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Citizens Regulatory Commission Petition for Leave to Intervene & Request for Hearing.* Petitions NRC for Leave to Intervene Re License Amend Application,,proposing Rev to Millstone,Unit 3 to Add New Sump Pump Subsystem
	ML20248C500
Person / Time
Site:	Millstone
Issue date:	05/21/1998
From:	Burton N; AFFILIATION NOT ASSIGNED
To:	; NRC COMMISSION (OCM)
Shared Package
ML20248C454	List: ML20248C451; ML20248C500;
References
	LA-2, NUDOCS 9806020168
	Download: ML20248C500 (13)
	v • d • e

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UNITED STATES NUCLEAR REGULATORY COMMISSION 00CKETED IN RE: APPLICATION FOR AMENDMENT : DOCKET No. 50-423 USNRC NY NORTHEAST NUCLEAR ENERGY :

COMPANY, ET AL :

'98 MAY 28 P1 :34 MILLSTONE NUCLEAR POWER STATION, :

UNIT NO. 3 :

OFFIE X SFCk.lN,Y NEW LONDON COUNTY, CONNECTICUT : MAY 21, 1998 RULEV^a $3/@D ADJUD:CMLNS STAFF CITIZENS REGULATORY COMMISSION PETITION FOR LEAVE TO INTERVENE AND REQUEST FOR HEARING The Citizens Regulatory Commission (" CRC") herewith petitions the United States Nuclear Regulatory Commission for leave to intervene.in the above-captioned proceedings concerning a license amendment application dated April 1, 1998 and described as follows:

The proposed revision to the Millstone Unit 3 licensing basis adds a new sump pump subsystem to address groundwater inleakage through the containment basemat.

This petition is submitted in accordance with the provisions of.10 C.F.R. 52.714 and further requests a hearing.

In support of this petition, the CRC represents as follows:

1. The Citizens Regulatory Commission (" CRC") is an organization of citizens, including families with young children, who reside in southeastern Connecticut and are concerned about the safety of the Millstone Nuclear Power Station. CRC includes members who. reside with their young children within the five-mile l

priority emergency evacuation zone of the Millstone Station.

2. The instant application involves issues which are critical to the safe operation of Millstone Unit 3 and thereby directly impact CRC members' health and safety.

9906020168 990529 PDR ADOCK 05000423 9 PDR L________________.___________________________________________________.______________________.._.

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13 . - The CRC. opposes issuance.of the requested amendment-

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at.this timei

4. The-CRC'sLobjections to the' proposed amendment are-

. summarized:asifoll'ows:

.a)

( The present management of.the licen'se amendment

applicant, Northeast' Nuclear Energy Company Et Al-("NU"), has for?the past two-(2) years permitted the; employment of faultyg calculations ~on a persistent basis involving-the operations'of systems at' Millstone Unit 13:

' (b)lThe present management of NU has for the past.two (2)'

years engaged iniinadequate procedures, methods and analysis of-

' safety systems at Millstone Unit 3; (c)';TheLpresent. management of NU has longibeen: aware of

.the-l' longstanding problems associated with the Recirculation-Spray} System'("RSS") at Millstone. Unit;3.

.(d) The;RSS is a critical safety system at Millstone Unit 3:

be) The United States Nuclear Regulatory Commission. publicly

acknowledged.on' February ~19, 1998- that Millstone Unit 3 has been permitted;to~ operate for years 1although the,RSS system was inoperables (f) The health,. safety and welfarelof the public,Eincluding

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. the CRC membership, has been' needlessly and recklessly ' jeopardized l.

bysthe? failure of NU and NRC to' assure complete operability of the _

L RSS[ system:in theLpast; o

1(g)JFailure of the:RSS system could be' catastrophic; 3

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(h) Early in March 1998, NU tested a modification it had made l to the RSS system at Millstone Unit 3; (i) The modification to the safety-critical RSS system proved to have been very poorly designed and inadequately reviewed 1

when testing of the modification resulted in serious damage to four pump systems which must be operable in a loss-of-coolant accident; (j ) CRC appends hereto the account of the March 1998 RSS modification failure which appeared in the April 3, 1998 issue of The New London Day newspapers (k) A nuclear engineer with the Union of Concerned Scientists is reported as having made the comment regarding the RSS modification failure: "This is engineering 101 stuff. Most disconcerting is nuclear oversight. Their sole job is to point out potential problems.'When they raise a flag and it's ignored, something's wrong.";

(1) The instant amendment proposal addresses a safety concern of which NU was aware more than three (3) months prior to its submission of the amendment proposal; (m) NU describes the need for the instant amendment as follows:

A Millstone Unit No. 3 Configuration Management Program review revealed that inleakage of groundwater has the potential to flood Engineered Safety Features (ESF) building sumps if the j existing nonsafety-related sump pumps should fail to operate.

If the sumps are not pumped out, the groundwater could eventually affect both trains of the Recirculation' Spray 1 System (RSS). This was previously reported in Licensee Event l Report (LER) 97-046-00.

The containment substructure is encased within a waterproof 3 membrane that is connected to sumps located in the ESF building. l Degradation of the waterproof membrane has been detected, i allowing groundwater inleakage. Any groundwater inleakage j 3

permeates through a porous containment basemat containing embedded drainage pipes, and is directed to one of the two RSS cubicle sumps in the ESF building.

The current FSAR concluded that significant amounts of groundwater are not expected and thus, no safety-related dewatering system is required. The degradation of the waterproof membrane and the measurements of groundwater leakage has changed this conclusion. It is now recognized that enough groundwater inleakage can occur to potentially affect the operability of both trains of RSS pumps. Thus, the FSAR is being changed to reflect this new conclusion. In order to resolve this issue, two safety-related, air-driven sump pumps have been installed in the RSS sumps. A description of these new pumps is being added to the FSAR.;

(n) The present management of NU has for the past two (2) years compromised safety at Millstone Unit 3 in the interests of schedule-driven efforts to obtain approval for restart; (o) That present NU management is schedule-driven at the expense of safety is illustrated by the fact that Bruce D. Kenyon, president and CEO of NU, will maximize a potential $500,000 bonus if Millstone Unit 3 restart by a particular identified month, according to Mr. Kenyon's sworn testimony before the Connecticut Department of Public Utility Control on April 9, 1998; (p) The present management of Millstone continues to perpetuate an employee environment in which workers are harassed, intimidated, retaliated against and discriminated against when they attempt to raise safety issues, which conduct is a violation of federal laws (q) As recently as February 1998, a five-year employee with a stellar record at Millstone as well as a stellar 26-year record as a commander in the United States Navy resigned from Millstone in frustration that under present management he was not able to achieve adequate resolution on safety issued he raised; 4

F (r)-In light of the above circumstances, CRC.has no confidence'that NU has analyzed the Engineered Safety Features system which-is the subject of the proposed amendment in a manner which is appropriate'and adequate,

-(s) In light of.the above circumstances, CRC has.no confidence that NU has analyzed the Engineered Safety' Features.

- system in accordance with the letter and spirit of the. standards articulated on February 19, 1998'by Dr. Shirley Jackson,-Chairman, NRC,~'during public proceedings.concerning Millstone.

5. In light of the above circumstances, CRC respectfully represents that approval of the requested amendment in the present form as submitted by NU will directly adversely impact the health, safety and welfare of each of the members of CRC, including those

' families with young children.

WHEREFORE, Citizens Regulatory Commission petitions for leave to intervene and-for a hearing in the above-referenced proceedings.

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tunity o oa certification. Specifically, the Sefeguards; Subcommittee Meeting on staw ,

. >bcommittee will review issues Advanced Reector Designe; Notice of pertaining to the AP600 Reactor Coolant Meeting therefor. can be obtained bI contactin8 System, including the resolution of the cognizant ACRS staff engineer, Mr. Issues identified in the February 19, The ACRS Subcommittee on Noel F. Dudley (telephone 301/415-1998 ACRS letter.The purpose of this Advanced Reactor Designs will hold a 6888) between 7:30 a.m. and 4:15 p.m. meWnb u to gather information, meeting on May 13-15,1998, Room T- WDT). Persons planmng to attend this analyze relevant issues and facts, and to 2B3,11545 Rockville Pike. Rockville, meeting are urged to contact the above formulate proposed positions and Maryland. named individual one or two working cctions, as appropriate, for deliberation The entire meeting will be open to days pnor to the meeting to be advised by the full Committee. Public attendance. of any potential changes to the agenda, Oral statements may be presented by The agenda for the subject meeting etc., that may have occurred. members of the public with the shall be as follows: Dated: April 16,1998. concurrence of the Subcommittee Wednesday, May 13,1998-8:30 a.m. 5,,, pares,,,,,y, Chairman; written statements will be until the conclusion of business. Chief.NuclearReactors Branch. accepted and made available to the Thursday, May 24,1998-8:30 a.m. [FR Doc. 98-10664 Filed 4-21-98; 8:45 aml Committee. Electronic recordings will untilthe conclusion of business. Friday, May 15,1998-8:30 a.m. until * * ' * * * * "

bepermitted only during those portions of tDe meeting that are open to the the conclusion of business.

public, and questions may be asked only The Subcommittee will continue its j by members of the Subcommittee,its review of the Westinghouse AP600 LAN consultants, and staff. Persons desiring design. Specifically, the Subcommittee to make oral statements should notify will review Chapters 3,6,9A,14,16 BlumeidyNoWce Wend the sant ACRS staff engineer and 17 of the AP600 Standard Safety' Amendments to Facimy Opwedng nam below five days prior to the Analysis Report, the probabilistic risk. Licenses invdving No Signmcent meeting,if possible, so that appropriate assessment (FRA), regulatory treatment Hazwde ConaldwoWons arrangements can be made. of non-safety systems (RTNSS), and the During the initial portion of the associated NRC staff's draft Final Safety L Background meeting, the Subcommittee, alon8 with Evaluation Report. The purpose of this any ofits consultants who may be meeting is to gather information, Pursuant to Public Law 97-415, the present, may exchange preliminary analyze relevant issues and facts, and to U.S. Nuclear Regulatory Commission views regarding matters to be formulate proposed positions and (the Commission or NRC staff)is considered during the balance of the actions, as appropriate, for deliberation Publishing this regular biweekly notice. meeting. by the full Committee. Public Law 97--415 revised section 189 'Ito Subcommittee will the:2 hear Oral statements may be presented by of th Atomic Energy Act of1954, as presentations by and hold discussions members of the public with the amended (the Act), to require the with representatives of the concurrence of the Subcommittee Commission to publish notice of any Westinghouse Electric Company, the Chairman; written statements will be amendments issued, or proposed to be NRC staff, their consultants, and other accepted and made available to the issued, under a new provision of section interested persons regarding this review. . Committee. Electronic recordings will 189 of the Act. This provision grants the Further information regarding topics be permitted only during those portions Commission the authority to issue and to be discussed, whether the meeting of the meeting that are open to the make immediately effective any has been canceled or rescheduled, the public, and questions may be asked only amendment to an operating license scheduling of sessions which are open by members of the Subcommittee,its upon a determination by the to the public, the Chairman's ruling on consultants, and stafL Persons desiring Commission that such amendment requests for the opportunity to present to make oral statements should notify involves no significant hazards oral statements and the time allotted the cognizant ACRS staff engineer consideration, notwithstanding the therefor, can be obtained by contacting named below five days prior to the Pendency before the Commission of a the cognizant ACRS staff engineer, Mr. meeting,if possible, so that appropriate request for a hearing from any person. Paul A. Boehnert (telephone 301/415- arrangements can be made. This biweekly notice includes all 8065) between 7:30 a.m. and 4:15 p.m. During the initial portion of the notices of amendments issued, or (EDT). Persons planning to attend this meeting, the Subcommittee, along with proposed to be issued from March 30, meeting are urged to contact the above any ofits consultants who may be 1998,through April 10,1998. The last named individual one or two working present, may exchange preliminary biweekly notice was published on April days prior to the meeting to be advised views regarding matters to be 8,1998 (63 FR 17219). l Fed:ral Regist r/Vol. 63, No. 77/ Wednesday, April 22,1998 / Notices 19965 l Notice of Consideration ofissuance of Document Room,the Gelman Building, Not later than 15 days prior to the first Amendments to Facility Operating 2120 L Street, NW., Washington, DC. prehearing conference scheduled in the Lic nses, Proposed No Significant The filing of requests for a hearing and proceeding, a petitioner shall file a H:zards Consideration Detennination, petitions for leave to intervene is supplement to the petition to intervene I cid Opportunity for a Hearing discussed below, which must include a list of the j The Commission has made a By May 22,1998, the licensee may file contentions which are sought to be proposed determination that the a request for a hearing with respect to litigated in the matter. Each contention followirig amendment requests involve issuance of the amendment to the must consist of a specific statement of no significant hazards consideration, subject facility operating license and the issue or law or fact to be raised or Under the Commission's regulations in any person whose interest may be controverted. In addition, the petitioner 10 CFR 50.92, this means that o affected by this proceeding and who shall provide a brief explanation of the of the facility in accordance the witberation wishes to participate as a party bases in theof the contention and a concise proposed amendment would not (1) proceeding must file a written request statement of the alleged facts or expert involve a significant increase in the for a hearing and a petition for leave to OPi nion which support the contention probability or consequences of an intervene. Requests for a hearing and a and on which the petitioner mtends to accident previously evaluated; or (2) petition for leave to intervene shall be relyin preving the contention at the create the possibility of a new or filed in accordance with the heanng. The petitioner must also different kind of accident from any Commission's " Rules of Practice for Provide references to those specific accident previou:.b evaluated; or (3) Domestic L-ising Proceedings" in 10 sources and documents of which the involve a significant reduction in a CFR Part 2. Interested persons should Petitioner is aware and on which the margin of safety. The basis for this consult a current copy of 10 CFR 2.714 Petitioner intends to mly to establish proposed determination for each which is available at the Commission's those facts or expert opinion. Petitioner amindment request is shown below. Public Document Room, the Gelman must provide sufficient information to The Commission is seeking public Building,2120 L Street, NW., show that a genuine dispute exists with comments on this proposed Washington, DC and at the local public the applicant on a matenal issue of law determination. Any comments received document room for the particular or fact. Co,ntentions shall be limited to within 30 days after the date of facility involved. If a request for a matters within the scope of the , publication of this notice will be hearing or petition for leave to intervene amendment under consideration. The considered in making any final is filed by the above date, the contention must be one which, if determination Commission or an Atomic Safety and Proven, would entitle the petitioner to Normally, the Commission will not I.icensing Board, designated by the relief. A petitioner who fails to file such issue the amendment until the Commission or by the Chairman of the a supplement which satisfies these cxpiration of the 30-day notice period. Atomic Safety and Licensing Board mquirements with respect to at least one lhwever, should circumstances change Panel, will rule on the request and/or contention will not be permitted to during the notice period such that Petition; and the Secretary or the Part ci a as pa y ; failure to act in a timely way would designated Atomic Safety and Licensing result, for example, in derating or Board will issue a notice of a hearing or rties to the pmceeding, subject to any shutdo,wn of the facility, the an appropriate order. fmitations in the order granting leave to Commission may issue the license As required by to CFR 2.714, a intervene, and have the opportunity to participate fully in the conduct of the amendment before the expiration of the petition, for leave to intervene shall set hearing, including the opportunity to 30-day notice period, provided that its forth with particularity the interest of final determination is that the present evidence and cross-examine i the petitioner in the proceeding, and witnesses. am ndment involves no significant how that interest may be affected by the hazards consideration.The final if a hearing is requested, the results of the proceeding. The petition Commission will make a final det:rmination will consider all public should specifically explain the reasons and State comments received before why intervention should be permitted determination on the issue of no significant hazards consideration. The action is taken. Should tha Commission with particular reference to the take this action, it will publish in the following factors:(1) The nature of the final determination will serve to decide Federal Register a notice ofissuance when the hearing is held. petitioner's right under the Act to be if the final determination is that the and provide for opportunity for a made a party to the proceeding: (2) the amendment request involves no hearing after issuance. The Commission nature and extent of the petitioner's si8nificant hazards consideration, the expects that the need to take this action property, financial, or other interest in Commission may issue the amendment will occur very infrequently. the proceeding; and (3) the possible Written comments may be submitted and make it immediately effective. effect of any order which may be notwithstanding the request for a by mail to the Chief, Rules and entered in the proceeding on the Directives Branch, Division of hearing. Any hearing held would take petitioner's interest. The petition should place after issuance of the arnendment. Administration Services, Office of also identify the specific aspect (s) of the if the final determinations that the Administration, U.S. Nuclear Regulatory subject matter of the proceeding as to amendment request involves a Commission, Washington, DC 20555- which petitioner wishes to intervene. 0001,and should cite the publication significant hazards consideration, any Any person who has filed a petition for hearing held would take place before data and page number of this Federal leave to intervene or who has been the issuance of any amendment. Register notice. Written comments may admitted as a party may amend thew A request for a liearing or a petition 60 b3 delivered to Room 6D22. Two petition without requesting leave of the for leave to intervene must be filed with Whita Flint North,11545 Rockville Board up to 15 days prior to the first the Secretary of the Commission, U.S. Pike. Rockville, Maryland from 7:30 prehearing conference scheduled in the Nuclear Regulatory Commission, a rn.13 4:15 p.m. Federal workdays, proceeding, but such an amended Washington, DC 20555-0001, Attention: Copies of written comments received petition must satisfy the specificity Rulemakings and Adjudications Staff, or may be examined at the NRC Public requirements described above. may be delivered to the Commission's

l. .

19966 Federal Register /Vol. 63, No. 77/ Wednesday, April 22,1998 / Notices probability or consequences of an accident Commonwealth Edison Company, Public Document Room, the Gelman previously evaluated. Docket Nos. STN 50-454 and STN 50-Building,2120 L Street, NW., B. The proposed changes do not create the 455, Byron Station, Unit Nos. I and 2, Washington, DC, by the above date. A Po5sibility of a new or different kind of Ogle County, Illinois copy of the petition should also be sent ,d' from any accident previously to the Office of the General Counsel, fj'Iu d 16,1997. U.S. Nuclear Regulatory Commission'he references Many of the proposed changes delete Washington, DC 20555-0001, and to t to items that have been completed. Description of amendment request: attorney for the licensee. The NRC required these items as a condition The proposed amendment would add an Nontimely filings of petitions for of granting the license. Since they have been exemption from 10 CFR 70.24(a) to the leave to intervene, arnended petitions, satisfied as intended, deleting them is Unit 1 license consistent with the Unit stipplemental petitions and/or requests administrative. 2 license, for a hearing will not be entertained None of the proposed changes affect the Basisforproposed no significant absent a determination by the design or operation of any system. structure' hazards considemtion determination: Commission, the presiding officer or the or f"ctions component As required by 10 CFR 50.91(a), the of theinrelated the plant. The safety structures, systems, he b piM b Wis o% Atomic Safety and Licensing Beard that '

d b *"

the petition and/or request should be y, ,",";,Q, 3y*,f ,,y structure, issue of no significant hazards granted based upon a balancing of system. or component reduced by the revised consideration, which is presented factors specified in 10 CFR surveillance or testing requirements. The below: 2.714(a)(1)(1)-(v) and 2.714(d). , changes do not affect the manner by which - A. The proposed change does not involve For further details with respect to this the facility is operated and do not change any a significant increase in the probability or action, see the application for facility design feature, structure, system, or consequences of an accident previously amendment which is available for component. No new or different type of evaluated. equipment will be installed. Since there is no The initial conditions and methodologies public inspection at the Commission's used in the accident analyses remain Public Document Room, the Celman change to the facility or operating Procedures, and the safety functions and unchanged. The proposed change does not Building,2120 L Street, NW., change or alter the design assumptions for Washington, DC, and at the local public reliability of Structures, systems orroposed document room,for the particular cchanges mp nents are not d n t create effected, the {ity of the possibi the a new the systems consequences or components of an accident. Therefore, used to mitigate facility involved

or different kind of accident from any accidents analysis results are not impacted.

~ accident previously evaluated. The There are no physical changes to me Commonwealth Edison Company, remaining changes are editorial in nature and facility, and all opwating procedures, Docket Nos. STN 50-454 and STN50- have no impact on plant operation or design. limiting conditions for operation, limiting 455, Byron Station, Unit Nos. I and 2, C, The proposed changes do not involve a safety system settings, and safety limits are Ogle County, Illinois signiScant reduction in a margin of safety. unchanged. . IA2te of amendment mquest: March The proposed changea>to the Operating The specific requirements for granting an 1.lconse are generally administrative in exemption from 10 CFR 70.24(a) have been 14,1997, met. The request le authorized by law, will nature and have no impact on the margia of Description of amendment mquest: The proposed amendment would delete safety of any Technical Specification: There defense andi security. not endanger and is in life er property the public - or the common is no impact on safety limits or limiting license conditions which have been safety system settings. The changes do not interest. satisfied, revise others to delete Parts affect any plant safety parameters or Therefore, the proposed change does not which are no longer applicable or to setpoints. The operating license wnditions involve a significant increase in the revise references, and make editorial have been satisfied, as requimd. There am no probability or consequences of an accident ~ changes- changes to the conditions themselves. previously evaluated. Basisfor proposed no significos.- The.efore, the proposed changes do not , B. "Its proposed change does not create the hazards consideration determination: involve a significant reduction in a margin of possibility or a new or different kind of safety. . accident-from any accident previously As required by 10 CFR 50.91(a), the Therefore, based on the above evaluation, . eve.luated. licensee has provided its analysis of the The proposed change does not affect the Issue of no signiucant hazards Commonwealth Edison has concluded that these changes do not involve significant design or operation of any system, structure, consideration, which is presented or component in the plant. The safety hazards considerations. below,* functions of structures, systems,or. The NRC staff has reviewed the components are not changed in any manner, A. The proposed changes do not involve a licensee's analysis and, based on this nor is the reliability of any structure, system, significant increase in the probability or or mmponent aduced by the revised consequences of an accident previously review,it appears that the three surveillance or testing requirements. The evaluated. standards of 10 CFR 50.92(c) are change d es not affect the manner by which The initial conditions and methodologies satisfied. Therefore, the NRC staff the facility is operated and does not change used in the accident analyses remain any facility design feature, structure, system, unchanged. Tb. proposed changes do not . mquested PNPoses to determine amendments that involve no the or enmponent. No new or different type of change or alter the design assurnptions for. significant hazards consideration. equipment will be inrtalled. Since there is no the systems or components used to mitigate change to the facility or operating the consequences of an accident.Therefore. local Public Docum*ent Room pmcedures, and the safety functions and accident analyses res,ults are not impacted, location: Byron Public Library District, reliability of structures, systems, or The license conditmos were one-time 10 components are not affected, the proposed commitments that have been satisfied. There Illm,9is N. 61010.Franyin, P.O. Box 434, Byron, change does not create the possibility of a are no physical changes to the facility, and new or different hind of accident from any all operating procedures, limiting conditions Attorneyforlicensee: Michael L for operation, limiting safety system settings, Miller, Esquire: Sidley and Austin, One accident previously evaluated. and safety limits are unchanged. Removal of First National Plaza, Chicago, Illinois . C. The proposed change does not involve these license conditions is appropriate and a significant reduction in a margin of safety. 60603* The proposed change to the Operating safe. L.icense has no impact on the margin of safety Therefore, the proposed chan8es do not NRCProject Director:Stuart A. Richards. of any Technical Specification. There is not involve a significant increase in the l l 19974 Federal Register / Vol. 63, No. 77 / Wednesday. April 22,1998 / Notices 4 reactivity changes and core alterations with issue of no significant hazards local Public Document Room both trains oi U CREMAFS inoperable does consideration, which is presented location: Exeter Public Library, not create the possibility of a new or different below: Founders Park. Exeter, Nil 03833. accient from any previously evaluated . Attorneyforlicensee: Lillian M.

1. The proposed changes do not involve a Cuoco, Esq., Sem.or Nuc; ear Counsel,

3. The proposed change does not involve signincar.t increase in the probability or Northeast Utilities Service Company, a significant reduction in the margin of c nsequences of an accident previously evaluated.

P.O. Box 270, liartford, CT 06141-0270. safety' The c hanges being proposed do not revise NRC Project Director. Cecil O. The design basis accidents are not affected equipment design or operation nor do they by the proposed editonal and administrative Thomas. make changes to Technical Specification changes. The proposed changes do not required safety hmits or safety system change the level of programmatic controls or Northeast Nuclear Energy Company the procedural details currently in pla;e. (NNECO), et al., Docket No. 50-423 n mr nt nIitions wh$care Furthermore, these changes have no adverse Afill6 tone Nuclear Power Station Unit maintained in the control room during affect to the safe operation of the station. No. 3. New lendon County. Connecticut normal oP' ration and following an accident Performance of certain maintenance and and they do not revise the accident analyses. testing activities during conditions or modes Date of amendment regtast: April 1, Therefore, tha proposed changes do not other than shutdown will be evaluated by 1998. Description of amendment request: involve a significant reduction in the margin North Atlantic to ensure proper regard to i of safety, their effect on safe operation of the plant is The proposed revision to the Millstone given prior to conduct of a particular Unit 3 licensing basis would add a new The NRC staff has reviewed .he surveillance, or portion thereof. Therefore, licensee's analysis, and based on this sump pump subsy stem to address t gr undwater inleakage through the review,it appears that the three e p babil ty or standards of 50.92(c) are satisfied. san $can cIreae containment basemat. consequences of an accident previously Basisforpro osed no sigmficant Therefore, the NRC staff proposes to evaluated. determine that the amendment request 2. The proposed changes do not create the hazards consi erotion determination: involves no significant hazards possibility of a new or different kind of As required by to CFR 50.91(a), the consideration, accident from any pre <iously analyzed. licensee has provided its analysis of the The proposed changes do not introduce issue of no significant hazards local Public Document Room new features or modify plant structurn, considera' ion, which is presented location: Exeter Public Library, systems and c mponents or procedures that Founders Park, E. xeter, NH 03833. bel m could Attorneyfor heensee: Lillian M. norma r$ssiblyabnormalaffect station conditions, thus,operations the underhas reviewed the pmposed NNECO Cuoco, Esq., Senior Nuclear Counsel, potential for an unanalvred accident is not revision in accordance with 10 CFR 50.92 Northeast Utilities Service Company, created. performance of maintenance and and hs concluded that the revielon does not .P.O. Box 270, Hartford, CT 06141-0270. testing activities on-line, as v ell as involve a significant hazards consideration shutdown, are contm!!ed by North Atlantic's (SHCl. The t>ases for this conclusion is that NRC Project Dimetor. Cecil O. the three criteria of 10 CFR 50.92(c) are not Thomas, pmcedures and policies to perform reviews and assessments of these activities to satisfied. The proposed revision does not North Atlantic Energy Sewice determine the affect on safe operation of the involve an SHC because the revision would facility. The proposed editorial and not: l Corporation, Docket No. 50-f 43, 1. Involve a significant increase in the l Seabmok Station, Unit No. 2, administrative changes have no adverse affect on the safety limits or design basis probability or consequences of an accident Rockingham County, New Hampshire accidents. Therefore, the proposed changes previously evaluated. do not create the possibility of a new or The current FSAR [ Final Safety Analysis Date of amendment request: April 3, 1998, different kind of acc' dent imm any Report] credits the waterproof membrane for previously analyzed. assuring that groundwater inleakage is not r Description of amendment mquest: significant and would hw no impact on

3. The proposed changes do not involve a The proposed change would revisc he significant reduction in a margin of safety. safety related structures and components.

Seabrook Station Technical inservice inspection and testing frequencies, (3) revise TS Table 1.1 to surveillance requirements and standards of 50.92(c) are satisfied. ',', an a a surveli!ance requirements. e , 9 f periodically tested to ensure their pumps will also be performed. The into procedures and the environmental failure proo(criterion." cnd components will perform the required protection from gmundwater inleakage during normal operation. Thus, there is no loss of offsite power or a design basis tir-drivin sump groundw ter, all sources ofliquid radiological contamination to plugged. Drains from equipment not to be a potential source of radiological to pravent the entrance of contaminated which are nonsafety-related, have been isolated from the indirect waste receptor which drzins to RSS [recircuhtion spray components nor do they introduce systeml pumps. The original p'. ant design Specifically, the proposed change had only nonsafety.related RSS sump pumps administrative changes to plant procedures would: (1) provide wording changes in available for pumping the groundwater from the Bases Section of TS 4.0.2 necessary that could affect operator response during n nnal, abnormal or emergency situations. the RSS sumps. These pumps are not to support 24-month surveillance Performance of certain maintenance and powered from the emergency busses and interval extensions, (2) revise TS 4.0.5.b testing activities during conditions or modes would not be accessible during a design bas,si to provide revised terminology for other than shutdown will be evaluated by LOCA lloss-of-coolant accidentl. North Atlantic to ensure proper regard to Thus, it is assumed that they would not be activities and their associated their effect on safe operation of the plant is available to mitigate a design basis accident. given prior to conduct of a particular Two independent safety-related air-driven surveillance. or portion thereof. Therefore. sump pumps have been installed to eliminate clarify current and future refueling the potential for groundwater inleakage that the proposed changes do not involve a latervals and their associated significant reduction in a margin of safety. would affect the RSS pumps. Air. driven sump purnps have been frquencies, and (4) delete the "during The NRC staff has reviewed the installed with the air supply line routed to shutdown" restriction from the licensee's analysia, and based on this a c nnecti n utside the ESF lengineered perft.rmance requirements of certain review, it appears that the three '" " "' #*'I gg, ",i p 3 Basisfor proposed no significant Therefore, the NRC staff proposes to that is accessible during a design basis hazards consideration determination: determine that the amendment request accident such as a LOCA. Two air invo lves no significant hazards comprusors have laen staged in designated As required by 10 CFR 50.91(a), the locations, and will be raaintained and licensee has provided its analysis of the consideration. I Federzl Re;;ister/Vol. 63 No. 77/ Wednesday, April 22,1998 / Notices 19975 l SUMP 10. To preclude any potential proof and meets the requirements of availability. Periodic testing of the sump siphoning from the potentially contaminated Standard Review Plan 3 4.1. Sump to back to Sumps 7A/7B. the lines of Use of the new system mquires operator surveillance requirements have been the existing nonsafety.related pumps have action to install pre-staged air compressors to 1 incorporated into the Technical been shortened to discharge above the water provide power for the new air-driven sump Requirements Manual. level in Sump 10. pumps. It is estimated that these sump-EOP (Emergency Operating Procedure) 3b The walls of Sumps 7A/7B have been pumps would be needed appmximately ten Est.3 his been modified to add a step to extended to protect from a Limited Panive hours after a design basis accident. Thus, instill thi compressors and start the sump Failure and Pipe Break in the RSS cubicles. there is sufficient time for the operators to pumps. It is estimated that these sump The expected nooding height is 6.6 inches perform this action.Since sufficient time is pumps would be needed approximately ten ( l. The sump cubicle height was extended available, the action has been incorporated hours (fter a design basis accident. Thus, to 3 ft. above the cubicle floor, well above' into procedures and the environmental thrre is sufficient time for the operators to this height. The sumps are covered with a conditions allow access to the area, it is perform this action. Since sufficient time is vented hood to protect from pipe break spray concluded that credit for operator action can avallibli, the action has been incorporated and miscellaneous overhead leaks to further be taken. 3ssure the sumps remain isolated from With credit for the new single failure proof conditions allow access to the area, it is rientially contaminated RSS system fluids. air-driven sump pumps and operator action concluded that credit for oparator action can The existing SIERS (supplementary leak to install pre-staged compressors to provide bet: kin. collection and release system) boundary has power for the pumps, the new subsystem Thus, the new system is single failure been extended to the isolation valves located ' provides the required assurance that the RSS proof tnd meets the requirements of outside of the ESF building. Additionally. pumps will not be affected by groundwater Stindtrd Review Plan 3.4.1 which stated tl when the sump level is reduced while usinB inleakage. Thus, it is concluded that the RSS following: the air driven pump, the pumps are designed pumps would be operable for long term "If s:fety-related structures are protected to prevent air from being discharged through accident mitigation and there is no impact on from below-grade groundwater seepage by the pump discharge outside of the ESF the margin of safety as defined in the basis muns of a permanent dewatering system, buildingr of the Emergency Core Cooling Technical thin thm system should be designed as a Thus, use of the new sump pumps would Specifications or any otherTechnical safety.rilited system and meet the single not affect the offsite doses following a design Specification. basis accident. Therefore, the proposed revision does not This previMs assurance that the RSS Therefore, the proposed revision does not involve a significant reduction in a margin of pumps and other safety related structures involve a significant increase in the safety. probabil;ty or consequence of an accident sity function as assumed in the accident previously evaluated. In conclusion, based on the cnityeis. 2. Create the possibility of a new or information provided, it is determined Th3 current nonsafety-related RSS sump different kind of accident from any accident that the proposed revision does not pump syrtem will continue to provide previously evaluated. involve an SHC. The current nonsafety-related RS$ sump The NRC staff has reviewed the j( pump systsm will continue to provide licensee's analysis and, based on this impact on the probability of occurrence of a protection from groundwater inleakage review, it appears that the three tr:nsient because of equipment or structural during normal operation. This will continue failure due to groundwater inleakage, in to provide assurance there is no potential for standa-ds of 10 CFR 50.92(c) are a transient because of equipment or satisfied. Therefore, the NRC staff cddition, the new safety-related RSS sump pump system provides additional assurance structural failure due to gmundwater Proposes to determine that the thit groundwater inleakage would not affect inleakage. In addition, the new safety.related amendment request involves no structures or equipment during an extended RSS sump pump system provides additional significant hazards consideration. assurance that groundwater inleakage would Local Public Document Poom accidrnt. Thus, it is concluded that there is not affect structures or equipment during an location: Learning Resources Center, no impct on the probability of occurrence of extended loss of offsite power or a design Three Rivers Community-Technical tny previously evaluated accident. basis accident. College 574 New London Turnpike, Thi change results in the use of the new Therefore, the proposed revis. ion does not Norwich, Connecticut, and the . pumps to remove create the possibility of a new or different groundwater in-leakage from the RSS kind of accident from any accident *Waterford Library, ATrN: Vince cubicles. To preclude the possibility for previously evaluated. Juliano,49 Rope Ferry Road, Waterford, radiological contamination of the 3. Involve a significant reduction in a , Connecticut. margin of safety. Attorneyforlicensee: Lillian M. the sumps have The current FSAR credits the waterpmof Cuoco, Esq., Senior Nuclear Counsel, been climinated. The RSS cubicle floor membrane for assuring that groundwater Northeast Utilitia Service Company, drrins heding to Sumps 7A/7B have been inleakage is not significant and would have P.O. Box 270 Hartford, Connecticut. determined - no impact on safety related structures and NRC Deputy Director:Phillip F. components. However, degradation of the McKeeu contamination continue to drain to Sumps waterproof membrane has been detected and 7A/7B (sources include CCP [ component it is now concluded that groundwater Pacific Gas and Electric Company, ccoling wsterl and Service Water relief inleakage can be significant in that it could Docket Nos. 50-275 and 50-323. Diablo valves) and are covered with splash guards affect the operability of the RSS pumps. Canyon Nuclear PowerPlant Unit Nos. Ongmal design had only nonsafety-related RSS sump pumps available for pumping the 2 and 2 San Luis Obispo County, spray. The Hydrogen Recombiner area floor drsins and the drain from the PASS l post groundwater from the RSS sumps. These rnia accident sampling system] sample sink, all of pumps are not powered from the emergency Date of amendment request: busses and would not be accessible during a December 23,1997. design basis LOCA. Thus. it is assumed that Description of amendment request: title="Sump">Sump 7B. Sumps 7A and 7B they would not be available to mitigate a hzve been cleaned and the existing design basis accident. Two independent The proposed amendments would nonsaf1ty-related sump pumps replaced to safety.related air-driven sump pumps have revise the combined Technical remove any existing residual contamination. been installed to eliminate the potential for SPecifications (TS) for the Diablo Th3 nonsafety-related pumps (3DAS-P8A/B) . groundwater inleakage that would affect the Canyon Power Plant Unit Nos.1 and 2 disch rge to ESF Building sump 3DAS- RSS pumps. The new system is single failure to revise Technical Specification (TS) 3/

ML20248C500

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