ML111660388

Request for Additional Information, Extension of Completion Time for Inoperable Diesel Generator, Technical Specifications Review

ML111660388
Person / Time
Site:	Nine Mile Point
Issue date:	07/11/2011
From:	Richard Guzman Division of Operating Reactor Licensing
To:	Belcher S Nine Mile Point
Guzman R, NRR/DORL, 415-1030
References
TAC ME3736
Download: ML111660388 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 11, 2011 Mr. Samuel L. Belcher Vice President Nine Mile Point Nine Mile Point Nuclear Station, LLC P.O. Box 63 Lycoming, NY 13093

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING NINE MILE POINT NUCLEAR STATION, UNIT NO.2 - RE: TECHNICAL SPECIFICATION REVIEW FOR EXTENSION OF COMPLETION TIME FOR INOPERABLE DIESEL GENERATOR (TAC NO. ME3736)

Dear Mr. Belcher:

By letter dated March 30, 2010, as supplemented on June 1, 2010, December 29, 2010, January 14, 2011, February 25, 2011, and April 27, 2011, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted a license amendment for Nine Mile Point, Unit No.2 (NMP2). The proposed amendment would modify NMP2 Technical Specification (TS) Section 3.8.1, !lAC Sources - Operating," to extend the Completion Time for an inoperable Division 1 or Division 2 diesel generator from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days. The proposed amendment represents a risk informed licensing change.

The Nuclear Regulatory Commission staff is reviewing the information provided in those letters and has determined that additional information is needed to support its review. Enclosed is the NRC staff's request for additional information (RAI). The RAI was discussed with your staff on June 15 and July 6, 2011, and it was agreed that your response would be provided within 30 days of the date of this letter.

Sincerely, Richard V. Guzman, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-410

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION FOR LICENSE AMENDMENT REQUEST RE: EXTENSION OF COMPLETION TIME FOR INOPERABLE DIESEL GENERATOR TECHNICAL SPECIFICATIONS REVIEW NINE MILE POINT NUCLEAR STATION, LLC NINE MILE POINT NUCLEAR STATION, UNIT NO.2 DOCKET NO. 50-410 By letter dated March 30, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100900460), as supplemented by letters dated June 1, 2010 (ML101600452), December 29,2010 (ML110110165), January 14,2011 (ML110250271),

February 25, 2011 (ML110670424), and April 27, 2011 (ML11119A137), Nine Mile Point Nuclear Station, LLC (NMPNS or the licensee) submitted a license amendment request (LAR) for Nine Mile Point Nuclear Station, Unit No.2 (NMP2) requesting changes to the Technical Specifications (TSs) to extend the allowable completion time (CT) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days when one emergency diesel generator (DG) is inoperable. The NRC staff is reviewing the LAR and has determined that additional information as requested below will be needed to complete its review.

Based on the NRC staff's review of the LAR and the supplemental information, the NRC staff has identified areas for which additional information is needed to complete its review.

In your response to the NRC staff's request for additional information (RAI) dated January 14, 2011, the following statements were provided, in part, in response to RAI-1:

As noted in the March 30, 2010 NMPNS submittal, prior to utilizing the extended DG CT (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), operability of the HPCS

[High Pressure Core Spray] system and the Division 3 (HPCS) DG will be confirmed, with no planned maintenance or testing activities scheduled (Emphasis added). This confirmation is a prerequisite for entering the extended DG CT.

The response to RAI-1 also states:

... As specified in TS 3.8.1, if the HPCS DG became inoperable during the time that the Division 1 or Division 2 DG was already inoperable, Required Action E.1 would require that the HPCS DG be restored to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

At the end of this 24-hour period, the HPCS system could be declared inoperable in accordance with the Applicability Note for TS 3.8.1, and Condition E could be exited with only one required DG remaining inoperable...." Emphasis added).

Enclosure

-2 Regarding the following RAI, it should be noted that the NMP2 TSs, Section 1.1, defines OPERABLE-OPERABILITY as follows:

A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

RAI-1.a Please explain how and why the OPERABLE HPCS could be intentionally declared inoperable given that no planned maintenance or testing activities will be scheduled during the extended CT.

RAI-1.b Please explain why the HPCS could be made intentionally inoperable given the above stated assurance that the OPERABILITY of the HPCS system and the Division 3 (HPCS) DG will be confirmed as a prerequisite for entering the extended DG CT.

RAI-1.c Please explain how it is possible to declare the HPCS system inoperable given the scenario described above when the system has been verified as OPERABLE, no work has been performed on the system and the system is OPERABLE per the NMP2 TS definition.

RAI-1.d Please explain the safety benefit(s) of intentionally causing an OPERABLE HPCS to be TS inoperable in order to extend the TS LCO 3.8.1.b non-compliance time, by an additional 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, when operating in a mode where the HPCS is required to be OPERABLE.

RAI-1.e As identified in the above January 14, 2011, response to RAI -1, it is stated that: " ... prior to utilizing the extended DG CT (greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and up to 14 days), operability of the HPCS system and the Division 3 (HPCS) DG will be confirmed, with no planned maintenance or testing activities scheduled." However, in the LAR dated March 30,2010, Attachment 1, List of Regulatory Commitments, and Attachment 3, Changes to Technical Specifications Bases, it is stated that: "The HPCS system is available and no planned maintenance or testing activities are scheduled."

Please explain/provide (1) any difference(s) between "operability" and "available" as used in the above statements, (2) the definition of "available," and identify where in the NMP2 TS the

-3 definition of "available" can be found, (3) provide an example of how an "available" HPCS, or other safety-related system, structure or component (SSC), differs from a TS "OPERABLE/OPERABILITY" HPCS or SSC.

The NMP2 TS LCO 3.0.2 Bases states, in part:

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems. Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience. Additionally, if intentional entry into ACTIONS would result in redundant equipment being inoperable, alternatives should be used instead ....

Please explain how the intentional removal of the OPERABLE HPCS system from service (Le.,

declared TS inoperable per the above definition of OPERABLE-OPERABILITY):

a. Does not compromise safety,

b. Does not result in redundant equipment being inoperable,

c. Is not being done for operational convenience (i.e., provide additional time to operate while the requirements of TS LCO 3.8.1 are not being met).

The requirements for TS LCOs are established in 10 CFR 50.36, which states:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The definition of "remedial actions" is described in the Standard Technical Specifications (NUREG-1434) as follows:

ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under deSignated Conditions within specified Completion Times.

Regarding the above background, please explain how NMP2 TS 3.8.1, Required Action E.1, "Restore one required inoperable DG to OPERABLE status" is met, with either Division 1 or Division 2 DG inoperable and the Division 3 DG inoperable by intentionally placing the TS OPERABLE HPCS in an inoperable Condition per the TS 3.8.1 "Note."

.. ML111660388 *RAI provided by memo. No substantial changes made.

OFFICE LPL 1-1/PM LPL1-1/LA ITSS/SC' LPL 1-1/SC INAME RGuzman SUttle RElliott NSalgado IDATE 7/11/11 7/11/11 06/09/11 7/11/11