B16343, Application for Amend to License DPR-65,modifying Minimum Accuracy Stated in Table 3.3-8 for Instruments Used to Measure Wind Speed & Air Temp - Delta T
| ML20141B689 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/08/1997 |
| From: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20141B694 | List: |
| References | |
| B16343, NUDOCS 9705160005 | |
| Download: ML20141B689 (12) | |
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Hope Ferry Hd. (Houte 1.%), Waterford, CF 06335
////fjY NuclearEnergy mustone Nuclear Power station Northeet Nuclear Energy Company P.O. Ilot 128 Waterford, Ur 06385-0128 (860) 447-1791 Fax (860) 444 4277 l
The Northeast Utibties System MAY 8 1997 Docket No. 50-336 B16343 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 Meteoroloaical Instrumentation (TAC No. M97746 )
Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO), in a letter dated January 17,1997, proposed to amend Operating License DPR65 by changing the Technical Specifications of Millstone Unit No. 2. The proposed changes modified Table 3.3-8, " Meteorological Monitoring Instrumentation," and B.; ses Section 3/4.3.3.4,
" Meteorological Instrumentation." The purpose of the proposed changes was to modify the minimum accuracy stated in Table 3.3-8 for the instruments used to measure wind speed and air temperature - delta T. Further review of the meteorological monitoring instrument loops used to monitor Technical Specification compliance has identified additional inaccuracies beyond the values contained in the original license amendment ;
j request. NNECO is proposing to revise the earlier values by submitting a separate amendment request to include the new instrument accuracies in Table 3.3-8.
This license amendment request supersedes the license amendment request dated q 4
January 17,1997. provides a discussion of the proposed changes. Attachment 2 provides the Significant Hazards Consideration. Attachment 3 provides the marked-up version of the appropriate pages of the current Technical Specifications.
provides the retyped pages of the Technical Specifications.
9705160005 970508 PDR ADOCK 05000336 P
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' U.S. Nuclear Regul tory Commission B16407\\Page 2 The proposed changes were e valuated utilizing the criteria of 10CFR50.59, and were determined to involve an unreviewed safety question because the accuracy requirements for the instrumeritation used to monitor air terrtperature - delta T and wind speed are nonconservative wih respect to the requirements of Regulatory Guide 1.23.
(The current basis for Technical Specification 3/4.3.3.4 states the instrumentation is consistent with Reg datory Guide 1.23.)
Thus, the license amendment request does involve a reduction in the margin of safety as defined in the basis for Technical Specification 3/4.3.3.4. However, since the change a) does not result in any increase in initiating event frequency, b) cioes not adversely affect the probability of failure of operator mitigation, c) does not adversely affect the probability of failure of mitigating equipment, and d) does not adersely impact the consequeras of 'he design basis ana':lG, it has been concluded to be safe.
The proposed changes do not involve a significant impact on public health and safety (see the Safety Assessment provided in Attachment 1) and do not involve a Signif; cant Hazards Consideration pursuant to the provisions of 100FR50.92 (see the Significant Hazards Consideration provided in Attachment 2).
Environmental Considerations NNECO has reviewed the proposed license amendment request agu!nst the criteria of 10CFR51.22 for environmental considerations. The proposed changes modify the minimum accuracy for the instruments used to measure wind speed and air temperature - delta T.
These changes do not increase the type and am
" of effluents that may be released offsite. In addition, this anendment request wn. not significantly increase individual or cumulative occupational radiation exposures.
Therefore, NNECO has determined the proposed changes will not have a significant effect on the quality of the human environment.
E,l.a_qt Operations Review Committee and Nuclear Safety Assessment Board The Plant Operations Review Committee and Nuclear Safety Assessment Board have reviewed and concurred with these determinations.
Schedule We request issuance at your earliest convenience, with the amendment to be imo!emented within 30 days of issuance.
SM.jdlotification in accordance with 10CFR50.91(b), a copy of this license amendment request is being provided to the State of Connecticut.
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- U.S. Nuclear RegulCtory Commission B16407\\Page 3 If you should have any questions on the above, please contact Mr. Ravi Joshi at (860) 440-2080.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY hI hth M. L. Bowling
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Millstone Unit No. 2 Reo6very Officer Subscribed and sworn to before me this T
day of fDOA/
.1997 hw U[h e i n ObM u
Date Commission expires n 30 Q001 DoSN A LYNNE WILLIANS
., ARY PUBLIC SWE ut CONNECTICW g
cc:
H. J. Miller, Region 1 Administrator D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 W. D. Travers, PhD, Director, Special Projects W. D. Lanning, Director, Millstone Assessment Team Kevin T. A. McCarthy, Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127
Dodet No 50-336 B16343 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications i
Meteorological Instrumentation Discussion of Proposed Changes
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May 1997 i
,U.S. Nucl:ar Regulatory Commission B16343/ Attachment 1/Page 1 Proposed Revision to Technical Specifications i
MeteorologicalInstrumentation Discussion of Proposed Changes i
introduction
' Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO), in a letter dated January 17,1997, proposed to amend Operating License DPR-65 by changing the Technical Specifications of Millstone Unit No. 2. The proposed changes modified Table 3.3-8, " Meteorological Monitoring instrumentation," and Bases Section 3/4.3.3.4,
" Meteorological Instrumentation." The purpose of the proposed changes was to modify the minimum accuracy stated in Table 3.3-8 for the instruments used to measure wind speed and air temperature - delta T. Further review of the meteorological monitoring instrument loops used to monitor Technical Specification compliance has identified additional inaccuracies beyond the values contained in the original license amendment request. NNECO is proposing to revise the earlier values by submitting a separate amendment request to include the new instrument accuracy in Table 3.3-8. This license amendment request supersedes the license amendment request dated January 17, 1997.
I Backaround in Licensee Event Report (LER) 50-336/96-034-00,' Millstone Unit No. 2 reported that the instrumentation used to monitor air temperature - delta T did not meet the instrument minimum accuracies as required by Technical Specification 3/4.3.3.4.
A license amendment request was submitted in a letter dated January 17,1997 to resolve the issues discussed in the LER. This submittal supersedes the original license amendment request and, if granted by the NRC, will resolve the condition reported in LER 50-336/96-034-00.
In addition to the inaccuracies associated with the meteorological monitoring instrument loops, Millstone Unit No. 2 has determined it is necessary to account for a loss of environmental control (building heating and/or cooling) in the Environmental Data Acquisition Network (EDAN) building. Therefore, NNECO proposes to modify the Technical Specification accuracy requirements for the Millstone Unit No. 2 meteorological instrumentation that measures wind speed and air temperature delta -
T. The proposed accuracy requirements, which include additional margin to account for any additional uncertainty, do not meet the accuracy requirements contained in Regulatory Guide 1.23.
P. M. Richardson letter to U.S. Nuclear Regulatory Commission, Licensee Event Report 50-336/96-034-00, dated December 9,1996.
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',U.S. Nuclear Reguictory Commission B16343/ Attachment 1/Page 2 The accuracy requirements for meteorological instrumentation are contained in Reguietory Guide 1.23 (Safety Guide 23) dated March 17, 1972. Regulatory Guide 1.97, Rev. 2, also provides accuracy requirements for meteorological instrumentation variables. These variables are classified as Type E.
Assuming a loss of environmental control in the EDAN building, the following conclusions can be made concerning the accuracy of the Millstone Unit No. 2 meteorologicalinstrumentation.
- 1. The wind direction instrumentation accuracy ( 12.2 *) at Millstone Unit No. 2 meets the accuracy requirements of Regulatory Guide 1.23 ( 15.0 *) and Regulatory Guide 1.97 Rev. 2 ( 5.0 *).
- 2. The wind speed instrumentation accuracy (0 to 15 mph 10.16 mph, above 15 mph i 1.09 %) at Millstone Unit No. 2 meets the accuracy requirements of Regulatory Guide 1.23 (i 0.5 mph) and Regulatory Guide 1.97, Rev. 2, (0 to 67 mph 10.5 mph) up to a wind speed of approximately 45 mph.
[ Regulatory Guide 1.97, Rev. 2, does not specify an accuracy requirement for the entire O to 67 mph range. For comparison purposes, the accuracy value of 0.5 mph has been applied to the entire O to 67 mph range.]
- 3. The delta-T instrumentation accuracy ( i 0.55 *C (0.99 F)) at Millstone Unit No. 2 does not meet the accuracy requirements of either Regulatory Guide 1.23 (
0.1* C (0.18 *F)) or Regulatory Guide 1.97, Rev. 2, (atmospheric stability 1 0.15 *C (0.27 *F) per 50 meter intervals).
[ Regulatory Guide 1.97 Rev. 2, accuracy values of 0.15 *C and 0.3 F are not equivalent. 0.15 or is equivalent to 0.27 *F and 0.3 *F is equivalent to 0.17 *C, For comparison purposes, the values of 0.15 *C and 0.27 F have been used.]
The accuracy requirements contained in Regulatory Guide 1.23 are for time averaged values of wind speed and temperature. The accuracy requirement for wind direction is instantaneous. Regulatory Guide 1.97, Rev. 2, does not specify time averaged or instantaneous.
Meteorological data can be obtained from the Millstone Unit No. 2 plant process computer and from EDAN. The plant process computer provides instantaneous values of wind speed, wind direction, and delta - T. The plant process computer also provides time averaged values of wind speed and wind direction. EDAN provides time averaged values of wind speed, wind direction, and delta - T.
Based on the above results, NNECO proposes to modify the Technical Specification accuracy requirements for the Millstone Unit No. 2 meteorological instrumentation that measures wind speed and delta - T. The proposed accuracy requirements, which
- U.S. Nuclear Regulatory Commission B16343/ Attachment 1/Page 3 include additional margin to account for any additional uncertainty, do not meet the requirements contained in Regulatory Guide 1.23.
Desion Basis and Licensino Basis The data from the meteorological instrumentation are used to:
a) estimate public dose from routine or accidental releases of airborne radioactivity; b) make decisions regarding actions to take to protect the public in the event of an accident involving the release of airborne radioactivity; and c) establish radiological dispersion parameters to determine radiological doses in design basis accident calculations.
Descriotion of Proposed Chanoes
.This submittal, which supersedes the original submittal dated January 17, 1997, provides the license amendment request which, if granted by the NRC, will resolve the condition reported in LER 50-336/96-034-00'. NNECO proposes to modify the Millstone Unit No. 2 Technical Specifications by:
- 1. changing the minimum accuracy stated in Table 3.3-8 for the instruments used to measure wind speed. The current minimum accuracy for these instruments is "i o.22 m/sec*."
The revised minimum awu acy for these will be " Wind Speed s 2.2 m/sec (5 mph) ; i 0.22 m/sec* (0.5 mph)" and " Wind Speed > 2.2 m/sec (5 mph) ; i 10% of measured value*."
- 2. changing the minimum accuracy stated in Table 3.3-8 for the instruments used to measure air temperature - delta T.
The current minimum accuracy for these instruments is 0.18 *F." For the instrument at elevation 142 feet, and the instrument at elevation 374 feet, the revised minimum accuracy will be "i 0.56 *C (i 1.0 *F)."
- 3. modifying Bases Section B3/4.3.3.4 to state that the instrumentation used to monitor air temperature - delta T and wind speed (when wind speed is greater than 2.2 m/sec (5 mph)) does not meet the recommendations of Regulatory Guide 1.23 regarding accuracy.
- 4. providing the concurrent metric equivalent for the elevations (43.3 meters and 114 meters).
8 P. M. Richardson letter to U.S. Nuclear Regulatory Commission, Licensee Event Report 50-336/96-034-00, dated December 9,1996.
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', U.S. Nuclear Regul tory Commission B16343/ Attachment 1/Page 4
- 5. providing the concurrent British equivalent for the starting threshold of the anemometer (1.0 mph).
Safety Assessment The proposed license amendment request modifies the minimum accuracy requirements for the instruments used to measure wind speed and air temperature -
delta T to comply with Technical Specification 3/4.3.3.4, and it modifies Bases Section 3/4.3.3.4 to identify that the instrumentation used to monitor air temperature - delta T and wind speed (when wind speeds are greater than 2.2 m/sec (5 mph)) does not meet the accuracy requirements of Regulatory Guide 1.23.
The data from the meteorological instrumentation are used to:
a) estimate public dose from routine or accidental releases of airborne radioactivity; b) make decisions regarding actions to take to protect the public in the event of an accident involving the release of airborne radioactivity; and j
c) establish radiological dispersion parameters to determine radiological doses in design basis accident calculations.
The proposed minimum instrument accuracy requirements are more than sufficient to meet the purposes denoted above.
The meteorological parameters measurement uncertainties insignificantly affect the results when compared to the accuracies of the source term estimates, meteorological dispersion models, dose models, and meteorological forecasting. In addition, the calculations performed to determine the instrument uncertainties did not conclude that there is any consistent instrument bias in one direction of a measured parameter. Therefore, there should be no impact on offsite doses associated with previously evaluated accidents, or accuracy in performing other dose assessments.
The proposed changes do not alter the way any structure, system, or component functions and do not alter the manner in which the plant is operated. They do not have any impact on the protective boundaries (e.g., fuel matrix and cladding, reactor coolant system pressure boundary, and primary and secondary containment), or on the safety limits for these boundaries. Therefore, the change can not impact the probability of initiation of an accident and can not impact the probability that mitigating equipment will fail.
The proposed changes do not alter how any instruments, safety systems or components function. However, they modify the accuracy requirements for the instruments which are used to measure wind speed and air temperature - delta T. The data obtained from these instruments are used to estimate the public dose following routine or accidental releases of aist>ome radioactivity and make decisions regarding actions to protect the public in the
, U.S. Nuclear Regulctory Commission B16343/ Attachment 1/Page 5 event of an accident involving a release of airborne radioactivity. The uncertainties medalM with the measurement of meteorological parameters insignificantly affect the results when compared to the accuracies of the source term estimates, meteorological disperson models, dose models, and meteorological forecasting. Thus, the changes should not asect the probability that the operators or the Emergerry Plan personnel will fail to mdigate an accident.
Thus, the proposed license amendment request does not have a significant impact on public health and safety.
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Docket No. 50-336 B16343 1
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Millstone Nuclear Power Station, Unit No. 2
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l Proposed Revision to Technical Specifications Meteorological Instrumentation i
Significant Hazards Consideration f
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' U.S. Nuclear Regulatory Commission
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Proposed Revision to Technical Specifications Meteorologicalinstrumentation Significant Hazards Consideration 3
Sionificant Hazards Consideration l
In accordance with 10CFR50.92, NNECO has reviewed the proposed changes and has concluded that they do not involve a significant hazards consideration (SHC). The
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basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes i
would not:
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Involve a significant increase in the probability or consequenco of an accident previously evaluated.
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3 The proposed changes modify the accuracy requirements for the instruments which are used to measure wind speed and air temperature - delta T. The data l
obtained from the meteorological instrumentation would be used to: a) estimate l
the public dose following routine or accidental releases of airborne radioactivity, b) make decisions regarding actions to protect the public in the event of an accident involving a release of airborne radioactivity, and c) establish radiological dispersion parameters to determine radiological doses in design
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basis accident calculations.
The proposed minimum instrument accuracy requirements are more than j
sufficient to meet the purposes denoted above. The meteorological parameters measurement uncertainties insignificantly affect the results when compared to i
the accuracies of the source term estimates, meteorological dispersion models, dose models, and meteorological forecasting. Therefore, there is no impact on i
the consequences (offsite doses) associated with previously evaluated accidents.
j The proposed changes do not alter the way any structure, system, or component functions, do not alter the manner in which the plant is operated, and do not have any impact on the protective boundaries and safety limits for the protective l
boundaries. Therefore, the proposed changes do not impact the probability of any previously evaluated accidents.
Thus, the license amendment request does not impact the probability of an accident previously evaluated nor does it involve a significant increase in the consequence of an accident previously evaluated.
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B16343/ Attachment 2/Page 2 o
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Create the possibility of a new or different kind of accident from any accident j
previously evaluated.
l The proposed changes modify the accuracy requirements for the instruments which are used to measure wind speed and air temperature - delta T. The data 3
provided by these instruments assist in respondino to a design basis accident which may involve a release of airborne radioactivity. The instruments are used 1
for post accident monitoring and serve a passive role; they cannot initiate or mitigate any accident.
1 The proposed changes do not alter the way any structure, system, or component functions and do not alter the manner in which the plant is operated. They do l
not introduca any new failure. modes.
Thus, the license amendment request does not create the possibility of a new or 4
different kind of accident from any previously analyzed.
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Involve a significant reduction in a margin of safety.
As discussed above, the proposed changes modify the accuracy requirements for the instruments which are used to measure wind speed and air temperature -
delta T which could impact the radiological dispersion coefficient used to 4
determine radiological doses in design basis accident calculations. However, the differences in the instrument accuracies and the Regulatory Guide 1.23 i
requirements have been determined not to significantly affect the dispersion coefficients. Thus, there is no significant impact on offsite doses associated with previously analyzed accidents. Therefore, there is no significant reduction in the margin of safety for the design basis accident analysis.
Thus, the license amendment request does not involve a significant reduction in the margin of safety, i
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