ML20029C877

Application for Amend to License DPR-65,deleting Requirements Re Condenser Air Ejector Monitor from Tables 3.3-12 & 4.3-12

ML20029C877
Person / Time
Site:	Millstone
Issue date:	04/22/1994
From:	Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20029C878	List: ML20029C877 ML20029C880
References
B14405, NUDOCS 9405020277
Download: ML20029C877 (6)

Text

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• P.O. Ikin 270 Ilartford, UT 06141-0270 (203) 665-5000 April 22,1994 Docket No. 50-336-B14405 Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Radioactive Liouid Effluent Monitorino Instrumentation Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License No. DPR-65, by incorporating the attached proposed changes into the Technical Specifications of Millstone Unit No. 2. The purpose of this proposed license amendment is to ensure that the Millstone Unit No. 2 Technical Specifications reflect the more reliable method of detecting radioactivity in the steam generator blowdown discharge line under all operating conditions (the steam generator blowdown monitor).

Specifically, NNEC0 proposes to delete the requirements regarding the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit No. 2 Technical Specifications. Attachment 1 provides the marked-up pages of the Millstone Unit No. 2 Technical Specifications, and Attachment 2 provides the retyped pages of the Millstone Unit No. 2 Technical Specifications. These changes are discussed in detail below.

Rackaround The condenser air ejector monitor (steam jet air ejector radiation monitor) and the steam generator blowdown monitor are gross radioactivity monitors which provide automatic termination of steam generator _ blowdown discharge.

Currently, Technical Specification 3.3.3.9 (Table 3.3-12) requires the operability of one of these monitors in Modes 1 through 5 -and when ' the blowdown pathway is being used in Mode 6.

The condenser air ejector monitor was- included in Table 3.3-12 of the  ;

Millstone Unit No. 2 Technical Specifications to provide an alternate method to . monitor and isolate blowdown. It has been used to monitor blowdown for ,

typical causes of increased blowdown activity, such as increased primary  !

coolant activity or increased primary to secondary leakage, with .a corresponding increase in both the -air ejector and blowdown monitors. I Operational experience has shown that blowdown activity can increase'without a  !

corresponding increase in air ejector activity. For example, a plant. trip following an extended period of primary to secondary leakage can cause long-

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.S. Nuclear Regulatory Commission B14405/Page 2 April 22, 1994 lived secondary side activity (e.g., Cs-l';7) to come out of " hideout" in the 1 steam generator, resulting in an increase in blowdown activity without a 4 corresponding increase in air ejector activity. Another example would be a '

reduction in blowdown flow, holding all other parameters constant. This would cause an increase in blowdown concentration without a corresponding increase in air ejector activity. Under these conditions, the condenser air ejector monitor does not adequately monitor or isolate steam generator blowdown.

Therefore, the purpose of this proposed license amendment is to ensure that '

the Millstone Unit No. 2 Technical Specifications reflect the more reliable method of detecting radioactivity in the stean generator blowdown discharge line under all operating conditions (the steam generator blowdown monitor).

Description of the Proposed Chanaes NNEC0 proposes to delete the requirements regarding the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit No. 2 Technical Specifications. These proposed changes do r<ot impact the Baset of the Millstone Unit No. 2 Technical Specifications.

NNEC0 proposes to delete the operability requirements for the condenser air ejector monitor from item 1.c of Table 3.3-12 of the Millstone Unit No. 2 Technical Specifications, and delete table note "** " . Deleting the operability requirements for the condenser air ejector monitor will leave the steam generator blowdown monitor as the primary method of monitoring and isolating steam generator blowdown. Table note "**" currently states that while both the condenser air ejector monitor and the steam generator blowdown monitor are normally operable, only one of these monitors is necessary to be operable. This table note will no longer be required, after the operability requirements for the condenser air ejector have been deleted.

NNECO proposes to delete the surveillance requirements for the condenser air ejector monitor from item 1.d of Table 4.3-12 of the Millstone Unit No. 2 Technical Specifications, delete table notation "(3)," and delete the last sentence in table notation "(2)b." Deletion of the operability requirements for the condenser air ejector monitor would permit the deletion of the applicable surveillance requirements. Deletion of table notation "(3)" and the last sentence of table notation "(2)b" would be appropriate, because the condenser air ejector monitor entry of Table 4.3-12 contains the only reference -to table notation "(3)," and the last sentence of table notation

"(2)b" only concerns the s. veillance requirements for the condenser air ejector monitor.

Safety Assessment The condenser air ejector monitor was included in Table 3.3-12 of the Millstone Unit No. 2 Technical Specifications to provide an alternate method to monitor and isolate steam generator blowdown. The steam generator blowdown monitor is the other method available to monitor and isolate steam generator blowdown.

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'U.S. Nuclear Regulatory Commission 1 B14405/Page 3  !

April 22, 1994 '

As stated in the Background Section of this submittal, operational experience has shown that blowdown activity can increase without a corresponding increase I in air ejector activity. Under these conditions, the condenser air ejector l monitor does not adequately monitor or isolate steam generator blowdown. l Deleting the operability and surveillance requirements for the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit No. 2 Technical Specifications would leave the steam generator blowdown monitor as 4 the primary method of monitoring and isolating steam generator blowdown.

While NNECO is proposing to delete the operability and surveillance requirements for the condenser air ejector monitor from the Millstone Unit No. 2 Technical Specifications, there is no intent to change any of the design features or functions of the condenser air ejector monitor, or any of the specified surveillances or frequency for such surveillances. The condenser air ejector monitor will continue to isolate steam generator blowdown upon a high radiation alarm.

Deleting the operability and surveillance requirements for the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit No. 2 Technical Specifications would leave the steam generator blowdown monitor as the primary method of monitoring and isolating steam generator blowdown. The proposed license amendment imposes stricter limitations on the operation of Millstone Unit No. 2, because it requires the use of a single monitor, the steam generator blowdown monitor, to meet the requirements of Millstone Unit No. 2 Technical Specification 3.3.3.9 (Table 3.3-12).

The condenser air ejector monitor is not safety related, and it performs no safety related function. Steam generator blowdown isolation is required to ensure compliance with 10CFR20. It is not required to ensure compliance with 10CFR100. Therefore, the condenser air ejector monitor does not perform any safety function. It is not credited in any radiological consequence calculations presented in the Millstone Unit No. 2 Final Safety Analysis '

Report (FSAR).

Based on the above, the proposed license amendment does not have any impact on the health and safety of the public and is safe.

Sianificant Hazards Consideration The proposed technical specification change has been reviewed against the criteria of 10CFR50.92, and it has been determined not to involve a significant hazards consideration (SHC). Specifically, the proposed change does not:

1. Involve a significant increase in the probability or consequences of an accident previously analyzed. 1 Deleting the operability and surveillance requirements for the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit No. 2 Technical Specifications would leave the steam generator blowdown l

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U Nuclear Regulatory Commission B14405/Page 4 April 22,1994 monitor as the primary method of monitoring and isolating steam generator bl owdown. The proposed license amendment imposes stricter limitations on the operation of Millstone Unit No. 2, because it requires the use of a single monitor, the steam generator blowdown monitor, to . meet the requirements of Millstone Unit No. 2 Technical Specification 3.3.3.9 (Table 3.3-12).

While NNECO is proposing to delete the operability and surveillance requirements for the condenser air ejector monitor from the Millstone Unit No. 2 Technical Specifications, there are no plans to change any of the design features or functions of the condenser air ejector monitor, or-any of the specified surveillances or frequency for such surveillances.

The condenser air ejector monitor will continue to isolate blowdown upon a high radiation alarm.

Additionally, steam generator blowdown isolation is required to ensure compliance with 10CFR20. It is not required to ensure compliance with 10CFR100. Therefore, the condenser air ejector monitor does not perform any safety function. The condenser air ejector monitor is not safety related. It is not credited in any radiological consequence calculations presented in the Millstone Unit No. 2 FSAR.

Based on the above, this proposed license amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

This proposed license amendment does not involve any physical changes to plant equipment or any changes to plant procedures that would be a precursor to an accident. NNEC0 has no plans to change any of the design features or functions of the condenser air ejector monitor, or any of the specified surveillances or frequency for such surveillances. The condenser air ejector monitor will continue to isolate blowdown upon a high radiation alarm. Also, the proposed license amendment imposes stricter limitations on the operation of Millstone Unit No. 2, because it requires the use of a single monitor, the steam generator blowdown monitor, to meet the requirements of Millstone Unit No. 2 Technical Specification 3.3.3.9 (Table 3.3-12). Therefore, this proposed license;-

amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of safety.

Deleting the operability and surveillance requirements for the condenser air ejector monitor from Tables 3.3-12 and 4.3-12 of the Millstone Unit-No. 2 Technical Specifications would leave the steam generator blowdown monitor as the primary method of monitoring and isolating steam generator j blowdown. The proposed license amendment imposes stricter limitations on-

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'U S. . Nuclear Regulatory Commission B14405/Page 5 April 22, 1994 the operation of Millstone Unit No. 2, because it requires the use of a single monitor, the steam generator blowdown monitor, to meet the requirements of Millstone Unit No. 2 Technical Specification 3.3.3.9 (Table 3.3-12) . Therefore, this proposed license amendment does not impact or reduce the margin of safety.

The Commission has provided guidance concerning the application of standards in 10CFR5.92 by providing certain examples (March 6, 1986, 51 FR 7751) of amendments that are considered not likely to involve an SHC. The change proposed herein is enveloped by example (ii), "a change that constitutes an y additional limitation, restriction, or control not presentiy included in the '

technical specifications, e.g. a more stringent surveillance requirement."

Currently, Technical Specification 3.3.3.9 (Table 3.3-12) requires the ,

operability of either the steam generator blowdown monitor or condenser air ejector monitor in Modes 1 through 5 and when the pathway is being used in Mode 6. With this proposed license amendment, the operability requirements of Table' 3.3-12 can only be met by the steam generator blowdown monitor. As described above, the proposed license amendment does not constitute an SHC in .

that the change does not involve a significant increase in the probability or '

consequence of an accident previously analyzed, does not create the possibility of a new or different kind of accident, nor does it involve a significant reduction in a margin of safety.

Environmental Consideration NNECO has reviewed the proposed license amendment against the criteria of i 10CFR51.22 for environmental considerations. The proposed changes do not involve an SHC, do not increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, NNECO concludes that the proposed changes meet the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact statement,

[htclear Review Board Review The Millstone Unit No. 2 Nuclear Review Board has reviewed the proposed amendment and has concurred with the above determination.

Proposed Schedule for License Amendment Issuance This request is not necessary for continued plant operation and as such no specific schedule 'for approval and issuance is requested. However, it is appropriate _ that this change become effective within thirty days of issuance of the license amendment.

In accordance-Hith 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.

U.S. Nuclear Regulatory Commission B14405/Page 6 April 22, 1994 Should the NRC Staff have any questions regarding this submittal, please contact Mr. R. H. Young,-Jr. at (203) 665-3717.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY h

'O J. F. Opeka Executive ) President Vice cc: T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 Mr. Kevin T.A. McCarthy, Director Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street P.O. Box 5066 Hartford, Connecticut 06102-5066 Subscribed and sworn to before me thisc 2s2 day of Mi /

, 1994

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Notary P0blic

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Date Commission Expires: ./s2I7//9(o

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