ML053320201
| ML053320201 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/17/2005 |
| From: | O'Connor T Constellation Energy Group, Nine Mile Point |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP1L 1996, TAC MC3272, TAC MC3273 | |
| Download: ML053320201 (27) | |
Text
Q,.Constellation Energy
- Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, NY 13093 November 17, 2005 NMP1L 1996 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
SUBJECT:
Nine Mile Point Units 1 and 2 Docket Nos. 50-220 and 50-4 10 Facility Operating License Nos. DPR-63 and NPF-69 Amended License Renewal Application - Superseding Tables for Clarifications to the Nine Mile Point Nuclear Station Amended License Renewal Application (TAC Nos. MC3272 and MC3273)
Gentlemen:
By letter dated July 14, 2005, Nine Mile Point Nuclear Station, LLC (NMPNS) submitted an Amended License Renewal Application (ALRA) for the operating licenses of Nine Mile Point Units 1 and 2.
By letter dated September 15, 2005, NMPNS provided responses to Requests for Additional Information (RAIs) and a table of clarifications to the ALRA in a section-by-section format.
Based on a request by the NRC staff, the clarifications have been regrouped and presented by topical area. Where appropriate, additional information supporting the basis for the clarifications has been added. Attachment A supersedes in its entirety the tabular clarification of information in the September 15, 2005 letter. The responses to the RAI in the September 15, 2005, letter remain unaffected. Attachment B identifies new and revised commitments in this letter.
If you have any questions about this submittal, please contact David D llario, NMPNS License Renewal Project Manager, at (315) 349-7141.
/
TJO/JJD/sac AC) 7
Page 2 NMP1L 1996 STATE OF NEW YORK
- TO WIT:
COUNTY OF OSWEGO I, Timothy J. O'Connor, being duly sworn, state that I am Plant General Manager, and that I am duly authorized to execute and file this information on behalf of Nine Mile Point Nuclear Station, LLC. To the best of my knowledge and belief, the statements contained in this submittal are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Nine Mile Point employees and/or consultants. Such information has been reviewed in accordance wit company practice and I believe it to be reliable.
/Timot J
'Connori Plant e eral Manager Subscribed and sworn before me, a Notary Public in and for the State of New York and County of Oswego, this l I +L day of 11a nIi A, 2005.
WITNESS my Hand and Notarial Seal:
TONYA L JONES Ndary Pubce kintState of Now York OswegdCounty Rz. No.01406q8354 My Commissioni Expires 1 Q4D My Commission Expires:
Ndary Public
' Ai //,O & 0 Dat'e
/
Attachment A: Superseding Tables for Clarifications to the Nine Mile Point Nuclear Station Amended License Renewal Application Attachment B:New and Revised Commitments cc:
Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. L. M. Cline, NRC Senior Resident Inspector Mr. T. G. Colburn, Senior Project Manager, NRR Mr. N. B. Le, License Renewal Project Manager, NRR Mr. J. P. Spath, NYSERDA
ATTACHMENT A to NMP1L 1996 IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
C Description ALRA Change Basis for Change N.or Table M LACag For the spent fuel racks, add the Component Types "Boraflex in Treated T 2.4.A.4-1 Water" and "Boral in Treated Water," each with the Intended Function (IF) of "Absorbs Neutrons" (AN).
Item 3.3.1.A Replace the Discussion with the following: "Consistent Aging management of T 3.31.A with NUREG-1 801, except the Water Chemistry Control (WCC) Program The basis for this change and the indicated spent fuel racks in the and the One Time Inspection (OTI) Programs are credited for aging ALRA revisions is to be consistent with the I
Nine Mile Point, Unit I management."
Generic Aging Lessons Learned (GALL)
Nine M*il spent fueni Report and to address discussions held during pool (SFP)e S 3.5.2.A.4 Add the OTI Program to the aging management program (AMP) Section.
the license renewal audit; therefore, AERMs For "Boral in Treated Water," revise this line Item to add the Aging Effect for "Boral in Treated Water" are added.
Requiring Management items (AERMs) of "Loss of Material" (LOM) and T 3.5.2.A-4 "Reduction of Neutron Absorbing Capacity," the AMPs of OTI and WCC, the NUREG-1 801, Volume 2, Item of VI.A2.1-b, the Table I Item of 3.3.I.A-l0, and a Note of E.
1 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Description Section (S ALRA Change Basis for Change No..
Tor Table (TM T 2.4 7-I For the spent fuel racks, add the Component Type "Boral in Treated Water"
.__._._-_(TW) with the IF of AN.
Item 3.3.1.B Replace the Discussion with the following: "Consistent with NUREG-l 801, except the WCC and OTI Programs are credited for aging management."
Item 3.3.1.B Replace the Discussion with the following: "Prior to entry T 3.3.1.B into the Period of Extended Operation (PEO), the current NMP2 spent fuel rack design that utilizes Boraflex for reactivity control will be replaced by a design that utilizes Boral for that function. Therefore, Boraflex is not within scope of license renewal (WSLR) and the Boraflex Monitoring Program (BMP) is not credited for NMP2."
Replace Boraflex with Boral in the Materials Section.
The basis for this change and the indicated Ao S 3.5.2..7 Remove the BMP from the AMP Section and add the OTI Program.
Nuclear Station, LLC (NhMcptNine Mile Point Aging management of NcerSain L
N N)mngmn spent fuel racks in the Remove the "Boraflex in Treated Water" line items from NMP2 Table decision to have all Boraflex removed from 2
Nine Mile Point, Unit 3.5.2.13-7. There will be no Boraflex WSLR in the NMP2 spent fuel pool the NMP2 SFP prior to entry into the NMP2 2 (NMP2), spent fuel during the PEO.
PEO. Due to the timing, the ALRA did not reflect this decision. Additionally, aging pool.
Add a new line item for "Boral in Treated Water" with the IF of AN, the management of Boral in the SFP was aligned Material of Boral, the environment of TW<I 401F, Gamma Irradiation, the with the GALL consistent with NMP I, as T 3.5.2.B-7 AERMs of LOM and "Reduction of Neutron Absorbing Capacity," the discussed in the previous issue.
AMPs of OTI and WCC, the NUREG-1 801, Volume 2, GALL Item of VIL.A2. I-b, the Table I Item of 3.3.1.B-1 0, and Notes of E, 8.
Add new Note 8 to the end of the 3.5.2 Tables as follows: "The current NMP2 spent fuel rack design utilizes Boraflex for neutron absorption; however, prior to entry into the PEO, these racks -will be replaced with a new design that utilizes Boral for this function."
Add a new commitment as follows: Commitment: Prior to the Period of Extended Operation for NMP2, the spent fuel rack design that currently S A2.4 utilizes Boraflex for reactivity control in the spent fuel pool will be replaced
.4 by a design that utilizes Boral for this function. Source: ALRA Table 3.3.1..B, Item 3.3.1.B-12 and ALRA Table 3.5.2.B-7. Schedule: Prior to Period of Extended Operation.
2 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Description Section ()
.ALRA Change Basis for Change No.
or Table (T)
S 3.2.2.A. I Add "Loss of Heat Transfer" to the AERM Section.
T 3.2. 1A Revise the Discussion column for Item 3.2.1.A-12 to delete the existing text and replace with the statement "Consistent with NUREG-I 801."
For consistency with the "Open Cycle Cooling Water System" (OCCW) Program described Aging management of in GALL Section XI.M20, these changes are the NMPI containment For the heat exchangers with a Material of carbon steel (CS), revise the made. The cooling water for the Containment 3
spray heat exchanger AMP to OCCW, the NUREG-I 801, Volume 2, Item to V.D2.4-a, the Table Spray System is its own OCCW System; cooling water I Item to 3.2.l.A-12 and the Note to A, 27.
however, it is not normally wetted. The components components arc, thereforc, not in a Raw Water For the heat exchangers with a Material of stainless steel, add an AERM of environment. They are normally in a moist air "Loss of Heat Transfer" with an AMP of OCCW, the NUREG-I 801, environment.
T 3.2.2.A-Volume 2, Item to V.D2.4-b, the Table I Item to 3.2.1.A-I 2 and the Note to A, 27.
For the heat exchangers with a Material of stainless steel and an AERM of LOM, revise the AMP to OCCW, the NUREG-1801, Volume 2, Item to
.V.D2.4-a, the Table I Item to 3.2.I.A-12 and the Note to A, 27.
Delete the "Wrought Austenitic Stainless Steel (WASS) Piping and A review of the system drawing and the Presence of WASS Fittings" line items with the IFs of "Leakage Boundary (Spatial)" (LBS)I piping classes of the NSR portions of the NSR components in the "Structural Integrity (Attached)" (SIA). It has been determined that there is system has resulted in the determination that 4
NMPI Emergency T 3.2.2A-3 o non-safety-related (NSR) WASS piping in this system.
all of the "NSR Piping and Fittings and Cooling (EC) System Delete the WASS Valves line items with the IFs of LBS/SIA. It has been Valves" are fabricated of CS instead of I determined that there are no NSR WASS valves in this system.
WASS.
3 of 16
IDENTIMIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Section (S).
NO.
Description Table
(
ALRA Change Basis for Change In the Environments Section, add "Demineralized Untreated Water" S 3.2.2.B.5 (DUW). In the AMP Section, add the "Closed Cycle Cooling Water" (CCCW) Program.
The RHR pump seal coolers are cooled by the Aging management of Revise the Discussion column for Item 3.2.1.B1-13 to delete the existing text Reactor Building Closed Loop Cooling the NMP2 residual heat T 3.2.1.13 and replace with the statement "Consistent with NUREG-1801."
(RBCLQ System. Te Servicc Water System 5
removal (RHR) pumpea provides manual backup cooling to these seal coolers components. The normal environment for the inside of the WASS tubes is, therefore, the For the WASS heat exchanger components on page 3.2-99, replace the DUW of the RBCLC System.
"Raw Water, Low Flow" environment with DUW; delete the row with the T 3.2.2.B-5 AERM of "Loss of Heat Transfer;" for the row with the AERM of "Loss of Material," revise the AMP to CCCW, NUREG-I 801 Volume 2 Item to V.D2.4-c, and Table I Item to 3.2.1.13-13.
T 3.3. 1.13 Item 3.3.1.13 In the Discussion, delete the last bullet referring to Turbine Building Closed Loop Cooling (TBCLC) System heat exchangers.
Te change in Environments for the NMPI TBCLC System was to make it consistent Change the Environment listing of TW<1401F to DUW. Change the AMP with the NMPI RBCLC System environment S 3.3.2.A.22 listing of CCCW Program to the Preventive Maintenance (PM) Program and since both systems share a common supply add the WCC Program.
source.
The discussions relative to the CCCW System For all Component Types except "Bolting," "External Surfaces," and and Program in GALL Sections VII.C2 and
- Aging Management of T3.3.2.A-22 "Copper Alloy Valves," change the Environment to DUW, the AMP to PM XI.M21, respectively, apply to the CCCW 6
the TBCLC System for and WCC Programs, the NUREG-1801, Volume 2, and Table I Items to System that provides cooling to reactor plant-NMPI and NMP2 blank, and the Notes to J.
related heat loads (this is the RBCLC System at NMPNS). Such systems undergo special S 3.3.2.B.40 Change the AMP listing of CCCW Program to the PM Program and add the surveillance testing, etc. due to their heat WCC program.
loads. The TBCLC System does not have any such heat loads within the scope of the system Change the AMP for all applicable TBCLC System components from the and does not, therefore, need to be subjected T 3.3.2.B-40 CCCW Program to the PM Program and the WCC Program. Change the to the same kind of surveillance rigor as the
..3.
NUREG-1 801, Volume 2, and Table I Items to blank and Notes to J for the RBCLC System.
same components.
4 of 16
IDENTIFIED CHANGES TO TILE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
ChangeSeto
)
no.
Description tALRAChange Basis for Change
.N.or Table, (1LR)hag S 3.3.2.A. I Replace the PM Program with the OCCW Program in the AMP Section.
Revise the Discussion column of Item 3.3.1.A-17 to delete the first sentence T 3.3.l.A of the second paragraph regarding the NMPI Circulation Water System crediting the PM Program.
Delete the PM AMP for "CS External Surfaces."
Since the system CS exteral surfaces are Change AMP for the Circulating Water Gates to the OCCW Program from already monitored by the Systems Walkdown Aging management of the PM Program and change Note to C, 8.
Program, the application of the PM Program the MP Cirulaingwas redundant, so it is being removed. For 7
the NMPI Circulating Change AMP for the "Piping and Fittings" to the OCCW Program from the the Circulating Water Gates, Piping and Water System PM Program and change Note to A.
Fittings, Pumps, Traveling Screens and Rakes, components and Valves, the change from the PM Program T 3.3.2.A-l Change AMP for the Pumps to the OCCW Program from the PM Program to the OCCW Program was made for GALL
..3.
and change Note to A for both the OCCW and Selective Leaching consistency.
Programs.
Change the AMP for "Traveling Screens and Rakes" to the OCCW Program from the PM Program and change Note E, 8 for CS and WASS to Note C, 8.
Change AMP for Valves to the OCCW Program from the PM Program and change Note E, F to just F for both the OCCW and Selective Leaching Programs.
S 3.3.2.A.8 Add the Buried Piping and Tanks Inspection Program to the AMP Section.
Add an External Surfaces item for "Gray Cast Iron (GCI) in Soil, Above the Aging management of T 3.3.2.A-8 Water Table" environment with the AERM of LOM, the AMP of Buried Piping and Tanks Inspection Program, the GALL Item of VII.C2.1-b, the It was determined that the barrel of the GCI 8
the NMPI and NMP2 Type I Table Item of 3.3.I.A-1 8, and Note F.
fire hydrants is partially buried.
f ire hydrants Add an External Surfaces item for GCI in Soil, Above the Water Table T 3.3.2.B-13 environment with LOM, the AMP of Buried Piping and Tanks Inspection T.3.2.13-1 Program, GALL Item VIL.C 1.1 -b, Type I Table Item of 3.3. 1.B-1 8, and Note F.
5 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Nge Description Section (,)
ALRA Change Basis for Change No.
or Table M LR Chag Delete the Flow Accelerated Corrosion (FAC) Program from the AMP
-S 3.3.2.A.14 Listing.
S 3.3.2.A.24 Delete the FAC Program from the AMP Section.
It was determined from the FAC Program Non-applicability of basis documentation that the applicable FAC to the NMPI Remove the FAC Program AMP line items for LOM of Piping and Fittings.
portions of the Radwaste and Electric Boiler Radwaste and Electric For Valves crediting the FAC Program, change the AMP to OTI and WCC, conditions <2% of the time. Per NSAC 202L, Boiler Systems T 3.3.2.A-14 the GALL Item to VllJ.C.2-b, the Table I Item to 3.4..A-02, and the Note with this usage, these systems do not warrant to B.
inclusion in the program.
Change line items for LOM credited by the FAC Program for Piping and Fittings and Valves to credit the OTI and WCC Programs, GALL Items T 3.3.2.A-24 VIII.C.1-b (for piping) and VIII.C.2-b (for valves), the Table I Item to 3.4.1.A-02, and Notes to B.
S 3.3.2.A.22 Add the OTI Program to the AMP Section.
For the Copper Alloy (A5% Zn) Valve in a TW<1401F environment, T 3.3.2.A-22 change to a DUW environment, change the AERM from None to LOM, the AMP from None to the OTI Program, and the Note from None to H.
For the Copper Alloy (:K 5% Zn) Valve in a DUW environment, change the T 3.3.2.A-2 AERM from None to LOM, the AMP from None to OTI Program, and the Note from None to H.
Aging management of For the Copper Alloy (: 5% Zn) Filter/Strainers and Valves in a DUW NMPI and NMP2 T 3.3.2.A-15 environment, change the AERM from None to LOM, the AMP from None It was determined that to be consistent with 10 Copper Alloy (A 5%
to the OTI Program, and the Note from None to 11.
other like material/environment applications Zn) components in a in the ALRA, these changes were needed.
DUW environment For the Copper Alloy ( 2 5% Zn) Heat Exchanger in a DUW environment, T 3.3.2.A-17 change the AERM from None to LOM, the AMP from None to the OTI Program, and the Note from None to H.
For the Copper Alloy (A 5% Zn) Piping and Fittings and Valves in a DUW T 3.3.2.B-I I environment, change the AERM from None to LOM, the AMP from None to the OTI Program, and the Note from None to H.
For the Copper Alloy (A 5% Zn) Piping and Fittings in a DUW T 3.3.2.B-38 environment, change the AERM from None to LOM, the AMP from None to the OTI Program, and the Note from None to 11.
6 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Scin()BssfrCag No.
-or Table
)
ALRA Change.
Basis fo Change To be consistent with the enhancement Aging management of identified for the NMPI Compressed Air NMPI Compressed Air Change the AMP for the Cold Worked Red Brass External Surfaces from Monitoring Program (ALRA Section Al.1.14) 1 1 System Cold Worked T 3.3.2.A-3 the Systems Walkdown Program to the Compressed Air Monitoring to develop a new activity to manage stress Red Brass tubing Program.
corrosion cracking. The Systems Walkdown external surfaces Program does not manage this aging mechanism.
Revise the Discussion column of Item 3.3.1.A-15, first sentence, to state:
T 3.3.1.A "Consistent with NUREG-I 801." Delete the existing phrase "with exceptions (see Appendix B.2.1.11)."
The removal of the BWR Reactor Water Cleanup Program is to correct an oversight Aging management of S 3.3.2.A.7 Under the Aging Management Programs heading, delete the WCC Program from the ALRA submittal.
components in the bugeted item.
The remaining changes were made based on 12 Diesel Generator For WASS heat exchangers in a TW<1407F environment (2 entries), change the consistency of the NMPNS CCCW (EDG) and RBCLC the AMP to CCCWProgram, the NUREG-1801, Volume 2, Item to Program with GALL Program XI.M21. The Systems VII.C2.2-a, the Table I Item to 3.3.1.A-15, and the Notes to C, 6.
identified components are in CCW Systems, T 3.3.2.A-7 which are managed for aging by the CCCW For WASS valves in a TW<I 401F environment, change the AMP to CCCW Program.
Program, the NUREG-1 801, Volume 2, Item to VII.C2.2-a, the Table I Item to 3.3.1.A-15, and the Note to A.
7 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change
~-.Section (S).....-.....-
Nge Description Section (S)
ALRA Change' Basis for Change
.or Table (T)
S 3.3.2.A.15 Under the Aging Management Programs heading, delete the BWR Reactor
.. A..
Water Cleanup System Program bulleted item.
For heat exchangers that credit the CCCW Program and the OTI Program (3 entries), delete the OTI Program.
For heat exchangers that credit only the On Program, add the WCC Program.
For WASS heat exchangers in a DUW environment, change the AMP to 12 Closed-Cycle Cooling Water System Program, the NUREG-I 801, Volume (continued) 2, Item and Table I Item to blank, and the Note to J.
T 3.3.2.A-15 For WASS orifices in a DUW environment, change the AMP to CCCW Program, the NUREG-1 801, Volume 2, Item and Table I Item to blank, and the Note to G.
For WASS temperature elements in a DUW environment, change the AMP to CCCW Program, the NUREG-. 801, Volume 2, Item and Table I Item to blank, and the Note to 0.
For WASS valves in a DUW environment (2 entries), change the AMP to CCCW Program, the NUREG-1801, Volume 2, Item and Table I Item to blank, and the Note to G.
Aging management of For Table 3.3.2.A-23, change the AERM for Fiberglass External Surfaces NMPI and NMP2 T 3.3.2.A-23 from None to Cracking and Loss of Strength, the AMP from None to PM Turbine Building (TB)
Progm, and Note from None to J.
The credited activities in the PM Program 13 Heating, Ventilation address both the internal and external portions and Air Conditioning For Table 3.3.2.B-23, change the AERM for Fiberglass External Surfaces of these fiberglass components.
(HVAC) System T 3.3.2.B-23 from None to Cracking and Loss of Strength, the AMP form None to PM fiberglass components Program, and Note from None to J.
8 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Description ALRA Change Basis for Change' No.
'or Table mAR Cag
,S 3.3.2.B.8 Add the Bolting Integrity Program and remove the OTI and WCC Programs S.3...
from the AMP Section.
Aging management of Revise the Discussion column for Item 3.3.1.B-15, first bullet to state, NMP2 Control T 3.3.1.B "Control Building Chilled Water System components in a treated water These changes are made for GALL 14 Building Chilled Water environment."
consistency since all of the cooling water System WASS Wltw components in this system are included in the elements and valves For WASS flow elements and valves in TW<1401F, change the OTI and CCCW Program.
WCC Programs to the CCCW Program. The flow elements and valves T 3.3.2.B-8 should be assigned the NUREG-I 801, Volume 2, Item VII.C2.2-a, the Table I Item 3.3.1.B-15, and the Notes should be C and A for the flow elements and valves, respectively.
Revise the Discussion column for Item 3.3.1.B-139, last bullet to include This change is made for GALL consistency.
Aging management of T 3.3.1.B carbon steel sprinklers in an internal air environment.
The Fire Protection Program was 15 the NMP2 Fire Water inadvertently credited for aging management System sprinklers T 3.3.2.B-13 Change the AMP for sprinklers from the Fire Protection Program to the Fire of the sprinklers instead of the Fire Water Water Program.
Program.
Aging management of For the Component Type "Piping and Fittings," the entries for the last three 16 NMP2 Hot Water T 3.3.2.B-17 columns are changed to VIII.E.I-b, 3.4.1.B-02, and B, respectively. For the The indicated changes are to bring these items Heating System piping Component Type 'Valves," the entries for the last three columns are into consistency with the GALL.
and fittings and valves changed to VIII.E.2-b, 3.4.1.B-02, and B, respectively.
T 2.3.3.B.34-1 Add Component Type of Flow Element, with an IF of LBS.
During post-ALRA reviews of the associated iNMP2 Circulating S 3.3.2.B.34 Under the Materials heading, add WASS.
Integrated Plant Assessment (IPA) documents, 1 7 NM2Cruaigit Nvas discovered that the Flowv Element Water System flow Add a newv row with a Component Type of Flow Element, IF of LBS, Component Type was inadvertently omitted emnT 3.3.2.-34 Material of WASS, Environment of Raw Water, AERM of LOM, AMP of for the NMP2 Circulating Water System.
OCCW, NUREG-I801, Volume 2, Item of VII. C3.2-a, Table I Item of 3.3.1.B-17, and Notes ofC, I.
9 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change Description l
Section
(
Basis for Change No.
or Table Add an additional enhancement to establish monitoring and trending S A1.1.5 instructions for in-situ test results, silica levels, and coupon results.
This enhancement was added to further align NMPI with the GALL, in that it assures that Addition of an Revise the Commitment for the BMP (Item 16), to add an additional activities associated with the BMP use 18 enhancement to the S Al.4 enhancement to establish monitoring and trending instructions for in-situ monitoring and trending of data wherever Program for NMPo I
test results, silica levels, and coupon results.
possible. 'Tis provides additional assurance that the shutdown margin in the SFP is maintained.
Add an additional enhancement to establish monitoring and trending S B2.1.12 instructions for in-situ test results, silica levels, and coupon results for the Program Element of Monitoring and Trending.
10 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
No.
Descriptionection ALRA Change Basis for Change ChN ge D s r p i n or Table (T)__
Clarify that the program activities include effects on fracture toughness due to neutron fluence and thermal embrittlement. Replace the last bullet on S A.l.112 page Al-6 with the following: "Enhance the program to evaluate component susceptibility to loss of fracture toughness. Assessments and inspections will be performed, as necessary to ensure that intended functions are not impacted by the aging effect."
Replace the Commitment in Item 37 with the following (the Source and Schedule remain the same): "Enhance the program to evaluate component S AI.4 susceptibility to loss of fracture toughness. Assessments and inspections will be performed, as necessary, to ensure that intended functions are not Management of fracture impacted by the aging effect."
toughness of NMPI Clarify that the program activities include effects on fracture toughness due NMPNS credits the BWRVIP for managing Austenitic Stainless to neutron fluence and thermal embrittlement. Replace the last bullet on the aging of CASS. The text wVas added to 19 Steel (CASS)
S A2.l.13 page A2-6 with the following: "Enhance the program to evaluate component address loss of fracture toughness as an aging components with the susceptibility to loss of fracture toughness. Assessments and inspections effect for CASS.
BWRpoVensselt Itherl will be performed, as necessary to ensure that intended functions are not.
impacted by the aging effect."
Replace the Commitment in Item 35 with the following (the Source and Schedule remain the same): "Enhance the program to evaluate component S A2.4 susceptibility to loss of fracture toughness. Assessments and inspections will be performed, as necessary, to ensure that intended functions are not
.____________ -impacted by the aging effect."
Under the "Parameters Monitored/Inspected" Program Element, replace the text of the current bullet with the following: "Enhance the program to S B2.1.8 evaluate component susceptibility to loss of fracture toughness.
Assessments and inspections will be performed, as necessary, to ensure that intended functions are not impacted by the aging effect."
11 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
- Change, Dsrito Section (S)
- n.
Desription ALRA Change Basis for Change No.
- o. Tal S A1.1.17 Add an additional enhancement to change Halon and Carbon Dioxide functional test frequencies to semi-annual.
Addition of an S A2.1.17 Add an additional enhancement to change Halon and Carbon Dioxide enhancement for functional test frequencies to semi-annual.
This enhancement is required to be consistent inspection frequency of Add an additional enhancement to change Halon and Carbon Dioxide with the GALL, which requires that a periodic 20 NMPI and NMP2 nulfrtePormEeeto halon/CO2 fire S B2.1.16 functional test frequencies to semi-annual for the Prgram Element of functional test and inspection be performed at suppression Detection of Aging Effects.
least once every six months on the halon/CO2 components in the Fire Commitment #19 - Add and enhancement to revise Halon and Carbon fire suppression systems.
Protection Program S Al.4 Dioxide Functional test frequencies to semi-annual.
Commitment #17-Add and enhancement to revise Halon and Carbon S A2.4 Dioxide Functional test frequencies to semi-annual.
S Al1.118 Add an enhancement to develop new procedures and PM tasks to implement l.1 sprinkler head replacement and/or inspections.
S A2. 1.18 Add an enhancement to develop new procedures and PM tasks to implement sprinkler head replacement and/or inspections.
o o aAdd an enhancement to develop new procedures and PM tasks to implement Addition of an S 132.1.17 sprinkler head replacement and/or inspections under the Program This enhancement is required to be consistent enhancement for new S
Despriptionk with the latest industry and regulatory NMPI and NMP2 p
precedence which stipulates that sprinkler 21 procedures and PM Commitment 120- Add an enhancement to develop new procedures and heads be inspected before the end of the 50-tasks for Fire Water PM tasks to implement sprinkler head replacements and/or inspections to year sprinkler head service life and at 10-year System sprinkler heads S A 1.4 meet National Fire Protection Association (NFPA) 25, "Inspection, Testing, intervals thereafter during the PEO.
and Maintenance of Vater-Based Fire Protection Systems," Section 5.3.1 (2003 Edition) requirements.
Commitment 118 - Add an enhancement to develop new procedures and PM S A2.4 tasks to implement sprinkler head replacements and/or inspections to meet NFPA 25, Section 5.3.1 (2003 Edition) requirements.
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IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Chne.
.t.o, No.
Description Section (5)
ALRA Change
-Basis for Change Delete an extraneous enhancement for microbiological organism tests.
(Basis #5)
Remove the diesel fire pump fuel oil day tank from the enhancement for periodic inspections, and add an exception for such inspections due to size and configuration. (Basis ff4)
I. Additional enhancements for trending Add an enhancement for periodic opening of the diesel fire pump fuel oil water and sediment, as well as requiring S A.1.20 day tank drain. (Basis #4) water removal were necessary to be Add an exception to performing internal inspections of any fuel oil day tank.
consisten with hem GALL.
(Basis #3)
- 2. Updated "Program Elements Affected" to Add an enhancement for quarterly trending of water and sediment. (Basis reflect the appropriate attributes applicable
- 1) to the exception taken to periodically sample the diesel fuel oil day tanks.
Add an enhancement for removal of water, if found. (Basis #1)
- 3. An additional exception was taken for Add an enhancement for quarterly trending of water and sediment. (Basis performing internal inspections of any fuel
- I) oil day tank since, after enhancement, all Revision of the S A2.1.20 Add an enhancement for removal of water, if found. (Basis#l) such tanks will be routinely drained; 22 enhancements for the Add an exception to performing internal inspections of any fuel oil day tank.
the tank that would provide an aging NMPI and NMP2 Fuel (Basis #3) mechanism.
Oil Chemistry Program
(
Delete an extraneous enhancement for microbiological organism tests.
- 4. NMPNS deleted the enhancement to (NMPI only -Basis f5) perform periodic internal inspections on Remove diesel fire pump fuel oil day tank from enhancement for periodic the diesel fire pump fuel oil day tank in inspections, and add an exception for such inspections due to size and favor of taking the appropriate exception configuration.. (NMPI only-Basis 114).
and substituting another enhancement for confgurtio.
(MPI nly-Bais 4).periodically draining the tank to remove Add an enhancement for quarterly trending of water and sediment, contaminants.
(NMPI&2-Basis#l).
S B2.1.18 Under "Detection of Aging Effects", add an exception to perfonming microbiological organism tests for NMPI.
internal inspections of any fuel oil day tank. (NMPI &2 - Basis #3)
This activity was already included in the Add an enhancement for periodic opening of the diesel fire pump fuel oil program prior to submission of the July 14, day tank drain. (NMPI only - Basis #4).
2005 ALRA.
Add an enhancement for removal of water, if found (NMPI&2 - Basis #1).
In "Exceptions to NUREG 1801," under "Program Elements Affected," add "Parameters Monitored and Inspected," to the exception taken to "Monitoring and Trending." (NMPI&2 - Basis #2).
13 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA).
Change l Description Section ()Change Basis for Change No.
or Table ALACag Commitment #21 -
Delete the extraneous enhancement for microbiological organism tests.
(Basis #5)
Remove the diesel fire pump fuel oil day tank from the enhancement for S Al.4 periodic inspection. (Basis #4)
Add an enhancement for quarterly trending of water and sediment. (Basis 22
- 1)
(continued)
Add an enhancement for periodic opening of the diesel fire pump fuel oil day tank drain. (Basis #4)
Add an enhancement forremoval of water, if found. (Basis #1)
Commitment #19-S A2.4 Add an enhancement for quarterly trending of water and sediment. (Basis A.4
- )
Add an enhancement for removal of water, if found. (Basis #Il)
SA~l 122 Expand the existing enhancement to cover all inspections, rather than just "pre-lift."
This revision removes the qualifier on the enhancement that limited it to "pre-lift"
- A2.1.22 Expand the existing enhancement to cover all inspections, rather than just inspections only. To align the program more Expansion of the "pre-lift."
closely to the GALL, NMPNS recognized that NMPI and NMP2 the existing enhancement should be broadened 23 Overhead Heavy Load S B Expand the existing enhancement to cover all inspections, rather than just to include corrosion inspections in all and Light Load
.."pre-lift."
activities credited for aging management of Handling System cranes. It arose from a review of the Program enhancement Commitment #17 - Expand the existing enhancement to cover all Program's implementing document that S AI.4 inspections, rather than just "pre-lifl."
revealed that all procedures, including those
_______________not associated wvith "pre-lift" activities, require enhancement in this regard.
Commitment #16 - Expand the existing enhancement to cover all S A2.4 inspections, rather than just "pre-lift."
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IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change
.Description Stion (S)
ALRA Change.
Basis for Change No.
or Table (T)____________________________________
Add an enhancement to develop acceptance criteria for inspections and S Al.1.27 testing, their support and insulation systems, and the low range ohmic checks of connections.
Add an enhancement to develop acceptance criteria for inspections and Addition of an S A2. 1.27 testing, their support and insulation systems, and the low range ohmic A
n o
checks of connections.
This enhancement was required to meet the enhancement to establish acceptance Add an enhancement to develop acceptance criteria for inspections and accept an ce criteria contained in the most 24 criteria for the NMPI S B2.1.34 testing, their support and insulation systems, and the low range ohmic recent industry and regulatory license renewal and NMP2 Non- -
checks of connections under the Program Element of Acceptance Criteria.
guidance. This guidance states that bolted Segregated Bus connections must be below the maximum Inspection Program Commitment 131 - Add an enhancement for program documents to define allowed temperature or low resistance value.
S Al.4 acceptance criteria for inspection of the bus ducts, their support and insulation systems, and the low range ohmic checks of connections.
Commitment #29 - Add an enhancement for program documents to define S A2.4 acceptance criteria for inspection of the bus ducts, their support and insulation systems, and the low range ohmic checks of connections.
Expand the scope discussion of the program to clarify that it includes internal portions of NSR segments of the circulating water and service water S Al.1.29 systems which are WSLR per the 10 CFR 54.4(a)(2). It also manages all The program also manages the aging of aging effects for components subject to the scope of recommendations for internal portions of the circulating water GL 89-13.
system which are connected to the service water system and NSR portions of interfacing EpninothscpExpand the scope discussion of the program to clarify that it includes systems such as service water, which arc NMPI and NMP2 internal portions of NSR segments of the circulating water and service water WSLR per the 10 CFR 54.4(a)(2) scoping nMPIland Noln S A2.1.29 systems which are WSLR per the 10 CFR 54.4(a)(2). It also manages all criterion. Also included arc both the internal 25 Water Program and aging effects for components subject to the scope of recommendations for and external surfaces of components subject to WtrPormadGL 89-13.
the scope of recommendations for GL 89-13 expansion of an per GALL, Revision 0,Section XI.M20. The enhancement Expand the scope discussion of the program to clarify that it includes components were added to the OCCW internal portions of NSR segments of the circulating water and service water Program for GALL consistency.
systems which are WSLR per the 10 CFR 54.4(a)(2). It also manages all aging effects for components subject to the scope of recommendations for The enhancements listed in the ALRA are also S B2.1.10 GL 89-13.
applicable to the additional program elements GL89-13.listed.
In the enhancements under "Program Elements Affected,, add "Program Description," "Preventative Actions," and "Monitoring and Trending, 'to the enhancements listed for "Scope of Program."
15 of 16
IDENTIFIED CHANGES TO THE AMENDED LICENSE RENEWAL APPLICATION (ALRA)
Change ALRA Change Basis for Change ChNo.
Dsrpin Section (S)
No.__
or Table (T)'
S AI.1.38 Add an exception to GALL Report Program XI.M18 for its reference to the The program described in NUREG 1801, 95-96 Addenda of the ASME Code.Th rgadsib nNUE 18, Add an exceptionotottheA_____Code.
Section XI.M 18, under "Detection of Aging Add n ecepion o te
-Effects,"
cites ASME Section XI requirements 26 NMPI and NMP t
S A2.NP37 Add an exception to GALL Report Program XI.M18 for its reference to the covered in the 1995 Edition through the 1996 Bolting Integrity 95.96 Addenda of the ASME Code.
Addenda. The Code of Record for NMP I and Program NMP2 is the 1989 Code with no Addenda, so 3
Add an exception to GALL Report Program XI.M18 for its reference to the this is an exception to GALL.
95-96 Addenda of the ASME Code.
The program described in NUREG 1801, Expand an existing Section XI.S8, under "Detection of Aging Exceptond to thex g Add an exception affecting "Parameters Monitored and Inspected,"
Eects" a nd "Mn torin n Trending 27 Proteceti o
ng S 2.1.38 Detection of Aging Effects," "Monitoring and Trending," and "Acceptance ASTM D 5163-96. NtMPNnSd Trend nge ctes Monitoring and ASTM D 5163-96 as specified in NUREG-1 80 1 to this in that the later version that superseded Maintenance Program it, ASTM D 5163-05a, will be used in the NMPNS program.
Delete the second sentence of the "Program Description," and replace it with the following two sentences:
Clarify the Scope of the S Al.1.29 "For NMPI, this includes portions of the Service Water (SW) System, the The changes more clearly and concisely 28 Open Cycle Cooling and Emergency SW System, shell side of the RBCLC heat exchangers, the EDG describe the scope of the OCCW Program for Water Program S B2.1.10 Cooling Water System, Containment Spray Raw Water System, and NMPI.
portions of the Circulating Water System. Also included are other components WSLR wetted by the SW System that are credited in the aging management review."
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ATTACHMENT B to NMP1L 1996 The following table identifies those actions committed to by Nine Mile Point Nuclear Station, LLC, in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
Revisions to existing Amended License Renewal Application (ALRA) commitments are shown with italics and strikethreu&hs.
ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date AI.4 16 The Boraflex Monitoring Program Revised Prior to will be enhanced to (1) Require Nine Mile periodic neutron attenuation testing
- Point, and measurement of boron areal Unit 1 density to confirm the correlation of (NMP1) the conditions of test coupons to Period of those of Boraflex racks that remain Extended in use during the period of extended Operation operation; and (2) Establish (PEO) monitoring and trending instructions for in-situ test results, silica levels, and coupon results.
A.417 Revise applicable procedures related Revised Prior to to the Crane Inspection Program to NMP1 add specific direction for PEO performance of pee lift corrosion inspections, with acceptance criteria,
,for certain hoist lifting assembly components.
1 of9
ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date A1.4 19 Enhance the Fire Protection Program Revised Prior to to (1) Incorporate periodic visual NMP1 inspections of piping and fittings PEO located in a non-water environment such as Halon and Carbon Dioxide fire suppression systems components, to detect evidence of corrosion and any system mechanical damage that could affect its intended function; (2) Expand the scope of periodic functional tests of the diesel-driven fire pump to include inspection of engine exhaust system components to verify that loss of material is managed; (3)
Perform an engineering evaluation to determine the plant specific inspection periodicity of fire doors; and (4) Revise Halon and Carbon Dioxide Functional testfrequencies to semi-annual.
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ALRA New or ALRA Section Commitment # Commitment Text Revised Due Date Al.4 20 Enhance the Fire Water System Revised Prior to Program by revising applicable NMP1 existing procedures to (1)
PEO Incorporate inspections to detect and manage loss of material due to corrosion into existing periodic test procedures; (2) Specify periodic component inspections to verify that loss of material is being managed; (3) Add procedural guidance for performing visual inspections to monitor internal corrosion and detect biofouling; (4) Add requirements to periodically check the water-based fire protection systems for microbiological contamination; (5)
Measure fire protection system piping wall thickness using non-intrusive techniques (e.g.,
volumetric testing) to detect loss of material due to corrosion; (6).
Establish an appropriate means of recording, evaluating, reviewing, and trending the results of visual inspections and volumetric testing; and-(7) Define acceptance criteria for visual inspections and volumetric testing; and (8) Develop new procedures and PM tasks to implement sprinkler head replacements and/or insp ctions to meet National Fire Protection Association (NFPA) 25,; "Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems,"
Section 5.3.1 (2003 Edition) requirements.
3 of9
ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date A 1.4 21 Enhance the Fuel Oil Chemistry Revised Prior to Program to (1) Incorporate periodic NMP1 tests for microbiological organisms PEO Establish a requirement toperform quarterly trending of water and sediment; (2) Provide guidelines for the appropriate use of biocides, corrosion inhibitors, and/or fuel stabilizers to maintain fuel oil quality; (3) Add requirements to periodically inspect the interior surfaces of the emergency diesel fuel oil storage tanks
-e pump fuel oil day tank for evidence of significant degradation, including a specific requirement that the tank bottom thickness be determined (4)
Add a requirement for quarterly trending of particulate contamination analysis results; and (5) Ensure acceptance criteria are specified in the implementing procedures for the applicable indications of potential degradation; (6) Establish a requirementfor periodic opening of the dieselfire pumpfitel oil day tank drain; and (7) Establish a requirement to remove water, if found.
4of9
ALRA New or
.ALRA Section Commitment #
Commitment Text Revised Due Date Al.4 31 Enhance the Non-Segregated Bus Revised Prior to Inspection Program to (1) Expand NMP1 visual inspections of the bus ducts, PEO their supports and insulation systems;. Also, (2) Create new provisions will be made to perform either periodic low range resistance checks of the bus ducts or torque checks of a statistical sample of accessible bolted connections; and (3) Define acceptance criteria for inspection of the bus ducts, their support and insulation systems, and the low range ohmic checks of connections.
Al.4 37 Enhance the program to evaluate Revised Prior to component susceptibility to loss of NMP1 fracture toughness. Assessments PEO and inspections will be performed, as necessary to ensure that intended functions are not impacted by the aging effect. MaiStenanee procedure for inspection of the Or-ifeed Fuel Support casting Mwill be enhanced to include a sample VT 1 inspection of the casting and EVT 1 inspection if any evidence of impact or-mishandling is identified.
A2.4 16 Revise applicable procedures related Revised Prior to to the Crane Inspection Program to Nine Mile add specific direction for
- Point, performance of pee lift corrosion Unit 2 inspections, with acceptance criteria, (NMP2) for certain hoist lifting assembly PEO components.
5of9
ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date A2.4 17 Enhance the Fire Protection Program Revised Prior to to (1) Incorporate periodic visual NMP2 inspections of piping and fittings PEO located in a non-water environment such as Halon and Carbon Dioxide fire suppression systems components, to detect evidence of corrosion and any system mechanical damage that could affect its intended function; (2) Expand the scope of periodic functional tests of the diesel-driven fire pump to include inspection of engine exhaust system components to verify that loss of material is managed; *nd-(3)
Perform an engineering evaluation to determine the plant specific inspection periodicity of fire doors; and (4) Revise Halon and Carbon Dioxide Functional testfrequencies to semi-annual.
6 of 9
ALRA New or ALRA Section I Commitment # Commitment Text I Revised j Due Date A2.4 18 Enhance the Fire Water System Revised Prior to Program by revising applicable NMP2 existing procedures to (1)
PEO Incorporate inspections to detect and manage loss of material due to corrosion into existing periodic test procedures; (2) Specify periodic component inspections to verify that loss of material is being managed; (3) Add procedural guidance for performing visual inspections to monitor internal corrosion and detect biofouling; (4) Add requirements to periodically check the water-based fire protection systems for microbiological contamination; (5)
Measure fire protection system piping wall thickness using non-intrusive techniques (e.g.,
volumetric testing) to detect loss of material due to corrosion; (6)
Establish an appropriate means of recording, evaluating, reviewing, and trending the results of visual inspections and volumetric testing; and-(7) Define acceptance criteria for visual inspections'and volumetric testing; and (8) Develop new procedures and PM tasks to implement sprinkler head replacements and/or inspections to meet National Fire Protection Association (NFPA) 25, "Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems,"
Section 5.3.1 (2003 Edition) requirements.
7of9
. 1
ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date A2.4 19 Enhance the Fuel Oil Chemistry Revised Prior to Program to (1) Provide guidelines NMP2 for the appropriate use of biocides, PEO corrosion inhibitors, and/or fuel stabilizers to maintain fuel oil quality; (2) Add a requirement to sample the diesel fuel oil storage tanks for water and sediment at least quarterly per the ASTM standard; (3) Add requirements to' periodically inspect the interior surfaces of the fuel oil storage tanks for evidence of significant degradation, including a specific requirement that the tank bottom thickness be determined; (4) Add a requirement for quarterly trending of particulate contamination analysis results; and-(5) Ensure acceptance criteria are specified in the implementing procedures for the applicable indications of potential degradation; (6) Establish a requirement to perform quarterly trending of water and sediment; and (7) Establish a requirement to remove water, iffound.
A2.4 29 Enhance the Non-Segregated Bus Revised Prior to Inspection Program to (1) Expand NMP2 visual inspections of the bus ducts, PEO their supports and insulation systems;. Alse, (2) Create new provisions will be made to perform either periodic low range resistance checks of the bus ducts or torque checks of a statistical sample of accessible bolted connections; and (3) Define acceptance criteria for inspection of the bus ducts, their support and insulation systems, and the low range ohmic checks of connections.
8 of 9
16 I'll ALRA New or ALRA Section Commitment #
Commitment Text Revised Due Date A2.4 35 Enhance the program to evaluate Revised Prior to component susceptibility to loss of NMP2 fracture toughness. Assessments PEO and inspections will beperformed, as necessary to ensure that intended functions are not impacted by the aging effect. Mainaenanee procedure for inspection of the Orifieed Fuel Suppeo eastingA4ll be enhanced to include a sample VT 1 inspection of the casting and EVT 1 inspection if any evidence of impact or-mishandling is identified.
A2.4 36 The spent fuel rack design that New Prior to currently utilizes Boraflex for NMP2 reactivity control in the spent fuel PEO pool will be replaced by a design that utilizes Boral for this function.
90f9 9