B11686, Application for Amend to License DPR-21,revising Tech Specs to Consolidate Specs 3.5.F.7 & 3.5.F.8 Into One Spec,To Clarify Water Level Requirements for Refuel Cavity & Modify Lpci/Core Spray Requirements.Fee Paid
| ML20138B475 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/07/1985 |
| From: | Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20138B479 | List: |
| References | |
| B11686, NUDOCS 8510150369 | |
| Download: ML20138B475 (4) | |
Text
.
m UTHJTIES con.<.i On c... seio.n sir i. Bernn. conn.ciicut 9
EsY$5.5eNcYO P.O. 80X 270
.c os..w w. a=
HARTFORD. CONNECTICUT 06141-0270
[ [,'C{C (203) 665-5000 k
L J
October 7,1985 Docket No. 50-245 B11686 Director of Nuclear Reactor Regulation Attn:
Mr. John A. Zwolinski, Chief Operating Reactor Branch #5 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No.1 Proposed Revision to Technical Specifications Minimum Core and Containment Cooling System Availability During Refueling Pursuant to 10CFR50.90, Northeast Nuc! car Energy Company (NNECO) hereby proposes to amend its Operating License, DPR-21, by incorporating the attached proposed changes into the Millstone Unit No.1 Technical Specifications.
The proposed Technical Specification revision is provided as Attachment 1.
These proposed changes:
o Consolidate Technical Specifications 3.5.F.7 and 3.5.F.8 into one Specification; o
Clarify water level requirements for the refuel cavity; Modify LPCI/ Core Spray requirements during the refuel condition to more o
closely match Standard Technical Specifications.
The proposed change to consolidate Technical Specifications 3.5.F.7 and 3.5.F.8 is administrative in nature and serves to climinate some of the redundant wording contained in the existing specifications.
Technical Specifications 3.5.F.7 and 8 specify conditions for work on control rod drive mechanisms and fuel movement and replacement during the refuel condition.
The proposed change consolidates into Specification 3.5.F.7 each of the non-redundant requirements contained in the current specifications.
The proposed changes in Sections 3.5.F.7 (a) thru (d) serve to describe the refuel conditions and make verification of the water level requirement consistent with the methods used by plant personnel to monitor water level in the refuel cavity without changing the intent of the specification. Existing specification 3.10.C requires a fuel storage pool water level of greater than or equal to 3) Icet. The existing Specification 3.5.F.7(e) and 3.5.F.8(b) require a refuel cavity water capacity of at ! cast 383,000 gallons.
j 0510150369 051007
-h PDR ADOCK 05000245 0
1 P
PDH L -
W 2-Under the new Technical Specifications 3.5.F.7(b), (c), and (d), the conditions are specified such that the water depth (the normal method of monitoring level for the spent fuel pool) is maintained for the pool with the cavity flooded and the spent fuel pool gates removed.
By maintaining the water level of the spent fuel pool as specified in Section 3.10.C during refuel operations, the currently specified requirement of 383,000 gallons of water in the refueling cavity is satisfied. The proposed change to modify LPCI/ Core Spray requirements would allow the operator to rack out the LPCI/ Core Spray pump breakers to prevent an inadvertent injection and possible drywell and refuel floor flooding with the reactor in the refuel mode, while maintaining the ability to return the LPCI/ Core Spray system (s) to full operability quickly (less than 2 minutes) by racking in the breaker (s). We view this step to be an improvement in overall plant safety and reliability.
NNECO has reviewed the attached proposed changes pursuant to 10CFR50.59 and has determined that they not constitute an unreviewed safety question.
Specifically, the margins of safety as defined in the Technical Specification Bases are maintained.
in addition, the probability of occurrence or the consequence of previously analyzed accidents have not been increased and the probability for a new type of accident not previously evaluated has not been created. The proposed changes to modify LPCI/ Core Spray requirements are more conservative than Standard Technical Specifications (STS). The Standard Technical Specifications do not require that the LPCl/ Core Spray systems be operable when the reactor vessel head is removed and the refuel cavity flooded.
The proposed changes are somewhat less restrictive than the existing Technical Specifications in that, while continuing to require operable systems, they allow the 4160 volt supply breakers to be racked out to prevent inadvertent initiation of the systems which would result in refuel floor flooding with the reactor in the refuel mode. We view the proposed change to be a net improvement in plant safety because the systems in question are available to perform their intended safety function, but are precluded from inadvertent actuation.
The other proposed changes are intended to consolidate or clarify existind specifications and are administrative in nature.
NNECO has reviewed the proposed changes in accordance with 10CFR50.92, and has concluded that they do not involve a significant hazards consideration. The basis for this conclusion is that the criteria of 10CFR50.92(c) are not compromised, a conclusion which is supported by our determinations made pursuant to 10CFR50.59. Additionally, the Commission has provided guidance concerning the Application of Standards in 10CFR50.92 by providing certain examples (48FR14870, April 6,1983).
The proposed changes to Technical Specifications 3.5.F.7 and 3.5.F,8 are enveloped by exampic (i) in 48 FR 14870 of actions not likely to involve a significant hazards consideration. Example (1) involves a purely administrative change to Technical Specifications; for example, a change to achieve consistency throughout the technical specifications. By combining the partially redundant requirements of Technical Specifications 3.5.F.7 and 3.5.F.8 and further clarifying the normal conditions of the refuel cavity the resulting specification is more consistent in its contents. Inclusion of a reference to Technical Specification 3.10.C in the proposed wording makes the requirement for water level in the refueling cavity consistent with the existing method used by the operator to monitor water level (an indicated level rather than a specified volume) without changing the intent of the specification.
L
. The current Technical Specifications require at least one LPCI/ Core Spray system to be operable in the Refuel Mode with irradiated fuel in the vessel and control rod drive or fuel movement work being, performed. The proposed change to modify LPC1/ Core Spray requirements during the Refuel Condition a most closely enveloped by example (vi) in 43 FR 14870 which involves a modest relaxation in operability requirements relative to existing Technical Specifications, but the change is within acceptable criteria as defined in Standard Technical Specifications, the applicable document analogous to the Standard Review Plan discussed in example (vi).
Importantly, the proposed changes represents a net improvement in overall plant safety and reliability.
The proposed change would allow an operator to rack out the LPCl/ Core Spray pump breakers, with the reactor in the Refuel Mode and the refuel cavity flooded, to prevent an inadvertent injection and possible drywell and refuel floor flooding while retaining the ability to quickly return the LPCl/ Core Spray system to full operability by racking in the breakers. This change results in conditions more conservative than Standard Technical Specifications in that it requires operability or availability of LPCl/ Core Spray for operations in the Refuel Mode while the Standard Technical Specifications do not require operability at all.
The Millstone Unit No. I Nuclear Review Board has reviewed and approved the attached proposed revision and has concurred with the above determinations.
In accordance with 10CFR50.91(b), NNECO is providing the State of Connecticut with a copy of this proposed Amendment.
Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.00.
We trust you find this information satisfactory.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY bit-J.F. OpekttJ U
Senior Vice President cc:
Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartiord, CT 06h 16 i
V 4
STATE OF CONNECTICUT ss. Berlin COUNTY OF HARTFORD Then personally appeared before me 3.F. Opeka, who being duly sworn, did s ate that he is Senior Vice President of Northeast Nuclear Energy Company, Lice see 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 his knowledge and belief.
[ h 4An*1 f b}?S'<W Notary Publy My Commission bpires March 31,1983 w