ML20217H702
| ML20217H702 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/23/1998 |
| From: | Burton N AFFILIATION NOT ASSIGNED |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20217H671 | List: |
| References | |
| LA, NUDOCS 9804300045 | |
| Download: ML20217H702 (10) | |
Text
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- UNITED STATES NUCLEAR REGULATORY COMMISSION
,:'e,r.2 /t tl) l IN RE: APPLICATION FOR AMENDMENT : b N. 0 23 BY NORTHEAST NUCLEAR ENERGY : PUBLIC DOCUMENT 1100N COMPANY, ET AL 9 10
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- % E MILLSTONE NUCLEAR POWER STATION, :
4 UNIT NO. 3 : x-00 # 9 APE 2 N 1993~
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NEW LONDON COUNTY, CONNECTICUT APRIL 23, 1998 h Ne b. CITIZENS REGULATORY COMMISSION PETITION FOR LEAVE TO INTERVENE h ig ( t The Citizens Regulatory Commission (" CRC") herewith petitions the United States Nuclear Regulatory Conmission for leave l to intervene in the above-captioned proceedings concerning a l license amendment application dated March 3, 1998 and described i as follows: The proposed revision to the Millstone Unit 3 licensing basis would eliminate the requirement to have the . recirculation spray system directly inject into the reactor l coolant system following a design basis accident. i This petition is submitted in accordance with the provisions of 10 C.F.R.52.714. j In support of thist petition, the CRC represents as follows:
- 1. The Citizens Regulatory Commission is an organization l
, of citizens, including families with youg children, who reside I l l in southeastern Connecticut and are concerned about the safety of the Millstone Nuclear Power Station. CRC includes members who reside with their young children within the five-mile priority emergency evacuation zone of the Millstone Station.
- 2. The instant application involves issues which are critical to the safe operation of Millstone Unit 3 and thereby directly impact CRC members' health and safety.
9804300045 980428 PDR ADOCK 05000423 0 PDR
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- 3. The CRC opposes issuance of the requested amendment at this time. I
- 4. The CRC's objections to the proposed anendment are summarized as follows: <
i (a) The present management of the license amendment applicant, Northeast Nuclear Energy Company Et A1 ("NU"), has for the past two (2) years permitted the employment of faulty calculations on a persistent basis involving the operations of systems at Millstone Unit 3; (b) The present management of NU has for the past two (2) years engaged in inadequate procedures, methods and analysic of safety systems at Millstone Unit 3; (c) The present management of NU has long been aware of the longstanding problems associated with the Recirculation Spray System ("RSS") at Millstone Unit 3, which system is the subject of the instant applications (d) The RSS is a critical safety system at Millstone Unit 3; (e) The United States Nuclear Regulatory Commission publicly acknowledged on February 19, 1998 that Millstone Unit 3 has been permitted to operate although the RSS system was inoperable; (e) The health, safety and welfare of the public, including the CRC membership, has been needlessly and recklessly jeopardized by the failure of NU and NRC to assure complete operability of I the RSS system in the past; (f) Failure of the RSS system could be catastrophic; (g) Early in March 1998, NU tested a modification it had made to the RSS system at Millstone Unit 3. ! 2 l
L l i (h) The modification to the safety-critical RSS system j l proved to have been very poorly designed and inadequately reviewed j when testing of the modification resulted in serious damage to four pump systems which nest be operable in a loss-of-coolant accident. (1) CRC appends hereto the account of the March 1998 RSS modification failure which appeared in the April 3, 1998 issue of The New London Day newspaper. l l (j) A nuclear engineer with the Union of Concerned Scientists
'is. reported as having made the comment regarding the RSS modification failure: "This is engineering 101 stuff. Most i
1 disconcerting is nuclear oversight. Their sole job is to point out potential problems. When they raise a flag and it's ignored, something's wrong." (k) The present management of NU has for the past two (2) years compromised safety at Millstone Unit 3 in the interests of schedule-driven efforts to obtain approval for restart. (1) That present NU management is schedule-driven at the expense of safety is illustrated by the fact that Bruce D. Kenyon, president and CEO of NU, will maximize a potential $500,000 bonus !
)
if Millstone Unit 3 restarts by a particular identified month, according to Mr. Kenyon's sworn testimony before the Connecticut Department of Public Utility Control on April 9, 1998. ! l (m) The present management of Millstone continues to perpetuate l an employee environment ~in . which workers are harassed, intimidated, [ retaliated against and discriminated against when they attempt to raise safety issues, whichLeonduct is a violation of federal law. 3
(n) As recently as February 1998, a five-year employee with a stellar record at Millstone as well as a stellar 26-year record as a commander in the United States Navy resigned from Millstone in frustration that under present management he was not able to achieve adequate resolution of safety issues he raised (o) In light of the above circumstances, CRC has no confidence that NU has properly and adequately analyzed the RSS system at Millstone Unit 3 to dates (p) In light of the above circumstances, CRC has no confidence that NU.has analyzed the RSS system at Millstone Unit 3 in accordance with the letter and spirit of the standards articulated on February 19, 1998 by Dr. Shirley Jackson, Chairman, NRC, during public proceedings concerning Millstone. ,
- 5. In light of the above circumstances, CRC respectfully represents that approval of the requested amendment in the present form as submitted by NU will directly adversely impact the health, safety.and welfare of each of the members of CRC, including those families with young children.
101EREFORE Citizens Regulatory Commission petitions for leave to intervene in the above-referenced proceedings. CITIZENS REGULATORY COMMISSION
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By: A m ;,, am _ - Nancy Bu , Esq. 147 C s Highway Reddi g Ridge CT 06876 Tel. 03-938-3952
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a 14482 Federal Register /Vol. 63, No. 57 / Wednesday, March 25,1998 / Notices ~ ;- Appendix A of 10 CFR Part 50, action and the alternative action are The proposed action would also exempt " General Design Criteria for Nuclear similar. the licensee from the requirements to Power Plants, Criterion 62. requires Alternative Use of Resources maintain emergency procedures for each Nat criticality in the fuel storage and area in which this licensed SNM is handling system shall be prevented by This action does not involve the use handled, used, or stored to ensure that of any resources not previously all personnel withdraw to an area of physical systems or processes, considered in the " Final Environmental safety upon the sounding of the alarm, preferably by use of geometrically-safe configurations. This is met at Sequoyah Statement Related to the Sequoyah Nuclear Plant, Unit Nos. I and 2," dated to familiarize personnel with the Nuclear Plant, Units 1 and 2, as evacuation plan, and to designate identified in the TS and the Updated February 13,1974. responsible individuals for determining Final Safety Analysis Report (UFSAR). the cause of the alarm, and to place Agencies and Persons Consulted Sequoyah TS Section 5.6.1.2 states that in accordance with its stated policy, radiation survey instruments in the new fuel storage racks are designed accessible locations for use in such an on January 30,1998, the Commission for dry storage of unirradiated fuel staff consulted with the State of emergency. assemblies having a U-235 enrichment j Tenne >see Official Goelle Key) regarding The proposed action is in accordance with the licensee's application for less than or equal to 5.0 weight percent, the environmentalimpact of the, while maintaining a k-effective of less exemption dated December 5,1997, than or equal to 0.98 under the most PmPosed action. The State official had no comments. The Needfor the Proposed Action reactive condition.UFSAR Section 9.1.1, New Fuel Storage, for both Units Finding of No Significant Impact The purpose of 10 CFR 70.24 is to 1 and 2 specify that the fuel racks are th I ensure that if a criticality were to occur B d s 'Pa 8 asses men , e Co s n ncludes durin tlw handling of SNM. personnel een ea mb e t aln a n a that the proposed action will not have woul be alerted to that fact and would subcritical (k-effcctive less than or equal a significant effect on the quality of the ta e appropriate action. At a to 0.98) array assuming the most human environment. Accordingly,the commercial nuclear power plant, the
, reactive condition, and under all design Commission has determined not to inadvertent criticality with hich to loadings including the safe shutdown PMPare an environmentalimpact CFR 70.24 is concerned could occur earthquake. The UFSAR also specifies statement for the proposed action.
during fuel handling operations. The that the new fuel racks are designed to For further details with respect to the SNM that could be assembled into a preclude the insertion of a new fuel proposed action, see the licensee's letter critical mass at a commercial nuclear assembly between cavities. dated December 5,1997, which is ower plant is in the form of nuclear The proposed exemption would not available for public inspection at the el; the quantity of other forms of SNM result in any signif. cant radiological Commission's Public Document Room, that is stored on site is small enough t impacts.The proposed exemption would not affect radiological plant which is located atThe Gelman preclude achieving a critical mass. Building,2120 L Street, NW., Because the fuelis not enriched beyond effluent nor cause any significant Washington, D.C., and at the local 5.0 weight percent Urnnium-235 and because commercial nu . lear plant occupational design controls exhsures since thePublic TScludingdocumentgeometric room located at the Chattanooga-Hamilton County Library, licensees have procedures and features spacing of fuel assembly storage spaces) 2001 Broad Street, Chattanooga, designed to prevent inadvertent and administrative controls preclude inadvertent criticality. The amount of Tennessee. criticality, the staff has determined that ' radioactive waste would not be changed Dated at Rockville. Maryland, this 17th day
.t is unlikely that an inadvertent !
by the proposed exemption. of March 1997. criticality could occur due to the For the Nuclear Regulatory Commission. handling of SNM at a commercial power The proposed exemption does not reactor.The requirements of to CFR result in any significant nonradiological Frederick f. Mden. 70.24, therefore, are not necessary to environmental impacts. The proposed Director, Profect Directomte U-3, Division of ensure the safety of personnel durin8 exemption involves features located Reactor Projects-UR, Office of Nuclear entirely within the restricted area as ReactorRegulation. the handling of SNM at cc,mmercial defined in 10 CFR Part 20. It does not (FR Doc. 96-78t2 Filed 3-24-98; 8:45 aml power reactors. affect non-radiological plant effluents - eo,, ,,,,,,, Environmentof Impacts of the Prvposed and has no other environmental impact. Action Accordingly, the Commission concludes The Commission has completed its that there are no significant non- NUCLEAR REGULATORY evaluation of the proposed action and radiological environmental impacts COMMISSION concludes that there is no signihcant associated with the proposed action. Blweeldy Notice; Appilcations and environmental impact if the exemptJon Alternots.ves to the Proposed Action Amendments to Facility Operating l is granted. Inadvertent or accidental Since the Commission has concluded Licenses involving No Significant I criticality will be precluded through Hazards Considerations compliance with the uoyah Nuclear that there is no measurable ical environmental impact associated with 1. Background Plant, Units 1 and 2 T the proposed action, any alternatives Pursuant to Public Law 97-415, the ! Specifications (TS), the design of the fuel storage racks providing geometric with equal or greater environmental U.S. Nuclear Regulatory Commission impact need not be evaluated. As aa spacing of fuel assemblies in their altemative to the proposed exemption, (the Commission or NRC staff)is storage locations, and administrative publishing this regular biweekly notice. controls imposed on fuel handling the staff considned denial of the requested exemption. Denial of the Public Law 97-415 revised section 189 procedures. TS requirements specify of the Atomic Energy Act of 1954, as reactivity limits for the fuel storage request would result in no change in amended (the Act), to require the current environmentalimpacts. The racks and minimum spacin8between Commission to publish notice of any the fuel assemblies in the storage racks. environmentalimpacts of the proposed
~. _ _ _ _ _ _ _ . _ _ . _ _
l'ederal Register M e, t. No. W ' W doesta . h h R Iwi - Noti ( es 14 4113 l amendments issued or proposed to be beanng after nsnam e ~! hr Conmassmn propert). tinancial. or other interest m 1 issued, under a new provision of seotmn espects that th. need to take this a tmn the promeding. and (il the possibb. 189 of the At t. This prmision grants the mil or i ur s en mtn quent!v. ef fett ni any order which may be Commission the authonty to issue and Wntten comments me he submitted entered in the preceeding on the make immediately ef fecth e any by mail to the Chief. Rules an i petitioner's interest. The petition should amendment to an operating license Directives Branch. Disision of also identify the specific aspect (s) of the upon a determination by the Administration Services. Office of subject matter of the proceeding as to i Commission that such amendment Administration. U.S. Nuclear Regulatory which petitioner wishes to intervene. i involves no significant hazards Commission. Washington, DC 20555- Any person who has filed a petition for l: consideration, notwithstanding the 0001, and shoul i cite the publicauon leave to inten ene or w ho has been l pendency before the Commission of a date and page number of this Federal admitted as a party may amend the request for a hearing from any person. Register notice. Written comments may petition without requesting leave of the This biweekly notice inclu~ des all also be delivered to Room 6D22 Two Board up to 15 days prior to the first !; notices of amendments issued, or White Flint North.11545 Rockville prehe'a ring confemnce scheduled in the I proposed to be issued from March 2, Pike Rocksille, Maryland from 7:30 proceeding, but such an amended 1998, through March 13,1998. The last a.m. to 4:15 p.m. Federal workdays. petition must satisfy the specificity biweekly notice was published on Copies of written comments received requirements described above. , March 11,1998 (63 FR 11913). may be examined at the NRC Public Not later than 15 days prior to the first N: tics of Consideration ofIssuance of Document Room, the Gelman Building, prehearing conference scheduled in the Am:ndments to Facility .OPerating 2120 L Street, NW.. Washmgton. DC. proceeding, a petitioner shall file a Lienses, Proposed No Sigmficant The filing of requests for a hearing and supplement to the petition to intervene liurrds Consideration Determmation, petitions for leave to intervene is which must include a list of the tnd Opportunity for a llearing discussed below. contentions which are sought to be By April 24,1998, the licensee may litigated in the matter. Each contention The Commission has made a file a request for a hearing with respect must consist of a specific statement of proposed determination that the to issuance of the amendment to the the issue of law or fact to be raised or i following amendment requests involve subject facility operating license and controverted. In addition, the petitioner I no significant hazards consideration. any person whose interest may be shall provide a brief explanation of the l Under the Commission's regulations in affected by this proceeding and who bases of the contention and a concise 10 CFR 50.92, this means that operation wishes to participate as a party in the statement of the alleged facts or expert of the facility in accordance with the proceeding must file a written request opinion which support the contention proposed amendment would not (1) for a hearing and a petition for ! eave to and on which the petitioner intends to involve a significant increase in the intervene. Requests for a hearing and a rely in proving the contention at the probability or consequences of an petition for leave to intervene shall be hearing. The petitioner must also i accident previously evaluated; or (2) filed in accordance with the provide references to those specific cretta the possibility of a new or Commission's " Rules of Practice for sources and documents of which the diff rent kind of accident from any Domestic Licensing Proceedings" in 10 petitioner is aware and on which the accident previously evaluated; or (3) CFR part 2. Interested persons should petitioner intends to rely to establish involve a significant reduction in a consult a current copy of 10 CFR 2.714 those facts or expert opinion. Petitioner i mitgin of safety. The basis for this which is available at the Commission's must provide sufficient information to proposed determination for each Public Document Room, the Gelman show that a genuine dispute exists with amendment request is shown below. Building,2120 L Street, NW., the applicant on a material issue of law The Commission is seeking public Washington, DC and at the local public or fact. Contentions shall be limited to comments on this proposed document room for the particular matters within the scope of the determination. Any comments received facility involved. If a request for a amendment under considercion. The within 30 days after the date of hearing or petition for leave to intervene contention must be one whicu, if publication of this notice will be is filed by th. above date, the proven, would entitle the petitioner to considered in making any final Commission or an Atomic Safety and relief. A petitioner who fails to file such det rmination. Licensing Board, designated by the a supplement which satisfies these Normally, the Commission will not Commission or by the Chairman of the requirements with respect to at least one issui the amendment until the Atomic Safety and Licensing Board contention will not be permitted to expiration of the 30-day notice period. Panel, will rule on the request and/or participate as a party. 110 wever, should circumstances change petition and the Secretary or the Those permitted to intervene become during the notice period such that designated Atomic Safety and Licensing parties to the proceeding, subject to any failure to act in a timely way would Board will issue a notice of a hearing or limitations in the order granting leave to result, for example, in derating or an appropriate order. intervene, and have the opportunity to I shutdown of the facility, the As required by 10 CFR 2.714, a panicipate fully in the conduct of the I Commission may issue the license petition for leave to intervene shall set hearing, including the opportunity to amendment before the expiration of the forth with panicularity the interest of present evidence and cross-examine 30-day notice period, provided that its the petitioner in the proceed;ng, and witnesses. final determination is that the how that interest may be affected by the if a hearing is requested, the amendment involves no significant results of the proceeding. The petition Commission will make a final nazards consideration. The final should specifically explam the reasons determination on the issue cf no determination will consider all public why intervention should be permitted significant hazards consideration. The md State comments received before with particular reference to the final detennination will serve to decide xtion is taken. Should the Commission following factors:(1) The nature of the w hen the hearing is held. take this action, it will publish in the petitioner's right under the Act to be if the final determination is that the Fed:rci Register a notice of issuance made a party to the proceeding:(2) the amendment request involves no and provide for opportunity for a nature and extent of the petitioner's significant hazards consideration, the
d 14484 Federal Register / Vol. 63, No. 57 / Wednesday, March 25, 1998 / Notices Commission may issue the amendment request is provided both in the format and (2) the operabihty of plant sptems and make it immediately effective, of the current TS as well as improved designed to mitigate the consequences of notwithstanding the request for a i e "8 Standard Technical Specifications {n "'$Otha1ng u , 9 d- pm (! 'hebsy hearing. Any hearing held would take (iSTS). The Brunswick licensee applied evaluated have not been increased. place afterissuance of the amendment. for conversion to ISTS on November 1. Additionally. removal of the footnote on If the final determination is that the 199f;. as supplemented on October 13, the safety limit MCPR vahme in Technical amendment request involves a 1997, and February 26,1998, and that Specification 2.1.2 and removal of reference significant hazards consideration; any { application is currently urgdergoing NRC "c" from the document list in Technical hearing held would take place before staff review. For iSTS 'the licensee has Specification 6.9.3.2 will not increase the the issuance of any amendment. proposed two safety limits MCPR, one probability or consequences of accide,ts A request for a hearing or a petition pertaining to two-recirculation loop dT for leave to intervene must be filed with P'y'y [5[$*y*gy&e n echr c operation and the other to single- Specification 2.1.2 and reference "c" in the Secretary of the Commission, U.S. recirculation loop operation. Technical Spbcification 6.9.3.2 were Nuclear Regulatory Commission, Basis for proposed no significont associated with the safety limit MCPR value Washington, DC 20555-0001, Attention: hazards considerution determinotion: of 1.10 for Unit 1 Cycle 11 operation. Siece I Rulemakings and Adjudications Staff, or As required by 10 CFR 50.91(a), the th< current safety limit MCPR value of 1.10 l may be delivered to the Commission's licensee has provided its analysis of the applies only to Unit 1 Cycle 11 operation, the 1 Public Document Room, the Gelman issue of no significant hazards fmtnote on the safety limit MCPR value in Building,2120 L Street, NW . Technical Specification 2.1.2 and the { consideration, which is presented reference "c" in Technical Specification Washington DC, by the above date. A below- - copy of the petition should also be sent 613.2 are no longer needed and should be
- 1. Does the change involve a significant deleted. Thus, removal of the footnote on the to the Office of the General Counsel
- increase in the probability or consequences
. safety limit MCPR value in Technical '
U.S. Nuclear Regulatory Comm.ission, of an accident previously evaluated? Specification 2.1.2 and removal of reference Washington, DC 20555-0001, and to the The proposed license amendment "c" from Technical Specification 6.9 3 2 is an attorney for the licensee. establishes a revised safety limit MCPR value administrative change that has no effect on Nontimely filings of petitions for of 1.09 Itwo-recirculation loop and 1.10 for the probability or consequences of accidents leave to intervene, amended petitions, single-recirculation loop operationi for use previously evaluated. supplemental petitions and/or requests during Unit 1 Cycle 12 operation. General 2. Does the change create the possibility of for a hearing will not be entertained Electryc (GE) has determined that both a new or different kind of accident from any enenc and plant-s cific evaluations (two- accident previously evaluated? absent.a determination by the ration] yie d the same calculated Commission, the presiding officer or the foop safety ofimit MCPR value. Additionally, a amendment involves This pmposed license a revision of the safety limit MCPR from 1.10 Atomic Safety and lacensing Board that document referenced by the Technical to 1.09 f two-loop /1.10 single-loop! based on the petition and/or request should be Specification 6 9 3.2 of methodologies used the results of both cycle-specific and generic l granted based upon a balancing of in determining core operating limits is being analyses, removal of the footnote on the factors specified in 10 CFR removed. safety limit MCPR value in Technical 2.714(a)(1)(i)-{v) gnd 2.714(d). The probability of an evaluated accident is Specification 2.1.2, and the removal of a For further details with respect to this derived from the probabilities of the document alarence listed tn Technical j individual precursors to that accident. The Specification 6.9.3.2 describing the methods cction, amendment see whi the is ap[lication for avaigage gor consequences of an evaluated accident are used only during Unit 1 Cycle 11 to determined by the operability of plant determine core operating limits. Creation of public inspection at the Commission,s systems designed to mitigate those Public Document Room, the Gelman the possibility of a new or different kind of consequences. Limits have been established, accident would require the creation of one or Building,2120 L Street, NW., consistent with NRCI l approved methods, to more new precursors of that accident. New Washington, DC. and at the local public ensure that fuel performance during normal, accident precursors may be created by document room for the particular transient, and accident conditions is modifications of the plant configuration. { facilityinvolved. _ *ccePtable. including changes in allowable modes of The probability of an evaluated accident is operation. This proposed license amendment Carolina Power 6 Light Company, et al., not increased by revising the safety limit does not involve any modifications of the Dockef No. 50-325 Brunswick Steam MCPR value to 1.09 (two-loop /1.10 single- plant configuration or changes in the Electric Plant, Unit 2, Brunswick looPl. The change does not require any allowable modes of operation. Therefore, no 4 County, North Carolina Physical plant modifications or physically new precursors of an accident are created I affect any plant components. Therefore, no and no new or different kinds of accidents Date of amendment request: February individual precursors of an accident are are created. 23,1998, affected. 3. Does this change involve a significant l Description of amendment request: The proposed license amendment reduction in a margin of safety? The amendment request proposes establishes a revised safety limit MCPR that As previously stated, the methods for I changes to the Brunswick Steam Electric ensures the fuel is protected during normal calculating the safety limit MCPR have been Plant Unit 1 Technical Specifications peration and during any plant transients or previously approved by the NRC and are l (TS)in support of Cycle 12 operation' """ ated perational occurrences. , Specifically. the reload analysis demonstrates described methodology in GE's topical reportreload NEDE-240licensing t 1. including a change to the Minimum that a safety limit MCPR value of 1.09 (two- l'se of mese methods ensures that the Critical Power Ratio safety limit (safety loop /1.10 single-loop) ensures that less than resulting safety limit MCPR satisfies the fuel limit MCPR) to a value equivalent to the 0.1 percent of the fuel rods will experience design safety criteria that less than 0.1 generic safety limit MCPR for General boiling transition during any plant operation percent of the fuel rods experience boiling Electric type GE-13 fuel. The request if the limit is not violated. transition if the safety limit is not violated. I would additionally re'nove a footnote The methods for calculating the safety Based on the assurance that the fuel design limit MCPR have teen approved by the NRC j limiting the stated value for the safety safety criteria will be met, the proposed limit MCPR to a specific fuel c and are descnbed in GE s reksad hcensms license amendment does not involve a reference to an NRC safety evafuclemethodology and topical report NEDE-24011. significant reduction in a margin of safety. ation .. General Electric Standard Application for documenting acceptance of methods Reactor Fuel (GESTAR II)." Based on (1) the The NRC staff has reviewed the used for determining the current cycle determination of the new safety linut MCPR licensee's analysis and, based on this safety limit MCPR. The amendment value using conservative approved methods, review, it appears that the three
f
- 4, e
25,1998 / Notices 14487
. Federal Register / Vol. 63. No. 57 / Wednesday, March The ehmmation of the direct iniection As required by 10 CFR 50 91b), the resulted in a flow reduction through the RSS instrumentation from SR lsurveillana licensee has provided its anahsis of tN heat exchanger, from approximately 4000 requirement] tables having no associated LCO llimiting condition for operationi. AIT issue of no significant hazardy gpm (gau ns pmnmutel t 1200 gpm. thus consideration
- which is presented reducmg the rate of the heat transfer from the fire protection systems descriptive text, and containment to the service water system. The correct previous typographical errors. Several below:
design basis of the containment heat removal of the proposed revisions involve changes Northeast Nuclear EnerRy Company systems (circa 1986) is that the containment which are consistent with NUREG-t 430. the (NNECO) has reviewed the proposed revision pressure will decrease to s Revised Standard Technical Specifications in accordance with 10CFR50 92 and has within one hour after the Design Basis (RSTS) for B&W plants. The reliability of concluded that the revision does not involve Accident to compensate for the reduction in systems and components depended upon to a significant hazards consideration (SHC). heat removal from the containment, a smaller prevent or mitigate the consequences of The basis for this conclusion is that the three allowable RSS pump degradation was accidents previously evaluated is not criteria of 10CFR50.92(c) are not satisfied.assumed in the revised containment analysis. degraded by the proposed changes because The proposed revision does not involve an The original RSS pump performance curve assurance of system and equipment was based on a 10 percent reduction in SHC because the revision would not: availability is maintained by surveillance 1. Involve a significant increase in the developed head from the design curve. For testing program requirements. probability or consequence of an accident the modification, a 5 percent reduction was
- 2. Operation of the facility in accordance previously evaluated. used. The results of the analysis show that with the proposed amendment would not The change to the Emergency Operating with these changes the design basis of creite the possibility of a new or different Procedures (EOP) to eliminate the use of maintaining substmospheric containment kind of accident fmm any accident Recirculation Spray System (RSS) direct pressure was met.
previously evaluated.The revised injection during cold and hot leg Based on the above, elimination of the surveillance requirements create no new recirculation does not effect the probability ' direct in,ection did not reduce the margin of Liture modes. Verification of equipment of any accident. The elimination of the safety because there was ao violation of the operation continues to be required by plant requirement to have RSS directly imiect! into acceptance limits and no weakening of the procedures. Elimination of the AIT fire the reactor coolant system did not increase protective boundaries. protection system descnptive text from the the consequences of the previously evaluated Therefore, the proposed revision does not TSs would not create a new or different kind accidents. These consequences were involve a significant reduction in a margin of of accident since the change has no effect on evaluated based on very conservative safety. surveillance methodology and frequency assumptions concerning the conta'nment in conclusion, based on the information requirements. They are maintained in the pressure after the design basis Ioss of provided, it is determined that the proposed Fire Protection Program. Coolant Accident (l.OCA), containment revision does not involve an SHC.
- 3. Operation of the facility in accordance integrated leakage rates, and the fraction of with the proposed amendment would not the sprayed volutne. None of these .
The NRC staff has reviewed the involve a significant reduction in a margin of assumptions were affected by the elimination licensee's analysis and, based on this safety because no operating limits are of the direct cold-leg inlection. review,it appears that the three cffected, Therefore, the proposed revision does not standards of to CFR 50.92(c) are involve a significant increase in the satisfied. Therefore,the NRC staff The NRC staff has reviewed the licensee's analysis and, based on this probability or consequence of an accident proposes to determine that the review,it appears that the three previously evaluated. amendment request involves no
- 2. Create the possibility of a new or stIndards of to CFR 50.G2(c) are different kind of accident from any accident significant hazards consideration.
l local Public Document Room satisfied Therefore, the NRC staff previously evaluated. proposes to determine that the The modification to the RSS did not create location:laarning Resources Center, 1 amendment request involves no the possibility of a new or different e accident Three Rivers Community-Technical l significant hazards consideration. " th pv s a y e, College,574 New London Turnpike, I [y',gy 9g Norwich, Connecticut, and the local Public Document Room ; location: Law / Government Publications flow path from the design basis of the system Waterford Library, A'ITN: Vince - Section, State Library of Pennsylvania- but did not involve physical modifications to juliano,49 Rope Ferry Roa:1, Waterford. the system itself. The opersbility of the Connecticut. (REGIONAL DEPOSITORY) Walnut affected valves within the direct injection Attorneyforlicensee: Lillian M. Street and Commonwealth Avenue, B" alignments remained unchanged and these Cuoco, Esq., Senior Nuclear Counsel, 1601, Harrisburg, PA 17105. paths were still available to the operators forNortheast Utilities Service Company. Attorneyfor heensee: Ernest L Blake, contingencies beyond the design basis. TheP.O. Box 270, ifartford, Connecticut. > I Jr., Esquire, Shaw, Pittman, Potts & EOPs provided clear and explicit guidance to NRC Deputy Director: Phillip F. Trowbridge,2300 N Street, NW., that effect. . __l Washington, DC 20037. Therefoni, the pmposed revision does not McKee. NRC Project Director: Cecil O. create the possibility of a new or different Southern California Edison Company, et kind of accident from any accident Th **** * . C'* s al., Docket Nos. 50-361 and 50-362, previousiy evaluated- San Onofre Nuclear Generating Station, FNortheast Nuclear Energy Company, et 3. Involve a significant reduction in a al., Docket No. 50~423, Millstone Unit Nos. 2 and 3, San Diego County, ,
**'B'"*f'*I"Y-In considering the impact on the margin of California ! Nuclear Power Station Unit No. 3. New London County, Connecticut safety as defined in the bases of the Date of amendment requests:
Technical Specifications. the impact of the November 2,1995, as supplemented by Dofe of amendment request: March 3. change on the design basis analysis of the letter dated January 9,1998.The
,2998. fission product barriers must tm evaluated Description of amendment request: The minimum Emergency Core Cooling January 9,1998, submittal supersedes The proposed revision to the Millstone System flow requirement for long. term core the staff's proposed no significant t Unit 3 licensing basis would eliminate c ling is that the modified alignment " hazards consideration determination evaluation for the requested changes the requirement to have the he ves el due to he recirculation spray system directly fo's te il i that was published on April 10,1996 inject into the reactor coolant system decay heat and the extended boiling from hot (61 FR 15995).
following a design basis accident- metal in the downcomer and the lowcr Description of amendment requests: plenum. The analysis determined that these In the November 2,1995, letter, the Basis for proposed no significant requirements were being met. hazards consideration determination: I}}