ML20055F322

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Application for Amend to License DPR-61,revising Tech Specs Sections 3.4.6.2.f,4.4.6.2.1.g & 4.4.6.2.1.h Re RCS Leakage & Low Temp Overpressurization Protection Sys Bases.No Radiological or Nonradiological Impact Associated W/Changes
ML20055F322
Person / Time
Site: Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 07/05/1990
From: Mroczka E
CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST UTILITIES
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20055F323 List:
References
B13570, NUDOCS 9007160274
Download: ML20055F322 (6)
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Text

7 4

Gener:I Others

  • Selden Street, Berlin, Connecticut ATO ONNECTICUmm.0270 July 5,1990 Docket No. 50-213 B13570 Re:

10CFR50.90 U.S. Nuclear Regulatory Commission Attention: Document Control Desk l

Washington, DC 20555

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l Gentlemen:

Haddam Neck Plant Proposed Revision to Technical S)ecifications Reactor Coolant System Lea cage, and Low Temperature Overpressurization J

Protection Systems Bases i

Pursuant to 10CFR50.90, Connecticut Yankee Atomic Power Company CYAPCO) hereby proposes to amend operating license DPR 61 by incorporating the(changes l identified in Attachment 1 into the Technical Specifications of the Haddam Neck Plant, j

Discussion Reactor Coolant System

Leakage, Sections 3.4.6.2.f.

4.4.6.2.1.g and 4.4.6.2.1.h l

.l The proposed change to the Haddam Neck Plant Technical Specifications Section 3.4.6.2.f is a rewo'rding of the specification to better define which sections of piping need to be included under surveillance 4.4.6.2.1.g.

The change to Section 4.4.6.2.1.g removes the requirement to perform a monthly I

pressure test on portions of HPSI, Charging and RHR suction piping which would l

be used for or pressurized during containment recirculation.

Performance of this test during normal operation, for certain sections of piping, is either not' possible due to physical or operational constraints (Charging and RHR suction piping) or would require the removal of both trains of safety related equipment from service during testing (HPSI suction piping).

The aroposed change would be in keeping with safety and the desire to maintain h gh ECCS availability.

These sections of piping will be tested pursuant to Technical Specification 4.0.5 and the Haddam Neck Plant Inservice Test (IST) program, j

'The change to Section 4i4.6.2.19 also permits entrv into MODE 4 prior to performing the leakage surveillance.

Specificatic; 4.0.4 requires that all applicable surveillances be performed prior ta entry into the plant mode for which an LCO is applicable (for this case, MODE 4).

However, Specification 3.5.2.a requires that both HPSI pumps be inoperable whenever LTOP is required ODTRn g71g2g4 g

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U.S. Nuclear Regulatory Commission i

B13570/Page 2 July 5, 1990 i

i to be operable (MODE 4 with RCS temperature less than or equal to 315'F and MODES 5 or 6 with the RCS not vented, per Specification 3.4.9.3).

Because of these conflicting requirements, the plant would be required to be placed in MODE 5 with the RCS vented to perform the HPSI discharge piping leakage surveillance prior to startup from a shutdown (MODES 4, 5, or 6) if Surveillance 4.4.6.2.1.g has not been performed in the previous 31 days. This change provides a window at the upper end of MODE 4 (RCS temperature between 315 and 350*F) to perform HPSI discharge piping leakage testing.

The note at the end of Surveillance 4.4.6.2.1.h, which permits transition into MODES 3 and 4 prior to completion of surveillances, has also been modified to state that this note a) plies to item "h" only and not the entire surveillance.

The applicability of t11s note has resulted in some confusion.

Low Temoerature Overoressurization Protection Systems Bases-Section 3/4.4.9

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This change to the Bases describes the requirement to lock out one centrifugal charging pump and both HPSI pumps in MODES 4, 5, and 6 with the reactor vessel head installed to preclude mass and heat inputs more severe than those assumed in the safety analysis. The requirement to disable the above pumps is already included in Specification 3.5.2.a.

The change therefore has no safety impact and is being made for the purpose of making the discussion in Bases 3/4.4.9 consistent with Technical Specification 3.5.2.a.

Sionificant Hazards Consideration CYAPC0 has reviewed the proposed changes in accordance with 10CrR50.92 and has concluded that the changes do not involve a significant ha ards consideration.

The basis for this conclusion is that the three criteri. of 10CFR50.92(c) are not compromised.

The proposed changes do not invol';e a significant hazards consideration because the changes would not:

1.

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

The proposed change to Section 3.4.6.2.f is a minor rewording of the specification to better define which sections of piping need to be included under Surveillance 4.4,6.2.1.g.

There are no failure modes associated with the proposed change nor are any design basis accidents i

impacted by the change.

The proposed changes to Section 4.4.6.2.1.g remove the requirement to perform a monthly pressure test on portions of HPSI, Charging and RHR suction piping which would be used for or pressurized during containment i

recirculation and permits entry into MODE 4 prior to performing the leakage surveillance.

)

4 U.S. Nuclear Regulatory Commission B13570/Page 3 July 5, 1990 The piping which cannot be tested during normal operation is all 150# and 600# class piping and will be exposed to relatively low post accident recirculation pressure.

The HPSI and charging suction piping would be exposed to the post accident RHR pump disenarge pressure while the RHR pump suction piping would be exposed to pressure associated with the post i

accident containment internal pressure.

4 The HPSI and RHR suction piping (downstream of RH MOV 22) is always full d

and under hydrostatic pressure from the RWST (approximately 15 psig for HPSI and 25 psig for RHR).

Technical Specification 4.4.6.2.1.f, which j

requires that this piping be monitored for leakage at least once per i

twelve hours, provides additional assurance that there is no gross l

1eakage associated with this piping between pressure tests.

i The charging suction header is also always full and under the hydrostatic pressure from the VCT (approximately 10 psig) plus a 25 to 50 psig gas overpressure in the VCT.

This piping is also subject to leakage monitor-1 ing at least once per twelve hours per the requirement of Technical Specification 4.4.6.2.1.f which provides additional assurance that there is no gross leakage in this piping.

Westinghouse Standard Technir41 Specification 3/4.4.6g--Operational Leakage has been reviewed and does not contain any requirements for ECCS

' leakage outside of cortsinment or any requirements for monthly pressure testing of ECCS piping.

This Haddam Neck Plant Technical Specification therefore exceeds the Westinghouse STS guidelines.

The change to Section 4.4.6.2.1.g also permits entry into MODE 4 prior to performing the leakage surveillance.

Specification 4.0.4 requires that all applicable surveillances be performed prior to entry into the plant mode for which an LCO is applicable (i.e.,

in this case, MODE 4).

However, Specification 3.5.2.a requires that both HPSI pumps be inoper-able whenever LTOP is required (Mode 4 with RCS temperature less than or equal to 315'F and Modes 5 or 6 with the RCS not vented, per Specifica-tion 3.4.9.3).

Because of these conflicting requirements, the plant would be required to be placed in Mode 5 with the RCS vented to perform the HPSI discharge piping leakage surveillance prior to startup froin a shutdown (Modes 4, 5, or 6) if Surveillance 4.4.6.2.1.g has not been performed in the previous 31 days.

This change provides a window at the upper end of Mode 4 (RCS tem)erature between 315 and 350*F) to perform HPSI discharge piping lea (age testing.

There are no technical specification requirements for HPSI pump operability or inoperability while operating in this tempera-ture band.

The note at the end of Surveillance 4.4.6.2.1.h, which permits transition into Modes 3 and 4 prior to completion of surveillances, has also been j

modified to state that this note applies to item h only and not the i

U.S. Nuclear Regulatory Commission B13570/Page 4 July 5, 1990 entire specification.

The applicability of this note has resulted in some confusion. This change has no negative safety significance since it is editorial and eliminates the potential misapplication of a specifica-tion.

The change to Section 3/4.4.9--Low Temperature Overpressurization Protec-tion System Bases has no safety impact since it is being made to be consistent with Technical Spuification 3.5.2.a which requires that one centrifugal charging and no HPSI pumps shall be operable whenever the LTOP system is required.

For these reasons, the proposed changes do 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 rewording of Section 3.4.6.2.f allows it to be consistent with surveillance 4.4.6.2.1.g by better defining the portions of piping tested.

The exception to Specification 4.0.4 in surveillance 4.4.6.2.1.g allevi-ates a conflict with specification 3.5.2.a.

The change to the note in surveillance 4.4.6.2.1.h clarifies that the note only pertains to item h.

This will mitigate the confusion over application of the exception.

The requirement to lock out one centrifugal charging pump and both HPSI pumps is being made for the purpose of making the discussion in Bases 3/4.4.9 consistent with Technical Specification 3.5.2.

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 unanalyzed accident is not created.

3.

Involve a significant reduction in the margin of safety.

The intent of the Technical Specifications for all changes remains unchanged.

The change to Section 4.4.6.2.1.g prevents the removal of portions of the ECCS during plant operation.

This proposed change maintains high ECCS availability.

The change to Specification 4.4.6.2.1.g and h permits entry into MODE 4 prior to performing the leakage surveillance.

This prevents the plant from going to MODE 5 to perform the surveillance.

The changes to the Bases are editorial. in nature. The proposed changes will not impact any protective boundary and do not affect the consequences of any accident previously analyzed.

Therefore, there is no reduction in the margin of safety, i

a l

U.S. Nuclear Regulatory Commission B13570/Page 5 July 5,1990 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

significant hazards consideration.

The proposed change to Bases Section 3/4.4.9 is enveloped by example (i), a purely administrative change to techni-cal specifications.

This change is being made for the purpose of making the discussion in Bases 3/4.4.9 consistent with Technical Specification 3.5.2.a.

Although the proposed changes to Section S.4.6.2,f, 4.4.6.2.1.g and 4.4.6.2.1.h are not enveloped by a specific example the changes will not involve a significant hazards consideration because they do not involve a significant increase in the probability or consequences of an accident previously. analyzed, create the possibility of a new or different kind of accident from that previously analyzed, or involve a significant reduction in the margin of safety.

Based upon the information contained in this submittal and the environmental assessment for the Haddam Neck Plant, there are no radiological or nonradio-logical-impacts associated with the proposed changes and the proposed license amendment will not have a significant effect on the quality of the human environment.

The Haddam Neck Plant Nuclear Review Board has reviewed and approved the attached proposed changes and has concurred with the above determinations.

In accordance with 10CFR 50.91(b) we are providing the State of Connecticut with a copy of this proposed amendment.

Regarding our proposed schedule for this amendment, we request issuance by August 14, 1990 to support continued operation, with the amendment effective within 30 days upon issuance.

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Should the Staff have any additional questions, please contact my staff directly.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY N

<1/

E. J. Voczka

(/

Senior Vice President

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i U.S. Nuclear Regulatory Commission B13570/Page 6 July 5, 1990 cc:

T. T. Martin, Region I Administrator A. B. Wang, NRC Project Manager, Haddam Neck Plant J. T. Shediosky, Senior Resident Inspector, Haddam Neck Plant Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 STATE OF CONNECTICUT ss. Berlin COUNTY OF HARTFORD Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior Vice President of Connecticut Yankee Atomic Power Company, a Licensee herein, that he is authorized to execute and file the foregoing information-in the name and on behalf of the Licensee herein, and that tha statements contained in said information are true and correct to the best of his knowledge and belief, wu wh MyCommission s#ic

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ittary P pires March 31,1993 1

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