B15199, Application for Amend to License DPR-65.Amend Would Modify TS 3.1.2.4 by Adding Note Indicating That Provisions 3.0.4 & 4.0.4 Not Applicable for Entry Into Mode 4 from Mode 5
| ML20082Q258 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/21/1995 |
| From: | Miller D NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20082Q262 | List: |
| References | |
| B15199, NUDOCS 9504280126 | |
| Download: ML20082Q258 (9) | |
Text
N g" g 107 Selden Street, Berlin, CT 06037 h > ) Utilities gg, System Normeut utstie. service company P.O. Box 270 liartford, CT 06141-0270 (203) 665-5000 April 21, 1995 pocket No. 50-336 B15199 Re: 10CFR50.90 10CFR50.91 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Charaina Pump-Onerating Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR-65 by incorporating the attached change into the Technical Specifications of Millstone Unit No. 2. The proposed revision would modify Technical Specification 3.1.2.4, " Charging Pumps-Operating," by adding a note that indicates that the provisions of Technical Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 4 from MODE 5. The Bases which correspond to this Section are also proposed to be modified.
In addition, NNECO is requesting that the NRC Staff process this license amendment request on an exigent basis pursuant to 10CFR50. 91(a) ( 6) . Currently, NNECO is in an extended shutdown, but is scheduled to enter MODE 4 on May 15, 1995. NNECO will inform the Staff of changes to the schedule that would impact our ability to enter into MODE 4. The proposed license amendment is required on an exigent basis to support planned reactor startup.
NNECO believes that expedited treatment is warranted in this case to avoid an unnecessary delay in reactor startup. NNECO has determined that this request does not involve any significant safety impact. Thus, the operational risk associated with the request has no significant impact on public health and safety.
Background
The NRC Staff's letter of February 15, 1995,* issued Amendment 185 to Facility Operating License DPR-65 for Millstone Unit No. 2.
(1) G. S. Vissing letter to J. F. Opeka, " Issuance of Amendment (TAC No. M89380)," dated February 15, 1995.
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April 21, 1995 This amendment was in response to NNECO's letters of April 24, 1 9 9 4 ,828 and September 21, 1994. NNECO's letters were developed to address four relatsd issues: (1) power-operated relief valve 3 (PORV) and block valve reliability, (2) low-temperature overpressure protection (LTOP), (3) boron dilution, and l (4) shutdown risk management. LTOP and boron dilution changes have ;
the desired goal of limiting the number of pumps available in a' i shutdown condition. One of shutdown risk managements goals is to '
maximize the sources of water available to the operatora in a shutdown condition. NNECO'S proposed license amendment 'was an attempt to balance these seemingly opposing goals. ;
NNECO's letters of April 24, 1994, and September 21, 1994, {
modified Technical Specification 3.1.2.3, " Charging Pump-Shutdown,"
to indicate that with relief capability provided by the PORVs, only one charging pump and one high-pressure safety injection (HPSI) pump would be operable in MODES 5 and 6. This change was made to address LTOP issues. The technical specification was further modified to allow an additional charging pump and an additional :
HPSI pump to oparate provided the reactor coolant system (RCS) was i' vented through a passive vent of greator than or equal to 2.8 in* .
This modification was made to address shutdown risk management and -
LTOP issues.
l When entering MODE 4 from MODE 5, Millstone Unit No. 2 is unable to i maintain a passive vent of greater than or equal to 2.8 in 2, Therefore, Technical Specification 3.1.2.3 limits Millstone Unit No. 2 to only one charging pump and one HPSI pump for MODES 5 and
- 6. Technical Specification 3.1.2.4, " Charging Pumps-Operating" i requires that two charging pumps be operable in MODES 1,.2, 3, and
- 4. The ACTION statement requires that if only one charging pump is operable that an additional charging pump must be restored to an i operable status or the unit must be shut down. Technical i Specification 3.0.4 prohibits entrance into an operational MODE when the limiting condition for operation (LCO) is not met and the l ACTION statement requires a shutdown. Similarly, Technical ;
Specification 4.0.4 prohibits entry into an operational MODE if the :
Surveillance Requirement cannot be met. !
Therefore, NNECO has concluded that the Technical Specifications as ;
i (2) J. F. Opeka letter to the U.S. Nuclear Regulatory Commission,
" Proposed Revision to Technical Specifications, Generic Letter 90-06," dated April 25, 1994.
(3) J. F. Opeka letter to the U.S. Nuclear Regulatory Commission,
" Proposed Revision to Technical Specifications, Generic Letter 90-06," dated September 21, 1994.
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. currently written prohibit entrance into MODE 4 due to plant j limitations on the restoration of two charging pumps prior to entry j into MODE 4. :
nancription of Pronomad cc-maa I
NNECO is proposing to add a footnote to Technical Specification 3.1.2.4 which. indicates that an exception to Technical Specification 3.0.4 and 4. 0. 4 is provided for entry into MODE 4 :
from MODE 5 for no greater than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> or prior to entry into MODE 3, whichever occurs first. l The provision that is proposed to be added to Technical ]
Specification 3.1.2.4 states that Technical Specifications 3.0.4 1 and 4.0.4 are not applicable for entry into MODE 4 to allow for i closing the motor circuit breaker and subsequent testing of an additional charging pump to restore it to an operable status. .
Specification 3.1.2.3, which is applicable to MODES 5 AND 6, i
requires that one charging pump be operable. Specification 3.1.2.4 mandates that at least two charging pumps be operable in MODES 1, t 2, 3, and 4. The exception from specification 3.0.4 and 4.0.4 will ;
allow Millstone Unit No. 2 to enter into MODE 4 and test an additional charging pump and declare it operable. The bases that ,
L' correspond to this section have also been modified !
There is no change necessary to the Technical Specifications associated with the HPSI pumps.
safety analysis The proposed modification will add a note to Technical Specification 3.1.2.4 which will indicate that the provisions of
. Technical Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 4 to restore the second charging pump to operable
- status pursuant to Technical Specification 3.1.2.3.
Technical Specification 3.1.2.3 requires that one charging pump and one HPSI pump be operable in MODES 5 and 6. This limitation is provided to balance LTOP concerns with ECCS concerns. The j specification allows an additional charging pump and HPSI pump to j be operable provided the RCS has a passive vent of greater than or
- equal to 2.8 square inches. ,
1 Technical Specification 3.1.2.4 requires that at least two charging pumps are operable in MODES 1, 2, 3, and 4, except when the RCS is less than 3 0 0* F, then a maximum of two charging pumps can be l
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- e ,. I U.S. Nuclear Regulatory Commission B15199/Page 4 April 21, 1995 operable. ~ The 300*F limitation is the result of the Boron Dilution analysis which assumes a maximum dilution flo'. rate of 88 gpa (2 charging pumps).
Entry into MODE 4 from NODE 5 requires that two charging pumps be
- operable. In MODE 5, only one charging pump may be operable. The proposed technical specification modification will allow the entrance into MODE 4 and the subsequennt testing of the second charging pump. The testing of the pump is required prior to declaring the pump operable.
Technical Specifications 3.0.4 and 4.0.4 prohibit entry into an operational mode when the LCOs are not met and the associated action statement requires a shutdown if they are not met within a specified time interval or if the surveillance has not been 4 performed. Currently, the technical specifications would prohibit entrance into MODE 4 from MODE 5 due to the inability to provide )i two operable charging pumps at the start of MODE 4. This situation was brought about by NNECO's attempt to maximize the amount of pumps that are available for addressing shutdown risk management issues. The incorporation of this modification has created a requirement that will not support plant operation without the proposed relief. ,
i This proposed change will also modify the accompanying bases by i clarifying that in MODES 5 and 6 only one charging pump and only !
one HPSI pump may be operable with relief provided by the power ;'
operated relief valves. In addition, a discussion has been added which describes why Technical Specification 3.1.2.4 has taken an exception to Technical Specifications 3.0.4 and 4.0.4.
The proposed change that NNECO is proposing is safe. The delay in the return to operability of one charging pump will assist in assuring that a LTOP condition or a boron dilution event do not .;
occur. The small delay in returning a second charging pump to ;
operable _ status will not detrimentally impact the risks associated with shutdown management practices.
Justification for Esriaant Liemune n=anAmant Pursuant to 10CFR50. 91(a) ( 6) , NNECO hereby requests NRC Staff exigent approval of the proposed amendment to operating License DPR-65. This request needs to be addressed in an exigent manner to allow Millstone Unit No. 2 to resume power operation.
b The proposed change to the technical specifications was first suggested during the special operator training session which was conducted in late March and early April 1995. Special training was requested to be given to the licensed personnel on this Technical
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April 21, 1995 l l
Specification amendment due to the complexity of the package and I the major changes being implemented. Subsequent in-house !
discussions resulted in the conclusion that the most conservative i interpretation of the Technical specifications as modified necessitates a modification to the Technical Specifications. This conservative position will prohibit entry into MODE 4 from MODE 5 due to the unavailability of two operable charging pumps.
Discovery of this restriction was not uncovered earlier due to the complexity of the change and the divergent issues being addressed by the license amendment.
Further, the requested exigent approval is appropriate because this amendment request does not involve a significant hazards consideration (SHC). Based on the SHC discussion provided later, ;
we have determined that the exception to Technical Specifications 3.0.4 and 4.0.4 for the short duration (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> maximum) to allow the testing of the second charging pump to verify its operability after entry into MODE 4 does not significantly affect the overall ;
, risk. Sufficient flow is provided to the RCS by the remaining operabla pumps to address shutdown risk issues while not impacting l the boron dilution analysis, PORV or block valve reliability, or ;
LTOP issues. {
significant manards considerations In accordance with 10CFR50.92, NNECO has reviewed the proposed change and has concluded that it does not involve an SHC. The basis for this conclusion is that the three criteria of 10 CFR50.92(c) is not compromised. The proposed change does not involve an SHC because the change would not:
- 1. Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed technical specification change will require that a second charging pump be returned to service within four hours of entering MODE 4 or prior to entering MODE 3, which ever occurs first. The addition of the footnote indicating that Technical Specifications 3.0.4 and 4.0.4 are not applicable for entry into MODE 4 from MODE 5 will allow for the testing and subsequent return to service of a charging pump that was required to be inoperable in MODE 5. The testing is necessary to restore the pump to operable status.
The need to restrict charging pump availability in MODE 5 is for LTOP protection. The restriction contained in Technical Specification 3.1.2.4 to have a maximum of two charging pumps ,
operable when the RCS is less than 300*F is provided for the !
boron dilution analysis. Maximizing charging pump flow is j l
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April 21, 1995 i desirable from shutdown risk management schemes. However, all three events, LTOP, boron dilution, and shutdown risk management must be integrated to maximize overall safety.
The short (less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) delay in verifying the operability of the second charging pump after entry into MODE 4 does not significantly affect the overall risk. The technical specification as proposed, balances all three events and will allow the plant to operate. i l
The addition of the proposed footnote to Technical l Specification 3.1.2.4 will not significantly increase the I probability or consequences of an accident previously i evaluated. The charging systems safety related functions are not being impacted by the proposed change.
- 2. Create the possibility of as new or different kind of accident from any previously evaluned.
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The proposed change does not alter or affect the design, I function, failure MODE, or operation of the plant. The proposed change will allow NNECO to perform the required operability tests to support the restoration of a charging >
pump to an operable status. I
- 3. Involve a significant reduction in a margin cf safety.
l The proposed modification will allow for the restoration of a second charging pump to support plant operation in MODES 1, 2, 3, and 4. Testing of the charging pump is necessary to verify operability of the pump. Sufficient flow is provided by the i remaining available pumps to address shutdown risk issues.
This proposed change will not negatively impact the LTOP 'l evaluation or boron dilution analysis, i The Commission has provided guidance concerning the application of the standards of 10CFR50.92 by providing certain examples ,
(51FR7751, March 6, 1986) of amendments that are not considered I likely to involve an SHC. While the proposed change is not I enveloped by a specific example, it has been shown that the exception to Technical Specifications 3.0.4 and 4.0.4 for Technical l Specification 3.1.2.4 is safe and is not an SHC. Increasing the unavailability of one charging pump for up to four hours ta verify its operability will not impact overall plant risk. ;
I Environment consideratiens NNECO has reviewed the proposed license amendment against the criteria of 10CFR51 22 for environmental considerations. The proposed change does not increase the types and amounts of l
U.S. Nuclear Regulatory Commission B15199/Page 7 April 21, 1995 effluents that inay be released offsite, nor does it significantly increase individual or cumulative occupational radiation exposures.
Based on the foregoing, NNECO concludes that the proposed change meets the criteria delineated in 10CFR51.22(c) (9) for a categorical exclusion from the requirements for an environmental impact statement.
uncleme anfaty assamament naard Review The Nuclear Safety Assessment Board has reviewed and concurred with the above determination.
state motification In accordance with 10CFR50.91(b) , we are providing the State of Connecticut with a copy of this proposed amendment to ensure their awareness of this request.
Conclusion In summary, NNECO is requesting an exigent license amendment that would allow the plant to take an exception to Technical Specifications 3.0.4 and 4.0.4 for Technical Specification 3.1.2.4.
This will allow the unit to enter MODE 4 and return to power operation. Therefore, NNECO hereby requests the NRC Staff to process and issue this proposed amendment prior to May 15, 1995, to be effective upon issuance. We acknowledge and apologize for the j short time available to process this request on an exigent basis.
We also wish to emphasize our conclusion that this proposed amendment does not involve any undue safety risk or the need for an environmental impact statement. We are, therefore, requesting this action to allow the plant to enter MODE 4 for a subsequent return to power operation.
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B15199/Page 8 April 21, 1995 7 We will promptly provide any additional information that the NRC Staff may need to respond to this request. The NNECO contact for this proposed revision is Mr. W. E. Hutchins at (203) 440-2073.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY ;
FOR: J. F. Opeka Executive Vice Presiden 1 BY: -
Donald'B. Miller Jr. pfl^ ;
Senior Vice President l
cc: T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 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 swor o before me this oI/ y of -
, 1995 AsJ'& 1 hte Commission Expires: /8/F4f}I i
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.y Docket No. 50-336 B15199 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Charging Pumps-Operating Marked Up Pages April 1995