ML20044A706

Application for Amend to License DPR-65,changing Definition for Core Alteration in Section 1.12 to Clarify Scope of Movement or Manipulation During Core Alteration,Per C-E STS

ML20044A706
Person / Time
Site:	Millstone
Issue date:	06/26/1990
From:	Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044A707	List: ML20044A706 ML20044A708
References
B13551, NUDOCS 9007020108
Download: ML20044A706 (4)

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$s" FORD. CONNECTICUT o61'41027o (2on 665 m m June 26, 1990' Docket No. 50-336 .i' B13551

.Re: 10CFR50.90. q U.S. Nuclear Regulatory Commission Attention:: Document Control Desk Washington, DC 20555 '

Gentlemen: . j Millstone Nuclear- Power / Station, Unit No.!2 '

Proposed Change to Technical Specifications Definition of Core Alteration Pursuant to 10CFR50.90, Nurtheast Nuclear- Energy Company'(NNECO)'hereby.

proposes to amend its Operating License .No. OPR.65 by incorporating the "

changes identified in Attachment l~ into the . Technical . Specifications > of +

Millstone Unit No. 2. This letter supersedes in its :ent <

request for a license amendment change dated April 10,1990.gty- Thisa previous revised submittal was prompted by recent communications with the - NRC. Staf f, as a. ,

result of the Staff's review of our April. 10, 1990,. letter. It was requested that NNEC0's definition of CORE ALTERATION be consistent with the Combustion Engineering Owners Group proposed definition developed as a result of the I Revised Standard Technical Specifications efforts..

Specifically, the proposed change will change the definition for Core Altera-tion-in Section 1.12 to clarify the scope of the movement or manipulation of a:

component during core alteration. The proposed definition reads as follows:

" CORE ALTERATION shall be the movement of any: fuel, sources, . reactivity control components, or other components significantly. affecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel.

Suspension of CORE ALTERATIONS shall not preclude completion of movement of a.  !

component to a safe position." This definit'lon is consistent with the Revised Standard Technical Specifications developed by the_ Combustion Engineering Owners Group currently under review by the NRC Staff.

(1) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit No. 2, Proposed Change to Technical Specifications, Definition of Core Alteration," dated April 10, 1990- .

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U.S. Nuclear Regulatory Commission B13551/Page 2 June 26, 1990 Backaround in a' letter to the NRC Staff dated April 3,1989,(2) .NNECO proposed to submit-a license amendment change which would clarify what ;onstitutes a core altera-

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tion.- The necd' for this license amendment was prompted by events during the ,

end of Cycle 9 refueling ' outage for Millstone Unit No. 2. Specifically, one ,

of the tasks performed routinely at each refueling outage is the replacement

.of a portion (approximately half) of the in-core instrumentation (101) detec-l tors. The procedures for this task are well established and were being l implemented by plant personnel to change out 23 'of the 46 in-core detectors.

During the performance of this task, it was noted that a' senior reactor operator (SRO) was not present, in apparent conflict with.the requirements of Technical Specification 6.2,2.e. The purpose of the April 1989 letter was to document NNECO's rationale in not assigning an SR0 to be present during the replacement of the in core detectors. Specifically, our interpretation was that the replacement of in-core detectors did not constitute a " Core Altera-tion" because it has a negligible effect on core reactivity and does not pose a threat to damaging the fuel which could result in a radioactive release.

In a letter dated May 4,1989,(3) the NRC Staff acknowledged NNEC0's- position on this issue but stated the literal interpretation'of Millstone Unit No. 2's i

Technical Specifications would-include in core detector replacement as a " Core Alteration." The NRC Staff noted that this issue would remain unresolved until the Technical Specifications' were changed ts be more specific. The attached proposed Technical Specification's' change. serves to provide that clarification such that ICI removal is not considered.a core alteration.

Stanificant Hazards Consideration i NNEC0 has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that they do not involve a significant hazards consideration in that these changes would not:

1. Involve a significant increase in the probability of - occurrence or

-consequences of an accident previously analyzed.- The- new definition of

! " Core Alteration" will continue to ensure that positive reactivity changes cannot occur while core alteration is suspended. There are no design basis accidents adversely affected due to the changes.

The reactivity effects caused by the insertion and removal of the ICI and ICI thimble tubes into the core are negligible. The ICI thimble tubes are made of zircaloy, and their removal . or insertion will - have an l

(2) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission, " Millstone Nuc' lear Power Station, Unit No. 2, Replacement of In-Core Detectors,"

dated April 3, 1989.

(3) J. P. Durr l t. .t e r to E. J. Mroczka, " Millstone 2 Resident Inspection 50-336/89-05 (2/11/89-3/23/89)," dated May 4, 1989.

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• U.S. Nuclear Regulatory Commission B13551/Page 3 June 26, 1990 insignificant effect on the core reactivity. Therefore, the movement -of the ICI plate and removal and installation of ICis will have no notice-able positive reactivity addition to the core.

2. Create the possibility of a new or different kind of accident from any previously analyzed. Since there are no changes in the way the plant-is operated, the potential for an' unanalyzed accident is 'not created, No-new failure modes are introduced.

3. Involve a significant reduction in a margin of safety. Since the changes  !

do not affect the consequences of any accident previou' sly analyzed,-there is no reduction in a margin of' safety.

The Commission has provided guidance concerning the application of Standards .,

in - 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986) of amendments that are considered not likely' to involve. af significant hazards consideration. Although the changes proposed herein are not enveloped by a specific example, this proposed change is intended to clarify. only the scope:

of the movement or manipulation of a component during core alteration.

The Millstone Unit No. 2 Nuclear Review Board has reviewed and approved the attached proposed revision and has~ concurred with-the above determinations.

NNECO respectfully requests that this proposed change be issued. prior to the start of the next refueling outage currently planned for September 1990 to avoid a similar situation as noted above. NNEC0' also requests this license amendment be effective as of the date of its issuance, to be implemented within 30 days of issuance.

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

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Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY

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Senior Vice President ,

cc: Mr. Kevin McCarthy, Director i Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 T. T. Martin, Region I Administrator

-G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 5

F ld U.S. Nuclear Regulatory Commission B13551/Page 4 June 26, 1990 STATEOFCONNECTICUT)

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Then personally appeared before me, E. J.. Mroczka, who being duly sworn, did i state that he is Senior- Vice President of Northeast Nuclear Energy- Company,. a -1 Licensee herein, that- he is authorized to execute and file the foregoing j information in the name and on behalf of the Licensee herein, and that the statements contained in said information are true and correct to the best of' I his knowledge and belief, j

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