B13303, Application for Amend to License DPR-21,revising Tech Specs to Address Generic Ltr 83-36 & TMI Item II.B.3, Post-Accident Sampling & Item II.F.1.2, Sampling & Analysis of Plant Effluents

Application for Amend to License DPR-21,revising Tech Specs to Address Generic Ltr 83-36 & TMI Item II.B.3, Post-Accident Sampling & Item II.F.1.2, Sampling & Analysis of Plant Effluents

ML20245E946
Person / Time
Site:	Millstone
Issue date:	08/01/1989
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245E950	List: B13303, Application for Amend to License DPR-21,revising Tech Specs to Address Generic Ltr 83-36 & TMI Item II.B.3, Post-Accident Sampling & Item II.F.1.2, Sampling & Analysis of Plant Effluents ML20245E952
References
RTR-NUREG-0737, TASK-2.B.3, TASK-2.F.1, TASK-TM B13303, GL-83-36, NUDOCS 8908140067
Download: ML20245E946 (5)

Text

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NORTHEAST t#TILITIES cenere Ome.. . seioen street. Berlin, Connecticut U,I[U[.rNrIs$iEcm.=$

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P.O. BOX 270 HARTFORD CONNECTICUT 06141-0270 k ' J NE[EN,"u","2 (203) 665-5000 l August 1, 1989 Docket No. 50-245 B13303 ,

Re: 10CFR50.90 ISAP Topic 1.36 GL 83-36 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Millstone Nuclear Power Station, Unit No.1 Generic Letter 83-36, TMI Technical Specifications Post-accident Sampling - NUREG-0737, Item II.B.3 Samolina and Analysis of Plant Effluents - NUREG-0737. Item II.F.1.2 Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License, No. DPR-21, by incorporating the proposed changes identified in Attachment 1 into the Technical Specifications of Millstone Unit No.1.

By letter dated November 1,1983,(I) the NRC Staff provided to all boiling water reactor licensees clarification of certain TMI Action Plan Requirements (NUREG-0737), by issuance of Generic Letter 83-36. This letter requested licensees to propose changes to their Technical Specifications to address each t

of the action applicable to plan theiritems, identified facilities. Byinletter Enclosure 1 of the 15, dated October letter,1985, g as is addressed in Integrated Safety Assessment Program (ISAP) Topic No. 1.36, NNEC0 prmided a status of each of the items in Enclosure I to Generic Letter 83-36 ar applicable to Millstone Unit No.1. After final revir:w of the Technical Specifications recommended by Generic Letter 83-36, NNEC0 hereby proposes modifications to the Millstone Unit No.1 Technical Specifications as identi-fied in Attachment 1.

l (1) D. G. Eisenhut letter to All Boiling Water Reactor Licensees, "NUREG-0737 Technical Specifications (Generic Letter 83-36)," dated November 1,1983.

l- (2) J. F. Opeka letter to C. I. Grimes, " Millstone Nuclear Power Station, l Unit No.1, Integrated Safety Assessment Program," dated October 15,

! 1985.

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.'B13303/Page 2 August 1, 1989' Provided below is detailed information which supports the proposed modifica-tions.

Post-accident Samplino (TMI Item II.B.3)

Generic Letter. 83-36 states in part that " Licensees should ensure that their plant has the capability to obtain and analyze reactor coolant and containment atmosphere samples under accident conditions. An administrative program should be established, implemented, and maintained to ensure this capability.

The program should include:

a) training of personnel b) procedures for sampling and analysis, and c) -provisions for maintenance of sampling and analysis equipment It is acceptable to the Staff, if the licensee elects to reference this program in the administrative controls section of the Technical Specifications and include a detailed description of the program in the plant operation manuals. A copy of the program should be readily available to the operating staff during accident and transient conditions."

In accordance with these guidelines, NNEC0 proposes to add, as Technical Specification 3.14.8.a Limiting Condition for Operation (LCO) that requires the post-accident ' sampling system to be operable whenever primary containment is required. The exception being that if the system becom.s inoperable, it must be restored to opereble status within 7 days or a Special Report must be prepared and submitted within the next 14 days outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the system to operable status. Additionally, Surveillance Requirement 4.14.B is being added to ensure that the post-accident sampling system is demonstrated operable at least once per six months by obtaining a containment air sample and a reactor coolant sample.

In addition, the Technical Specification Bases are being amended to reflect the above change, and Administrative Controls Technical Specification 6.9.2 is being amended to reflect the new requirements regarding the submittal of Special Reports.

Samolino and Analysis of Plant Effluents (TMI Item II.F.1.2)

Generic Letter 83-36 states in part that "Each operating nuclear power reactor I should have the capability to collect and analyze or measure representative samples of radioactive iodines and particulate in plant gaseous effluents 4 during and following an accident. An administrative program should be estab-lished, implemented, and maintained to ensure this capability. The program should include:

a) training of personnel b) procedure for sampling and analysis, and )

c) provision for maintenance of sampling and analysis equipment j It is acceptable to the staff, if the licensee elects to reference this program in the administrative controls section of the Technical Specifications and include 3 detailed description of the program in the plant operation

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manuals. A copy of the program should be readily available to the operating staff during accident and transient conditions."

Technical Specification 6.14 in the administrative controls section includes the requirements for a program to be implemented which will ensure the capa-bility to accurately determine the airborne iodine concentratka in vital areas and in effluents from the Millstone Unit No. I stack Lader accident conditions. The proposed modification clarifies that the iodine monitoring system has the capability to accurately determine the airborne iodine concen-tration in effluents from the Millstone Unit No. I stack. As such, NNEC0 believes that Technical Specification 6.14, as amended, fully meets the intent of Generic Letter 83-36 regarding sampling and analysis of plant effluents.

Significant Hazards Consideration In accordance with 10CFR50.92, NNEC0 has reviewed the proposed changes described above and has concluded that they do not involve a significant hazards consideration because the changes would not:

1. Involve a significant increase in the probability of an accident previ-ously evaluated.

The added and/or amended LCOs and Surveillance Requirements ensure the availability of the existing post-accident sampling and iodine monitoring systems and will have no impact on the initiation or consequences of an accident previously evaluated. These changes ensure that additional information is available to the operator for proper accident assessment.

Therefore, the aforementioned changes do not increase the probability or consequences of a design basis accident nor do they affect the perfor-mance or failure probability of any safety system. The changes to the Technical Specifications described above have no effst on the initia-tion, probability, or consequences of any previously evaluated accident scenario.

2. Create the possibility of a new or different kind of accident from any previously evaluated.

The changes do not result in physical modification of the plant response or operator response to an accident and no new failure modes are associ-ated with these changes. Instrument drift factors were reviewed to ensure the instrumentation does not provide erroneous or conflicting information to the operator in any given situation. In addition, given the inherent characteristics of passive monitoring equipment, it has been determined that no new or different kind of accident has been creat2d.

3. Involve a significant reduction in the margin of safety.

These changes do not impact the consequences on the protective bounda-ries, no safety limits for the protective boundaries are impacted, and the basis for any Technical Specification is not changed because the instrumentation associated with these changes are passive by nature and do not in any way affect any safety-related equipment. Also, the bases for these proposed Technical Specifications are being revised to include information regarding these systems which serve to provide additional

, *, U.S. Nuclear Regulatory Commission B13:}03/Page 4 August 1, 1989 information to plant personnel during and following an accident. There-fore, there is no reduction in the margin of safety.

The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986) of amendments that are considered not likely to involve a significant hazards consideration. The changes proposed herein most closely resemble Example (ii), a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specification; e.g., a more stringent surveillance requirement. The proposed changes will ensure Millstone Unit No. I's conformance with NUREG-0737 - TMI Action Plan Items II.B.3 and II.F.1.2 (Post-Accident Sampling and Sampling and Analysis of Plant Effluents, respectively), as outlined in Generic Letter 83-36. Specifically, Limiting Conditions for Operation are being added to Technical Specification Section 3.14.B to ensure the availability of the existing post-accident sampling system which will assist in post-accident assessments. Surveillance Requirement 4.14.8 is being added to further ensure that the post-accident sampling system '.s demonstrated operable at least once per six months and that the intent of the above-mentioned TMI Action Plan Items is met. The require-ments for a Special Report to be submitted, as outlined in Technical Specifi-cation 6.9.2.g, will help ensure the NRC Staff is notified of an expeditious repair while still allowing an appropriate degree of operational flexibility.

Bases section 3.14/4.14 is being modified to reflect the above changes.

Administrative Controls Section 6.14 is being modified to clarify that air-borne iodine concentrations can be accurately monitored in effluents from the Millstone Unit No. I stack. This clarification ensures that the intent of TMI Action Plan Item II.F.1.2 is met.

This change is being proposed to incorporate the provisions of Generic Letter 83-36 into the Millstone Unit No.1 Technical Specifications. As such, no specific schedule for approval and issuance is requested. However, we request that these proposed changes become effective 30 days after issuance in order to allow adequate time for procedure revision to be made prior to implementa-tion.

Please note that the remaining Generic Letter 83-36 items for Millstone Unit No. I are being processed in conjunction with this submittal under separate cover. It should therefore be noted that the subparagraphs under the Special Reports Section 6.9.2 are overlapping and should be adjusted accordingly upon issuance.

l The Millstone Unit No. 1 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.

In accordance with 10CFR50.91(b) NNEC0 will provide the State of Connecticut with a copy of this proposed amendment.

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' Augu'st 1, 1989 It may be appropriate to note that the NRC has recently reviewed and approved similar license ame regarding TMI Plan Items for Millstone Unit No. 2 gentand . requests the- Haddam Neck Plant,gtion particularly as they relate.to some of the proposed deviations from the guidance in the Generic Letter.

Very truly-yours, NORTHEAST NUCLEAR ENERGY COMPANY E. Uj. flr6cfka //

Senror Vice Presi" dent Enclosure cc: Mr. Kevin McCarthy Director, Radiation Control Unit

-Department of' Environmental Protection Hartford, CT 06115 W. T. Russell, Region i Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 STATE OF CONNECTICUT)

) ss. Berlin COUNTY OF HARTFORD )

Then personally appeared before me, E. J. Hroczka, 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 Licensee herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.

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l (3) D. H. Jaffe letter to E. J. Mroczka, " Issuance of Amendment (TAC Nos.

54546 and 54399)," dated September 28, 1987.

(4) Alan B. Wang letter to E. J. Mroczka, " Issuance of Amendment (TAC No.

54538)," dated April 24, 1989.

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