ML17031A164

E-mail from J. Semancik to R. Guzman - State Official Comments Planned Issuance of Millstone Unit 2 License Amendment Re Surveillance Requirement 4.1.3.1.2 CEA-39

ML17031A164
Person / Time
Site:	Millstone
Issue date:	01/19/2017
From:	Semancik J State of CT, Dept of Energy and Environmental Protection
To:	Richard Guzman Plant Licensing Branch 1
Guzman R
References
CAC MF8935
Download: ML17031A164 (3)

Text

From: Semancik, Jeffrey <Jeffrey.Semancik@ct.gov>

Sent: Thursday, January 19, 2017 2:58 PM To: Guzman, Richard Cc: Tifft, Doug

Subject:

[External_Sender] RE: Planned Issuance of Millstone Unit 2 License Amendment re: Surveillance Requirement 4.1.3.1.2 for CEA 39 (MF8935)

Categories: Action

Richard, I do have a few comments/questions:

1. Millstone 2 surveillance frequencies, including SR 4.1.3.1.2 are controlled by TS Surveillance Control Program. Is there a reason that this change, a de facto surveillance frequency change, is not being evaluated under this program?

2. Dominions NSHC response to question 1 states, CEA 39 was demonstrated to be moveable and trippable during the last performance of SR 4.1.3.1.2. Since the functionality of CEA 39 has not been affected The purpose of SR 4.1.3.1.2 is to determine if there are any conditions that have resulted in mechanical binding of the CEA. Dominion has not (see 1) determined that the surveillance interval can be extended; therefore, it is not clear to me how they can justify that the rod remains operable without performing the required surveillance within the specified surveillance interval. (TS 4.0.1) What is the basis for assuming the rod remains operable for a period beyond the surveillance interval? Does Dominion have rod failure data? How have they justified that end of cycle failure mechanisms such as thermally induced twisting/bowing are not present? Is there predictive data that indicates other signs of mechanical bowing? In short, the assessment provided seems to focus on why the UGC condition does not affect trippability but does not address basis for assuming that the CEA is not affected by other unrelated mechanisms beyond the analyzed surveillance interval.

3. How is the UGC being maintained de-energized? Does this method require any actions outside the control room to re-energize in order to move rods or can the LGC perform this function alone? If so, does this affect any TCOAs for an ATWS or other events requiring rapid manual insertion of control rods? I did not see this addressed under Administrative Controls.

I would appreciate a phone call to discuss in addition any email response.

Jeff Semancik Director, Radiation Division Connecticut Department of Energy and Environmental Protection 79 Elm Street, Hartford, CT 06106-5127 P: 860.424.4190F: 860.706.5339 E: Jeffrey.Semancik@ct.gov

www.ct.gov/deep Conserving, improving and protecting our natural resources and environment; Ensuring a clean, affordable, reliable, and sustainable energy supply.

From: Guzman, Richard [1]

Sent: Thursday, January 19, 2017 7:30 AM To: Semancik, Jeffrey

Subject:

Planned Issuance of Millstone Unit 2 License Amendment re: Surveillance Requirement 4.1.3.1.2 for CEA 39 (MF8935)

Good Morning, The NRC staff is preparing to issue the following license amendment related to Millstone Power Station, Unit 2. A brief description of the license amendment request (LAR) is provided below.

Additional information can be found in the licensees submittal which is also referenced below by ADAMS Accession number.

Please let me know if you have any comments or questions regarding this licensing action by January 26. My current projection for issuance of the amendment is by the 1st week of February.

Millstone Power Station, Unit 2 (MPS2), License Amendment Request re: Surveillance Requirement 4.1.3.1.2 for Control Element Assembly 39 (CAC No. MF8935)

Application date: December 14, 2016 (ADAMS Accession No. ML16354A424)

Brief Description of LAR: The amendment would revise the MPS2 Technical Specifications (TSs) for MPS2 by adding a note to TS Surveillance Requirement (SR) 4.1.3.1.2, control element assembly (CEA) freedom of movement surveillance, such that CEA 39 may be excluded from the remaining quarterly performance of the SR in Cycle 24. The amendment would allow the licensee to delay exercising CEA 39 until after repairs can be made during the next outage.

The LAR was published in the Federal Register (FR) on January 3, 2017 (82 FR 157) https://www.gpo.gov/fdsys/pkg/FR-2017-01-03/pdf/2016-31813.pdf. To date, no comments have been received.

Thanks, Rich

~~~~~~~~~

Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-8E10 l Phone: 301-415-1030