B10205, Application to Amend License DPR-65,revising Tech Specs to Clarify Power Operated Relief Valve Operability & Position Indication Surveillance Requirements.Amend Fee Encl
| ML20003J373 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/05/1981 |
| From: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20003J374 | List: |
| References | |
| B10205, TAC-43842, NUDOCS 8105110322 | |
| Download: ML20003J373 (3) | |
Text
e-4 NORTHEAST UTILITIES 14 e we,,uin et -w m o ***
P.o. Box 270 Us M S $((ErsY. M b wy HARTFORD, CONNECTICUT 06101 L
tTa E!!EI5i3,9Ehr
/GT;s May 5, 1981 q
Docket No. 50-336 l$
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MAY l11981>
8 B10205 m
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M Director of Nuclear Reactor Regulation
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Attn:
Mr. Robert A. Clark, Chief 57 Operating Reactors Branch #3
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U. S. Nuclear Regulatory Commission Washington, D.C.
20555
References:
(1)
R. A. Clark letter to W. G. Counsil, dated April 7,1981.
(2)
W. G. Counsil letter to D. G. Eisenhut, dated September 16, 1980.
(3)
R. A. Clark letter to B. D. Withers, dated January 21, 1981.
Gentlemen:
Millstone Nuclear Pc <er Station, Unit No. 2 gposed Revisions to Technical Specifications As a result of a review of Amendment No. 66 to DPR-65 issued by Reference (1),
Northeast Nuclear Energy Company (NNECO) has identified the need to revise portions of the Millstone Unit No. 2 Technical Specifications. The required changes:
(1) correct conflicting requirements of Action Statements 3.3.3.8(a) and 3.4.3(a), (b) for the Power Operated Relief Valve (PORV )
Block Valve and, (2) permit mode changes with less than two (2) operable PORV's provided j
the appropriate action statement is fulfilled.
Accordingly, pursuant to 10CFR50.90, NNECO hereby proposes to amend Operating License No. DPR-65 by incorporating the revisions identified in the attachment l
into the Millstone Unit No. 2 Technical. Specifications.
The proposed changes are administrative in nature a' are designed to clarify the Technical Specification requirements regarding '~ 0RV operability and position indication surveillance requirements. The proposed changes are discussed in detail below.
Currently, there exist conflicting requirements in Technical Specification Action Statements 3.3.3.8(a) and 3.4.3(a) and (b). To comply with Action Statement i
3.h.3(a) or (b), the inoperable PORV is isolated by closing its associated f
810511 W322
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i block valve and re=oving power fro = the block valve. However, when power is re=cved fro = the block valve, its position indication is rendered inoperable.
Technical Specification 3.3.3.8(a) requires that block valve position indication be operable as part of the accident mnitoring instru=entation of Table 3.3-11.
By co= plying with Action State =ent 3.h.3(a) or 3.h.3(b), block valve position vill be known and as such, tne requirements of Table 3.3-11 for the block valve are satisfied and Action State =ent 3.3.3.8(a).3 for the block valve is not applicable. The proposed change =cdifies Action 3
' Table 3.3-11 as vell as appropriate portions of Table k.3-7 such that te are not required, as applied to the block valve, if Action State =ent 3.4.3(a) or (b) has been invoked.
j Included in Reference (1) were Technical Specification Li=iting Conditions for Operation and Surveillance Require =ents for the PORV's resulting from the NRC Staff's assess =ent of the accident at Three Mile Island. As the PORV's are not safety-related cc=ponents, no credit is taken in current licensing basis safety analyses for their operability. It was not ICIECO's intention to propose, in Reference (2), that both PORV's be required to be operable prior to passage through operational = odes. Therefore, deletien of the re-quire =ents of Standard Technical Specification 3.0.L are requested for the PORV's, and is included as Action State =ent 3.h.3(c).
It is ICIECO's understanding that the Technical Specificaticns for the Trojan Nuclear Plant, Operating License No. NPE-1, do not require that both PORV's be operable prior to mode changes as docu=ected in Reference (3).
In addition, NURM-Ok52, Revision 3, Septe=ber 1980, in which the Staff issued the Standard Technical Spe:ifications for h'estinghouse Nuclear Stea Supply Syste=s, does not require that both PORV's be operable prior to changing operational modes.
Regarding the potential conflict which may arise between Action State =ents 3.4.3(a) and (b) and Sarveillance Require =ent h.h.3.2, :iNICO ic hereby docu=enting its interpretation that the require =ents of the action state-
=ent take precedence. If the current plant configuration of an inoperable PORY a id a closed associated block valve is =aintained until such time as l
Surveillance Require =ent k.h.3.2 is due, the block valve vill not be cycled.
l ICIECO has reviewed the attacced changes pursrat to the requirements of 10CFR50.59 and ha : determined that they do nc.c constitute an unre rieved safety question.
The Millstone Unit No. 2 Nuclear Reviev Board has reviewed and approved the attached proposed changes and has concurred in the above deter =ination.
i ICiECO has reviewed the proposed license a=end=ent pursuant to the require =ents of 10CFR170 and has deter =ined that these proposed changes constitute a Class II license a=end=ent.
The basis for this deter =.ination is that the proposed change is administrative in nature as it is designed to clarify r
existing conflicts within the Technical Specifications. Accordingly, enclosed I
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" herewith is paynent in the a=ount of $1,2C ' (twelve hundred dollars). -
As discussed verbally with your Staff, issuance of the license a=end=ent today -
is respectfully requested.
Very truly'yours, NORTHEAST NUCLEAR ENE?,GY COMPANY
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W. G. - Counsil Senior Vice President STATE OF CC35ECTICUT )
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Eerlin COU3TY OF EARTFORD
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Then personally appeared before =e W. G. Counsil, who being duly.svorn, did state that he is Sen.or Vice President of Northeast Nuclear Energy Cc=pany, a Licensee herein, that he is authorized to execute and file the foregoing infer:ation in the name and on behalf of the Licensees herein and that the state =ents contained in sai?. infor:ation are true and correct to tne best of his knowledge and belief.
i AA Bs notary Publi:
M Comm!ssion Exp!res IJmfi 3r,1988
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