ML20064J069
| ML20064J069 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 03/14/1994 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES SERVICE CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20064J072 | List: |
| References | |
| B14770, NUDOCS 9403180302 | |
| Download: ML20064J069 (7) | |
Text
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, Utilities systerii se,tseo,, esiiiti,, s,,,i< comp.ny P.O. Ihu 270 Ilartford, CT 06141-0270 (203) 66*>-5000 March 14, 1994 Docket No. 50-336 814770 .
Re: 10CFR50.90 U.S. Nuclear Regulatory Commission ~
Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications One-Time Extension to 18-Month Surveillances Jntroduction Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License No. DPR-65 by incorporating the changes identified herein into the Technical Specifications of Millstone Unit No. 2.
In this submittal, NNEC0 proposes a one-time extension of the surveillance frequency for Millstone Unit No. 2 Technical Specifications 4.1.2.2.c and 4.7.4.1.b. NNEC0's proposal would permit Millstone Unit No. 2 to avoid an unnecessary plant shutdown prior to the start of the 1994 Refueling and Maintenance Outage (RF0).
The proposed changes are discussed in detail below. Attachment 1 provides a mark-up of the proposed changes, and Attachment 2 provides the retyped pages of the Millstone Unit No. 2 Technical Specifications.
Backaround As a result of an extended Millstone Unit No. 2 Steam Generator Replacement Outage, the start of the 1994 RF0 was rescheduled from March 1994 to July-1994. As a result,. the scheduled window for performing ~ many surveillances with an 18-month frequency has been impacted. The due date for the completion of various surveillances, including a 25 percent allowance per Section 4.0.2 of the Millstone Unit No. 2 Technical Specifications, will occur prior to the start of the 1994 RF0. Millstone Unit No. 2 has reduced the number of surveillances requiring one-time extensions by performing those surveillances during plant operation which could be completed without necessitating a plant shutdown.
A number of Millstone Unit No. 2 Technical Specification surveillances which require the unit to be in a shutdown condition will be due prior to the start of the 1994 RF0. This submittal proposes a one-time extension . for the
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B14770/Page 2 March 14, 1994 surveillances that are due in April and May of 1994 (Sections 4.1.2.2.c and l 4.7.4.1.b of the Millstone Unit No. 2 Technical Specifications). A subsequent submittal will propose a one-time extension for the remaining surveillance j requirements.
In a letter dated February 26, 1993,m NNEC0 subniitted information on actions taken and planned for identi fying 18-month surveillances which ,
required a plant shutdown, but which would be required to be performed before j the next refueling outage. Within that letter, NNECO stated that the review i would be completed, and appropriate steps taken to initiate a license amendment request with ample time to secure the required NRC approvals. Due to plant operational events, the recent performance issues, and the subsequent J reorganization of the management at each of the NNEC0 nuclear plants, '
specifically, Millstone Unit No. 2, this action item was not completed for Millstone Unit No. 2 until March 1994. This submittal is timely relative to the completion of that assessment.
This submittal is being made under the assumption that Millstone Unit No. 2 l will not experience a forced outage prior to the start of the 1994 RFO. !
Currently, the potential exists that Millstone Unit No. 2 may shutdown to replace a seal on the 'D' reactor coolant pump. If a forced outage were to occur, Millstone Unit No. 2 would utilize the opportunity to complete the previously noted surveillances, and withdraw this request promptly.
Description of the Proposed Chances l
NNEC0 is proposing a one-time extension of the surveillance frequency for l Millstone Unit No. 2 Technical Specifications 4.1.2.2.c and 4.7.4.1.b on pages :
3/4 1-10 and 3/4 7-12, respectively. Technical Specification 4.1.2.2.c l requires that each power operated valve in each boron injection flowpath be exercised through at least one complete cycle at least once per 18 months, during shutdown, Currently, valve 2-CH-508-is required to be exercised during shutdown prior to the start of the 1994 RF0. Technical Specification 4.7.4.1.b requires each power-operated valve in each of the service water system loops be exercised through one full cycle at least once per 18 iannths.
Currently, two service water power-operated valves, 2-SW-3.1A and 2-SW-3.1B, are required to be exercised prior to the start of the 1994 RF0. This proposal would permit Millstone Unit No. 2 to avoid an unnecessary plant shutdown prior to the start of the 1994 RF0.
Currently, Technical Specification 4.1.2.2.c is required to be performed no later than April 23, 1994, and Technical Specification 4.7.4.1.b is required to be performed no later than May 5, 1994 (these due dates include -the 25 percent allowance per Millstone Unit No. 2 Technical Specification 4.0.2).
(1) J. F. Opeka letter to U.S. Nuclear Regulatory Commission, "Haddam Neck Plant, Millstone Nuclear Power Station, Unit Nos.1, 2, and 3,18-Month Technical Specification Surveillance (TAC No M85470)," dated February 26, 1993.
s-U.S. Nuclear Regulatory Commission B14770/Page 3 March 14, 1994 The following footnotes are proposed to be added to Technical Specifications 4.1.2.2.c and 4.7.4.1.b:
Technical Specification 4.1.2.2.c -
"Except that the surveillance requirement due no later than April 23, 1994, may be deferred until the next refueling outage, but no later than September 30, 1994, whichever is earlier." q Technical Specification 4.7.4.1.b "Except that the surveillance requirement due no later than May 5, 1994, may be deferred until the next refueling outage, but no later than September 30, 1994, whichever is earlier."
i The proposed changes do not alter or change any acceptance criteria of the l surveillance requirements. T!.e changes proposed herein (one-time extension to '
the 18-month interval for certain surveillances) are similar in nature to those approved by the NRC on June 8,1993, for Millstone Unit No. 3 m lafety Assessment In Generic Letter 91-04,* the NRC Staff identified that they have reviewed a number of requests to extend 18-month surveillances to the end of a fuel cycle and a few requests for changes in surveillance intervals to accommodate a 24-month fuel cycle. The NRC Staff has found that these changes ' haste a small impact on the margin of safety because safety systems - use redundant electrical and mechanical compone0ts, and because licensees perform other surveillances during plant operation that confirm that these systems and components can perform their safety function.
Valve 2-CH-508 in the boron injection flowpath was exercised through a complete cycle or March 7, 1994, during the performance of surveillance procedure SP 2601A, " Borated Water Source and Flow Path. Verification." This surveillance verified the valve's operability. However, the performance -of this surveillance did not satisfy literal compliance with. Technical Specification 4.1.2.2.c, because it was not performed while the unit was nutdown. Therefore, PIECO i s proposing a one-time extension to the
.arveillance frequency for Technical Specification 4.1.2.2.c.
(2) V. L. Rooney letter to J. F. Opeka, Mssuance of Amendment (TAC No.
M86148)," dated June 8, 1993.
(3) J. G. Partlow letter to All Holders. of Operating Licenses or Construction Permits for Nuclear Power Reactors, " Changes in Technical Specification Surveillance Intervals to Accommodate a .24-Month Fuel Cycle (Generic Letter 91-04)," stated April 2, 1991.
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B14770,'Page 4-March 14, 1994 Motor-operated valves 2-SW-3.lA and 2-SW-3.lB are located on the ' A' and 'B' '!
service water headers, immediately upstream of the service water supply piping l to the reactor building closed cooling water heat exchangers. The valves provide isolation of the upstream piping in the event of a significant leak-in ,
the piping. The valves are norm 11y open, and are designed to fail in.the "as '
is" condition. The valves d- - i perform any active safety function, nor do they provide isolation between i..s two service water headers. Their primary function is to isolate the downstream portion of the header for maintenance ,
activities. >
A review of the maintenance and operational history of the service water system valves did not identify any previous problems with the ability of the valves to open or close, or to meet any other design requirements. The' valves are normally cycled to meet Technical Specification requirements during Mode 6 while only one header is operable.
. In addition, the proposed one-time extensions for 2-CH-508, 2-SW-3.lA, and 2-SW-3.lB were reviewed utilizing probabilistic risk assessment -(PRA) techniques. The PRA review determined that the one-time increase to . the surveillance frequencies would have a negligible impact on overall public risk.
Based on the above, the one-time extensions to the surveillance requirements for Technical Specifications 4.1.2.2.c and 4.7.4.1.b do not impair the ability of the valves to perform their design basis furction.
11anificant Hazards Considerati_oji NNEC0 has reviewed the proposed chango. in accordance with 10CFR50.92 and concluded that the changes do not involv , mignificant hazards consideration (SHC). The basis for this conclusic .s that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve a SHC because the changes would not:
1, involve a significant increase in the probability or consequences of an accident previously analyzed.
Technical Specification 4.1.2.2.c The subject valve in the baron injection flowpath was exercised through a complete cycle on March 7, 1994, during the performance of SP 2601A.
This surveillance verified the valve's operability. However, the performance of this surveillance did not satisfy literal compliance with Technical Specification 4.1.2.2.c, because it was not performed while the unit was shutdown. A one-time extension to the surveillance frequency for the subject valve in the br m injection system does not involve a significant increase in the probability or consequences of an- accident previously analyzed.
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March 14, 1994 '
Technical Specification 4.7.4.1.b Service water valves 2-SW-3.lA and 2-SW-3.lB are normally open and are designed to fail in the "as is" position. The valves do not perform any active safety function (are not considered in any operational procedure to mitigate the effects of an abnormal event), nor do they provide isolation between the two service water headers. Their primary function is to isolate the' downstream portion of the header for maintenance activities. Increasing the time interval between performance of -
surveillance testing on 2-SW-3.1A and 2-SW-3.lB does not involve - a significant increase in the probability or the consequences of a previously analyzed accident.
In addition, a review of the maintenance and operational. history of the service water system valves did not identify any previous problems with the ability of the valves to open or close, or to. meet any other design requirements.
Therefore, the one-time extension of the surveillance interval does not involve a significant increase in the probability or consequences of an accident.
- 2. Create the possibility of a new or different kind of accident from any previously analyzed.
The proposed. changes do. not involve any physical modifications to any equipment, structures, or components, nor do they involve any changes' to any plant operating procedures. The only change is a one-time extension of the surveillance intervals for one power-operated-valve in the boron injection system and two power-operated valves in the service water system. Thus, the proposed changes do not introduce any new failure modes, and they do not c sate the possibility of a new or different kind of accident.
- 3. Involve a significant reduction in the margin of safety.
The proposed changes to Technical Specifications 4.1.2.2.c and 4.7.4.1.b do not involve any changes to any safety limits, setpoints, or design margins. Also, the proposed changes do not affect any protective boundaries.
Technical Sped fication 4.1.2.2.c 3 The subject valve in the boron injection flowpath was exercised through a 3 complete cycle on March 7, 1994. This surveillance verified the valve's operability. However, the . performance of this surveillance. did not satisfy literal compliance with Technical Specification 4.1.2.2.c, because it was not performed while the _ unit was shutdown. A one-time extension of 'the surveillance for the subject valve in the boron i
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.l U.S. Nuclear Regulatory Commission B14770/Page 6 March 14, 1994 injection system does not involve a significant reduction in the margin of safety.
Technical Specification 4.7.4.1.b Service water valves 2-SW-3.lA and 2-SW-3.lB are normally open and are designed to fail in the "as is" position. The valves do not perform any active safety function (are not considered in any operational procedure to mitigate the effects of en abnormal event), nor do they provide isolation between the two service water headers. Their primary function is to isolate the downstream portion of the header for maintenance activities. Since service water valves 2-SW-3.lA and 2-SW-3.lB possess no risk significance, the proposed one-time extension to the_ surveillance frequency for service water valves 2-SW-3.lA and 2-SW-3.lB does not involve a reduction in the margin of sai'ety.
The Commission has provided guidance concerning the application' of the standards of 10CFR50.92 by providing certain examples (51 FR 7751, March 6, 1986) of amendments that are not considered likely to involve a SHC. Although the changes proposed herein are not enveloped by a specific example, they do not involve a SHC. The proposed one-time extension to Technical Specification 4.1.2.2.c is actually an administrative request, since the operability of the subject valve in the boron injection system was~ recently cor. firmed by exercising the valve through a complete cycle. The proposed one-time extension to Technical Specification 4.7.4.1.b does not involve a SHC, because service water valves 2-SW-3.lA and 2-SW-3.18 do not possess any risk significance. The service water valves are normally open and are designed to fail in the "as is" position. They do not perform any active safety function (are not considered in any operational procedure to mitigate the effects p' an abnormal event), nor do they . provide isolation between the two service water !
headers. ;
Environmental Considerations ]
NNECO has reviewed the proposed license amendment against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not increase the types and amounts of effluents that may be released offsite, nor !
significantly increase individual or cumulative occupational radiation .)
exposures. Based on the foregoing, NNECO concl Jes that the proposed changes 1 meet the criteria delineated in 10CFR5122(c)(9) for a categorical exclusion from the requirements for an environmental impact statement.
The Hillstone Unit No. 2 Nuclear Review Board has reviewed and concurred with the above determinations.
In accordance with 10CfR50.91(b), we are providing the State of Connecticut' with a copy of this amendment, ,
The proposed changes will allow the frequency for Millstone Unit No. 2 Technical Specifications 4.1.2.2.c and 4.7.4.1.b to be extended to coincide .
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U.S. Nuclear Regulatory Commission B14770/Page 7 March 14, 1994 with the 1994 Rf0 scheduled to begin in July 1994. Currently, these surveillances are required to be performed by April 23, 1994, and May 5, 1994, respectively. Therefore, NNECO hereby requests the NRC Staff process and issue this proposed amendment prior to April 23, 1994, to be effective upon issuance. We acknowledge that this schedule provides less than the nominal period appropriate for NRC Staff review and issuance of routine amendment requests.
As stated previously, a short duration shutdown to replace a 'D' reactor coolant pump seal may occur. We will keep the NRC Staff apprised of our ongoing assessment of the likelihood of this occurrix. If this shutdown does occur, the NRC Staff will be promptly notifiec, this request will be withdrawn, and these surveillances will be performed during this outage.
We wil_1 promptly provide any additional information the NRC Staff may need to respond to this request.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY k bd J. F. Opska (/
Executive Vice President cc: T. T. Martin, Region I Administrator G. S. Vissing, NRC Project Manager, liillstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 Mr. Kevin T.A. McCarthy, Director ;
Monitoring and Radiation Division Department of Environmental Protection l 79 Elm Street 1 P.O. Box 5066 i Hartford, CT 06102-5065 l
l Subscribed and sworn to before me-this / '/ day of ManA , 1994 -
GuaulP m %bn Date Commission Expires:
/R/3//97 1
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