ML20247A484

Safety Evaluation Supporting Amend 121 to License DPR-61

ML20247A484
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Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	09/05/1989
From:	Office of Nuclear Reactor Regulation
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ML20247A454	List: ML20247A447 ML20247A465 ML20247A484
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NUDOCS 8909120130
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SAFE'Y EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.121

]0FACILITYOPERATINGLICENSENO.DPR-61 CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT D_0CKET NO. 50-213 f 10 INTRODUCTION On April 21,19E9, Connecticut Yankee Atomic Power Company (CYAPCO) submitted a proposed amendment to Facility Operating Licente No. DPR-61. The proposed amendment combines Technical Specification (TS) Section 3.6 " Core Cooling Systems," Section 3.7 " Minimum Water Volume and Boron Concentration'in the Refueling Water Storage Tank," and Section 4.3, " Core Cooling Systems -

Periodic Testing." The new combined section will be Section 3.6 titled,

'" Emergency Core Cooling Systems." The new section upgrades the current custom TS format to the Westinghouse Standard Technical Specification (WSTS) fonnat with definitive Limiting Conditions for Operation (LCO) statements and Action statements. In addition, there are some changes to the current TS which are ade m ed in the Evaluation.

2.0 DISCUSSION As part of the Systematic Evaluation Program (SEP), CYAPCO committed to convert L their custom TS to the WSTS. In a meeting on September 20, 1988, CYAPCO proposed to submit the TS conversion packages over a three month period i

beginning October 1988. With the impending issuance of the revised WSTS, the staff proposed that it would be advantageous for CYAPCO to await the issuance of the revised WSTS before addressing the full WSTS conversion. In the interim, the steff agreed that the custom TS format could be upgraded to the current WSTS fcnnat. The :;taff concluded that this interim step would: 1)

_ provid.e a substantially improvec' T3 while facilitating the future conversion effort to the revised.WS15, 2) provide definitive LCO and action statements for l'

several safety related systems, 3) eliminate the use of administrative TS, 4) provide a mechanism to close prior TS connitments associated with NUREG 0737,

l. . SEP and various,other Generic letter (GL) recommendations, and 5) eliminate ll ambiguities inherent with tne wording and format of the current TS. Based on l- tha above, the staff concluded thet the revised TS would significantly enhance ,

public safety'and therefore justified this interim step to improve the Haddam I

l. Neck TS. The staff has informed CYAPCO several times that this TS does not I fulfill CYAPCO's SEP comitment to convert to the WSTS.

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This amendment is one of several that is part of the TS upgrade. With a letter dated September 22, 1987, the NRC provided Northeast Utilities with an acceptable revision of the WSTS. The TS upgrade will be using the provided WSTS revision as a guidance while niaintaining its current TS requirements.

Since this upgrade is primarily a format change, the staff did not pursue all deviations and_ omissions from the provided WSTS with the same intensity Os would have been done for a normal WSTS conversion. Therefore, if the proposed TS omits portions of the requirements that appear ir. the provided WS1'S revision and these same requirements did not already exist in the current TS, tM review of these omissions will be deferred to the full WSTS conversion.

However, where new TS statements have been proposed (statements not previously found in the current TS) that deviate from the provided WSTS revision, a review of the deviation will be given. The deviations will be reviewed in

. part, based on' three previously agreed upon criteria: 1) plant specific design, 2) previously approved hardware, structural or organizational changes, and 3) past operating experiences that can be shown to provide an equivalent degree of protection to that provided by the WSTS. Any deviations from the current custom TS will also be reviewed. The format change and the additional restrictions resulting from this amendment make substantial improvements in the clarity and readability of the TS. As a result, the staff considered this TS upgrade beneficial from both a public safety and an operational perspective.

3.0 EVALUATION The evaluation has been divided into two sections.Section I will address proposed TS that are consistent with the provided WSTS and/or the current TS. In addition, many of these TS sections add restrictions to the current TS.Section II will address proposed TS that relax restrictions from either the current TS or the provided WSTS revision. As noted earlier, the staff did not perform a " completeness" review to ensure that all secticns of the WSTS were included in this format change. Therefore, this review will exclude the review of complete omissions of WSTS sections that did not already exist in the current TS. Each of the deviations will be addressed individually. If a GL or a SEP issue has been addressed by the proposed TS change then it will also be noted.

3.1 Section I Previously, the NRC staff provided a version of the WSTS to CYAPC0 and excluding plant specific alterations, stated the provided WSTS should be an acceptable guidance for a STS conversion. Although this amendment is not a STS conversion, the amendment does follow the guidance of this WSTS revision. The logic fdr this TS upgrade has been stated in the Discussion section of this Safety Evaluation. Figure 1 provides a list of proposed TS that are consistent with the provided WSTS and/or the current TS. In many cases the propose'd TS impose added restrictions to the current TS or add restrictions that do not currently exist. In all cases, the proposed TS listed in Figure 1 do not relax any of the restrictions found in the current custom TS.

Based on the above, the staff has concluded that the TS changes associated with Figure I are be purely administrative (format change) or provide additional limitations restrictions or controls not previously included in the Haydam Neck TS. T6erefore the staff concludes that the proposed TS listed in rigure 1 are acceptable, u-_____-______-_._ _. - -

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. 3.2 Section II The TS reviewed in this section will be addressed by number and subsection as it appears in the proposed TS. For the remainder of this evaluation "WSTS" will refer to the WSTS revision that the NRC provided to Northeast Utilities with a letter dated September 22, 1987.

3.6.1 LCO a.6 The purpose of this LCO is to require two independent Emergency Core Cooling Systems (ECC3) to be operable and list the components of those systems that must be operable. Part 6 of this LCO requires an operable flow path capable of taking suction from the Refueling Water Storage Tank (RWST) on a Safety Injection Signal (SIS) and suction from the containment sump during'the recirculation phase of operation.

The proposed TS deviates from the WSTS by requiring a manual transfer of pump suction to the containment sump during the recirculation phase of operation.

The WSTS requires an automatic transfer of suction. The deviation is a result of the Haddam Neck plant design which does not allow for an automatic transfer. In view of the design, the term " automatic" would not be applicable to this LCO. Currently, the manual transfer sequence and-conditions are dictated by CYAPCO's procedure no. ES-1.3. Based on SEP Topic VI - 7.B and the review of the transfer procedures, the staff determined that the proposed TS in conjunction with the existing procedures does meet the intent of the WSTS.

Therefore, the staff finds the proposed TS to be acceptable.

3.6.1 LCO b and Associated Action b The purpose of this LCO is to require two independent ECCS trains to be operable and list the components of these systems that also must be operable.

Part b of the proposed LCO requires a flow path from the reactor cavity to the containment sump through reactor cavity pool seal hatches and transfer canal drain valves. The associated action statement requires that if the flow path from the reactor cavity to the containment sump is inoperable, the flow path must be restored to operable status within one hour or be in cold shutdown within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The proposed TS does not exist in the WSTS or the current TS and is the result of the installation of a permanent reactor cavity pool seal. The intent of this LCO is to prevent water that may accumulate in the reactor ctvity as a result of the seal, from starving the containment sump. Prior to the installation of the permanent reactor cavity i pool seal, any water that would accumulate in the reactor cavity would return

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j to the containment sump by the drip pans. When the permanent seal was 1 installed. a different method for returntng water to the sump was required. By l allowing the cavity pool seal hatches to remain open, any accumulated water can again drain throuhh the drip pans to the containment sump. The transfer cana7 j drain valves.will also be open to drain additional low points of the refueling i cavity. Currently, CYAPC0 has been following this practice through the use of l administrative TS used in conjunction with the current TS. The proposed TS w

L* , O adds an additional restriction to the current TS and provides an effective means of preventing a possible shortage of water in the containment sump that could adversely affect the recirculation design. In addition, requiring a timely shutdown of the reactor on a loss of this flow path provides an effective response for this condition. Therefore, the staff concludes that this proposed TS is acceptable.

3.6.1 Surveillance a This surveillance provides a list of valves, valve functions and valve positions required at operation. The surveillance requires that the valves be verified in the listed positions at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

The proposed TS deviates slightly from the current TS when referring to valve no. RH-FCV-602 and valve no. RH-MCV-22. The current TS requires valve no.

RH-FCV-602 to be locked in the closed position. The proposed TS requires the valve to be blocked in the closed position. CYAPCO proposed the change as a matter of clarity since the terms describe the manner in which a valve is secured in a given position. CYAPC0 used the term " locked" to refer to a valve that is secured in position by a padlock and chain. CYAPCO uses the term " blocked" to refer to a valve that has a split and hinged lengthwise section of pipe padlocked around the valve stem. Since in both cases the valve is secured in a given position with a padlock, the staff determined that the change offers an equivalent level of protection to the current TS.

Therefore, the staff determined that the change is acceptable.

The current TS requires valve no. RHR-MOV-22 to be locked open during normal operation and the circuit breaker be locked open during the post LOCA phase.

CYAPCO's proposed TS only specifies the normal operation position which CYAPCO states is the intent of this TS. In addition they note that the valve position is incorrectly stated in the current TS. The closed position is consistent with Emergency Response Procedure ES-1.3 which requires the operators to initiate recirculation during a LOCA transient by opening valve RHR-MOV-22. The staff agrees that the intent of this TS is to verify valve position during normal operation and that the valve's correct position is closed during nomal operation. Based on the above, the staff concludes that the proposed TS is acceptable.

3.6.1 Surveillance d.2 The purpose of this surveillance is to verify that no loose debris are present in containment that cou-id be transported to the containment sump and cause a restriction of pump suctions. Part 2 of this surveillance requires that the areas of containment affected by the work activity be inspected within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of each containment entry and at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter.

While there is no current TS requirement. the administrative TS require a visual' inspection for. loose debris at the completion of each containment entry when CONTAINMENT INTEGRITY is established. The proposed TS deviates from the administrative TS in that the visual inspection will be done within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

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following each entry and at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> thereafter. In addition, the visual inspection has been tied to the containment air lock (

testing. CYAPC0 states that while the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is less restrictive than the j administrative TS, it does provide a more definitive inspection interval and by procedure will be a prerequisite to closing the air lock and performing the air lock test. This TS will eliminate an administrative TS and although it is slightly less conservative, it does provide more definitive language as to when the visual inspection will be performed. The staff has concluded that this TS will provide sufficient assurance that any loose debris will be cleaned-up by the visual inspections performed at least once every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after an initial containment entry and prior to the final exit from containment when any work activity is completed. Based on the above, the staff concludes that the proposed TS is acceptable.

3.6.2 LCO b The purpose of this LC0 is to require one ECCS subsystem to be operable and list the components of these systems that also must be operable when in MODE 4 Part b of the proposed LCO requires that a flow path be available from the reactor cavity to the containment pump through the reactor cavity pool seal hatches and transfer canal drain valves.

This LC0 is the same requirement as proposed TS ?,.6.1 LC0 b except it applies only to MODE 4 when only one ECCS subsystem is r.. quired. The logic of the evaluation of 3.6.1 is directly applicable to this LCO. Therefore, based on the staff's previous conclusion for TS 3.6.1 LCO b, the staff concludes that 4 the proposed TS is acceptable. .

3.6.2 Surveillance a This surveillance applies to the plant in MODE 4 and requires that the ECCS subsystems shall be demonstrated operable per the applicable Surveillance Requirements of TS 3.6.1 with the exception that, for valves RH-FCV-602 and RH-FCV-796, restoration of valve controls be allowed.

Tb; proposed TS deviates from the WSTS by allowing the restoration of valve controls for the valves RH-FCV-602 and RH-FCV-796. The valve exception statements do not appear in the WSTS and are not specifically stated in the current TS. The valves are used as a part of the shutdown procedures to control the cooldown rate while in MODE 4. The two valves control the cooldown rate, by adjusting the flow through the RHR heat exchangers while maintaining a constant pump flow rate. The valves are placed in service as part of Shutdown Procedure No. 6.4. Once in service, the valves are controlled automatically by temperature and flow. If the exception statement l was not included As part of this Surveillance, CYAPC0 would be in violation of TS when following the existing procedures used to control the cooldown rate. Since the valves are necessary to control the cooldown rate and are an integral part of the current plant procedures, the staff determined that the exception statement for these two valves is warranted. Therefore, the staff finds the proposed TS to be acceptable.

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3.6.4 The proposed TS establishes LCO, Applicability, ac tion and Surveillance requirements for a PH Control System. The current TS and the WSTS do not contain this porticular TS. The control system provides Trisodium Phosphate Dodecahydrate (TSP) stored in po8us wire mesh baskets located adjacent to the containment sump. The TSP will be used to raise the PH of the sump during accident conditions. With the given amount of TSP, CYAPC0 has calculated the approximate PH for various conditions and has included these numerical values  ;

in the Basis section. The proposed TS represents an added restriction to the current TS and will help reduce the susceptibility of certain ECCS components to stress corronon cracking. Based on the above, the staff has determined that the proposed TS will provide a reliable method of controlling PH during an accident. Therefore the staff concludes that the proposed TS is acceptable.

4.0

SUMMARY

After checking the current TS sections 3.6, 3.7 and 4.3, the steff determined that the current TS requirements have been maittained by the proposed TS.

Furthermore, the proposed amendment offers not only an improved format over the current TS but also adds numerous TS restrictions to plant operation.

Based on the considerations discussed in the above evaluation, the staff concluded that the proposed amendment will make overall improvements in operational safety while maintaining the current safety analysis. The r efore.,

the staff finds the proposed amendment to be acceptable.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. We have determined that the amendment involves no significara 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 staff has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 651.22(c)(9).

Pursuant to 10 CFR 951.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by ope' ration in the proposed manner, and (2) such activities will be I l

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.the health and safety'of the public.--

Dated:- September 5,:1989, L .c . Principal ' Contributor:' G. E. Garten -

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I,- '4 s Figure-1

-TS# SUBSECTIONS ' TYPE 3.6.1 ~a-1,2,3,4,5 LCO

'3.6.1 Applicability' 23.6.1 a;b Action 3.6.1 b;c-1,2,3,4 Surveillance d-1; e-1,2 f-1,2,3;g h-1,2,3;i;j

-Table 3.6-1 3.6.2 a-1,2,3,4 ~LCO.

3.6.2- Applicability

, 3.6.2 a,b,c Action

- 3.6.2 b-1,2,3 Surveillance 3.6.3 a,b,c,d LC0 3.6.3- Applicability 3.6.3 . Action 3.6.3 a;b Surveillance t

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