ML20055E053
| ML20055E053 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/29/1990 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20055E054 | List: |
| References | |
| B13558, NUDOCS 9007100321 | |
| Download: ML20055E053 (4) | |
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I General Othces o Seloon Street, Serhn, Cinnecticut l
RTFOR CONNECTICUT 061410270
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i June 29, 1990 Docket No. 50-423 B13558 i
Re:
10CFR50.90 J
l U.S. Nuclear Regulatory Commission I
Attention:
Document Control Desk Washington, DC 20555.
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Gentlemen:
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' Millstone Nuclear Power Station, Unit No. 3 Proposed Revision-to Technical Specifications j
~ Reactor Coolant Soecific Activity 1
Pursuant 'to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License NPF 49 by incorporating the changes-identified in Attachment 1 into the Technical Specifications of Hillstone Unit j
No. 3.
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Discussion
- As per the Millstone Unit No. 3 Technical Specification Section 4.4.8, a
radiochemical analysis for E determination is required to be performed every six months with the unit operating in MODE 1.
The E sample is a measurement of the specific activity of all the isotopes in the reactor coolant that have half lives that are greater than 10 minutes.
The E sample is used to limit i
the activity of the reactor coolant which.is not allowed to exceed-the 100/E limit.
By limiting coolant activity, the exposure that' an individual would Jreceive if a release were made to the environment is in turn decreased.
To assure equilibrium conditions at the time the sample is drawn, this surveil-lance must be performed after a minimum of 2 effective full-power days (EFPD) and 20 days of POWER OPERATION -(MODE 1) have elapsed since the reactor was last subcritical for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
These requirements for the E determination directly relate to the limiting condition for operation (LCO) and are required to verify unit operation within the specified LCO limits.
On January'18, 1990, NNECO discovered that the surveillance that requires E be measured once every 6 months.per(3)echnical Specification Section 4.4.8 had not T
been met.
On. January 18, 1990, NNEC0 requested NRC Enforcement Discretion (1)
C.
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Clement letter to W.
T.
- Russell, Request for Enforcement Discretion, dated January 18, 1990.
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t U.S. Nuclear Regulatory Commission B13558/Page 2 June 29, 1990 to the requirements of Specification 4.0.4 to allow start up of Millstone Unit No. 3 from MODE 3 in order to take a reactor coolant sample to satisfy the requirement for the E determination.
After review of NNECO's reasons discussed in our letter dated January 18,(2L990, the NRC, first verbally and then by a letter dated January 21, 1990,
- granted a one-time relief from Technical Specification 4.0.4, regarding completion of surveillance require-ments per Section 4.4.8 3rior to plant start-up.
This one-time relief allowed restart of Millstone Un't No. 3 to allow taking a reactor coolant sample to satisfy the E determination.
While reviewing Technical Specification 4.4.8, NNECO has identified an area j
where the specification may be improved.
The proposed change contained herein-t is one example that will add an exception from the requirements of Technical Specification 4.0.4 for performing the E surveillance prior to entry into MODE 1.
Technical Specification 4.0.4 prevents entry into an operational mode unless the surveillance requirements associated with the LCO have been per-formed within the required surveillance interval.
This change ensures that the plant would be able to enter into MODE 1, if it was returning to. power beyond the 6-month surveillance interval specified (e.g.,
extended outage greater than 6 months), at which point the surveillance could be performed.
Sianificant Hazards Consideration NNECO has reviewed the proposed change in accordance with 100FR50.92 and has
'3 concluded that the change does not involve a significant hazards considera-tion.
The basis for this conclusion is that the three criteria of 10CFRSO.92(c) are not compromised.
The proposed change does not invcive a significant hazards consideration because the change would not:
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Involve a significant increase in the probability or consequences of an E
accident previously analyzed.
The proposed change to the E surveillance addresses a situation that woulc prevent entrance into MODE 1.
Sampling can only be performed at power as stated in the footnote.
An exception to Specification 4.0.4 is necessary to allow changing from MODE 2 to MODE 1.
This does not change the allowable reactor coolant radioactivity limit and, therefore, does not affect the radiological calculations and will still ensure that the off site dose following a steam generator tube rupture will not exceed a small fraction of 10CFR100 limits.
It does not reduce the frequency requirements for analysis of reactor coolant for gross activity, and therefore it does not decrease the confidence that the reactor coolant l
r (2)
W. T. Russell letter to E. J. Mroczka, Enforcement Discretion Regarding Reactor Coolant System Chemistry Measurements and Plant Startup, dated January 21, 1990.
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f U.S. Nuclear Regulatory Commission B13558/Page 3 June 29, 1990 activity is within the specification.
For these reasons, the proposed change does not increase the probability or consequences of any accident previously analyzed.
2.
Create the possibility of a new or different kind of accident from that previously analyzed.
The proposed change to the I surveillance requirement alleviates a situation that would prevent entry into MODE 1.
There are no changes in the way the plant is operated or in the operation of equipment credited in the design basis accidents.
Therefore, the potential for an unana-lyzed accident is not created.
3.
Involve a significant reduction in the margin of safety.
The intent of the Technical Specification for the proposed change remains unchanged.
The proposed change will not impact any protective boundary and does not affect the consequences of an accident previously analyzed.
Therefore, there is no reduction in the margin of safety.
Moreover, the Commission has provided guidance concerning the application of
. standards in 10CFR50.92 by providing certain examples (March 6,
- 1986, 51FR7751) of amendments that are considered not likely to involve a signifi-cant hazards consideration.
Although the proposed change is not enveloped by a specific example, the proposed change would not involve a significant increase in the probability or consequences of an accident previously ana-lyzed. As stated earlier, the proposed change to the E surveillance require-ment alleviates a situation that would prevent entry into MODE 1.
The intent of the, Technical Specification remains the same by performing the sampling after a minimum of 2 EFPD and 20 days of POWER OPERATION have elapsed.
The proposed changes does not affect the radiological dose calculations or the confidence that coolant activity is within specifications.
Based upon the information contained in this submittal and the environmental assessment for Millstone Unit No. 3, there are no radiological or-nonradio-logical impacts associated with the proposed change, and the proposed license amendment will not have a significant effect on the quality of the human environment.
The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved the attached proposed revision and has concurred with the above determinations.
In accordance with 10CFR50.91(b), NNECO is providing the State of Connecticut with a copy of this proposed amendment.
Regarding our proposed schedule for this amendment, we request issuance at your earliest convenience with the amendment effective within 30 days upon issuance.
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i U.S. Nuclear Regulatory Commission i
B13558/Page 4 June 29, 1990 Should you have any questions regarding the attached amendment request, please contact our licensing representative directly.
Very truly yours, l
NORTHEAST NUCLEAR ENERGY COMPANY 1
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FOR: E. J. Mroczka i
Se i r'Vice President BY:
C*A C. F. Sears i
Vice President J
cc: Mr. Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection
-J Hartford, CT 06116 i
T. T. Martin, Region I Administrator J
D. H. Jaffe, NRC Project Manager, Millstone Unit No. 3 J
W. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 STATE OF CONNECTICUT)) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, C. F. Sears, who being duly sworn, did J
state that he is Vice - President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing 1
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 his knowledge and belief.
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