ML20214F285
| ML20214F285 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/15/1987 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20214F288 | List: |
| References | |
| B12520, GL-84-13, NUDOCS 8705260016 | |
| Download: ML20214F285 (4) | |
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(203) 665-5000 May 15,1987 Docket No. 50-245 B12520 Re: 10CFR50.90 U.S. Nuclear Regulatory Commbslon Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No.1 Proposed Revision to Technical Specifications Hydraulic and Mechanical Snubbers Pursuant to 10CFR50.90, Northecst Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License DPR-21 by incorporating the changes identified in Attachment 1 into the Technical Specifications of Millstone Unit No.1.
Technical Specification 3.6.I.6 permits additions and ' eletions to Tables 3.6.1.a d
and 3.6.1.b, Hydraulic and Mechanical Snubbers, respectively, provided that safety evaluations, documentation, and reporting are performed in accordance with 10CFR50.59 and that a proposed revision to the tables is included with the next license amendment request. Changes to the snubber population resulted from work accomplished during the 1985 refueling outage.
Subsequently, additional snubbers were placed on the safety-related snubber lists in the station procedures. These were also periodically tested in accordance with Surveillance Requirement 4.6.I.
However, due to administrative oversights, we had not completed the processing of the required snubber list revision until now. We are hereby submitting, as Attachment 1,
the proposed amended Technical Specification sections to resolve this matter.
Generic Letter 84-13 concluded that the inclusion of snubber listings within the Technical Specifications is not necessary provided the snubbers are required to be operable. As such, to meet the intent of Generic Letter 84-13 and in an effort to maintain conservatisms consistent with the BWR Standard Technical Specifications, NNECO proposes to delete Tables 3.6.1.a and 3.6.1.b, Technical Specifications 3.6.I.1, 3.6.I.6; to amend Technical Specifications 3.6.I.2, 3.6.I.3, 3.6.I.4, 3.6.I.5, 4.6.I.2, 4.6.I.3, 4.6.I.4; and to add Technical Specification 4.6.I.S.
Specifically, the proposed changes and the intent of these changes are briefly summarized below.
Table 3.6.1.a and 3.6.1.b listing the safety-related hydraulic and t./
o dl\\ \\ J0 mechanical snubbers are being deleted from the Technical Specifications.
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(The; snubber listings; currently?in thei station procedures :will bel maintained and. updated as appropriate, and will be subject to the.:
.more stringent. surveillance requirements as outlined by the proposed-
-technical specifications.
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o' The required. number of ' additional snubbers to bs tested for.every failed : snubber discovered during the = functional testing is ? being' reduced from 10% to.5% of the total number of snubbers of, that.
type.
m This change-is : consistent with.the conclusions of. the : ASME-OM-4.
evalu'ation which asserted that a retest of 50% of the origina.1 sample -
(i.e.; - 5% ' sample size ; of that type;of. snubber) provided adequate -
conservatism associated with snubber surveillance testing.. The Staff has previously concurred with these conclusions. -
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- A; surveillance requirement for the snubber service life program is, being added.-
The intent of this new requirement is _to ensure that the service life 2
of the snubber is not exceeded between surveillance inspections.': This represents a more stringent surveillance requirement.
o Clarification of the Visual Inspection - Acceptance Criteria land functional retest requirements is being added. ~
_These clarifying statements serve: to better. ' define snubber ~
operability and to' assure the retesting of the current snubbers after-
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failure of the functional test in prior outages.
s NNECO has reviewed the attached proposed. changes pursuant 'to 10CFR50.59 i
and has determined that they do not constitute an unreviewed safety question.~
The probability of occurrence or the consequences of an accident or. malfunction-of: equipment-important' to safety'(i.e., safety-related) previously evaluated in 4
the Final Safety Analysis Report have not been increased.- The possibilitp for an.
accident or malfunction of a different type than any evaluated previously in the Final Safety Analysis Report has not' been created.
There has l not - been. a reduction in the margin of safety,as defined in the basis for?any Technical Specification. These proposed changes will not result in physical changes to the -
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plant or changes in the way the plant is operated. Hence, there is no effect on j
.the design basis accident analyses.
NNECO has also revieweo the proposed changes in accordance with 10CFR50.92 and has concluded that they do not involve a significant hazards consideration in j :-
that these changes would not:
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Involve a 'significant increase in,the probability or consequences 'of an accident previously analyzed. There are no physical changes to the plant 1
- as a result of the proposed changes;. therefore, previously analyzed:
accidents are not affected.
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previously analyzed. Since there are no changes in the way the-plant is Create the possibility of a new or different kind of accident from any operated, the potential for an unanalyzed accident is not created because no new failure modes are introduced.
3.
Involve a significant reduction in a margin of safety. rhe proposed changes to. the Technical Specifications willi not significantly reduce the surveillance testing requirements.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by. providing certain examples (51FR7751, March 6,1936). The new-requirement for monitoring the service life of hydraulic and mechanical snubbers constitutes an additional control which is enveloped by ' example (ii) in 51FR7751, a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, ' e.g.,
a more stringent surveillance requirement. The change of retest. sample _ size, the snubber list deletions, and the visual inspection acceptance criteria clarifications resemble example (vi), a change which either may result in : some increase to. the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan. The changes have no effect on the intent of the original Technical Specifications.
No changes in the intent of current surveillance testing will result. The changes will more easily accommodate future additions or deletiens to the safety-related snubber listings because a formal license amendment will not be required. However, any changes in snubber quantities, types, or locations would be a change to the facility, and such changes would continue to be evaluated against the provisions of 10CFR50.59, and would be reflected in plant records ss appropriate.
The Millstone Unit No. I Nuclear Review Board has reviewed and approved the-attached proposed revisions and has concurred with the above determinations.
In the interim period between submittal of this letter and Staff issuance of a license amendment, NNECO intends to perform snubber surveillance in accordance with the attached more stringent surveillance requirements. : Station procedures identifying current snubber lists will continue to be used to determine which snubbers are subject to the required surveillances. Upon issuance of the proposed license amendment, station procedures will be appropriately amended to maintain consistency with the applicable Technical Specifications.
Until NRC Staff issuance of the requested Technical Specifications changes, the submittal of additional proposed snubber Technical Specification revisions in accordance with Specification 3.6.I.6 are judged to be inappropriatc, especially in light of the upcoming refueling outage. More appropriately, temporary relief from the administrative reporting requirement of Specification 3.6.I.6 is warranted in this case. As such, relief based on enforcement discretion is being.
requested..We propose that the NRC advise us as to the acceptability-of this approach in the near future, so as to avoid any, future literal Technical Specification violations.
{
_ U.S Nucl:ar Rtgultt:ry Commissi:n
.Bi2520/Pagt 4
' May -15,1987 ;
In accordance with 10CFR50.91(b), we;arei providing the. State of Connecticut with a copy of this proposed amendment.--
Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee of $150.
Very truly yours,-
NORTHEAST NUCLEAR ENERGY COMPANY Ph4 s
E. I Mr'oczka -(/
Senio)r Vice President Encbsure i
cc:
W. T. Russell, Region I Administrator
- 3. 3. Shea, NRC Project Manager, Millstone Unit' No.1 T. Rebelowski, Resident Inspector, Millstone Unit No.1 Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 STATE OF CONNECTICUT)
) ss. Berlin COUNTY OF HARTFORD )
Thea personally appeared before me, E. 3. 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 statements contained in'said information are true and correct to the best of his
- knowle'dge and belief.
i
/zdbA1 Yb Notary Publicg _
M/f My CommissiM Expires March 31,1988
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