B15236, Application for Amend to License NPF-49,relocating TS Requirements for Containment Purge Exhaust & Supply Valves from Radiation Monitoring Instrumentation TS Table to ESF Actuation Sys TS Table

Application for Amend to License NPF-49,relocating TS Requirements for Containment Purge Exhaust & Supply Valves from Radiation Monitoring Instrumentation TS Table to ESF Actuation Sys TS Table

ML20086A335
Person / Time
Site:	Millstone
Issue date:	06/27/1995
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086A337	List: B15236, Application for Amend to License NPF-49,relocating TS Requirements for Containment Purge Exhaust & Supply Valves from Radiation Monitoring Instrumentation TS Table to ESF Actuation Sys TS Table ML20086A344
References
B15236, NUDOCS 9507030171
Download: ML20086A335 (7)

Text

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Utilities System - Northeut vtame. ser+e comp.ny j P.O. Box 270 i

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June 27, 1995'  ;

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-Docket No. 50-423  !

B15236 Re: 10CFR50.90 .;

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'UlS. Nuclear Regulatory Commission f Attention: Document Control Desk .i Washington, DC 20555 Millstone Nuclear' Power Station, Unit No. 3 Proposed Revision to Technical Specification Encineered Safetv Features Actuation System Instrumentation

. Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO)- t hereby proposes to amend Operating License NPF-49 by incorporating-the changes _ identified in the Attachments into the Technical.

Specifications of Millstone Unit No. 3. The proposed changes to {

the Technical Specifications will: (1) relocate technical specification requirements for the containment purge exhaust-and supply valves from the radiation monitoring instrumentation technical specification table, to the engineered safety feature  !

(ESP) actuation system technical specification table; and (2)- remove a duplicative testing requirement for the safety l

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injection input from ESFs from the technical specification.

t Descriotion of Proposed Chances ,

The proposed technical specification change will accomplish two. l tasks. The first task will relocate technical specification '

requirements for the containment purge exhaust'and supply valves-from the radiation monitoring instrumentation table to the ESF l actuation system table. This action was - taken based upon an j evaluation done to document the recent failure of radiation monitor

'3RMS*RE41,-and the resultant auto-close-of'the containment purge i i

exhaust and supply valves. Initially this event _-was determined to be not reportable as an ESF actuation based on, in part,'the. fact-  !

that'the auto-close function was not listed on'the ESF actuation table in the - technical- specifications. Subsequent evaluations concluded that the event described was an ESF actuation, and should have been reported as a License Event Report (LER). As documented in Plant Incident Report 3-91-324, based on discussion with the i

.NRC, it is not necessary to report this past occurrence as.either an-immediate report, or a 30 day LER. Future issues of this: type should be reported. To help ensure that this error does not occur ,

again, the containment purge exhaust and supply valves are proposed j to be relocated to the ESF table. ,

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U.S. Nuclear Regulatory Commission B15236/Page 2 June 27, 1995 The second task will delete " Trip Actuating Device Operational Test" requirement from the Millstone Unit No. 3 Technical Specification Table 4.3-1 for item 16. The current Millstone Unit No. 3 Technical Specification requires a trip actuating device operational test (TADOT) be performed on an 18-month frequency for

" Safety Injection Input from ESF," functional unit 16 of Table 4.3-1. There is no single trip actuating device for this signal. The signal originates as three separate inputs: (1) low pressurizer pressure, (2) low steam line pressure, and (3) high  ;

containment pressure. It is noted that TADOTs are not specified for any other automatic reactor trip (see Table 4.3-1). NNECO proposes to delete this requirement because the logic circuitry that processes the safety injection signals and produces a reactor trip is tested under functional unit 19, " Automatic Trip and Interlock logic" of Table 4.3-1, on a monthly staggered test basis

• during the solid-state protection system actuation logic test.

Consistent with the'above change, it is proposed to also delete functional unit 16 of Table 3.3-1.

These changes are administrative in nature. The requirements and .

functionality of the purge system and containment area purge  !

radiation monitor are unchanged by this proposed change.

Safety Assessment Containment Purae and Sunnly Valves These proposed changes will relocate the technical specification requirements for the containment high range radiation monitors (3RMS *RE41 and 3RMS *RE42) from the Millstone Unit No. 3 Technical i Specification Section 3.3.3, " Radiation Monitoring for Plant Operation," to Specification 3.3.2, " Engineered Safety Features ,

Actuation System Instrumentation." This action is taken based upon j an evaluation done in support of a plant information report (PIR) .

This PIR documents the failure of the radiation monitor, and the resultant auto-close of the containment purge exhaust and supply valves. NNECO originally determined that this event was not ,

reportable because this particular function was not listed as an  :

ESF function in Technical Specification Section 3.3.2 (i.e., Table  !

3.3-3, 3.3-4, 3.3-5, and 4.3-2). Based on a reevaluation of our original decision, NNECO determined that the auto-closure of the  !

containment purge and exhaust valve on a receipt of a high -

radiation signal is an ESF function and should have been considered  !

a reportable event per 10CFR50.73 (a) (2) (iv) . To help ensure that this error does not occur again, the containment purge exhaust and i supply valves radiation monitors will be listed in the ESE Tables l of the Millstone Unit No. 3 Technical Specifications. Moving the l requirements to the ESF instrumentation section of the Millstone Unit No. 3 Technical Specifications necessitates the inclusion of i

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.;g .,r U.S. Nuclear Regulatory Commission B15236/Page 3 June 27, 1995 1

l a response time, which was calculated to be 5.29 seconds. It is  !

noted that the ESF response times have been relocated to the Millstone Unit No. 3 Technical Requirements Manual (TRM). This I change was approved by the NRC in Amendment No. 91. m Therefore, the response time for these radiation monitors will be included in the Millstone Unit No. 3 TRM.

The proposed changes do not alter the operability and surveillance requirements of the radiation monitors that close'the containment purge exhaust and supply valves. These proposed changes do not alter the way any structure, system, or component functions and do not modify the manner in which the plant is operated and do not involve any physical changes to the plant. As such, the proposed changes related to the relocation of the technical specification requirements of Radiation Monitors, 3RMS*RE41 and 3RMS*RE42 to other technical specification sections (i.e., to the ESF Tables) ,

will not degrade the ability of the containment high range radiation monitors to perform their intended function.

Reactor Trio System The purpose of the reactor trip system instrumentation surveillance is to establish operability to ensure that: (1) the associated ,

action and/or reactor trip will be initiated when the parameter monitored by each channel or combination thereof reaches its setpoint, (2) specified coincidence logic is maintained, >

(3) sufficient redundancy is maintained, and (4) sufficient system functional capability is available from diverse parameters. The testing required for functional unit 16 of Table 4.3-1 is covered under the actuation logic test of the functional unit 19 of Table 4.3-1 and is performed on more frequent basis (i.e., a monthly staggered test versus an 18-month basis) . In addition, .

Table 4.3-2, " Engineered Safety Features Actuation System Instrumentation Surveillance Requirements," functional unit 1.a,

" Manual Initiation," provides for testing of the ESF on an 18-month basis. Also, Table 4.3-2, functional unit 1.b provides for testing  ;

of the ESF, " Automatic Actuation Logic and Actuation Relays." This testing is performed on a monthly staggered basis. Therefore, the deletion of functional unit 16 of Tables 4.3-1 and 3.3-1 has no impact on the overall testing of ESF or reactor trip system instrumentation logics. ,

Therefore, the proposed changes do not affect public health and safety.

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(1) V. L. Rooney letter to J. F. Opeka, " Issuance of Amendment (TAC No. M82 94a) , " dated June 28, 1994.

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U.S. Nuclear Regulatory Commission ,

B15236/Page 4 June 27, 1995 Sionificant Hazards Consideration NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that the changes do not involve a ,

significant hazards consideration (SHC). The basis for this conclusion is that the three criterja of 10CFR50. 92 (c) are . not compromised. The proposed changes do not involve an SHC because the changes would not:

1. Involve a significant increase in the probability or -

consequences of an accident previously analyzed.

The first proposed change relocates the operability and surveillance requirements for the containment high range radiation monitors from Technical Specification Section 3.3.3 to Technical Specification Section 3.3.2. The proposed changes are administrative in nature. The proposed changes do not alter the way any structure, system, or component functions and do not modify the manner in which the plant is operated and do not involve any physical changes to the plant.

i The second proposed modification will delete the testing requirement for functional unit 16, " Safety Injection Input I

from ESF," of Table 4.3-1 because the logic circuitry that processes the safety injection signals and produces a reactor trip is tested under functional unit 19 " Automatic Trip and ,

Interlock Logic," and the testing is performed on a more frequent basis (i.e., on a monthly staggered bases versus on an 18-month frequency). In addition, the same logic testing is accomplished with an 18-month TADOT of functional unit 1.a of Table 4.3-2 and with a monthly staggered actuation logic testing of functional unit 16 of Table 4.3-2. This testing  ;

ensures that operability of the logic under functional unit 16 of Table 4.3-1 is verified. The other tests will continue to verify the operability of the reactor trip system and that a reactor trip will be initiated when required.

i Therefore, there is no change in the potential for an increase in the 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 do not affect the operation or response of any plant equipment or introduce any new failure mechanisms. The proposed elimination of the testing  ;

requirement line item does not affect the test results since the logic circuitry that processes the safety injection signal i

l

.a 6:*p ,f U.S. Nuclear Regulatory Commission B15236/Page 5 June 27, 1995 and produces a reactor trip will be tested and is tested under functional unit 19 of Table 4.3-1. As such, the changes do not create the possibility of a new or different kind of accident previously evaluated. ,

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

The proposed changes do not have any adverse impact on the protective boundaries nor do they affect the consequences of any accident previously analyzed. The operability and surveillance requirements, although relocated to other technical specifications, will still ensure that the system (the radiation monitors) is tested and within limits. The proposed elimination of the testing requirement will not change the performance or operating conditions of the safety systems. The operable reactor trip system instrumentation ensures that the assumptions in the Bases of the Technical Specifications are not affected and ensures that the margin of safety is not reduced. Therefore, the proposed changes do not reduce the margin of safety.

Moreover, 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 consicered not likely to involve an SHC. The proposed changes are enveloped by example (1) a purely administrative change to technical specifications; for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature. These changes are administrative in nature and will merely relocate existing technical specifications and eliminate redundant testing.

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 concluded 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 Safety Assessment Board The Nuclear Safety Assessment Board has reviewed and has concurred with the above determination.

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,, .i L ' ;p .f U.S. Nuclear Regulatory Commission B15236/Page 6 June 27, 1995 State Notification 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.

Schedule Regarding our proposed schedule for this amendment, we request issuance at your earliest convenience with the amendment effective as of the date of issuance, to be implemented within 60 days of issuance.

Conclusion The proposed changes have been reviewed in accordance with 10CFR50.92 and have been determined to not constitute a significant hazards consideration. In addition, the proposed changes have been reviewed against 10CFR51.21 and it has been determined that the proposed changes meet the criteria for a categorical exemption for an environmental impact statement.

The marked-up pages of the existing Technical Specifications are provided in Attachment 1. The retyped pages are provided in Attachment 2 and reflects the currently issued pages.

If you should have any questions on the above or attached, please contact Mr. R. G. Joshi at (203) 440-2080.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY J. F.(Qp4ka ~(

Executive Vice President cc: See Page 7

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U.S. Nuclear Regulatory Commission B15236/Page 7 June 27, 1995 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 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 sworn to before me this d day of hm#u -

, 1995 stst L Ynu f Da e Commi ion Expires: d /

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