B15039, Application for Amend to License NPF-49,revising TS Table 4.3-1 by Adding Note for Functional Unit 2b Re Reactor Trip Sys Instrumentation Surveillance Requirements Change

Application for Amend to License NPF-49,revising TS Table 4.3-1 by Adding Note for Functional Unit 2b Re Reactor Trip Sys Instrumentation Surveillance Requirements Change

ML20077F108
Person / Time
Site:	Millstone
Issue date:	12/02/1994
From:	Debarba E, Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077F113	List: B15039, Application for Amend to License NPF-49,revising TS Table 4.3-1 by Adding Note for Functional Unit 2b Re Reactor Trip Sys Instrumentation Surveillance Requirements Change ML20077F114
References
B15039, NUDOCS 9412130270
Download: ML20077F108 (7)

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.- 9 44 Utilities Systeni sorthe..: crititie. service coine.ny P P.O. iku 270 l{artford, CT 06141-0270 (203) 665-5000 December 2, 1994 Docket No. 50-423 B15039 Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications .

Reactor Trip System Instrumentation Surveillance Requirements Change Introduction Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License NPF-49 by incorporating the proposed changes described in Attachments 1 and 2 into the Technical Specifications of Millstone Unit No. 3. NNECO is proposing to revise the Millstone Unit No. 3 Technical Specification Table 4.3-1 by adding a note for Functional Unit 2b (Power Range, Neutron Flux-Low Setpoint), Functional Unit 3 (Power Range, Neutron Flux - High Positive Rate), and' Functional Unit 4 (Power Range, Neutron Flux - High Negative Rate) which would allow an entry into Mode 2 or )'ade 1 to perform necessary tests for the power range detectors.

Background

On September 16, 1994, with Millstone Unit No. 3 in cold shutdown, it was determined that previous plant startups were conducted with several operability tests not performed prior to entry into Mode 4 or Mode 3. The affected equipment included the main steam isolation valves, the turbine-driven auxiliary feedwater portion of engineered safety features actuation system, and the turbine-driven auxiliary feedwater pump. The plant remained in cold shutdown 9 ,,

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U.S.' Nuclear Regulatory Commission B15039/Page 2 December 2, 1994 while a request was submitted to the NRC on September 17, 1994,ni for enforcement discretion and to change the technical specifications. Timely enforcement discretion was granted on September 17, 1994, as subsequently confirmed on September 20, 1994, c2) to allow the plant to conduct the required tests in Mode 4 and Mode 3, as appropriate, and allow the plant to resume operations. Subsequently, on September 29, 19 94, I'l the NRC approved the technical specification change related to Technical Specification 4.0.4.

As action taken to prevent recurrence, a review of all technical specifications for generic 4.0.4 implications was performed. One related item was identified for Technical Specification Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements.

Currently, the Millstone Unit No. 3 Technical Specification Section 4.3.1.1, Table 4.3-1 entitled " Reactor Trip System Instrumentation Surveillance Requirements" requires the channel calibrations to be performed once per 18 months for Functional Units 2, 3, 4, 5, and 6 (Power Range, Neutron Flux; Intermediate Range; Source Range, Neutron Flux). Functional Unit 2a (Power Range, Neutron Flux - High Setpoint) contains a note of exception (Note 5) to Technical Specification 4.0.4 which allows entry into Mode 2 or Mode 1. This exception is not currently included for Functional Unit 2b (Power Range, Neutron Flux - Low Setpoint),

Functional Unit 3 (Power Range, Neutron Flux - High Positive Rate),

nor Functional Unit 4 (Power Range, Neutron Flux - High Negative Rate), although it is necessary for the plant to enter Mode 2 or Mode 1 to perform the channel calibration for power range neutron detectors.

(1) J. F. Opeka letter to the U.S. Nuclear Regulatory Commission,

" Proposed Revision to Technical Specifications, Auxiliary Feedwater System, Main Steam Line Isolation Valves, and ESFAs Instrumentation," dated September 17, 1994.

(2) C. I. Miller letter to J. F. Opeka, " Notice of Enforcement Discretion," dated September 20, 1994.

I (3) V. L. Rooney letter to J. F. Opeka, " Issuance of Amendment (TAC No. M90379)," dated September 29, 1994.

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. I U.S.' Nuclear Regulatory Commission B15039/Page 3 December 2, 1994 l

l Description of the Proposed Changes 1 The Millstone Unit No. 3 Technical Specification Section 4.3.1.1 requires that each reactor trip system instrumentation channel and interlock and the automatic trip logic be demonstrated operable by  ;

performance of surveillances specified in Table 4.3-1. Table 4.3-1 requires, in part, that the channel calibration for Functional Units 2, 3, 4, 5, and 6 (i.e., Power Range, Neutron Flux; Intermediate Neutron Flux; and Source Range, Neutron Flux) be performed once per 18 months. The channel calibration for the source range, intermediate range, and power range neutron detectors consists of obtaining the detector plateau curves, evaluating those curves, and comparing the curves to the manufacturer's data. The plant must be in at least Mode 2 to perform this surveillance for the intermediate range detectors and in at least Mode 1 to perform the surveillance for the power range detectors. Therefore, a note (Note 5) has been added to Functional Unit 5, Intermediate Range, to specify that the provisions of Specification 4.0.4 are not applicable for entry into Mode 2 or Mode 1. A similar note is provided for Functional Unit 2a, " Power Range, Neutron Flux - High Setpoint." However, an exception to Specification 4.0.4 to l Functional Unit 2b, Power Range, Neutron Flux - Low Setpoint, '

Functional Unit 3, Power Range, Neutron Flux - High Positive Rate,  ;

and Functional Unit 4, Power Range Neutron Flux - High Negative Rate, is not included in Table 4.3-1. NNECO is proposing to modify Table 4.3-1 by adding Note 5 to Functional Units 2b, 3, and 4. l This will allow the plant to enter Mode 2 or Mode 1 to perform the channel calibration for the power range neutron detectors. In addition, Note 5 is being revised to include a reference to the source range detectors. This will make Note 5 consistent with the Functional Unit 6 of Table 4.3-1. It is noted that the NRC Staff has recognized this situation and the correction to this table is reflected in the new improved standard technical specifications (STS) for the Westinghouse plants (NUREG-1431).

Safety Assessment The proposed changes (i.e., addition of Note 5) to Functional Units 2b, 3, and 4 of Table 4.3-1 will allow an exception from the provisions of Technical Specification 4.0.4 for entry into Mode 2 or Mode 1, as appropriate. This will allow appropriate test conditions for the power range detectors. Therefore, the changes I improve the plant overall safety by performing tests at the correct l plant conditions. These changes do not have any impact on the design basis accidents previously evaluated. This situation is recognized in the Westinghouse STS (NUREG-1431) where a similar

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M U.S.' Nuclear Regulatory Commission B15039/Page 4 December 2, 1994 exception from provisions of Technical Specification 4.0.4 appears.

The proposed changes do not modify the surveillance acceptance criterion nor do they change the frequency of the surveillance.

The proposed changes do not have any adverse impact on the design basis accident radiation dose calculations, because the proposed testing condition or method is not an assumption in any of those dose calculations. Therefore, the proposed changes do not pose a condition adverse to safety and there are no adverse safety consequences created by the proposed changes.

The revision to Note 5 to include a reference to the source range dotectors is an administrative change, since this change makes the note consistent with Functional Unit 6 of Table 4.3-1, and has no adverse impact on the plant safety.

Significant Hazards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and concluded that the changes do not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50. 92 (c) are satisfied. The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or consequence of an accident previously analyzed.

NNECO is proposing to modify Table 4.3-1 by adding Note 5 to Functional Units 2b, 3, and 4. This note provide- an exception from the provisions of Technical Specification 4.0.4. Entry into Mode 2 or Mode 1, as appropriate, would allow for appropriate test conditions to complete the channel calibration of power range neutron detectors (i.e., Functional Units 2b, 3, and 4 of Table 4.3-1). This will improve plant safety by performing tests at proper conditions. The acceptance criteria, such as response times, test frequency, or test methods, are not revised. Therefore, the power range neutron detectors will perform their intended function when called upon.

Additionally, the proposed changes are consistent with the new, improved STS for the Westinghouse plants (NUREG-1431).

Based on the above, the proposed changes to Functional Units 2b, 3, and 4 of Table 4.3-1 of the Millstone Unit No. 3 a

U.S.* Nuclear Regulatory Commission B15039/Page 5 December 2, 1994 Technical Spec 2fications do not involve a significant increase in the probability or consequences of an accident previously analyzed.

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

The proposed changes to Functional Units 2b, 3, and 4 of Table.4.3-1 do not make any physical or operational changes to existing plant structures, systems, or components. The proposed changes do not introduce any new failure mode. They simply allow tests to be performed at appropriate conditions (e.g., Mode 2 or Mode 1 rather than Mode 4 or Mode 3).

Additionally, the proposed changes do not modify the acceptance criteria for the tests. The purpose of the tests is to ensure that the power range neutron detectors can perform their intended function.

Thus, the proposed changes do not create the possibility of a i

new or different kind of accident from any previously analyzed.

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

The proposed changes to Functional Units 2b, 3, and 4 of Table 4.3-1 do not have any adverse impact on the design basis accident analyses. The applicable acceptance criteria for the power . range neutron detectors will not be modified by the proposed changes. The proposed changes will permit the tests to be conducted under the proper conditions, so that the ability of the power range neutron detectors to perform their intended safety function can be confirmed.

Based on the above, there is no significant reduction in the ,

margin of safety.

The Commission has provided guidance concerning the application of the standards of 10CFR50.92 by providing certain examples (51 FR 7751, March 6, 1986) of amendments that are not considered likely to involve an SHC. NNECO's proposal to modify the notes of exception to Technical Specification 4.04, as contained in Table 4.3-1, is not enveloped by any of the examples. As indicated above, NNECO has concluded that the proposed changes do not involve an SHC.

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. I U.S.' Nuclear Regulatory Commission B15039/Page 6 December 2, 1994 Environmental Considerations NNECO has reviewed the proposed license amendment against the ,

criteria of 10CFR51.22 for environmental considerations. The  :

proposed changes do not increase'the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, NNECO concludes that the proposed changes meet the criteria delineated in 10CFR51.22 (c) (9) for a categorical exclusion from the requirements for an environmental impact statement.

Nuclear Review Board The Millstone Unit No. 3 Nuclear Review Board has reviewed and concurred with the above determinations.

Notification of the State of Connecticut In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this amendment.

Schedule for NRC Approval and Issuance While this request is not needed at the present time to ensure continued safe operation of the unit, we are requesting that the NRC review and approve this proposal at their earliest convenienct.

The proposed change will be needed prior to startup from the April 1995 refueling outage. The license amendment will be implemented within 30 days of the date of issuance.

Should you have any questions regarding this submittal, please contact Mr. R. G. Joshi at (203) 440-2080.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: J. F. Opeka Executive Vice President BY: 6 d2 kc4k '

E. A. DeBarba Vice President cc: See Page 7

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U.S.' Nuclear Regulatory Commission B15039/Page 7 December 2, 1994 cc: T. T. Martin, Region I Administrator V. L. Rooney, NRC Project Manager, Millstone Unit No. 3 P. D. Swetland, Senior Resident Inspector, Millstone Unit Hos. 1, 2, and 3 Mr. Kevin T. A. McCarthy, Director Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street P.O. Box 5066 Hartford, CT 06102-5066 Subscribed and sworn to before me this ONl day of /)e r em f e r. , 1994 6Mn/ l. 'vsn kn et des ~

Date Commission Expires: /s/w/9 7 i

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