B12236, Application for Amend to License DPR-65,changing Tech Specs to Reduce Reporting Requirements for Primary Coolant Iodine Spikes to Annually,Per Generic Ltr 85-19

Application for Amend to License DPR-65,changing Tech Specs to Reduce Reporting Requirements for Primary Coolant Iodine Spikes to Annually,Per Generic Ltr 85-19

ML20213D329
Person / Time
Site:	Millstone
Issue date:	10/29/1986
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO.
To:	Thadani A Office of Nuclear Reactor Regulation
Shared Package
ML20213D331	List: B12236, Application for Amend to License DPR-65,changing Tech Specs to Reduce Reporting Requirements for Primary Coolant Iodine Spikes to Annually,Per Generic Ltr 85-19 ML20213D639
References
B12236, GL-85-19, TAC-63349, NUDOCS 8611110505
Download: ML20213D329 (3)

Text

_ _ _ .

General Offices e Selden Street, Berlin, Connecticut w coweten 6en me,o.in cown 48'E888 U aaacMveytts gigCmc coww hRTFORD, CONNECTICUT 06141-0270 g o=Y.sOEEc~w.

menas' wets.n a.saa' cow = (203) 665-5000 October 29,1986 Docket No. 50-336 B12236 Office of Nuclear Reactor Regulation Attn: Mr. Ashok C. Thadani, Director PWR Project Directorate #8 Division of PWR Licensing - B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Reporting Requirements on Primary Coolant Iodine Spikes Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License, No. DPR-65, by incorporating the changes identified in Attachment 1 into the Technical Specifications of Millstone Unit No. 2.

The propuzd change will reduce the reporting requirements for primary coolant iodine spikes from a short-term report (special report or a licensee event report (LER)) to an item that will be included in the annual report, and eliminate the portion of the Technical Specification Action Statement that requires the plant to shut down if the coolant iodine activity limits are exceeded for ten (10) percent of the unit's total yearly operating time. The changes proposeA herein are in response to and in accordance with NRC Generic Letter 85-19,(U which recommends the deletion of unnecessary reporting and technical specification requirements.

The proposed change to the technical specifications involves the limit on the total cumulative length of time the plant could operate in excess of the reactor coolant system activity specification. This requirement was intended to prevent operation for an extended period of time with poor fuel performance. Fuel performance at Millstone Unit No. 2 has improved significantly since the initial cycles of plant operation; therefore, this requirement is no longer necessary.

(1) Generic Letter No. 85-19, " Reporting Requirements on Primary Coolant Iodine Spikes," dated September 27,1985. }

i I

8611110505 861029

DR ADOCK 0500033g PDR he,ha)fGlec,5Qf/!D00

m.

~

The current technical specifications require th'a t the plant be shut down.for -

excessive reactor coolant lodine levels totaling ten (10) percent of the' unit's yearly operating time. An a!!owance of forty-eight (48) hours in a single event is made for iodine spiking after power changes. Recent changes to regulations (i.e.

- 10CFR50.72(b)(1)(ll)) ~ require NRC notification of ' any unusual increases ' in reactor coolant activity. This will bring attention to a fuel performance problem long before' exceeding the present technical specification limit. The proposed changes to the technical specifications will still provide the forty-eight (48) hour limit for spiking, yet delete the unnecessary cumulative time limit.

The proposed changes will effect techaical specifications page B 3/4 4-4 by deleting reference to operation within specific activity levels. Page 3/4 4-13

~

will be. revised to allow operation to continue for up to forty-eight (48) hours, deleting the requirement that operation'shall not exceed ten (10) percent _of the unit's total yearly operating time. Pages 3/4 4-13 and 4-14 will no longer require the preparation and submittal of a special report to the Commission pursuant to -

Specification 6.9.2. The table in Specification 6.9.2 will be changed to eliminate the entry for " Specific Activity Levels." Lastly, Technical Specification 6.9.1.4,

- Annual Reports, will include a reporting requirement detailing the results of specific activity analysis in which the primary coolant exceeded the limits.of Specification 3.4.8.

NNECO has reviewed the attached proposed changes pursuant to 10CFR50.59 and has determined that they do not constitute an unreviewe'd safety question.

The probability- of occurrence 'or the consequences of a previously analyzed accident have not been increased and the possibility for a new type of accident has not been created. NNECO concurs with the NRC that based on current fuel technology, the probability of operating at greater than 1 micro Ci/gm Dose Equivalent I-131 for more than eight. hundred (800) hours / year is so negligible that a technical specification limit is no longer necessary. NNECO concludes and concurs with the NRC that the probability of a steam generator tube rupture with a pre-existing iodine spike is . not increased by this amendment request; therefore, there is no effect on the consequences of an accident.

NNECO has reviewed the proposed changes, in accordance with 10CFR50.92, and has concluded that they do not involve a significant hazards consideration in that these changes would not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated, in that they do not effect the allowed plant operating conditions. Therefore, this change does not invalidate the assumptions made in the design basis analysis for the calculation of of!-site dose.

2. Create the possibility of a new or different kind of accident from any previously analyzed. The change is procedural, affecting only the reporting requirements and not the allowed plant operation as related to primary coolant lodine spikes. The elimination of unnecessary technical specifications reflects current fuel performance technology, and existing reporting requirements (10CFR50.72(b)(1)(ii)) ensure that appropriate actions are taken.

3. Involve a significant reduction in a margin of safety. Based on current fuel technology, the probability of operating with excessive reactor coolant lodine levels is negligible. In addition,10CFR50.72 requires

~

NRC notification of any unusual increases in activity which would bring

' attention to a fuel performance problem long before exceeding the present limit.-

The Commission has provided guidance concerning the application of standards in 10CFR50.92 byL providing certain examples (51FR7750, March 6,1986). The changes proposed herein are not enveloped by a specific example, but this does ;

not. alter the conclusion that the proposed. amendment does. not. involve _a significant hazards consideration. The change to reporting requirements reflects .

the determination that the technical specification limit is no longer necessary on the : basis that proper fuelidesign and management: and existing reporting

- requirements (10CFR50.72(b)(1)(ii)) provide the appropriate controls.

-The Millstone Unit No. 2 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.

-It is also noted that this proposal is in complete conformance with Generic Letter 85-19, which invites licensees to seek the amendment proposed herein.

In accordance with 10CFR50.91(b), we are providing the State of Connecticut -

with a copy of this proposed amendment.

Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment is the application fee of $150.

.. NNECO does not propose a specific date by which this amendment needs to be 7 issued; we are available to answer any questions that may arise.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY L F. 01.JL

3. F. Opekh U Senior Vice President cc: Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT ) ~

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me 3. F. Opeka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that. the statements contained in said information are true and correct to the best of his knowledge and belief.

AhAA15 YbM/r flotary Pup By Commission Expires March 31,1988 1