ML20151L622
| ML20151L622 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/15/1988 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20151L628 | List: |
| References | |
| B12888, NUDOCS 8804220097 | |
| Download: ML20151L622 (7) | |
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(N P O. BOX 270 H ARTFORD. CONN ECTICUT 06141-0270 k k J I. ,NC.Y,$2. (203) 665 5000 April 15, 1988 Docket No. 50-423 B12888 Re: 10CFR50.90 and 50.91 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Reference:
(1) E. J. Mroczka letter to U.S. Nuclear Regulatory Commission Document Control Desk, "Millstone Nuclear Power Station, Unit No. 3, Temporary Waiver of Compliance From Technical Specifications - Limiting Condition for Operation", dated April 14, 1988.
(2) 8. A. Boger letter to E. J. Mroczka, "Temporary Waiver of Compliance From Technical Specification 3.6.3, Containment Isolation Valves," dated April 15, 1988.
Gentlemen:
Millstone Nuclear Power Station, Unit No. 3 Proposed Revision to Technical Specifications Containment Isolation Valves - Limitina Condition for Operation Pursuant to 10CFR50.90 and 50.91, Northeast Nuclear Energy Company (NNECO) hereby requests amendment of Operating License No. NPF-49 for the Millstone Nuclear Power Station, Unit No. 3, by incorporating the attached change into the plant Technical Specifications.
The proposed change would amend the Technical Specifications to allow start-up of the plant while utilizing the provisions of the ACTION statement associated with Technical Specification 3.6.3. Technical Specification 3.0.4 currently prohibits mode changes unless the requirements of all the Limiting Conditions for Operation (LCOs) are met without reliance on any ACTION statement. A change is proposed to Technical Specification 3.6.3 th t would allow changes in operational mode while utilizing ACTION statement (b) or (c).
Reference (1) requested a temporary waiver of compliance from Technical Specification 3.0.4 to LCO 3.6.3 until an emergency license amendment is processed. The temporary waiver of compliance from Technical Specification 3.6.3 was issued on April 15, 1988 (Reference (2)). NNECO requests that this amendment be issued on an emergency basis in accordance with 10CFR50.91(a)(5).
As discussed below, this request involves no significant hazards consideration and failure to act promptly would prevent start-up of the plant. Plant start-up (i.e., criticality) is currently scheduled for April 16, 1988. grl ,
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U.S. Nuclear Regulatory Commission B12888/Page 2 April 15, 1988 Backaround and Summary On March 1,1988, while performing the biennial sample line valve position indication testing, it was discovered that two inside containment isolation valves would not open and a third isolation valve inside containment was found leaking. Specifically, the Pressurizer Relief Tank (PRT) gas sample line (3/4") isolation valve 3SSR*CV8026 and the pressurizer vapor space sample line (3/4") isolation valve 3SSR*CTV20 would not open to perform Technical Specifi-cation required surveillance testing and this precluded surveillance of the outside containment isolation valves 3SSR*CV8025 and 3SSR*CTV21. The third valve, pressurizer liquid sample line (3/4") isolation valve 3SSR*CTV22, was leaking. Therefore, these valves were considered to be inoperable on March 1 and compensatory measures were tal:9 as required by the ACTION statement of 3.6.3.b of the Millstone Unit No. J Technical Specifications. Specifically, corresponding outside containment isolation valves 3SSR*CV8025, 3SSR*CTV21, and 3SSR*CVT23 were closed and power was removej from the valve operators.
Millstone Unit No. 3 was in Mode 1 at that time rod, as allowed by the ACTION statement of Technical Specification 3.6.3, continued operation until the unit 5 tripped on April 13, 1988 due to low condenser vacuum causing . turbine and reactor trip. The low condenser vacuum was caused by automatic tripping of two circulation water pumps in the intake structure due to high differential pressure across the traveling screens.
Millstone Unit No. 3 Technical Specification Section 3.0.4 states that entry into an operational mode or other specified condition shall not be made unless all LCOs are met without reliance on the provisions of the ACTION statements.
The intent is to ensure that a higher mode of operation is not entered when equipment is inoperable. This precludes a plant start-up if an LC0 is not met, even if the ACTION statements would permit continued operation of the plant for an unlimited period of time. Generally, the individual specifica-tions that have ACTION statements which allow continued operations note that Specification 3.0.4 does not apply.
However, exceptions to Specification 3.0.4 have not been consistently applied.
This is true in the case of Specification 3.6.3. Millstone Unit No. 3 Tech-nical Specifications are based on Westinghouse Standard Technical Specifica-tions (STS). Exceptions to Specification 3.0.4 have not been applied to the STS Section 3.6.3, "Containment Isolation Valves". Generically, the NRC has recognized this inconsistent application of exceptions to Specification 3.0.4.
To alleviate this problem, on June 4, 1987, the NRC issued Generic Letter 87-09, "Section 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of limiting Conditions for Operation and Surveillance Requirements". In that Generic Letter the Staff addressed three specific problems and provided alternatives to the STS to resolve these problems. The Staff also encouraged the licensees to propose changes to their Technical Specifications that will be consistent with the guidance provided in the enclosure of the Generic Letter. NNECO has not previously submitted any changes to Specifications 3.0 and 4.0 due to generic industry concerns with Generic Letter 87 09 which were recently resolved with the NRC. NRC approval
U.S. Nuclear Regulatory Commission B12888/Page 3 April 15, 1988 for the lead Owner's Group plant is expected shortly and NNECO plans to eventually submit a proposed license amendment, as offered by Generic Letter 87-09. A comprehensive, plant-specific review of the applicability of the provisions of the Generic Letter will, of course, precede submittal of the amendment request.
Further, for the reasons discussed herein, NNECO requests, pursuant to 10CFR50.91(a)(5), that this amendment be issued on an emergency basis to permit timely resumption of Millstone Unit No. 3 operation. NNEC0 demon-strates below th at this revision presents no significant hazards considera-tion. In faci *he request is consistent with recent Staff guidance regarding s
modification r Tschnical Specification LCOs which impose unnecessary restric-tions on modo clanges. Further, the need to request the amendment on an emergency basis could not have been reasonably avoided as explained below.
Repair of thest. valves inside containment can only be accomplished with containment at 4tmospheric pressure. Working in the subatmospheric contain-ment is limited to inspections and work durations of less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Replssement of the solenoid valves will likely require grinding out the damaged valve and welding a new valve in place. Relaxing the subatmospheric condition in the containment is permitted only when the plant is cold in shutdown (Mode 5) or refueling (Mode 6). For these reasons, issuance of the requested amendment on an emergency basis is warranted.
Justification for Emeraency License Amendment Pursuant to 10CFR50.91(a)(5), NNECO requests NRC approval of the License amendment described herein on an emergency basis. Emergency approval is appropriate because "an emergency situation exists, that failure to act in a timely way would result in . . . prevention of either resumption of oporation or of increase in power ou?put to the plant's licensed power level . . . " and because, as discussed below, the amendment does not involve a significant hazards consideration.
Presently, Millstone Unit No. 3 is in Mode 3 since the plant tripped on April 13, 1988 and emergency authorization is required to permit timely resumption of operation (i.e. criticality) which is currently scheduled for April 16, 1988. On March 1,1988 as a result of surveillance testing of affected sample lines, the containment isolation valves for the three sample lines were declared inoperable and compensatory measures were taken as required by the ACTION statement of 3.6.3.b of the Millstone Unit No. 3 Technical Specifica-tions. Specifically, corresponding containment isolation valves were closed and power was removed from the valve operators. Millstone Unit No. 3 was in Mode 1 at that time and continued to operate as allowed by the ACTION state-ment of Technical Specification 3.6.3. Repair of these valves inside contain-ment can only be accomplished with containment at atmospheric pressure and relaxing the subatmospheric condition in the containment is permitted only when the plant is in cold shutdown (Mode 5) or refueling (Mode 6). NNECO could not have reasonably anticipated the reactor trip which occurred on April 13,1988. Approval of this amendment will prevent a thermal cycle to
U.S. Nuclear Regulatory Commission B12888/Page 4 April 15, 1988 cold shutdown and return to the normal operating temperature of 5570. In summary, therefore, emergency approval is warranted for this license amendment since an unavoidable emergency situation has resulted in the plant not being able to resume power operation and since the license amendment involves no significant hazards consideration.
Acolicability of Generic letter 87-09 In addition to technical justification described herein, NNECO notes that the proposed amendment is consistent with a recent NRC Staff position encouraging revision of Technical Specifications which ipvolve unnecessary restrictions on mode changes. In Generic Letter 87-09,II' the Staff describes acceptablu revisions of three areas of current Technical Specifications. One of those areas concerns LCOs applicable to entry into an operational mode which are more restrictive than ACTION statements applicable to the operational mode itsel f. As an example of this conditica, the Generic Letter describes the situation where ACTION statements would permit operation for an unlimited period of time under conditions for which an LCO would prohibit start-up.
(See Generic Letter 87-09 Enclosure 1, Problem No.1, pp.1-3.) The present request involves a change to Technical Specifications precisely as is offered in the Generic letter.
Specifically, although operation for an unlimited time is permitted with one or more isolation valves inoperable, the LCO for entry into an operational mode is more restrictive; i.e., all isolation valves in Table 3.6-2 must be OPERABLE.
Accordingly, NNECO submits that the present amendment request would be appro-priate, irrespective of the current situation. In fact, this emergency amendment represents one very limited aspect of the eventual scope of Generic Letter 87-09 driven changes to the Technical Specifications which we envision making in the longer term. NNECO, of course, does not favor commencing operation with equipment unavailable, independent of whatever provisions the Technical Specifications may contain. However, as explained herein, these containment isolation valves which are inoperable are not required for safe plant operation and, as required by the Technical Specification 3.6.3 ACTION statement, the affected penetrations are maintained in the safe (isolated) configuration. Consequently, NNECO believes the compelling considerations discussed herein fully justify issuance of this amendment. We will be evaluating the full scope of options presented in Generic Letter 87-09 on a more deliberate basis and will address them via separate correspondence.
(1) Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements" (June 4, 1987).
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j U.S. Nuclear Regulatory Commission l B12888/Page 5 April 15, 1988 i i
Safety Stanificance j
The proposed change would allow plant start-up while subject to the provisions i of ACTION statement 3.6.3.b or c. These ACTION statements require that each :
containment penetration with an inoperable containment isolation valve be !
I isolated within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by use of at least one deactivated automatic valve !
- . secured in the isolated position, or by use of a closed manual valve or blind l flange. l
- The basis for the operability requirements for containment isolation valves in
- Technical Specification 3.6.3 is to ensure that the associated containment
- penetrations can be isolated when required. If the requirements of ACTION (b) !
i or (c)-are met (e.g. - valve closed and deactivated) then the safety function is satisfied and the affected penetration would not be a leakage pathway.
Thus, there would be no impact on the consequences of any design basis acci- !
i dent. j
- It is noted that if this ACTION statement were entered during power operation !
i and the ACTION requirements satisfied, operation could continue indefinitely i and shutdown would not be required. Since, for containment isolation purposes l l there is no difference between start-up and steady-state operation, it is ;
- concluded that starting up with the isolation valves closed and deactivated or i
- isolated with a blind flange would have no adverse impact on any design basis i 1 accident. j Sionificant Hazards Consideration In accordance with 10CFR50.92, NNECO has reviewed the attached proposed change r
- and has concluded that it does not involve a significant hazards considera- i tion. The basis for this conclusion is that the three criteria of i
! 10CFR50.92(c) are not compromised. The proposed change does not involve a !
j significant hazards consideration because the change would not: i s i l 1. Involve a significant increase in the probability or consequences of an !
I accident previously evaluated. The proposed change has no impact on the :
1 probability of an accident. With respect to consequences, allowing plant l start-up with isolation valves closed and de-energized or the penetration l isolated with a blind flange provides at least the same level of assur- i i ance that the affected penetrations will be isolated when required. f i Since the ability to isolate the containment is not adversely affected, !
.there can be no adverse impact on the consequences of any accident, j
- 2. Create the possibility of a new or different kind of accident from any ;
j accident previously evaluated. The proposed change will not affect plant j c response in any way, and there are no new failure modes associated with j j the change that could create a new accident. The specific valves which ;
l are inoperable have no safety function other than containment isolation, !
i which is satisfied by meeting the ACTION statements. These valves are l
! not associated with a post accident situation, t i !
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i U.S. Nuclear Regulatory Commission B12888/Page 6 April 15, 1988 l j
- 3. Involve a significant reduction in safety margin. The proposed change will apply only when the inoperable containment isolation valve (s) are isolated by use of at least one deactivated automatic valve secured in the closed position or by use of a closed manual valve or blind flange.
In this position, the penetration is isolated. Therefore, the proposed change does not have any adverse impact on the containment boundary.
Allowing plant start up in this configuration involves no adverse impact.
The basis of Technical Specification 3.6.3 is to ensure that the contain-ment can be isolated from the outside atmosphere when required. Allowing 31 ant start-up with affected penetrations isolated is consistent with the 3 asis of this Technical Specification.
In summary, for the reasons above, NNECO has concluded that start-up and operation of the facility in accordance with the proposed amendment would not involve a significant hazards consideration.
Moreover, the Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986) of amendments that are considered not likely to involve significant hazards consideration. Although the proposed change herein is not enveloped by a specific example, the proposed change would not involve a significant increase in the probability or consequences of an accident previously analyzed. Since the ability to isolate the containment is not adversely affected, there can be no adverse impact on the consequences of any accident.
It is also reiterated that the subject amendment request conforms precisely to t %t encouraged by the Staff via Generic Letter 87-09.
fpnclusion 4
for reasons presented above, NNECO requests, pursuant to 10CFR50.91(a)(5), an emergency amendment of the Millstone Unit No. 3 Technical Specifications to allow start-up with containment isolation valves inoperable previding they meet ACTION statement 3.6.3.b or c. We respectfully request that this amendment be issued before the temporary waiver expires.
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 that the proposed licence amendment will not have a significant effect on the quality of the hun n environment.
The Millstone Unit No. 3 Nuclear Review Board has reviewed and approved this proposed amendment and concurs with the above determinations.
In accordance with 10CFR50.91(b), NNECO will provide the State of Connecticut with a copy of this proposed amendment to ensure their awareness of this i request.
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U.S. Nuclear Regulatory Commission B12888/Page 7 April 15, 1988 Pursuant to 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.00.
We believe the above information coupled with the information provided in Reference (1) provides a complete basis for approval of the requested amend-ment. Of course, should the Staff have any additional questions, NNECO will be available to address the Staff's questions.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
- 4 E." # Mroczka /
Senior Vice President cc: 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 Mr. Kevin McCarthy, Director Radiation Centrol Unit Connecticut State Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT ss. Berlin COUNTY OF HARTFORD Then personally appeared before me, E. J. Mroczka, who being duly sworn, did state that he is Senior 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 Licensee herein and that the statement contained in said information are true and correct to the best of his knowledge and belief, tAhdki Nbtary Publi{/
b !&~Y 14 C:=' :Sn e Ex'*es March 31,l993