ML20212F138

Safety Evaluation Supporting Amend 102 to License DPR-21

ML20212F138
Person / Time
Site:	Millstone
Issue date:	10/22/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20212F126	List: ML20212F121 ML20212F130 ML20212F138
References
NUDOCS 9711040193
Download: ML20212F138 (4)

Text

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~ NUCLEAR REGULATORY COMMIS810N WASHINeTON, D.C. 30006 4001

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 4

RELATED TO AMENDMENT NC. 102

, -19 FACILITY OPERATING LICENSE N0. DPR-21 NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNIT 1 f ~

DOCKET NO. 50-245 i

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1.0 INTRODUCTION

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By letter dated February 7, 1997, as supplemented April 3 and September 19, i

11997, the Northeast Nuclear Energy Company (NNECO or licensee) submitted a request:for changes to the Millstone Nuclear Power Station, Unit 1 Technical-Specifications (TS).- The;TS changes will clarify and/or modify instrument 1

calibration,_ functional, and response time requirements for resistance temperature detector (RTD) and thermoco'rple (TC) testing. Also, certain

j. Ldefinitions will be clarified and/or modified using applicable wording from NRC's NUREG-14D, " Standard Technical Specifications " Revision 1, and industry:recomendations. Additionally.-the change relocates the reactor 7

F prot:.; tion system logic response time value -to the Updated Final- Safety

.- Analysis ' Report:(UFSAR) utilizing the guidance.provided by NRC's Generic L  : Letter (GL) 93-08, ." Relocation.of Technical Specification Tables- of Instrument t Response Time Limits." The amendment -is intended to clarify instrumentation  :

L surveillance requirements, thereby helping to ensure proper testing of safety-

.. related components. The April 3 and September 19 1997, letters provided clarifying -information that did not' affect the staff's initial proposed no-significant hazards consideration determination.

! 2.0L bACKCROUND L

AsinotedLin the above paragraph,-the licensee is proposing to relocate a. . -

. portion of the TS to the UFSAR. Section 182a of the Atomic Energy Act (the "Act") requires. applicants for nuclear power plant operating licenses to state TS to be-included as part of the. license. The Comission's regulatory

-requirements related to the content of TS are set forth in 10 CFR 50.36. That-reguhtion requires:that the TS include items in five specific categories, Lincluding-(l) safety limits, limiting ~ safety system settings and limiting control: settings;-(2) limiting conditions for operation-(LCOs);

(3)-surveillance requirements;-(4)-design features; and (5) administrative controlc. However, the regulation does not 'specify the particular requirements: to be included in a plant's TS.

The Commission has provided guidance for the contents of TS in its " Final Policy-. Statement on Techni .a1 Specifications -Improvements for Nuclear Power m 9711040193 971022 PDR ADOCK 05000245 P. PDR

J Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which I the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act. In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979). In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."

Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining thether particular safety functions are required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressura boundary; (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 mitigata a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operating experienec dr probabilistic safety assessment has shown to be significant to public health and safety. The Commission recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate these criteria. See Final Rule,

" Technical Specifications," 60 FR 36593 (July 19,1995). As a result, TS requirements that fall within or satisfy any of the criteria in 10 CFR 50.36 must be retained in the TS, while those TS requirements that do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents. The Commission's policy statement provides that those existing TS LCOs which do not satisfy these four specified criteria may be relocated to the UFSAR, such that future changes could be made to these provisions pursuant to 10 CFR 50.59.

3.0 EVALUATION The proposed revision deletes the requirement to remove RTDs and TCs for

' testing since their removal can cause damage to these sensors. As noted in NUREG-1433, Revision 1, calibration of instrument channels with RTDs and TCs I may consist of inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjJstable devices in the channel.

The licensee stated that a qualitative inplace test would be satisfied by the performance of instrument checks, which involve a qualitative determination of operability by observation of behavior during operation and will include, where possible, comparison of the instrument with other independent instruments measuring the same variable. The licensee also stated that if any 3 -

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1 RTD'or-TC fails to meet the test criteria for the inplace qualitative test, the sensor will be replaced and the new instrument will be calibrated using standard . industry methods.

On the basis of the discussion above, the staff _ concludes that the proposed

changes to-the Millstone Unit 1 TS to permit inplace qualitative assessment of RTD and TC performance are in conformance with the-guidance of the Standard TS for_ General Electric Plants,

BWR/4 (NUREG-1433,- Revision:1), and are therefore acceptable.-

.TheLreactor protection system res>onse time test ensures that the response

- times are less than or equal ~ to tie maximus' values assumed in the accident- '

x analysis.- The licensee has proposed to relocate the acceptable maximum value of this test to the UFSAR and'TS Bases such that future changes could be made in accordance with 10 CFR 50.59.. The-licensee is requesting this TS change in accordance.with'the guidance of GL-93-08.- NUREG-1433, Revision 1,_for the '

= reactor protection system includes a response time test but does not include the acceptable maximum values for_ response time testing as part of-the TS, Instead, NUREG-1433, Revision 1, references.the_UFSAR (as the licensee is proposing to do). ' Additionally, 10 CFR 50.36 requires testing for this Lvariable,tbut-does not require that the acceptable maximum value be included

-in the TS. The licensee's proposal is consistent with the-guidance provided in GL.93-08, the staff's- latest guidance on TS (i.e., NUREG-1433,- Revision ~1),

and the requirements:of 10 CFR 50.36 and is therefore acceptable.

The licensee also clarified the TS wording regarding the RTD and TC testing.

The licensee's wording is consistent with the staff's guidance in NUREG-1433,-

Revision 1 and is therefore acceptable.

4.0 . STATE CONSULTATION-In accordance'with the Commission's regulations, the Connecticut State-official _was notified of the proposed issuance of the amendment. The State official-had.no comments.

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- 5.0 -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 l Part 20-and changes surveillance requirements. The NRC staff has. determined i that the amendment involves ~no significant increase in the amounts, and no i

significant change in the types, of any effluents that may be released u offsite, and'that_there is no significant increase in individual or cumulative occupational:radiationLexposure. 'The Commission has previously-issued a fproposed finding that the amendment involves no significant hazards consideration, Land there has.been-no public comment on such-finding (62 FR 17236 dated April 9, 1997).- Accordingly,_the 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 the amendment.

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.6,0' GNCLUSION The Comission 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 tne proposed manner, (2) such- l activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public. ,

Principal Contributors: F. Gee S. Dembek

.- Da t e : October 22,-1997

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