ML102930350

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Preliminary Discussion with Millstone
ML102930350
Person / Time
Site: Millstone  Dominion icon.png
Issue date: 10/20/2010
From: Sanders C
Plant Licensing Branch 1
To: Chernoff H
Plant Licensing Branch 1
Sandeers, Carleen, NRR/DORL, 415-1603
References
FOIA/PA-2011-0115
Download: ML102930350 (2)
v • d • e


Text

From: Sanders, Carleen Sent: Wednesday, October 20, 2010 1:22 PM To: Chernoff, Harold Cc: 'William D Bartron'

Subject:

Preliminary Discussion with Millstone

Harold, This is a summary of the preliminary discussion we had this morning with Mr. William Bartron of Dominion Nuclear Connecticut, Inc.(DNC), regarding Millstone.
  • DNC submitted relief request RR-04-02 for Millstone Unit No. 2 regarding VT-2 visual examinations of the lower portion of the reactor vessel. The request was made under 10 CFR 50.55a(a)(3)(ii), hardship or unusual difficulty without a compensating increase in level of quality or safety, without enough information to support the request. The NRC staff has determined that there is enough information to review the request under 10 CFR 50.55a(a)(3)(i), alternative provides acceptable level of quality and safety. This relief request is still under review.
  • DNC submitted Updated Final Safety Analysis Report for Millstone Power Station, Unit Nos. 1, 2, and 3 by letter dated June 22, 2009. Below is a list of potential issues identified during the project managers review.

MPS1, MPS2 and MPS3

  • The cover letter transmitting the UFSAR changes contained the wrong UFSAR Revision numbers (5, 25.4, and 20.5, respectively). The licensee stated that the correct Revisions (6.1, 26.3, and 21.4, respectively) to the UFSARs were attached.
  • The cover letters, dating back until 2002, have gaps in the time period covered by the UFSAR updates. This was addressed with the licensee, who stated that no time period had actually been missed.
  • DNCs procedure specifies that the UFSAR update cycle for MPS1, MPS2, and MPS3 is December 31 through December 31; however, the cover letter states that the UFSAR update cycle is from April 1, 2008, through December 31, 2008. The licensee stated that the cover letter is incorrect, and that the UFSAR update cycle covers December 31, 2007, through December 31, 2008.

MPS2

  • Table 1.1-1, Licensing History, of the MPS2 UFSAR was not updated to reflect the MPS2 License Renewal. The NRC staff identified this to the licensee and a condition report was generated (CR385359).
  • Section 7.5.6.1.4, Availability and Reliability, states that area radiation monitoring equipment is designed for continuous operation during the 40-year life of the plant.

The MPS2 license renewal extended the life of the plant to 60 years. A brief review of Chapter 15, License Renewal, leads me to believe the time frame should have been updated.

  • Updates associated with License Amendment No. 298, Issuance of Amendment Regarding Alternate Source Term (ADAMS Accession No. ML071450053), were included. Amendment No. 298 was issued prior to this UFSAR change cycle (May 31, 2007). Some updates associated with Amendment No. 298 appear to have been captured in previous MPS2 UFSAR update cycles. Part of the UFSAR change in this cycle removed information. Removal of information should be specifically identified to the NRC staff, including a brief description and basis for the removal in accordance with NEI 98-03, Guidelines for Updating Final Safety Analysis Reports. Millstone Power Station adheres to the guidance of NEI 98-03 per procedure CM-AA-SAR-101, Updating Safety Analysis Report (SAR). The removed information was not specifically identified to the NRC staff nor was a brief description and basis for the removal provided.
  • License Amendment No. 304, American Society of Mechanical Engineers Code Update (ADAMS Accession No. ML082270679), should have resulted in updates to the UFSAR. Specifically Section 1.A, AEC General Design Criteria for Nuclear Power Plants, should have been updated to reference the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants instead of Section XI of the ASME Boiler and Pressure Vessel Code. It appears that this update should have been made throughout the MPS2 UFSAR.
  • License Amendment No. 305, Control Room Habitability (ADAMS Accession No. ML082270679), should have resulted in the UFSAR being updated to capture the control room envelope habitability program. Specifically, the testing requirements should have been added to Section 14.8.4.3, Control Room Habitability. MPS3 USFAR was updated to reflect License Amendment No. 243,Control Room Habitability (ADAMS Accession No. ML082270679).

removed credit for containment atmosphere gaseous radioactive monitors; however, the MPS2 UFSAR still states they will be available (7.5.1.2.1.2), calibrated (7.5.6.3.3), and provide input to ESFAS [engineered safety features actuation system] (7.5.6.3.2.1.2). DNC should verify the UFSAR is accurate or update the information.

MPS3

  • License Amendment No. 241, American Society of Mechanical Engineers Code Update (ADAMS Accession No. ML081960312), should have resulted in updates to the UFSAR. Specifically, Section 1.2.10, Engineered Safety Features, and Section 3.1.2.32, Inspection of Reactor Coolant Pressure Boundary (Criterion 32), should have been updated to reference the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants instead of Section XI of the ASME Boiler and Pressure Vessel Code. It appears that this update should have been made throughout the MPS3 UFSAR.

removed credit for containment atmosphere gaseous radioactive monitors; however, the MPS3 UFSAR still states they are used for detection of unidentified leakage (5.2.5.2.3) and describes them, including their sensitivity, response times, indicators and alarms, and seismic capability. The containment atmosphere gaseous radioactive monitors are also described as being part of the reactor monitoring system (11.5.2 and 12.3.4.5). DNC should verify the UFSAR is accurate or update the information.

revises the reactor coolant system-specific activity to utilize a new indicator, Dose Equivalent Xenon-133, and only take into account the noble gas activity in the primary coolant. This new reactor coolant system-specific activity is added to the limiting condition for operation regarding the specific activity of the reactor coolant; however, the degree of compliance for Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, contained in Table 1.8-1, NRC Regulatory Guides, still uses the old technical specification wording. The new wording regarding Dose Equivalent Xenon-133 should be added to the table.

Thank you, Carleen Sanders Millstone Project Manager 301-415-1603 E-mail Properties Mail Envelope Properties ()

Subject:

Preliminary Discussion with Millstone Sent Date: 10/20/2010 1:09:59 PM Received Date: 10/20/2010 1:22:00 PM From: Sanders, Carleen Created By: Carleen.Sanders@nrc.gov Recipients:

Harold.Chernoff@nrc.gov (Chernoff, Harold)

Tracking Status: None william.d.bartron@dom.com ('William D Bartron')

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 29482 10/20/2010 Options Expiration Date:

Priority: olImportanceNormal ReplyRequested: False Return Notification: False Sensitivity: olNormal Recipients received:

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