ML20248A100
| ML20248A100 | |
| Person / Time | |
|---|---|
| Site: | Millstone |
| Issue date: | 08/01/1989 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20248A104 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM B13298, GL-83-36, NUDOCS 8908080200 | |
| Download: ML20248A100 (5) | |
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August 1, 1989 j
Docket No. 50-245 E13298 Re:
10CFR50.90 ISAP Topic 1.36 GL 83-36 i
U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 i
Gentlemen:
Millstone Nuclear Power Station, Unit No.1 Generic Letter 83-36, TMI Technical Specifications Noble Gas Effluent Monitors - NUREG-0737. Item II.F.1.1 Pursuant to 10CFR50.90, Northeast Nuclear Energy Company (NNECO) hereby proposes to amend its Operating License No. DPR-21 by incorporating the i
proposed changes identified in Attachment 1 into the Technical Specifications i
of Millstone Unit No. 1.
By letter dated November 1, 1983,II) the NRC Staff provided to all boiling water reactor licensees clarification of certain TMI Action Plan Requirements j
(NUREG-0737) by issuance of Generic Letter 83-36.
This letter requested licensees to propose changes to their Technical Specifications to address each
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of the action plan items, identified in Enclosure 1 of that letter, tgt is applicable to their facilities.
By letter dated October 15, 1985, as i
addressed in Integrated Safety Assessment Program (ISAP) Topic No. 1.36, NNEC0 l
provided a status of each of these items in Enclosure I to Generic Let-i ter 83-36 as apolicable to Millstone Unit No.1.
After final review of the Technical Specifications recommended by Generic Letter 83-36, NNEC0 hereby proposes the modification to the Millstone Unit No. 1 Technical Specifications j
as identified in Attachment 1.
l Provided below is detailed information which supports the proposed modifica-
- tions, i
t (1)
D. G. Eisenhut letter to All Boiling Water Reactor Licensees, "NUREG-0737 Technical Specifications (Generic Letter 83-36)," dated November 1,1983.
(2)
J. F. Opeka letter to C. I. Grimes, " Millstone Nuclear Power Station, Unit No. 1, Integrated Safety Assessment Program," dated October 15, 1985.
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I U.S. Nuclear Regulatory Conrnission B13298/Page 2 August 1, 1989 i
Noble Gas Effluent Monitors (TMI Item.II.F.1.1)
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l' Generic Letter 83-36 states in part
... Noble Gas effluent monitors provide information, during and following an accident, which are considered helpful to the operator in accessing the plant condition.
It is desired that j
these monitors be operable at all times during plant operation, but they are not required for safe shutdown of the plant.
In case of failure of the j
monitor, appropriate actions should be taken to restore its operational capability in a reasonable period of time.
Considering the importance of the availability of the equipment and possible delays involved in administrative controls, 7 days is considered to be the appropriate time period t) restore the operability of the monitor.
An alternate method for monitoring the l
effluent should be initiated as soon as practical, but no later than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> l
after the identification of the failure of the monitor.
If the monitor is not restored to an operable condition within 7 days after the failure, a special l
report should be submitted to the NRC within 14 days fo Wing the event,
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outlining the cause of inoperability, actions taken and the planned schedule for restoring the system to operable status."
l In accordance with the above-mentioned guidelines, NNECO proposes to add l
Technical Specification 3.8.D.7 to specify that the stack high range noble gas effluent monitor shall be operable on a continuous basis, except that outages are permitted within the time frame of the specified action statement, for the purpose of maintenance and performance of required tests, checks, and calibra-l tion.
The specified action statement is as follows:
If the stack high range i
noble gas monitor is not OPERABLE, then initiate a preplanned alternate method of monitoring noble gas effluents within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and either restore the inoperable monitor to OPERABLE status within 7 days or prepare and submit a i
special report to the Commission pursuant to Specification 6.9.2 within l
14 days following the event outlining the action taken, the cause of the inoperability, and the plans and schedule for restoring the monitor to l
OPERABLE status.
1 Additionally, Surveillance Requirement 4.8.0.7 is being added to ensure that the high range stack noble gas monitor is demonstrated operable by performance of a channel check on a monthly frequency and by performance of a channel calibration once per refueling cycle.
Bases Section 3.8.D.7 notes that the l
Millstone Unit No. I stack represents the final release point for potential accident level releases from all three Millstone Nuclear Power Station units l
and, as such, the operability of the high range stack noble gas monitor is j
defined as "at all times."
Administrative Controls Section 6.9.2.g and Bases Section 3.8.D.7 are being revised to reflect the above-mentioned modifications.
Significant Hazards Consideration In accordance with 10CFR50.92, NNEC0 has reviewed the proposed che.nges described above and has concluded that they do not involve a significant 1
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)Li i1 U.S. Nuclear Regulatory Commission B13298/Page 3 August 1, 1989 hazards consideration.
The proposed changes do not involve a significant hazards consideration bectuse the changes would not:
1.
Involve a significant increase in the probability of an accident previ-ously evaluated.
The added and/or amended LCOs and Surveillance Requirements ensure the availability of these systems and will have no impact on the initiation or consequences of an accident previously evaluated.
The changes ensure that additional information is available to the operator for proper accident assessment.
Therefore, the aforementioned changes do not increase the probability or consequences of a design basis accident nor do they affctt the performance or failure probability of any safety system. The changes to Technical Specifications described above have no effect on the initiation, probability, or consequences of any previously evaluated accident scenario.
2.
Create the possibility of a new or different kind of accident from any previously evaluated.
These changes do not result in physical modification of the plant response or operator response to an accident, and no new failure modes are associated wfth these changes.
Instrument drift factors were reviewed to ensure the instrumentation does not provide erroneous or conflicting informatica to the operator in any given situation.
In addition, given the inherent characteristics of passive monitoring equipment, it has been determined that no new or different kind of accident from any previously evaluated has been created.
3.
Involve a significant reduction in the margin cf safety.
These changes do not impact the consequences on the protective bounda-ries, no safety limits for the protective boundaries are impacted, and the basis fo-any Technical Specification is not changed because the instrumentation associated with these changes are passive by nature and do not la any way affect any safety-related equipment.
Also, the bases for these proposed Technical Specifications are being revised to include information regarding these systems which serve to provide additional information to plant personnel during and following an accident..
There-fore, there is no reduction in the margin of safety.
The Commission has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (51FR7751, March 6, 1986) of amendments that are considered not likely to involve a significant hazards consideration.
The changes proposed herein most closely resemble Exam-ple (ii), a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications; e.g.,
a more stringent surveillance requirement.
The proposed changes will ensure l
Millstone Unit No. I's conformance with NUREG-0737--TMI Action Plan
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1 U.S. Nuclear Regulatory Commission J
B13298/Page 4 j
August 1, 1989 l
i Item II.F.1.1 (Noble Gas Effluent. Monitors) as outlined in Generic. Let-ter 83-36. Specifically, Limiting Conditions for Operation are being added'to Technical Specification Section 3.8.D.7.to ensure.the availability of existing l"
hipt range stack noble gas monitors which will assist in post-accident assess-mer:t 3.
Surveillance Requirement 4.8.D.7.1 is. being added to ensure. that 3
calibration requirements for the high range' stack noble gas monitor meet the intent of the above-mentioned TMI Action Plan recommendations.
The require-ment for a special report to be submitted as outlined in Technical Specifica-tion 6.9.2 9 will help ensure the NRC Staff is notified.of an expeditious
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2 repair while still allowing the appropriate degree of operational flexibility.
i This change is being proposed to incorporate the provisions'of Generic Letter 83-36 into the Millstone Unit No.1 ' Technical-Specifications.
As such, no specific schedule for approval and issuance is requested. However, we request that these proposed changes become effective 30 days after issuance in order 1
to allow adequate time for procedure revisions to be made prior to implementa-i l
tion.
i l
Please note that the remaining Generic Letter 83-36 items for Millstone Unit No. I are being processed in conjunction with this submittal under separate cover.
It should therefore be noted that the subparagraphs under the Special I
Reports Section 6.9.2 are overlapping and should be adjustad accordingly upon i
issuance.
The Millstone Unit No.1 Nuclear Review' Board has reviewed and approved the ottached proposed revisions and has concurred with the above determinations.
1 It may be appropriate to note that the NRC has recently reviewed and tpproved similar license ame Millstone Unit No. 2qj$ent requests regarding TMI Plan Items for and the Haddam Neck Plant,(ggtion particularly as they i
relate to some of the proposed deviations from the guidance in -the Generic Letter.
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(3)
'O. H. Jaffe letter to E. J. Mroczka, " Issuance of Amendment (TAC Nos.
54546 and 54399)," dated September 28, 1987.
(4) Alan B. Wang letter to E. J. Mroczka, " Issuance of Amendment (TAC No.
54538)," dated April 24, 1989.
U.S. Nuclear Regulatory Commission B13298/Page 5 August 1, 1989 In accordance with 10CFR50.91(b), NNECO will provide the State of Connecticut with a copy of this proposed amendment.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY h t'a-E. Nydifoczka /
Senior Vice President cc:
W. T. Russell, Region I Administrator M. L. Boyle, NRC Project Manager, Millstone Unit No. 1 W. J. Raymond, Senior Resident Inspector, !4111 stone Unit Nos.1, 2, and 3 Mr. Kevin McCarthy, Director Radiation Control Unit Department of Environmental Protection Hartford, CT 06116 STATE OF CONNECTICUT)) ss. Berlin COUNTY OF HARTFORD )
Then personally appeared before me, E. J. 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 information are true and correct to the best of his knowledge and belief.
l L~2m. Ladu Notaty Public i
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