ML20046C424

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Discusses Proposed Rev to TS Re Addition of Requirement 4.8.1.1.2.C.8,items A,B, & C, to EDG Surveillance Requirements Section to TS Section 3/4.8, Electrical Power Sys
ML20046C424
Person / Time
Site: Millstone Dominion icon.png
Issue date: 08/04/1993
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20046C425 List:
References
B14562, NUDOCS 9308110016
Download: ML20046C424 (4)


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August 4, 1993 Docket No. 50-336 B14562 t

Re:

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

Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specification Electrical Power Systems In a letter dated October 28, 1992,"' Northeast Nuclear Energy Compa'ny (NNECO) proposed to amend Operating License DPR-65 for Millstone Unit No. 2 as a result of plant design change modifications performed in response to main steam line break (MSLB) reanalysis.

One of the modifications involved the addition of an emergency _ diesel generator - (EDG) start signal upon the receipt of a safety injection actuation signal (SIAS) without loss of offsite power. During their technical review of that amendment, the NRC Staff requested additional information to which NNECO responded with telephone conferences and written followup submittals. As part of their technical review, the Staff also requested 4

that NNECO perform an additional EDG start on SIAS refueling outage surveillance beyond that to which the unit was originally licensed.

After discussion and evaluation, in a letter dated December 4,1992,i2' NNECO committed to submit a license amendment (worded similarly to that requested by the Staff) several months following startup from the refueling outage then in progress. Subsequent 1

discussions with the NRC Staff resultea in a mutually acceptable revised submittal schedule.

Accordingly, NNEC0 hereby proposes to amend Operating License DPR-65 by incorporating the attached proposed change into the Technical Specifications of Millstone Unit No. 2, as previously committed.

(1)

J. F. Opeka letter to U.S. Nuclear Regulatory Commission, " Millstone Nuclear Power Station, Unit No. 2 Proposed Revisions to Technical i

Specifications Main Steam Line Break Design Limits," dated October 28, 1992.

(2)

J. F. Opeka letter to U.S. Nuclear Regulatory Commission, " Millstone Nuclear Power. Station, Unit No. 2 Proposed Revision to Technical Specifications Main Steam Line Break Design Limits Response to Request for Additional Information," dated December 4,-1992.-

hI'f nnann oma ncva-as 9308110016 930804 PDR ADOCK 05000336 h-P; PDR

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U.S. Nuclear Regulatory Commission B14562/Page 2 August 4, 1993 Description of the Procosed Chanaes The proposed changes will include the addition of requirement 4.8.1.1.2.C.8, I

items a, b, and c, to the Emergency Diesel Generator Surveillance Requirements section to the Technical Specification Section 3/4.8, " Electrical Power Systems."

The requirements to be added are as follows:

8.

Verifying that on an actual or simulated Safety Injection Actuation Signal (SIAS) without a loss of offsite power:

a.

The diesel generator starts on the auto-start signal and operates on Standby for greater than 5 minutes; b.

The generator frequency and voltage shall reach 58.8 to 61.2 Hertz, and 3740 to 4580 VAC, and be maintained during this test; c.

The diesel start time (time to reach 90% of rated speed and l

97% of rated voltage) shall be less than or. equal to 15 i

seconds. indicates the current technical specification with the proposed change noted. Attachment 2 provides the proposed revision replacement page to the technical specification.

Safety Assessment This proposed amendment is an improvement and generally conforms with the respective section of the Standard Technical Specification (STS) requirements, as endorsed by the NRC. The voltage and frequency limits are identical to the STS limits, and the EDG start time is based upon the existing technical t

specification definition-required start time. Verification of this SIAS start feature will additionally ensure that the EDG is capable of starting as a result t

of an accident ~ without loss of offsite power and conforms with the practices of other similar plants. Since this surveillance is proposed to be performed on an eighteen-month basis, the additional fast-start test requirements associated with this change are minimal, and are within the design capability of the EDG. Based

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on this, and the significant hazards considerations (SHC) discussion below, the j

proposed license amendment is considered safe and technical _ly acceptable.

Sianificant Hazards Consideration

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In accordance with 10CFR50.92, NNEC0 has reviewed the proposed change and concluded that it does not involve a significant hazards consideration.

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U.S. Nuclear Regulatory Commission B14562/Page 3 August 4, 1993 basis for this conclusion is that the three criteria of 10CFR50.92(c) are not l

compromised.

The proposed change does not involve an SHC because the change would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated.

Durina the conduct of the proposed surveillance, the diesel will run on standby for at least five minutes.

The determination from. the diesel manufacturer is that fuel oil fouling of the exhaust would not occur under these conditions.

This change is simply an additional surveillance to demonstrate operability (starting) of the EDG, with offsite power available, as a result of an SIAS signal, therefore it 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 than any previously evaluated.

Testing of the EDG is normally performed in the same manner as is being proposed in this license amendment; the only difference is the source of the start signal. This additional surveillance requirement is a routine requirement for some other plants and is included as part of STS.

Accordingly, the change does not create the' possibility of a new or different kind of accident than any previously evaluated.

3.

Involve a significant reduction in a margin of safety.

The proposed testing of the EDG will provide additional assurance of reliability to maintain the present margin of. safety. Since this proposed license amendment will add a surveillance beyond that currently existing, it would likely add to the margin of safety.

Moreover, the Commission has provided guidance concerning the application of I

standards set forth in 10CFR50.92 by providing certain examples (March 6,1986, 51FR7751) of amendments that are considered not likely to involve an SHC. The proposed change to Section 4.8.1.1.2.C. is enveloped by example (ii); a change that constitutes an additional limitation, restriction, or control not presently included in the technical specification. Therefore, the proposed change will not involve a significant increase in the probability or consequences of an accident previously analyzed.

Environmental Consideration NNECO has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations.

The proposed change does not increase the types' and amounts of effluents.that may be released off site, nor significantly increase individual or cumulative occupational radiation expnsures.

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- - U.S. Nuclear Regulatory Commission B14562/Page 4 August 4, 1993 Based on the foregoing, NNECO concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an environmental impact statement.

I Conclusion The Millstone Unit No. 2 Plant Operations Review Committee and the Nuclear Review 1

Board have reviewed and approved the proposed change and have concurred with the above determination tcat the proposed license amendment described in this submittal involves no significant hazards consideration.

In accordance with 10CFr.60.91(b), we are providing the State of Connecticut with a copy of this pre;;osed amendment to ensure their awareness of this request.

3 Regarding our schedule for this amendment, we request issuance at your convenience with the amendment effective within 30 days of issuance.

If you have any questions regarding this amendment, please contact us.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY k FM l

J. F. Dpeka u

Executive Vice President cc:

T. T. Martin, Region I Administrator I

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 McCarthy, Director, Radiation Control Unit, Department of Environmental Protection, Hartford, CT 06116 Subscribed and sworn to before me this N day of Oru ual, 1993 MM

/K. O$ttC W l

Notary Public l

[U h Date Commission Expires:

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