B15241, Application for Amend to License NPF-49,relocating Requirements of Spec 3.6.6 for Main Steam Line Isolation Valves (Msivs) to Spec 3.7.1.5, Msivs

Application for Amend to License NPF-49,relocating Requirements of Spec 3.6.6 for Main Steam Line Isolation Valves (Msivs) to Spec 3.7.1.5, Msivs

ML20085L185
Person / Time
Site:	Millstone
Issue date:	06/20/1995
From:	Opeka J, Scace S NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20085L189	List: B15241, Application for Amend to License NPF-49,relocating Requirements of Spec 3.6.6 for Main Steam Line Isolation Valves (Msivs) to Spec 3.7.1.5, Msivs ML20085L190
References
B15241, NUDOCS 9506280348
Download: ML20085L185 (7)

Text

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1 Northeast ' 107 seiden street, Berlin, cr 06037

- Utilities System . Northen.t Utintie. service company P.O. Box 270

, . Ilartford. cr 06141-0270 (203) 665-5000 i

l June 20,'1995 j Docket No. 50-423 B15241 l i

Re: 10CFR50.90 i U.S. Nuclear Regulatory Commission l Attention: Document Control Desk

• Washington, DC 20555 i Millstone Nuclear Power Station, Unit No. 3 l Proposed Revision to Technical Specifications Main Steam Line Isolation valves i Int;roduction i

Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposed to amend its Operating License, NPF-49: by l incorporating the changes identified in Attachments 1 and 2 into the Millstone Unit No. 3 Technical Specifications. Specifically,  ;

NNECO is proposing to relocate ' the applicable requirements of Specification 3.6.3 for ' the main steam line isolation valves (MSIVs) to Specification 3.7.1.5, " Main Steam Line Isolation Valves." In addition, the Applicability section of Specification 3.7.1.5 has been revised to indicate' that Specification 3.7.1.5 is applicable in Mode 1 and in Modes 2, 3 and 4, except where all  !

MSIVs are closed and deactivated. .(i.e. , in Modes 2, 3, and 4, specification 3.7.1.5 is applicable only if the MSIVs are open) .

Also, the Action Statement for the Limiting Condition for Operation (LCO) 3.7.1.5 has been revised using the guidance of ,

the improved standard technical specifications (STS) for Westinghouse plants (NUREG-1431). j Descrintion of the Proposed Chances NNECO proposes the following changes to Millstone Unit No. 3 ,

Technical Specification Sections 3.6.3 and 3.7.1.5.  ;

Section 3.6.3. Containment Isolation Valves This specification addresses the function of the MSIV to serve as a containment isolation valve for general design criteria (GDC) l penetrations. NNECO is proposing to relocate the applicable l requirements of this specification regarding the MSIVs to specification 3.7.1.5, " Main Steam Line Isolation Valves."

Accordingly, a footnote at the bottom of Page 3/4 6-15 is being j revised to read as follows: >

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U.S. Nuclear Regulatory Commission B15241/Page 2 June 20, 1995 "The provisions of this specification are not applicable for main steam -line isolation valves. . However, provisions of Specification 3.7.1.5 are applicable for main steam line isolation valves." ,

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In addition, an asterisk (*) associated with surveillance i Requirement 4.6.3.1 is being deleted since it is no longer  !

required. Instead, an asterisk (*) has been added to LCO 3.6.3.  ;

t section 3.7.1.5. Main steam Line Isolation valves l The Applicability portion of LCO 3.7.1.5 has been revised to f indicate that the LCO is applicable for MODE 1 and for Modes 2, i 3, or 4, except when the MSIVs are closed and deactivated. The j Modes 2, 3, or 4 note was added for the case when the MSIVs are i closed, since they are already performing their safety function. i The Action statement for MODE 1 has been revised to increase the  !

restoration time for an inoperable MSIV to operable status from  ;

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time is reasonable, j considering the low probability of an accident occurring during i this time frame that would require a closure of the MSIVs. This  !

time duration is also consistent with the new improved STS for Westinghouse plants (NUREG-1431).  ;

In addition, if the MSIV cannot be restored to an Operable status  !

within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, the plant must be placed in a MODE in which the  !

LCO does not apply. To achieve this, the action statement has i been revised to indicate that the plant must be placed in Mode 2  :

within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. It is noted that, in this case, the condition for Mode 2 must be entered. )

i The Action Statement for Modes 2, 3, and 4 has been revised to )

recognize that there could be more than one MSIVs inoperable at a l time. Also, the Action Statement requires closure of the  !

inoperable MSIV(s) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for continued operation. Once again, when closed, the MSIVs are already in the position  !

required by the assumptions in the safety analysis. The Action i' Statement-also requires verification that the MSIVs are closed once per 7 days. Additionally, it is noted that a separate condition entry is allowed for each MSIV.

Surveillance Requirements 4.7.1.5.1 and 4.7.1.5.2 are being revised to include verification of MSIV closure on an actual or simulated actuation signal. This requirement is taken from Specification 3.6.3 and included here.

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U.S. Nuclear Regulatory, Commission B15241/Page 3 .

June 20,.1995  ;

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l In addition, Surveillance Requirement 4.7.1.5.1 has been revised j to clarify that if the closure time of the MSIV is less than 10  !

seconds when verified in accordance with Surveillance Requirement .;

u4.7.1.5.2, the operability testing in Modes 1, 2, or 3 required l per Surveillance Requirement 4.7.1.5.1' does not have to be j performed. ,

Bases Section 3/4.7.1.5, Main Steam Line Isolation Valves, has i been expanded using the guidance of the improved STS l (NUREG 1431). The Table of Contents has been revised to reflect  !

the expansion of the Bases. i Safety Assessment The safety function of the MSIVs is to close on a steam line l isolation signal to isolate steam flow from the secondary side of i the steam generators following a high energy line break. As i currently written, the Applicability section of Specification  !

3.7.1.5 requires that the MSIVs must be operable in Modes 1 l

. through 4. The proposed change to the Applicability section of i specification 3.7.1.5 will require the MSIVs to be operable in  !

Mode 1 and in Modes 2, 3, and 4, except when closed and I deactivated (Modes 2, 3, and 4 only). The closure of the MSIVs  :

in Modes 2, 3, and 4 is acceptable because when they are closed,  !

they are already performing their safety function. The MSIV is I also considered as a containment isolation valve per GDC-57.  ;

Therefore, it is also covered under Specification 3.6.3, and the. l proposed change relocates the applicable requirements of  !

Specification 3.6.3 to specification 3.7.1.5. The deactivation- l' of the MSIVs in Modes 2, 3, or 4 ensures that any spurious actuation will not cause .an opening of the MSIVs. This requirement is consistent with Action Statement 'b' of  :

Specification 3.6.3, " Containment Isolation Valves." Therefore, the proposed change also meets the' requirements of Specification j 3.6.3 (except for the completion time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). The increase 1 in completion time from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is reasonable,  ;

considering the low probability of an accident occurring during j this time period that would require a closure of the MSIVs. It  !

is noted that the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> completion time is greater than that {

normally allowed for containment isolation valves because the >

MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment  !

isolation valves in that the closed system provides a passive i barrier for containment isolation. The footnote added to Page 3/4 6-15 is appropriate to indicate that Specification 3.7.1.5 is applicable for the MSIV instead of Specification 3.6.3. Changes t

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l U.S. Nuclear Regulatory Commission B15241/Page 4 June 20, 1995 i i

to the Actic.n Statement for LCO 3.7.1.5 simply clarifies what actions must be taken to restore the one or more inoperable MSIVs.

The proposed changes do not involve any physical changes to the plant and do not alter the way any structure, system, or component functions. The proposed changes do not have any adverse impact on design basis accidents. If the valves are closed and deactivated in Modes 2, 3, or 4, they are already performing their safety function. The proposed changes to Surveillance Requirements 4.7.1.5.1 and 4.7.1.5.2 are being revised to include the surveillance requirements of Specification 3.6.3. Therefore, the proposed changes have no adverse impact on the safety of the plant.

Sionificant 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 consequences of an accident previously evaluated.

The proposed changes to the Applicability section, Action Statements, and Surveillance Requirements of Specification 3.7.1.5 and the proposed changes to Specification 3.6.3 preserve the assumptions in the existing safety analysis.

The proposed changes to the Applicability Section of Specification 3.7.1.5 will require the MSIVs to be operable in Mode 1 and in Modes 2, 3, and 4, except when closed and deactivated. The closure of the MSIVs in Modes 2, 3, or 4 is acceptable because when they are closed, they are already performing their safety function. Since the MSIV closure time has not been changed, there is no adverse impact on the accidents previously evaluated.

The proposed changes do not involve any physical changes to the plant, and do not alter the way any structure, system, or component functions. Therefore, the proposed changes do not affect the probability of any previously evaluated accident. Additionally, the proposed changes are consistent ,

with the new, improved STS for Westinghouse plants l (NUREG-1431).

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. J U.S. Nuclear. Regulatory Commission B15241/Page 5 June 20, 1995 Based on the above, the proposed changes do not involve a significant increase in the probability or consequences of j an accident previously evaluated. )

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

The proposed changes do not make any physical changes to l existing plant structures, systems, or components. When the  !

MSIVs are closed and deactivated, they are already in the  :

safe position; therefore, the proposed changes do not I introduce a new failure mode. Additionally, the MSIV  !

closure time (i.e., surveillance acceptance criterion) is j not changed. The purpose of the surveillance is to ensure  ;

that the MSIVs can perform their safety function, and this  ;

requirement is preserved. l 1

Thus, the proposed changes do not create the possibility of l a new or different kind of accident from any accident l 1 previ'ously evaluated.  ;

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

The proposed changes do not revise the closure. time of the  !

, MSIVs. This provides assurance that the MSIVs will perform -i their design safety function to mitigate the consequences of l an accident. In addition, when they are closed in Modes 2,  !

! 3, and 4, they are already performing their safety function.  ;

$ Therefore, there is no significant reduction in the margin  !

of safety.

• i The Commission has provided guidance concerning the application )

l of the standards of 10CFR50.92 by providing certain examples j (51 FR 775), March 6, 1986) of amendments that are not considered '

likely to involve an SHC. While proposed changes are not enveloped by any of the examples, NNECO has demonstrated that the i changes do not involve an SHC. l 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) l

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U.S. Nuclear Regulatory Commission-B15241/Page 6 June 20, 1995 l

i for categorical exclusion from the requirements for an i environmental impact statement.

i Nuclear Safety Assessment Board Review l The Nuclear Safety Assessment Board has reviewed and concurred with the above determinations. j i

state Notification l I

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

Connecticut with a copy of this proposed amendment to ensure i their awareness of this request.

t Schedule Required for NRC ADDroval  ;

We request that the Staff review this proposal at your earliest convenience with the amendment effective as of the date of ,

issuance, to be implemented within 60 days of issuance.

If the NRC- Staff should have any questions regarding this submittal, please contact Mr. R. G. Joshi at (203) 440-2080. We l' will promptly provide any additional information the NRC Staff may need to respond to this request, and we appreciate your efforts in support of this request.

Very truly yours, i

NORTHEAST NUCLEAR ENERGY COMPANY  :

FOR: J. F. Opeka ,

Executive Vice President '

i f

BY: nLe# /

15 . E . 1 c'a c e Vice President '

cc: See Page 7 1

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U.S. Nuclear Regulatory Commission B15241/Page 7 June 20, 1995 >

cc: T. T. Martin, Region I Administrator '

V. L. Rooney, NRC Project Manager, Millstone Unit No. 3 P. D. Swatland, 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 l

Subscribed and sworn to before me this jo# day of hi m , 1995

( J 9- AMA A I' '

5HERRY J. SHERMAN Date Commission Expires: NOTARY PUBLIC 6 MY COMMIS$10N EXP6RES AUG. 31,1998 l

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