ML20248M113
| ML20248M113 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/10/1998 |
| From: | Mckee P NRC (Affiliation Not Assigned) |
| To: | Bowling M, Loftus P NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| TAC-MA1799, NUDOCS 9806150015 | |
| Download: ML20248M113 (5) | |
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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20566-0001 h[% l l
June 10; 1998 Mr. Martin L. Bowling, Jr.
Recovery Officer - Technical Services Northeast Nuclear Energy Company clo Ms. Patricia A. Loftus Director-Regulatory Affairs P. O. Box 128 Waterford, Connecticut 06385
SUBJECT:
MILLSTONE NUCLEAR POWER STATION, UNIT NO. 3 - A1.TERNATIVE TO REQUIREMENTS OF ASME CODE SECTION lli (TAC NO MA1799)
Dear Mr. Bowling:
By letter dated May 20,1998, as supplemented May 29,1998, you submitted, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(a)(3)(i), an alternative to the requirements of the American Society of Mechanica! Engineers (ASME) Boiler and Pressure Vessel Code (ASME Code), Section Ill, NC-3677.3,1971 Edition, Summer 1973 Addenda, for relief valve discharge to a common header.
In the May 20,1998, letter, you state that ASME Code, Section lil, NC-3677.3, provides the requirements for the discharge piping from pressure relief devices. Paragraph (d) of this section of the Code requires that when the discharges of two or more relief valves are combined *in no case shall the area of such common lines be less than the combined area of alllines discharging into it." At Millstone Unit 3, you state that as-built configurations exist where various systems' relief valves discharge into common headers. In several cases, these common headers are less than the combined area of alllines discharging into them, and this is not in compliance with the requirements of NC-3677.3(d). This issue was discussed in NRC Inspection Report (IR) 50-413/97-206, dated December 5,1997. In the IR, the NRC staff stated that contrary to Articles NC-7512 and NC-3677, you failed to consider possible volume control tank back pressure and that the area of the common discharge lines for certain relief valves was considerably smaller than the required combined area of alllines discharging to it. This issue was found to be an apparent violation of NRC requirements. As a result, you submitted a request for interpretation to the ASME Code to clarify whether the designer can perform a detailed sizing analysis of a relief header system in accordance with the requirements of NC-7512 in lieu of meeting the conservative requirements of NC-3677.3(d).
In the May 20,1998, letter, you provided the ASME Code interpretation. The ASME Code interpretation states that "the designer can design a relief header system to the requirements of l
NC-7512 by demonstrating through analysis that adequate system relief capacity is provided.
2 The limitations of NC-3677.3(d) do not apply to relief discharge headers designed to the rules of U
NC-7512."
The NRC staff has reviewed your request for the NRC to authorize the proposed alternative pursuant to 10 CFR 50.55a(a)(3). The NRC staff finds that ASME Code, Section ill requirements
, Dl for Quality Group B and C components (ASME Code Class 2 and 3 components stated in 10 CFR 50.55a(d) and (e), apply to nuclear power plants whose applications for construction permits (cps) were docketed after May 14,1984. The CP for Millstone Unit 3 was docketed prior to May 14,1984. Therefore, the regulations in 10 CFR 50.55a(e) concerning 9906150015 990610
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l M. L. Bowling June 10,1998 i
ASME Code, Section lit design requirements for Class 2 and 3 components do not apply to Millstone Unit 3. Accordingly, authorization of an alternative to ASME Code, Section 111 design requirements pursuant to 10 CFR 50.55a(a)(3) is unnecessary and inappropriate for Millstone Unit 3.
In the Millstone Unit 3 Final Safety Analysis Report, you committed to design and construct Millstone Unit 3 in accordarice with ASME Code, Section Ill design provisions. In the May 20, 1998, submittal you identified several common relief valve discharge headers, which are less
.than the combined area of alllines discharging into them. You stated that this is not in compliance with the requirements of NC-3677.3(d). The NRC staff views the licensee's discovered condition of noncompliance with the ASME Code, Section ill design provisions as a deviation from plant licensing commitments. Accordingly, you may either modify the plant to conform to the provisions of the current licensing and design basis information, or change the current licensing and design basis information to accurately reflect the existing plant design.
Action may be taken pursuant to the provisions of 10 CFR 50.59; and depending on the results of your evaluation, a license amendment may be required.
On the basis of the preceding evaluation, the NRC staff concludes that authorization of an attemative or relief from ASME Code, Section ill design provisions for ASME Code Class 2 and 3 components is unnecessary and inappropriate for Millstone Unit 3. You may resolve the existing deviation by modifying the plant, or by revising the licensing and design information.
If you have any questions related to this matter, please contact James Andersen at (301) 415-1437.
Sincerely, original signed by:
Phillip F. McKee Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation Docket No. 50-423 cc: See next page DISTRIBUTION:
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I M. L. Bowling ASME Code, Section lli design requirements for Class 2 and 3 components do not apply to Millstone Unit 3. Accordingly, authorization of an altemative to ASME Code, Section ll1 design requirements pursuant to 10 CFR 50.55a(a)(3) is unnecessary and inappropriate for Millstone Unit 3.
In the Millstone Unit 3 Final Safety Analysis Report, you committed to design and construct Millstone Unit 3 in accordance with ASME Code, Section lit design provisions.- In the May 20, 1998, submittal you identified several common relief valve discharge headers, which are less than the combined area of all lines discharging into them. You stated that this is not in I
compliance with the requirements of NC-3677.3(d). The NRC staff views the licensee's discovered condition of noncompliance with the ASME Code, Section lli design provisions as a t
l-deviation from plant licensing commitments. Accordingly, you may either modify the plant to conform to the provisions of the current licensing and design basis information, or change the iL current licensing and design basis information to accurately reflect the existing plant design.
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- Action may be taken pursuant to the provisions of 10 CFR 50.59; and depending on the results of l
your evaluation, a license amendment may be required.
On the basis of the preceding evaluation, the NRC staff concludes that authorization of an altemative or relief from ASME Code, Section til design provisions for ASME Code Class 2 and 3 components is unnecessary and inappropriate for Millstone Unit 3. You may resolve the existing deviation by modifying the plant, or by revising the licensing and design information.
. lf you have any questions related to this matter, please contact James Andersen at (301)
)
415-1437.
j Sincerely,-
Phillip F. McKee L
Deputy Director for Licensing Special Projects Office Office of Nuclear Reactor Regulation l
Docket No. 50-423 i
cc: See next page l
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L_-__-___---_____-__
,a Millstone Nuclear Power Station Unit 3 cc:
Lillian M. Cuoco, Esquire Joseph R. Egan, Esquire Senior Nuclear Counsel Egan & Associates, P.C.
Northeast Utilities Service Company 2300 N Street, NW P. O. Box 270 Washington, DC 20037 Hartford, CT 06141-0270 Mr. F. C. Rothen Mr. Kevin T. A. McCarthy, Director Vice President - Work Services Monitoring and Radiation Division Northeast Uti'ities Service Company Department of Environmental Protection P. O. Box 128 79 Elm Street Waterford, CT 06385 Hartford, CT 06106-5127 Emest C. Hadley, Esquire Regional Administrator, Region i 1040 B Main Street U.S. Nuclear Regulatory Commission P.O. Box 549 475 Allendale Road West Wareham, MA 02576 King of Prussia, PA 19406 Mr. John Buckingham First Selectmen Department of Public Utility Control Town of Waterford Electric Unit Hall of Records 10 Liberty Square 200 boston Post Road New Britain, CT 06051 Waterford, CT 06385 Mr. James S. Robinson, Manager Mr. Wayne D. Lanning NuclearInvestments and Administration Deputy Director of Inspections New England Power Company Special Projects Office 25 Research Drive 475 Allendale Road Westborough, MA 01582 King of Prussia, PA 19406-1415 Mr. John Streeter Mr. M. H. Brothers Recovery Officer - Nuclear Oversight Vice President - Millstone Unit 3 Northeast Utilities Service Company Northeast Nuclear Energy Company P. O. Box 128 P.O. Box 128 Waterford, CT 06385
- Waterford, CT 06385 Deborah Katz, President Mr. M. R. Scully, Executive Director Citizens Awareness Network Connecticut Municipal Electric P.O. Box 83 Energy Cooperative Shelbume Falls, MA 03170 30 Stott Avenue Norwich, CT 06360 Mr. Allan Johanson, Assistant Director Office of Policy and Management Mr. David Amerine Policy Development and Planning Vice President-Human Services Division Northeast Utilities Sarvice Company 450 Capitol Avenue - MS# 52ERN P. O. Box 128 P. O. Box 341441 Waterford, CT 06385 Hartford, CT 06134-1441 i
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Millston] Nucle:r Power Striion Unit 3 I
cc:
The Honorable Terry Concannon Mr. William D. Meinert Nuclear Energy Advisory Council Nuclear Engineer Room 4035 Massachusetts Municipal Wholesale l
Legislative Office Building Electric Company Capitol Avenue P.O. Box 426 Hartford, CT 06106 Ludlow, MA ' 01056 l
Mr. Ecn W. Woollacott Attomey Nicholas J. Scobbo, Jr.
Co-Chair Ferriter, Scobbo, Caruso, Rodophele, PC Nuclear Energy Advisory Council 1 Beacon Street,11th Floor 128 Terry's Plain Road Boston, MA 02108 Simsbury, CT 06070 Citizens Regulatory Commission Mr. John W. Beck, President ATTN: Ms. Susan Perry Luxton Little Harbor Consultants, Inc.
180 Great Neck Road Millstone-ITPOP Project Office Waterford, CT 06385 P.O. Box 0630 Niantic, CT 06357-0630 Mr. B. D. Kenyon (Acting)
Chief Nuclear Officer-Millstone Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Mr. Daniel L. Curry Project Director j
Parsons Power Group Inc.
2675 Morgantown Road Reading, PA 19607 l
Mr. Don Schopfer Verification Team Manager Sargent & Lundy 55 E. Monroe Street Chicago,IL 60603 Mr. G. D. Hicks Director-Unit 3 Northeast Nuclear Energy Company P.O. Box 128 Waterford, CT 06385 Senior Resident inspector Millstone Nuclear Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 r
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