ML19260D849
| ML19260D849 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 12/18/1979 |
| From: | Ziemann D Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| Shared Package | |
| ML19260D850 | List: |
| References | |
| NUDOCS 8002120503 | |
| Download: ML19260D849 (10) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION yDe g
- C WASHINGTON, D. C. 20555 5"
December 18, 1979
- ..../
y Docket No. 50-245 Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
On September 19, 1979, Amendment No. 64 to Provisional Operating License No. DPR-21 for the Millstone Nuclear Power Station Unit No. I was issued.
This amendment revised the Technical Specifications to incorporate an inservice inspection and testing program that meets the requirements of 10 CFR 50.55a.
By letter dated Se r. ember 13, 1979, you submitted (1) a revised valve listing and requests for relief, which were addressed in Amendment No. 64, and (2) testing infomation and requests for relief related to the non-Emergency Core Cooling Systems (ECCS) for Millstone 1.
During the preparation of our Safety Evaluation (SE) supporting Am.ndment No. 64 and the granting of certain requests for relief,.ve inadvertently omitted the valve testing infomation and relief requests for the non-ECCS area.
Based on our review of this portion of your valve testing program, we have determined that the conclusions contained in Section VI (page 23) of our SE supporting License Amendment No. 64, dated September 19, 1979, remain valid.
Relief from valve testing requirements pertaining to non-ECCS is hereby granted as discussed in the enclosed SE pages.
We have determined that the granting of this relief is authorized by law and will not endanger life or property or the comon defense and security and is otherwise in the public interest.
We have determined that granting of the relief does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this detenination, we have further concluded that the relief involves an action which is insignif{ cant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement, or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this action.
1950 001 soouso 50 3 g
Mr. W. G. Counsil December 18, 1979 You are, therefore, requested to replace the existing page 20 with the enclosed page 20 and add new pages 22a through 22f to our SE dated September 19, 1979.
A notice relating to the granting of additional relief is enclosed for your information.
We regret any inconvenience this inadvertent error may have caused you.
Sincerely,
.h y~.6%s h (imy Dennis L. Zieman Chief Operating Reactors E.aanch #2 Division of Operating Reactors
Enclosures:
1.
Pages 20, 22a - 22f to the SE supporting License Amendment 64 2.
Notice cc w/ enclosures:
See next page 1950 002
Mr. W. G. Counsil December 18, 1979 cc w/ enclosures:
William H. Cuddy, Esquire Connecticut Energy Agency Day, Berry & Howard ATTN: Assistant Director Counselors at Law Research and Policy One Constitution Plaza Devel opment Hartford, Connecticut 06103 Department of Planning and Energy Policy Anthony Z. Roisman 20 Grand Street Natural Resources Defense Council Hartford, Connecticut 06106 917 15th Street, N. W.
Washington, D. C.
20005 Director, Technical Assessment Division Northeast Nuclear Energy Company Office of Radiation Programs ATTN:
Superintendent
( AW-459 )
Millstone Plant U. S. Environmental Protection P. O. Box 128 Agency Waterford, Connecticut 06385 Crystal Mall #2 Arlington, Virginia 20460 Mr. James R. Himmelwright Northeast Utilities Service Company U. S. Environmental Protection P. 0. Box 270 Agency Hartford, Connecticut 06101 Region I Office ATTN:
EIS COORDINATOR Nuclear Regulatory Commission, Region I JFK Federal Building Office of Inspection and Enforcement Boston, Massachusetts 02203 ATTN: John T. Shedlosky 631 Park Avenue King of Prussia, Pennsylvania 19406 Waterford Public Library Rope Ferry Road, Route 156 Waterford, Connecticut 06385 First Selectman of the Town of Waterford Hall of Records 200 Boston Po.;t Road Waterford, Connecticut 06385 1950 003
. Basis for Requestino Rollef The licensee interprets this section c,f the Code to mean that the Authorized Nuclear Inspector may elect to witness any or all opera-tional readiness tests and the preparations thereof. Because operating tests may be conducted at any hour, seven days a week, and the Author-i-zed Nuclear Inspector has no training or experience in plant opera-tions, the licensee requests a waiver from the requirement.
Evaluation Testing af some valves during normal plant operations cannot be performed because of safety considerations. These valves are being required to be tested during other modes of plant operation and strict scheduling of tests for these valves cannot be maintained by the licensee.
In such cases, the licensee must request relief from the requirement of having an Authorized Nuclear Inspector present to observe the performance of the tests. However, the licensee is not relieved from recordig *est results and retaining this infomation for inspection the Authorized Nuclear Inspector.
9.
The Appendix J review for this plant is a completely separate review from the IST program review.
However, the determinations made by that review are directly applicable to the IST program.
Our review has detennined that the current IST program as submitted by the licensee correctly reflects our interpretation of Section XI vis-a-vis Appendix J.
The licensee has acreed that, should the Appendix J program be amended, they will amend their IST program accordingly.
B.
Core Spray and Low Pressure Coolant Injection System 1.
Category C Valves 1.1 Relief Requested Exclude the following check valves from the ASME Code Section XI requirements for quarterly operability test.
1-CS-6A and 1-C'-6B (Pump discharge to vessel checks) 1-LP-llA (Inboard check in the LPCI system)
ASME Code Requirement 1950 004 Refer to paragraph V. A.3.
Licensee Basis for Requested Relief There is no design provision for manually exercising these valves and stroking vith system flow requires that water be pumped into the reactor vessel. This is not possible at power, because of pressure differences and themal-hydraulic considerations.
NRC Evaluation Valves 1-LP-11 A,1-CS-6A and 6B cannot be exericised without de-pressurizing the reactor because the LPCI and core spray system pumps are not able to overcome reactor coolant pressure.
December 18, 1979
s
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D.
General 1.0 Relief Requested The Category A valves will meet Appendix J leak testing requirements in lieu of Section XI requirements.
Code Requirements Category A valves shall be leak tested to IWV-3420.
Basis for Requesting Relief This request applies to valves whose only safety function is containnent isolation.
Present Technical Specifications require both an individual and an integrated leakage rate test for containment isolation valves and penetrations.
Technical Specifications also require repair and retest of any valves exceeding the leakage criteria.
The licensee believes that these tests insure the leak-tightness of
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all contaimnent isolation valves, in that they are tested under the conditions for which they are designed.
Operability testing of these valves during normal plant operation could cause a loss of containment integrity and/or systen function if a valve fails in a nonconservative position.
The licensee also requests relief from paragraph IWV-3420(f)
" Analysis of Leakage Rates" in that present rules for local leak rate testing of contaimnent isolation valves provide analytical data for determining acceptance criteria, based on canbined leakage of several valves.
Based on seat leakage data recorded to date, in connection with the contaimnent leak rate test program, the licensee requests relief from paragraph INV-3420(g)(2) because no meaningful trends have been established.
Evaluation The Category A valve leak rate test requirements of IWV-3420(a-e) have been superseded by Appendix J requirements for containment isolation valves (CIV). The NRC staff has concluded that the applicable leak test procedures and requirements for CIVs are detennined by 10 CFR 50 Appendix J.
Relief from paragraph INV-3420(a-e) for CIVs presents no safety problem since the intent of IWV-3420(a-e) is met by the Appendix J requirements.
1950 005 December 18, 1979
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We agree with ti.s licensee's basis that paragraphs f and g of IWV-3420 provide no additional information essential for plant operation or safety, or valve operability for Millstone 1 and the relief should be granted.
It should be noted that this relief request applies only where a type C Appendix J leak test is performed.
Based on the consideration discussed above the staff concludes that the alternate testing proposed above will give the reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
E.
Condensate System 1.0 Category C 1.1 Relief Requested The licensee has proposed to exercise the following valves at pump rotations such that all valves will be exercised at least once every six months:
a.
Condensate Pump 1A Discharge Valve 1-CN-2A b.
Condensate Pump 1B Discharge Valve 1-CN-2B c.
Condensate Pump 1C Discharge Valve 1-CN-2C d.
Condensate Booster Pump 1 A 1-CN-30A Discharge Valve e.
Condensate Booster Pump 1B 1-CN-30B Discharge Valve f.
Condensate Booster Pump 1C 1-CN-30C Discharge Valve Code Requirement Refer to paragrtoh V.A.3 Basis for Requesting Relief These valves are in normal service and are exercised as pumps are routinely rotated.
Each individual valve will not be exercised every three months.
Collectively, all valves will be exercised within a six month period.
Evaluation The valves listed in the above relief request are either passive and/or redundant valves.
The optimum test interval for operability testing passive and/or redundant valves 1950 006 December 18, 1979
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was detemined by the staff, using actual failure rate data and standard probabilistic techniques, to be in the range of three months to 27 months.
The interval, which has been proposed as the exercise interval for the above valves, occur every six months which is within the optimum range for operability testing of these valves.
Passive, as used in the above paragraph, means any component whoge unavailability upon demand is less than or equal to 10- / demand.
Check valves are considered pa their unavailability has tieen found to be 10 gsive since
/ demand.
Redundant, as used above, means the existence of more than one valve for performing a given function.
Furthermore, the ASME Code, which requires testjng be done quarterly and which has been adopted in 10 CFR $50.55a, also allows testing at cold shutdowns if quarterly testing is impractical.
Cold shutdowns can occur at intervals up to refueling outages. Therefore, changing the test intervals from quarterly to once every six months shall not differ significantly from the Code pemitted change from quarterly to colJ shutdown testing.
Based on the considerations discussed above, the staff concludes that the alternate testino frequencies proposed above will give the reasonable assurance of valve operability intended by the Code and that the relief thus granted will not endanger life or property or the common defense and security of the public.
F.
Control Rod Hydraulic (CRH) System 1.0 Category B Valves 1.1 Relief Requested The licensee has proposed to exercise the following valves at refueling outages:
a.
Air valves from Reactor Protection 302-19A b.
Air valves from Reactor Protection 302-19B c.
Air valves from Reactor Protection 302-20A d.
Air valves from Reactor Protection 302-208 Code Recuirement Refer to paragraph V. A.3 1950 007 December 18, 1979
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Basis for Requesting Relief These valves are solenoid operated and thus cannot be part-stroked. Full stroking could cause an unscheduled reactor trip. These valves are operated 145 times each refueling as part of control rod testing.
Evaluation We agree with the licensee's basis for not stroking these valves during power operation or during cold shutdowns. We find that the proposed request to exercise at refueling outages only is warranted and should be granted.
(Refer to the evaluation contained in V.E.)
1.2 Relief Reouested The licensee has proposed to exercise the following valves at refueling outages:
a.
CRH Scram Outlet 305-114 (Category C) b.
CRH Scram Inlet 305-115 (Category C) d.
CRH Scram Inlet 305-126 Code Recuirenent Refer to paragraph V.A.3 Basis for Recuesting Relie' These valves cannot be part-stroked because of their construction. They cannot be exercised at cold shutdowns because of system interlocks. The cold shutdown made switch prohibits the withdrawal of control rods.
Evaluation We agree with the licensee's basis for not stroking these valves during power operation or during cold shutdowns.
We find that the proposed request to exercise at refueling outages only is warranted and should be granted.
(Refer to the evaluation contained in V.E).
1950 008 December 18, 1979
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G.
Feedwater Coolant Injection 1.0 Category C Valves 1.1 Relief Reouested The licensee has proposed to verify that these valves are closed once every rLfueling:
a.
Outside Containment Check Valve 1-FW-9A b.
Outside Containment Check Valve 1-FW-98 c.
Inside Containment Check Valve 1-FW-10A d.
Inside Containment Check Valve 1-FH-10B Code Requirement Refer to paragraph V.A.3 Basis for Requesting Relief Cessation of flow would cause the loss of feedwater.
But even with the cessation of flow the position of the valve cannot be verified except with a leak test.
Evaluation We agree with the licensee's basis that stroking these valves is impractical during power operation or cold shutdowns. We find that the proposed request to exercise at refueling outages only is warranted and should be granted.
(Refer to the evaluation contained in V.E).
H.
Isolation Condenser 1.0 Category C Valves 1.1 Relief Requested The licensee has proposed to exercise the following valve at refueling outages:
a.
Make-up Check Valve 1-lC-11 Basis for Requesting Relief Exercising this valve requires flow into the isolation condenser. Operating water level must be lowered to allow for additional water to be pumped to the shell. Lowering the water level reduces the safety margin of this component.
1950 009 December 18, 1979
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Evaluation We agree with the licensee's basis that stroking this valve is impractical during power operation or cold shutdowns. We find that the proposed request to exercise at refueling cJtages is warranted and should be granted.
(Refer to the evaluation contained in V.E).
1950 010 December 18, 1979