ML20140E308
| ML20140E308 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/15/1986 |
| From: | Bishop R, Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20140E315 | List: |
| References | |
| B11964, NUDOCS 8602030222 | |
| Download: ML20140E308 (5) | |
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(203) 665-5000 January 15, 1986 Docket No. 50-423 B11964 Office of Nuclear Reactor Regulation Attn:
Mr. V. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing - A U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Noonan:
Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Remote Shutdown Instrumentation Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License NPF-44 for Millstone Unit No. 3 by incorporating the attached change into the Technical Specifications.
The proposed change revises Technical Specification Table 3.3-9, Remote Shutdown Instrumentation, by deleting the transfer switches associated with valves FWA
- A0V-61 A, 61B, 62A, and 62B (items 7, 3, 9, and 10 in the table). The change would resolve an administrative error made in the compilation of Tabic 3.3-9 by making the table reflective of the actual plant configuration. provides a corresponding change to FSAR Tab'e 7.4-1 which will be provided in a future FSAR amendment.
Discussion As a result of the Steam Generator Owner's Group recommendations (Ref. NUREG-0844), the Auxiliary Feedwater System (FWA) design was revised to include safety-related air operated valves in each motor-driven auxiliary feedwater pump suction line and in the discharge line cross-connect piping. This allows use of the FWA system for plant startup and normal plant shutdown. The suction valves (3FWA*AOV61 A, B) are normally open and receive a safety signal to open on-an FWA pump start, safety injection or loss of power to assure aligninent to the safety grade Demineralized Water Storage Tank (DWST). The discharge cross-connect valves (3FWA* AOV62A, B) are normally closed and receive a safety signal to close on an FWA pump start, safety injection or loss of power to assure independence between the two motor-driven pump trains during hot standby.
This allows each motor-driven train to feed a pair of steam
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generators directly from the DWST.
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. During normal plant startup and shutdown operations, these valves are repositioned to allow use of the nonsafety grade condensate storage tank (CST) thus preserving the water inventory in the safety grade DWST.
Parallel to both motor-driven FWA pump trains is a full capacity turbine-driven auxiliary feedwater pump which supplies water from the DWST to all four steam generators. The suction line contains only locked-open manual valves assuring pump availability for all safe shutdown operations.
In the event that the control room must be evacuated, the steam driven auxiliary feedwater pump is the primary means of removing decay heat. Pump and flow controls are located on the auxiliary shutdown panel (ASP).
Technical Specification Table 3.3-9 and FSAR Table 7.4-1 currently indicate that valves 3FWA* AOV61 A, B and AOV 62A, B can be operated from the ASP. From the above brief description, it is clear that this is not necessary for the FWA system to fulfill its safe shutdown and Appendix R requirements.
The existing error in the Technical Specifications and the FSAR is the result of a late FSAR change which was made based upon the conceptual design drawings resulting from NUREG-0844. During subsequent development of the final design basis drawings it was determined that operation of these valves from the ASP was not necessary. As a result, no design drawings showing these switches on the ASP were ever issued for construction. Therefore no switches have ever been installed. Based upon the above information, it is obvious that the installation of the control switches for 3FWA* AOV61 A, B and 3FWA* AOV62A, B was never part of the design basis of the plant. An administrative error made during the conceptual design phase allowed an erroneous FSAR change to be incorporated which was subsequently incorporated into the Technical Specifications.
Safety Evaluation Effect on Design Basis Accident Analysis The four valves in question are not credited in the design basis accident analysis.
The valves are neither Appendix R nor safety-grade cold shutdown valves.
Deleting these valves from the operability and surveillance requirements of Technical Specification 3/4.3.3.5 will not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report.
Potential for creation of an Unanalyzed Accident Deleting these four valves from the operability and surveillance requirements of Technical Specification 3/4.3.3.5 will not affect plant operation or introduce any new failure modes. As a result, this proposed Technical Specification change does not create the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report.
1,
l Effect on the Margin of Safety Deleting these four valves from the operability and surveillance requirements of Technical Specification 3/4.3.3.5 corrects an administrative error. The proposed change will not affect any of the protective barriers. Therefore this change does not reduce the margin of safety as specified in the basis of any technical specification.
Summary and Conclusions Because of the above assessments, the changes implemented by this are considered to be safe and do not constitute an unreviewed safety question as defined in 10CFR50.59 since it does not:
1.
Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report, 2.
Create the possibility for an accident or malfunction of a different type than previously analyzed in the safety analysis report or 3.
Reduce the margin of safety as defined in technical specifications.
Significant Hazards Consideration in accordance with 10CFR50.92, NNECO has reviewed the attached proposed change and has concluded that it does not involve a significant hazards consideration. The basis for this conclusion is that the three criteria of 50.92(c) are not compromised, a conclusion which is supported by our determination made pursuant to 10CFR50.59.
Moreoter, the Commission has provided guidance concerning the application of the standards in 10CFR50.92 by providing certain examples (April 6,1933, 4SFR14870) of amendments that are considered not likely to involve significant hazards consideration. Example i relates purely to administrative changes to the Technical Specifications.
The proposed change to Technical Specification 3.3.3.5 (Table 3.3-9) will correct an administrative error which allowed an erroneous FSAR change to be incorporated which was subsequently incorporated into the Technical Specification. Based on the above consideration, NNECO has determined that this change does not involve a significant hazards consideration.
Request for Expedited Approval Pursuant to 10CFR50.91(a)(5), NNECO requests that this proposed amendment be reviewed and approved on an expedited basis under the provisions made for emergency license amendments.
Expiration of the Technical Specification Limiting Condition for Operation will occur on January 22, 1936. Therefore, unless the proposed Technical Specification change is approved prior to this date, the plant will be prevented from operating above Mode 4.
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_4 The discrepancy between the Technical Specifications and the actual plant configuration was not discovered until preparations were being made for entry into Mode 3.
In accordance with 10CFR50.91(b), NNECO is providing the State of Connecticut with a copy of this proposed amendment.
The _ Millstone Unit No. 3 Nuclear Review Board has reviewed this proposed amendment and concurs with the above determinations.
Pursuant to the requirements of 10CFR170.2(c), enclosed with this amendment request is the application fee of $150.00 Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY et. al.
BY NORTHEAST NUCLEAR ENERGY COMPANY Their Agent b k AYA J. F. Opeka Senior Vice President f
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By: R. W. Bishop '
Secretary cc:
Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection State Office Building Hartford, Connecticut 06116 Dr. Thomas E. Murley Regional Administrator
. Region i U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 i
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. STATE OF CONNECTICUT )
) ss. Berlin COUNTY OF HARTFORD
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Then personally appeared before me R. W. Bishop, who being duly sworn, did l
state that he is Secretary 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 Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
J k' '
Notar'y Public f
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