L-11-139, Request for an Amendment to Revise Both the Plants Technical Specification 3.4.15, RCS Leakage Detection Instrumentation, Using the Consolidated Line Item Improvement Process

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Request for an Amendment to Revise Both the Plants Technical Specification 3.4.15, RCS Leakage Detection Instrumentation, Using the Consolidated Line Item Improvement Process
ML11126A014
Person / Time
Site: Beaver Valley, Davis Besse
Issue date: 04/29/2011
From: Sena P
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-139
Download: ML11126A014 (44)
v • d • e


Text

"FENOC Oft*% 76 South Main Street FirstEnergyNuclear Operating Company Akron, Ohio 44308 Peter P. Sena Ill President and Chief Operating Officer April 29, 2011 L-11-139 10 CFR 50.90 Attention: Documentt Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket Nos. 50-334 and 50-412, License Nos. DPR-66 and NPF-73 Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Request for an Amendment to Revise Both the Beaver Valley Power Station and the Davis-Besse Nuclear Power Station Technical Specification (TS) 3.4.15, "RCS Leakage Detection Instrumentation," Using the Consolidated Line Item Improvement Process In accordance with the provisions of 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the Technical Specifications (TS) for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS),

and for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS).

The proposed amendments would revise the TS to define a new time limit for restoring inoperable reactor coolant system (RCS) leakage detection instrumentation to operable status, establish alternate methods of monitoring RCS leakage when one or more required monitors are inoperable, and make TS Bases changes that reflect the proposed changes and more accurately reflect the contents of the facility design basis related to operability of the RCS leakage detection instrumentation. These changes are consistent with NRC-approved Revision 3 to TSTF Improved Standard Technical Specification (STS) Change Traveler TSTF-513, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on January 3, 2011 (76 FR 189) as part of the consolidated line item improvement process (CLIIP).

Enclosed is an evaluation of the proposed changes for both BVPS and DBNPS.

The enclos.c;re also includes the markup pages of the existing BVPS and DBNPS TS shcw*wing the proposed changes, the markup pages of the existing BVPS and

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station, Unit No. 1 L-11-139 Page 2 DBNPS TS Bases showing the proposed changes, and the revised (clean) BVPS and DBNPS TS pages.

FENOC requests approval of the proposed license amendments by May 1, 2012, with the amendments being implemented within 90 days.

In accordance with 10 CFR 50.91 (a)(1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in accordance with the distribution requirements in 10 CFR 50.4.

In accordance with 10 CFR 50.91(b)(1), "State Consultation," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the designated state officials in Ohio and Pennsylvania.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 761-6071.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 29 ,2011.

Sincerely, Peter P. Sena III

Enclosure:

EVALUATION OF PROPOSED CHANGES for Beaver Valley Power Station, Unit Nos. 1 and 2, and Davis-Besse Nuclear Power Station, Unit No. 1 License Amendment Request for Adoption of TSTF-513, Revision 3, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation"

Beaver Valley Power Station, Unit Nos. 1 and 2 Davis-Besse Nuclear Power Station, Unit No. 1 L-11-139 Page 3 cc: NRC Region I Administrator NRC Region III Administrator NRC Project Manager - Beaver Valley Power Station, Unit Nos. 1 and 2 NRC Project Manager - Davis-Besse Nuclear Power Station, Unit No. 1 NRC Resident Inspector - Beaver Valley Power Station, Unit Nos. 1 and 2 NRC Resident Inspector - Davis-Besse Nuclear Power Station, Unit No. 1 Director BRP/DEP Site Representative (BRP/DEP)

Executive Director, Ohio Emergency Management Agency,

-State of Ohio (NRC Liaison)

Utility Radiological Safety Board

EVALUATION OF PROPOSED CHANGES for Beaver Valley Power Station, Unit Nos. 1 and 2, and Davis-Besse Nuclear Power Station, Unit No. 1 License Amendment Request for Adoption of TSTF-513, Revision 3, "Revise PWR Operability Requirements and Actions for RCS Leakage Instrumentation" Page 1 of 7

1.0 DESCRIPTION

The proposed amendment would revise the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), and the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS) Technical Specifications (TS) to define a new time limit for restoring inoperable reactor coolant system (RCS) leakage detection instrumentation to operable status, establish alternate methods of monitoring RCS leakage-when one or more required monitors are inoperable, and make conforming TS Bases changes. These changes are consistent with Nuclear Regulatory Commission (NRC) approved Revision 3 to Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change Traveler TSTF-513, "RevisePWR-Operability Requirements and Actions for RCS Leakage Instrumentation,.," The availability of this TS improvement was announced in the FederalRegister on January 3, 2011 (76 FR 189) as part of the consolidated line item improvement process (CLIIP).

2.0 PROPOSED CHANGE

S, 2.1 BVPS Changes For BVPS, the proposed changes revise and add a new Condition C to TS 3.4.15, "RCS Leakage Detection Instrumentation," and revise the associated Bases. New Condition C is applicable when the containment atmosphere gaseous radioactivity monitor is the only operable TS-required monitor (that is, all other monitors are inoperable). New Condition C Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and restoring another monitor within 7:

days. Attachment 1 provides a marked up version of the BVPS TS pages with-the TSTF-513 changes, while Attachment 3 provides a clean, typed version of the BVPS TS pages with the changes incorporated. Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in the limiting condition for operation (LCO) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.15. provides an information only copy of the TS Bases pages marked up to reflect the aforementioned changes.

The FirstEnergy Nuclear Operating Company (FENOC) is not proposing variations or deviations from the Westinghouse Owner's Group Standard Technical Specification changes described in TSTF-513, Revision 3, or the NRC staffs model safety evaluation (SE) referenced in the CLIIP Notice of Availability published on January 3, 2011 (76 FR 189).

Page 2 of 7 FENOC has made some modifications to the TS Bases, in addition to those proposed in TSTF-5113, Revision 3, in order to reflect the existing BVPS containment sump and humidity instrumentation. The proposed TS Bases modifications will be implemented along with the changes proposed by TSTF-513 using the BVPS Technical Specification Bases Control Program (TS 5.5.10) and evaluated under the BVPS 10 CFR 50.59 program.

2.2 DBNPS Changes For DBNPS, the proposed changes revise and add a new Condition C to TS 3.4.15, "RCS Leakage Detection Instrumentation," and revise the associated Bases. New Condition C is applicable when the containment atmosphere gaseous radioactivity.

monitor'is the only operable TS-required monitor (that is, all other monitors are, inoperable). New Condition C Required Actions require analyzing grab samples of the containment atmosphere every12 hours and restoring another monitor within 7 days. Attachment 4 provides a marked up version of the DBNPS TS pages with the TSTF-513 changes', while Attachment 6 provides a clean, typed-version of the DBNPS TS pages with the changes incorporated. Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to:clarify the specified safety function for each required instrument in the limiting condition for operation (LCO) Bases, delete discussion from the Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made:

to TS 3.4.15. Attachment 5 provides an information only copy of the TS Bases pages marked up to reflect the aforementioned changes.

The proposed changes also correct inappropriate references to "required" equipment in TS 3.4.15. In several locations the specifications incorrectly refer to a,,,.

"required" containment sump monitor. The term "required"'is reserved for situations.

in which there are multiple ways to meet the LCO, such as the-requirement for-.

either a gaseous or particulate radiation monitor. The incorrect use of the term "required" is removed from TS 3.4.15 Condition A.

Although the FirstEnergy Nuclear Operating Company (FENOC) is proposing a variation to the Babcock and Wilcox Owner's Group Standard Technical Specification changes described in TSTF-513, Revision 3, the NRC staff's model safety evaluation (SE) referenced in the CLIIP Notice of Availability published on January 3, 2011 (76 FR 189) is unaffected. New Condition D will state "Required Action and associated Completion Time of Condition A, B, or C not met."

Additionally, Surveillance Requirement (SR) 3.4.15.4 will be modified to delete the*

word "required" to be consistent with the change made to Condition A. These changes satisfy the intent of the TSTF change.

The TS Bases changes proposed by TSTF-513 will be implemented using the DBNPS Technical Specification Bases Control Program (TS 5.5.13) and evaluated under the DBNPS 10 CFR 50.59 program.

Page 3 of 7 3,0 BACKGROUND NRC Information Notice (IN) 2005-24, "Nonconservatism in Leakage Detection Sensitivity," dated August 3, 2005, informed addressees that the reactor coolant activity assumptions for primary containment atmosphere gaseous radioactivity monitors may be non-conservative. This means the monitors may not be able to, detect a one gallon per minute leak within one hour. Some licensees have taken action in response to IN 2005-24 to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the primary containment atmosphere gaseous radiation monitor is often the first monitor to indicate an increase in RCS leak rate. As a result, the TSTF and the NRC staff.

met on April 29, 2008, and April 14, 2009, to develop an alternative approach to address the issue identified in IN 2005-24. The agreed solution is to retain the primary containment atmosphere gaseous radiation monitor in the LCO list of required equipment, revise the specified safety function of.the. gas monitor to specify the required instrument sensitivity level, revise the Actions to require additional monitoring, and provide less time before a plant shutdown is required,..

when the primary containment atmosphere gaseous radiation- monitor is the only operable monitor.

4.0 TECHNICAL ANALYSIS

FENOC has reviewed TSTF-513, Revision 3, and the model SE referenced in the CLIIP Notice of Availability published on January 3, 2011 (76 FR 189). FENOC has concluded that the technical bases presented in TSTF-513, Revision 3, and the model SE prepared by the NRC staff are applicable to both BVPS and DBNPS..

The proposed amendment revises the language in thejTS Bases that describes when the gaseous and particulateý containment atmosphere ,radioactivity monitors.4 :--.

are operable. The proposed amendment requires additional batch or manual RCS.-,

leakage monitoring to be performed when the primary containment atmosphere gaseous radiation monitor is the only operable continuous or automatic monitor.'.

These alternative batch methods provide an RCS leakage detection capability similar to the TS-required methods. The grab sample has an RCS leakage detection capability that is comparable to that of the containment particulate radiation monitor. The proposed Actions and Completion Times for grab samples are adequate because use of frequent grab samples provides additional assurance (in addition to the mass balances required by Condition A) that any significant RCS leakage will be detected prior to significant reactor coolant pressure boundary (RCPB) degradation.

4.1 BVPS - General Design Criterion (GDC) 30, "Quality of Reactor Coolant Pressure boundary" The Beaver Valley Power Station, Unit No. 1 (BVPS-1) Updated Final Safety Analysis Report (UFSAR) Appendix 1A, "1971 AEC General Design Criteria Conformance," Item 1A.30, "Quality of Reactor Coolant Pressure Boundary

Page 4 of 7 (Criterion 30)," states that BVPS-1 design conforms with the intent of General Design Criteria (GDC) 30. UFSAR Section 4.2.7.1, "Leakage Detection,"

describes the leakage detection methods which include, but are not limited to, the containment sump water level, and containment gas and particulate radiation monitors. The time required for the containment gas and particulate radiation monitors to detect reactor coolant leakage depends on the size of the leak, the reactor coolant activity level, and containment background activity due to prior leakage.

The Beaver Valley Power Station, Unit No. 2.(BVPS-2).UFSAR Section 5.2.5, "Detection of Leakage Through Reactor Coolant Pressure Boundary," describes the

-basis for compliance with GDC 30.* The methods described include monitoring containment sump level-and flow, containment airborne (particulate and gaseous) radioactivity, and containment atmospheric, pressure, temperature, and humidity..

UFSAR Table 1.8-1, "USNRC Regulatory Guides," describes the basisfor general compliance with Regulatory Guide (RG) 1.45, "Reactor Coolant Pressure Boundary

.-Leakage Detection Systems," Revision 0.

4.2 DBNPS - GDC 30 Though RG 1.45, Revision 0, was issued after the issuance of the DBNPS construction permit, the DBNPS Updated Safety Analysis Report (USAR) Section 5.2.4, '!RCPB Leak Detection System," states that the intent of RG 1.45 was met.ý The USAR section indicates the leak detection system includes a containment atmosphere particulate radioactivity monitor, a containment sump level and flow monitor, and a containment atmosphere gaseous radioactivity monitor. GDC 30 requires the means for detecting and, to the extent practical, identifying the location

.ofthe source of RCS-leakage, and RG 1.45 describes -the means to meet the-GDC.

5.: REGULATORY SAFETYANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FENOC has evaluated the proposed changes to both the BVPS and DBNPS TS

-using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration at either BVPS or DBNPS.-. An .

analysis of the issue of no significant hazards consideration is presented below:

Description of Amendment Request: The proposed amendment would revise BVPS TS 3.4,15, "RCS Leakage Detection Instrumentation," and DBNPS TS 3.4.15, "RCS Leakage Detection Instrumentation," Conditions and Required Actions and the licensing basis for the gaseous radiation monitor, as well as make associated TS Bases changes forTS 3.4.15.

Page 5 of 7 Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91(a), the FENOC analysis of the issue, for both BVPS and DBNPS, of no significant hazards consideration using the standards in 10 CFR 50.92 is presented below:

1. Does the Proposed Change Involve a Significant Increase in the:Probability or Consequences of an Accident Previously Evaluated?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. The monitoring of RCS leakage is not a precursor to any accident previously: evaluated. ..The monitoring. of RCS leakage is not used to mitigate the consequences of:any accident previously evaluated. Therefore, it is concluded that the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the Proposed Change Create the Possibility of a New or Different Kind of Accident from any Accident Previously Evaluated?.

Response: No The proposed change clarifies-the operability: requirements for the RCS leakage detection instrumentation and reduces the time allowed-for the plant.to operate when the only TS-required operable RCS leakage detection instrumentation monitor:*

is the containment atmosphere gaseous radiation monitor. .The proposed change-does not involve a physical alteration. of.the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The proposed change maintains'Sufficient continuity and diversity of leak detection capability that the probability of piping evaluated and approved for Leak-Before-Break progressing to pipe rupture remains extremely low. Therefore, it is concluded that the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated:

3. Does the Proposed Change Involve a Significant Reduction in a Margin of Safety?

Response: No The proposed change clarifies the operability requirements for the RCS leakage detection instrumentation and reduces the time allowed for the plant to operate when the only TS-required operable RCS leakage detection instrumentation monitor is the containment atmosphere gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the containment atmosphere gaseous

Page 6 of 7 radiation monitor operable increases the margin of safety by increasing the likelihood that an increase in RCS leakage will be detected before it potentially results in gross failure. Therefore, it is concluded that the proposed change does not involve a significant reduction in a margin of safety.

Based upon the above analysis, FENOC concludes that the requested change does not involve a significant hazards consideration, as set forth in- 10 CFR 50.92(c),

"Issuance of Amendment" for either BVPS or DBNPS.

5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of the proposed .TS change and' its relationship to applicable

--regulatory requirements are-contained in TSTF-513, Revision 3 and the NRC's model SE that were referenced in the CLIIP Notice of Availability published on January 3, 2011 (76 FR 189). FENOC has reviewed- the'NRCstaff's model SE .

referenced in the CLIIP Notice of Availability and concluded that the regulatory evaluation section is applicable to both BVPS and DBNPS. -

6.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with, respect to installation or use of a facility component located within the restricted area,, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement.

However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite; or (iii) a significant increase in.

individual or cumulative occupational radiation exposure..' Accordingly, the proposed.

change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).- Therefore, pursuant to 10 CFR 51-.22(b),-no environmental-impact statement or environmental assessment need beiprepared in connection

-with the proposed change.

7.0 REFERENCES

1. Technical Specification Task Force Improved Standard Technical Specifications Change Traveler TSTF-513, Revision-3, dated January 3, 2011.
2. NRC Information Notice 2005-24, "Nonconservatism in Leakage Detection Sensitivity," dated August 3, 2005.
3. Regulatory Guide (RG) 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.
4. Beaver Valley Power Station, Unit No. 1 Updated Final Safety Analysis Report, Section 4.2.7.1, "Leakage Detection."

Page 7 of 7

6. Beaver Valley Power Station, Unit No. 2 Updated Final Safety Analysis Report, Section 5.2.5, "Detection of Leakage Through Reactor Coolant Pressure Boundary."
7. Davis-Besse Nuclear Power Station Updated Safety Analysis Report, Section 5.2.4, "RCPB Leak Detection System."

8.0 ATTACHMENTS

1. Markup Pages of Existing Beaver.Valley Power, Station, Unit Nos. 1 and 2 Technical Specifications to Show the Proposed Changes
2. Markup Pages of Existing Beaver Valley Power Station, Unit Nos. 1 and 2 Technical Specification Bases to Show the Proposed Changes (For Information Only)
3. Revised (Clean) Beaver Valley Power Station, Unit Nos. 1 and 2-Technical Specification Pages
4. Markup Pages-of Existing Davis-Besse Nuclear Power Station, Unit No. 1 Technical Specifications to- Show the Proposed Changes
5. Markup Pages of Existing Davis-Besse:Nuclear Power Station, Unit No. 1 Technical Specification Bases to Show -the Proposed Changes -

(For. Information Only)

6. Revised (Clean) Davis-Besse Nuclear PowerStation, Unit No. 1 Technical Specification Pages

Attachment 1 Markup Pages of Existing Beave r-Valley Power Station, Unit Nos. 1 and 2 Technical Specifications to Show the Proposed Changes (Four Pages Follow)

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump (level or discharge flow) monitor, and
b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required containment A.1 sump monitor - NOTE -

inoperable. Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND A.2 Restore required 30 days containment sump monitor to OPERABLE status.

0~ u/A'&4 p~fOiO Beaver Valley Units I and 2 3.4.15- 1 Amendments 278 / 161

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION I REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere radioactivity the containment monitor inoperable. atmosphere.

OR B.1.2

- NOTE -

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

\. Required Action and k.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion D Time not met. AND D

Vý.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />

"*. All required monitors *.1 Enter LCO 3.0.3. Immediately inoperable.

~ti Beaver Valley Units 1 and 2 3.4.15 -2 Amendments 278 / 161

INSERT #1 CONDITION REQUIRED ACTION COMPLETION TIME

- NOTE -

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

C. Required containment C. 1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> sump monitor inoperable. the containment atmosphere.

AND C.2 Restore required 7 days containment sump monitor to OPERABLE status.

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of the required containment 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmosphere radioactivity monitor.

SR 3.4.15.2 Perform COT of the required containment atmosphere 92 days radioactivity monitor.

SR 3.4.15.3 Perform CHANNEL CALIBRATION of the required 18 months containment sump monitor.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of the required 18 months containment atmosphere radioactivity monitor.

0 ~fLoPo~

NO OPy

jýCL~jDUf* koA 6tn~i Beaver Valley Units 1 and 2 3.4.15-3 Amendments 278 / 161

Attachment 2 Markup Pages of.Existing Beaver Valley Power Station, Unit NosAI and 2 Technical Specification Bases to Show the Proposed Changes*-

(For Information Only)

(Eight Pages. Follow)

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50, as discussed in Reference

( fZ'dVi',0j 0)I requires means for detecting and, to the extent practical, identifyiQ the location of the source of RCS LEAKAGE. Regulatory Guide 1.45, as discussed in Reference 2, describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE. -/I- %L(

tndustIy reaatIce has t ow chanrges u' 0.5 t 1.0 g.m-

,can-.o roadily -- tectod in 3cntaincd volumer b ii-

,wataervelý,- ,*,, iat, th e - , The non-Emergency Core Cooling System (ECCS) portion of the containment sump used to collect unidentified LEAKAGE is qkutrentedtoa- due

,'gP jCA'Td of--Jc2/t The reactor co nt contains radioactivity that, when released to the containment, be detected by radiation monitoring instrumentation.

.. eS F c nt roleectvity

" b c'&clz ","i-l&l , iitia~Frft-up--

rnntminnt'on or rinrldtnn r4*fpt, Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE...

--- ýAn increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE.

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump. Humidity level monitoring is i 1A'RA considered most useful as an indirect.ae-m-ef indication toael-he operator to a potential problem. Humidity monitors are not required by this LCO.

Beaver Valley Units I and 2 B 3.4.15 - 1 Revision 0

INSERT #1 In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

INSERT #2 Other indications may be used to detect an increase in unidentified LEAKAGE; however. they are not reauired to be OPERABLE by this LCO.

RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS leakage into the containment. The relevance of temperature and pressure measurements_4e.affected by containment free volume and, for

[-- ,,-rpmt.rz, -det~ctAorr'iation. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO. , *-

APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY to the operators, and the ability to compare and verify with indications ANALYSES from other systems is necessary. -tip3e in1trurnet-lea-tienR-ar-e-uthz-ed,4.-needed,_to-B~ue-that-tbeta,rnspor4-deley-tim-e--ef-the-4eakage fr m-it,-seur-ee.4e-aeinistf-ume1-t0*aton-yietds-an.-acceptabie-vefaI--

FestRSe4Me-,.-.-

The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring RCS LEAKAGE into the containment area is necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leakage occur detrimental to the safety of the unit and the public.

RCS leakage detection instrumentation satisfies Criterion I of 10 CFR 50.36(c)(2)(ii).

LCO 9ie--ef--pretee, ng-ieft-erCe-R.-ea kage-der-ive s-frrrth-abili ne-rapidly-dýtac--ext y-eme -leak-s* This LGG-requires-instruments-of-diverse-monitoring-principles-to-be-OPERABLE to provide+-ig--degriee-e4 confidence thate-tieey small

.J4aa are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

-eml 1447 C- l The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment sump monitor, in combination with a gaseous or particulate radioactivity monitor, provides an acceptable minimum. The containment sump monitor is comprised of the instruments associated with the non-ECCS portion of the containment sump which monitor narrow range level and sump pump discharge flow.

The LCO only requires that the sump level or discharge flow monitor be OPERABLE. The required particulate and gaseous radioactivity monitors are RM-IRM-215A&B (Unit 1) and 2RMR-RQ3D3A&B (Unit 2).

Beaver Valley Units 1 and 2 B 3.4.15 - 2 Revision 0

INSERT #3 The above-mentioned LEAKAGE detection methods.or systems differ in sensitivity and response time., Some of these systems could serve as early'-. I.. .-

alarm systems signaling the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

INSERT#4 The LCO requires two instruments to be OPERABLE.

The non-ECCS portion of the containment sump is used to collect unidentified LEAKAGE. The monitor on the containment sump detects level or flow rate and is instrumented to detect when there is an increase above the normal value. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by the gaseous or particulate containment atmosphere radioactivity monitor. Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be'low during initial reactor startup and for a few weeks.

thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination-or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 3).

RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is to be < 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation are much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A,.1 and A.2 . <r*'7.-,.*,*-

With the required containment sump r~onitor inoperable, no other form of sampling can provide the equivalent i formation; however, containment atmosphere radioactivity .onitor will pro* e indications of changes in leakage. Together with the tmosphere onitor, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Restoration of the required sump monitor to OPERABLE status within a Completion Time of 30 days is required to regain the function after the monitor's failure. This time is acceptable, considering the Frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

B.1.1, B.1.2, and B.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors.

Beaver Valley Units 1 and 2 B 3.4.15 - 3 Revision 0

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all

.Z -,-necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leakage detection

'ý"- is available.

DJ,.C.1land/.21 P zC If a Required Action of Condition A-er-B-cannot be met, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

With all required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that the channel is operating properly. The Fr-equency-of-1-2-hours-is-based-on-instrument-reliability-and-is-reasonable-for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. A successful test of.f, required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This PA clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by Beaver Valley Units 1 and 2 B 3.4.15 - 4 Revision 0

INSERT #5 C.1 and C.2 With the required containment sump monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere radiation monitor.

A Note clarifies that this Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radioactivity monitor. The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection.

Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity.

The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE REQUIREMENTS (continued) other Technical Specification Surveillance Requirements. The test verifies the alarm setpoint and relative accuracy of the instrument string.

The Frequency of 92 days considers instrument reliability, and operating experience has shown that it is proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the RCS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

REFERENCES 1. Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."

  • .UFSAR Section 4.2.7.1 (Unit 1) and UFSAR Section 5.2.5(Ui2)

- , .I~ ~y O (Ui~.T(/'

nit2)

CooH ' u.Zgo~n/Z 0A) -,0 OL b4C46yP 14Al Beaver Valley Units 1 and 2 B 3.4.15 - 5 Revision 0

Attachment 3 Revised (Clean) Beaver Valley Power.Station, Unit Nos-. 1 and 2 -'C

'Technical Specification Pages (One Page Follows)

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere radioactivity the containment monitor inoperable, atmosphere.

OR B .1 .2 -------- .-.-.--- . .... ..

- NOTE -

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

- NOTE -

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

C. Required containment C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> sump monitor inoperable, the containment atmosphere.

AND C.2 Restore required 7 days containment sump monitor to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. All required monitors E.1 Enter LCO 3.0.3. Immediately inoperable.

Beaver Valley Units 1 and 2 3.4.15- 2 Amendments TBID / TBD

Attachment 4 Markup Pages of Existing Davis-Besse Nuclear Power Station, Unit No. 1 Technical Specifications to Show the Proposed Changes (Four Pages Follow)

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and
b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C

A. R.equired-containment A.1 ----------- NOTE-sump monitor Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable, after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND A.2 Restore requr-ed- 30 days containment sump monitor to OPERABLE status.

B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere radioactivity the containment monitor inoperable, atmosphere.

OR Davis-Besse 3,4.15-1 Amendment 279

I RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.1.2 -------- NOTE Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to J#* "* 1

D-k. Required Action and Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A r-&- AND not met. .1 3"D C j

Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> i +

Both required monitors *Q.1 Enter LCO 3.0.3. Immediately inoperable.

.1.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of required containment 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmosphere radioactivity monitor.

SR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of required 31 days containment atmosphere radioactivity monitor.

Davis-Besse 3.4.15-2 Amendment 279

INSERT #1 CONDITION REQUIRED ACTION COMPLETION TIME

- NOTE -

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

C. Containment sump monitor C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> inoperable. the containment atmosphere.

AND C.2 Restore containment sump 7 days monitor to OPERABLE status.

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.4.15.3 Perform CHANNEL CALIBRATION of required 18 months containment atmosphere radioactivity monitor.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of-,er,*ed 24 months containment sump monitor.

Davis-Besse 3.4.15-3 Amendment 279

Attachment 5 Markup Pages of Existing Davis-Besse Nuclear Power Station, Unit No.1 Technical Specification- Bases to Show the Proposed Changes-ý.

(For Information Only)

(Eight Pages Follow)

RCS Leakage Detection Instrumentation B 3.4.15 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.15 RCS Leakage Detection Instrumentation BASES BACKGROUND GDC 30 of Appendix A to 10 CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Although not committed to Regulatory Guide 1.45 (Ref. 2), it describes acceptable methods for selecting leakage detection systems.

Leakage detection systems must have the capability to detect significant reactor coolant pressure boundary (RCPB) degradation as soon after occurrence as practical to minimize the potential for propagation to a gross failure. Thus, an early indication or warning signal is necessary to permit proper evaluation of all unidentified LEAKAGE.

Inu.t... p. act h

.... h....that...t.r....

.... *Jiaiges ot 0.5 to 1.0 gpm

  • ran readi4Ly h-_1%detectd inMRondvl~~b~mn~n iiy~f

...... level, i fl...t. in the oporating froguency of a pump. The

, o. *r containment sump used to collect unidentified LEAKAGE is instrumented to allow detecting increasesf .5o the normal flow rates L-EAKAGE.

The reactor coolit contains radioactivity that, when released to the containment, can be detected by radiation monitoring instrumentation.

cuoi R~dL~u aduL ua vLiy ....... illb..lo duin n;tjidl I~lddu strtu and for a few woe.. the ,aLer uneil activated corrosion peudu have 9.formed an f'io

.hpen uducis appear from fuel element c',addlng--

c~ont~min~tion o-,r c~ladding; dofooto. Insru.lr m ent sensiti\iti~e of, 1 0"9 pJ,tC;;

redioactiVity for p.rt.icuatc monitcring and of 10.6 FCi/cc radioacti-ity for gaseou monitoring arAe prFactic"I fo tfhse l#ie rk*dye Ueet* tI .

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE. ._.L, 'ex'?T .PVZ.-

Air temperature and pressure monitoring methods may also be used to infer unidentified LEAKAGE to the containment. Containment temperature and pressure fluctuate slightly during plant operation, but a rise above the normally indicated range of values may indicate RCS

.ionptai ment. The relevance of temperature and S ,, pressure measuremente.-affected by containment free volume and, for temperature, detector location. Alarm signals from these instruments can be valuable in recognizing rapid and sizable leakage to the containment.

Temperature and pressure monitors are not required by this LCO.

~cY7/

-Tvs__,_ tb3 Davis-Besse B 3.4.15-1 Revision 0

INSERT #1 In addition to meeting the OPERABILITY requirements, the monitors are typically set to provide the most sensitive response without causing an excessive number of spurious alarms.

INSERT #2 Other indications may be used to detect an increase in unidentified LEAKAGE; however, they are not required to be OPERABLE by this LCO. An increase in humidity of the containment atmosphere would indicate release of water vapor to the containment. Dew point temperature measurements can thus be used to monitor humidity levels of the containment atmosphere as an indicator of potential RCS LEAKAGE.

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable and should be compared to observed increases in liquid flow into or from the containment sump and condensate flow from air coolers. Humidity level monitoring is considered most useful as an indirect alarm or indication to alert the operator to a potential problem. Humidity monitors are not required for this LCO.

INSERT #3 The above-mentioned LEAKAGE detection methods or systems differ in sensitivity and response time. Some of these systems could serve as early alarm systems signaling the operators that closer examination of other detection systems is necessary to determine the extent of any corrective action that may be required.

RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABLE The need to evaluate the severity of an alarm or an indication is important SAFETY to the operators, and the ability to compare and verify with indications ANALYSES from other systems is necessary. 4'"lt'" nocations

.t...zed, ifneeded, t- ens..re the t.an.p..t delay time of th leakage from 4its *ou to an tru.....

"" Oreso location "'d^e* .n...... oA"rall The safety significance of RCS LEAKAGE varies widely depending on its source, rate, and duration. Therefore, detecting and monitoring reactor coolant LEAKAGE into the containment area are necessary. Quickly separating the identified LEAKAGE from the unidentified LEAKAGE provides quantitative information to the operators, allowing them to take corrective action should a leak occur detrimental to the safety of the unit and the public.

Refer to the Bases of LCO 3.4.13, "RCS Operational LEAKAGE," for further information regarding RCS LEAKAGE.

RCS leakage detection instrumentation satisfies Criterion 1 of 10 CFR 50.36(c)(2)(ii).

LCO Onemcthed of P^ ... L C is fro "bi y cf ; r...... "eteet cxtrc,,mal'y sAal ,oa.f. This LCO to rapidlE" requires instruments of diverse monitoring principles to be OPERABLE to A14,C Vu'kD"r'A provide a high deeff confidence that e*t-emewy small F detected in time to allow actions to place the plant in a safe condition L when RCS LEAKAGE indicates possible RCPB degradation.

The LCO requirements are satisfied when monitors of diverse .. AY*-SX 5' measurement means are available. Thus, the containment sump monitor (both the level and flow portions), in combination with a particulate or gaseous radioactivity monitor, provides an acceptable minimum.

APPLICABILITY Because of elevated RCS temperature and pressure in MODES 1, 2, 3, and 4, RCS leakage detection instrumentation is required to be OPERABLE.

In MODE 5 or 6, the temperature is < 200°F and pressure is maintained low or at atmospheric pressure. Since the temperatures and pressures are far lower than those for MODES 1, 2, 3, and 4, the likelihood of leakage and crack propagation is much smaller. Therefore, the requirements of this LCO are not applicable in MODES 5 and 6.

ACTIONS A.1 and A.2 With the fequifed containment sump monitor inoperable (i.e., either level or flow or both), no other form of sampling can provide the equivalent information.

Davis-Besse B 3.4.15-2 Revision 0

INSERT #4 The LCO requires two instruments to be OPERABLE.

The containment normal sump is used to collect unidentified LEAKAGE. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in this sump. The monitors associated with the containment normal sump detect level or flow rate. The monitors are instrumented to detect when there is an increase above the normal value by 1 gpm. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the containment normal sump and it may take longer than one hour to detect a 1 gpm increase in unidentified LEAKAGE, depending on the origin and magnitude of the LEAKAGE. This sensitivity is acceptable for containment normal sump monitor OPERABILITY.

The reactor coolant contains radioactivity that, when released to the containment, can be detected by the gaseous or particulate containment atmosphere radioactivity monitor. Only one of the two detectors is required to be OPERABLE. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE, but have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and for a few weeks thereafter, until activated corrosion products have been formed and fission products appear from fuel element cladding contamination or cladding defects. If there are few fuel element cladding defects and low levels of activation products, it may not be possible for the gaseous or particulate containment atmosphere radioactivity monitors to detect a 1 gpm increase within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> during normal operation. However, the gaseous or particulate containment atmosphere radioactivity monitor is OPERABLE when it is capable of detecting a 1 gpm increase in unidentified LEAKAGE within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> given an RCS activity equivalent to that assumed in the design calculations for the monitors (Ref. 3).

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS /j/q' A.1 and A.2 (continued)

However, the containment atmosphere radioactivity onitor will provide indications of changes in leakage. Together with theatmosphere monitor, the periodic surveillance for RCS inventory balance, SR 3.4.13.1, water inventory balance, must be performed at an increased frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to provide information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, and pressurizer level). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Restoration of the reqUi4e containment sump monitor to OPERABLE status is required to regain the function in a Completion Time of 30 days after the monitor's failure. This time is acceptable considering the frequency and adequacy of the RCS water inventory balance required by Required Action A.1.

B.1.1, B.1.2, and B.2 With required gaseous or particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information. With a sample obtained and analyzed or a water inventory balance performed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the reactor may be operated for up to 30 days to allow restoration of at least one of the radioactivity monitors.

The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> interval provides periodic information that is adequate to detect leakage. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishing steady state operation (stable temperature, power level, and pressurizer level). The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. The 30 day Completion Time recognizes at least one other form of leak detection is available.

D 6.1 and .2 If a Required Action of Condition A1 r Bv'cannot be met within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at Davis-Besse B 3.4.15-3 Revision 0

INSERT #5 C.1 and C,2 With the containment sump monitor inoperable, the only means of detecting LEAKAGE is the required containment atmosphere radiation monitor. A Note clarifies that this Condition is applicable when the only OPERABLE monitor is the containment atmosphere gaseous radioactivity monitor. The containment atmosphere gaseous radioactivity monitor typically cannot detect a 1 gpm leak within one hour when RCS activity is low. In addition, this configuration does not provide the required diverse means of leakage detection. Indirect methods of monitoring RCS leakage must be implemented. Grab samples of the containment atmosphere must be taken to provide alternate periodic information.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> interval is sufficient to detect increasing RCS leakage. The Required Action provides 7 days to restore another RCS leakage monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS 0.1 and 0.2 (continued) least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

With both required monitors inoperable, no automatic means of monitoring leakage are available, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SURVEILLANCE SR 3.4.15.1 REQUIREMENTS SR 3.4.15.1 requires the performance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives reasonable confidence that each channel is operating properly. The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is based on instrument reliability and is reasonable for detecting off normal conditions.

SR 3.4.15.2 SR 3.4.15.2 requires the performance of a CHANNEL FUNCTIONAL TEST of the required containment atmosphere radioactivity monitor. The test ensures that the monitor can perform its function in the desired manner. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Frequency of 31 days considers instrument reliability, and operating experience has shown it proper for detecting degradation.

SR 3.4.15.3 and SR 3.4.15.4 These SRs require the performance of a CHANNEL CALIBRATION for each of the required RCS leakage detection instrumentation channels.

The calibration verifies the accuracy of the instrument string, including the instruments located inside containment. The Frequency of 18 months or 24 months, as applicable, considers channel reliability and, operating experience has proven this Frequency is acceptable.

Davis-Besse B 3.4.15-4 Revision 0

RCS Leakage Detection Instrumentation B 3.4.15 BASES REFERENCES 1. 10 CFR 50, Appendix A, Section IV, GDC 30.

2. Regulatory Guide 1.45, a,

A4,. -.

\

Davis-Besse B 3.4.15-5 Revision 0

Attachment 6 1

Revised (Clean) Davis-Besse Nuclear Power Station, Unit No*.!:.

. Technical Specification Pages (Three Pages Follow)

RCS Leakage 0)etection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. One containment sump monitor; and
b. One containment atmosphere radioactivity monitor (gaseous or particulate).

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Containment sump monitor inoperable.

A.1 ---------- NOTE-------

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> I

after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND A.2 Restore containment sump monitor to OPERABLE 30 days

/

status.

B. Required containment B.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> atmosphere radioactivity the containment monitor inoperable, atmosphere.

OR Davis-Besse 3.4.15-1 Amendment

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.1.2 ---------- NOTE-------

Not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation.

Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND B.2 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

- NOTE -

Only applicable when the containment atmosphere gaseous radiation monitor is the only OPERABLE monitor.

C. Containment sump C.1 Analyze grab samples of Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> monitor inoperable, the containment atmosphere.

AND C.2 Restore containment sump 7 days monitor to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> E. Both required monitors E.1 Enter LCO 3.0.3. Immediately inoperable.

SURVEILLANCE REQUIREMENTS Davis-Besse 3.4.15-2 Amendment

RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE FREQUENCY SR 3.4.15.1 Perform CHANNEL CHECK of required containment 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> atmosphere radioactivity monitor.

SR 3.4.15.2 Perform CHANNEL FUNCTIONAL TEST of required 31 days containment atmosphere radioactivity monitor.

SR 3.4.15.3 Perform CHANNEL CALIBRATION of required 18 months containment atmosphere radioactivity monitor.

SR 3.4.15.4 Perform CHANNEL CALIBRATION of containment 24 months sump monitor. I Davis-Besse 3.4.15-3 Amendment

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