ML20062F351
| ML20062F351 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/09/1990 |
| From: | Mroczka E, Sears C NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20062F354 | List: |
| References | |
| B13557, NUDOCS 9011270231 | |
| Download: ML20062F351 (4) | |
Text
'
s
.s General Offices
- Selden Street. Berlin, Co,necticut 9
U U.NE,$e*cIduTa~
P.O. BOX 270 a um.m mi. t"*
HARTFORD. CONNECTICUT 061410270 i
j.
L L
J [Z[ET,%,[
(203) 665-5000
=
November 9,-1990 Docket No. 50-336 B13557 Re:
U.S. Nuclear Regulatory Commission i
Attention: Document Control Desk i
Washington, DC 20555 G6ntlemen:
Millstone Nuclear Power Station, Unit No. 2 Proposed-Change to Technical Specifications Surveillance Frecuency Pursuant to 10CFR50.90, Northeast. Nuclear Energy - Company (NNECO)-hereby proposes to amend its Operating License No. DPR-65 by incorporating the-changes-identified in Attachment 1 into the Technical Specifications of-Millstone. Unit No. 2.
Descriotion of the Proposed Chanae The proposed change. would revise a surveillance requirement in Technical Specification 4.0.2 by deleting the requirement that the combined time inter-val for any three consecutive surveillance intervals is. not ~ to exceed 3,25 times the specific surveillance interval.
The revised Technical Specifi-cation 4.0.2 would require that "each Surveillance ' Requirement -shall be, per-formed within the specified time: interval with a maximum allowable extension not to exceed 25% of the surveillance time interval'." ' The : associated bases -
l section is being revised to reflect the proposed change.,
Backaround 0'n August 21, 1989,II)-'the NRC ' issued Generic Letter: 89-14 which provided guidance to licensees for the preparation of license amendment requestsi.to implement a -line item improvement in the Technical Specifications to: remove the 3.25 limit on extending surveillance intervals.
The generic; letter provided an alternative to the requirements of Technical Specification 4.0.2
--to remove an unnecessary restriction on extendingt surveillance s requirements-and'to provide a benefit to safety when plant conditions are not conducive to (1)- J. G. Partlow letter to All Licensees, "Line-Item Improvements in
, Technical
-Specifications-Removal of the 3.25 Limit on Extending Surveillance Intervals -(Generic Letter 89-14)," dated: August 21, 1989.
9011270231 9o1109 90 0,3 s e m e pr<
ock *
- gg!6
4 U.S. Nuclear Regulatory Commission B13557/Page 2 i
November 9, 1990 1
the safe conduct-of surveillance requirements.
A lead plant proposal was i
submitted by Commonwealth Edison for the LaSalle Nuclear Power Station to modify the 3.25 limitation' on extending surveillance intervals.
Based _ upon the review of the Commonwealth Edison ' proposal, -the NRC Staff concluded that the removal of the 3.25 limit from Specification 4.0.2 results -in a greater benefit to safety than limiting the use of the 25-percent allowance to extend.
surveillance interval s.
The proposed change to the Millstone Unit No. 2 Technical Specifications is consistent with-the recommendations of Generic-Letter 89-14.
Sionificant Hazards Consideration 1
NNEC0 has reviewed the proposed change in -accordance with 10CFR50.92 and has -
l concluded-that the change does not involve a -significant hazards considera-tion.
The. basis for this conclusion is that the three criteria of i
10CFR50.92(c) are not compromised.
The proposed change. does not involve a significant hazards consideration because the change would not:
1.
Involve a significant increase in the. probability or consequences of an accident previously analyzed.
The ; proposed change would remove the 3,25 limit on extending surveillance intervals in accordance with the guidance contained in Generic Letter'89-14.
-This change 5would not involve any change to the actual surveillance requirements other than a small increase in the mavimum allowable average -surveillance -interval.
-l The increase in-the probability of failure of components and systems that
]
would result from longer average surveillance' intervals are within the range of expected variations in the' calculated failure probabilities associated 'with' the anticipated changes in plant' configuration during normal operation and would not significantly --impact the. probability of any accident.
The reliability ensured throuah. surveillance activities following the proposed change would not be: sisaificantly' degraded beyond i
that obtained from surveillance performed within the:3;25' limit.
There-fore, this change would not significantly increase the probability of occurrence or the consequences of an accident previously:. evaluated.
2.
Create the possibility of a -new or different kind of ' accidentfrom any areviously evaluated.
The proposed change would not alter the method of tperating the plant or change the way the surveillancei requirement is pirformed. The proposed change would allow a surveillance interval to be e> tended at a time that conditions are not suitable for performing the surveillance.
No new failure modes are introduced.
Therefore, tnis change would have no effect on the possibility' of creating a new or different kind of accident from any accident previously evaluated..
l 3.
Involve a significant reduction in.the margin _ of safety.-
The change would not have a significant impact on the consequences of an accident or on any of the protective boundaries.
This change would not involvo any change to-the actual surveillance requirements other than frequency..The reliability ensured through surveillance activities-would ' not ' be -
o
i U.S. Nuclear Regulatory Commission 813557/Page 3 November 9, 1990 significantly degraded beyond that obtained from the specified. surveil-lance interval.-
Therefore, it is' concluded hat operation of the t
facility in accordance with the proposed change would not involve-a significant reduction in the margin of safety, j
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 haz)ards 1
consideration.
Although-the proposed change: is not enveloped; by a specific 1
example, the change would not involve a significant increase in the prc.ba -
j bility or consequences of an accident previously. analyzed. The small increase in the probability of failure of components and systems:that would result from -
longer average surveillance-intervals are within the range of expected varia-tions in-the calculated failure probabilities associated with: anticipated changes in plant configurations during normal operation and would not signifi-j cantly impact the probability of any-accident.
The. proposed change would remove an unnecessary restriction on extending surveillance requirements.
It would result 'in a benefit to safety. for those instances where surveillances would not ce required to be-performed at times when plant conditions _ are'not conducive i.o the safe conduct of that particular surveillance-(e.g., transient plant operating conditions or other ongoing surveillance or-maintenance activities).
Removal of the 3.25 limit would al.o eliminate-the necessity? to shut down for the purpose of performing surveillances whi' h= cannot be per-c formed on line, which would reduce the potential _ for a condition that: would challenge-plant safety systems unnecessarily; The removalLof:the 3' 25 limit.
wouldr provide greater flexibility in 'the use of the-provision for extending surveillance intervals and reduce the administrative burden-associated with its use. The proposed change to the Millstone Unit No. 2 Technical Specifica-tions is consistent with the guidance provided via Generic Letter 89-14.
The Millstone Unit No. 2 Nu ' ear Review Board has reviewed and approved the attached proposed revision t...dthas concurred with the above determinations.
The proposed change is -not required to support continued operation.
NNEC0 requests that the proposed change become effective upon issuance by? the NRC.
Staff.
Similar changes' were 22,1990,gbmitted for M111stg Unit Nos.1 and 3 by letters dated August and June 13, 1990,-
respectively.
Th NRC Staff has issued the requested amendment for Millstone Unit No. 3 by letter e
(2)
E. J. Mroczka letter to U.S. Nuclear _ -Regulatory; Commission, " Proposed Revision to' Technical Specifications--Removal - of the 3.25 Limit on Extending Surveillance Intervals," dated August 22,3 1990.
(3)
E. J. Mroczka letter to U.S. Nuclear.legulatory Commission, " Proposed Revision-to Technical Specifications--Removal of the 3.25 Limit on Extending Surveillance Intervals," dated June ~13, 1990, o
_L
4 U.S. Nuclear Regulatory Commission B13557/Page 4 November 9, 1990 dated September l' ) 1990,(4) and for Millstone Unit No. I by letter dated November 1, 1990.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.
Please contact my staff if you have any questions.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR:
E. J. Mroczka Senior Vice President N
BY:
C T. Sears Vice President cc:
T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, Millstone Unit No. 2 W. J. Raymond, Senior Resident.nspector, Millstone Unit Nos. 1, 2, and 3 P. Habighorst, Resident Inspector, Millstone Unit No. 2 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, C. F. Sears,- who being duly sworn, did state that he is Vice President of Northeast Nuclear Energy 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 the statements contained in said information are true and correct to the best of j
I his knowledge and beliof.
Ny vvn Ohn, Sf4 rdQAo I
Nottry Public (4)
D. H. Jaffe letter to E. J. Mroczka, " Millstone Unit No. 3--Issuance of' Amendment No. 54," dated September 19, 1990.
j (5)
M. L. Boyle letter to E. J. Mroczka, " Millstone Unit No.1--Issuance of Amendment No. 47," dated November 1, 1990.
,