ML20059J356
| ML20059J356 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/05/1993 |
| From: | Calvo J Office of Nuclear Reactor Regulation |
| To: | Opeka J CONNECTICUT YANKEE ATOMIC POWER CO., NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-M87216, NUDOCS 9311120185 | |
| Download: ML20059J356 (5) | |
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UNITED STATES 5
NUCLEAR REGULATORY COMMISSION 3 ( yd r S k
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Docket No. 50-423 N0ED No. 93-6-025 Mr. John F. Opeka Executive Vice President, Nuclear l
Connecticut Yankee Atomic Power Company Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06141-0270
Dear Mr. Opeka:
SUBJECT:
NOTICE OF ENFORCEMENT DISCRETION RELATED 10 THE SUPPLEMENTARY L!
COLLECTION AND RELEASE SYSTEM, AND AUXILIARY BUILDING FILTER SYSTEM LIMITING CONDITIONS OF OPERATION (TAC M87216)
This letter confirms that on November 5,1993, the Nuclear Regulatory Commission (NRC) granted orally Northeast Nuclear Energy Company's (NNECO's) request for enforcement discretion in order to permit Millstone Nuclear Power Station Unit No. 3 to enter Mode 1 (operation above 5% power). The enforcement discretion pertained to the Technical Specifications (TS) i applicable to the supplementary leak collection and release system (SLCRS) and l
the auxiliary building filter system (ABFS) operability requirements, and required compensating reductions in containment leakage rate.
l During testing in September 1993, near the end of a refueling outage, NNECO determined that SLCRS could not meet its TS requirements for operability.
SLCRS and the ABFS, are required to work in unison to allow SLCRS to draw down to 0.25 inches of vacuum on the secondary containment boundary within 1 minute following a design basis accident. Timing delays in the ABFS fan circuitry caused actual drawdown times in the secondary containment in excess of 60 i
seconds in certain system alignments. NNECO undertook extensive j
investigations and t M s to characterize the SLCRS and ABFS systems. Three single failure vulne vilities were identified and subsequently corrected by modifications.
Adjustments in control circuitry timing, and subsequent tests have shown that TS required drawdown times cannot be achieved.
On October 22, 1993, NNECO representatives requested the NRC to exercise its discretion not to enforce compliance with Millstone 3 Technical Specification i
Limiting Conditions of Operation 3.6.6.1 and 3.7.9.
Based on calculations i
that showed minimal accident consequences from low power operation for short periods of time, enforcement discretion was granted on October 25, 1993, to allow Millstone Unit 3 to proceed to Mode 2 for a period not to exceed 7 days following the current refueling outage.
NNECO, by letter dated November 4,1993, proposed a revision to the TS which consolidated submittals dated October 27, 29 and November 3, 1993. The proposed revision extends the required drawdown time of the secondary containment boundary to 120 seconds and increases the required vacuum to 0.4 g
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Mr. John F. Opeka -
November 5,1993 inches as measured at the 24' 6" elevation in the Auxiliary Building, based on a compensating reduction in containment leakage rate to 0.3% per day from 0.65% per day. The November 4, 1993, letter, requested that the NRC exercise its enforcement discretion not to enforce compliance with Millstone 3 Technical Specifications 3.6.6.6.1 and 3.7.9 during the time the proposed TS change was being processed.
Information in support of the proposed TS change had been presented by NNECO in meetings on October 25 and November 3,1993, at NRC headquarters in Rockville, Maryland.
To offset the increase from 60 seconds to 120 seconds in the allowable time to bring the secondary containment to a negative pressure of 0.4 inches rater gauge (w.g.), NNECO chose to decrease the allowable leak rate associated with primary containment from 0.65% per day to 0.3% per day. NNECO has provided test data which shows that the current primary containment leakage rate is well below the proposed limit of 0.3% per day. NNEC0 has also provided the staff with the results of tests that show that the modified system can draw down to the required vacuum within the proposed 120 second drawdown time with a variety of system configurations.
In support of its request to amend its operating license by changing the technical specifications (TS) and to support its request for the NRC to exercise discretionary enforcement until the amendment can be acted upon, NNEC0 presented the results of a revised evaluation of a loss-of-coolant accident (LOCA) at Millstone 3.
NNECO calculated Exclusion Area Boundary (EAB) and the Low Population Zone (LPZ) thyroid doses of 141 rem and 29.8 rem, respectively. The whole body doses at the EAB and LPZ were calculated to be 9.4 rem and 3.5 rem, respectively.
The staff reviewed NNECO's dose calculation parameters and determined that they were reasonable and appropriate. The staff independently calculated LOCA doses and came up with results comparable to those of NNECO.
Both the staff and NNEC0 were able to conclude that the dose reference values in 10 CFR Part 100 were met.
Based upon our review of your justifications identified above, and the remaining supporting material provided in your submittal relative to the justification for this Notice of Enforcement Discretion the staff has concluded that this course of action involves minimum safety impact, and we are satisfied that the exercise of enforcement discretion is warranted from a public health and safety perspective. The staff is planning to issue a license amendment on an exigency basis with a supporting safety evaluation.
The staff is also currently processing a Notice of Consideration of Issuance of the amendment with a proposed No Significant Hazards Consideration Determination and Opportunity for a Hearing in accordance with 10 CFR 50.91(a)(6) and 10 CFR 2.105(a)(4)(ii).
It is our intention to exercise discretion not to enforce compliance with Technical Specification Limiting Conditions of Operation 3.6.6.1 and 3.7.9 commencing November 5, 1993, until the proposed amendment is issued. At this time we are denying your request for Technical Specification 1.12 to be revised to exclude SLCRS operability from the Secondary Containment Boundary definition. During the period of Enforcement Discretion you must observe the reduction in containment leakage rate in proposed TS 3.6.1.2 and the operability requirements of the proposed TS 3.6.6.1 and 3.7.9 submitted with your letter dated November 4,1993.
'Mr. John F. Opeka November 5, 1993 I
Although enforcement discretion is granted to allow Millstone Unit 3 to proceed up to Mode 1 without having to first demonstrate operability according to the existing TS, we will consider enforcement action, as appropriate, for the circumstances that led to the need for this exercise of enforcement discretion.
Sincerely, Original signed by:
Jose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation i
cc:
See next page i
DISTRIBUTION:
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i Mr. John F. Opeka November 3, 1993 L
i Although enforcement discretion is granted to allow Millstone Unit 3 to proceed up to Mode I without having to first demonstrate operability according i
to the existing TS, we will consider enforcement action, as appropriate, for the circumstances that led to the need for this exercise of enforcement discretion.
i sincerely, i
' 4. O j
t ose A. Calvo, Assistant Director for Region I Reactors Division of Reactor Projects - I/II 4
l Office of Nuclear Reactor Regulation cc: See next page i
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Mr. John F. Opeka Millstone Nuclear Power Station Northeast Nuclear Energy Company Unit 3 cc:
Gerald Garfield, Esquire R. M. Katich, Director Day, Berry and Howard Nuclear Licensing Counselors at Law Northeast Utilities Service Company City Place Post Office Box 270 Hartford, Connecticut 06103-3499 Hartford, Connecticut 06141-0270 W. D. Romberg, Vice President J. P. Stetz, Vice President Nuclear Operations Services Haddam Neck Plant Northeast Utilities Service Company Connecticut Yankee Atomic Power Com.nany Post Office Box 270 362 Injun Hollow Road Hartford, Connecticut 06141-0270 East Hampton, Connecticut 06424-3099 Kevin T. A. McCarthy, Director Regional Administrator Monitoring and P.adiation Division Region 1 Department of Environmental Protection U.S. Nuclear Regulatory Commission 79 Elm Street 475 Allendale Road Post Office Box 5066 King of Prussia, Pennsylvania 19406 Hartford, Connecticut 06102-5066 Allan Johanson, Assistant Director First Selectmen Office of Policy and Management Town of Waterford Policy Development and Planning Division Hall of Records 80 Washington Street 200 Boston Post Road Hartford, Connecticut 06106 Waterford, Connecticut 06385 S. E. Scace, Vice President P. D. Swetland, Resident Inspector Millstone Nuclear Power Station Millstone Nuclear Power Station Northeast Nuclear Energy Company c/o U.S. Nuclear Regulatory Commission Post Office Box 128 Post Office Box 513 Waterford, Connecticut 06385 Niantic, Connecticut 06357 F. R. Dacimo, Nuclear Unit Director M. R. Scully, Executive Director Millstone Unit No. 3 Connecticut Municipal Electric Northeast Nuclear Energy Company Energy Cooperative Post Office Box 128 30 Stott Avenue Waterford, Connecticut 06385 Norwich, Connecticut 06360 Burlington Electric Department David W. Graham c/o Robert E. Fletcher, Esq.
Fuel Supply Planning Manager 271 South Union Street Massachusetts Municipal Wholesale Burlington, Vermont 05402 Electric Company Post Office Box 426 Nicholas S. Reynolds Ludlow, Massachusetts 01056 Winston & Strawn 1400 L Street, NW J. M. Solymossy, Director Washington, DC 20005-3502 Nuclear Quality and Assessment Services Northeast Utilities Service Company Post Office Box 270 Hartford, Connecticut 06141-0270
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