B10019, Application to Amend License DPR-65, Consisting of Proposed Revisions to Tech Specs Re Containment Electrical Penetrations.Procedure for Fuel Handling Accident Inside Containment Encl
| ML19320A880 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/26/1980 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | |
| Shared Package | |
| ML19320A881 | List: |
| References | |
| B10019, TAC-7424, NUDOCS 8007080164 | |
| Download: ML19320A880 (6) | |
Text
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i NOIrl'HEAST IRILITIES
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I FORD CONNECTICUT 06101 Z"OlJ"1'l:10ll""~
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L J :::::'f.;::a'rll7,*2l June 26, 1930 Docket No. 50-336 B10019 Director of Nuclear Reactor Regulation Attn:
Mr. Robert A. Clark, Chief Operating Reactors Branch #3 U. S. Nuclear Regulatory Commission Washington, D. C.
20555
References:
(1)
R. Reid letter to W. G. Counsil dated May 12, 1979.
(2)
W. G. Counsil letter to R. A. Clark dated May 13, 1980.
(3)
W. G. Counsil letter to R. Reid dated March 21, 1977.
(4)
W. G. Counsil letter to R. A. Clark dated May 9,1980.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 Proposed Revisions to Technical Specifications In Reference (1), the NRC Staff issued License Amendment No. 52 and the supporting Safety Evaluation to Facility Operating License No. DPR-65 for Millstone Unit No. 2.
Documented in Reference (1) was a commitment for Northeast Nuclear Energy Company (NNECO) to provide a proposal for permanent type repair of the containment electrical penetrations.
In response to that commitment, NNECO provided Refceence (2) which outlined the details of NNECO's containment electrical penetration replacement program at Millstone Unit No. 2.
The presently scheduled replacement program calls for replacing all electrical penetration modules which have experienced insulation resistance (IR) degradation during the 1980 refueling outage. NNECO intends to rer'..ee the remaining penetration modules, identified in Reference (2),
during future outages.
With the evolution of the 1980 refueling outage schedule, which includes the construction work schedule, it is evident that sufficient time will not be availabic to replace all electrical penetration modules which have experienced IR degradation without adversely impacting the startup schedule.
This is the result of Technical Specification limiting conditions f operation requiring containment integrity during periods of fuel movement.
This requirement has a significant and costly impact on the refueling outage schedule.
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< In an attempt to relieve this schedule constraint, and pursuant to 10CFR50.90, hNECO proposes to amend its operating license, DPR-65, by incorporating the revisions identified in Attachment 1 into the Millstone Unit No. 2 Technical Specifications.
The proposed changes permit electrical penetration work coincident with fuel movement in accordance with the provisions outlined in this letter. The purpose of this submittal is to demonstrate that adequate provisions can be taken to ensure continued protection of the public health and safety to accommodate NNECO's request for a license amendment.
Electrical penetrations through the containment are located in two areas of the plant. These penetrations terminate in the East and West Penetration Rooms at elevation 14'6" in the Auxiliary Building.
During times when electrical penetra-tion work is being performed coincident with fuel movement, the potential
' exists for increased consequences of a postulated fuel handling accident inside containment (FHAIC). To assure that the pc tential radiological consequences of a FHAIC remain within the bounds of the Staff's Safety Evaluation of Reference (1), NNECO intends to provide the following measures during penetration work coincident with fuel movement.
Provide dedicated personnel outside and inside containment to seal o
any open penetrations in the event of a FRAIC.
Direct communications will exist at all times between the control o
room and the electrical penetration workers both inside and outside the containment.
In the event of a FRAIC, workers inside and outside containment would o
seal any open electrical penetration upon direction from the control room.
Electrical penetration module work, resulting in a breach of containment o
integrity, will be performed on not more than four penetrations at any tine.
In addition, work resulting in a breach of containment integrity will~ be performed on no more than two electrical penetrations at any time in each penetration room.
In the event of a fuel handling accident inside containment, personnel located in the cicctrical penetration areas would be instructed by the control room to isolate the containment. This is accomplished by scaling the electrical penetration terminal boxes inside and outside the containment.
The electrical penetration terninal box is a NEMA 4 box having dimensions of 22" x 22" x -3t".
The terminal box has three (3) removable sides and can be sealed within five (5) minutes. The termf
-1 boxes meet all the appropriate requirements delineated in NEMA Standards Puulication 151.1-1975.
These boxes are illustrated in the attached figure.
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NNECO has determined that.the electrical' pene ration terminal box will provide an adequate. barrier to fission product release to the environment in the event' of a FtlAIC coincident with an open electrical penetration. This is based.on the following:
o Direct communications from the control room to personnel located at theJelectrical-penetrations will provide prompt notification of a FHAIC'and initiate containment isolation.
o - The time required to seal the terminal boxes (isolate the containment)
J(five minutes) is'50% less than that assumed in the evaluation by NNECO
~
of a FHAIC (Reference '(3)) and, as such, the results of that evaluation still apply.
Reference (3) concluded that the dose consequences of a FHAIC at the site boundary are well within the guidelines of 10CFR100.
o 'The electrical penetration terminal boxes are rated as NEMA 4 and are drip and dust proof.- Since no differential pressure will exist across the
. penetration as a result of a postulated FHAIC, the terminal box will
- provide an adequate barrier to fission product release from the containment.
Operation of the containment purge system during fuel movement with a flow o
rate of 32,000 cfm maintains ~the containment at a pressure lower than ambient and as such, leakage through any open electrical penetration, prior to sealing the penetration terminal box, will be into the containment.
The; maximum equivalent flow area from the containment with four o
electrical penetrations completely open is approximately 144 in.
' Based on the information provided above, NNECO has determined that limited electrical penetration. work coincident with fuel movement can be performed safely'and with no adverse environmental health effects.
In the highly unlikely event of a fuel handling accident inside containment, adequate provisions and procedures.will exist which will assure that the consequences of the incident will be within the guidelines of 10CFR100.
Included in Attachment 2 is the' procedure which will be utilized, in the event of a FHAIC..This procedure'will be revised to accommodate electrical penetration work coincident with' fuel movement as described above.
- NNECO has reviewed the attached change pursuant to the requirements of 10CR50.59 and has determined that-it does not constitute an unreviewed safety question.
I The Millstone Unit No. 2 Nuclear Review Board has reviewed and approved the attached proposed changes and concurred in the above determination.
NNECO has reviewed - the proposed license amendment pursuant to the requirements -
of 10CFP170 and.has determined that' this change is in conjunction with the
-CycleE4' reload. 'The appropriate amendment ~ fee was forwarded in Reference (4),
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We~ trust this information is sufficient for the Staff to expedite issuance of the requested license amendment to--facilitate development of an optimized refueling schedule.-
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY jfil/V1A W.-G.
Counsil Senior Vice President Attachment 4
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~ Then personally appeared before me W. G. Counsil, who being duly sworn,
~did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
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Notary Public ' My Ccmmission Expires Matcn.31, a.
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