ML20217D301

Forwards Request for Addl Info Re Util 990118 Request for Amend to License NPF-49 to Allow full-core Offloads to Spent Fuel Pool During Core Offloads to Spent Fuel Pool During Core Offload Events

ML20217D301
Person / Time
Site:	Millstone
Issue date:	10/07/1999
From:	John Nakoski NRC (Affiliation Not Assigned)
To:	Necci R NORTHEAST NUCLEAR ENERGY CO.
References
TAC-MA4586, NUDOCS 9910150111
Download: ML20217D301 (7)

Text

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October 7,1999 A'

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' Mr. R. P. Necci - Vice President -

Nuclear Oversight and Regulatory Affairs

- c/o Mr. David A. Smith -

! ( Northeast Nuclear Energy Compa'ny '

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' P. O. Box 128 Waterford, CT. 06385-0128

SUBJECT:

MILLSTONE _ NUCLEAR POWER STATION, UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION ON FULL CORE OFFLOAD LICENSE AMENDMENT REQUEST (TAC NO. MA4586)

Dear Mr. Necci:

By letter dated January 18,1999, Northeast Nuclear Energy Company requested an amendment to Operating License NPF-49 for Millstone Nuclear Power Station, Unit No. 3. The amendment proposed changes to the Technical Specifications (TS) and Final Safety Analysis <

Report (FSAR) to allow full-core offloads to the spent fuel pool during core offload events.

' Enclosed is a request for additional information regarding your amendment request. The )

enclosed request for additional information was discussed with Mr. David Dodson, et. aL of  !

.'your staff during a teleconference on October 5,1999. As mutually agreed to during the teleconference, we requested that you provide this information within 60 days from the date of this letter. If circumstances result in the need to revise this target, please call me at (301) 415-1278 at the earliest opportunity.  ;

i Sincerely, i

. Original signed by:

John A. Nakoski, Sr. Project Manager, Section 2 Project Directorate I .

Division of Licensing Project Management Office of Nuclear Reactor Regulation j i

- Docket 'No. 50-4231 I

Enclosure:

Request for Additional Information;

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DISTRIBUTION: i Docket File - PUBLIC _ J. Linville, RI J. Clifford J. Nakoski T. Clark ,

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DOCUMENT NAME: G:\PDI-2\ millstone 3\raia4586.wpd To vecelse a cop i of this document, Indicate in the bor "C" = Copy w/o attachment / enclosure "E" = Copy w/ attachment / enclosure "N" = No copy OFFICE - PM:PDI-2 v E LA:PDI-2w /a lE SC:PQl l l

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p Y 4 p e- . 4 UNITED STATES

's; j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&O001

% October 7, 1999 f

Mr. R. P. Necci- Vice President Nuclear Oversight and Regula. tory Affairs

' c/o Mr. David A. Smith Northeast Nuclear Energy Company P. O. Box 128 Waterford, CT 06385-0128

SUBJECT:

MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 - REQUEST FOR ADDITIONAL INFORMATION ON FULL CORE OFFLOAD LICENSE AMENDMENT REQUEST (TAC NO. MA4586)

Dear Mr. Necci:

By letter dated January 18,1999, Northeast Nuclear Energy Company requested an amendment to Operating License NPF-49 for Millstone Nuclear Power Station, Unit No. 3. The amendment proposed changes to the Technical Specifications (TS) and Final Safety Analysis Report (FSAR) to allow full-core offloads to the spent fuel pool during core offload events.

Enclosed is a request 'for additional information regarding your amendment request. The enclosed request for additional information was discussed with Mr. David Dodson, et. al., of your staff during a teleconference on October 5,1999. As mutually agreed to during the teleconference, we requested that you provide this information within 60 days from the date of this letter.' If circumstances result in the need to revise this target, please call me at

- (301) 415-1278 at the earliest opportunity..  !

Sincerely, s ,

./ N Jo n A. Nakoski, Sr. Project Manager, Section 2 :

' Project Directorate i Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-423

Enclosure:

Request for Additional Information cc w/ encl: See next page G

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~ iMilntons Nucl:ar Pow:r Sthtion

+  : Unit 3

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- cc:

Ms.' L. M. Cuoco _. Mr. F. C. Rothen ._ ,

Senior Nuclear Counsel c Vice President - Nuclear Operations Northeast Utilities Service' Company : Northeast Nuclear Energy Company P. O. Box 270 i P. O. Box 128 Hartford. CT 06141-02701 Waterford, CT 06385 -

Edward L.LWilds,;Jr., Ph.D. Ernest C. Hadley, Esquire Director, Division of Radiation . 1040 B Main Street

Department of Environmental Protection P.O. Box 549

- 79 Elm Street West Wareham, MA 02576 Hartford, CT 06106-5127 -

Mr. James S. Robinson, Manager Regiorial Administrator, Region l Nuclear Investments and Administration -

U.S. Nuclear Regulatory Commission New England Power Company .

475 Allendale Road . . 25 Research Drive King of Prussia, PA 19406 Westborough, MA 01582 First Selectmen Mr. R. P. Necci

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Town of Waterford Vice President - Nuclear Oversight and l15 Rope Ferry Road Regulatory Affairs Waterford, CT 06385 - Northeast Nuclear Energy Company P. O. Box 128 Mr. M. H. Brothers Waterford, CT 06385 Vice President - Nuclear Operations Northeast Nuclear Energy Company Deborah Katz, President

. P.O. Box 128 Citizens Awareness Network LWaterford, CT 06385, P.O. Box 83 -

Shelburne Falls, MA 03170

,  ; Mr. M. R. Scully, Executive Director Connecticut Municipal Electric - Mr. Allan Johanson, Assistant Director

, . Energy Cooperative : Office of Policy and Management 30 Stott Avenue' Policy Development & Planning Division Norwich, CT 06360. -

450 Capitol Avenue - MS# 52ERN P. O. Box 341441 1 Mr. J. T. Carlin Hartford, CT 06134-1441 i

' Vice President - Human Services Northeast Nuclear Energy Company - Ms. Terry Ccr. arr.on

P. O. Box 128 Co-Chair Waterford, CT 06385 - Nuclear Energy Advisory Council 415 Buckboard Lane Marlborro, CT 06447 i

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bs i ]

I Millstons Nucinr Power Station

Unit 3 l'

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, . cc:

Mr. Evan W. Woollacott - Citizens Regulatory Commission Co-Chair ATTN: Ms. Geri Winslow

' Nuclear Energy Advisory Council P. O. Box 199

- 128 Terry's Plain Road Waterford, CT 06385 Simsbury, CT 06070

' Mr. William D.' Meinert

= Mr. John W. Beck, President Nuclear Engineer Little Harbor Consultants, Inc. Massachusetts Municipal Wholesale Millstone -ITPOP Project Office. Electric Company P.O. Box 0630 P.O. Box 426 l Niantic, CT 06357-0630. Ludlow, MA 01056

!  : Mr. L. J. Olivier- Mr. B. D. Kenyon Senior Vice President and President and Chief Executive Officer-

. Chief Nuclear Officer - Millstone NNECO Northeast Nuclear Energy Company Northeast Nuclear Energy Company P.O. Box 128. P.O. Box 128 Waterford, CT- 06385 Waterford, CT 06385 Mr. C. J. Schwarz Mr. D. B. Amerine Station Director Vice President - Engineering Services Northeast Nuclear Energy Company Northeast Nuclear Energy Company P.O. Box 128 - P. O. Box 128 Waterford, CT 06385 Waterford, CT 06385 i

l Senior Resident inspector Mr. D. A. Smith -

Millstone Nuclear Power Station Manager - Regulatory Affairs c/o U.S. Nuclear Regulatory Commission z Northeast Nuclear Energy Company  ;

P. O. Box 513 - P. O. Box 128

.Niantic, CT 06357 Waterford, CT 06385 Nicholas J. Scobbo, Jr., Esquire .

Ms. Nancy Burton j i Ferriter, Scobbo, Caruso, & Rodophele, P.C. .

147 Cross Highway ,

75 State Street,7th Floor Redding Ridge, CT 00870  ;

Boston, MA- 02108-1807'

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1 Mr. G. D. Hicks

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' Director - Nuclear Training Services Northeast Nuclear Energy Company _

' P.O. Box 128 Waterford, CT 06385 w

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Request for AdditionalInformation Related to Full Core Offload Amendment For Millstone Unit No. 3 l

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1. With regard to the thermal hydraulic analyses for the spent fuel pool (SFP), for the case j with component cooling water (CCP) temperature of 95 F, provide the decay heat loads  !

, .in the SFP. The information should clearly show the decay heat generated from each  ;

l' batch of the previously discharged spent fuel assemblies (SFAs) and from the freshly l discharged full core in the SFP. This information is necessary to allow the NRC staff to i determine whether the analyses is consistent with the guidance described in Standard l Review Plan, Section 9.1.2," Spent Fuel Pool Cooling and Cleanup System." j

2. With regard to the decay heat calculation, on Page 8 of the Holtec report, Holtec stated that fuel burnup for freshly discharged SFAs is assumed to be consistent with a 24-month operating cycle. On Page 13, Holtec stated that 1 year operation at full power is assumed before a scheduled full-core discharge. Please provide clarification of this apparent discrepancy.

3. Please provide information for each CCP temperature, preferably in a revision to Table 5.4 of the Holtec report, on the calculated peak temperature and its associated coincident time after the reactor shutdown. This information is necessary to allow the NRC staff to determine whether the results are consistent with the guidance described in Standard Review Plan, Section 9.1.2," Spent Fuel Pool Cooling and Cleanup System."

4. In the thermal hydraulic analyses for the SFP, Holtec took into account that the heat removal capability of the SFP cooling system heat exchanger is a function of the CCP temperature. In order to maintain the SFP water below the SFP temperature limit of 150 F, the SFAs "in-reactor" decay time (hold time) required prior to discharge of any SFAs to the SFP varies as the CCP temperature varies. Holtec calculated the following SFA "in-reactor" hold times required prior to a planned full-core offload operation at four CCP temperatures (80 F,85 F,90 F and 95 F):

CCP SFAs In Reactor Hold Temperature,' F Time Required, Hrs.

80 101 85 142 90 200 95 285 Also, Northeast Nuclear Energy Company (NNECo) proposed to add a new figure (Figure 9.1-20," Fuel Assembly Transfer Limit Verses CCP Temperature") to the Final Safety Analysis Report (FSAR). This new figure shows SFA discharge limits' verses SFA "in-reactor" hold times and CCP temperatures.

' The number of SFAs allowed to be discharged to the SFP at CCP temperatures l of 80 F,85 F,90 F and 95 F.

Enclosure

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In order to determine whether adequate controls exist to ensure the guidance of Standard Review Plan, Section 9.1.2, " Spent Fuel Pool Cooling and Cleanup System,"

l are met, the NRC staff needs to understand the provisions established or to be I established in the plant operating procedure to ensure that these SFA discharge limits will not be exceeded.

5. On Page 6 of Attachment 2 to the January 18,1999, submittal, NNECo stated that two additional criteria control the minimum SFA "in-reactor" hold time. One is the Millstone 3 Technical Specifications (TS) which require a minimum SFA "in-reactor" hold time of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />. The other is the thermal and stress analysis of the existing Westinghouse storage racks which require a minimum SFA in reactor hold time of 132 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. NNECo further stated that the minimum SFAs "in-reactor" hold time for CCP temperatures in the range of 80 F to 95 F are from 132 to 285 hours0.0033 days <br />0.0792 hours <br />4.712302e-4 weeks <br />1.084425e-4 months <br /> respectively. The results of the Holtec analysis (as indicated in the above O-4) show that the corresponding minimum SFA "in-reactor" hold time for CCP temperature at 80 F is 101 hours0.00117 days <br />0.0281 hours <br />1.669974e-4 weeks <br />3.84305e-5 months <br />. Please clarify which of the these three " minimum" SFA "in-reactor" hold times will be incorporated in the TS or

- operating procedures as an SFA discharge constraint. Also, clarify how the minimum 1 SFA "in-reactor" hold time of 132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br /> was derived. l

6. On Page 8 of Attachment 2 to the January 18,1999 submittal, NNECo stated that  ;

during shutdown (i.e. Modes 5,6, and with the reactor defueled) SFP cooling system  !

availability may be limited to a single train. Under these circumstances, NNECo relied l cn the large passive water volume contained in the SFP to protect against single j failures. NNECo's rationale is that Holtec's thermal hydraulic analysis for this design change was performed with the assumption that only a single SFP cooling train was s

operating and that a single SFP cooling train has sufficient heat removal capacity to maintain the SFP during normal operation at or below 1500 F. This is not consistent with the guidance in Standard Review Plan, Section 9.1.3, " Spent Fuel Pool Cooling And

- Cleanup System," and does not satisfy the requirement described in General Design Criterion 44, " Cooling Water." in order to determine whether adequate controls exist to ensure the guidance of Standard Review Plan, Section 9.1.3 is met, the NRC staff needs to understand the provisions established or to be established in plant operating procedures to ensure that prior to a planned offload (partial or full-core) event, both trains of the SFP cooling system are operable and available for SFP cooling.

7. In the unlikely event that there is a complete loss of cooling following an unplanned full-core offload event, the SFP water temperature will begin to rise and eventually will reach the boiling temperature. In order for the staff to determine whether the guidance in Standard Review Plan Section,9.1.2, " Spent Fuel Pool Cooling and Cleanup System," is met the staff needs information on the calculated minimum time-to-boil (hours) and its corresponding boil-off rate (gpm) for the case with maximum decay heat input as presented in Holtec report Table 5.4, " Minimum Hold Time Results", and the available make-up rate.

2 The proposed FSAR Figure 9.1-20 also shows that with CCP temperature at q 80 F, the minimum SFA in reactor hold time is 132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br />. l l

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8. In order to determine whether adequate controls exist to ensure the guidance of Standard Review Plan, Section,.9.1.2, " Spent Fuel Pool Cooling and Cleanup System," '

is met, the NRC staff needs to understand the provisions established or to be  !

established in plant operating procedures to monitor and control the SFP water

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temperature during full-core offload events. Information should include-

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I (A) How often the local temperature indicators for SFP water temperature will be )

I monitored. )

(B) The set-point of the high water temperature alarm for the SFP.

(C) Information supporting a determination that there is sufficient time for operators l l to intervene in order to ensure that the temperature limit of 150 F will not be  ;

exceeded. j (D) The mitigative actions (i.e. prohibit fuel handing, aligning other systems to provide SFP cooling, etc.) to be taken in the event of a high SFP water

- temperature alarm.

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