experience at NMP2 has shown that these plugs will hold pressure when subjected to the 40 psig LLRT pressure, however, the test volume created includes the Main Steam Relief Valves, Reactor Head Vent, Main Steam Line Drain and Reactor Core Isolation Cooling piping which increase the number of potential leak paths. Therefore, this method of testing may not accurately reflect the leak tightness of the MSIVs.
Another method of testing that has been attempted at NMP2 involves testing of the inboard and outboard MSIVs simultaneously by pressurizing between the inboard and outboard valves to Pa. Based on site and industry experience, testing the inboard MSIVs at Pa in the reverse direction tends to cause difficulty in achieving proper test conditions due to the orientation of the valves on the main steam lines. Station operating experience concludes that the results of this method of testing do not accurately reflect the isolation capabilities of the valves. The inability to achieve proper testing conditions when pressurizing between the inboard and outboard valves at Pa necessitates reperforming the leak rate testing. This is done by conducting the tests in the accident direction at Pa to accurately evaluate the performance of each valve, resulting in additional dose expenditure.
This exemption is being requested to allow leak testing of the MSIVs at a reduced pressure of 25 psig. Industry experience has shown that testing the inboard and outboard valves simultaneously by pressurizing between the valves at a lower pressure of 25 psig has shown to be successful in achieving proper test conditions. When conducting the required leak rate testing at a reduced pressure, the total observed leakage through both valves would be conservatively assigned to the penetration. The reduction in test pressure allows for an accurate test to be conducted by allowing test conditions to be obtained while maintaining conservatism.
ENCLOSURE 1 CONSTELLATION REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION UNIT 2 Page 4 of 5 Testing the inboard valve in the reverse direction is conservative as the direction of pressurization introduces a force in the opposite direction of the valves seating forces.
Additionally, as mentioned above, due to the orientation of the MSIVs, when the outboard valves are tested in the accident direction, the pressurization provides better sealing as it would introduce a force in the direction of the valves seating forces. Therefore, testing in between the valves provides more conservative results and is acceptable per ANSI/ANS 56.8-2002, Section 6.2. (Reference 1)
Based on the above discussion, there is no increase in the probability of higher post-accident offsite or onsite doses related to the exemption and therefore no increase in environmental impact beyond that experienced with no exemption.
The alternative measure proposed in the discussion above, will provide reasonable assurance that the primary reactor containment shall not exceed allowable leakage rate values as specified in the technical specifications and associated bases. Therefore, the exemption satisfies Special Circumstance (a)(2)(ii) because the underlying purpose of the regulation from which the exemption is sought is met through CEGs proposed testing.
Special Circumstance (a)(2)(iv) is also met because the exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption. Experience shows that testing in the accident direction has been successful, yet this test method required by Appendix J requires the local leak rate test (LLRT) to be conducted inside the drywell as opposed to outside the drywell in the MSIV room, subjecting personnel conducting the test to higher radiation doses, and also requires the tests to be performed in series, which increases total testing duration. Specifically, the increased duration and number of tests inside the drywell has historically resulted in a significant dose exposure. In contrast, success with the proposed alternative test method using lower test pressure would result in dose savings of up to 4 person-REM pursuant to ALARA practices. Therefore, Special Circumstance (a)(2)(iv) is met given the lower radiation exposure for plant workers conducting Appendix J testing would benefit overall public health and safety without any decrease in safety through the use of the alternative testing method.
Precedent:
Exemption from Paragraph III.C.2 of Appendix J is consistent with current regulatory practice, as evidenced by the granting of a similar exemptions documented, in part, from Paragraph III.C.2 of Appendix J, for Monticello Nuclear Generating Plant, dated June 3,
ENCLOSURE 1 CONSTELLATION REQUEST FOR SPECIFIC EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR 50, APPENDIX J, FOR NINE MILE POINT NUCLEAR STATION UNIT 2 Page 5 of 5 1984 (Reference 2), and for Peach Bottom Atomic Power Station, dated November 21, 1990 (Reference 3) as it relates to reducing the test pressure from Pa to 25 psig for the MSIVs.
Summary:
The above analysis demonstrates that the proposed MSIV testing does not present an undue risk to the public health and safety or the common defense and security.
As such the safety significance of testing the MSIVs at a lower test pressure is bounded by the technical justification summarized and discussed in this request.
III. ENVIRONMENTAL ASSESSMENT CEG has determined that the requested exemption meets the categorical exclusion provision in 10 CFR 51.22(c)(25), as the requested licensing action is an exemption from the requirements of the Commission's regulations and (i) there is no significant hazards consideration; (ii) there is no significant changes in the types or significant increase in the amounts of any effluents that may be released offsite; (iii) there is no significant increase in individual or cumulative public or occupational radiation exposure; (iv) there is no significant construction impact; (v) there is no significant increase in the potential for or consequences from radiological accidents; and (vi) the requirements from which an exemption is sought involve surveillance requirements. Therefore, in accordance with 10 CFR 51.22(b), no environmental assessment or environmental impact statement needs to be prepared in connection with the proposed exemption request.
IV. CONCLUSION As demonstrated above, CEG considers that this exemption request is in accordance with the criteria of 10 CFR 50.12. Specifically, the requested exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. Also, special circumstances are present as previously described.
There are no adverse environmental impacts.
V. REFERENCE 1
American National Standards Institute/American Nuclear Society (ANSI/ANS) 56.8-2002, "Containment System Leakage Testing Requirements," Reaffirmed May 26, 2016 2
Issuance of Exemption from Certain Requirements of Section 50.54(o) and Appendix J to 10 CFR 50, dated Jun 3, 1984 3
Appendix J Exemption for Peach Bottom Atomic Power Station, Units 2 and 3, dated November 21, 1990
ENCLOSURE 2 CONSTELLATION REQUEST FOR LICENSE AMENDMENT TO REVISE SURVEILLANCE REQUIREMENT (SR) 3.6.1.3.12, FOR NINE MILE POINT NUCLEAR STATION, UNIT2
ENCLOSURE 2 Evaluation of Proposed Changes Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-410
Subject:
License Amendment Request - Revise Surveillance Requirement (SR) 3.6.1.3.12 to Reduce MSIV Test Pressure 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
Evaluation of Proposed Changes Page 1 of 4 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 approval of proposed changes to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. NPF-69 for Nine Mile Point Nuclear Station, Unit 2 (NMP2).
2.0 DETAILED DESCRIPTION The proposed change will revise the Main Steam Isolation Valve (MSIV) test pressure value from 40 psig to 25 psig in TS Surveillance Requirement (SR) 3.6.1.3.12. The proposed reduction in test pressure would also require an adjustment to the maximum allowable leakage through each MSIV to account for the change in test pressure. The current TS maximum allowable leakage through each MSIV of 50 standard cubic feet per hour (SCFH) when tested at 40 psig. The proposed change will adjust the maximum allowable leakage to 39 SCFH when tested at 25 psig. This change will allow for MSIV testing by pressurizing between the inboard and outboard MSIVs simultaneously at the lower pressure of 25 psig to allow test conditions to be met and will provide an alternative to testing in the forward (accident) direction.
The marked-up TS page 3.6.1.3-13 is provided in Attachment 1 and the marked-up TS Bases page B 3.6.1.3-19 is provided in Attachment 2 to this enclosure.
Additionally, testing of the inboard MSIVs in the accident direction would require the local leak rate test (LLRT) to be conducted inside the drywell as opposed to outside the drywell in the MSIV room, subjecting personnel conducting the test to higher radiation doses.
3.0 TECHNICAL EVALUATION
Due to the orientation of the MSIVs on the Main Steam Lines when inboard MSIVs at NMP2 are tested in the forward (accident) direction the reactor vessel head is removed, requiring the installation of plugs at the inside steam nozzle penetrations, and involves draining and then pressurizing that volume to the peak calculated containment pressure related to the design basis accident (Pa). Currently, the test pressure is 40 psig in accordance with NMP2 TS SR 3.6.1.3.12. Experience shows that this testing method has been successful, yet this test method creates undue hardships during outages by requiring installation of plugs at the inside steam line nozzle penetrations and expose workers to radiological dose.
Another method of testing that is used at NMP2 involves testing of the inboard and outboard MSIVs simultaneously by pressurizing between the inboard and outboard valves to Pa. Based on site and industry experience, testing the inboard MSIVs at Pa in the reverse direction tends to cause difficulty in achieving proper test conditions due to the orientation of the valves on the main steam lines. Station operating experience concludes that the results of this method of testing do not accurately reflect the isolation capabilities of the valves. The inability to achieve proper testing conditions when pressurizing between the inboard and outboard valves at Pa necessitates reperforming the leak rate testing. This is done by conducting the tests in the accident direction at Pa to accurately evaluate the performance of each valve, resulting in additional dose expenditure.
This License Amendment is being requested to allow leak testing of the MSIVs at a lower pressure of 25 psig. Industry experience has shown that testing the inboard and outboard Evaluation of Proposed Change Page 2 of 4 valves simultaneously by pressurizing between the valves at a lower pressure of 25 psig to be successful in achieving proper test conditions. When conducting the required leak rate testing at a reduced pressure, the total observed leakage through both valves would be conservatively assigned to the penetration. The reduction in test pressure allows for an accurate test to be conducted by allowing test conditions to be obtained while maintaining conservatism.
Testing the inboard valve in the reverse direction is conservative as the direction of pressurization introduces a force in the opposite direction of the valves seating forces.
Additionally, as mentioned above, due to the orientation of the MSIVs, when the outboard valves are tested in the accident direction, the pressurization provides better sealing as it would introduce a force in the direction of the valves seating forces. Therefore, testing between the MSIVs provides more conservative results and is acceptable per ANSI/ANS 56.8-2002, Section 6.2. (Reference 6.1)
The proposed reduction in test pressure would also require an adjustment to the maximum allowable leakage through each MSIV to account for the change in test pressure. By scaling the maximum allowable leakage at Pa (50 SCFH) as listed in the NMP2 TS to the proposed test pressure, the equivalent maximum allowable leakage limit through each MSIV will be 39 SCFH when tested at 25 psig.
This acceptance criteria are effective and reliable in determining the status of the MSIVs and in verifying that substantial degradation of the valves has not occurred since the last Local Leak Rate Test.
The application of reduced test pressure between the MSIVs as proposed above will provide assurance that the primary reactor containment is an essentially leak tight barrier against the uncontrolled release of radioactivity to the environment. Therefore, the above evaluation demonstrates that the proposed MSIV test does not present and undue risk to the public health and safety or the common defense and security. As such the safety significance of testing the MSIVs at a lower test pressure is bounded by the technical justification summarized and discussed above.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria Title 10 Code of federal Regulations 50.36, "Technical specifications" 4.2 Precedent Similar changes with respect to reduced test pressure are approved for the Brunswick Steam Electric Plant, Units 1 and 2 through Amendments 10 and 36, respectively. See Reference 6.2.
4.3 No Significant Hazards Consideration Constellation Energy Generation, LLC (CEG) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:
Evaluation of Proposed Change Page 3 of 4
- 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes will revise Surveillance Requirement (SR) 3.6.1.3.12 to allow for Main Steam Isolation Valves (MSIVs) to be pressure tested using a lower pressure than the peak calculated containment pressure (Pa) related to the design basis accident and associated lower allowable leakage rate.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change does not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component to perform their safety function. The proposed changes will revise Surveillance Requirement SR 3.6.1.3.12 to allow MSIV testing at a lower pressure and equivalent lower allowable leakage rate.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed change does not alter the safety limits, or safety analysis assumptions associated with the operation of the plant. The proposed change provides an equivalent method of testing and does not have an adverse impact on safety margins.
Therefore, the proposed change does not result in a significant reduction in a margin of safety.
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 Commissions 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.
Evaluation of Proposed Change Page 4 of 4
5.0 ENVIRONMENTAL CONSIDERATION
A review has determined that the proposed amendment 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, or would change an inspection or surveillance requirement. However, the proposed amendment 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 need be prepared in connection with the proposed amendment.
6.0 REFERENCES
6.1 American National Standards Institute/American Nuclear Society (ANSI/ANS) 56.8-2002, "Containment System Leakage Testing Requirements,"
Reaffirmed May 26, 2016 6.2 Brunswick Units 1 and 2, License Amendments 10 and 36, Re: Changes to TS to Grant Exemptions to 10 CFR 50, Appendix J, Section III.C.2, dated November 8, 1977 (ML020370372)
ENCLOSURE 2 ATTACHMENT 1 Proposed Technical Specifications Markup Pages Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-410 REVISED TECHNICAL SPECIFICATIONS PAGE 3.6.1.3-13
PCIVs 3.6.1.3 NMP2 3.6.1.3-13 Amendment 91, 182 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.6.1.3.12 Verify leakage rate through each MSIV is 50 scfh when tested at 40 psig.
In accordance with 10 CFR 50 Appendix J Testing Program Plan SR 3.6.1.3.13 Verify combined leakage rate through hydrostatically tested lines that penetrate the primary containment is within limits.
In accordance with 10 CFR 50 Appendix J Testing Program Plan 39 25
ENCLOSURE 2 ATTACHMENT 2 Proposed Technical Specifications Bases Markup Pages Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 Docket No. 50-410 REVISED TECHNICAL SPECIFICATIONS BASES PAGE 3.6.1.3-19
PCIVs B 3.6.1.3 NMP2 B 3.6.1.3-19 Revision 0, 3 (A96), 44 (A152),
45 (A156), 61 (182)
BASES SURVEILLANCE SR 3.6.1.3.12 REQUIREMENTS (continued)
The analyses in Reference 2 are based on leakage that is less than the specified leakage rate. Leakage through each MSIV must be 50 scfh when tested at 40 psig. The Frequency is required by the 10 CFR 50 Appendix J Testing Program Plan.
SR 3.6.1.3.13 Surveillance of hydrostatically tested lines provides assurance that the calculation assumptions of Reference 1 are met. The acceptance criteria for the combined leakage of all hydrostatically tested lines is 1 gpm times the total number of hydrostatically tested PCIVs when tested at 1.10 Pa (43.73 psig). The combined leakage rates must be demonstrated in accordance with the leakage test Frequency required by the 10 CFR 50 Appendix J Testing Program Plan.
REFERENCES
- 1.
Technical Requirements Manual.
- 2.
USAR, Section 15.6.5.
- 3.
USAR, Section 15.6.4.
- 4.
USAR, Section 15.2.4.
- 5.
- 6.
USAR, Section 6.2.4.3.2.
- 7.
10 CFR 50, Appendix J Option B.
- 8.