B12889, Requests Temporary Relief from Tech Specs 3.0.4 Re Limiting Condition for Operation 3.6.3 for Return to Operation.Prompt Relief Requested in Order to Minimize Delay of Startup of Plant.Fee Paid
| ML20151J253 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 04/14/1988 |
| From: | Mroczka E NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| B12889, GL-87-09, GL-87-9, NUDOCS 8804210077 | |
| Download: ML20151J253 (4) | |
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L J w.w w xa.ww~ (203) 665-5000 April 14, 1988 Docket No. 50-423 B12889 Re: Technical Specification 3.6.3 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Vashington, D.C. 20555 Gentlemen:
Hillstone Nuclear Pover Station, Unit No. 3 Temporary Valver of Compliance From Technical Specification Limiting Condition for Operation On March 1, 1988, while performing the biennial sample line valve position indication testing, it was discovered that two inside containment isolation valves vould not open and a third isolation valve inside containment was found leaking. Specifically, the Pressurizer Relief Tank (PRT) gas sample line (3/4") 8. solation talve 3SSR*CV8026 and the pressurizer vapor space sample Ifne (3/4") isolation valve 3SSR*CTV20 would not open to perform Technical Specifi-cation required surveillance testing and this precluded surveillance of the outside contain.ent isolation valves 3SSR*CV8025 and 3SSR*CTV21. The third valve, pressuri?.er liquid sample line (3/4") isolation valve 3SSR*CTV22, was leaking. Therefore, these valves were considered to be inoperable on March 1 and compensatory measures were taken as required by the Action Statement of 3.6.3.b of the Hillstone Unit No. 3 Technical Specifications. Specifically, corresponding outside containment isolation valves 3SSRCV*8025, 3SSR*CTV21, and 3SSR*CVT23 vere closed and power was removed from the valve operators. It should be noted that these valves were successfully leak-rate +ested prior to start-up from the first refueling outage. Hillstone Unit No. 3 was in Hede 1 at that time and, as allowed by the Action Statement of Technical Cpeelfication 3.6.3, continued operations until the unit tripped on April 13, 1988, due to low condenser vacuum causing a turbine and reactor trip. The low condenser vacuum vas caused by automatic tripping of two circulation vater pumps in the intake structure due to high differential pressure across the traveling screens.
The Hillstone Unit No. 3 Technical Specification Section 3.0.4 states that entry into an operational mode or other specified condition shall not be made unii a the Limiting Condition for Operation (LCO) is met without reliance on the provisions of the Action Requirements. Thc intent is to ensure that a higher mode of operation is not entered when equipment is inoperable. This precludes a plant startup if an LCO is not met, even if the Action Require-ments vould permit continued operation of the plant for an unlimited period of time. Generally, the individual specifications that have Action Requirements 8804210077 880414 PDR ADGCK 05000423
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- U.S. Nuclea'. Regulatory Commission B12889/Page 2 April 14, 1988 vhich allow continued operation note that Specification 3.0.4 does not apply.
Hovever, exceptions to Specification 3.0.4 have not been consistently applied.
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This is true in the case of Specification 3.6.3. Millstone Unit No. 3 Tech-nien1 Specifications are based on Vestinghouse Standard Technical Specifica-tions (STS). Exceptions to Specification 3.0.4 have not been applied to the STS Section 3.6.3., "Containment Isolation valves". Generically, the NRC has recognized this inconsistent application of exceptions to Specification 3.0.4.
To alleviate this problem, on June 4, 1987, the NRC issued Generic Letter 87-09, "Section 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirceents". In that Generic Letter the Staff addressed three specific problems and provided alternatives to the STS to resolve these problems. The Staff also encouraged licensees to propose changes to their Technical Fpecifi-cations that are consistent with the guidance provided in the enclosure of the Generic Letter. Northeast Nuclear Energy Company (NNECO) has not previously submitted any changes to specification 3.0 and 4.0 due to generic industry concerns with Generic Letter 87-09 which were recently resolved with the NRC.
NRC approval for the lead owner's group plant is expected shortly and NNECO plans to eventually submit a proposed license amcadment, as offered by Generic Letter 87-09. A comprehensive, plant-specific teview of the applicability of the provisions of the Generic Letter vil), of course, precede sobmittal of the amendment request.
In accordance with recent discussions between NNECO and the NRC Staff, NNECO hereby requests a temporary valver of compliance from Technical Specification 3.0.4 to LC0 3.6.3, which precludes ascending in modes if an LCO is not met, L even though the Action Statements of Technical Specification 3.6.3 vould permit continued operation of Millstone Unit ho. 3 for an unlimited period of time. This relief is requested to permit the plant to return u ?)ver Opera-tion (Mode 1) from the current Hot Shutdown (Mode 3) condition. Repair of these valves inside containment can only be accomplished with containment at atmospheric pressure. Vorking in the su'oatmosphere containment is limited to inspections and work durations of less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Replacement of the sole-noid valves vill likely require grinding out the damaged valve and velding a new valve in place. Relaxing the subatmospheric condition in the containment is permitted only when the plant is in cold shutdown (Mode 5) or Refueling (Mode 6). Approval of this temporary valver request vill prevent a thermal cycle to cold shutdovn and return to the normal operating temperature of 557'F. NNECO has determined that entering into a higher mode until an emer-gency license amendment is processed vill not place the plant in an unsafe condition.
The basis for the determination is:
(1) The three sample line outside containment isolation valves are closed and the power removed from the valve operator, thereby ensuring the ability
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- $ JA U.S. Nuclear Regulatory commission B12889/Page 3 April 14, 1988 to provide containment isolation when required. Leaving these penetra-tions in an isolated configuration accomplishes the safety function of Technical Specif' cation 3.6.3 for these lines.
(2) The sample lines affected are provided for sampling capability. However, the sam;1e lines are not normally used during plant operation and are not required during a post accident situation.
(3) The substance of this proposed change is to allov us to return to power operation in a configuration originally recognized as acceptable in the 3 Technical Specifications for an indefinite period.
Additional bases for this temporary valver request can be found in Generic
-Letter 87-09. One important element of the Generic Letter was to recognize that, for some specifications, unnecessary restrictions on mode changes are imposed by Specification 3.0.4. Upon review of the specific circumstances at issue here, NNECO has determined that the intent o! changes offered in Generic Letter 87-09 are applicable to Specification 3.6.3. As such, this request can be characterized as the initial application of the Generic Letter to Millstone Unit No. 3. It is also noted that a similar application of the Generic Letter was applied for by NNECO and issued by the NRC at Hillstone Unit No. 1, Speci-fication 3.6.G.2, regarding flov indication for the 20 jet pumps. Our request was filed on July 23, 1987, and Amendment No. 7 vas issued on August 6, 1987.
Prompt relief is requested in order to minimize the delay of startup of the plant. NNECO vill submit an emergency license amendment request regarding Technical Spacification 3.6.3 to remove the inconsistent application of excep-tions to specification 3.0.4 on April 15, 1988. The substance of the forth-coming amendment request is to eliminate the applicability of Specifica-tion 3.0.4 to Action Statements (b) and (c) of Specification 3.6.3. The amendment request vill be submitted tomorrov vith the objective of minimizing the duratica of time under which NNEC0 vill be operating under the provisions of the subject valver.
Pursuant to the requirements of 10CFR170.12(c), enclosed with this valver request is the application fee of $150.
Ve vill continue to keep you informed on matters relevant to thie :equest.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY f$4 W E . *G'. foczka Seni Vice Pre (97 sident
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U.S.-Nuclear Regulatory Commission B12889/Page 4 April 14, 1988 cc V. T. Russell, Region I Administrator R._L. Ferguson, NRC Project Manager, Millstone Unit No.'3-U. J. Raymond, Senior Resident Inspector, Millstone Unit Nos. 1,-2, and 3 ?
STATE O!7 CONN?CTICUT)
) s2. Berlin COUNTY OF HARTFORD )
Then personally appeered 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 Liceasee herein, and that the statements contained in said information are true and correct to the best of his knowledge and belief.
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LOTH No'taryPplic MY COMMISSION EL' IRES MMCH 31, 1991' I
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