ML033490721

RAI, Facsimile Transmission, Draft Request for Additional Information (RAI) to Be Discussed in an Upcoming Conference Call.

ML033490721
Person / Time
Site:	Millstone
Issue date:	12/19/2003
From:	Pulsifer R NRC/NRR/DLPM/LPD1
To:	Darrell Roberts NRC/NRR/DLPM/LPD1
Pulsifer R M, NRR/DLPM, 415-3016
References
TAC MB5019
Download: ML033490721 (6)

Text

December 19, 2003 MEMORANDUM TO: Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Robert M. Pulsifer, Project Manager, Section 2 /RA/

Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 2, FACSIMILE TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (RAI) TO BE DISCUSSED IN AN UPCOMING CONFERENCE CALL (TAC NO. MB5019)

The attached draft RAI was transmitted by facsimile on December 4, 2003, to Mr. David Dodson, Dominion Nuclear Connecticut, Inc. (licensee). This draft RAI was transmitted to facilitate the technical review being conducted by the Office of Nuclear Reactor Regulation and to support a conference call with the licensee to discuss the RAI. The RAI was related to the licensees submittal dated May 7, 2002, as supplemented April 7, 2003, concerning the Boration System technical specification requirements. Review of the RAI would allow the licensee to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.

Docket No. 50-336

Attachment:

As stated

December 19, 2003 MEMORANDUM TO: Darrell J. Roberts, Acting Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation FROM: Robert M. Pulsifer, Project Manager, Section 2 /RA/

Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation

SUBJECT:

MILLSTONE POWER STATION, UNIT NO. 2, FACSIMILE TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION (RAI) TO BE DISCUSSED IN AN UPCOMING CONFERENCE CALL (TAC NO. MB5019)

The attached draft RAI was transmitted by facsimile on December 4, 2003, to Mr. David Dodson, Dominion Nuclear Connecticut, Inc. (licensee). This draft RAI was transmitted to facilitate the technical review being conducted by the Office of Nuclear Reactor Regulation and to support a conference call with the licensee to discuss the RAI. The RAI was related to the licensees submittal dated May 7, 2002, as supplemented April 7, 2003, concerning the Boration System technical specification requirements. Review of the RAI would allow the licensee to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees request.

Docket No. 50-336

Attachment:

Draft RAI DISTRIBUTION PUBLIC D. Roberts R. Pulsifer T. Boyce PDI-2 Reading Accession Number: ML033490721

• Input received 11/04/03.

OFFICE PDI-2/PM SRXB/SC NAME RPulsifer TBoyce*

DATE 12/17/03 11/04/03 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED AMENDMENT TO TECHNICAL SPECIFICATIONS BORATION, EMERGENCY CORE COOLING, CONTAINMENT SPRAY AND COOLING, AND AUXILIARY FEEDWATER SYSTEMS MILLSTONE POWER STATION, UNIT NO. 2 DOCKET NO. 50-336 By letter dated May 7, 2002, Dominion Nuclear Connecticut, Inc. (DNC or the licensee),

submitted a proposed amendment to the Technical Specifications (TSs) for Millstone Power Station, Unit No. 2. The proposed amendment would relocate the Boration System TS requirements to the Technical Requirements Manual, relocate boron dilution analysis restrictions within the TS, and revise the TS Limiting Condition for Operation, action, and surveillance requirements (SRs) associated with the Emergency Core Cooling, Containment Spray and Cooling, and Auxiliary Feedwater Systems.

On December 31, 2002, the Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) with 31 questions pertaining to the May 7, 2002 submittal. On April 7, 2003, DNC provided a response to the RAI. The NRC staff has reviewed the information the licensee provided in the April 7, 2003, submittal and has determined that some of the RAI responses do not provide adequate justification for the proposed changes. In order for the NRC staff to complete its evaluation, a response to the following RAI questions is requested. Note, the RAI questions are numbered starting with 32 in order to differentiate from the RAI questions issued on December 31, 2002.

32) 3/4.1.1.3 Boron Dilution Current TS (CTS) 3/4.1.1.3 CTS 3.1.2.3 Actions a and b Proposed TS (PTS) 3/4.1.3 Actions The response to RAI No. 3 is unacceptable. The basis for relocating the boron dilution TSs 3/4.1.2.1 through 3/4.1.2.8 was that the revised loss-of-coolant accident analysis no longer credited the Chemical and Volume Control System for accident mitigation. While this basis may be an acceptable justification for relocating those specifications that are applicable in MODES 1, 2, 3, and 4 whenever the temperature of one or more of the Reactor Coolant System (RCS) cold legs is greater than 300 EF, it is not an acceptable basis or justification for those MODES when the temperature is less than 300 EF. With no charging pumps operable under these conditions, the CTS either requires a shutdown per CTS 3.0.3 if in MODE 4 with the temperature less than 300 EF, or entry into CTS 3.1.2.3 Action a if in MODES 5 or 6.

Enclosure

Comment: Revise the Actions of PTS 3.1.1.3 to include remedial measures to be taken when no charging pumps are capable of injecting into the RCS when the RCS temperature is less than 300 EF. Provide appropriate discussions and justifications for this change.

33) 3/4.5.2. Emergency Core Cooling Systems (ECCS) Subsystems - Tavg $ 300 EF, 3/4.6.2.1 Containment Spray and Cooling Systems, and 3/4.7.1.2 Auxiliary Feedwater Pumps CTS 4.5.2.a.1.a, a.2.a, a.5 and c.1 CTS 4.7.1.2.c PTS 4.5.2.f, g, h, and k PTS 4.7.1.2.c and 4.7.1.2.d The response to RAI Nos. 11 and 29 state that the change from component automatic actuation by a test or simulated signal to automatic actuation by an actual or simulated signal is an administrative change. The justification for this change is that the proposed wording change would not result in any technical change to the verification of the automatic actuation feature, thus, per Nuclear Energy Institute (NEI) 96-06 this would be an administrative change. This is not quite correct. From a design point of view there is no technical change - the actuated device doesnt know where the signal came from or was generated (actual or simulated). However from a TS requirement point of view it is a technical change. The CTS only allows a test or simulated signal to be used to verify automatic component actuation. By allowing an actual signal to be used, the change becomes less restrictive (one type of signal versus two types of signals).

Comment: Revise the responses to RAI Nos. 11 and 29 to justify this Less restrictive change.

34) 3/4.5.2. ECCS Subsystems - Tavg $ 300 EF, 3/4.6.2.1 Containment Spray and Cooling Systems, and 3/4.7.1.2 Auxiliary Feedwater Pumps CTS 4.5.2.a.1.b, and 2.b CTS 4.6.2.1.1.a.2, CTS 4.7.1.2.a.2.a and 2.b PTS 4.5.2.c and d PTS 4.6.2.1.1.b and 4.7.1.2.b CTS 4.5.2.a.1.b, 4.5.2.a.2.b, 4.6.2.1.1.a.2, 4.7.1.2.a.2.a, and 4.7.1.2.a.2.b verify that the high pressure safety injection pump, the low pressure safety injection pump, the containment spray pump, the motor driven auxiliary feedwater pumps, and the steam driven auxiliary feedwater pump, respectively, develop a differential pressure greater than the specified TS limit on recirculation flow. In converting these CTS to PTS 4.5.2.c, 4.5.2.d, 4.6.2.1.1.b, and 4.7.1.2.b, the specific differential pressure is changed to verifying the developed head is greater than, or equal to, the required developed head.

This change is a less restrictive change, in that the test can be performed at any differential pressure and flow provided that the test point is greater than or equal to pump pressure/flow curve.

Comment: Provide a justification and discussion for this less restrictive change.

35) 3/4.5.2 ECCS Subsystems - T avg $ 300 EF CTS 4.0.1, 4.5.2.e.2 and 4.5.2.f The response to RAI No. 14 which justifies the less restrictive changes associated with CTS 4.5.2.e.2 and 4.5.2.f actually reinforces and provides additional justification to the staffs position that the changes are administrative changes. The response states that the Bases for CTS 4.0.1 does contain the same discussion of PMT [post maintenance tersting] as in the Improved Technical Specification Bases for SR 3.0.1 as quoted in RAI No. 14. Since the TS Bases (CTS/Standard TS (STS)) provides the means by which TSs are interpreted and the intent or purpose of a TS, and based on the justifications provide in RAI No. 14, CTS 4.0.1 maintains the current requirements for post maintenance testing of CTS 4.5.2.e.2 and 4.5.2.f. Thus, the changes are administrative, not less restrictive.

Comment: Revise the justification and discussion accordingly.

36) 3/4.5.2 ECCS Subsystems - T avg $ 300 EF CTS 4.5.2.a.5 PTS 4.5.2.f In converting CTS 4.5.2.a.5 to PTS 4.5.2.f, the justification classifies the change as more restrictive since more valves will be tested in the proposed surveillance than in CTS 4.5.2.a.5. However, no justification was provided other than consistency with the STS and other CTS for excluding those valves that are locked, sealed or otherwise secured in position from the actuation test.

Comment: Provide a discussion and justification for this portion of more restrictive change.

37) 3/4.6.2.1 Containment Spray and Cooling Systems CTS 4.6.2.1.1.a.6 PTS 4.6.2.1.1.c CTS 4.6.2.1.1.a.6 is converted to PTS 4.6.2.1.1.c. The justification and discussion provided in Attachment 1, CTS 3.6.2.1 item 5 for converting CTS 4.6.2.1.1.a.6 to PTS 4.6.2.1.1.a states the following: Relocation of this requirement will not result in a reduction in the number of valves tested. This statement is only partially correct.

CTS 4.6.2.1.1.a.6 verifies the correct position of each accessible manual valve that is not locked, sealed, or otherwise secured in position. No justification is provided for the more restrictive change of going from the CTS requirement of verifying only the non-secured accessible manual valves to all non-secured manual valves.

Comment: Provide a discussion and justification for this more restrictive change.

38) 3/4.7.1.2 Auxiliary Feedwater Pumps CTS 4.7.1.2.b PTS 4.7.1.2.e CTS 4.7.1.2.b requires verifying flow from the condensate storage tank (CST) to each steam generator (SG) whenever the unit has been in COLD SHUTDOWN for at least 30 days. COLD SHUTDOWN is defined in the CTS as MODE 5. The corresponding PTS 4.7.1.2.e requires this to be performed whenever the unit has been in MODES 5 and 6 or defueled for a cumulative period of greater than 30 days. Technically, if the plant has been in MODE 6 and/or defueled for 30 or more days, but has not been in MODE 5/COLD SHUTDOWN for at least 30 days, the CTS SR does not have to be performed. This more restrictive change going from COLD SHUTDOWN/MODE 5 to MODES 5 and 6 and defueled has not been justified.

Comment: Provide a discussion and justification for this more restrictive change.

39) 3/4.7.1.2 Auxiliary Feedwater Pumps CTS 4.7.1.2.b PTS 4.7.1.2.e STS SR 3.7.5.5 and associated bases CTS 4.7.1.2.b requires verifying flow from the CST to each SG whenever the unit has been in COLD SHUTDOWN for at least 30 days. The corresponding PTS 4.7.1.2.e requires the SR be performed prior to entering MODE 2 whenever the unit has been in MODE 5, MODE 6 or defueled for a cumulative period of greater than 30 days. STS SR 3.7.5.5 uses basically the same frequency words as the PTS. The PTS bases (Insert L in the submittal dated May 7, 2002) defines this SR frequency as prior to entering MODE 2 after 30 cumulative days in MODE 5, MODE 6 or a defueled condition. This PTS definition or interpretation of the SR frequency differs from the STS definition and the intent of the CTS definition. The STS definition for this SR frequency is prior to entering MODE 2 operation, after 30 days in any combination of MODES 5 or 6 or defueled. The interpretation of the STS and the CTS is that the 30 days is consecutive. The PTS definition or interpretation would include the STS/CTS interpretation; but since cumulative connotates additive, it would also mean that the SR would have to be performed prior to entering MODE 2 after 30 cumulative days in MODES 5, 6 or defueled over a period of time. For example if a unit was in MODE 1 and shutdown to MODE 5 for five days, went up in power (MODE 4 or above) for two weeks, shutdown to MODE 5 for 10 days, went up in power for one month, followed by a shutdown to MODE 5 for 16 days, then the PTS SR would need to be performed prior to entering MODE 2 following the last shutdown (cumulative time in MODE 5 - 31 days).

This would not be the case for the CTS/STS.

Comment: Provide a discussion and justification for this more restrictive change.