B12821, Application for Amend to License NPF-49,changing Tech Spec Section 3.3.3.9 & 3.3.3.10 to Revise Applicability of Limiting Condition for Operation to Allow Removal of Liquid & Gaseous Effluent Monitors from Svc.Fee Paid
| ML20147C273 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/24/1988 |
| From: | Mroczka E, Sears C NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20147C283 | List: |
| References | |
| B12821, NUDOCS 8803030041 | |
| Download: ML20147C273 (4) | |
Text
/
O NORTHEAST UTRUTIES o.n.,e ome... s m.n street. somn. conn.cocui t
j 03) 5-February 24, 1988 4
50-243'/) 3 7 Docket No.
B12821 Re: 10CFR50.90 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C. 20555
References:
(1)
E. J. Mroczka letter to U.S Nuclear Regulatory Commission, Radioactive Effluent Monitoring, dated November 2,1987.
(2)
E.
J.
Mroczka letter to U.S.
Nuclear Regulatory Commission, Radioactive Effluent Monitoring, dated December 18, 1987.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Radioactive Liouid and Gaseous Effluent Monitorina Instrumentation Pursuant to 10 CFR 50.90, Northeast Nuclear Energy Company (NfiECO) hereby proposes to amend its Operating License, NPF-49, by incorporating the changes identified in Attachment 1 into the Technical Specifications of Millstone Unit No. 3.
Specifically, the proposed changes to Technical Specification Section 3.3.3.9 and 3.3.3.10 will revise the applicability of the Limiting Condition for Operation (LCO) to allow removal of the liquid and gaseous effluent monitors from service for a limited period of time (up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) for testing, calibrations, etc. A change is also proposed to ACTION #35 in Table 3.3-13 to require that auxiliary sampling be initiated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when in this ACTION statement.
Currently, there is no time frame specified in this actier, statement.
Discussion Radiation monitors must occasionally be taken out of service for short periods i
of time in order to perform calibrations, change filters, oil pumps, etc.
Currently these effluent monitors are required to be OPERABLE "at all times",
which could be interpreted as meaning that the ACTION statement is entered voluntarily whenever maintenance or testing is performed on the monitors.
The proposed changes will now explicitly allow a monitor to be taken out of A
service for up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for maintenance / testing without entering the ACTION 60 8803030041 880224 PDR ADOCK 05000423 0
4 P
ppg i
i \\
U.S. Nuclear Regulatory Commission B12821/Page 2 February 24, 1988 statement.
Similar changes to the Millstone Unit No.
2 Technical Specification were submitted to the NRC (Reference 1).
Also, the information related to the sampling process included in Reference (2) is also applicable to the proposed changes included herein.
Sionificant Hazards Consideration In accordance with 10CFR50.92, NNEC0 has reviewed the attached proposed changes and has concluded that they do not involve a significant hazards consideration.
The basis for this conclusion is that the three criteria of 10 CFR 50.92(c) are not compromised.
The proposed changes do not involve a significant hazards consideration because the changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes will not change the way in which the effluent monitors operate nor change any of their control functions.
These changes will not have any irmact on the probability of an accident.
None of the affected instrumentation is required to mitigate the consequences of any design basis accident.
While some of these monitors may be used in the emergency operating procedures, they are not the sole indicator available.
For example, steam generator blowdown radiation can be used as one (but not the only) indication of a steam generator tube rupture.
Furthermore, the proposed changes would only allow these radiation monitors to be out of service for a short period of time (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />).
The twelve hours is less than one percent of the hours in a calendar quarter, the time period over which off-site close limits are based.
The loss of effluent data for this short period of time should have little or no effect on the accuracy of the calculations.
Although theoretically the instruments could be out-of-service for more than twelve hours in a particular calendar quarter, past experience at all NNEC0's nuclear units has shown that for the specific purposes intended, these instruments are not out-of-service for more than twelve hours per average calendar quarter.
Based on these factors, it is concluded that the proposed changes will not have any impact on the consequences of an accident.
2.
Create the possibility of a new or different kind of accident from any previously evaluated.
The proposed changes will not change the way in which the effluent monitors are operated.
The proposed changes also have no effect on alarm setpoints or control functions.
Further, no operator actions that are required to mitigate any accident rely solely on these monitors, and these monitors provide no protective functions.
Therefore, the proposed changes cannot have any impact on plant response or create the possibility of a new or different kind of accident.
3.
Involve a significant reduction in a margin of safety.
Since the proposed changes do not have any impact on the consequences of a design basis accident and they do not create the possibility of a new or different kind of accident, they cannot cause a significant reduction in the margin of safety.
U.S. Nuclear Regulatory Commission B12821/Page 3 February 24, 1988 Moreover, the Commission has provided guidance concerning the application of standards in 10 CFR 50.92 by providing certain examples (March 6,
- 1986, FR7751) of amendments that are considered not likely to involve a significant hazards consideration. Although the proposed changes herein are not enveloped by a specific example, the proposed changes would not involve a significant increase in the probability or consequences of an accident previously analyzed. As stated earlier, the proposed changes will not change the way in which the effluent monitors operate nor change any of their control functions.
In addition, none of the affected instrumentation is required to mitigate the consequences of any design basis accident.
The proposed changes would only allow these radiation monitors to be out of service for a short period of time (12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />), which is comparable to the time frame allowed for other equipment.
Therefore, it is concluded that the proposed changes will not have any impact on the consequences of an accident.
Based upon the information contained in this submittal and the environmental assessment for Millstone Unit No. 3, there are no significant radiological or nonradiological impacts associated with the proposed action, and the proposed license amendment will not have a significant effect on the quality of the human environment.
The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.
In accordance with 10 CFR 50.91(b) we are providing the State of Connecticut with a copy of this proposed amendment.
Pursuant to the requirements of 10 CFR 170.12(c), enclosed with this amendment request is the application fee of $150.00 Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Y,
. Y (LOG hl E. J. Mroczka V
Senior Vice President L(t%L By:
C. F. Sears Vice President Attachment
p
~
d;.
4 se i t 15 U.S. Nuclear Regulatory Commission jj B12821/Page 4 February 24, 1988 cc: Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 W. T. Russell, Region I Administrator R. L. Ferguson, NRC Project Manager, Millstone Unit No. 3 W.'J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3 STATE OF CONNECTICUT )
) ss. Berlin COUNTY OF HARTFORD
)
Then prsonally appeared before me C. F. Sears, who being duly sworn, did state: G at he is Vice President 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.
/Ahninl.
huir Notary Pub Ry Comm!ssion Exp!res thrch 31,1938 a
k