ML20132A959

Forwards RAI Re Changes to Plant,Unit 1 TS for Standby Gas Treatment Sys

ML20132A959
Person / Time
Site:	Millstone
Issue date:	12/09/1996
From:	Stephen Dembek NRC (Affiliation Not Assigned)
To:	Harpster T, Kenyon B NORTHEAST UTILITIES SERVICE CO.
References
TAC-M94258, NUDOCS 9612160398
Download: ML20132A959 (5)

Text

. _ _ _ __ _ _

Mr. B. D. Kenyon Dewcember 9, 1996 President - Nuclear Group I

.c N2rtheast Utilities Service Company l '

c/o Mr. Terry L. Harpster Director - Nuclear Licensing Services P.O. Box 128 Waterford, CT 06385 l

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING A STANDBY GAS TREATMENT ,

l SYSTEM LICENSE AMENDMENT REQUEST FOR MILLSTONE UNIT 1 (TAC N0. l l M94258) l

Dear Mr. Kenyon:

By letter dated December 7, 1995, Northeast Nuclear Energy Company (NNECO) submitted a license amendment request regarding changes to the Millstone Unit 1 Technical Specifications for the standby gas treatment system. The NRC staff has completed a preliminary review of NNECO's request i and has identified two issues that require additional information. Please respond to the attached request for additional information within 60 days from I receipt of this letter. ,

1 Sincerely 1 Original s,igned by:

Stephen Dembek, Project Manager Special Projects Office - Licensing i Office of Nuclear Reactor Regulation

]

Docket No 50-245 l

Enclosure:

As stated cc w/ encl: See next page DISTRIBUTION:

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%,*****p December 9, 1996

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l Mr. B. D. Kenyon j President - Nuclear Group i

Northeast Utilities Service Company '

c/o Mr. Terry L. Harpster i

Director - Nuclear Licensing Services l 4

P.O. Box 128  !

Waterford, CT 06385 '

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING A STANDBY GAS TREATMENT SYSTEM LICENSE AMENDMENT REQUEST FOR MILLSTONE UNIT 1 (TAC NO.

M94258)

I

Dear Mr. Kenyon:

4

By letter dated December 7, 1995, Northeast Nuclear Energy Company (NNECO) submitted a license amendment request regarding changes to the j Millstone Unit 1 Technical Specifications for the standby gas treatment l 1 system. The NRC staff has completed a preliminary review of NNECO's request

, and has identified two issues that require additional information. Please respond to the attached request for additional information within 60 days from receipt of this letter.

1 j Sincerely, i Stephen Dembek, Project Manager

Special Projects Office - Licensing Office of Nuclear Reactor Regulation Docket No 50-245

Enclosure:

As stated cc w/ encl: See next page k -

Northeast Utilities Service Company Millstone Nuclear Power Station Unit 1 cc:

Lillian M. Cuoco, Esquire Mr. Wayne D. Lanning Senior Nuclear Counsel Deputy Director for Inspections Northeast Utilities Service Company Millstone Nuclear Power Station P. O. Box 270 c/o U.S. Nuclear Regulatory Hartford, CT 06141-0270 Commission P. O. Box 513 Mr. Kevin T. A. McCarthy, Director Niantic, CT 06357 Monitoring and Radiation Division l Department of Environmental Mr. F. C. Rothen

! Protection Vice President - Work Services j 79 Elm Street Northeast Utilities Service Company j Hartford, CT 06106-5127 P. O. Box 128 Waterford, CT 06385 Mr. Allan Johanson, Assistant Director Mr. Ernest C. Hadley, Esq.

Office of Policy and Management 1040 B Main Street Policy Development and Planning P. O. Box 549 Division West Wareham, MA 02576 i 80 Washington Street Hartford, CT 06106 Mr. John Buckingham Department of Public Utility Control i Regional Administrator Electric Unit Region I 10 Liberty Square U.S. Nuclear Regulatory Commission New Britain, CT 06051 475 Allendale Road King of Prussia, PA 19406 Mr. P. D. Hinnenkamp Director, Unit Operations First Selectmen Northeast Utilities Service Company Town of Waterford P. O. Box 128 Hall of Records Waterford, Connecticut 06385 ,

200 Boston Post Road I Waterford, CT 06385 Mr. T. C. Feigenbaum Executive Vice President and Mr. D. M. Goebel Chief Nuclear Officer l Vice President - Nuclear Oversight Northeast Utilities Service Company I Northeast Utilities Service Company P. O. Bxo 128 P. O. Box 128 Waterford, Connecticut 06385 Waterford, Connecticut 06385 Mr. J. McElwain Millstone Unit No. 1 Nuclear Recovery Officer Northeast Utilities Service Company P. O. Box 128 Waterford, Connecticut 06385

!.s REQUEST FOR ADDITIONAL INFORMATION I MILLSIONE.. UNIT..1

! STANDBY EAS TREATMENT SYSTEM i TAC NO. M94258 s

By letter dated December 7, 1995, Northeast Nuclear Energy Company (NNECO) submitted a license amendment request regarding changes to the Millstone Unit 1 Technical Specifications for the standby gas treatment (SBGT) system.

The NRC staff has completed a preliminary review of NNECO's request and has

! identified the following two issues that require additional information.

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1. In the discussion of purging or venting through the SBGT system on page 6 of the December 7, 1995, letter, NNECO states:

When this issue [ license amendment request] was first discussed, the

! staff requested a specification which would limit the use of SBGT for i

purging and venting to less than 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> per year. The intent of the t original proposed change was to achieve a similar limitation on usage without being bound to a specific number of hours. Having the option to purge or vent to the stack should significantly decrease the time when SBGT is exposed, since exhausting directly to the exhaust plenum will be the normal path.

, Limiting Condition for Operation (LCO) action statement times are determined,

in part, on the safety significance of the system and on the amount of time one train is expected to be unavailable due to testing, maintenance, or failures of one or more components. Since the LCO for the SBGT system will now be entered when the SBGT system is used for venting, the time spent in the SBGT system action statement has the potential to increase significantly.

l Therefore, the staff needs further clarification on the estimated time SBGT will be used for venting and NNEC0's plans for controlling the amount of time

the SBGT system is used for venting. This information is needed so that the staff can be assured that the additional time to be spent in the action

statement is not inconsistent with the assumption that entry into the action

. statement will be infrequent and will primarily be to address out of service i

equipment or to conduct required testing.

2. In the submittal dated December 7, 1995, NNECO included a change to Bases Section 3.7.B which would state:

When standby gas is used in this manner (and primary containment is required), the automatic initiation of the train not in use will be disabled, and an operator will be assigned responsibility to ensure, in the event of a DBA [ design basis accident], that the train is started

after the atmosphere control containment isolation valves close. This j manual action is necessary to ensure that the second train is not exposed to the pressure created from a LOCA [ loss-of-coolant accident]

inside containment.

I Enclosure

.' l 2-1 In the discussion of substituting manual actions for automatic actions, NNEC0 did not address whether they reviewed the regulations, general design criteria, the Millstone Unit 1 Updated Final Safety Analysis Report, or other l licensing documents that would prohibit the manual actions. Further, although l NNECO did address the issue of the possible increase in overall radiation '

! release, NNECO (1) did not adequately justify why the 1- and 3-minute l

! scenarios for operator action are bounding, and (2) did not address other  ;

l considerations such a potential radiation e,tposure to the operator, or other l l potentially relevant considerations such as these summarized in Section 6.7  ;

! the of Inspection Manual section entitled, " Operable / Operability: Ensuring the  !

Functional Capability of a System or Component," which was issued as part of Generic Letter 91-18.

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