ML19276F284
| ML19276F284 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/12/1979 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-30200, NUDOCS 7903280219 | |
| Download: ML19276F284 (10) | |
Text
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UNITED STATES j
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NUCLEAR REGULATORY COMMisslON
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WASHINGTON, D. C. 20555
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March 12,1979 e i Dockets Nos.:
50-245 and 50-336 Mr. W. G. Counsil, Vice President Nuclear Engineering & Operations Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
By applications, dated April 4 and October 31,1977, you proposed changes to the Technical Specifications that would revise the surveillance frequency for incore detector calibration and modify the reporting requirements for Millstone Unit No. 2 and Millstone Units Nos.1 and 2, respectively. By letters dated August 10 and September 8,1978, you expressed your concerns regarding our handling of these two request for amendments.
This letter is to document our review of the staff's handling of the April 4,1977 request relating to the surveillance requirement for incore detector calibration and the October 31, 1977 request for changes to the reporting requirements.
Our positions in regards to these reviews are contained in Enclosures 1 and 2 to this letter.
Based on our findings documented in Enclosure 1, we consider your request for an amendment relating to the surveillance frequency of the incore detector channels to be withdrawn by your September 8,1978 letter.
This item is, therefore, considered resolved.
We apologize for inadequate communications with your staff prior to the issuance of Amendments Nos. 45 and 36 on reporting requirements.
790a280 &7
Northeast Nuclear Energy Company It is our intent to resolve differences between licensee requests and our requirements before final action is taken.
However, based on our findings documented in Enclosure 2, we conclude that the issued reporting requirements are acceptable. We consider this item resolved unless we receive an additional response from you within 30 days of the date of this letter.
Sincerely, q
W Brian K. Grimes, Assistant Director for Engineering & Projects Division of Operating Reactors
Enclosures:
1.
NRC Positions - Request to Change the Incore Detector Calibration Frequency for Unit 2 2.
NRC Position - Request to Modify Reporting Requirements for Unit 2 -
cc w/er :losures:
See next page
Northeast Nuclear Energy Company CC:
William H. Cuddy, Esquire Day, Berry & Howard Counselors at Law One Constitution Plaza Hartford, Connecticut 06103 Waterford Pu' lic Library o
Rope Ferry Road, Route 156 Waterford, Connecticut 06385 Northeast Nuclear Energy Company ATTN:
Superintendent Millstone Plant Post Of fice Box 128 Waterford, Connecticut 06385 Northeast Utilities Service Company ATTN: Mr. James R. Himmelwright Nuclear Engineering and Operations P. O. Box 270 Hartford, Connecticut 06101 Anthony Z. Roisman, Esq.
Natural Resources Defense Council 917 15th Street, N.W.
Washington, D.C.
20005 Mr. John T. Shediosky Nuclear Regulatory Commission, Region I Office of Inspection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406
ENCLOSURE 1 NRC POSITIONS IN REGARDS TO NNEC0 REOUEST TO CHANGE THE INCORE DETECTOR CALIBRATION FREOUENCY FOR MILLSTONE UNIT NO. 2 Introduction By letter dated April 4,1977, NNECO proposed an amendment to Operating License No. DPR-65 for Millstone Unit No. 2 that would revise Technical Specification (TS) Surveillance Requirement 4.3.2.2.b.
The proposed revision would change the incore detection system channel calibration frequency from an 18-month interval to each time the reactor vessel head is removed. Although the April 4,1977 letter does not document the reason for this request, the staff understood that a forced outage could be required to perform Surveillance Requirement 4.3.3.2.b, since this surveillance cannot be performed during reactor operation.
This understanding is verified by the NNECO letter, dated September 8,1978.
Issue Whether the TS should be changed from:
"4.3.3.2 The incore detection system shall be demonstrated OPERABLE:
b.
At least once per 18 months by performance of a CHANNEL CALIBRATION operation which exempts the neutron detectors but includes all electronic components.
The neutron detectors shall be calibrated prior to installation in the reactor core."
to-
"4.3.3.2 The incore detection system shall be demonstrated OPERABLE:
b.
Prior to operation following removal of the reactor vessel head by performance of a CHANNEL CALIBRATION operation which exempts the neutron detectors but includes all electronic components. The neutron detectors shall be calibrated prior to installation in the reactor core."
Licensee Position The NNEC0 letters, dated April 4,1977 and September 8,1978, give the following positions in support of their proposal.
1.
The intention of the 18-month surveillance frequency on the incore detector channel calibration is to perform this cali-bration once per fuel cycle.
ENCLOSURE 1 2.
The primary purpose of the calibration is to verify channel continuity.
Individual channels of the incore detector system are demonstrated operable by the readout of the plant comparater in performing the Incore Analysis (INCA) program.
The INCA program utilizes the incore detection system electronic components for all channels and these are continuously cross-checked and updated for detector sensitivity corrections.
In performing the required calibration, the connections between the neutron detectors and the balance of the incore detection system must be broken.
Inasmuch as these connections are proved on a continuous basis, it is not necessary to additionally demonstrate their integrity by disconnecting for the purpose of verifying continuity.
- However, it would be prudent to perform this continuity check whenever incore cable connections are broken such as when the reactor vessel head is removed.
3.
The staff requirement that the incore detector calibration be performed ahead of the first refueling outage was contrary to the Commission-propagated ALARA philosophy, highlighted by the fact that no increase in plant safety or reliability resulted.
Staff Response The staff response to the licensee positions is as follows:
1.
The intent of TS Table 1.2 is to specify the frequency required for performing the various surveillance requirements.
All of these frequencies are based upon elapsed time intervals rather than "once per fuel cycle" as you indicate.
The longest interval specified in Table 1.2 is "at least once per 18 months" which was selected as a time interval sufficiently long to cover normal fuel cycles but still an adequate frequency to satisfy our performance criteria.
We find the licensee's proposed words, " Prior to operation following removal of the reactor vessel head" overly conservative in that several licensees have, in the past few years, founu a core related problem that dictated vessel head removal shortly after initial startup or after a refueling. Thus an extra unneeded instrument calibration would have been required.
ENCLOSURE 1 2.
A channel calibration, as defined in Specification 1.9, requires much more than to simply " assure the integrity of the incore cabling after the reactor vessel head handling operations are compl ete. "
It requires the adjustment, as necessary, of the channel output such that it responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The channel calibration shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the channel functional test.
We conclude that the licensee's interpretation of the intent of the channel calibration, as quoted in NMECO letters of April 4,1977 and September 8, 1978, is inadequate.
3.
As the NNEC0 letter of September 8,1978 indicates, the staff was agreeable to issue the requested "one-time" extension for the incore detector calibration surveillance requirement. The basis for this extension to December 31, 1977 was since the actual extension was less than two months (18-month due date of June 26,1977 plus 4.5 months allowed by TS 4.0.2), a forced outage to perform this surveillance was not justified.
- However, when the reactor was placed in cold shutdown in May 1977 to retube the main condenser, the justification for the extension became void.
The licensee's letter stated that by not granting the extension, the staff made an arbitrary decision contrary to the Commission's ALARA philosophy.
Between the start of commerical operation of fiillstone 2 (December 26, 1975) and the spring 1979 refueling outage (presently scheduled to begin on March 17, 1979) only one incore detector calibration was required. Whether this calibration was performed between June 26, 1977 and November 9,1977 or before December 31, 1977 should have no effect on the radiation exposure of the personnel per-forming the calibration.
Therefore, the staff decision to not authorize the requested extension had no adverse effect on the ALARA philosophy.
Resolutica Since the surveillance requirement under discussion has already been performed, processing the NNEC0 request, dated April 4,1977, would serve no useful purpose. Also, the NNEC0 letter, dated September 8,1978, states that they no longer request the proposed cha nge. Therefore,this request for an amendment related to the incore detector channel calibration surveillan e frequency should be considered resolved.
ENCLOSURE 2 NRC POSITION IN REGARDS TO NNECO REOUEST TO MODIFY THE REPORTING REOUIREMENTS FOR MILLSTONE UNIT NO. 2 Introduction By letter dated October 31,1977, NNEC0 proposed an amendment to Provisional Operating License No. DPR-21 and Operating License No. DPR-65 for Millstone Units Nos.1 and 2 that would modify the Technical Specifications (TS) Reporting Requirements, Section 6.9.
This proposed amendment was in response to NRC requests dated July 29, 1977 and September 22, 1977.
Amendments Nos. 45 and 36 for Millstone Units Nos.1 and 2, respectively, issued on March 10, 1978, modified Section 6.9 of the TS to permit use of LER and Monthly Operating Report formats di?ferent than those contained in Regulatory Guide 1.16 and calete the requirements for an Annual Operating Report.
- However, in the October 31, 1977 submittal, NNECO included six extra state-ments beyond what the staff had requested and issued by Amendments Nos.
45 and 36. A NNEC0 letter, dated August 10, 1978, states their belief that these extra statements provide "more explicit definitions of a degraded mode, excepting surveillance testing, calibration and preventive maintenance from reporting requirements and other clarifying points."
Issue Whether the TS should be modified to add the following underlined extra statements.
Reportable Occurrences
- 6. 9. l. 7 The REPORTABLE OCCURRENCES of Specifications 6.9.1.8 and 6.9.1.9 below, including corrective actions and measures to prevent recurren;e, shall be reported to the NRC.
Supplemental reports may be required to fully describe final resolution of occurrence.
In case of corrected or supplemental reports, a licensee event report :nall be completed and reference shall be made to the original report date.
Reports shall be submitted in accordance with " Instructions for Preoaration of Data Entry Sheets (1) for Licensee Event Report (LER) File," NUREG-0161, July 1977, except that addition.I narrative may be supplemental to the LER form and is not reauired to be complete in itself.
ENCLOSURE 2 Prompt Notification with Written Followup 6.9.1.8 The types of events listed below shall be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegraph, mailgram or facsimile transmission to the Director of the Regional Office, or his designate, no later than the first working day following the event, with a written followup report within 14 days.
The written followup report shall include, as a minimum, a completed copy of a licensee event report form.
Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.
Abnormal degradation discovered in fuel cladding, reactor c.
coolant pressure boundary, or primary containment.
Abnormal dearadation is defined as any condition in (2) excess of apolicable inspection or Technical Specification cri teria.
Failure or malfunction of one or more components which e.
prevents or could prevent, by itself, the fulfillment of the functional requirements of system (s) used to cope with accidents analyzed in the SAR.
This item is not (3) applicable to reduced redundancy that does not result in loss of system function.
f.
Personnel error or procedural inadequacy which prevents or could prevent, by itself, the fulfillment of the functional requirements of systems required to cope with accidents analyzed in the SAR.
This item is not (4) apolicable to reduced redm6cy that does not result in loss of system function.
i.
Performance of structures, systems, or components that requires remedial action or corrective measures to prevent operation in a manner less conservative than assumed in the accident analyses in the Safety Analysis Report or technical specifications bases; or discovery curing unit life or conditions not specifically con-sidered in the Safety Analysis Report or technical specifications that require remedial action or corrective measures to prevent the existence or development of an unsafe condition.
The tyoes of events to be recorted (5) under this item are those having ceneric significance.
ENCLOSURE 2 Thirty Day Written Reports 6.9.1.9 The types of events listed below shall be the subject of written reports to the Director of the Regional Office within 30 days of occurrence of the event. The written report shall include, as a minimum, a completed copy of a licensee event report form.
Information provided on the licensee event report form shall be supplemented, as needed, by additional narrative material to provide complete explanation of the circumstances surrounding the event.
b.
Conditions leading to operation in a degraded mode permitted by a limiting condition for operation or plant shutdown required by a limiting condition for operation.
Note: Routine surveillance testing, instrument calibration or oreventive maintenance reauir-ina system configurations as described in items a and b above need not be reported except (6) where test results themselves reveal a degraded mode. A degraded mode is a condition res'ilting in a reduction in the sDecified degree of redundancy of any safety related system or com-ponent reauired to cope with accidents analyzed in the SAR.
Licensee Position The NNECO letters of October 31, 1977 and August 10, 1978 give the positions in support of the six extra statements that they had identified as, " areas which had proven ambiguous in the past.
These areas involved such things as more explicit definitions of a degraded mode, excepting surveillance testing, calibration and preventive maintenance from reporting requirements and other clarifying points."
They believe that,"the need for this type of clarification cannot be overemphasized due to the strictly literal interpretation the Office of Inspection and Enforcement applies to Technical Specification requirements."
Staff Response The staff response to the licensee arguments are as follows.
The bracketed numerals refer back to the " Issue" section of this document.
ENCLOSURE 2 (1) The staff believes that as experience is gained with the LER format, modifications may be necessary or desirable.
For this reason, the staff deliberately chose not to include a reference in the TS to a particular NUREG document so that modifications to the LER format could be made without a TS change.
(2) thru (6)
The extra statements proposed by the licensee are based on notes contained in Regulatory Guide 1.16 Revision 4, out for comment since August 1975. Although the staff has no problem with these extra statements and recommends that the licensee use all Regulatory Guides as appropriate, we find repeating the notes in the TS is repetitive and unnecessary.
In order to evaluate the licensee's statement in regards to the
" strictly literal interpretation the Office of Inspection and Enforcement applies to TS requirements," the staff performed a computer search of the enforcement records of all facilities for the past year.
This search has revealed a total of 23 violations (infraction or deficiencies) on the reporting requirements section of TS.
Of this total, ten involved late NRC notification, eight were failure to report the incident and five were because of lack of content of the reports.
No violations of the " strictly literal interpretation" type were identified.
Resolution Based on the above staff respcase, we conclude that the standardized reporting requirements issued to Millstone Units Nos. I and 2 by Amendments Nos. 45 and 36 are still acceptable.
However, the licensee should be given an opportunity to commei.t on our findings prior to considering this ratter closed.