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| | issue date = 03/05/1986 | | | issue date = 03/05/1986 |
| | title = Requests Exemption to Exclude Certain Relief Valves from Type C Testing Contained in Section Ii.H of App J of 10CFR50.Valves Located Inside Primary Containment or Discharge to Suppression Pool from Outside | | | title = Requests Exemption to Exclude Certain Relief Valves from Type C Testing Contained in Section Ii.H of App J of 10CFR50.Valves Located Inside Primary Containment or Discharge to Suppression Pool from Outside |
| | author name = MANGAN C V | | | author name = Mangan C |
| | author affiliation = NIAGARA MOHAWK POWER CORP. | | | author affiliation = NIAGARA MOHAWK POWER CORP. |
| | addressee name = ADENSAM E G | | | addressee name = Adensam E |
| | addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) | | | addressee affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR) |
| | docket = 05000410 | | | docket = 05000410 |
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| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC |
| | page count = 14 | | | page count = 14 |
| | revision = 0 | | | project = |
| | | stage = Other |
| }} | | }} |
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| | =Text= |
| | {{#Wiki_filter:REGULATORY NFORNATION DISTRIBUTION SY 1'EN (RIDS) |
| | ACCESSION NBR: 8603110343 DOC. DATE: 86/03/05 NOTARIZED: YES,, DOCKET ¹ FACIL: 50-410 Nine Mile Point Nuclear Station> Unit 2> Niagara Noha 05000410 AUTH. NANE AUTHOR AFFILIATION NANGAN> C. V. Niagara Mohawk Power Corp. |
| | REC IP. NANE RECIPIENT AFFILIATION |
| | *DENSAN> E. G. BWR ProJect Directorate 3 SUH CT; Requests exemption to exclude certain relief valves from Type C testing contained in Sec'tion II. H of App 4 of 10CFR50. Valves located inside primary containment or discharge to suppression pool from outside. |
| | DISTRIBUTION CODE: H001D COPIES RECEIVED: LTR ENCL SIZE: |
| | TITLE: Licensing Submittal: PSAR/FSAR Amdts Zc Related Correspondence NOTES'EC IP IENT COPIES RECIPIENT COPIES ID CODE/MANE LTTR ENCL ID CODE/NAME LTTR ENCL BWR ADTS 1 1 BWR PD3 PD 1 1 HWR EB 1 1 BWR EICSB 1 1 HWR PD3 LA '1 HWR FOB 1 1 1 HAUGHEY> M 01 2 2 BWR PSB 1 BWR RSH 1 1 INTERNAL: ACRS 41 6 ADN/LFMB 1 0 ELD/HDS3 1 0 IE FILE 1 1 IE/DEPER/EPB 36 1 1 IE/DGAVT/GAB 21 1 1 NRR BWR ADTS 1 0 NRR PWR-A ADTS 1 0 NRR PWR-H *DTS 1 0 NRR'OE> M. L 1 1 QRRPH I |
| | /HF H 1 l4RR/DHFT/NTB 1 1 REG FILE 04 RGN1 3 3 |
| | /NI B 1 0 EXTERNAL: 24X 1 BNL(AMDTS ONLY) 1 1 DNB/DSS (ANDTS) 1 1 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 PNL GRUEL> R 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 39 ENCL 33 |
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| | NIAGARA MOHAWK POWER CORPORATION/300 ERIE BOULEVARD WEST. SYRACUSE, N.Y. 13202/TELEPHONE (315) 474-1511 March 5, 1986 (NMP2L 0649) |
| | Ms. Elinor G. Adensam, Director BHR Project Directorate No. 3 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Nashington, DC 20555 |
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| | ==Dear Ms. Adensam:== |
| | |
| | Re: Nine Mile Point Unit 2 Docket No. 50-410 Niagara Mohawk Power Corporation (" Niagara Mohawk" ) hereby requests exemptions pursuant to 10 CFR 50.12(a) from Type C test requirements of 10 CFR Part 50 Appendix J. Specifically, Niagara Mohawk requests the exclusion of certain relief valves from Type C testing contained in Section II.H of Appendix J. |
| | The exemption has been reviewed and found to be authorized by law and consistent wi th the common defense and security. The attachment to this letter demonstrates that the requested exemption presents no undue risk to the health and safety of, the public and that special circumstances are present that justify granting the exemptions. |
| | With regard to the "common defense and security" standard, the grant of the requested exemptions is consistent with the common defense and security of the United States. The Commission's Statement of Considerations in support of the exemption rule note with approval the explanation of this standard as set forth in Lon Island Li htin Com an (Shoreham Nuclear Power Station, Unit 1), LBP-84-45, 20 NRC 1343, 1400 (October 29, 1984). There, the term "common defense and security" refers principally to the safeguarding of special nuclear material, the absence of foreign control over the applicant, the protection of Restricted Data, and the availability of special nuclear material for defense needs. The granting of the requested exemptions will not affect any of these matters and thus such grant is consistent with the common defense and security. |
| | The proposed exemption has been analyzed and determined not to cause additional construction or operational activities which may significantly affect the environment. They do not result in a significant increase in any adverse environmental impact previously evaluated in the final Environmental Impact Statement-Operating License Stage, a significant change in effluents or power levels or a matter uot previously reviewed by the Nuclear Regulatory Commission which may have a significant adverse environmental impact. |
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| | Ms. |
| | Page Elinor 2 |
| | G. Adensam t |
| | Niagara Mohawk is ready to meet with the cognizant Nuclear Regulatory Commission personnel to review these matters should you require additional information. |
| | Very truly yours, C. V. Mang Senior Vice President NLR:ja 1380G xc: R. A. Gramm, NRC Resident Inspector Project File (2) |
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| | ~ % |
| | UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Niagara Mohawk Power Corporation, ) Docket No. 50-410 (Nine Mile Point Unit 2) ) |
| | AFFIDAVIT C. V. Man an , being duly sworn, states that he is Senior Vice President of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief. |
| | Subscribed and swor to be ore me, a Notary Public in d for t e State of New York and County of , this R Y" day of 1986. |
| | N tar Public in and for County, New York My Commission expires: |
| | JANIS M. MACRO Notary Pubttc In the State ot New York Qualitied In Onondaga County No. 47045 5 aty commlsslon r.xrrlrcs arc r |
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| | ~ i ATTACHMENT |
| | ~EX ~ lt UES RELIEF VALVES TYPE C TESTING It is requested that an exemption be issued to exclude certain relief valves from the requirements of Section II.H of 10 CFR Part 50, Appendix J. These valves either are located inside the primary containment or discharge to the suppression pool from outside the primary containment. The discharges of the relief valves would be exposed to containment atmosphere following a loss of coolant accident. A listing of these valves is provided below: |
| | : a. Residual Heat Removal System (RHS) |
| | : l. 2RHS*RV20A, B, C |
| | : 2. 2RHS*RV61A, B, C |
| | : 3. 2RHS*RV108 |
| | : 4. 2RHS*RV110 |
| | : 5. 2RHS*RV139 |
| | : 6. 2RHS*RV152 |
| | : b. Low Pressure Core Spray (CSL) |
| | : 1. 2CSL*RV105 |
| | : 2. 2CSL*RV123 |
| | : c. High Pressure Core Spray (CSH) |
| | : 1. 2CSH*RV113 2 ~ 2CSH*RV114 |
| | : d. Reactor Building Closed Loop Cooling Water (CCP) |
| | : 1. 2CCP*RV170 |
| | : 2. 2CCP*RV171 The relief valves and associated containment penetration piping are all Seismic Category I, Safety Class 2 components. |
| | The grant of the requested exemption will not present an undue risk to the public health and safety. These valves are all included in the Type A primary containment integrated leak test. The discharge piping of the valves is exposed to either drywell or wetwell pressure during the test. |
| | The purpose of this exemption request is to waive the requirement for Type C testing of these valves in accordance with 10 CFR 50 Appendix J. They will be included in the Type A test instead. The basis for this exemption request is the ALARA and design considerations related to the conduct of the Type C test for these valves. |
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| | ~ ~ |
| | All the valves are located in potentially high radiation areas. They require dismantling of discharge piping to perform the test, since there are no maintenance valves to provide a test boundary. The relief valves were purposely designed without surrounding block valves to comply with the guidance of Subsection NC7000 of the ASME Code, Section III. Thus, preparations and performance for Type C testing of these valves could result in excessive radiation exposure to plant personnel. This is contrary to ALARA policies considering that the valves can be included in the Type A test. |
| | In addition to ALARA concerns, other considerations support the exemption of these'valves from Type C test requirements. All the valves located in the secondary containment (13 out of 16 valves) discharge into common headers which penetrate the primary containment wall and then turn down into the suppression pool. To provide a test boundary for individual valves would require blank flanges in each valve discharge line. These flange connections would themselves represent additional leakage paths from the primary containment. Also, these flange connections would require Type 8 testing, thereby aggravating the ALARA concerns. It should also be noted that LOCA pressure and valve spring pressure tend to seat the valves against leakage. |
| | For the three valves located inside the drywell, i.e., CCP*RV170, 171 and RHS"RV152, there is little likelihood of any leakage to the secondary containment. The only path through these valves is across the valve seat. |
| | LOCA pressure opposes the normal valve opening, and the valve springs, set for relief pressures of 100 psig to 1575 psig, assist in seating the valves. |
| | Furthermore, any leakage that might occur would be detected during normal system operation. System operating pressures are higher than LOCA pressure and tend to open the valves. Thus, any valve seat degradation would be evident during system operation prior to reaching a condition that would permit significant post-LOCA leakage. Leakage through these valves would be detected early by several means, e.g., loss of expansion tank level (CCP), a loss of reactor level (RHS), and an increase in drywell floor drain tank level. |
| | Based on the above considerations, exclusion of the safety relief valves from the Type C testing would present no undue risk to the public health and safety. |
| | |
| | Speci Circumstances are Present Which Warrant Issuance of the Re vested Exem tions Special circumstances are present which warrant issuance of the requested exemption. These special circumstances are discussed in accordance with the classification contained in the rule. |
| | (i) "Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; or" As previously discussed, Appendix J is in conflict with ALARA considerations. |
| | Thus, special circumstances are present which warrant granti,ng .the exemption... |
| | (ii) "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule..." |
| | As previously discussed, to provide a test boundary for certain individual valves would require blank flanges in each valve discharge line. These flange connections would themselves represent additional leakage paths from the primary containment. Thus, special circumstances are present which warrant granting the exemption. |
| | (ii) "Application of the regulation i'n the particular circumstances . . . is not necessary to achieve the underlying purpose of the rule; or The underlying purpose of the rule is to assure a low leakage containment with the ultimate objective of keeping accident doses low. These valves are all included in the Type A primary containment integrated leak test. The discharge piping of the valves is exposed to either drywell or wetwell pressure during the test. Thus, special circumstances are present which warrant granting the exemptions. |
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Category:CORRESPONDENCE-LETTERS
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Y2K Readiness Disclosure,Encl ML20211P5271999-06-29029 June 1999 Submits Written Comments Addressing Petition Dtd 990405, Submitted by R Norway as It Relates to Expressed Concerns That Involve NMPC Activities.None of Relief Requested in Petition Warranted ML20196K6461999-06-29029 June 1999 Discusses Ofc of Investigations Rept 1-98-33 Re Unqualified Senior Reactor Operator Assuming Position of Assistant Station Shift Supervisor at Unit 1 on 980616.One Violation Being Cited as Described in Encl NOV ML20209B3501999-06-25025 June 1999 Submits Torus Shell & Coupon Corrosion Rate Determination for Nmpns,Unit 1.Torus Meets ASME Code Requirements,Iaw NRC 920825 & 940811 SERs ML20212J4431999-06-25025 June 1999 Discusses Responses to RAI Re GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20209B3531999-06-25025 June 1999 Informs NRC That All Actions Associated with NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs, Has Been Completed.Summary of Actions Completed & Other Pertinent Info Is Provided in Attachment ML20196F5721999-06-23023 June 1999 Forwards Rev 3 to NMP1-IST-003, Third Ten Year Inservice Testing Program Plan, Which Will Begin on 991226.Program Plan Conforms to Requirements of 1989 Edition of ASME Boiler & Pressure Vessel Code.Three Relief Requests,Encl ML20196G1461999-06-23023 June 1999 Informs That Actions Requested in GL 96-01, Testing of Safety-Related Logic Circuits Completed 1999-09-07
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217K2831999-10-14014 October 1999 Submits Response to NRC Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates, for Fiscal Yrs 2000 & 2001 ML20217H3211999-10-0808 October 1999 Forwards Changed Pages for Issue 5,rev 1 of Nine Mile Point Station Physical Security & Safeguards Contingency Plan,Iaw 10CFR50.54(p).Without Encls ML18040A3701999-09-30030 September 1999 Provides Changes to Application for Amend Re Volumes 1-11 of 981016 Submittal & Discard & Insertion Instructions Re Integration of Proposed Changes,In Response to NRC RAIs ML20216J9311999-09-30030 September 1999 Forwards Response to NRC 981119 Suppl RAI Re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20212E9801999-09-23023 September 1999 Submits Info in Response to Request for Estimated Initial Operator Licensing Exam Needs,Per Administrative Ltr 99-03 ML20216F7101999-09-17017 September 1999 Forwards Response to NRC 990806 RAI Re USI A-46,verification of Seismic Adequacy of Mechanical & Electrical Equipment in Operating Reactors.Nrc Is Informed That Actions Required for Resolution of USI A-46 Have Been Completed ML20212D8981999-09-14014 September 1999 Forwards ISI Summary Rept for Refueling Outage 15 & Flaw Indication Repts.Supporting Info Repts & Calculations, Encl ML20212B2581999-09-10010 September 1999 Requests That Name of Bm Bordenick Be Removed from Nine Mile Point,Units 1 & 2 Service List ML20211P5771999-09-10010 September 1999 Forwards Application for Amends to Licenses DPR-63 & NPF-69, to Transfer Licenses to Amergen Energy Co,Llc.Ts Pages & Proprietary Addendum,Included.Proprietary Encl Withheld ML20212A1341999-09-0707 September 1999 Forwards Summary Rept Secondary Containment Leakage Testing, Dtd June 1999 for Nine Mile Point,Unit 1,IAW TS 6.9.3.f ML20211K8141999-09-0101 September 1999 Forwards Reactor Containment Bldg Ilrt,Iaw Plant TS 6.9.3.e.Testing Confirmed That TS 3.3.3/4.3.3 & 6.16 Primary Containment Leakage Requirements Were Satisfactorily Met ML20211L9221999-09-0101 September 1999 Confirms That Licensee Will Retain Weld 32-WD-050 as IGSCC Category F Until Completion of Reinspection Program,In Response to NRC ML20211K3001999-08-30030 August 1999 Forwards Semi-Annual Radioactive Effluent Release Rept for 990101-990630 & Revised ODCM, for Nine Mile Point,Unit 1. Format Used for Effluent Data Is Outlined in App B of Regulatory Guide 1.21,rev 1 ML20211J6461999-08-30030 August 1999 Forwards Response to NRC 990625 RAI Re NMPC Responses to GL 92-01,rev 1,supplement 1, Reactor Vessel Structural Integrity ML20211H1921999-08-26026 August 1999 Forwards Application for Amend to License DPR-63,supporting Implementation of Noble Metal Chemical Addition by Raising Reactor Water Conductivity Limits in TSs 3.2.3.a,3.2.3.c.1 & 3.2.3.b ML20211D7731999-08-20020 August 1999 Forwards Semiannual FFD Program Performance Data Rept Covering Period 990101 Through 990630 ML20211B9371999-08-18018 August 1999 Provides Addl Info Re Application of Method a at Nmp,Unit 1 as Described in Generic Implementation Procedure,Rev 2 (GIP-2),NRC Supplemental SER 2 & Documents Ref in GIP-2 Upon Which GIP-2 Is Based ML18040A3691999-08-16016 August 1999 Forwards Response to NRC 990510 RAI Pertaining to NMP Application for Amend Re Conversion of NMPNS Unit 2 Current TS to Its.Nrc Requested Info Re Several Sections,Including Section 3.6, Containment Sys. ML20210R6661999-08-10010 August 1999 Confirms Conversation on 990721 Re Concerns of Syracuse Anti-Nuclear Effort on Status of 2.206 Petition (Filed 990524) & Upcoming NRC Performance Review Meeting on Nine Mile Point Units 1 & 2 ML20210R8101999-08-10010 August 1999 Forwards 1998 Annual Repts for NMP & co-tenants,including Rg&E,Energy East Corp/Nyse&G,Chg&E & Long Island Power Authority,Per 10CFR50.71(b) ML18041A0711999-07-30030 July 1999 Forwards Rev 1 to NMP2-ISI-006, Second Ten Year Interval ISI Program Plan for Nine Mile Point Nuclear Power Station Unit 2. Significant Changes from Rev 0 Listed ML20210J9351999-07-29029 July 1999 Informs That NMP Is Changing Completion Date for Replacement of Valves Having O Rings with Installed Life Greater than Eight Years.Replacement to Be Completed by 991031, During Hydrogen Monitoring Sys Maintenance Outage ML20209G3711999-07-12012 July 1999 Provides Final Root Cause Evaluation Re GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 1 ML20209G7911999-07-12012 July 1999 Provides Info Requested in NRC Re 990407 Generic Fundamentals Exam Failure Causes & Corrective Actions ML20209G2001999-07-0909 July 1999 Forwards RFO-15 Core Shroud Insp Summary Rept, as Required by GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in BWRs & BWRVIP Rept BWR Core Shroud Insp & Flaw Evaluation Guideline (BWRVIP-01) ML20209F8561999-07-0606 July 1999 Forwards Rev 1 to Nmp,Unit 1 COLR for Cycle 14. Rept Is Being Submitted to Commission in Compliance with TS 6.9.1.f.4 ML20211K5071999-07-0606 July 1999 Submits Concerns Re 990624 Event Involving Automatic Reactor Shutdown.More than 5 Failures Were Identified in Event Number 35857 ML20209B7071999-06-30030 June 1999 Responds to NRC Request for Info Re Y2K Readiness at Nuclear Facilities,As Contained in GL 98-01,Supp 1, Y2K Readiness of Computer Sys at Nuclear Power Plants. Y2K Readiness Disclosure,Encl ML20211P5271999-06-29029 June 1999 Submits Written Comments Addressing Petition Dtd 990405, Submitted by R Norway as It Relates to Expressed Concerns That Involve NMPC Activities.None of Relief Requested in Petition Warranted ML20209B3501999-06-25025 June 1999 Submits Torus Shell & Coupon Corrosion Rate Determination for Nmpns,Unit 1.Torus Meets ASME Code Requirements,Iaw NRC 920825 & 940811 SERs ML20209B3531999-06-25025 June 1999 Informs NRC That All Actions Associated with NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs, Has Been Completed.Summary of Actions Completed & Other Pertinent Info Is Provided in Attachment ML20196G1461999-06-23023 June 1999 Informs That Actions Requested in GL 96-01, Testing of Safety-Related Logic Circuits Completed ML20196F5721999-06-23023 June 1999 Forwards Rev 3 to NMP1-IST-003, Third Ten Year Inservice Testing Program Plan, Which Will Begin on 991226.Program Plan Conforms to Requirements of 1989 Edition of ASME Boiler & Pressure Vessel Code.Three Relief Requests,Encl ML20209B2951999-06-22022 June 1999 Informs That Training Re Pressure Relief Panels Was Completed for Remainder of Target Population on 990226 ML20196E9231999-06-21021 June 1999 Forwards Response to NRC 990510 RAI Re NMP 981116 Application Proposing Changes to TSs to Provide Reasonable Assurance That Coupled neutronic/thermal-hydraulic Instabilities Were Detected & Suppressed in NMPN-1 Reactor ML18040A3651999-06-0707 June 1999 Forwards for Filing Original Application of Central Hudson & Gas & Electric Corp Seeking Extension of Expiration Date of Order,Dtd 980719,issued by Commission ML18040A3661999-06-0404 June 1999 Informs That Entire Attachment to Ltr NMP2L 1862 Dtd 990421, Should Be Replaced with Entire Attachment Being Sent with Present Ltr ML20195C9751999-06-0101 June 1999 Informs That Weld 32-WD-050 Will Be Reclassified Back to GL 88-01 Category a Weld & ASME Code Section XI Insps Will Be Conducted in Next Three Insp Periods ML20195C9601999-05-28028 May 1999 Provides Final Extent of Condition Evaluation Re Failed Cap Screw Beyond Upper Spring.Nmpc Continues to Conclude as Stated in That No Addl Mods Are Needed Other than Those Indicated in Ltr ML20207F1811999-05-24024 May 1999 Petitions NRC to Suspend Operating License of NMP for NMPNS Unit 1 Until Such Time as NMPC Releases Most Recent Insp Data on Plant Core Shroud & Adequate Public Review of Plant Safety Accomplished Because of Listed Concerns ML20195B1861999-05-21021 May 1999 Requests Staff Approval of Proposed Mod to Each of Four Tie Rods Per 10CFR50.55a(a)(3)(i).Summary of Tie Rod Insp Findings,Summary of Root Cause Evaluation of Failure of Cap Screw,Calculation B-13-01739-23 & Summary of Se,Encl ML20207D1541999-05-21021 May 1999 Forwards Issue 5,rev 0 of Physical Security & Safeguards Contingency Plan for Nmpns.Summary of Changes Included to Facilitate Review.Encls Withheld ML20207D5331999-05-21021 May 1999 Forwards Issue 3,Rev 1 of NMP Nuclear Security Training & Qualification Plan.Summary of Changes Is Included with Plan to Provide Basis for Individual Changes & to Facilitate NRC Review.Plan Withheld Per 10CFR2.790 ML20206S2621999-05-16016 May 1999 Expresses Concerns About Safety of Nmp,Unit 1 Nuclear Reactor.Nrc Should Conduct Insp of Reactor Including Area Besides Core Shroud Welds & Publicly Disclose Results at Least Wk Before Restart Date ML20195D5911999-05-13013 May 1999 Submits Final Copy of Open Ltr to Central Ny,With Proposals Re Nine Mile One Core Shroud Insp During Refueling Outage Which Began on 990411 ML20206P1981999-05-11011 May 1999 Forwards Response to NRC RAI Re NMP Previous Responses to GL 96-05, Periodic Verification of Design-Basis of SR Movs, for NMP Units 1 & 2 ML20206R6941999-05-10010 May 1999 Responds to 990413 & 0430 Ltrs Re Apparent Violation Noted in Investigation Rept 1-98-033.Util Agrees with Violation, But Disagrees with Characterization That Violation Was Willful or Deliberate ML20206N0291999-05-0707 May 1999 Forwards Rev 39 to NMP Site Emergency Plan & Revised Epips,Including Rev 1 to EPMP-EPP-03,rev 5 to EPIP-EPP-25 & Rev 5 to EPIP-EPP-28 ML20206G8121999-04-30030 April 1999 Forwards Comments on Draft Reg Guide DG-1083, Content of UFSAR IAW 10CFR50.71(e), Dtd Mar 1999.Util Generally Supports DG-1083 ML20206F7731999-04-22022 April 1999 Forwards Renewal Application for SPDES Permit Number NY-000-1015 for Nmpns,Units 1 & 2 1999-09-07
[Table view] Category:UTILITY TO NRC
MONTHYEARML17056A9771990-08-30030 August 1990 Forwards Semiannual Radioactive Effluent Release Rept for Jan-June 1990 & Revs 4 & 5 to Odcm. ML18038A3231990-08-30030 August 1990 Forwards Semiannual Radioactive Effluent Release Rept Jan- June 1990 & Revs 6-8 to Odcm. Radioactive Effluent Release Rept Includes Summary of Liquid,Gaseous & Solid Effluents & Justification for Revs to ODCM ML18038A3221990-08-24024 August 1990 Forwards NRC Form 474, Simulation Facility Certification & Supporting Documentation ML18038A3201990-08-21021 August 1990 Discusses Status of Completion of Generic Safety Issue 75, Item 2.2.2 Re Vendor Interface for safety-related Components ML18038A3251990-08-20020 August 1990 Forwards Rev 3 to Nine Mile Point Requalification Program Action Plan, Certifying That All short-term Corrective Actions Completed ML20058Q1151990-08-15015 August 1990 Forwards Response to Regulatory Effectiveness Review on 900604-08.Response Withheld (Ref 10CFR73.21) ML20055G5261990-07-18018 July 1990 Forwards Decommissioning Rept Indicating Reasonable Assurance That Funds Available to Decommission Facility. Financial Assurance of Cotenants Also Encl ML17058A5841990-06-27027 June 1990 Forwards Rev 8 to Updated FSAR for Nine Mile Point Unit 1. Changes Re Findings Noted in Insp Rept 50-220/88-201 Included in Rev.Rev Does Not Reflect Changes Re Reg Guide 1.97,Rev 2 ML18038A3051990-06-26026 June 1990 Responds to Generic Ltr 90-04 Re Status of Implementation of Generic Safety Issue Requirements.Tabulated Info Re Generic Safety Issue Title,Applicability,Status & Remarks Encl ML20042E3741990-04-11011 April 1990 Lists Info Re Unit Containment Vent & Purge Valves,Per NRC 900315 Request ML20012F6131990-03-30030 March 1990 Forwards Changes to Security Training & Qualification Plan. Plan Rewritten & Revised to Incorporate performance-oriented Training Program.Plan Withheld (Ref 10CFR2.790(d)) ML17056A6721990-03-0202 March 1990 Forwards Semiannual Radioactive Effluent Release Rept for Jul-Dec 1989 & Rev 3 to Administrative Procedure AP-3.7.1, Unit 2 Radwaste Process Control Program. ML18038A7071990-02-0505 February 1990 Forwards Rev 5 to NMPC-QATR-1, QA Topical Rept for Nine Mile Point Nuclear Station Operations. ML18038A7061990-01-10010 January 1990 Forwards Rev 21 to Emergency Plan,Revised Emergency Action Procedures,Including Rev 7 to S-EAP-1,Rev 11 to S-EAP-2,Rev 8 to S-EAP-3 & Epips,Including Rev 13 to S-EPP-4 & Rev 13 to S-EPP-20 ML20042D1981989-12-28028 December 1989 Informs of Delay in Response to Generic Ltr 89-10, Safety-Related Motor-Operated Valve Testing & Surveillance, Until BWR Owner Group Generic Program Completed & NRC Appraisal of Program Reviewed by Util ML18038A7021989-11-28028 November 1989 Responds to Generic Ltr 89-21 Re Status of Implementation of USI Requirements.Usi A-5,A-6 & A-7 Inapplicable to Facility ML18038A7711989-11-28028 November 1989 Responds to Generic Ltr 89-21 Re Status of Implementation of USI Requirements.Requirements for NUREG-0612 Re Control of Heavy Loads Near Spent Fuel Completed.Usi A-40 Re Seismic Design Criteria Being Resolved as Part of USI A-46 ML18038A7701989-10-25025 October 1989 Forwards Rev 1 to Updated SAR for Nine Mile Point Unit 2. All Errata Items Identified in Attachment 1 to Previous Updated SAR Transmittal Ltr of 890428 Resolved.Programs to Resolve Setpoint Issues Will Be Established by 891130 ML18038A7611989-09-29029 September 1989 Forwards Addl Info Re Simulator Certification for Facility, Per 890803 Request.Schedule Extension Verbally Granted Until 890930 ML18038A6641989-09-0808 September 1989 Forwards Restart Readiness Rept. Rept Submitted in Fulfillment of Util Third Action Required by Confirmatory Action Ltr CAL-88-17,dtd 880724 ML17056A2701989-08-30030 August 1989 Forwards Nine Mile Point Nuclear Station - Unit 2 Semiannual Radioactive Effluent Release Rept Jan-June 1989 & Rev 1 to Administrative Procedure AP-3.7.1 Process Control Program. ML20245E8451989-08-0707 August 1989 Forwards Rev 6 to Training & Qualification Plan.Rev Withheld (Ref 10CFR73.21 & 10CFR2.790(d)) ML20247M2771989-07-25025 July 1989 Forwards Issue 2,Rev 0 to Physical Security Plan.Specific Changes Set Forth in Attachment A.Supporting Info Set Forth in Attachment B.Master Acronym & Abbreviation List Also Encl.Encls Withheld (Ref 10CFR73.21) ML20246N9041989-07-13013 July 1989 Forwards Vital Area Evaluation for Plant Screenhouse.Encl Withheld (Ref 10CFR73.21(b)) ML18038A6611989-07-11011 July 1989 Provides Response to Generic Ltr 89-06, Task Action Plan Item I.D.2 - Spds. Certification Stating Plant Unit 1 SPDS Sys Meets Requirements of NUREG-0737,Suppl 1 & Plant Unit 2 SPDS Sys Will Be Modified to Meet NUREG-0737,Suppl 1 Encl ML18038A6591989-06-23023 June 1989 Forwards Util Response to 890522 Salp.Util Agrees W/Need to Improve Surveillance Testing Data & Upgrading Design Basis for Core Spray & HPCI Sys ML20244E3631989-06-15015 June 1989 Forwards Revised Application for Amend to License DPR-63, Incorporating Request to Limit Reactor Power Level at Which Blocking Valve in Feedwater May Be Closed ML18038A4731989-05-31031 May 1989 Forwards Emergency Preparedness Exercise/Drill Scenario 12 1989 Annual Exercise, Vols 1 & 2 ML18038A4581989-04-28028 April 1989 Forwards Rev 0 to Updated SAR for Nine Mile Point Unit 2. Emergency Plan,Formerly Included in Fsar,Not Included in Updated Sar.Portions of Util Responses to NRC FSAR Questions Incorporated Into Body of Initial Updated SAR ML20246Q0071989-04-28028 April 1989 Forwards Proprietary Section 6A of Updated FSAR for Nine Mile Point Unit 2.Section 6A Withheld (Ref 10CFR2.790) ML20246B5451989-04-28028 April 1989 Advises That Util Will Submit Rev to Restart Action Plan After Receipt of Repts from NRC Special Team Insp & INPO Reassessment of Facility ML18038A4561989-03-23023 March 1989 Forwards Addl Info Supporting Application to Use Alternative to 10CFR50.55a Requirements.W/Two Oversize Drawings ML18038A4551989-03-21021 March 1989 Provides Util Plans for Future Exam & Evaluation of Four Feedwater Nozzles Per NUREG-0619.Indications Conservatively Evaluated as Cracks Not Scratch Marks.During 1993 Refueling Outage,Sparger from Nozzle a Will Be Removed 05000410/LER-1989-003, Forwards Corrected Copy of LER 89-003-00 Submitted on 890320.Typo Identified on Page 5 of 7 Corrected1989-03-21021 March 1989 Forwards Corrected Copy of LER 89-003-00 Submitted on 890320.Typo Identified on Page 5 of 7 Corrected ML18038A4521989-03-0202 March 1989 Forwards Responses to NRC Questions Re Licensee Restart Action Plan & Nuclear Improvement Program.Replacement Pages for Action Plan Encl ML20245J5521989-03-0202 March 1989 Forwards Rept of Physical Security Event,Reported Via Emergency Notification Sys on 890203 ML18038A4511989-02-22022 February 1989 Forwards Rev 4 to NMPC-QATR-1, QA Program Topical Rept for Nine Mile Point Nuclear Station Operations. Revs Include Corporate Reporting & Responsibility Changes as Well as Descriptions for Organizations Not Previously Identified ML18038A4501989-02-14014 February 1989 Forwards Rev 1 to TR-6801-2, Mark I Torus Shell & Vent Sys Thickness Requirements Nine Mile Point Unit 1 Nuclear Station. Requests Approval to Use Certified Matl Test Repts for Most of Torus Matls ML18038A4341989-01-18018 January 1989 Forwards Revised,Second 10-yr Interval Inservice Testing Program Plan for Plant & Supporting Documentation,Per 881220 Commitment.Interim Approval of Program as Submitted to Spent Fuel Loading Scheduled for Apr 1989 Requested ML18038A4201988-09-29029 September 1988 Advises That No Unresolved Safety Issues Re Flow Fluctuations & Neutron Flux Noise Exist,Per NRC 880527 Ltr Requesting Summary of Plans to Mitigate Oscillations in APRM Signals & Total Core Flow ML20154C4221988-09-0909 September 1988 Informs That Contracted Vendor to Present Courses Will Not Be Able to Commence Training Until Later in Month of Oct or Early Nov 1988.Schedule Revised to Have Instrumentation & Control Initial Training Implemented by Nov 1988 ML20154B4301988-09-0808 September 1988 Forwards Security & Safeguards Contingency Plan.Definition of Security Force Member Discussed.Plan Withheld ML17055E2471988-08-30030 August 1988 Forwards Semiannual Radioactive Effluent Release Rept, Jan-Jun 1988, & Revs 4 & 6 to Offsite Dose Calculation Manual. ML18038A4121988-07-28028 July 1988 Forwards Info Re Implementation of NUREG-0131,Rev 2, Technical Rept on Matl Selection & Process Guidelines for BWR Coolant Pressure Boundary Piping. ML18038A4101988-07-28028 July 1988 Forwards Comments,Clarifications & Agreements Re Implementation Re 880506 SER Concerning 10CFR50,App J.Info Submitted Per Commitment Resulting from 880609 Meeting W/ NRC.W/15 Oversize Drawings ML18038A4111988-07-28028 July 1988 Forwards Licensee Response to Generic Ltr 88-01 Re Austenitic Stainless Steel Piping at Facility.Application for Amend to Incorporate Requirements of Generic Ltr Will Be Submitted Later ML20151A2971988-07-15015 July 1988 Forwards Changes to Physical Security Plan.Supporting Info Also Encl.Encls Withheld (Ref 10CFR73.21) ML20151A2751988-07-15015 July 1988 Forwards Changes to Security Training & Qualification Plan. Changes Withheld (Ref 10CFR2.790) ML18038A4081988-07-0707 July 1988 Submits Listed Changes to Util 880609 Comments on SALP, Including Advisal That Review of Nonradiological Chemistry Program Revised to More Accurately Describe How Review Performed ML18038A4061988-07-0606 July 1988 Responds to Request for Addl Info on ATWS Review Re Alternate Rod Injection & Recirculation Pump Trip Sys.W/ Seven Oversize Drawings 1990-08-30
[Table view] |
Text
REGULATORY NFORNATION DISTRIBUTION SY 1'EN (RIDS)
ACCESSION NBR: 8603110343 DOC. DATE: 86/03/05 NOTARIZED: YES,, DOCKET ¹ FACIL: 50-410 Nine Mile Point Nuclear Station> Unit 2> Niagara Noha 05000410 AUTH. NANE AUTHOR AFFILIATION NANGAN> C. V. Niagara Mohawk Power Corp.
REC IP. NANE RECIPIENT AFFILIATION
- DENSAN> E. G. BWR ProJect Directorate 3 SUH CT; Requests exemption to exclude certain relief valves from Type C testing contained in Sec'tion II. H of App 4 of 10CFR50. Valves located inside primary containment or discharge to suppression pool from outside.
DISTRIBUTION CODE: H001D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: Licensing Submittal: PSAR/FSAR Amdts Zc Related Correspondence NOTES'EC IP IENT COPIES RECIPIENT COPIES ID CODE/MANE LTTR ENCL ID CODE/NAME LTTR ENCL BWR ADTS 1 1 BWR PD3 PD 1 1 HWR EB 1 1 BWR EICSB 1 1 HWR PD3 LA '1 HWR FOB 1 1 1 HAUGHEY> M 01 2 2 BWR PSB 1 BWR RSH 1 1 INTERNAL: ACRS 41 6 ADN/LFMB 1 0 ELD/HDS3 1 0 IE FILE 1 1 IE/DEPER/EPB 36 1 1 IE/DGAVT/GAB 21 1 1 NRR BWR ADTS 1 0 NRR PWR-A ADTS 1 0 NRR PWR-H *DTS 1 0 NRR'OE> M. L 1 1 QRRPH I
/HF H 1 l4RR/DHFT/NTB 1 1 REG FILE 04 RGN1 3 3
/NI B 1 0 EXTERNAL: 24X 1 BNL(AMDTS ONLY) 1 1 DNB/DSS (ANDTS) 1 1 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 PNL GRUEL> R 1 TOTAL NUMBER OF COPIES REQUIRED: LTTR 39 ENCL 33
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NIAGARA MOHAWK POWER CORPORATION/300 ERIE BOULEVARD WEST. SYRACUSE, N.Y. 13202/TELEPHONE (315) 474-1511 March 5, 1986 (NMP2L 0649)
Ms. Elinor G. Adensam, Director BHR Project Directorate No. 3 U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Nashington, DC 20555
Dear Ms. Adensam:
Re: Nine Mile Point Unit 2 Docket No. 50-410 Niagara Mohawk Power Corporation (" Niagara Mohawk" ) hereby requests exemptions pursuant to 10 CFR 50.12(a) from Type C test requirements of 10 CFR Part 50 Appendix J. Specifically, Niagara Mohawk requests the exclusion of certain relief valves from Type C testing contained in Section II.H of Appendix J.
The exemption has been reviewed and found to be authorized by law and consistent wi th the common defense and security. The attachment to this letter demonstrates that the requested exemption presents no undue risk to the health and safety of, the public and that special circumstances are present that justify granting the exemptions.
With regard to the "common defense and security" standard, the grant of the requested exemptions is consistent with the common defense and security of the United States. The Commission's Statement of Considerations in support of the exemption rule note with approval the explanation of this standard as set forth in Lon Island Li htin Com an (Shoreham Nuclear Power Station, Unit 1), LBP-84-45, 20 NRC 1343, 1400 (October 29, 1984). There, the term "common defense and security" refers principally to the safeguarding of special nuclear material, the absence of foreign control over the applicant, the protection of Restricted Data, and the availability of special nuclear material for defense needs. The granting of the requested exemptions will not affect any of these matters and thus such grant is consistent with the common defense and security.
The proposed exemption has been analyzed and determined not to cause additional construction or operational activities which may significantly affect the environment. They do not result in a significant increase in any adverse environmental impact previously evaluated in the final Environmental Impact Statement-Operating License Stage, a significant change in effluents or power levels or a matter uot previously reviewed by the Nuclear Regulatory Commission which may have a significant adverse environmental impact.
I I PDR
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Ms.
Page Elinor 2
G. Adensam t
Niagara Mohawk is ready to meet with the cognizant Nuclear Regulatory Commission personnel to review these matters should you require additional information.
Very truly yours, C. V. Mang Senior Vice President NLR:ja 1380G xc: R. A. Gramm, NRC Resident Inspector Project File (2)
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of Niagara Mohawk Power Corporation, ) Docket No. 50-410 (Nine Mile Point Unit 2) )
AFFIDAVIT C. V. Man an , being duly sworn, states that he is Senior Vice President of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
Subscribed and swor to be ore me, a Notary Public in d for t e State of New York and County of , this R Y" day of 1986.
N tar Public in and for County, New York My Commission expires:
JANIS M. MACRO Notary Pubttc In the State ot New York Qualitied In Onondaga County No. 47045 5 aty commlsslon r.xrrlrcs arc r
~ i ATTACHMENT
~EX ~ lt UES RELIEF VALVES TYPE C TESTING It is requested that an exemption be issued to exclude certain relief valves from the requirements of Section II.H of 10 CFR Part 50, Appendix J. These valves either are located inside the primary containment or discharge to the suppression pool from outside the primary containment. The discharges of the relief valves would be exposed to containment atmosphere following a loss of coolant accident. A listing of these valves is provided below:
- a. Residual Heat Removal System (RHS)
- l. 2RHS*RV20A, B, C
- 2. 2RHS*RV61A, B, C
- 3. 2RHS*RV108
- 4. 2RHS*RV110
- 5. 2RHS*RV139
- 6. 2RHS*RV152
- b. Low Pressure Core Spray (CSL)
- 1. 2CSL*RV105
- 2. 2CSL*RV123
- c. High Pressure Core Spray (CSH)
- 1. 2CSH*RV113 2 ~ 2CSH*RV114
- d. Reactor Building Closed Loop Cooling Water (CCP)
- 1. 2CCP*RV170
- 2. 2CCP*RV171 The relief valves and associated containment penetration piping are all Seismic Category I, Safety Class 2 components.
The grant of the requested exemption will not present an undue risk to the public health and safety. These valves are all included in the Type A primary containment integrated leak test. The discharge piping of the valves is exposed to either drywell or wetwell pressure during the test.
The purpose of this exemption request is to waive the requirement for Type C testing of these valves in accordance with 10 CFR 50 Appendix J. They will be included in the Type A test instead. The basis for this exemption request is the ALARA and design considerations related to the conduct of the Type C test for these valves.
~ ~
All the valves are located in potentially high radiation areas. They require dismantling of discharge piping to perform the test, since there are no maintenance valves to provide a test boundary. The relief valves were purposely designed without surrounding block valves to comply with the guidance of Subsection NC7000 of the ASME Code,Section III. Thus, preparations and performance for Type C testing of these valves could result in excessive radiation exposure to plant personnel. This is contrary to ALARA policies considering that the valves can be included in the Type A test.
In addition to ALARA concerns, other considerations support the exemption of these'valves from Type C test requirements. All the valves located in the secondary containment (13 out of 16 valves) discharge into common headers which penetrate the primary containment wall and then turn down into the suppression pool. To provide a test boundary for individual valves would require blank flanges in each valve discharge line. These flange connections would themselves represent additional leakage paths from the primary containment. Also, these flange connections would require Type 8 testing, thereby aggravating the ALARA concerns. It should also be noted that LOCA pressure and valve spring pressure tend to seat the valves against leakage.
For the three valves located inside the drywell, i.e., CCP*RV170, 171 and RHS"RV152, there is little likelihood of any leakage to the secondary containment. The only path through these valves is across the valve seat.
LOCA pressure opposes the normal valve opening, and the valve springs, set for relief pressures of 100 psig to 1575 psig, assist in seating the valves.
Furthermore, any leakage that might occur would be detected during normal system operation. System operating pressures are higher than LOCA pressure and tend to open the valves. Thus, any valve seat degradation would be evident during system operation prior to reaching a condition that would permit significant post-LOCA leakage. Leakage through these valves would be detected early by several means, e.g., loss of expansion tank level (CCP), a loss of reactor level (RHS), and an increase in drywell floor drain tank level.
Based on the above considerations, exclusion of the safety relief valves from the Type C testing would present no undue risk to the public health and safety.
Speci Circumstances are Present Which Warrant Issuance of the Re vested Exem tions Special circumstances are present which warrant issuance of the requested exemption. These special circumstances are discussed in accordance with the classification contained in the rule.
(i) "Application of the regulation in the particular circumstances conflicts with other rules or requirements of the Commission; or" As previously discussed, Appendix J is in conflict with ALARA considerations.
Thus, special circumstances are present which warrant granti,ng .the exemption...
(ii) "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule..."
As previously discussed, to provide a test boundary for certain individual valves would require blank flanges in each valve discharge line. These flange connections would themselves represent additional leakage paths from the primary containment. Thus, special circumstances are present which warrant granting the exemption.
(ii) "Application of the regulation i'n the particular circumstances . . . is not necessary to achieve the underlying purpose of the rule; or The underlying purpose of the rule is to assure a low leakage containment with the ultimate objective of keeping accident doses low. These valves are all included in the Type A primary containment integrated leak test. The discharge piping of the valves is exposed to either drywell or wetwell pressure during the test. Thus, special circumstances are present which warrant granting the exemptions.
IP L