ML20217Q752
| ML20217Q752 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/28/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20217Q747 | List: |
| References | |
| NUDOCS 9709030348 | |
| Download: ML20217Q752 (4) | |
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It UNITED STATES g
,j NUCLEAR RELULATORY COMMISSION g,
t WAaHINGToN, D.C. 30665-0001 s.,...../
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 147 TO FACILITY OPERATING LICENSE NO. NPF-49 NORTHEAST NUCLEAR ENERGY COMPANY. ET AL.
MILLSTONE NUCLEAR POWER STAT 10ti. UNIT NO. 3 DOCKET NO. 50-423
1.0 INTRODUCTION
By letter dated May 5, 1997, the Northeast Nuclear Energy Company, et al. (the licensee), submitted a request for changes to the Millstone Nuclear Power Station, Unit No. 3 Technical Specifications (TS).
TS Surveillance 4.5.2.b.1 requires that the emergency core cooling system (ECCS) piping be verified full of water at least once per 31 days.
The proposed amendment would evise the surveillance to exempt the operating charging pump (s) and associated piping from the requirement to be verified full of water and move the description of the verification method from the surveillance to the Bases section.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act of 1954, as amended (the "Act"),
requires applicants for nuclear power 31 ant operating licenses to sttde TS to be included as part of the license.
Tie Commission's regulatory redirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) Nrveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
e The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which 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 A> peal Board indicated that " technical specifications are to be reserved for tiose 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 "
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w 2-Consistent with this approach the Final Policy Statement identified four criteriatobeusedindetermlningwhetherparticularsafetyfunctionsare required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a si abnormal degradation of the reactor coolant pressure boundary;gnificant variable, design feature, or operating restriction that is an in(2) a process itial 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, syt, tem, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and (4) a structure, system, or component which operating experience or 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 requirements which fall within or satisfy any of the cr).) As a result, TS iteria in the Final Policy Statement must be retained in the TS while those TS requirements which 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 Updated Final Safety Analysis Report (UFSAR), such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Other requirements may be relocated to more ap Assurance (QA) Plan,propriate documents (e.g., Security Plan, Quality and Emergency Plan) and controlled by the applicable regulatory requirement.
Similarly, while the required content of TS of administrative controls may be relocated to licensee-co)ntrolled documentsad where 10 CFR 50.54, 10 CFR 50.59, or other regulations provide adequate regulatory. control.
While the criteria specifically apply to LCOs, in adopting the revision to the rule, the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS (60 FR 36958). Addressing ada.inistrative controls, 10 CFR 50.36 states that they "are the provisions relating to organization and management, precedures, recordkeeping, review and audit, and reportin operation of the facility in a safe manner." g necessary to assure safe The specific content of the administrative controls section of the TS is therefore that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from the administrative controls section.
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3.0 EVALVATIfd TS Surveillance 4.5.2.b.1 currently states that the ECCS piping, except for the recirculation spray system (RSS) pump, heat exchanger and associated piping, be verified full of water by venting the ECCS pump casings and accessible discharge piping high points.
In its letter dated May 5, 1997, the itcensee proposed to modif centrifugal charging pump (y the TS surveillance by exempting the operating s) and associated piping from the requirement to be vented at least once per 31 days.
The licensee stated that this surveillance is intended for systems and components that have the potential to develop voids and pockets of entrained gases due to their not being in service. An operating centrifugal charging pump and the associated piping is self venting and cannot develop voids and pockets of entrained gases.
The licensee also pro)osed moving the description of the venting method from the surveillance to t1e Bases section. The licensee stated that the venting description would be expanded when moved to the Bases to include an exclusion for the above described operating centrifugal charging pump (s) and associated piping and the venting method used for nonoperating centrifugal charging pump (s).
The centrifugal charging pumps have top mounted suction and discharge nozzles and do not have casing vents.
The pump manufacturer has indicated that venting the pump suction pipe will assure that the pump is full of water. This venting of the nonoperating centrifugal charging pumps is accomplished by using a pump suction line test connection.
The NRC staff has reviewed the licensee's )roposed changes and has determined that exempting the operating centrifugal ciarging pump (s) and associated piping from the requirement to be vented is acceptable since (1) the operating pum)(s) and associated piping is self venting and cannot develop voids and poc(ets of entrained-gases, and (2) the surveillance requirement continues to require that the nonoperating centrifugal charging pump (s) be vented every 31 days.
In addition, since the operating centrifugal charging pump (s) and associated pipin entrained gases,g is self venting and would not contain voids or pockets of it should perform properly when called upon to inject water into the reactor coolant system.
Stopping the operating centrifugal charging pump (s) to vent it as currently required by the TS would not (1) identify a significant abnormal degradation of the reactor coolant pressure boundary, (2) present a challenge to the integrity of a fission product barrier, (3) be necessary to ensure that the charging system would be able to mitigate a design basis accident or transient, or (4) result in a significant impact to public health and safety.
Therefore, excluding the operating charging pump (s) from TS Surveillance 4.5.2.b.1 satisfies the four criteria in the Final Policy Statement on TS.
The staff has determined that moving the description of the venting method from the surveillance to the Bases is acceptable in that the surveillance requirement continues to require that the venting be accomplished every 31 days. The Bases will contain how the venting will be accomplished. The description of how the venting will be accomplished is not otherwise required m
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to be included in the TS pursuant to 10 CFR 50.36, in that it does not satisfy the criteria in the Commission's Final Policy Statement. Changes which might be made to the venting method will be adequately controlled by the licensee.
Therefore, moving the description of the venting method from the surveillance to the Bases is acceptable. The staff notes that excluding the o>erating centrifugal charging pump (s) and the placement of the venting metiod description in the Bases is consistent with the Standard Technical Specifications for Westinghouse Plants (NUREG-1431).
The NRC staff has reviewed the proposed change to Bases Section 3/4.5.2 and 3/4.5.3 and has no objection to the wording.
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.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes surveillance requirements.
The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (62 FR 30638 dated June 4, 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 environmental assessment need be prepar(b) no environmental impact statement or ed in connection with the issuance of the amendment.
6.0 CONCLUSION
Ihe Commission has concluded, based on the considerations discussed above, that:
(1) there is-reasonable assurance that the health and safet public will not be endangered by operation in the proposed manner,y of the
- 2) such activities will be conducted in compliance with the Commission's reg (ulations, and (3) the issuance of the emendment will not be inimical to the common defense and security or to i + health and safety of the public.
Principal Contributor: J. Andt rsen Date: August 28, 1997
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