L-11-038, License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation

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License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-514, Revision 3, Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation
ML111030640
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 04/12/2011
From: Bezilla M
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-038, TSTF-514, Rev 3
Download: ML111030640 (28)
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Text

{{#Wiki_filter:FENOC FirstEnergy Nuclear Operating Company Mark B. Bezilla Vice President April 12, 2011 L-11-038 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Perry Nuclear Power Plant Docket No. 50-440, License No. NPF-58 Perry Nuclear Power Plant 10 Center Road Perry Ohio 44081 10 CFR 50.90 440-280-5382 Fax. 440-280-8029 License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for ReS Leakage Instrumentation" 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 Perry Nuclear Power Plant. The proposed amendment 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 Technical Specification Task Force (TSTF) Improved Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on December 17, 2010 (75 FR 79048) as part of the consolidated line item improvement process (CUIP). The enclosure contains an evaluation of the proposed changes. Attachments in the enclosure provide the markup pages of the existing TS to show the proposed changes, information only markup pages of the existing TS Bases to show the proposed changes, and revised (clean) TS pages. FENOC requests approval of the proposed license amendment by April 30, 2012, with the amendment being implemented within 90 days.

Perry Nuclear Power Plant L-11-038 Page 2 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 NRC 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 Ohio Official. 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 ~, 2011. ~ii72f!3 Mark B. Bezilla

Enclosure:

EVALUATION OF PROPOSED CHANGES License Amendment Request for Adoption of TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" cc: NRC Region III Administrator NRC Project Manager NRC Resident Inspector Executive Director, Ohio Emergency Management Agency, State of Ohio (NRC Liaison) Utility Radiological Safety Board

EVALUATION OF PROPOSED CHANGES License Amendment Request for Adoption of TSTF-514, Revision 3, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation" Page 1 of 7

1.0 DESCRIPTION

The proposed amendment would revise the Perry Nuclear Power Plant (PNPP) 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 the NRC-approved Revision 3 to Technical Specification Task Force (TSTF) Standard Technical Specification (STS) Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation." The availability of this TS improvement was announced in the Federal Register on December 17, 2010 (75 FR 79048) as part of the consolidated line item improvement process (CUIP).

2.0 PROPOSED CHANGE

S The proposed changes add a new Condition D to TS 3.4.7, "RCS Leakage Detection Instrumentation," and revise the associated bases. New Condition D is applicable when the drywell atmospheric gaseous monitor is the only operable TS-required instrument monitoring RCS leakage, i.e., TS-required drywell atmospheric particulate, drywell floor drain sump, and upper drywell air cooler condensate flow rate monitors are inoperable. New Condition D Required Actions require monitoring RCS leakage by obtaining and analyzing grab samples of the drywell atmosphere every 12 hours; monitoring RCS leakage using administrative means every 12 hours; and taking action to restore monitoring capability using another monitor within 7 days. Attachment 1 provides a marked up version of the PNPP TS pages with the TSTF-514 changes, while Attachment 3 provides a clean, typed version of the PNPP TS pages with the changes incorporated. The FirstEnergy Nuclear Operating Company (FENOC) is not proposing variations or deviations from the TS changes described in TSTF-514, Revision 3, or the NRC staff's model safety evaluation (SE) referenced in the CUIP Notice of Availability published on December 17, 2010 (75 FR 79048).

Page 2 of 7 Additionally, the TS Bases, which summarize the reasons for the specifications, are revised to clarify the specified safety function for each required instrument in Limiting Condition for Operation (LCO) Bases, delete discussion from the TS Bases that could be construed to alter the meaning of TS operability requirements, and reflect the changes made to TS 3.4.7. FENOC has made some modifications to the TS Bases, in addition to those proposed in TSTF-514, Revision 3, in order to reflect the existing PNPP drywell atmospheric monitoring instrumentation. provides an information only copy of the TS Bases marked up to reflect the aforementioned changes. The TS Bases changes will be implemented using the PNPP Technical Specification Bases Control Program (TS 5.5.11) and evaluated under the PNPP 10 CFR 50.59 program.

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 drywell atmospheric 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, in response to IN 2005-24, have taken action to remove the gaseous radioactivity monitor from the TS list of required monitors. However, industry experience has shown that the drywell atmospheric 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 drywell atmospheric 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 requiring additional monitoring, and provide less time before a plant shutdown is required when the drywell atmospheric gaseous radiation monitor is the only operable monitor.

4.0 TECHNICAL ANALYSIS

FENOC has reviewed TSTF-514, Revision 3, and the model SE referenced in the CUIP Notice of Availability published on December 17, 2010 (75 FR 79048). FENOC has concluded that the technical bases presented in TSTF Traveler-514, Revision 3, and the model SE prepared by the NRC staff are applicable to PNPP. The detection methods at PNPP for small unidentified leaks within the drywell include monitoring of floor drain sump inleakage, upper air cooler condensate flow rate, and atmospheric gaseous and particulate radioactivity, as described in PNPP Updated Safety Analysis Report (USAR), Section 5.2.5.1.1, "Detection of Leakage within the Drywell." USAR Section 5.2.5.2.1, "Leak Detection Instrumentation and Monitoring Inside Drywell," describes these methods.

Page 3 of 7 Drywell Floor Drain Sump Monitoring The leakage collected in the floor drain sump includes unidentified leakage from the control rod drives, valve flange leakage, component cooling water, air cooler drains, and any leakage not connected to the equipment drain sump. The floor drain sump instrumentation monitors and records sump level. Abnormal leakage rates are alarmed in the main control room. Collection in excess of background leakage would indicate an increase in reactor coolant leakage from an unidentified source. Two fixed-measurement interval methods exist for determining unidentified drywelileakage rates. First, the leakage rate can be calculated using the change in the drywell floor drain sump level as indicated in the control room. By monitoring the level change over a period of time, the leakage rate can be calculated. The second fixed-measurement method involves monitoring the drywell floor sump drain pump run time. By determining pump run time over a given period, the leakage rate can be determined if the pump rate is known or can be conservatively estimated. Drywell Air Cooler Condensate Flow Rate Monitoring Condensate from the upper two drywell coolers is routed to the floor drain sump and is monitored by use of a flow transmitter which measures flow in the condensate drain line and sends signals for indication and alarm instrumentation in the control room. Drywell Atmospheric Monitoring This drywell air sampling system continuously monitors the drywell atmosphere for airborne radioactivity. The sample is drawn directly from the drywell. A sudden increase of activity, which may be attributed to steam or reactor water leakage, is annunciated in the control room. Airborne particulate and gaseous radioactivity are monitored in the drywell as a qualitative method for determining high gross unidentified leakage. Correlating particulate and gaseous radioactivity readings with reactor coolant leakage rate is considered impractical in detecting increases in leakage rates of 1 gallons per minute (gpm) to 3 gpm. Additionally, USAR Section 5.2.5.2.1 also includes other methods of leak detection inside of the drywell, including but not limited to, drywell temperature and drywell pressure.

Page 4 of 7 USAR Section 5.2.5.10, "Regulatory Guide 1.45 Compliance," states that the drywell floor drain sump monitoring and the upper drywell air cooler condensate flow rate monitoring systems are designed to detect leakage rates of 1 gpm within 1 hour, thus meeting Position C.5 of Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0, May 1973. The drywell atmospheric monitoring system is not designed to detect leakage rates of 1 gpm within 1 hour. The USAR section indicates that, given these, as well as other methods described in the PNPP USAR, the leakage detection systems meets the intent of Regulatory Guide 1.45. The NRC stated in NUREG-0887, "Safety Evaluation Report related to the operation of the Perry Nuclear Power Plant, Units 1 and 2," Supplement No.7, dated November 1985, Section 5.2.6, the PNPP reactor coolant pressure boundary leakage detection systems meet the applicable acceptance criteria in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," Section 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection." The applicable NUREG-0800 acceptance criteria is GDC 30 which is based on meeting the guidelines of Regulatory Guide 1.45. The administrative means of monitoring include diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. Based upon an evaluation of the monitoring mechanisms noted in Section 4.0 of the model application, FENOC will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, and manual timing of the drywell floor drain sump pumpout. There are diverse alternative methods for determining that RCS leakage has not increased, from which appropriate indicators may be selected based on plant conditions. FENOC will utilize the following method or methods considering the current plant conditions and historical or expected sources of unidentified leakage: drywell pressure, drywell temperature, and manual timing of the drywell floor drain sump pumpout. Actions to verify that these indications have not increased since the required monitors became inoperable and analyze drywell atmospheric grab samples are sufficient to alert the operating staff to an unexpected increase in RCS leakage. 5.0 REGULATORY SAFETY ANALYSIS 5.1 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION FENOC has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a

Page 50f7 significant hazards consideration. An analysis of the issue of no significant hazards consideration is presented below: Description of Amendment Request: The proposed amendment would revise TS 3.4.7, "RCS Leakage Detection Instrumentation" Conditions and Required Actions and the licensing basis for the drywell atmospheric gaseous radiation monitor, as well as make associated TS Bases changes for TS 3.4.7. Basis for proposed no significant hazards consideration determination: As required by 10 CFR 50.91 (a), the FENOC analysis of the issue 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 drywell atmospheric 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 this 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 drywell atmospheric 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. 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.

Page 6 of 7

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 drywell atmospheric gaseous radiation monitor. Reducing the amount of time the plant is allowed to operate with only the drywell atmospheric gaseous 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." 5.2 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA A description of the proposed TS change and its relationship to applicable regulatory requirements are contained in TSTF-514, Revision 3 and the NRC staff's SE that were referenced in the CLlIP Notice of Availability published in the Federal Registeron December 17, 2010 (75 FR 79048). FENOC has reviewed the NRC staff's model SE referenced in the CLlIP Notice of Availability and concluded that the regulatory evaluation section is applicable to PNPP.

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 be prepared in connection with the proposed change.

Page 7 of 7

7.0 REFERENCES

1. Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-514, "Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation," Revision 3, December 17, 2010.
2. Regulatory Guide 1.45, "Reactor Coolant Pressure Boundary Leakage Detection Systems," Revision 0, May 1973.
3. December 17, 2010 Federal Register (75 FR 79048), "Notice of Availability of the Models for Plant-Specific Adoption of Technical Specifications Task Force Traveler TSTF-514, Revision 3, 'Revise BWR Operability Requirements and Actions for RCS Leakage Instrumentation.'"
4. Perry Nuclear Power Plant Updated Safety Analysis Report (USAR),

Section 5.2.5, "Detection of Leakage Through Reactor Coolant Pressure Boundary."

5. NUREG-0887, "Safety Evaluation Report related to the operation of the Perry Nuclear Power Plant, Units 1 and 2," Supplement No.7, dated November 1985, Section 5.2.6.
6. NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR Edition," Section 5.2.5, "Reactor Coolant Pressure Boundary Leakage Detection."

8.0 ATTACHMENTS

1. Markup Pages of Existing Perry Nuclear Power Plant Technical Specifications to Show the Proposed Changes
2. Markup Pages of Existing Perry Nuclear Power Plant Technical Specification Bases to Show the Proposed Changes (For Information Only)
3. Revised (Clean) Perry Nuclear Power Plant Technical Specification Pages Markup Pages of Existing Perry Nuclear Power Plant Technical Specifications to Show the Proposed Changes (Four Pages Follow)

RCS Leakage Detection Instrumentation 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Leakage Detection Instrumentation LCO 3.4.7 The following RCS leakage detection instrumentation shall be OPERABLE:

a.
b.
c.

Drywell floor drain sump monitoring system; One channel of either drywell atmospheric particulate monitoring system or drywell atmospheric gaseous monitoring system; and Upper drywell air cooler condensate flow rate monitoring system. APPLICABILITY:. MODES 1, 2, and 3. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Drywell floor drain A.1 Restore drywell floor 30 days sump monitoring system drain sump monitoring inoperable. system to OPERABLE status. B. Required drywell B.1 Analyze grab samples Once per atmospheric monitoring of drywell 24 hours system inoperable. atmosphere. (continued) CC!)/v T If: X:/, PERRY - UN IT 1 3.4-16 Amendment No.131

ACTIONS (continued) CONDITION C. Upper drywell air cooler condensate flow rate monitoring system inoperable. r . Cn ~ Required drywell atmospheric monitoring system inoperable. AND Upper drywell air cooler condensate flow rate monitoring system inoperable.

y. Required Action and associated Completion Time of Condition A, f*

B, C 'A or.~ not met. D l2 Y. All required leakage detection systems inoperable. PERRY - UNIT 1 RCS Leakage Detection Instrumentation 3.4.7 REQUIRED ACTION COMPLETION TIME

NOTE-------------

Not applicable when the required drywell atmospheric monitoring system is inoperable. C.1 Perform SR* 3.4.7.1. Once per 8 hours C. )3'.1 Restore required 30 days drywell atmospheric monitoring system to OPERABLE status. OR )1':2 Restore upper drywell 30 days ('" air cooler condensate

t.

flow rate monitoring system to OPERABLE status. r .f-.1 Be in MODE 3. 12 hours AND t:2 Be in MODE 4. 36 hours f-11 Enter LCO 3.0.3. Immediately G-3.4-17 Amendment NO'131

INSERT#1 CONDITION REQUIRED ACTION COMPLETION TIME D.1 Analyze grab samples of Once per 12 hours - NOTE-the drywell atmosphere. Only applicable when the drywell atmospheric gaseous AND monitoring system is the only OPERABLE monitor. D.2 Monitor RCS LEAKAGE by Once per 12 hours administrative means. AND O. Orywell floor drain sump monitoring system 0.3.1 Restore drywell floor drain 7 days inoperable. sump monitoring system to ANO OPERABLE status. OR Upper drywel/ air cooler condensate flow rate 0.3.2 Restore upper drywell air 7 days monitoring system cooler condensate flow inoperable. rate monitoring system to OPERABLE status.

RCS Leakage Detection Instrumentation 3.4.7 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.4.7.1 Perform CHANNEL CHECK of required drywell atmospheric monitoring system. FREQUENCY 12 hours SR 3.4.7.2 Perform CHANNEL FUNCTIONAL TEST of required 31 days leakage detection instrumentation. SR 3.4.7.3 Perform CHANNEL CALIBRATION of required leakage detection instrumentation. (--- COP I tt:X / I PERRY - UNIT 1 3.4-18 24 months Amendment No. 115 Markup Pages of Existing Perry Nuclear Power Plant Technical Specification Bases to Show the Proposed Changes (For Information Only) (Ten Pages Follow)

RCS Leakage Detection Instrumentation B 3.4.7 B 3..4 REACTOR COOLANT SYSTEM (RCS) B 3.4.7 RCS Leakage Detection Instrumentation BASES BACKGROUND GOC 30 of 10 CFR 50, Appendix A (Ref. I), requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45nCRef. 2) describes acceptable methods for D.(",,' *o;} 0 ~ leakage detection systems. I IC-t:. v J~ i-I PERRY - UNIT 1 Limits on LEAKAGE from the reactor coolant pressure boundary (RCPB) are required so that appropriate action can be taken before the integrity of the RePB is impaired (Ref. 2). Leakage detection systems for the RCS are provided to alert the operators when leakage rates above normal background levels are detected and also to supply quantitative measurement of rates.1' The Bases for LCD 3.4.5, "RCS Operational LEAKAG I~discuss the limits on RCS LEAKAGE Systems for separating the LEAKAGE of an identified source from an unidentified source are necessary to provide prompt and quantitative information to the operators to permit them to take immediate corrective action. LEAKAGE from the RCPB inside the drywell ;s detected by at. least one of three independently monitored variables, such as sump level changes and drywell particulate and gaseous radioactivity levels. The primary means of quantifying LEAKAGE in the drywell is the drywell floor drain sump monitoring system. The drywell floor drain sump monitoring system monitors the LEAKAGE collected in the drywell floor drain sump. This unidentified LEAKAGE consists of LEAKAGE from control rod drives, valve flanges or packings, floor drains, the Nuclear Closed Cooling Water System, and drywell air cooling unit condensate drains, and any LEAKAGE not collected in the drywell equipment drain sump. (continued) B 3.4-33 Revision No. 1

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.

BASES BACKGROUND (continued) PERRY - UNIT 1 Res Leakage Detection Instrumentation B 3.4.7 The drywell floor drain sump level monitoring system contains sump level instrumentation. The drywell floor drain sump level monitoring system provides two separate indications of LEAKAGE to the control room. First the level instrumentation provides input into a differentiation circuit that indicates the rate of change of the drywell floor drain sump level. This leakage rate is displayed in the control room. An alarm is provided if the leakage rate exceeds a preset limit. In addition, sump level is indicated in the control room. This sump can also be used to determine leak rates by determining how much the sump level has changed over any specific period of time, and thus establishing the leak rate associated with the level change. Either of these two automatic methods of quantifying leak rates are acceptable for determining the unidentified LEAKAGE in accordance with the requirements of LCD 3.4.5. and thus if either of these two automatic methods are available, the drywell floor drain sump monitoring system can be considered OPERABLE. If the drywell floor drain sump monitoring system is inoperable, manual methods may be utilized. Such manual methods may be necessary when sump level switches are out-of-service such that operator actions are necessary to determine in leakage (manually starting or stopping the sump pump, or manually timing its operating time). To employ such manual methods. the pumping rate of the pump must have been determined within the last fuel cycle (i.e., approximately 24 months). The drywell atmospheric monitoring systems continuously monitor the drywell atmosphere for airborne particulate and gaseous radioactivity. A sudden increase of radioactivity, which may be attributed to RePB steam or reactor water LEAKAGE. is annunciated in the control room.....:r-fl8 drj"II@1J_

  • -a-t~~-ulate aoo gaseous radioaGtivity-meA:j.to~

.system£ ere not capabl c of~uanti fyi A§-i-eak-a§c pates, el:it- ~re sensitive enough to indicate ~~alitative iRcreases in _ --LEAKAGE rates, o!9-the order of 3 gpm 'wi th-=ii1--+-oottP-: (continued) B 3.4-34 Revision NO.3

BASES BACKGROUND (continued) APPLICABLE SAFETY ANALYSES RCS Leakage Detection Instrumentation B 3.4.7 L~rger changes in LEAKAGE ra~1 e detected itr- --¥~~-e-r-t-:i-mes-{-Ref. 3j-,. Condensate from the two upper drywell air coolers is routed to the drywell floor drain sump and is monitored by a flow transmitter that provides indications and alarms in the control room. This upper drywell air cooler condensate flow rate monitoring system serves as an added qualitative indicator. but not quantifier. of RCS unidentified LEAKAGE. A threat of significant compromise to the RCPB exists if the barrier contains a crack that is large enough to propagate rapidly. LEAKAGE rate limits are set low enough to detect '7 the LEAKAGE emitted from a single crack in the RCPB (Refs. ~ ~? f' aru;j,,'5.). ~Ea5h ?f the 1-ea~Eage detec~i~n syst-ems in~ide the L ~,--r,ctfyv.'ell ~5 ees=i-!'med w~-l4ty-fTf-BetectHlg-bE-AKA{i£ ~ess than the cstablislled LEAKAGE I ate lifflitg-;--f~t-ems -either provide appropriate alarJII of excess LEAKAGE in the LCD PERRY - UNIT 1 . control room-;-e-r tlley a t'e f1f0fl iLOi ed at-approprtate-int-e'rv-a+s-

    • to ; clentify excess LEAKAGf-,.-..

Identification of the LEAKAGE allows the operators to evaluate the significance of the indicated LEAKAGE and, if necessary. shut down the reactor for further investigation and corrective action. The allowed LEAKAGE rates are well ~' below the rates predicted for critical crack sizes (Ref. tV:- Therefore. these actions provide adequate response before a significant break in the RCPB can occur. RCS 1 e'akage detect ion i nstrumentati on sat i sfi es Crileri on 1 of the NRC Final Policy Statement on Technical Specification Improvements (58 FR 39132). - The drY',rell floar drei n sump ffiooitori ng syst~~ 65 ~e1~~re4-to qUent:i-f-Y ths unidentified LEAKAGf--frtlffl ttr R. s-;- for the system to be com; i dered OPERABLE. one -ef the t'A'O_ . illitomat;c methods of determ=i-ntng floo~p in lea.j@.g@- -must be -8PERABLE. The other mon4Wr-=i ng Sj'stCfflS provi de -wrly alarms t~;~h~ l~e~~L~~~ :t C~~t~~' +~~III~g~~-efl-B~~ ..,detscti on syst \\ ie ~ dd~; IIItne the~elit e:f-,- -arty cerr-ect; ve acti on that may be I"equi Fd. k/it~~~e 1 eakage detecti on :5j3tcffl3 i I'lOperabl e. II/Of I I tor' i 119 FUI LEAKAGE ~n the REPB is degraded. ¢---- (continued) B 3.4-35 Revision NO.7

INSERT #2 This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confidence that small amounts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation. The LCO requires three instruments to be OPERABLE. The drywell floor drain sump monitoring system is required to quantify the unidentified LEAKAGE rate from the RCS. Thus, for the system to be considered OPERABLE, either the flow monitoring or the sump level monitoring portion of the system must be OPERABLE and capable of determining the leakage rate. The identification of an increase in unidentified LEAKAGE will be delayed by the time required for the unidentified LEAKAGE to travel to the drywell floor drain 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 drywell sump monitor OPERABILITY. The reactor coolant contains radioactivity that, when released to the drywell, can be detected by the gaseous or particulate drywell atmospheric 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 drywell atmospheric radioactivity monitors to detect a 1 gpm increase within 1 hour during normal operation. However, the gaseous or particulate drywell atmospheric radioactivity monitor is OPERABLE when it is capable of detecting activity equivalent to that assumed in the design calculations for the monitors (Reference 6). An increase in humidity of the drywell atmosphere could indicate the release of water vapor to the drywell. Upper drywell air cooler condensate flow rate is instrumented to detect when there is an increase above the normal value by 1 gpm. The time required to detect a 1 gpm increase above the normal value varies based on environmental and system conditions and may take longer than 1 hour. This sensitivity is acceptable for upper drywell air cooler condensate flow rate monitor OPERABILITY. The LCO is satisfied when monitors of diverse measurement means are available. Thus, the drywell floor drain sump monitoring system, in combination with a gaseous or particulate drywell atmospheric radioactivity monitor, and an upper drywell air cooler condensate flow rate monitoring system, provides an acceptable minimum.

Res Leakage Detection Instrumentation B 3.4.7 BASES (continued) APPLICABILITY ACTIONS In MODES 1. 2. and 3. leakage detection systems are required to be OPERABLE to support LCO 3.4.5. This Applicability is consistent with that for LCO 3.4.5. A.1 With the drywell floor drain sump monitoring system inoperable. manual methods of determining the sump in leakage rate can provide the equivalent information to quantify leakage. In addition. the drywell atmospheric particulate or atmospheric gaseous monitor and the upper drywell air cooler condensate flow rate monitor will provide indications of changes in leakage. With the drywell floor drain sump monitoring system inoperable. but with Res unidentified and total LEAKAGE being determined every 12 hours (SR 3.4.5.1) using alternate methods such as the pump timer. operation may continue for 30 days. The 30 day Completion Time of Required Action A.1 is acceptable. based on operating experience. considering the multiple forms of leakage detection that are still operable. B.1 With* both particulate and gaseous drywell atmospheric monitoring channels inoperable. grab samples of the drywell atmosphere shall be taken and analyzed to provide periodic leakage information. Provided a sample is obtained and analyzed every 24 hours. the plant may continue operation since at least one other form of drywell leakage detection (i.e.. upper drywell air cooler condensate flow rate monitoring system) is available. The 24 hour interval provides* periodic information that is adequate to detect LEAKAGE. (continued) N D Cl-If'tjJcs6S

  • -rO Jri,' ~ f'ft:;ti przol!ip!5D foIL (ojJT;;J v JI1f PERRY - UNIT 1 B 3.4-36 Revision NO.5

BASES ACTIONS (continued) PERRY - UNIT 1 C.1 46 %4ffiSiiiittffl&'fWiMrifflii4lW$2¥1 RCS Leakage Detection Instrumentation B 3.4.7 With the required upper drywell air cooler condensate flow rate monitoring system inoperable, SR 3.4.7.1 is performed every 8 hours to provide periodic information of activity in the drywell at a more frequent interval than the routine Frequency of SR 3.4.7.1. The 8 hour interval provides periodic information that is adequate to detect LEAKAGE and recognizes that other forms of leakage detection are available. However, this Required Action is modified by a Note that allows this action ~o be not applicable if the required drywell atmospheric monitoring system is inoperable. Consistent with SR 3.0.1, Surveillances are not required to be performed on inoperable equipment. 4R~etR~~WU4~~~~BAC 'HlQPj.tor-:i+lQ--Gfl.er-lB-l-£ and U!-YfJfl~r_ =eei-e-r- ~ens~te flow rate monitoring system-+Ae~er~l~

  • means of detecting LEAKAGE is tR~~~OI dl ain sum~

men i tori ng system Th is Coodi ti en-G~Ifi-de---t-he- -eeQl,Ji re? dive rse mea!IS~-w-k-a§H~-eet-;-on-. -fhC:'~"Reqttj-ree -ActlOQ 15 to restore eltRer of tile lnoperable momtoring ~s to OPERABLE status wtt-h-tn-3fr--d-ay-s-t-trf'e§~ intended 1 eakage deteGt4en di vel'S i Ly. TI Ie 30 day--Gempl eti on. Ti me en3UI es that the-pl ant wil--l--!wt4e--eperet-el--=i-fl-e_

    • Elegraded confi gurati-en for a 1 ength:Y--t4me-f3~

K.. I~~on;} 1f..3 (continued) B 3.4-37 Revision NO.5

INSERT #3 With the drywell floor drain sump monitoring system and the upper drywell air cooler condensate flow rate monitoring system inoperable, the only means of detecting LEAKAGE is the drywell atmospheric radiation monitor. A Note clarifies the applicability of the Condition. The drywell atmospheric gaseous radiation 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 drywell atmosphere must be taken and analyzed and monitoring of RCS leakage by administrative means must be performed every 12 hours to provide alternate periodic information. Administrative means of monitoring RCS leakage include monitoring and trending parameters that may indicate an increase in RCS leakage. There are diverse alternative mechanisms from which appropriate indicators may be selected based on plant conditions. It is not necessary to utilize all of these methods, but a method or methods should be selected considering the current plant conditions and historical or expected sources of unidentified leakage. The administrative methods are monitoring drywell pressure and temperature, and manual timing of the drywell floor drain sump pumpout. These indications, coupled with the atmospheric grab samples, are sufficient to alert the operating staff to an unexpected increase in unidentified LEAKAGE. The 12 hour 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.. E. 1. and E.2 With both the particulate and gaseous drywell atmospheric monitoring channels and the upper drywell air cooler condensate flow rate monitoring system inoperable, the only means of detecting LEAKAGE is the drywell floor drain sump monitoring system. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable monitoring systems to OPERABLE status within 30 days to regain the intended leakage detection diversity. The 30 day Completion Time ensures that the plant will not be operated in a degraded configuration for a lengthy time period.

BASES ACTIONS (continued) RCS Leakage Detection Instrumentation B 3.4.7 r r ( it 1 and)?,. 2 QIZ.. C If any Required Action of Condition A. B. C. ~ D~annot be met within the associated Completion Time. the plant must be brought to a MODE in which the LCO does not apply. To achieve this status. the plant must be brought to at least MODE 3 within 12 hours and to MODE 4 within 36 hours. The allowed Completion Times are reasonable. based on operating experience. to reach the required plant conditions in an orderly manner and without challenging plant systems. G- ~1 SURVEILLANCE REQUIREMENTS PERRY - UN IT 1 With all required leakage detection systems inoperable. no required automatic means of monitoring LEAKAGE are available. and immediate plant shutdown in accordance with LCD 3.0.3 is required. SR 3.4.7.1 This SR requires the performance of a CHANNEL CHECK of the required drywell atmospheric monitoring system. The check gives reasonable confidence that the channel is operating properly. The Frequency of 12 hours is based on instrument reliability and is reasonable for detecting off normal conditions. SR 3.4.7.2 This SR requires the performance of a CHANNEL FUNCTIONAL TEST of the required RCS leakage detection instrumentation. The test ensures that the monitors can perform their function in the desired manner. The test also verifies the relative accuracy of the instrumentation. The Frequency of 31 days considers instrument reliability. and operating experience has shown it proper for detecting degradation. (continued) B 3.4-38 Revision No. 1

BASES SURVEILLANCE REQUIREMENTS (continued) REFERENCES PERRY - UNIT 1 Res leakage cection Instrumentation B 3.4.7 SR 3.4.7.3 This SR requires the performance of a CHANNEL CALIBRATION of the required ReS leakage detection instrumentation channels. The calibration verifies the accuracy of the instrumentation. including the instruments located inside the drywell. The 24 month Frequency is based on operating eXRerience. and is consistent with a typical industry refueling cycle.

1.

10 CFR 50, Appendix A, GDC 30.

2.

Regulatory GUide 1.45, May 1973. -&--. -+UJ.l<SAAtR~, -'Swe~ctHi1"11onR-'-r5-7. 2L-. '!"-S.-7'2'-. - 3 Y. GEAP-5620, "Failure Behavior in ASTM AI06B Pipes Containing Axial Through-Wall Flaws," April 1968. . I;f. NUREG-75/067, "Investigation and Evaluation of J Cracking in Austenitic Stainless Steel Piping of Boiling Water Reactor Plants," O~tober 1975. USAR, Section 5.2.5.5.3. B 3.4-39 Revision No.3 Revised (Clean) Perry Nuclear Power Plant Technical Specification Pages (Two Pages Follow)

ACTIONS (continued) CONDITION C. Upper drywell air cooler condensate flow rate monitoring system inoperable.

NOTE--------

Only applicable when the drywell atmospheric gaseous monitoring system is the only OPERABLE monitor. D. Drywell floor drain sump monitoring system inoperable. AND Upper drywell air cooler condensate flow rate monitoring system inoperable. PERRY - UNIT 1 RCS Leakage Detection Instrumentation 3.4.7 REQUIRED ACTION

NOTE----------

Not applicable when the required drywell atmospheric monitoring system is inoperable. C.1 Perform SR 3.4.7.1. D.1 Analyze grab samples of the drywell atmosphere. AND D.2 Monitor RCS leaka~e by adminJ.strative means. AND D.3.1 Restore drywell floor drain sump monitoring system to OPERABLE status. OR D.3.2 Restore uJ?per drywell aJ.r cooler condensate flow rate monitoring system to OPERABLE status. 3.4-17 COMPLETION TIME Once per 8 hours Once per hours 12 Once per hours 12 7 days 7 days Amendment No.

ACTIONS (continued) CONDITION E.Required drywell E.1 atmospheric monitoring system inoperable. AND OR Upper drywell air cooler condensate E.2 flow rate monitoring system inoperable. F. Required Action F.1 and associated Completion Time of AND Condition A, B, C, D or E not met. F.2 G. All required G.1 leakage detection systems inoperable PERRY - UNIT 1 RCS Leakage Detection Instrumentation 3.4.7 COMPLETION REQUIRED ACTION TIME Restore required 30 days drywell atmospheric monitoring system to OPERABLE status. Restore upper 30 days drywell air cooler condensate flow rate monitoring system to OPERABLE status. Be in MODE 3. 12 hours Be in MODE 4. 36 hours Enter LCO 3.0.3. Immediately 3.4-17a Amendment No.}}

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