ML20206C876

Safety Evaluation Supporting Amend 194 to License DPR-61

ML20206C876
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	04/28/1999
From:	NRC (Affiliation Not Assigned)
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ML20206C867	List: ML20206C863 ML20206C873 ML20206C876
References
NUDOCS 9905030231
Download: ML20206C876 (4)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.194 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT DOCKET NO 50-213

1.0 INTRODUCTION

By letter dated June 2,1998, as supplemented January 18 and March 9,1999, the Connecticut Yankee Atomic Power Company (CYAPCO, the licensee) submitted a proposed revision to the Haddam Neck Plant Technical Specifications (TSs). The June 2 letter proposed to relocate the requirements for a seismic monitor to the Technical Requirements Manual (TRM),

consistent with the guidance contained in Generic Letter 95-10, Relocation of Selected Technical Specification Requirements Related to Instrumentation. The proposed amendment fulfills a commitment that CYAPCO made to the NRC in Licensee Event Report (LER)

LER 50-213/1998-001-00, dated May 7,1998.

By letter dated January 18,1999, CYAPCO submitted a revised page of its Updated Final Safety Analysis Report (UFSAR), which incorporated Section il of its TRM by reference and l stated that changes to the TRM require a [10 CFR) 50.59 Safety Evaluation. The January 18 letter also submitted a revision to Section 11 of its TRM, which contained the TS requirements for seismic monitoring.

l By letter dated March 9,1999, CYAPCO submitted an additional clarification of its proposed revision.

, The January 18 and March 9,1999, letters did not contain any information outside the scope of the initial Federal Reaister notice,

2.0 BACKGROUND

Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to state the TS to be included as part of the license.

The Commission's regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36. That regulation requires the TS to include items in five specific categories:

(1) safety limits, limiting system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

However, the regulation does not specify the particular requirements to be included in a plant's TS.

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2- )i The four criteria defined in 10 CFR 50.36 to be used in determining whether a particular matter is required to be included in the TS are as follows:

(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; j (2) a process variable, design feature, or operating restriction that is an initial condition of a design-basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design-basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

As a result, existing TS requirements, which fall within or satisfy any of the criteria in the regulation, must be retained in the TSs, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other licensee-controlled documents. )

3.0

SUMMARY

OF PROPOSED CHANGES The following information will be deleted from the TSs and transferred to the TRM:

3/4.3.3.3 Seismic Instrumentation Table 3.3-5 Seismic Monitoring Instrumentation Table 4.3-4 Seismic Monitoring Instrumentation Surveillance Requirements 4.0 DISCUSSION AND EVALUATION LER 50-213/1998-001-00 contained commitment number CY-98-048-01, which stated, "A proposed modification to the Haddam Neck Plant's technical specifications will be submitted to the NRC by July 1,1998." The licensee submitted a license amendment request on June 2,1998, which proposed a modification to the seismic monitoring instrumentation requirements. The licensee has, therefore, fulfilled its commitment.

The licensee proposed a relocation of the requirements for seismic monitoring instrumentation to the TRM and a correction of a typographical error.

Section Vi(a)(3) of Appendix A to 10 CFR Part 100 requires that seismic monitoring l instrumentation be provided to promptly determine the response of those nuclear power plant features important to safety in the event of an earthquake. This capability is required to allow for a comparison of the measured response to that used in the design basis for the unit. 1 L Comparison of such data is needed to determir'e whether the plant can continue to be operated l safely and to permit such timely action as may be appropriate. However, the capability of a L.

plant to withstand a seismic event or other design-basis accident is determined by the initial design and construction of systems, structures, and components. The seismic instrumentation is used after the initiating event occurs to alert operators and to evaluate the plant response.

Seismic monitoring instrumentation requirements do not meet the four criteria of 10 CFR 50.36 and are not required to be included in the TSs as discussed below.

Regarding the first criterion, the Final Commission Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors (58 FR 39132) explained that instrumentation to detect precursors to reactor coolant pressure boundary leakage, such as seismic instrumentation is not included as a first criterion. Regarding the second criterion, the seismic instrumentation does not serve as a process variable, protective design feature, or operating restriction that is an initial condition of a design-basis event, which challenges fission product barriers. Regarding the third criterion, seismic instrumentation is not part of a primary success path and does not actuate any protective equipment or serve any direct role in the mitigation of a design-basis accident. Regarding the fourth criterion, the seismic instrumentation does affect the probability or consequences of a seismic event, and is not significant to public health and safety. The staff has co'icluded that the seismic monitoring instrumentation does not satisfy the 10 CFR 50.36 criteria and may be relocated to a licensee-controlled document.

By letter dated January 18,1999, the licensee proposed a method to relocate seismic monitoring requirements to a licensee-controlled document. The January 18 letter contained copies of approved changes to its UFSAR and TRM. The approved changes have incorporated Section 11 of the TRM into the UFSAR by reference and will transfer seismic monitoring instrumentation TS requirements to Section 11 of the TRM. By incorporating the TRM into its UFSAR, changes to the TRM are subject to the requirements of 10 CFR 50.59. The staff concludes that sufficient regulatory controls exist to adequately protect public health and safety.

In addition, the licensee provided a commitment to implement changes to the TRM concurrent with implementation of the license amendment.

The licensee corrected a typographical error in the measurement range of the Triaxial Servo Accelerometer. Upon transfer from the TSs to the TRM, the measurement range will be corrected from "O to 0.59" to "O to 0.5g." The licensee stated that the revised measurement range is adequate to determine if earthquake motion is within the design basis of the plant.

Based on the preceding facts, the staff finds that the relocation of seismic monitoring instrumentation requirements from the TSs to the TRM is acceptable.

5.0 STATE CONSULTATION

in accordance with its regulations, on October 20,1998, the State of Connecticut official was notified of the proposed issuance of the amendment. The State official had no comment.

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4 60 ENVIRONMENTAL CONSIDERATION The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the proposed amendment involves no significant hazards consideration, and there has been no public comment on such finding (63 FR 50936, September 23,1998). Accordingly, the amendment meets the eligibility enteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with the issuance of die amendment.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Thomas L. Fredrichs Date: April 28, 1999