ML080860479
| ML080860479 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/17/2008 |
| From: | John Hughey NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Christian D Virginia Electric & Power Co (VEPCO) |
| Thorpe-Kavanaugh Meghan, LP1-2, 415-5735 | |
| References | |
| TAC MD6640, TAC MD6641 | |
| Download: ML080860479 (5) | |
Text
April 17, 2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION, UNIT NOS 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REACTOR COOLANT SYSTEM LEAKAGE DETECTION SYSTEMS LICENSE AMENDMENT REQUEST (TAC NO. MD6640 AND MD6641)
Dear Mr. Christian:
By letter to the Nuclear Regulatory Commission (NRC) dated August 15, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072330309),
Dominion Nuclear Connecticut, Inc. (DNC) submitted the proposed license amendment request (LAR) to modify Technical Specification (TS) 3.3.3.1, Radiation Monitoring, and TS 3.4.6.1, Reactor Coolant System Leakage Detection Systems, for Millstone Power Station Units 2 and 3 to require only one containment radioactivity monitor (particulate channel) to be operable in Modes 1, 2, 3 and 4. The NRC staff has reviewed the LAR submitted by DNC and has identified a need for additional information required to complete the review as set forth in the Enclosure.
The draft questions were sent to Mr. Bill Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. During a discussion with your staff on February 8, 2008, it was agreed that you would provide a response within 30 days from the date of this letter.
Please note that if you do not respond to this letter within this agreed response time or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, please contact John Hughey at (301) 415-3204.
Sincerely,
/RA/
John D. Hughey, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-423
Enclosure:
RAI cc w/encl: See next page
Millstone Power Station, Unit Nos. 2 and 3 cc:
Lillian M. Cuoco, Esquire Senior Counsel Dominion Resources Services, Inc.
Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Edward L. Wilds, Jr., Ph.D.
Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. J. W. "Bill" Sheehan Co-Chair NEAC 19 Laurel Crest Drive Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Mr. Joseph Roy Director of Operations Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056 Mr. William D. Bartron Licensing Supervisor Dominion Nuclear Connecticut, Inc.
Building 475, 5th Floor Roper Ferry Road Waterford, CT 06385 Mr. J. Alan Price Site Vice President Dominion Nuclear Connecticut, Inc.
Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Mr. Chris L. Funderburk Director, Nuclear Licensing and Operations Support Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. David A. Sommers Dominion Resources Services, Inc.
5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
April 17, 2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711
SUBJECT:
MILLSTONE POWER STATION, UNIT NOS 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REACTOR COOLANT SYSTEM LEAKAGE DETECTION SYSTEMS LICENSE AMENDMENT REQUEST (TAC NO. MD6640 AND MD6641)
Dear Mr. Christian:
By letter to the Nuclear Regulatory Commission (NRC) dated August 15, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072330309),
Dominion Nuclear Connecticut, Inc. (DNC) submitted the proposed license amendment request (LAR) to modify Technical Specification (TS) 3.3.3.1, Radiation Monitoring, and TS 3.4.6.1, Reactor Coolant System Leakage Detection Systems, for Millstone Power Station Units 2 and 3 to require only one containment radioactivity monitor (particulate channel) to be operable in Modes 1, 2, 3 and 4. The NRC staff has reviewed the LAR submitted by DNC and has identified a need for additional information required to complete the review as set forth in the Enclosure.
The draft questions were sent to Mr. Bill Bartron, of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. During a discussion with your staff on February 8, 2008, it was agreed that you would provide a response within 30 days from the date of this letter.
Please note that if you do not respond to this letter within this agreed response time or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, please contact John Hughey at (301) 415-3204.
Sincerely,
/RA/
John D. Hughey, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-336 and 50-423
Enclosure:
RAI cc w/encl: See next page DISTRIBUTION:
PUBLIC LPL1-2 R/F RidsNrrDorlLpl1-2 RidsNrrPMJHughey RidsNrrLAABaxter RidsRgn1MailCenter RidsAcrsAcnwMailCenter RidsOgcRp RidsNrrPMMThorpe-Kavanaugh ADAMS Accession No. ML080860479 *By memo dated 12/7/07 OFFICE LPL1-2/PM LPL1-2/LA DIRS/ITSB DCI/CPNB LPL1-2/BC NAME JHughey ABaxter TKobetz* by CSchulten for DHarrison HChernoff DATE 4/03/08 3/27/08 12/7/2007 04/01/08 4/17/08 Official Record Copy
ENCLOSURE MILLSTONE POWER STATION, UNIT NOS. 2 AND 3 LICENSE AMENDMENT REQUEST REGARDING REACTOR COOLANT SYSTEM LEAKAGE DETECTION SYSTEMS DOCKET NOS. 50-336 AND 50-423 TAC NOS. MD6440 AND MD6441 REQUEST FOR ADDITIONAL INFORMATION In reviewing the Dominion Nuclear Connecticut, Inc. license amendment request (LAR) dated August 15, 2007 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML072330309), regarding reactor coolant system (RCS) leakage detection systems for Millstone Power Station, Unit Nos. 2 and 3 (MPS2 and MPS3), the Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed in order to complete its review:
The above-mentioned LAR proposes a completion time of 7 days with all of the required leakage detection systems inoperable. The LAR cites precedent for removing the containment atmosphere gaseous radioactivity monitor from the specifications based on Braidwood, Byron and South Texas Project yet these plants require entry into limiting conditions for operation (LCO) 3.0.3 when all leakage detection systems are inoperable. In addition, Section 3.3 and 4.1 of the LAR refer to consistency of the amendment request to NUREG 1432, Revision 3.1 Standard Technical Specifications Combustion Engineering Plants Specifications. However, NUREG 1432 also specifies entry into LCO 3.0.3 when all leakage detection systems are inoperable. This is based on no automatic means of leakage detection available to the operator.
- 1) Provide additional technical justification to support continued plant operation when all automatic leakage detection systems are inoperable.
The LAR proposes an action to monitor other alternate leakage detection systems when a condition is entered with all leakage detection instrumentation inoperable. As proposed, there is no clear guidance on what is meant by monitor alternate leakage detection systems with regard to an acceptable frequency.
- 2) Provide additional technical and regulatory justification for the lack of any frequency in which the operator must monitor other alternate leakage detection systems when all leakage detection instrumentation is inoperable.
Additionally, General Design Criterion 4, Environmental and Dynamic Effects Design Bases, of Appendix A to 10 CFR Part 50 states that structures, systems, and components important to safety shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit.
However, dynamic effects associated with postulated pipe ruptures in nuclear power units may be excluded from the design basis when analyses reviewed and approved by the Commission demonstrate that the probability of fluid system piping rupture is extremely low under conditions consistent with the design basis for the piping. This exclusion is termed leak-before-break, and staff guidance for evaluation of the associated analysis is contained in Section 3.6.3, Leak-Before-Break Evaluation Procedures, of the NRC Standard Review Plan (SRP), NUREG-0800.
This SRP Section provides guidance for staff evaluation of leakage detection systems to determine whether they are sufficiently reliable, redundant, and sensitive so that a margin on the detection of unidentified leakage exists for through-wall flaws to support the deterministic fracture mechanics evaluation used for the leak-before-break methodology.
The Final Safety Analysis Reports (FSAR) identify that the NRC staff accepted leak-before-break analyses. Specifically, Appendix 1-A of the MPS2 FSAR states the extent to which MPS2 complies with GDC 4 and identifies leak-before-break analyses accepted for several piping segments at MPS2, including the main reactor coolant system piping and the pressurizer surge line. For MPS3, FSAR Chapters 3 and 19 identify leak-before-break analyses accepted for the main reactor coolant system piping. In accepting these leak-before-break analyses, the NRC staff considered the performance of the available leak detection systems.
- 3) Accordingly, describe any current reference to the gaseous radiation monitors in the leak-before-break analysis assumptions and identify any impact the proposed amendment has on the analysis assumptions for MPS2 and MPS3. Also, identify the available leak detection systems with overall response times (i.e., response times that consider transport and holdup of the measured leakage constituents) adequate to support the leak-before-break analysis assumptions that are provided in addition to the gaseous radiation monitors.
- 4) Explain how the proposed action statements affect the redundancy and minimal functionality of leak detection instrumentation necessary to support the leak-before-break analysis.