A07990, Responds to NRC Re Need to Include Certain Valves of Reactor Bldg Closed Cooling Water Sys in Plant Leak Rate Testing Program.Valves Removed from App J Testing Program, Per 10CFR50.59 & Criteria of Licensing Basis

Responds to NRC Re Need to Include Certain Valves of Reactor Bldg Closed Cooling Water Sys in Plant Leak Rate Testing Program.Valves Removed from App J Testing Program, Per 10CFR50.59 & Criteria of Licensing Basis

ML20245F431
Person / Time
Site:	Millstone
Issue date:	06/20/1989
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
A07990, A7990, NUDOCS 8906280136
Download: ML20245F431 (2)

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June 20, 1989 4

Docket No. 50-336 j A07990 J Re: 10CFR50.109 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Reactor Building Closed Cooling Water System Containment Isolation Valves This letter is in response to the Staff's letter of May 4,1939,II) concerning the need to include certain valves of the Reactor Building Closed Cooling Water (RBCCW) system in the Millstone Unit No. 2 Appendix J leak rate testing program. The Staff's May 4, 1989, letter reiterated the Staff's position that the valves should remain in the Appendix J program. Northeast Nuclear Energy Company (NNECO) has reviewed the Staff's position and, for the reasons stated below, does not believe it appropriate to retain these valves in the program.

L As. you know, NNEC0 made the change to the Millstone Unit No. 2 Appendix J

. . testing program to remove these valves from Type C testing after performing a written safety evaluation under 10CFR50.59. NNEC0's justification for

. change was docketed in submittals dated July 14, 1987, andJanuary7,1988.g As the Staff is well aware, Section 50.59 authorizes a licensee to make certain changes without prior Staff approval if they involve no unreviewed safety ' question. NNECO conformed to the Section 50.59 process in making the subject change to the Millstone Unit No. 2 Appendix J program. While we informed the . Staff of this change, no Staff approval or disapproval was necessary under. the provisions of Section 50.59. NNECO considers its Sec-tion 50.59 evaluation of this change to have been appropriate and accordingly has implemented the change.

(1) J. F. Stolz letter to E. J. Mroczka, dated May 4, 1989, " Millstone Unit 2 ,

Reactor Building Closed Cooling Water (RBCCW) System Containment l Isolation Valves (TAC No. 66385)."

(2) E. J.-Mroczka letter to U.S. Nuclear Regulatory Commission, dated July 14, 1987, "10CFR50 Appendix J"; and E. J. Mroczka letter to U.S.

Nuclear Regulatory Commission, dated January 7,1988, "NRC Staff Request for Additional Information."

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& . June 20,:1989 It also appears'that' the Staff's position is based on current Standard Review Plan -(SRP) criteria' which are not part of the licensing basis for Millstone -

Unit No.'2. The Staff has taken the position that the RBCCW system should not be classi.fied' as a closed-loop system (such that the . valves in question may be

- excluded from the Appendix J program) because it does not meet all the current SRP criteria for that classification; i.e., the piping inside containment is Safety Class 3 rather than . Class 2 as required by the 5RP. See SRP Sec-tion 6.2.4, Item g 0.Millstone .However, as we pointed out in our' letter of September 9, 1988, Unit No. 2 was not designed. or reviewed to 4

this SRP criterion. Moreover, at. the time of licensing, the NRC expressly concluded:in the Safety Evaluation Report for Millstop) Unit RBCCW met applicable requirements for a closed system.

No. 2 that the The application of SRP criterion -in this case, . therefore,- would represent the imposition of a revised Staff position and would therefore have to be addressed under 10CFR50.109. We also believe' that the position advocated by NNEC0 in this letter is consistent with Senior NRC Staff guidance provided during the April 1989? Regulatory Information Conference during which it was made clear that

licensees are encouraged to identify instances where the Staff may be advanc-

. ing backfits without following the backfit rule.

' For these reasons, ' NNECO continues to believe that the RBCCW valves were appropriately removed from the Appendix J program in accordance with 10CFR50.59 and that the change was consistent with the criteria and require-ments reflected in Millstone Unit No. 2's licensing basis.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY M 6t/

E.J.fr'oczka~f Senior Vice President cc: 'W. T. Russell, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos.1, 2, and 3 E. L. Jordan, Director, Office for Analysis and Evaluation of Operations Data (3) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, dated September 9, 1988, "10CFR50, Appendix J Testing."

(4) Millstone Unit No. 2 Safety Evaluation Report, Section 6.3.3, dated May 10, 1974.  !

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