ML20216C040
| ML20216C040 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/06/1998 |
| From: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216C048 | List: |
| References | |
| B17102, NUDOCS 9804140272 | |
| Download: ML20216C040 (13) | |
Text
T Northeast Rope Ferry Rd. (Houte 156), Waterford, Ur 06385 N
T Millstone Nuclear Power Station Northeast Nuclear Energy Company P.O. Box 128 Waterford, Ur 06385-0128 (860) 447 1791 Faa (860) 444-4277 The Nortlwast Utilitice System APR 6 1998 Docket No. 50-336 i
B17102 Re: 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Comoliance issues Number 3 Introduction Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR-65 by incorporating the attached proposed changes into the Technical Specifications of Millstone Unit No. 2. NNECO is proposing to change Techni. cal Specifications 3.4.4, " Reactor Coolant System - Pressurizer,"
3.6.1.5, " Containment Systems - Air Temperature," and 3.7.1.5, " Plant Systems - Main Steam Line isolation Valves." Information will be added to the Bases of the associated Technical Specifications to address the proposed changes. provides a discussion of the proposed changes and the Safety Summary. provides the Significant Hazards Consideration. Attachment 3 provides the marked-up version of the appropriate pages of the current Technical Specifications. provides the retyped pages of the Technical Specifications.
Environmental Considerations NNECO has reviewed the proposed License Amendment Request against the criteria of 10CFR51.22 for environmental considerations.
The proposed changes add a surveillance requirement to verify pressurizer heater capacity, relocate the list of i
b 900414o272 9804o6
,l DR ADOCK 050003 6
O.S. Nucl2ar Reguintory Commission B17102/Page 2 containment air temperature detectors from the surveillance requirement to the Bases, and modify the action statements and surveillance requirements for the main steam line isolation valves. These changes do not increase the type and amounts of offluents that may be released off site. In addition, this amendment request will not significantly increase individual or cumulative occupational radiation exposures.
Therefore, l
NNECO has determined the proposed changes will not have a significant effect on the l
quality of the human environment.
1 Conclusions The proposed changes were evaluated utilizing the criteria of 10CFR50.59 and were determined not to involve an unreviewed safety question.
Additionally, we have concluded the proposed changes are safe.
l The proposed changes do not involve a significant impact on public health and safety (see the Safety Summary provided in Attachment 1) and do not involve a Significant Hazards Consideration pursuant to the provisions of 10CFR50.92 (see the Significant Hazards Consideration provided in Attachment 2).
Plant Operations Review Committee and Nuclear Safety Assessment Board l
The Plant Operations Review Committee and Nuclear Safety Assessment Board have reviewed and concurred with the determinations.
Schedule We request issuance at your earliest convenience, with the amendment to be l
implemented within 60 days of issuance.
State Notification i
in accordance with 10CFR50.91(b), a copy of this License Amendment Request is l
being provided to the State of Connecticut.
l l
.S. Nuclear Regulatory Commission B17102/Page 3
, if you should have any questions on the above, please contact Mr. Ravi Joshi at (860) 440-2080.
Very truly yours, j
NORTHEAST NUCLEAR ENERGY COMPANY l
N$b M. L. Bowling,' Jr.
/
Millstone Unit No. 2 - Recovery Officer 1
Sworn to and subscribed before me this d day of Arvd B
.1998 htcrl Y b A
p Notary Pubic My Commission expires //3 //Jood Attachments (5) cc:
H. J. Miller, Region i Administrator.
D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 W. D. Travers, Ph.D, Director, Special Projects Office W. D. Lanning, Deputy Director of Inspections - Special Projects Office P. F. McKee, Deputy Director of Licensing - Special Projects Office Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127
Docket No. 50-336 B17102
{
Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications 4
Compliance issues Number 3 Discussion of Proposed Changes l
4 l
l
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April 1998
. S. Nucl:ar Regul: tory Commission B17102/ Attachment 1/Page 1
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Proposed Revision to Technical Specifications Compliance issues Number 3 Discussion of Proposed Changes i
101roduction Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR 65 by incorporating the attachea proposed changes into the Technical Specifications of Millstone Unit No. 2.
NNECO is proposing to change Technical Specifications 3.4.4, "Readw Coolant System - Pressurizer," 3.6.1.5, " Containment i
Systems - Air Temperature," and 3.7.1.5, " Plant Systems - Main Steam Line Isolation Valves."
Information will be added to the Bases of the associated Technical Specifications to address the proposed changes.
I Descriotion of Proposed Chanoes Technical Specification 3.4.4 1.
This specification requires at least two groups of pressurizer heaters with a minimum capacity of at least 130 kW.
However, no surveillance requirement (SR) currently exists to verify this capacity. Therefore, SR 4.4.4.2 will be added to verify the required pressurizer heater capacity at l
least once per 92 days. This is consistent with NUREG - 1432, " Standard Technical Specifications Combustion Engineering Plants."
2.
SR 4.4.4 will be renumbered as SR 4.4.4.1 to account for the addition of SR 4.4.4.2. This is an editorial change only.
Technical Specification 3.6.1.5 1.
SR 4.6.1.5 will be modified by relocating the list of contai.went air temperature detectors from the SR to the Bases. The Bases will be expanded to provide more specific details concerning the temperature detectors inside containment. The current detector location specified in the SR is not consistent with plant terminology to describe floor elevations inside containment. The containment floor elevation where the detectors are located is referred to as the 38 ft. 6 in. elevation, not the 38 ft.
elevation as currently specified in SR 4.6.1.5. Relocating this information to the Bases will allow additional detail, concerning the location of the detectors, to be added. This proposed change has no effect on the instrumentation that is used to perform SR 4.6.1.5. The proposed change to SR 4.6.1.5 is consistent with NUREG - 1432.
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- b. S. Nuclear Regulitory Commission B17102/ Attachment 1/Page 2 2.
SR 4.6.1.5 will be modified by adding the words "to be 5120 *F."
The addition of the containment temperature limit will clarify the purpose of the SR. It will not affect any technical aspect of the SR.
3.
SR 4.6.1.5 will be modified by removing the words " arithmetical average."
This is redundant to the wording contained in the Limiting Condition for Operation (LCO) and in the first part of the SR. It will not affect the requirement to verify average containment air temperature is within the limit.
Technical Specification 3.7.1.5 1.
The action statement for Mode 1 will be modified to require the plant to be placed into Mode 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, instead of Hot Shutdown (Mode 4) within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The current action requirements are only applicable when the plant is in Mode 1.
Once the plant leaves Mode 1, the action statement for Modes 2 and 3 will apply Therefore, the current requirement of the Mode 1 action statemer.t to be in Hot Shutdown would no longer apply.
The proposed change in plant operation mode requirement will match the mode and action requirements with the mode of applicability of the action statement. The proposed change in time requirement from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is similar to the time allowed by Technical Specification 3.0.3, which allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach Mode 3. The
(
change to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> will allow sufficient time to shut down the plant from 100 % power. These proposed changes are consistent with NUREG -
- 1432, 2.
The action statements for Modes 2 and 3 will be modified to address more than one inoperable main steam line isolation valve (MSIV). This will eliminate the need to enter Technical Specification 3.0.3 if both MSIVs are inoperable. The reference to continued operation in Mode 1 will be removed since these action statements do not apply in Mode 1. An action time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> will be added to restore the inoperable valve (s) to operable status or to c. lose the affected valve (s). One hour is a reasonable time to allow the valve (s) to be repaired, or to establish the plant conditions to close the valve (s). The phrase " maintained closed" will be modified by removing " maintained," and the phrase "and verified closed at least once per 7 days";will be added.
This will not affect the action statement requirement ;to close inoperable MSIVs, and will provide additional assurance this inoperable MSIVs are closed. A note (*) will be added that states the MSIVs may be opened to perform SR 4.7.1.5. This will allow MSlVs, that are closed to comply with the action statement, to be opened and tested to verify operability. The requirement to be in Hot Shutdown (Mode 4) within the next 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will be modified to require Mode 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and Mode 4 in the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The proposed j
U. S. Nuclear Regulatory Commission B17102/ Attachment 1/Page 3 l
changes in time requirements from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to a total of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> is consistent with the time allowed by Technical Specification 3.0.3. These proposed changes are consistent with NUREG - 1432.
3.
SR 4.7.1.5 will be modified by deleting the words "that is open." The surveillance requirement will apply regardless of valve position. This proposed change is consistent with HUREG - 1432.
4.
SR 4.7.1.5.a, MSIV partial stroke test, will be deleted.
Partial stroke testing will still be required by Technical Specification 4.0.5, which invokes the Millstone Unit No. 2 Inservice Testing (IST) Program. In the l
future, if an exemption to the IST requirement for partial stroke testing is determined to be appropriate, NNECO would follow the normal procedure to request such an exemption from the NRC.
5.
SR 4.7.1.5.b, MSIV full stroke testing, will become SR 4.7.1.5.
The requirement to perform this test will be changed from "during each reactor shutdown" to "during each plant startup." It is more appropriate to verify equipment operability prior to plant operation, instead of after plant operation, in addition, it may be difficult to perform this test at the conditions specified if a rapid shutdown of the unit is required. This proposed change is consistent with NUREG - 1432.
An exception to Technical Specification 4.0.4 will be added to allow entry into Mode 3. This is necessary to allow establishment of the appropriate plant conditions for test performance. This proposed change is consistent with NUREG - 1432.
Safety Summary Technical Specification 3.4.4 - Pressurizer The proposed change will add a surveillance requirement (SR) 4.4.4.2 to verify pressurizer heater capacity. This will verify the operability of the pressurizer heaters, and will help ensure the pressurizer will function as designed to maintain Reactor Coolant System pressure. There will be no change to the pressurizer operability requirements, as defined by this specification. This is an enhancement to the current Technical Specifications. The proposed SR and performance frequency are consistent with NUREG - 1432. Therefore, there is no adverse impact on public health and safety.
Techn, cal Spe-:.'ia2 ion 3.6.1.5 - Containment Temperature The proposed changes to modify the wording of SR 4.6.1.5 and to relocate the list of containment air temperature detectors from SR 4.6.1.5 to the Bases will
U. S. Nucitar Regulttory Commission B17102/ Attachment 1/Page 4 not affect the Technical Specification limit for containment temperature, or the frequency of verification of this limit. The instrumentation used will remain the same.
There will be no offect on any design basis accident previously evaluated. Therefore, there is no adverse impact on public health and safety.
Technical Specification 3.7.1.5 - Mein Steam Lino isolation Valves The current action statement for Mode 1 allows 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore an inoperable MSlV to operable status or to close the valve, otherwise the plant is required to be in Hot Shutdown (Mode 4) in the following 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The proposed change to the action statement for Mode 1 will not change the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed to restore the valve to operable status or to close the valve. However, the requirement to be in Mode 4 in 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> will be changed to Mode 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This will match the mode and action requirements with the mode of applicability of the action statement. The change to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> will allow sufficient time to shut down the plant from 100% power, and is similar to the time allowed by Technical Specification 3.0.3, which. allows 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to reach Mode 3.
After the plant reaches Mode 2, the requirements of the Modes 2 and 3 action statement will apply. This proposed change is consistent with NUREG - 1432.
The scope of the Modes 2 and 3 action statement will be expanded a address more than one inoperable MSIV, the reference to continued operation in Mode 1 will be removed, an action time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> will be added to restore the inoperable valve (s) to operable status or to close the affected valve (s), and the time to reach Mode 4 with one inoperable MSIV will be increased. If one MSIV is inoperable in Modes 2 or 3, and the MSIV is not restored to operable status or closed (no time limit given), the current action statument requires the plant to be in Mode 4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. if two MSIVs are inoperable, the requirements of j
Technical Specification 3.0.3 would apply (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to take action, Mode 3 within 1
next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and Mode 4 the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />). Therefore, the current action requirements for two inoperable MSIVs are less restrictive than the requirement for one inoperable MSlV. However, when more plant equipment is inoperable, the action requirements normally should be more restrictive. The proposed changes will correct this inconsistency by making the action requirements for one or two inoperable MSlVs the same as the action requirements of Technical Specification 3.0.3.
A time period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> will be added to either restore the valve (s) to operable status or to close the valve (s) before action is required to shut down
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the plant. The addition of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> time period, where none was previously specified, is a reasonable time to allow the valve (s) to be repaired, or to establish the plant conditions to close the valve (s). In addition, the current time to reach Mode 4 from Mode 2 with one inoperable MSIV will be increased from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This will increase the total time to reach Mode 4 from Mode 2 to 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />, instead of the current 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. This is the same as the current time requirement for 2 inoperable MSIVs (Technical Specification 3.0.3). The proposed changes in the mode transition times of the MSIV action statements are consistent
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,U. S. Nucirr Regulttory Commission B17102/ Attachment 1/Page 5 with the transition times used in most Technical Specif' ations, including Technical c
Specification 3.0.3, and are reasonable times for the plant to accomplish a controlled transition to a lower mode. These proposed changes are consistent with NUREG - 1432.
The Modes 2 and 3 action statement will be modified by removing " maintained,"
1 and adding "and verified closed at least once per 7 days." This will not affect the action statement requirement to close inoperable MSIVs, and will provide additional assurance the inoperable MSIVs are closed. A note (*) will be added that states the MSIVs may be opened to perform SR 4.7.1.5.
This will allow I
MSIVs, that are closed to comply with the action statement, to be opened and I
tested to verify operability.
These proposed changes are consistent with NUREG - 1432.
The proposed change to remove the words "that is open" from SR 4.7.1.5 will expand the scope of the SR. It is not necessary to specify that the SR only applies to valves that are open. If the valves are not operable, the proposed changes to the Mcvies 2 and 3 action statements will allow continued plant operation provided the valves are closed. This is acceptable since the accident position of the MSlVs is closed.
This proposed change is consistent with NUREG - 1432.
SR 4.7.1.5.a, MSIV partial stroke test, will be deleted. Partial stroke testing will still be required by Technical Specification 4.0.5, which invokes the Millstone Unit No. 2 IST Program. This proposed change is consistent with NUREG -
1432.
SR 4.7.1.5.b, MSIV full stroke testing, will become SR 4.7.1.5. The requirement to perform this test will be changed from "during each reactor shutdown" to "during each plant startup." It is more appropriate to verify equipment operability prior to plant operation, instead of after plant operation. In addition, it may be difficult to perform this test at the conditions specified if a rapid shutdown of the unit is required. This proposed change is consistent with NUREG - 1432.
An exception to Technical Specification 4.0.4 will be added to SR 4.7.1.5 to allow entry into Mode 3. This is necessary to allow plant startup to proceed with equipment that is believed to be operable, but that can't be verified until the appropriate plant conditions for test performance have been established. After entering Mode 3, and establishing the necessary plant conditions as defined in the proposed surveillance, the MSIVs will be declared inoperable if SR 4.7.1.5 has not been performed within the required frequency, plus 25%, in accordance with Technical Specifications 4.0.2 and 4.0.3. The proposed action statement for Modes 2 and 3 would be entered. However, the required actions can be deferred for up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Technical Specification 4.0.3) to allow performance of SR 4.7.1.5. This proposed change is consistent with NUREG - 1432.
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'U S Nuclear Regul tory Commission B17102/ Attachment 1/Page 6 1
The proposed changes will not affect the operability requirements of the MSIVs.
The MSIVs will still function as designed to mitigate the consequences of design basis accidents. Therefore, there is no adverse impact on public health and safety.
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The proposed changes have no adverse effect on how any of the associated systems or components function to prevent or mitigate the consequences of design basis accidents. Also, the proposed changes have no adverse effect on any design basis accident previously evaluated. Therefore, there is no adverse impact on public health and safety.
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I Docket No. 50-336 B17102 i
Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Compliance issues Number 3 j
Significant Hazards Consideration i
1 April 1998
U. S. Nucl:ar Regul tory Commission B17102/ Attachment 2/Page 1 Proposed Revision to Technical Specifications Compliance issues Number 3 Significant Hazards Consideration Sionificant Hazards Consideration in accordance with 10CFR50.92, NNECO has reviewed the proposed changes and has concluded that they do not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes l
would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change to add a surveillance requirement (SR) 4.4.4.2 to verify pressurizer heater capacity will help ensure the pressurizer will be able to function as designed to maintain Reactor Coolant System pressure. There will be no effect on any design basis accident previously evaluated or on any equipment important to safety. Therefore, the proposed change will not result in a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to modify the wording of SR 4.6.1.5 and to relocate the list of containment air temperature detectors from SR 4.6.1.5 to the Bases will not affect the Technical Specification limit for containment temperature or the frequency of verification of this limit. The proposed changes do not alter the way any structure, system, or component functions.
The initial assumption for containment temperature used in the design basis accident analysis will remain the same. There will be no effect on any design basis accident previously evaluated or on any equipment important to safety. Therefore, the proposed changes will not result in a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes to the action statements and surveillance requirements of Technical Specification 3.7.1.5 will not affect the operability requirements of the main steam line isolation valves (MSIVs). There will be no effect on any design basis accident previously evaluated or on any equipment important to safety. Therefore, the proposed changes will not result in a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes have no adverse effect on any of the design basis I
accidents previously evaluated or on any equipment important to safety.
Therefore, the License Amendment Request does not impact the probability of i
a
U. S. Nuclear Reguirtory Commission B17102/ Attachment 2/Page 2 l
an accident previously evaluated nor does it involve a significant increase in the consequences of an accident previously evaluated.
2.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes will not alter the plant configuration (no new or different type of equipment will be installed) or require any new or unusual operator
)
actions. They do not alter the way any structure, system, or component functions and do not alter the manner in which the plant is operated. The proposed changes do not introduce any new failure modes. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from j
any accident previously evaluated.
3.
Involve a significant reduction in a margin of safety, i
The proposed changes will add SR 4.4.4.2 to verify pressurizer heater capacity, relocate the list of containment temperature detectors used to verify containment temperature from SR 4.6.1.5 to the associated Bases, and modify the action statements and surveillance requirements of Technical Specification 3.7.1.5.
These changes will have no adverse effect on equipment important to safety.
This equipment will continue to function as assumed in the design basis accident analysis. Therefore, there will be no significant reduction in the margin of safety as defined in the Bases for the Technical Specifications affected by these proposed changes.
The NRC has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March 6, 1986, 51 FR 7751) of amendments that are considered not likely to involve an SHC. The change proposed 1
herein to add a surveillance requirement for pressurizer heater capacity is enveloped by example (ii), a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications. The other changes proposed herein are not enveloped by any specific examples.
As described above, this License Amendment Request does not impact the probability of an accident previousiy evaluated, does not involve a significant increase in the consequences of an accident previously evaluated, does not create the possibility of a new or different kind of accident from any accident previously evaluated, and does not result in a significant reduction in a margin of safety.
Therefore, NNECO has concluded that the proposed changes do not involve an SHC.