ML20236B646
| ML20236B646 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/21/1987 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236B649 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 B12588, GL-83-36, GL-83-37, TAC-54546, NUDOCS 8707290182 | |
| Download: ML20236B646 (4) | |
Text
--
-l
]
- l NORTHEAST UTILITIES cenemi Omces seiden street. Berna. connecticut 1
T NO rs$eNcc P.O. BOX 270 s
)
.xxce we e=" cw-HARTFORD, CONNECTICUT 06141-0270 L
L J %Z C'e",",%.l".~,
(203) 665-5000 i
July 21,1987 Docket No. 50-336 B12588 Re: Generic Letter 83-37 U.S. Nuclear Regulatory Commission Attention: Document Control Desk i
Washington, D.C. 20555 Gentlemen:
]
Millstone Nuclear Power Station, Unit No. 2 Proposed Changes to Technical Specifications Generic Letter 83 NUREG-0737 Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its operating license, No. DPR-65, by incorporating the attached changes into the Technical Specifications for Millstone Unit No. 2.
In a letter dated October 14,1986, (I) NNECO proposed changes to the Technical l
Specifications for Millstone Unit No. 2 to address Generic Letter 83-37.(2) Since l
that time this issue has been the subject of much discussion between the NRC
(
Staff and NNECO. Based on those discussions, NNECO hereby submits revised I
proposed Technical Specification changes to address Generic Letter 83-37. This submittal supersedes Reference (1) in its entirety.
The proposed changes, included as Attachrnent (1) to this letter, consist of new Technical Specifications that provide limiting conditions for operation (LCO) and surveillance requirements in response to Generic Letter 83-37, as well as other Technical Specification changes proposed to provide clarifications of other unrelated topics. Attachment (2) to this letter provides a list of each of the individual elements of Generic Letter 83-37, how they compare to model i
specifications recommended by the NRC Staff, and why NNECO's proposed changes are justified.
Attachment (3) describes the other Technical Specification changes included in this amendment request.
(1)
- 3. F. Opeka letter to A. C. Thadani, " Proposed Changes to Technical Specifications, Generic Letter 83 NUREG-0737," dated October 14, 1986.
(2)
Darrell G. Eisenhut letter to All PWR Licensees, "NUREG-0737 Technical
)
Specifications (Generic Letter No. 83-37)," dated November 1,1983.
id 8707290102 870721 g
gDR ADOCK0500g6 ij qMCpp.$
i w
1 i
l U.S. Nuclear Regulatory Commission B12588/Page 2 July 21,1987
)
NNECO has reviewed the attached proposed changes pursuant to 10CFR50.59 and has determined that they do not constitute an unreviewed safety question.
With the exception of the changes related to the surveillance on the Auxiliary Feedwater (AFW) System, none of the systems or instruments affected by the proposed changes are required for safe shutdown or mitigation of design basis accidents.
Most of the proposed changes will add LCOs and surveillance requirements for instrumentation and systems which could be used for post-l accident monitoring a id mitigation of accidents beyond the design basis. This instrumentation will enhance the operators ability to monitor an accident, but j
their postulated failure will not adversely affect the consequences.
I i
The proposed changes to the AFW surveillance do not change the frequency of a method for testing but rather make the testing requirements consistent with other Engineered Safety Features listed in Technical Specification Table 4.3-2.
This testing is currently performed as part of the surveillance for item 9.b, l
"S team Generator Level-Low," of Table 4.3-2 "ESF Actuation System l
Instrumentation Surveillance Requirements".
Thus, this change is only l
administrative in nature.
l All design basis accidents were reviewed for any potential impact due to these changes.
None of the proposed changes would impact adversely the i
consequences of any postulated accident. On the contrary, the operators' ability to monitor the course of an accident wil'. be enhanced by the instrumentation l
addressed in the proposed specifications.
The availability of the RCS Vent System will improve the ability of the operators to vent non-condensible gases from the RCS during accidents which progress beyond the design basis. The proposed specifications help ensure that the instrumentation and systems involved are available if and when needed.
The proposed changes do not increase the probability or consequences of an accident previously analyzed or create the potential for a new unanalyzed accident nor reduce the margin of safety as defined in the basis of any Technical Specification.
The proposed changes adc' new LCOs and surveillance requirements to ensure that instrumentation and systems are available to aid operators in the mitigation of events both within or beyond the design basis of Millstone Unit No. 2, consistent with the intent of Generic Letter 83-37.
The two proposed changes discussed in Attachment (3) are not directly related to Generic Letter 83-37. The first is editorial in nature and the second adds new LCOs and surveillance requirements for radiation monitors that were added to the main steamlines at Millstone Unit No. 2. They do not involve any substantive additions or deletions to the Technical Specifications and are therefore con :luded by NNECO to not constitute an unreviewed safety question.
NNECO has reviewed the proposed changes, in accordance with 10CFR50.92, and has concluded that they involve no significant hazards considerations in that these changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
Since the proposed changes provide additional reporting requirements and greater assurance that
U.S. Nuclear Regulatory Commission B12588/Page 3 1
July 21,1987 instrumentation and systems will be available to the operators, there is no increase in the probability or consequences of an accident previously analyzed.
i 2.
Create the possibility of a new or different kind of accident from any previously analyzed.
Again, due to the nature of these changes as described above, no new accidents or malfunctions are created. These proposed changes provide additional controls and restrictions over systems I
already in service at'the' plant.
i 3.
Involve a significant reduction in a margin of safety. As previously stated, these changes will not adversely affect the margins of safety in existing specifications.
These proposed changes represent additions to the Technical Specifications. They involve systems that have been in operation j
l in response to NUREG-0737.
1 NNECO's conclusion that the three criteria of 10CFR50.92(c) are not compromised is supported by our determination made pursuant to 10CFR50.59.
With respect to the proposed specifications discussed in Attachment (2), our review of the given examples in 51 FR 7750, March 6,1986, of amendments that l
are considered not likely to involve a significant hazards consideration has i
determined that example (ii), a change that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications, is applicable.
The proposed changes institute new LCOs and surveillance requirements which will help ensure the reliability of the instruments that l
monitor the course of an accident.
l i
With respect to the proposed specifications discussed in Attachment (3), our I
review of the given examples in 51 FR 7750, March 6,1986, of amendments that are considered not likely to involve a significant hazards consideration has determined that example (i), a purely administrative change to the Technical Specifications is applicable to the first of the two changes. This proposed change described in Attachment (3) is editorial in nature, bringing about consistency between different Technical Specifications. The second change is best represented by example (ii), a change that constitutes an additional limitation, restriction or control not presently included in the Technical Specifications.
These proposed changes would add LCOs and surveillance requirements for the main steamline radiation monitors recently installed at i
l Millstone Unit No. 2.
The Millstone Unit No. 2 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.
In accordance with 10CFR50.91(b), we are providing the State of Connecticut with a copy of this proposed amendment.
Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment request is the application fee off $150.00, t
U.S. Nuclear Regulatory Commission B12588/Pagete July 21,1987 These proposed changes are not required to support continued plant operation but are being submitted at the request of the Staff. Therefore no schedule for amendment issuance has been proposed herein.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY '
/20 i
E. Ypffoczka g i
Seni6r Vice President l
cc:
Kevin McCarthy l
Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 W. T. Russell, Region 1 Administrator D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 T. Rebelowski, Resident Inspector, Millstone Unit Nos. I and 2 1
l STATE OF CONNECTICUT )
) ss. Berlin l
l COUNTY OF HARTFORD )
Then personally appeared before me E. 3. Mroczka who, being duly sworn, did i
state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.
k&/1it-Notary Publ
/h*
Mr Commisslun Expires March 31,1988 l
l L--___-._______
.