ML20216J514

Application for Amend to License DPR-65,adding TS 3.5.5, ECCS - Trisodium Phosphate

ML20216J514
Person / Time
Site:	Millstone
Issue date:	04/13/1998
From:	Mcelwain J NORTHEAST NUCLEAR ENERGY CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20216J521	List: B17143, Proposed Tech Specs 3.5.5 Re ECCS Trisodium Phosphate ML20216J514
References
B17143, NUDOCS 9804210404
Download: ML20216J514 (12)

Text

• Nded ""P' D"Y "d- (""" 256)' "d"'d Cf 6383 Nuclear Energy mne Noacar ro.er su,non Northeast Nudcar Energy Company l

P.O. Box 128 '

Waterford, Cr 06385-0128 (860) 447 1791 Fan (860) 444-4277 ne Northeast Utilitice System i APR I 31998

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Docket No. 50-336 B17143 Re: 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk l Washington, DC 20555 l Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Trisodium Phosphate (TSP) introduction Pursuant to 10CFR50.90,- Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR-65 by incorporating the attached proposed i changes into the Technical Specifications of Millstone Unit No. 2. NNECO is proposing to change Technical Specification 3.5.2, " Emergency Core Cooling Systems - ECCS  !

Subsystems - Tavg > 300 F," and to add Technical Specification 3.5.5, " Emergency Core Cooling Systems - Trisodium Phosphate (TSP)." Information will be added to the Bases of the associated Technical Specifications to address the proposed changes.

1 Attachment 1 provides a discussion of the proposed changes and the Safety Summary. i Attachment 2 provides the Significant Hazards Consideration. Attachment 3 provides the marked-up version of the appropriate pages of the current Technical Specifications.

Attachment 4 provides the retyped pages of the Technical Specifications.

The proposed changes to the Technical Specification Index are on the same pages (VI and XII) which have been proposed to be changed in a separate [[letter::B15335, Application for Amend to License DPR-65,extending AOT from 48 H to 7 Days for ECCS Train Declared Inoperable as Result of Inoperable LPSI Subsystem|letter dated November 3,1995]],' which addressed the allowed outage time of an Emergency Core Cooling Subsystem. The proposed change to Technical Specification Section 3.5.2 is on the same page (3/4 5-5) which has been proposed to be changed in a separate

' E. A. DeBarba letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed Technical Specification Revision Emergency Core Cooling Subsystem Allowed Outage Time Extension," dated November 3,1995.

9804210404 9804 3 I PDR ADOCK 0500o336 P PDR

, .U.S. Nuclear Regulatory Commission B17143/Pago 2 letter dated September 2,1997,2 which addressed compliance issues. The proposed change to' Technical Specification Section B 3/4.5.2 is on the same page (B 3/4 5-1 which has been proposed to be changed in a separate letter dated November 3,1 ,

which addressed the allowed outage time of an Emergency Core Cooling Subsystem.

The proposed change to Technical Specification Section B 3/4.5.2 is on the same page (B 3/4 5-2) which has been proposed to be changed in separate letters dated November 3,1995,d which addressed the allowed outage time of an Emergency Core Cooling Subsystem, September 2, 1997,5 which addressed compliance issues, November 13, 1997,8 which addressed RCS heatup and cooldown limits, and l December 8,1997,7 which also addressed compliance issues. The proposed changes contained in this letter do not assume approval of any of the previously submitted changes.

Environmental Considerations NNECO has reviewed the proposed License Amendment Request against the criteria of 10CFR51.22 for environmental considerations. The proposed changes will relocate the requirements for TSP to a new Technical Specification. The required amount of TSP will be increased. These changes do not increase the type and amounts of effluents that may be released off site. In addition, this amendment request will not significantly increase individual or cumulative occupational radiation exposures.

Therefore, NNECO has determined the proposed changes will not have a significant effect on the quality of the human environment.

2 M. L. Bowling, Jr. letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 1 Proposed Revision to Technical Specifications Compliance issues," dated September 2,1997.

3 E. A. DeBarba letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed Technical Specification Revision Emergency Core Cooling Subsystem Allowed Outage Time Extension," dated November 3,1995.

E. A. DeBarba letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed i Technical Specification Revision Emergency Core Cooling Subsystem Allowed Outage i Time Extension," dated November 3,1995.

M. L. Bowling, Jr. letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed F . vision to Technical Specifications Compliance issues," dated September 2,1997.

M. L. Bowling, Jr. letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Reactor Coolant System Heatup/Cooldown Limits and Low Temperature Overpressure Protection," dated November 13,1997.

M. L. Bowling, Jr. letter to the NRC, " Millstone Nuclear Power Station, Unit No. 2 Proposed Revision to Technical Specifications Compliance issues Number 2," dated December 8,1997.

' ,b.S. Nucl:tr Regulatory Commission

. B17143/Pago 3 Conclusions The proposed changes were evaluated utilizing the criteria of 10CFR50.59 and were determined not to involve an unreviewed safety question. Additionally, we have concluded the proposed changes are safe.

The proposed changes do not involve a significant impact on public health and safety !

(see the Safety Summary provided in Attachment 1) and do not involve a Significant Hazards Consideration pursuant to the provisions of 10CFR50.92 (see the Significant i Hazards Consideration provided in Attachment 2).

Plant Operations Review Committee and Nuclear Safety Assessment Board The Plant Operations Review Committee and Nuclear Safety Assessment Board have l reviewed and concurred with the determinations. I Schedule We request issuance at your earliest convenience, with the amendment to be implemented within 60 days of issuance.

State Notification in accordance with 10CFR50.91(b), a copy of this License Amendment Request is being provided to the State of Connecticut.

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' .U.S. Nucl:ar Rcgulatory Commission

. B17143/Pago 4 If you should have any questions on the above, please contact Mr. Ravi Joshi at (860) 440:2080.*

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: M. L. Bowling, Jr.

Millstone Unit No. 2 - Recovery Officer BY: /M7M John P. sicElw6in' Millstone Unit No.1 - Recovery Officer Sworn to and subscribed before me this .\ 3. day of O nei\ 1998

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b.a ku.e d%thwA shtary Pubic My Commission expires Kh. Sf3 Aco\

Attachments (5) cc: H. J. Miller, Region I Administrator ]

4 D. G. Mcdonald, Jr., NRC Senior Project Manager, Millstone Unit No. 2 )

D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 W. D. Travers, Ph.D, Director, Special Projects Office

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W. D. Lanning, Deputy Director of Inspections - Special Projects Office P. F. McKee, Deputy Director of Licensing - Special Projects Office Director Bureau of Air Management Monitoring and Radiation Division Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 I

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Docket No. 50-336

. . B17143 l

1 Attachment 1 Millstone Nuclear Power Station, Unit No. 2 i Proposed Revision to Technical Specifications '

Trisodium Phosphate (TSP) l Discussion of Proposed Changes 1

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April 1998

' .U. S. Nuclear Regulatory Commission B17143/Attachmnnt 1/Page 1 Proposed Revision to Technical Specifications Trisodium Phosphate (TSP)

Discussion of Proposed Changes Introduction Northeast Nuclear Energy Company (NNECO) hereby proposes to amend Operating License DPR-65 by incorporating the attached proposed changes into the Technical Specifications of Millstone Unit No. 2. NNECO is proposing to change Technical Specification 3.5.2, " Emergency Core Cooling Systems - ECCS Subsystems - Tavg 2 300 F," and to add Technical Specification 3.5.5, " Emergency Core Cooling Systems -

Trisodiu Phosphate (TSP)." Information will be added to the Bases of the associated Technict ' Specifications to address the proposed changes.

Backaround Trisodium phosphate (TSP) dodecahydrate is stored in wire mesh baskets located in l the lowest level of containment. The TSP will dissolve in the containment sump water following a loss of coolant accident. This will adjust the pH of the containment sump water fe minimize stress corrosion cracking of certain metal components inside l containment. A review of the TSP volume calculation has revealed that the quantity of TSP stored inside containment, and required by Technical Specifications, is not sufficient to raise the containment sump pH 2 7.0 following a design basis loss of coolant accident. This was reported in Licensee Event Report (LER) 97-036-00.' I 1

A new calculation has been performed to determine the required quantity of TSP to store inside containment. The calculation, which considers the total quantity of borated water that could be available in the containment sump following a LOCA, the amount of hydrochloric acid from the degradation of electric cable insulation, and the amount of nitric acid from the irradiation of the containment air and sump water, has determined that the minimum required TSP is 282 cubic feet. Therefore, the current Technical Specification, which requires a minimum volume of 110 cubic feet, needs to be modified.

The new TSP volume calculation is consistent with the guidance contained in the following references. However, Millstone Unit No. 2 is not committed to the  !

requirements contained in these documents.

l J. A. Price letter to the U.S. Nuclear Regulatory Commission, Millstone Nuclear Power Station, Unit No. 2, Licensee Event Report (LER) 97-036-00, " Technical Specification Containment Sump Trisodium Phosphate Volume Insufficient," dated December 17, 1997.

.'U. S. Nucl:ar Regulatory Commission B17143/ Attachment 1/Pago 2 l

1. NUREG - 0800, Standard Review Plan, "6.1.1 Engineered Safety l

. . Features Materials," Revision 2, July 1981.

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2. NUREGICR - 5950, " lodine Evolution and pH Control," December 1992. l l

The additional TSP will be stored inside containment in two new larger wire mesh '

baskets constructed of 304 stainless steel. The two new baskets will replace two existing baskets. The design of the new baskets is similar to the design of the baskets installed in the containment of Millstone Unit No. 3 in 1995. l l

The plant design change associated with increasing the quantity of TSP stored inside containment was evaluated utilizing the criteria of 10CFR50.59 and was determined to ,

not ir'volve an unreviewed safety question. Additionally, we have concluded the plant design change is safe.

Description of Proposed Chanaes 1

Technical Specification Index l

1. Index Pages VI and Xil will be revised to reflect the proposed addition of a separate Technical Specification and associated Bases for TSP.

Technical Specification 3.5.2

1. Surveillance Requirement (SR) 4.5.2.c.3 will be relocated to Technical Specification 3.5.5 as SR 4.5.5.1. Changes to the current requirements contained in SR 4.5.2.c.3 will be discussed below. The use of a separate Technical Specification for TSP is consistent with NUREG - 1432,

" Standard Technical Specifications, Combustion Engineering Plants."

2. SR 4.5.2.c.4 will be relocated to Technical Specification 3.5.5 as SR 4.5.5.2. The specific details of test performance will be relocated from the SR to the associated Bases. This is consistent with NUREG - 1432.  !

Technical Specification 3.5.5 l

1. The TSP requirements currently contained in SR 4.5.2.c.3 will become the Limiting Condition for Operation (LCO) for this new specification. The amount of TSP required will increase from 2110 ft' to 2 282 ft as a result of the new calculations.  !

2. The applicability of this new specification will be expanded to include all l of Mode 3, instead of just Mode 3* (Mode 3 with pressurizer pressure 2 l 1750 psia). There is no reason to limit the TSP requirement based on pressurizer pressure. This is consistent with NUREG - 1432.

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. U. S. Nuclscr Regulatory Commission

. B17143/ Attachment 1/Pags 3

3. . The action statement for this new specification will allow 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> to restore the TSP volume. This time frame, and subsequent actions, are -

consistent with the required actions for ECCS equipment in accordance with Technical Specification 3.5.2. The basis for the proposed allowed outage time is consistent with NUREG - 1432.

4. The requirement currently contained in SR 4.5.2.c.3 to verify sufficient TSP volume will become SR 4.5.5.1. The frequency of test performance will remain the same.

5. The requirement currently contained in SR 4.5.2.c.4 to verify solubility, and the ability of the TSP to adjust the pH of a sample of borated water, will become SR 4.5.5.2. The specific details of test performance will be relocated from the SR to the associated Bases.

The method of test performance will be changed to use a smaller quantity of TSP and borated water. This will reduce the contaminated waste generated, and will make the test easier to perform.

Reference to the use of RWST water will be changed to " borated water "  :

This has been done to reflect that the water expected to be in the I containment sump is a combination of Reactor Coolant System water, Refueling Water Storage Tank water, Safety injection Tank water, and Boric Acid Storage Tank water. The sample tested will be at a boron ,

concentration representative of these sources (2482120 ppm). The I required borated water sample temperature will be changed from 1801 10 F to a measurement temperature of 77 F 15 'F. '

The required pH value will be increased from 2 6.0 to 2 7.0. This is consistent with the new calculation and the FSAR. The time limit of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> will not change.

The required TSP sample size will be reduced to be consistent with the ,

reduced borated water test volume, and to reflect the TSP volume added i to neutralize the boric acid concentration expected in the containment sump following a loss of coolant accident (223 ft of TSP for boric acid neutralization, 59 ft' of TSP for neutralization of hydrochloric and nitric acids). Additional test details will be added to the Bases.

These proposed changes are c onsistent with NUREG - 1432.

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.'U. S. Nuct:cr Regulatory Commission B17143/Attcchm:nt 1/Pcga 4 Safety Summary The proposed changes will relocate the Technical Specification requirements for TSP to a new Technical Specification. SR 4.5.2.c.3, which contains the current minimum required TSP volume, will become the LCO of Technical Specification 3.5.5,

" Emergency Core Cooling Systems - Trisodium Phosphate (TSP)." The minimum i required volume will be increased to reflect the results of a new calculation performed I to support the current requirement to raise containment sump pH 2 7.0 following a loss of coolant accident. I The action statement for Technical Specification 3.5.5 will require the TSP voiume to be restored within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or a plant shutdown to Mode 4 will be required. The 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed outage time is based on the current ECCS Subsystem allowed outage time specified in Techn. cal Specification 3.5.2, " Emergency Core Cooling Systems -

ECCS Subsystems - Tavg 2 300 F," for one inoperable subsystem. The current Technical Specifications do not address this situation. This is consistent with NUREG - l 1432. l The surveillance requirements to verify the volume, solubility, and buffering ability of the TSP inside of containment will be retained. The specific details of surveillance testing for solubility and buffering ability will be relocated to the associated Bases. This is consistent with NUREG - 1432.

The index pages will be revised to reflect the proposed addition of a separate Technical Specification and associated Bases for TSP. l These proposed changes will ensure the correct amount of TSP will be stored inside l containment, and will verify the ability of this TSP to neutralize a representative sample of borated water. The proposed changes have no adverse effect on how any of the associated systems or components function to prevent or mitigate the consequences of design basis accidents. Also, the proposed changes have no adverse effect on any I design basis accident previously evaluated. Therefore, there is no adverse impact on public health and safety.

Docket No 50-336

. B17143 Attachment 2 Millstone Nuclear Power Station, Unit No. 2  !

Proposed Revision to Technical Specifications l Trisodium Phosphate (TSP) l Significant Hazards Consideration j j

April 1998 I

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' .'U. S. Nuclear Regulatory Commission B17143/Attachmnnt 2/Pago 1 Proposed Revision to Technical Specifications

. Trisodium Phosphate (TSP)

Significant Hazards Consideration Sionificant Hazards Consideration in accordance with 10CFR50.92, NNECO has reviewed the proposed changes and has 4 concluded that they do not involve a significant hazards consideration (SHC). The basis for this conclusion is that the three criteria of 10CFR50.92(c) are not compromised. The proposed changes do not involve an SHC because the changes j would not:

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1. Involve a significant increase in the probability or consequences of an accident i previously evaluated.

The proposed changes to relocate the current trisodium phosphate (TSP) dodecahydrate Technical Specification requirements from the surveillance requirements for the Emergency Core Cooling System to a new TSP Technical Specification will not change the requirement to store TSP inside containment.  ;

The proposed changes will require a larger quantity of TSP to be stored inside  ;

containment. This larger quantity, based on a recently revised calculation, will ensure sufficient TSP is available for containment sump water pH control.

These proposed changes do not alter the way any structure, system, or j component functions. There will be no adverse effect on any design basis l accident previously evaluated, on any equipment important to safety, or on the radiological consequences of any design basis accident. Therefore, this License Amendment Request does not impact the probability of an accident previously evaluated nor does it involve a significant increase in the consequences of an accident previously evaluated.

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2. Create the possibility of a new or different kind of accident from any accident j previously evaluated. '

The proposed change to increase the TSP volume stored inside containment will i require two of the wire mesh TSP baskets inside containment to be replaced by two new and larger wire mesh baskets. The design of the new baskets has been evaluated and it is consistent with the requirements for equipment installed in i containment. The replacement of the two wire mesh baskets will not result in any significant change in plant configuration and will not require any new or unusual operator actions. It will not alter the way any structure, system, or component functions and does not alter the manner in which the plant is l operated. It will not introduce any new failure modes. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

. U. S. Nuclear Regulatory Commission

. B17143/Attachmsnt 2/Paga 2

3. Involve a significant reduction in a margin of safety.

The proposed changes will relocate the current Technical Specification requirements for TSP to a new Technical Specification. The minimum required volume will be increased to reflect the results of a new calculation performed to support the current requirement to raise containment sump pH > 7.0. These changes will have no adverse effect on equipment important to safety. This equipment will continue to function as assumed in the design basis accident analysis. Therefore, there will be no significant reduction of the margin of safety as defined in the Bases for the Technical Specifications affected by these proposed changes.

The NRC has provided guidance concerning the application of standards in 10CFR50.92 by providing certain examples (March 6, 1986, 51 FR 7751) of amendments that are considered not likely to involve an SHC. The changes proposed herein to revise the index pages are enveloped by example (i), a purely administrative change to Technical Specifications. The change proposed herein to add a new TSP Technical Specification with a specific allowed outage time is enveloped by example (ii), a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications.

As described above, this License Amendment Request does not impact the probability of an accident previously evaluated, does not involve a significant increase in the q consequences of an accident previously evaluated, does not create the possibility of a '

new or different kind of accident from any accident previously evaluated, and does not result in a significant reduction in a margin of safety. Therefore, NNECO has concluded that the proposed changes do not involve an SHC.

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