ML20210A345
| ML20210A345 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/29/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20210A248 | List: |
| References | |
| NUDOCS 8702060459 | |
| Download: ML20210A345 (8) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION g
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,,,,e SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT N0. 1 TO FACILITY OPERATING LICENSE NO. DPR-21 NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION, UNIT N0. 1 DOCKET N0. 50-245
1.0 INTRODUCTION
By letter dated January 10, 1986, the Northeast Nuclear Energy Company (NNECO) submitted a request for changes to the Millstone Nuclear Power Station, Unit No. 1.
The changes pertain to the condensate demineralizer resin. The condensate demineralizer system maintains the purity of the reactor coolant water.
The demineralizer system removes corrosion products picked up by the condensate main and extraction steam, protects the reactor against the effects of condenser tube leaks that would allow contamination of the reactor coolant water by sea water, and removes impurities which might enter the system in the make up water.
This section of the amendment would change:
1.1 Existing Technical Specification 3.6.J.1 to:
3.6.J.1 Regeneration and/or replacement of a condensate dimineralizing resin charge shall occur before the unused capacity of the resin reaches a minimum value of 30 pounds as chloride ions.
The underlined words "and/or replacement" added to the existing technical specification constitutes this change.
" Charge" corrects a typo, i.e. change to charge.
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1.2 Existing Technical Specification 3.6.J.2 to:
3.6.J.2 If the charge is regenerated, the anion resins in the condensate demineralizing system shall have a minimum salt-spitting capacity of 0.75 milliequivalents per milliliter in the wet, chloride form. Anion resins which do not have a capacity of 0.75 milliequiva-lents per milliliter will be replaced with new resin as will the cation resin which occupies the same bed.
The underlined words "If the charge is regenerated" added to the existing technical specification constitutes this change.
1.3 Existing Technical Specification 3.6.J.3 by inserting a new section:
3.6.J.3 If the charge is replaced, the new anion resin shall have a minimum salt-splitting capacity of 1.2 milliequivalents per milliliter in the wet, chloride form.
The requirements of existing technical specifications 3.6.J.3, 3.6.J.4 and 3.6.J.5 would remain unchanged except for renumbering to 3.6.J.4, 3.6.J.5, and 3.6.J.6 to accommodate the added requirement shown above.
1.4 Existing technical specification 4.6.J.2 to:
4.6.J.2 All REGENERATED condensate demineralizer charges shall have the anion resin analyzed quarterly for salt-splitting capacity.
The underlined word " REGENERATED" is the essential change to the rephrased existing technical specification.
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1.5 Existing technical specification 4.6.J. by adding a new section:
4.6.J.3 If resin is replaced instead of regenerated new samples of anion resin shall be analyzed for salt-splitting capacity as follows:
1 a.
At least once per year or at each replacement, whichever is longer, if resin is replaced with material of the same type.
b.
Prior to use in the condensate demineralizers if the type of anion resin is changed.
1.6 Existing technical specification bases 3/4 6 J to:
B 3/4 6 J.
Condensate Demineralizers The criteria of the resin monitoring program and the resin replacement program have been established to protect the reactor from high chloride level should a seawater leak occur in the main condenser.
Should a seawater leak occur when a resin has 30 pounds of capacity remaining, this criterion will allow a sufficient buffer for an orderly plant shutdown.
Therefore, the resin must be replaced, or regenerated, before the calculated unused capacity of the resin reaches 30_ pounds of chloride ion.
Should a demineralizer be regenerated, the anion minimum salt-splitting capacity of 0.75 milliequivalents per milliter will ensure that the resin shall be replaced prior to reaching a point where a regeneration provides a recovery of less than 60 percent of its original salt-splitting capacity.
The resin depletion can be calculated using the measured salt-splitting capacity, the flow through the bed, and the average influent conductivity. Based on this result, a depletion can be calculated which will assure a 30-pound chloride ion exchange Regeneration prior to this level of depletion will assure reserve.
a sufficient ion exchange reserve for removal of chloride from the condensate system. __
These factors form the basis for the frequency of sampling, analyzing, calculation and logging surveillance requirements. A yearly or once per replacement sampling frequency will be sufficient to verify supplier resin specifications. A quarterly sampling frequency will be sufficient to detect the slow, long-term degradation of regenerated resin. As conductivity increases, the calculation and logging will be increased to a weekly basis and ultimately on a daily basis when and if influent condactivity reaches 0.3 umho/cm or greater.
The underlined words "or replacement", "A yearly or once per replacement sampling frequency will be sufficient to verify supplier resin specification," and " regenerated" and removal of a sentence from the third paragraph "Since startup of Unit 1, the salt-splitting capacity of the resins has degraded about 15% from its initial value of 1.2 meq" constitute the changes to this section.
A Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on March 12, 1986 (51 FR 8598). No comments or requests for hearing were received.
Each of the changes identified above by number, is addressed in the same order in the following evaluation.
2.0 EVALUATION The proposed additions to the Technical Specifications relate to (new) replacement resin (TS 3.6.J.3. and 4.6.J.3.) in contrast to regenerated resin (TS 3.6.J.2 & 4.6.J.3).
The other changes are for clarity and consistency with the proposed addition.
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2.1 The Limiting Condition for Operation (LCO) (regeneration or replacement of the resin before the capacity to remove an additional 30 pounds of chloride ions from the condensate is reached) remains unchanged. The addition of the words "and/or replacement" and a spelling correction (change to charge) are for clarification purposes.
2.2 Repeated regeneration of the anion resin reduces the recovery capacity for the resin to remove the chloride ion from the condensate.
This LC0 continues unchanged to require replacement with new resin when the salt-splitting capacity can not be regenerated to more than 0.75 milli equivalents per milliliter.
The addition of the words "If the charge is regenerated" is for clarification.
2.3 This section is entirely new.
It specifies that new anion (replacement) resin should have a minimum salt-splitting capacity of 1.2 milli-equivalent per milliliter. The basis for the existing section 3.6.J notes "Since startup of Unit 1, the salt-splitting capacity of resins has degraded about 15% from its initial value of 1.2 meq/ml" and Section 3.5.J.2 specifies that " anion resins which do not have a capacity of 0.75 milli equivalent, per milliliter will be replaced with new resin...".
Until this proposed change the LC0 for replacement resin was implied by the sentence removed from the basis.
(See item 2.6 below). This change corrects that omission by specifying an LC0 that requires the same 1.2 meq/ml salt-splitting capacity for replacement resin as for the original demineralizer resin. By telephone on February 20, 1986 the licensee acknowledged a typographical error in the January 10, 1986 submittal and forwarded a replacement page that changed 1.1 meq/ml to 1.2 meq/ml as the minimum salt splitting capacity for replacement resins.
The renumbering of sections 3.6.J.3/4/5 to 3.6.J.4/5/6 changes only the numerical identification of the sections. The change is necessary because of the new LC0 for " replacement" resin i.e.
proposed section 3.6.J.3.
Except for the numerical identification, these sections remain unchanged. __
2.4 By removing the words " Anion resins in all" and substituting "All REGENERATED" consistency between sections 3.6.J.2, the LC0 for regenerated resin, and 4.6.J.2, surveillance requirements for regenerated resin is achieved. The requirement than applies to regenerated resins only and not replaced resins.
2.5 The proposed new section (4.6.J.3) specifies the surveillance requirements for new replacement resin. The existing technical specifications do not relax surveillance requirements for (new) replacement resin. Operating experience (refer to transcript of ACRS subcommittee meeting on Full Term Operating Licensing Conversion on November 19, 1985 page 307) has shown that resin replacement rather than regeneration is more ecnnomical and results in lower chloride in the primary coolant water. The frequency of replacing demineralizer resins has in actual practice been much greater than was anticipated when the plant started up in 1970.
The surveillance requirements for regenerated resin would, therefore, be excessive and unjustified if applied to new replacement resins.
The surveillance requirements for replacement resin are in accordance with Regulatory Guide 1.56 Section C.3 and therefore acceptable.
2.6 The changes in the basis for the demineralizer LC0 and surveillance requirements involve clarification only. The provision for a minimum unused capacity of 30 pounds of chloride ion before a planned regeneration or rep'lacement remains unchanged.
Replacement resin should have been included in the original basis for consistency with the existing 3.6.J.2.
The proposed change corrects this deficiency (an omission) and provides consistency with the proposed revised l
technical specifications. The remaining changes in this section are:
l The removal of a sentence from the existing technical specification because it concerns information that is outdated 1.e. degradation of the resin used during the initial plant l l t
operation in 1970, and because the 1.2 meq/ml replacement resin chloride ion exchange capability is specified in the revised T.S. 3.6.J.3.
The insertion of two new sentences. The licensee revised the change proposed in the submittal dated January 10, 1986 to reflect NRC coments and provided the revised page that is included in this amendment.
The net effect of the proposed changes to the technical specification is to add new requirements (TS 3/4.6.J.3) for " replacement" resin that are less restrictive than those for " regenerated" resin.
However, the added requirements for the " replacement" resin satisfy Regulatory Guide 1.56 and the proposed additions to the technical specifications are therefore acceptable.
The requirements for " regenerated" resin remain unchanged.
The staff has concluded that the change does not involve a significant hazards consideration since 1.
The probability of occurrence of malfunction of equipment important to safety previously evaluated in the SAR is not increased because the minimum reserve chloride ion capacity of the condensate demineralizer is unchanged.
2.
The possibility for a new type of accident not previously evaluated has not been created.
Fresh resin provides equivalent or better chloride protection than regenerated resin.
3.
The margin of safety is unchanged since the minimum reserve chloride ion capacity of the condensate demineralizer is unchanged.
For these reasons the staff recommends approval of the proposed changes to the technical specification as described above. '
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3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change to a requirement with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR part 20. The staff had 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 this amendment involves no significant hazards consideration and there has been no public comment on such finding.
Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
4.0 CONCLUSION
The staff,has concluded, based on the considerations discussed above that the proposed changes, relating to replaced and regenerated resins should be approved and that:
(1) there is reasonable assurance that the health and safety of the public will not be endan'gered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ACKNOWLEDGEMENT This Safety Evaluation has been prepared by James J. Shea Dated: January 29, 1987 s.-. _.
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