ML20035D611
| ML20035D611 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 04/07/1993 |
| From: | NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML20035D608 | List: |
| References | |
| NUDOCS 9304130324 | |
| Download: ML20035D611 (10) | |
Text
,
ATTACIIMENT A NIAGARA MOIIAWK POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 PROPOSED CHANGE TO THE TECHNICAL SPECIFICATIONS Replace page 3/41-19 with the attached revised page. This page has been retyped in its entirety with marginal markings to indicate changes to the text.
j i
I 4
[
i f
f l
i 003584Lt.
9304130324 930407 PDR ADOCK 05000410 P
l l
l REACTIVITY CONTROL SYSTEMS 3/4.1.5 STANDBY LIQUID CONTROL SYSTEM l
LIMITING CONDITIONS FOR OPERATION l
3.1.5 The standby liquid control system shall be OPERABLE.
APPLICABILITY: OPERATIONAL CONDITIONS 1 and 2 l
ACTION:
i a.
In OPERATIONAL CONDITION 1 or 2:
1.
With one pump and/or one explosive valve inoperable, restore the inoperable pump and/or explosive valve to OPERABLE status within 7 days or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
?
2.
With the standby liquid control system otherwise inoperable, restore the system to OPERABLE status within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or be in at least HOT SHUTDOWN within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
l 1
SURVEILLANCE REQUIREMENTS 4.1.5 The standby liquid control system shall be demonstrated OPERABLE:
E a.
At least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by verifying that:
1.
The temperature of the sodium pentaborate solution in the storage tank is greater than or equal to 70 F.
2.
The available volume of sodium pentaborate solution is within the limits of Figure 3.1.5-1.
d
?
3.
The temperature of the pump suction piping is greater than or equal to 70oF.
t NINE MILE POINT - UNIT 2 3/4 1-19 Amendment No.
A'ITACIIMENT B t
NIAGARA MOIIAWK POWER CORPORATION I
LICENSE NO. NPF-69 DOCKET NO. 50-410 SUPPORTING INFORMATION AND NO SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS l
l INTRODUCTION Niagara Mohawk proposes to delete the requirement for having the Standby Liquid Control (SLC) System OPERABLE during OPERATIONAL CONDITION 5 (Refueling) with any control rod withdrawn. Currently, Technical Specification 3.1.5 requires the SLC System to be OPERABLE during OPERATIONAL CONDITION 5 with any control rod withdrawn.
r The SLC System is required to be OPERABLE in order to terminate an inadvertent criticality during core alterations. This analysis will show that the SLC System was not designed to terminate an inadvertent criticality event during core alterations. Adequate controls are also in place to terminate an inadvertent criticality in OPERATIONAL CONDITION 5, without the SLC System, in the unlikely event that one should occur.
A DESCRIPTION OF PROPOSED CIIANGE I
I j
This change will remove the requirement of Technical Specification 3.1.5 for the SLC System to be OPERABLE in OPERATIONAL CONDITION 5 with any control rod 4
withdrawn.
l 4
j EVALUATION r
The purpose of the SLC System is to provide the capability of bringing the reactor, at any i
time in a fuel cycle, from full power and minimum control rod inventory to a subcritical condition with the reactor in the most reactive xenon free state without taking credit for control rod movement. The amount of boron contained in the SLC System is designed to achieve shutdown assuming the water inventory in the reactor vessel is at normal power operating levels. During refceling operations, the reactor vessel head is removed and the refueling cavity is flooded. With the refueling cavity flooded, the amount of boron in the SLC System may not be sufficient to halt an inadvertent criticality event.
According to General Design Criterion (GDC) 26, two independent reactivity control systems of different design principles shall be provided, However, according to the GDC, only one of the two reactivity control systems must be capable of holding the reactor subcritical under cold conditions. Cold conditions are defm' ed as OPERATIONAL CONDITIONS 4, Cold l
Shutdown or 5, Refueling. As stated in Updated Safety Analysis Report (USAR) Section l
3.1.2.26, " Reactivity Control Syste.m Redundancy and Capability," Nine Mile Point Unit 2's compliance with GDC 26 is accomplished with the Control Rod System and the Reactor j
Recirculation System. The Control Rod System is capable of holding the reactor core 1
003584LL Page 1 of 4
i subcritical under cold conditions regardless of the water level in the reactor. The SLC l
System provides additional backup capability for reactivity control, independent of the normal reactivity control provisions of GDC 26.
10CFR50.62(c)(4) requires that each boiling water reactor have a SLC System to reduce the risks of Anticipated Transient Without Scram (ATWS) events, which can only occur during power operations. The SLC System at Nine Mile Point Unit 2 satisfies this requirement.
USAR Section 7.4.1.2, " Standby Liquid Control" states that the SLC System is not required once the reactor has achieved cold shutdown by means of the control rods. In addition, the SLC System design basis does not consider the additional water volume provided by the flooded refueling cavity. Therefore, the proposed Technical Specification is consistent with i
the licensing basis of Nine Mile Point Unit 2.
In OPERATIONAL CONDITION 5 the reactor is already shutdown with control rods fully inserted in any cell that has fuel in it. In accordance with Technical Specifications and procedural controls, the amount of reactivity present in the core will be constantly reduced
^
during core offloading. This means that the Shutdown Margin (SDM) of the core is the i
same or greater than its initial value during the entire core offload process.
SDM is analytically determined prior to the reactor core being reloaded into the vessel. The calculated SDM is the acceptance criteria used in Technical Specification Surveillance 4.1.1.
l This analytical SDM, in conjunction with Technical Specification requirements and i
procedural controls, assures that an :nadvertent criticality will not occur during core reloading activities.
3
+
If a control rod is withdrawn in OPERATIONAL CONDITION 5 and SDM has not been demonstrated (i.e. Reload), additional restrictions are placed on the plant by Technical Specifications 3.9.2 and 3.10.3. In the extremely unlikely event that an inadvertent criticality occurs during this time, these additional restrictions assure the Control Rod System will be automatically actuated by the Reactor Protection System (RPS). Both the Control l
Rod System and the RPS are highly reliable systems. This conclusion is based upon the following:
1)
Both the Control Rod System and the RPS are designed such that no single active i
failure will prevent them from performing their protective functions.
2)
The RPS is a fail safe system such that upon a loss of power it will perform its safety
' nedon.
l 3)
The RPS, control rods and control rod drive mechanisms are standard designs provided by General Electric with many years of operation which have demonstrated the soundness of their design and their reliability.
j 4)
The preventative maintenance program of these systems maintains them in a state of high operational readiness.
5)
Numerous Technical Specification Surveillances demonstrate the operational readiness of the Control Rod System and the RPS.
6)
Each control rod has a dedicated hydraulic control unit scram accumulator to assure I
timely scrams are achieved.
0035s4LL Page 2 of 4 f
e
- 7). In addition to the hydraulic control unit (HCU) scram solenoid valves at each HCU scram accumulator, the RPS simultaneously actuates backup scram valves in the scram i
air header to block and vent the scram air header so that the scram valves will open l
and cause the control rods to scram even if the failure of the scram solenoid valves were to occur.
Based on the above analysis it k concluded that the SLC System is not required to be l
OPERABLE during OPERATIbNAL CONDITION 5, provided that SDM, either demonstrated or analytically determined, is maintained and all required Technical Specification actions and procederal controls are followed. This change is consistent with the requirements in the Improved Standard Technical Specifications, NUREG-1434, issued -
September 28,1992.
CONCLUSION Niagara Mohawk proposes to delete the requirement to have the SLC System OPERABLE j
during OPERATIONAL CONDITION 5. The basis for these changes are that the SLC System was not designed to terminate an inadvertent criticality event during OPERATIONAL CONDITION 5. SDM, either demonstrated or analytically determined, in conjunction with Technical Specification requirements and procedural controls, will assure that an inadvertent
(
criticality event will not occur during refuel operations. In addition, the RPS and Control Rod Systems will provide protection in the unlikely event that an inadvertent criticality should occur.
Therefore, there is reasonable assurance that the operation of Nine Mile Point Unit 2 in the i
proposed manner will not endanger the public health and safety, and that issuance of the proposed amendment will not be inimical to our common defense and security.
i t
10 CFR 50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10 CFR 50.92 concerning the issue of no significant hazards consideration. Therefore, in accordance with 10 CFR 50.91, the following i
analysis has been performed:
The operation of Nine Mile Point Unit 2, in accordance with the proposed amendment, will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The purpose of the SLC System is to bring the reactor to and maintain it in a cold shutdown condition from normal power operations following failure to scram with the control rods event. Initiation of the SLC System is not a precursor to any accident. Therefore, inoperability of the SLC System cannot increase the probability of an accident previously evaluated. The SLC System was not designed to provide shutdown capability during OPERATIONAL CONDITION 5. Since the SLC System's purpose is to shut the reactor i
down following a failure to scram during power operation, the USAR takes no credit for the l
operability of the SLC System in OPERATIONAL CONDITION 5. Therefore, the SLC System not being operable in OPERATIONAL CONDITION 5 will not involve a significant increase in the consequences of an accident previously evaluated.
j The operation of Nine Mile Point Unit 2, in accordance with the proposed amendment, I
will not create the possibility of a new or different kind of accident from any accident previously evaluated.
i
+
003584LL Page 3 of 4
It This request does not involve a physical change in any syster 's configuration and no new modes of operation are introduced. The SLC System's only purpose is to mitigate the i
consequences of a failure to scram during power operation; it neither causes nor prevents an,
accident from occurring. Furthermore, in OPERATIONAL CONDITION 5 the SLC System has no analyzed function. Therefore, this change will not create the possibility of a new or different kind of accident from any previously evaluated.
The operation of Nine Mile Point Unit 2, in accordance with the proposed amendment, will not involve a significant reduction in a margin of safety.
The purpose of the SLC System is to bring the reactor to and maintain it in a cold shutdown condition from normal power operations following a failure to scram during power operations. Initiation of the SLC System is not designed to terminate an inadvertent criticality during OPERATIONAL CONDITION 5. SDM, either demonstrated or analytically determined, in conjunction with Technical Specifications and procedural controls, will assure that an inadvertent criticality event will not occur during refueling operations. In addition, the RPS and Cor.irol Rod System, which are extremely reliable, will provide protection in the unlikely event that an inadvertent criticality does occur. Therefore, this change will not involve a significant reduction in a margin cf safety.
I 003584LL Page 4 of 4
MAR-15-93 MON 12:15 NM?C NUO!. EAR - SAUNA FAX NO. 3154532836 P.02 EB.C__C.0 R.NF_S PCND E NHJPf ROJ_A_1. FORM
_o 1 PLANT #:
APPLIES TO OTHER UNIT? _ YES _L N0
SUBJECT:
4C h J. Aumgr DUE DATE:
J/hMI PREPARED BY: Micf &#>or'6a wiv) APPLICABLE NCTS NO.: New:
REFERENCE:
T 52 /I Closing:
[HMEffRLNS AND LICENSJEq,flyJIM Si,qt1AtyIt NRC Project Manager
__L/_
Supervisor Licensing Support Manager Technology Services Design Engineer Er.gtneering Supervisor
/
Manager Nuclear Engineering Other (Specify)
SITE REY 13 lignaturt r Plant Manager
/_I i b ' I' -
/
Manager Haintenance
.__ t
/
Hanager Technical Support 7
Manager Operations
,e 50RC Review g
Tech Review v_
5RAB Review Other (Specify)
FINAL REVIEW Signature System Attorney
__.7 Hanager Licensing 7
Proofreader Coments i
DISPOSITION NCTS Forms Attached N/A No new comit.nents made or followup actions required.
FSAR Change Require.
LDCN #
Mod Work Reauest Generated.
KEWORD5 (For Records Kget.) _
_ m m.: mcw mm - -
,e
. es + ~~
MAR-15-93 MON 12:0B NMPC NUCLEAR - SALIN.1 FAX NO. 3154532836 P.15 t!,RC CORREEQ$pfEL APPPOVAL FORM PLANT #:
A APPLIES TO OTHER UNIT 7 YES
_(_ NO
SUBJECT:
I4C hf. *s-eur DUE DATE:
7/nN_7 PREPARED BY: M ik f M / M 64 7o d APPLICABLE
~
NCTS NO.: New:
REFERENCE:
TJ 2 / 5' Closing:
ENGINEERING AND LICENi1RG REY!Ei!
Sienature NRC Pro,1ect Manager V
Supervisor Licensing Support l
Hanager Technology Services Design Engineer Engineering Supervisor 7
Manager Nuclear Engineering Other (Specify)__
SITE REVIEW SiqDature
/
Plant Manager Manager Maintenance Manager Technical Support 7
7 Manager Operations SORC Review
/
Tech Review 7
SRAB Review Other (Specify) __
FINAL REVIEV 5Iceaturt
/
System Attorney k f '-
7 Manager Licensing
/
Proofreader Coments -
DISPOSITION NCTS Forms Attached N/A Ho new comitments made or followup actions required.
FSAR Change Require. LDCN f Mod Work Request Generated.
KEWORDS (For Records Mgmt.)
NIP-IRG-01 PAGE 10 REV 00
114R-15-93 MON 13:02 NMPC NUCLEAR - SALINA FAX NO. 3154532838 P.15 i
3
!LRC CORRESPONDENCE APPROVAL FORM PLANT #:
1 APPLIES TO OTHER UNIT 7 _ YES
_g,_ NO
SUBJECT:
AchJ.44ere DUE DATE:
-.Yhh5 PREFARED BY: hief Of4'>e#64 7nd APPLICABLE NCTS NO.: New: __
REFERENCE:
73 J./ #
Closing:
l ENGTNEERING AND LICENSING REVIEW 11onatur_e
'/
hRC Project Manager V
Supervisor Licensing Support Mariager Technology services Design Engineer Engineering Supervisor Manager Nuclear Engineering c,~,nr %.oj w /o Other (Specify) __-
SITE REYLEM 11anature
/
Plant Manager Manager Maintenance
_ _/_
Manager Technical Support Hanager Operations 7
SORC Review 7
Tech Review V
SRAB Review Other (Specify) ___
~~~
i FINAL REVlO!
Signature 1
Systern Attorney
_((
Hanager Licensing i
Proofreader Coments DliM51LIQN
_ NCTS Forns Attached N/A No new comitments made or followup actions required.
Mod Work Request Generated.
l KEYWORD 5 (For Records Mgmt.) _
. mm, _. -
NIP-IRG-01 PAGE 10 REV 00 I
O
, A tM-15-93 MON 13:01
.NMPC NUCLEAR - SALINA FAX NO, 3154532836-P.14
[
.t i
1 N3Mtif&
M AGARA R40 HAWS ( >cWER CORPORATeck/MI PLAINFtELD ROAD SYFiACU$E.N Y 18212tTELEPHONE (315J 4741511
\\',
f/
~
g///71D 1
t
%Elt%CQEX-,*BhNQRIETAh 1
k, AgAgf TOs ygon: 3,9 g yp,,,
i RBOKE1 _ % V-79 7"D~
i
_ 3 rs - /7z t FAR #
(315) 453-2836 r
NUCLEAR DIVISION OFFICEB SALINA MEADOWS (2ND FLOOR)
I NIAGARA MORANK POWER CORP.
301 PLAINFIELD ROAD SYRACUSE, NErl YORK 13212 TRIS 15 mEtanG TahmsmItyRp yg,og gg g m m ygg m i
N N S N FEODR.
Sm00LD TOU RAYR ANY P90eLErf5 OR QUEJTIONE, PLEASE CONTACT THE PERSON WHOSE NAME AND EETF.NSION ARE LI8IED ABOVE.
t f(kAQ bfVISU 0Y TBANK YOU.
ZZ
,)
8 DATE:
TOTAL PAGES:
/6
[
INCLUDING
- yygg, TRAN5MITTAL I
f i
t NRC CORRESPONDENCE APPROVAL r0RM 1
PLANT #:
APPLIES TO OTHER UNIT 7 _ _ YES Y NO
SUBJECT:
Sc hJ. hers DUE DATE:
V72/f3 PREPARED Gi: h !c( Of/>o#64 7ea) APPLICABLE NCTS NO.: New:
REFERENCE:
75 M. f Closing:
ENGINEERING AND LICENSING REVIEW Sionature NRC Project' Manager b*< *4b won /hid V
Supervisor Licensing Support Manager Technology Services Design Er.gineer Engineering Supervisor Manager Nuclear Engineering Other (Specify)
'>s.s.
.v.
o SITE REVIEW Sicnat urst-
.aav..
/
Plant Manager Manager Maintenance
/
Manager Technical Support Manager Operations 7
SORC Review 7
Tech Review
[
/
SRAB Review Other (Specify) fE AL REVIEW Sionature
/
System Attorney 4
/
Manager Licensing
/
Proofreader Corcents DISPOSITION NCTS Forms Attached N/A No new commitments made or followup actions required.
FSAR Change Require. LDCN i Mod Work Request Generated.
KEYWORDS (For Records Mgat.}
NIP-IRG-01 PAGE 10 RrV 00
,--