ML20010E427
| ML20010E427 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/28/1981 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Counsil W NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| RTR-REGGD-01.045, RTR-REGGD-1.045, TASK-05-05, TASK-5-5, TASK-RR LSO5-81-08-088, LSO5-81-8-88, NUDOCS 8109040122 | |
| Download: ML20010E427 (9) | |
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I August 28, 1981 Docket ?!o. 50-245 t-LS05 08-088 j
h SEP 03198% Q 4r. W. G. Counsil, Vice President "A gnaxame
~Iluclear Engineering and Operations V
U flortheast Huclear Energy Company P. O. Box 270 4
Nq,
Hartford, Connecticut 06101
Dear Mr. Counsil:
SUBJECT:
SEP TOPIC V-5, REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION - MILLSTONE NUCLEAR POWER STATI0tl Enclosed is a copy of our final evaluation of SEP Topic V-5 for the Millstone Nuclear Power Station. This assessment compares your facility as described in Docket No. 50-245, with the criteria currently used by the regulatory staff for licensing new facilities. This revised evalua-tion factors in the information contained in your April 25, 1981 and August 6,1981 letters on this subject, and pertinent information con-tained in SEP Topic V-10.A and available 10 CFR 50, Appendix I submittals fer Millstone Unit 1.
The evaluation concludes that the reactor coolant pressure boundary leakage detection systems do not presently confom to the recoranendations of Regulatory Guide 1.45 and gives the modifications needed to establish compliance. The necessity for implementation of the modifications will be considered during the integrated safety assessment. This assessment may be retised in the future if your facility design is changed or if NRC criteria relatb g to this subject are modified before the integrated assessment is comp k ced.
Sincerely, Dennis H. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing
Enclosure:
SEP Topic V-5 A
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NUCLEAR REGULATORY COMMISSION E
WASHING TON, D. C. 20555
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August 28, 1981 Docket No. 50-245 LS05 08-088 Mr. W. G. Counsil, Vice President Nuclear Engineering and Operations Northeast Nuclear Energy Company P. O. Box 270 Hartford, Connecticut 06101
Dear Mr. Counsil:
SUBJECT:
SEF OPIC V-5, REACTOR COOLANT PRESSURE B0UNDARY LEAKAGE DEisCTION - MILLSTONE NUCLEAR POWER STATION Enclosed is a copy of our final evaluation of SEP Topic V-5 for the Millstone Nuclear Power Station.
This assessment compares your facility as described in Docket No. 50-245, with the criteria curre.1tly used by the regulatory staff for licensing new facilities.
This revised evalua-tion factors in the information contained in your April 25,1981 and August 6,1981 letters on this subject, and pertinent information con-tained in SEP Topic V-10.A and available 10 CFR 50, Appendix I submittals for Millstone Unit 1.
The evaluation concludes that the reactor coolant pressure boundary leakage detection systen.s do not presently conform to the recommendations of Regulatory Guide 1.45 and gives the modifications needed to establish compliance. The necessity for implementation of the modifications will be considered during the integrated safety assessment. This assessment may be revised in the future if your facility design is changed or if l
l NRC criteria relating to this subject are modified before the integrated assessment is completed.
l Sincerely,
/ !+t4 4 Dennis M. Crutchfield, C ef Operating Reactors Branch No. 5 Division of Licensi.ng
Enclosure:
SEP Topic V-5 cc w/ enclosure:
See next page L
o Mr. W. G. Counsil cc William H. Cuddy, Esquire Connecticut En?rgy Agency Day, Berry & Howard ATTN: Assistant Director Couns~clors at Law Research an d Policy One Constitution Plaza Development Hartford, Connecticut 06103 Department of Planning and Energ; 'alicy Natural Resources Defense Council 20 Grand Street 91715th Street, N. W.
Hartford, Connecticut 06106 Washington, D. C.
20005 Director, Criteria and Standards Division Northeast Nuclear Energy Coupany Office of Radiation Programs ATTN: Superintercent (ANR-460)
Millstone Plant U. S. Environmental Protection P. O. Box 128 Agency Waterford, Connecticut 06385 Washingtone D. C.
20460 Mr. James R. Himmelwright U. S. Environmental Protection Northeast Utilities Service Conpany Agency P. O. Box 270 Region 1 Office Hartford, Connecticut 06101 ATTN: EIS COORDINATOR JFK Federal Building Resident Inspector Boston, Massachusetts 02203 c/o U. S. NRC P. O. Box Drawer KK Niantic, Connecticut 06357 Oaterford Public Library Rope Ferry Road, Route 136 Waterford, Connecticut 06385 First Selectman of the 'ogn of Waterford Hall of Records 200 Boston Post Road Waterford, Connecticut 06385 John F. Opeka Systens Superintendent Northeast Utilities Service Conpany P. O. Box 270 Hartford, Connecticut 06101 e
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MILLSTONE 1 SYSTEMATIC EVALUATION PROGRAM TCPIC V-5 REACTOR Cn0LANT PRESSURE B0UGARTTRCFBTEETML DLIECTION 1.
Introduction The safety objective of Topic V-5 is to determine the reliability and sensitivity of the leak detection systems which monitor the reactor coolant pressure boundary to identify primary system leaks at an early stage before failures occur.
II.
P,cview Criteria The acceptance criteria for the detection of leakace from the reactor coolant pressure boundary is stated in the General Design Criteria of Apperdix A,10 CFR Part 50. Criterion 30, " Quality of Reactor Coolant Pressure Bom dary,"
requires that means shall be provided for detecting and, to the extr.nt practi-cal, identifying the location of the source of leakage in the reactor coolant pressure boundary.
III. Review Guidelines The acceptance criteria are described in the Nuclear Regulatory Comission Standard Review Plan Section 5.2.5, " Reactor Coolant Pressure Boundary Leakage Detection." The areas cf the Safety Aaalysis Report and Technical Specifications are reviewed to establith that informaticn submitted by the licensee is in compli-ance with Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems."
IV.
Evaluation Safety Topic V-5 was evaluated in this review for compliance of the information submitted by the licensee with Regulatory Guide 1.45, " Reactor Coolant Pressure Boundary Leakage Detection Systems." The information in the Safety Analysis Report, Technical Specifications, the April 25, 1981 and August 6, 1981 letters l
from NU to the NRC regarding SEP Topic V-5 for Millstone Unit 1, the April 30, 1981 letter from NU to the NRC regarding SEP Topic V-5 for Haddam Neck, the March 5,1979 letter from NU to the NRC regarding SEP Topic V-10. A, and the available 10 CFR 50, Appendix I review information 'for Millstone Unit I was reviewed.
Regulatory Guide 1.45 requires that at-least three separate detection systems be installed in a nuclear power plant to detect an unidenti-
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fied leakage from the reactor coolant pressure boundary to the primary' contain-ment of one gallon per minute within one hour.
Leakage from identified sources must be isolated so that the flow rates may be monitored separately from unidentified leakage. The detection systems should be capable of per-forming their functions following certain seismic events and capable of being.
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A checked in the control room. Of the three separate leak detection methods required, two of the methods should be (1) sump level and flow monitoring and (2) airborne particulate radioactivity monitoring.
The third method may be either monitoring of condensate flow rate ~from air coolers or monitoring of aircorne gaseous radioactivity. Other detection methods, such as humidity, temperature and prenure, should be considered to be alarms of indirect indication of leakage to the containment.
In addition, provisions should be made to monitor systems interfacing with the reactor coolant pressure boundary for signs of intersystem leakage through methods such as radioact and water level or flow monitors.
Plant i
incorporated systems anr f4a corresponding features are tabalated in.
Detailed a'Jarce for the leakage detection system is con-tained in Regulatory Gr
. 45.
Based upon our review of the referenced documents and the summaries presented in Enclosure 1, we have determined:
- 1) The systems employed for the detection of leakage from the reactor coolant pressure boundary to the prin,ary containment meet the Regu-latory Guid 1.45 requirement for the types of leakage detection systems to be employed.
However, each of the systems required to be present does not have the required sensitivity for the detection of leaks of 1 gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
However, the aggregate use of systems 1 through 4 and 6 through 8,,1ven in Table 1 of Enclosure 1 results in the appropriate sensitivii.y.
In addition, none of the instruments are testable during r.ormal operation, and the sump level inventory and flow, and containment atmosphere temperature monitoring systems are not seismically qualified to function following earthquakesup to the OBE level, as required by the Guide.
(See Table 1 of Enclosure 1).
- 2) The Millstone Unit 1 Technical Specifications do not impose require-ments concerning the operability of the leakage detection systems to monitor leakage to the prinary containment,as required by Regulatory Guide 1.45.
- 3) Provisions are made to monitor reactor coolant in-leakage to those systems listed in Table 2 of Enclosure 1.
However, from the review of the referenced information it is not clear that this table includes all systems which interface with the reactor coolant oressure boundary.
In addition, the instruments are not testable during normal operation, and are not seismically qualified to function'following earthquakes up to the OBE level, as required by Regulatory Guide 1.45.
4)
Information concerning the use of reactor coolant inventory balances, as indicated in Table 3 of Enclosure 1, for a determination of its usefulness for reactor coolant pressure boundary leak detection is not available.
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V.
Conclusions Our review indicates that the systems employed at Millstone Unit 1 to measure reactor coolant pressure boundary leakage do not meet the reccamendations given in Regulatory Guide 1.45.
The following would be requh aj to establish compliance with the intent of this Guide:
- 1) While systems 1 through 4 and 6 through 8, listed in Table 1 of, cach do not have the capab,ility to detect reactor coolan* pressure boundary-to-containment leakage o.f 1 gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the licensee's experience is that the use of these systems in conjunction with each other is adequate to achieve this sensi-tivi ty.
Reliance on these systems for measurement of leakage from the. reactor coolant pressure bour.dary to the containment is adequate to meet the intent of Regulatory Guide 1.45 provided:
a) These instruments are modified to provide the capability for testing during normal operation:
b) The sump level and flow, and containment temperature monitoring systems are scismically goalified to assure their function following earthquakes up to and including the SSE given the poor sensitivity of the particulate radioactivity monitor; and c) A section is added to the Hillstone Unit 1 Technical Specifica-tions concerning operability of the reactor ccolant pressure boundary to the containment leakage deteciion systems.
Standard Technicht Specification 3/4.4.6 and the corresponding surveillance requirements should be used as guidance for the development of this se, tion. Operability of systems 1 through 4 and 6 through 8 is required, rather than the 4 listed in the Standard Technical Specification.
- 2) All systems interfacing with the reactor coolant pressure boundary should be identified.
Instrumentation conforming with the Regulatory Guide 1.45 recommendations should be installed to monitor for reactor coolant leakage into these systems, unless adequate justification is provided for not supplying such instrumentation.
The necessity for the implementation of the above modifications will be considered during the integrated safety assessment.
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.s REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE DETECTION SYSTEMS Regulatory Guide 1.45 Requirements 2
Plant: Millstone Unit 1
.Tablo 1:
Time Req'd **
Earthquake For Control Room' Document RCPB to Containment Leak Rate **
to Achieve Which ' Function Indicatian For ation Re System Incorporated Sensitivity '
Senritivity Is Assured Alarms & Indicators erence 4/25/81 a
- 1) Sump Level Monitori;ng (Inventory)
Yes Not qualified Yes 8/6/81 NL 4/25/81 a
- 2) Sump Pump Actsations Yes Not qualified Yes 8/6/81 NL Monitoring (Time Meters) 4/25/81 a Yes 78/6/81 NL
- 3) Airborne Particulate Yes
- Poor
- Poor SSE Radioactivity Monitoring 4/25/81 a 55E Yes 8/6/81 HL
- 4) Airborne Gaseous Yes Radioactivity Monitoring
- 5) Condensated Flow Rate from Air Coolers 4/25/81 SSE Yes 8/6/81 N
- 6) Containment Atmosphere Hs Pressure Monitoring 4/25/81 d SSE Yes 8/6/81 Nt
'/ ) Containment Atmosphere Yes Humidity Monitoring 4/25/81fI
- 8) Co'ntainment Atmosphere Yes Not qualified Yes 8/6/81 NL Temperature Monitoring
- 9) Accoustic Emissions
- 10) Moisture Sensitive Tape 8/6/81 NI
- 11) Air Conditioner Coolant Temperature Rise Yes Not qualified No and FSAR u-a.,
32)
- Based upon 4/30/81 letter from Nts re:
Haddam Neck, SEP Topic V-5
- S/6/81 letter from NU re: Millstone Unit 1, SEP Topic V-5 indicates in vidual systems are each ni for 1 gpm within 1 hr., however, the use of 1 through 4 and 6 through 8(above in conju i
adequate to achieve 1 gpm within 1 hr.
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Plant: Millstone Unit 1
'i Intersystem Leakage Methods to Time Req'd Earthquake For Control Room Measure RCPB Leak Rate to Achieve Which Function Indication For
{ Systems 2Wnich Interface w/ RCPB In-Leakage Sensi tivi ty
' Sensitivity Is Assured Alarms & Indicators I' I Reactor Building Closed Cooling Rad. Monitor Not specified Not specified Not qualified Yes I
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- 2) Water System Level Not spec 6fied Not specified Not qualified Yes.
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REACTOR COOLANT PRESSURE BOUNDARY LEAKAGE /0ETECTION SYSTEMS Regulatory Guide 1.45 Requirements 5
Plant: Millstono tinit 1
. Table 3:
RCS Inventory Enlance - Not available Leak P. ate Sensitiv.ity l
Corresponding Time Required to Achieve Sensitivity
- Normal 'Im entory Check Instrumentation Required with Corresponding Location:
l, Earthquake For Which Instrumentation Hardware Functioning Is Assured:
ll il Testable During Normal Operation:
Documentation
Reference:
8/6/81 NU letter re: Millstone Unit 1, SEP Topic V-5.
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