ML20236K106
| ML20236K106 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/02/1987 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236K109 | List: |
| References | |
| B12658, TAC-66323, TAC-66592, NUDOCS 8711090100 | |
| Download: ML20236K106 (4) | |
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HARTFORD. CONNECTICUT 06141-0270 i
L J %',0",J',",1",Jg; I203) 665-5000 November 2,1987 Docket No.' 50-336 B1265_8 Re: 10CFR50.90 -
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:
Millstone Nuclear Power Station, Unit No. 2 i
Proposed Revision to Technical Specifications Radioactive Ef fluent Monitoring l
Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby j
proposes to amend its Operating License DPR-65 by incorporating the attached
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changes into the Technical Specifications of Millstone Unit No. 2.
BACKGROUND The proposed changes are being submitted for the purpose of clarifying the length of time that radioactive liquid and gaseous monitors may be taken out of service for the purpose of maintenance, required tests, checks, calibrations or sampling. Clarification is also provided for when auxiliary sampling equipment must be initiated.
The concerns addressed by these proposed changes were identified as a result of the review of the Technical Specifications for another of NNECO's nuclear units.
DESCRIPTION OF CHANGES Proposed changes to Pages 3/4 3-52 and 3/4 3-57, Tables 3.3-12 and 3.3-13 respectively, specify a specific limit as to how long the Radioactive Effluent q
Monitoring Instrumentation may be out-of-service for the purpose of I
maintenance, required tests, checks, calibrations or sampling.
The proposed change replaces the statement "within the time frame of the specified ACTION statement" with "for a maximum of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />"la two places in the Table Notes on Page 3/4 3-52, and in one place at the bottom of Page 3/4 3-57. Also, " sampling" is being added to the Table Notes in all three places as an additional reason for instrumentation to be out-of-service.
The proposed change to ACTION r
statement 2 on Page 3/4 3-58 adds the sentence " auxiliary sampling must be I
r initiated within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of initiation of this ACTION statement."
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U. S. Nuclear Regulatory Commission I
B12658/Page 2 November 2,1987 i
SAFETY ASSESSMENT The proposed changes are administrative in nature and are intended to provide a clarification of the existing Technical Specifications. The proposed wording changes reflect what NNECO believes is the most likely interpretation given to the present wording. The twelve (12) hour period specified during which the s
effluent monitors may be out-of-service is less than one (1) percent of the total hours in a calender quarter. Off-site dose limits for normal plant operations are based on a calendar quarter. The loss of effluent data for this short period of time should have little or no effect on the accuracy of the calculations.
Although theoretically the instruments could be out-of-service for more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> in a particular calendar quarter, past experience has shown that for the specific purposes intended (i.e., maintenance, required tests, checks, calibrations or sampling), these instruments are not out-of-service for more than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per average calendar quarter.
The twelve-hour time limit is actually more restrictive than the existing Technical Specifications which do not specify a particular time limit.
The addition of the word " sampling" as an additional off-line purpose is also administrative in nature and serves only to clarify the purposes which may be accomplished during off-line time of the radioactive effluent monitoring instruments. The addition of a sampling function to the off-line purposes has no impact on safety since 'it only clarifies the intent of the Technical Specifications and changes nothing.
The addition of a sentence regarding the initiation of auxiliary sampling within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of initiation of the ACTION statement (on page 3/4 3-38) does not consist of a change in actual requirements for initiation of the ACTION statement, only clarifies the intent of the Technical Specifications and thus raises no safety questions.
No hardware, sof tware or setpoint changes are involved in this wording change and there is no reduction in the margin of safety.
SIGNIFICANT HAZARDS CONSIDERATION NNECO has reviewed the proposed changes in accordance with 10CFR50.92 and has concluded that they do not involve a significant hazards consideration in that these changes would not:
1.
Involve a significant increase in the probability or consequences of an accident previously analyzed.
The proposed changes only address the operability requirement for radioactive effluent monitoring instrumentation and are administrative in nature. The proposed changes are intended to clarify existing controls in the present Technical Specifications.
2.
Create the possibility of a new or different kind of accident from any previously analyzed. Since the proposed changes are administrative and have no impact on design basis accidents, these changes do not modify the plant response or present a new unanalyzed accideot.
U. S. Nuclear Regulatory Commission B12658/Page 3 -
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November 2,1987 3.
' Involve a significant reduction in a margin of safety. Since these proposed changes are administrative in nature with no reduction in the restrictions provided by the operability and surveillance requirements, there is no l
Impact on safety limits.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6,1986). The proposed changes described herein most closely resemble example (i); a change to achieve consistency thr, wt the Technical Specifications, correction of an error, or a change in nomenclature. These proposed changes are administrative in nature and clarify existing Technical Specifications by providing a specific time limit during which the radioactive effluent monitoring instrumentation may be out-of-service. " Sampling"is also added as a reason for instrumentation to be out-of-service and a specific time limit is given after which auxiliary sampling must be initiated.
The Millstone Unit No. 2 Nuclear Review Board has reviewed and approved the attached proposed revisions and has concurred with the above determinations.
These changes are being proposed to provide clarification of existing Technical Specifications. NNECO does not have any urgent need for these changes and therefore no schedule for approval and issuance by the Staff is requested.
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 of $150.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY
% de E. Jgroczka /
Senior Vice President Attachment cc:
Kevin McCarthy Director, Radiation ContrcA Unit Department of Environmental Protection Hartford, CT 06116 W. T. Russell, Region I Administrator D. H. Jaffe, NRC Project Manager, Millstone Unit No. 2 W. 3. Raymond, Senior Resident Inspector, Milistone Unit Nos.1,2, and 3
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U. S. Nuclear Regulatory Commission 1
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B12658/Page 4 November 2,1987 STATE OF CONNECTICUT )
) ss. Berlin COUNTY OF HARTFORD.
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Then personally appeared before me E.3. Mroczka, who being duly sworn, did 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 informa 'on are true and correct to the best of his knowledge and belief.
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.Ye9HJW Notary Publy My Comm!ss(on Expires March 31,'1988