ML20149E072
| ML20149E072 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/05/1988 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20149E077 | List: |
| References | |
| B12792, NUDOCS 8802100212 | |
| Download: ML20149E072 (4) | |
Text
4 NORTHEAST UTILITIES o.n.r.i ome... s.io.n sir i. B.<4,n. connect,cui O
HhRTFORD CONNECTICUT 061410270 1 J $,$[C$C MNN k
L Februsry 5, 1988 Docket No. 50-423 B12792 Re:
10CFR50.90 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Reactor Coolant System Leakacte Detection Systems Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) 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.
DiscussiqD Currently the Millstone Unit No. 3 Technical Specifications are based on the assumption that there are three independent leakage detection systems.
In
- reality, the containment atmosphere gaseous monitor and the containment atmosphere particulate monitor are a common system sharing a common sample point, sample lines, isolation valves, sample fan, radiation monitor skid and power supply.
The only independence is that there are two detectors with associated electronics; one looking at a particu-late filter and the other at a gas chamber.
Should one of the common components in the system fail, both systems will fail, thereby placing the unit in an action statement requiring shut-down in six hours.
Plant shutdown is unnecessary in this case, since adequate capability still exists to detect primary system leakage.
The containment sump monitoring capabilities are still j
available and containment atmosphere airborne levels will be determined using grab samples.
i The changes to Technical Specification Section 3.4.6.1 clarify i
that primary system leakage at Millstone Unit No. 3 is monitored by two techniques and not three.
The requirements of Regulatory Guide 1.45 are satisfied by employing separate detection methods for monitoring airborne radioactivity and sump level as discussed in FSAR Section 5.2.5 and SER Section 5.2.5.
Airborne radioac-tivity is monitored using the particulate and/or gaseous monitor g(
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U.S.
liuclear Regulatory Commission B12792/Page 2 February 5, 1988 and the liquid volumes are monitored using the sump level and/or pumped capacity system.
Loss of one technique is acceptable for thirty days provided the other technique is available.
These changes to the Technical Specifications allow greater flexibility with both the particulate and the gaseous radioactivity monitors inoperable.
The thirty day action statement allows adequate time to repair or replace the inoperable components.
The proposed action statement for the inoperable airborne monitors also requires more frequent grab sampling (once overy 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as opposed to once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) and further clarifies the analy-sis requirements.
The proposed changes require that analysis for the sample be performed within the subsequent 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, which is more restrictive than the current Technical Specifications.
The proposed action statement for inoperable containment drain sump level and pumped capacity monitoring systems, although worded differently, remains the same as the current specification.
Both allow up to 30 days of continued operation in the Action State-ment.
Based on the above discussion, litiECO has determined that there is no change in the radioactivity detection capability of the RCS leakage detection system due to the proposed changes.
Sionificant Hazards Consideration litiECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that they do not involve a signifi-cant hazards consideration in that these changes would not:
1.
Involve a significant increase in the probability of occur-rence or consequences of an accident previously analyzed.
The revised operability requirements will not provide a significant degradation in the Reactor Coolant System leakage detection capability.
These changes do not adverse-ly affect the consequences of the design basis accidents.
Therefore, it is concluded that previously analyzed acci-dents are not affected.
2.
Create the possibility of a new or different kind of acci-dent from any previously analyzed.
Since there are no changes in the way the plant is operated, the potential for an unanalyzed accident is not created.
lio new failure modes are introduced.
3.
Involve a significant reduction in a margin of safety.
The proposed requirements do not have any adverse impact on the containment integrity.
Since the proposed changes do not affect the conseqdences of any accident previously analyzed, there is no reduction in the margin to safety.
j r
U.S. Nuclear Regulatory Commission B12792/Page 3 February 5, 1988 Moreover, the Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March 6, 1986, FR7751) of amendments that are consid-ered not likely to involve a significant hazards consideration.
The proposed changes are enveloped by example (ii), a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, e.g., a more stringent surveillance requirement.
Although the 30 day action statement is a less restrictive requirement for RCS leakage monitoring, more stringent surveillance requirements have been established.
The proposed changes require that grab samples of the containment atmosphere be obtained at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzed within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
This requirement is more restrictive than the current technical specification which requires that grab samples of the containment atmosphere be obtained and analyzed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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 ef fect on the quality of the human envi-ronment.
The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.
I In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.
l Pursuant to the requirements of 10CFR170.12(c),
enclosed with this amendment request is the application fee of $150.
l Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY f4 ?
E. Xftbczka (/
Senior Vice President l
l cc:
Kevin McCarthy, Director
'l Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 i
i U.S. Nuclear Regulatory Commission B12792/Pago 4 February 5, 1988 l
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 personally appeared before ne E. J.
Mroczka, who being duly sworn, did state that ho is Senior Vice President of Northeast Nuclear Energy Company, a Licensec 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.
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