B15432, Application for Amend to License DPR-65,incorporating TS Table 3.3-12 to Provide Clarifications to Applicability & Action Statements of Radioactive Liquid Effluent Monitoring Instrumentation

Application for Amend to License DPR-65,incorporating TS Table 3.3-12 to Provide Clarifications to Applicability & Action Statements of Radioactive Liquid Effluent Monitoring Instrumentation

ML20094P339
Person / Time
Site:	Millstone
Issue date:	11/20/1995
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20094P342	List: B15432, Application for Amend to License DPR-65,incorporating TS Table 3.3-12 to Provide Clarifications to Applicability & Action Statements of Radioactive Liquid Effluent Monitoring Instrumentation ML20094P344
References
B15432, NUDOCS 9511290057
Download: ML20094P339 (9)

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"h Northeast ' 7 8*'d*" 8"' 8"h"' C* 37  !

gp Utilities System Snhe :mu scia compay P.O. Box 270

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. llanford, CT 06141-0270 l (203) 665-5000 November-20, 1995  ;

1 Docket No. 50-336 l B15432 ,

Re: 10CFR50.90 ,

U.S. Nuclear Regulatory Commission .

Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Proposed Technical Specifications Revision Radioactive Licuid' Effluent Monitorina Instrumentation Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License, DPR-65, by incorporating the attached changes into the Technical Specifications of Millstone Unit No. 2. The proposed changes affect Technical Specifications Table 3.3-12.

The proposed changes to Table 3.3-12 provide clarifications to the applicability and action statements of the radioactive liquid effluent monitoring instrumentation. These changes will resolve a deficiency (95-201-05) noted'in the NRC Restart Assessment Team Inspection Report of Millstone Unit No. 2 dated July 21, 1995.m Attachment 1 to this letter provides a safety assessment of the proposed changes. Attachment 2 is the determination of no significant hazards considerations. Attachment 3 is a copy of the marked-up version of the appropriate pages of the current Technical Specifications. Attachment 4 is the retyped Technical Specification pages.

NNECO has reviewed the proposed Technical Specification changes in  :

accordance with 10CFR50.92 and concludes that the changes do not involve a significant hazards consideration. NNECO has also reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations and concludes that the changes do not increase the types and amounts of effluent that may I be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Thus, NNECO concludes (1) U.S. Nuclear Regulatory Commission letter to J. F. Opeka, "NRC Inspection Report 50-336/95-201, Millstone Nuclear Power Station Unit 2, Restart Assessment Team Inspection," dated July 21, 1995. l 28002a ,

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November 20, 1995 ,

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l that the proposal satisfies '10CFR51.22 (c) (9) for a categorical l j exclusion from the requirements for_ an environmental impact  ;

statement.  ;

[ The Nuclear Safety Assessment Board has reviewed the proposed '

- changes to the Technical Specifications and concurs with the above determinations. In accordance- with 10CFR50. 91 (b) , NNECO is i i providing the State of Connecticut with a copy of this proposed - r j license amendment.  ;

i Since this proposed license amendment is not required to support  !

j continued safe operation, NNECO is requesting NRC review and '

approval at your earliest convenience with the amendment to be l implemented within 60 days of. issuance.

l There are no commitments contained within this letter. If the NRC

) Staff should have any questions or comments regarding this 3

submittal, please contact Mr. Mario Robles at (860) 440-2073.

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! Very truly yours,  !

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. NORTHEAST NUCLEAR ENERGY COMPANY i  ;

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J. F. M ca #

Executive Vice President cc: T. T. Martin, Region I Administrator j G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit

Nos. 1, 2, and 3 I

l Mr. Kevin T.A. McCarthy, Director f

Bureau of Air Management I

Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street i ' Hartford, CT 06106-5127 i

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.U.S. Nuclear Regulatory Commission B15432/Page.3 November 20, 1995-Subscribed and sworn.to before me-this 6 ~ day of v

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W Docket No. 50-336 B15432 Attachment 1 Millstone Nuclear Power Station, Unit-No. 2 Proposed Technical Specifications Revision Radioactive Liquid Effluent Monitoring Instrumentation d

i November 1995 i

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,,U.S.* Nuclear Regulatory Commission ,

2 B15432/ Attachment 1/Page 1 i November 20,'1995 {

1 Millstone Nuclear Power station, Unit No. 2

! Proposed Technical specifications Revision i Radioactive Liquid Effluent Monitoring Instrumentation l l safety Assessment of Proposed Changes f Damerintion of Proposed t'hanera  !

I The first of the proposed changes provides clarification'to the ,

l applicability statement for the steam generator blowdown monitor in  ;

jl Table 3.3-12. The applicability is changed to be for Modes 1-4 1 only.

h j The applicability is being clarified because in Modes 1-4, steam i generator blowdown is continuously in service, and therefore the L radiation monitor is required to be operable. However, in Modes 5 '

and 6, steam generator blowdown is not in service, and therefore the radiation monitor is not required to be in service. Steam l generator discharges in Modes 5 and 6 are batch discharges. I Station procedures require sampling prior to discharge.

The second change involves the action statement for the steam generator blowdown monitor in Table 3.3-12, Action 2. The action j required when the monitor is not operable is clarified to state l 1 that if discharges are suspended, no sampling is required.  !

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l The last change involves the applicability statement for the 1 condensate polishing facility waste neutralizing sump radiation l monitor. It is clarified to state that the monitor is only i required when the pathway is in use.  !

i safety Assessment

! The proposed changes are administrative in nature and are intended 3

to clarify the applicability and actions of Technical Specification 3.3.3.9, Limiting Condition for Operation (LCO) for Radioactive i Liquid Effluent Monitoring Instrumentation.

The above changes do not change the intent of the requirements, but rather make the Technical Specifications consistent with existing conditions. Therefore, the changes are considered safe.

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. . i Docket No'. 50-336 B15432 a

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s i Attachment 2 Millstone Nuclear Power. Station, Unit No. 2 Proposed Technical Specifications Revision l i Radioactive Liquid Effluent Monitoring Instrumentation Determination of No Significant Hazards Considerations  ;

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[ November 1995

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,U.S.' Nuclear Regulatory Commission B15432/ Attachment 2/Page 1 November 20, 1995 Millstone Nuclear Power Station, Unit No. 2 Proposed Technical Specifications Revision Radioactive Liquid Effluent Monitoring Instrumentation Determination of No Significant Hazards Considerations Pursuant to 10CFR50.92, NNECO has reviewed the proposed changes.

NNECO concludes that these changes do not involve a significant hazards consideration since the proposed changes satisfy the criteria in 10CFR50.92(c). That is, the proposed changes do not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes clarify the modes and conditions for which the ,

radiation monitors are utilized, as well as the required actions when the monitors are not operable. These changes are ,

administrative in nature, therefore, the changes will not increase l the probability or consequences of an accident previously evaluated. l l

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

The proposed changes have no affect on the ability of the monitors to perform their design function. The clarifications do not involve any physical modifications to any equipment, structures, or components. The proposed changes have no impact on design basis accidents, and the changes will not modify plant response or create a new or unanalyzed event.

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

These changes do not have any impact on the protective boundaries and, therefore, have no impact on the safety limits for these boundaries. The instrumentation associated with these changes do not provide a cafety function and only serve to provide l radiological information to plant operators. The instrumentation l has no affect on the operation of any safety-related equipment. No hardware, software, or setpoint changes are involved in this proposed change. These changes provide clarification of modes and conditions for which the radiation monitors are utilized. As such, these changes have no impact on 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 considered not likely to involve a significant hazards consideration. The proposed changes described herein resemble

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,U.S. Nuclear Regulatory Commission B15432/ Attachment 2/Page 2 November 20, 1995 example (i), a purely administrative change to technical specifications, which for example include a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature. The administrative changes have no effect on the protective boundaries or the margin of safety, i

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, ' Docket No. 50-336 B15432 I

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! Attachment 3 i

" ' Millstone Nuclear Power Station, Unit No. 2

{ Proposed Technical Specifications Revision j Radioactive Liquid Effluent Monitoring Instrumentation Marked-up Version.of current Technical Specifications i

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i November 1995