Text

License Amendment Request (LAR)19-001, Application to Adopt TSTF-513-A, Revision 3, PWR Operability Requirements and Actions for RCS Leakage Instrumentation
	ML19325C593
Person / Time
Site:	Comanche Peak
Issue date:	11/07/2019
From:	Thomas McCool; Luminant, TXU Energy, Vistra Energy
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CP-201900393, TXX-19067
	Download: ML19325C593 (62)
	v • d • e

CP-201900393 TXX-19067 U.S. Nuclear Regulatory Comm1ss1on ATIN: Document Control Desk Washington, DC 20555-0001 11/07/2019

SUBJECT:

COMANCHE PEAK NUCLEAR POWER PLANT DOCKET NOS. 50-445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR)19-001 rhomas P. McCool Site Vice President Luminant P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 o 254.897.6042 Ref 10 CFR 50.90 10 CFR 50.91(b)

APPLICATION TO ADOPTTSTF-513-A, REVISION 3, "PWR OPERABILITY.REQUIREMENTS AND ACTIONS FOR RCS LEAKAGE INSTRUMENTATION"

Dear Sir or Madam:

Pursuant to 10CFR50.90, Vistra Operations Company LLC (Vistra OpCo) hereby reque*sts an amendment to the Comanche Peak Nuclear Power Plant (CPNPP) Unit 1 Operating License (NPF-87) and CPNPP Unit 2 Operating License (NPF-89) by incorporating the attached change into the CPNPP Units 1 and 2 Technical Spec1f1cat1ons.

This change request applies to both units.

V1stra OpCo requests adoption ofTSTF-513-A, Revision 3, "PWR Operability Requirements and Actions for RCS_

Leakage Instrumentation." TSTF-513-A, Revision 3 revises Technical Specification 3.4.15, "RCS Leakage Detection Instrumentation," to add a new Condition. New Condition D (Condition C In NUREG-1430) 1s applicable when the containment atmosp_here gaseous radioact1v1ty monitor 1s the only Operable monitor (1.e., all other monitors are inoperable). The Required Actions require analyzing grab samples of the containment atmosphere every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restoring another monitor w1th1n 7 days The subsequent Conditions are renumbered to reflect in addition of the new Cond1t1on. provides a description and assessment of the proposed_changes. provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages.

Approval of the proposed amendment 1s requested w1th1n one year of the NRC acceptance date. Once approved, the amendment shall be implemented within 60 days.

TXX-19067 Page 2 of 2 In accordance with 10CFRS0.91(b), V1stra OpCo 1s providing the State of Texas with a copy of this proposed amendment This communication contains no new commitments regarding CPNPP Units 1 and 2.

Should you have any questions, please contact Garry Struble at (254) 897-6628 or garry.struble@luminant.com.

"I state under penalty of perjury that the foregoing 1s true and correct.

Executed on 11/07/2019 Attachments.

DESCRIPTION AND ASSESSMENT Sincerely, 7,,

Thomis'"P. McCool

1.

2.

3.

PROPOSED TECHNICAL SPECIFICATION' CHANGES (MARK-UP)

REVISED TECHNICAL SPECIFICATION CHANGES c -

Scott-Moms, Region IV Dennis Galvin, NRR Resident Inspectors, Comanche Peak Mr. Robert Free Environmental Monitoring & Emergency Response Manager Texas Department of State-Health Services

- Mall Code 1986 P. 0. Box 149347 Austin TX, 78714-9347 CPNPP LAR 19--001 Page 1 of 21 to TXX-19067 LAR 19-001 Comanche Peak Technical Specifications, LCO 3.4.15, RCS Leakage Detection Instrumentation DESCRIPTION AND ASSESSMENT CPNPP LAR 19--00,1 Page 2 of 21 T

LAR 19-001, LCO 3.4.1 fr, RCS Leakage Detection Instrumentation Table of Contents 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design ah_d Operation 2.2 Curr:ent'TeGhalcal Specification-Require!Jlents 2.3

..Reason for Pr9po?ed Change 2.4 De~cription of Proposed Change

3.0 TECHNICAL EVALUATION

~.O REGUlATORY EVALUATION 4.1

. -Applicat!le Regulatory ~~quiternents 4.2

-Precedent 4.3'

No Significant Hazards Consideration Determination

4)i Conclusions s.o-ENVIRONMENTAL CONSIDERATIONS 6.0 Rl:FERENCES C

CPNPP LAR-19--001 Page 3 of21 1.0

SUMMARY

DESCRIPTION Proposed change LAR 19-001 is to revise Technical Specifications 3.4.15, RCS.

Leakage Detection Instrumentation for Comanche Peak Nuclear Power Plant (CPNPP) Uriits: 1 and 2.

Vfstra OpCo is requesting this change to align.the CPNPP Technical Specifications (TS) with the Standard Technical Specification.s (S.TS) for**

Westirighou*se Plants and to incorporate the changes made by TSTF-513-A, Revision 3.. Revising CPNPP Technical Sp_ecification, LCO 3.4.15, RCS Leakage Detection Instrumentation and associated Bases will clarify OPERABILITY requirements and allow a limited time to repair one _or more* of the.

inoperable monitors.',.

No changes to the Comanche Peak Nuclear Power Plant Final Safety Analysis Report are anticipated ~s a result of this License* Amendment Reque¢t.

2.0 : DETAILED DESCRIPTION RCS Leakage-Detection lnstf!Jmentation uses diverse monftors to_ assist the..

operators in timely ~etermination of unidentifie~ leakage. Curreptly CPNPP TS list the following, monitors;

One. Containr:ne.nt ~ump L~vel and Flow.Monitoring System; One containment atmosphere *particulate radioactivity_ monitor; -and One,.containn:ient air cooler flow rate monitor qr one containment. -

~tmosphere radioactivity monitor (gaseous).

The Westinghouse srs*and TSTF-5.13-A, Rev!sion 3 lis_t the following monitors;

_ One co.ntainrnentJ;ump (level or dis_9harge *flow) mon~pr,"

One containr,:tent atmospnere radioactivity monitqr (gaseous or particulate),_.and One containment air cooler cond.ensate flow rate monitor.

Current. CPNPP Technical Specifications do not align with Westinghouse STS or TSTF-513-A, Revision 3.

Specification 3.4.15*; RCS Leakage Detection Instrumentation, requires instrumentation to detect sign~cant reactor coolant pressµre boundary (RCPB),

degradation* as soon after occurrence as practical to minimize the potential tor:

propagation to a gross failure. The Improved Standard Techriical Specifications (ISTS) require ohe contai'nment sump monitor,(for Westinghouse plants, level or.

discharge flow), one containment' atmo.sphere radioactivity monitor (gaseous or particulate), and for Westinghouse plants; one containment air cooler condensate flow rate monitor.

CPNPP LAR 19--001 Page 4 of 21 Questi_ons have been raised regarding the Operability requirements for these instruments.

~n particular, improvements in plant fuel integrity have resulted i11 a

. reduction of the Re~ctor Coolant System (RCS) activity. As a result, the containment atmosphere radioactivity monitors may not be capable of promptly

det~cJing an_ increase in RCS leakage.

Tlie proposed change revi~s the Bases to clearly define the RCS leakage.

detection *instrumentation OPE~BIUTY requirements* and to modify the*Actior,s to be -taken when the containment atmosphere gaseous radioactivity monitor is t~e only OPERABLE monitor to 'require add_i_tional, more frequent monitoring of other indications *of RCS leakage and to shorten the time allo~ed to restore another monitor to OPERABLI; l:itatus.

. 2.1 Sys~erry Design and o.peration

. The leal<age-detection sys_t~ms are*intentled*to sehsEfleakage)rom the

-reactor* coolant and aw_xiliary system~ into ttie _Co!1tairiment and to provide the means to locate s_uch leakage. -

The safety signi~cance* of leaks ~hrough the reactor coolant pressure*

boundary- (RCPB) can vary widely depending on the source of the leak as well as the leakage rate ancf duration. Therefore, the detectio11 and

, monitoring of reactor coolant leakage into the* Containment is.necessary.

~

The* leakage-detection systems-provide _information which permits the -

plant operate~ to take* immediate corrective action_ ~h.ould a leak be evalua~ed as detrimental to the s_afefy of the plant_.

Leakage-detection.

system design objective~ ar~ in accordi;lnce with the requirements of 10

_GFR Part 50, GDC.30, and NRC Re~ulatory Guide 1.45, Revision b.

RCPB leak~ge is classified as identified 9r unidE;mtified and m*ethods for physically* se*parating the leakage into these classifications are provided to supply prompt anc;f quantitative informatiqn about tl)e leakage to the plant operators. Identified leakage is reactor coc;>_lant leakage into the containment area (i.e.. into a closed system or containment atmosphere) that is specifically h;>cated, can-be detected, collected ~nd to th~ extent practical,' isolated*fromthe**containment atmosphere so as not fo mask any

- pote_ntially $.erious lea!< should it occur.

ldenti_fied_, leak~ge. is comprised of:

Leakage, from r:eactor head flange leak-offs* and valve packing leak-offs, that i$ captured and conducted.to the reactor coolant drain tank (Reon. - All reactor coolant pressure boundary vatves

-- that use ttie compressed packing method of sealing the working fluid a_r,e equipped with piped leak;-Off connections and the potential leaks* are classified as identified.

Since the leakage detection system is-closed, it *is essentially isolated from the C0.nti1inment :

atmosphere and cannot mask any potentially serious leakage to the atmosphere *from unidentified squrces including a flaw in the RCPB. _.

'I CPNPP l.AR 001 Page 5 of21 _.

Reactor coolant leakage through stear)1 generators to the secondary system.

Leakage through the closed pressurizer safety and. relief va_lves.

leakage of the seal water through the reactor coolant pumps seal number 2 directed to.the Reactor Coolant Drain Tank (reactor coolant pump seal leak-off number 2).

Leakage of the seal water through the reaq:or coolant pumps seal number 3 directed to the-Containment Sump (reactor coolant pump seal leak-off number 3).

Leakage of the reactor coolant to U,e Component Cooling Water System (CCW) resulting from leakage from the Reactor Coolant Pumps. Jh.ermal barrier.

lntersystem leqkage -through Reactor Coolant System Pressure Isolation Valves.

All ic_lentlfied leakage_ (except primary-to-secondary leakage, intersystem leakage, RC pump*seal No.. 3 leakage and closed pressurizer safety and*

relief valves leakagef is coJlected in Reactor Coolant _Drain rank.

Un[dentified leakage is all leakage which*is not ic_lentified leakage or controlled leakage..It is im-practical to completely eliminate unidentified

leakage, but efforts are made to-requce tt,is.lea_kage to a small background. flow-rate.permitting. the leakage detection systems* to detect positively. and rapidly any small increase in unidentified leakage floY" rate.-

_ Controlled leakage is the seal water flow supplied to the reactor coolant pump seal nu_mber 1 (appro~im.ately 8-gpm per pump).

Leakage *through the RCPB is limited to the following:

Identified leakage; -

150 gpd through any one steam g~nerator 10 gpm total leakage

Unidentified leakage 1 gpm Unid.entified ~eakage Detection Methods*

Prfmary detection of unidentified leakage to the Containment atmosphere

is provided by air particulate monitors, containment sump flow monitors and coridensate*flow rate measuring system. In addition, containment*

dewpoint; indication of gross leakage and liquid iriventory.~nd radioactive CPNPP LAR 19-001 Page 6 of21 gas monitor are other indications available to the operator for determination of unidentified leakage.

In normal operation, the primary monitors show a background level which is indicative of the normal magnitude of unidentified leakage inside the Containment. Variations in airborne reactor coolant _corrosion products or condensate flow rate above the normal level signifies an increase in unidentified leakage rates and signals to the plant operators that corrective action may be required. Similarly, increases in Containment

sump flow and radioactive gaseous concentration in the containment atmosphere signifies an increase in unidentified leakage.

Unidentified Leakage Monitors Containment Air Particulate Monitor Air particulate monitors take continuous air samples from the containment atmosphere and measure the particulate activity collected on a filter paper system. After passing through an iodine and noble gas monitor downstream of the particulate monitor, the air returns to the Containment. The sensitivity of the Containment air particulate monitor to an increase in 'reactor coolant le*ak rate is dependent upon the magnitude of the normal baseline leakage into the Containment. Sensitivity is greatest where baseline leakage is lowest.

Radioactive Gas Monitor The radioactive gas monitor indicates the presence of containment gaseous activity originating from fuel-cladding defects. It measures the gaseous beta radioactivity by continuously sampling the containment atmosphere. The radioactive gas monitor is less sensitive to an increase in reactor coolant leak rate than the containment particulate monitor.

Containment Sump Flow Monitoring After collection in Gontainment sump 1, containment sump 2, cir the reactor cavity sump, leakage is pumped via a common header to floor drain tank 1 or to the waste hold-up tank. In-this common discharge J,eader is a flow totalizer/indicator that measures flow -

and facilitates the recording of this total flow in the control room.

The sumps also have several-other features as follows:

Any one of the 6 pumps in these 3 sumps starting causes the "ANY CONT SUMP PUMP RUN" audible/visual alarm to actuate in the control room.

CPNPP LAR. 19--001 Page 7 of21

Each of the 3 sumps has a separate high level audible/visual alarm in the control room.

Sumps 1 and 2 have an additional level switch arranged with a time delay and the appropriate logic so that an increase by 1 gpm or greater flow. into the sump will actuate a "CONT SUMP FILL RATE INCREASE" audible/visual alartn in the control room.

The sump discharge line may be sampled froni outside of the Containment to provide additional aid in identifying the leakage source.

Sp~cific Humidity Monitors SpecifiG humidity monitors are sensitive to vapor originating from the reactor coola'nt; steam, feedwater, and auxiliary systems in the Containment.. Therefore, these monitors provide a. means of detecting unidentified leakage from both radio~ctive and.

non-radioactive sources. Humidity detecti0n is accomplished.

either by measuring the condensate from the Conta1nni'ent air cooli~g coils or, by monitoring th~ dewpoint temperature in the

. Containment.

Condensate Flow *Rate M~asurem~nt Humidity detection* is accomplished by measuring* the condensate flow rate from the Containment cooling coils.

The.containment specific humidity increases proportionately

with time and leakage until the dewpoint is reached at the Containment.recirculation unit cooling coils. If the specific

hurnidity increases above this point; the heafremoval:

needed to co9I the air-steam mixture to its dewpoint

temperature>i'ncreases above this point. :

Therefore, since the cooling coils are designed to. remove heat at a constant r~te; an increase i_n specific humidify results in intjreased condens~te flow:- _The condensate measuring system consists* of a vertical standpipe with an internal self-siphoning device which.empties'the condensate

in the standpipe to the sump when the standpipe is nearly full. The condensate measuring system permits

measurement of the condensate fl0w rate from each.-

I

- Containment recirculation unit by means. of a derivative unit which measures the rate of ~hange in tt:ie standpipe level.

Should the leakage inside the Containment increase, the condensate flow also increases, thereby increasing th'e rate of change of.the standpipe level. The rate of level change in the standpipe is continuously recorded on strip chart

recorders in the Control Room. An alarm for high rate of CPNPP LAR 19--001 Page 8 of 21 level change is provided to warn Control Room personnel of an increase in the condensate flow rate.* An alarm is also

_provided if condensate flow is greater than the amount of flow that the siphon can discharge to the $ump. Through accu-rate measurements of condensate flow, a reliable estimate _of the total leakage rate to the:Containnient can be made.

Containment Dewpoint Monitors The Containment humidity sensing system consists of dewpoint sel')sors, signal conditioning units, cabling,*

indicators, and plant process computer inputs, all pack~ged in a system cap~ble of the continuous, unatte*nded,

- automatic operation for remote monitoring of the dewpoint of the Conta\\nment atmosphere. _ *Dewpoint senso*rs are *.

strategically located in five representative areas of th~ -

-Containment and are capable of detecting and reading out a change of 1 °F in:dewpoint. the signal conditioning units prov_ide a linear output signal for transmission Jo a Contr0I Room board-mounted analog indi~ator.

- Containment Tempe'ratur~ ty'lonitors An increase:in ContainmenHemperature *can indicate a leak of high temperature fluid fro.m the RCPB or other high temperature-systems..

a Containment Pressure Monitors AiJ increase in Containment pressure can indicate a leak of high -

te"!lP.~rature fluid from the RCPB or other ~igh temperature s~sterhs.

Frequency and Duration of C)peration *of the Containment Sump*

Pu*mps Each pump is provided with-a running time indicator which indicates in seconds-the duration of pump operation. This indicator can be used to estimate gross leakage rates and_can act as a backup to the discharge flow_rnonitors.

Gross* Leakage*lndications Decrease in pressurizer level -

_. Increase in the !Cite of supply of reactor coolant makeup water Containment temperature.monitors*

CPNPP LAR 19--001 Page 9 of21 Containment pressure monitors.

Containment sur:np level high alarm_,

Liquid inventory Reactor coolant volume can be indicative of system leakages. Net level ~hanges in the pressurizer.and volurtie control tank ar~

functions of the system leakage because the Chemical Volume Control System is a closed loop system. Abnormal makeup.

requirements can be indicative of system leakage.

Sensitivity of Select Leakage Detection Monitors Containment Air Partfculate M*onitor The Containment ~ir particulate monitor is the most sensitive instrument available for detection of reactor coolant.leakage* into th~ Contain merit. This* instrument is capable of detecting.

particulate activity in* concentrations as low as 5E-11 microcuries.

per cubic centimeter (µCi/cm3) in the Containment air sampled.

Using this concentration, calculations show that the parti~ulate monitor; for a reference nuclide of Cs.-137, can conservatively detect* a 1 *.0-gpm increase in unidentified leakage within the.

Containment in less than one hour after the leak begins. The se*nsitivity of the containment *airborne particul~te and gas monit.ors for detection of 1 gpm primary coolant leakage is dependent of both the primary coolant activity level and the background radiation level

. in containment which vary with Reactor Power..

Conservative analysis indicates that the maximum pr~xisting coritainment backgroµnd levels that will not prevent reliable leak detection by the p~_rticulate _fTlonitor (without sp_urious alarms) will vary with changes *in the primary coolant activity. The relation between fail~d fuel fractjon, primary coolant activity and..

background levels.for any specified condition may be_ derived fror:n

. the general sensitivity equat,ion in ANSI 13.10 an*d the time constants specified for the monitor used in this service. Operating experience has shown the particulate background radiation: levels have remained low :relative to the expected activity increase from*

1-gpm leak. Th~refore, this monitor is expected to detect a 1 gpm leak within one* hour.

Containment Radioactive *Gas Monitor This system is less sensitive than the Containment air particulate monitor but give~ a positive indication of leakage in the event that reactor coolant gaseous activity exists as a result of fuel-cladding defects. One gallon per minute leakage from the primary coolant CPNPP LAR 19-001 Page10of21 pressure boundary in the con_tainment can be detected in less than one hour provided the containment atmosphere activity is below the level that would mask the activity corre$pol)ding to the leakage. If this system *is one of the two required monitors inoperable in MODES 1, 2, 3 and 4 ope_rations may continue up to 30 days

_ provided grab samples of the containment atmosphere are obtained and analyzed at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .*

Analysis also shows-that the maximum pre-existing containment radioactive gaseous background levels for which reliable detection is po?sible will vary directly with the activi.ty levels in the p-rimary coolant. With primary coolant concentrations less than ~quilib~ium levels, su¢h as during startup, the increase in d~tector count rate due to leakage-will be pa.rtially mi:Jsked by the statistical variation of the minimum detectqr background count rate, rendering reliable detection-of a 1 gpm leak uncertain.

Operating experience has shown elevated gaseous background

radiation levels will partially mask t~e detection of a 1 gpm leak. -

H9wever, _the monitor is capable of qualitative_ly detecting an RCS to con.tainment abnosphere leak. :'

In *conclusion, reliable leak detection is possible, provided that the equilibrium activity of the containment atmosphere i$ below the

level that would-mask the change-in activity corresponding to a 1 gpm leak in. one _hou_r.

Givefl the above limitati_ons, the _intent,of the leak detection requirements*of Regulatory Guide 1.45, Revision O is met in the following manner. The n:ionitors are seismically qualified as required in Section C of Regulatory Guide 1.45, Revision O_: The mihimum $ensitivities of the containment air particulate and the radioactive gas monitors are 5E-f1 µCi/ml (re'ference nuclide Cs-137) and 1 E-6 µCi/ml (reference nuclide X~-133),- r~spectively.

These are the minimum detetjable activities when situated in a 2.5 mR/hr, of 1 Mev Garr:ima Background field, which is the normal maximum anticipated at the-_

location of tne monitors: These sensitivities meet or exceed the sensitivities required of these monitors' by Section B of Regulatory Guid_e 1.45, Revision 0.

Condensate Measuring* System

. The measurement of the. cond~nsate flow from containment recirculation u_nit cooling coils giv~s a sensitive indi_cation of increases_in unidentified leakage into the Containment..

c'ondensate flow from ap_.proximately O gprn to 4.0 gpm can ~

measured with this system. In the event of very low reactor coolant activity levels, this system provides the most sensitive_

indication of unidentified lea~age.

CPNPP LAR *19-001 Page 11 of21 -

Dewpoint Temperature Monitors-

- These instruments are sensitive to an increase in dew point of 1 °F or greater.

~ontainment Sump Fill R~te Increased by~ 1 ~PM Alarm All open floor areas a*nd the equipment room floors are slop~d

_ toward floor drains with the drain piping routed to containment sumps 1 or 2. By-design; flow to the sumps is-unimpeded. This ensures that all liquid leakage will be routed to the s-umps~

The contai'nment sumps are equipped with level switches and -an-alarm timer. A sump in leak increase of~ 1. gpn:, will activate the sump-leak detection system by initiating t_he alarm timer whi~h is

. ~et at an interval.which allows dete.cti.on of~ 1 gpm leak increase in less than-one hour:-

Differenti~tion Between lde_ntified and Unidentified Leaks Any increas~s above U1e background level of 1.0 gpm of unidentified leakage and 10 gpm identified* leakage ( other th~n primary-to-secondary

_leakage) are investigated and evaluated by the operator in order to locate the SOL!rces of.l~akage.-..

Examples of techniques which will be employed by the operator in locating the area of leakage are::

Leakage occu*r~ng frqm the reactor vessel head-to vessel closure joint is identifiable by an increase in temperature in the leak-off line

- provided ~t this joint.

Leakage occurring from the main steam supply system, feedwater system, or CCW-is,identifiable by an increase* in *condensate monitor indication withoufassociated--incre~se in background radio*activity. The increased frequency of-sump pump operation is also an ind!cation as_ is the 1 gpm leak increase alarm in the Control

Room.

Leakage occurring from the RCPB is usually identifiable by a-simultaneous inQrease 'in condensate and-radioactivity monitor indication*s.

Dewpoint temperature plant process computer data can assist

. : operators iri locating leakage points because of the various locations of the dew cells in* the Containment.

CPNPP LAR 19-001 Page 12 of 21 Steam generator primary-to-secondary leakage is detected by the Steam Generator Slowdown Process Sample (SGBPS) Monitor, the Steam Generator Leak Rate (SGLRM) Monitors, and the -

Condenser Off-Gas Monitor.

Leakage of the reactor coolant to the CCW is detectable by means of the radiatiofl-monitor in the CCW system.

Leakage of the reactor coola*nt outside* Containment is detectable by plar:tt vent gas monitors and the airborne radioactivity mon.itors*

of the Safeguards Building.

Adequacy of the Leakage Detection*System A normal level of 1 gpm or less in unidentified leakage is :expected. The-leakage detection-systems are ca(pable of detecting leakage as*low as 0,1

.gpm using the.air particulate monitor and as 1ow as 1. gpm usin'g the condensate flow rate and the sump lever alarm. The sensitivity is _

reasonably adeq1,1ate to detect *an increase in unidentified leakage rate.

In addition, the capacity of the reactor coolant makeup system and containment water removal are well above the proposed leakage limits provided in the Technical Spe_cifications.

2.2 Current Technical Specification Requirements The current CPNPP TS requirements are different than those found in NUREG:...1431 Volume 1, Revision 3. The. change accomplishes two things; it aligns the current CPNPP-Lco 3.4'.15, RCS Leakage* Detection Instrumentation with NUREG-_1431 Stapdard Tec;:hnical Specifications for*

Westinghouse Plants and it incorporates TSTF-513-A, -Revision 3,.

Operability Requ_irements and Actions for RC_S Leakage Instrumentation.

There will be no changes to the current_Surveillance Requ_irements;

_The current CPNPP LCO. 3.4.15 is as follows; LCO 3.4.15 The following-RCS leakage detection instrumentat_ion shall be OPERABLE: -

a.

One Containment Sump Level and Flow_

Monitoring System;

b.

_Qne containment atmosphere particulate radioactivity m~mitor; anq

c.

-One containment air.cooler condensate flow rate

. monitor or one containment atmosphere radioactivity monitor (gaseous).

CPNPP LAR 19-001 Page 13 of 21 ihe Stan_dard Technical Specifications for Westinghouse Plan~. NUREG- -

1431,* prior to TSTF-513-A, Revision 3 for' LCO 3.4.15 is as follows; LCO 3.4.15 The foll9~ing RCS leakage detection instrumentation shall be OPERABLE:

a.

One containr,:ient sump (level or discharge flow)

monitor,

b. -

One containment atmosphere radioactivity monitor (gaseous or particulate), and

c.

One containment air cooler condensate flow rate monitor:

The CPNPP current LCO has Actions A ~rough E which are different than

.

Actions A through F found in NUREG-1431,'Volu_me :t, Revisip(l 3. Th~

differences -are largely due to the manne_r in which the CPNPP Tech:nical Specifica_tion LCO 3.4.15 is aligned. When Improved Sta-ndard_ Technical

.. Specifications were implemented at CPNPP the difference from the

NUREG-1_43.1 standard was only described as not adopting the standa-rd due to LCO 3.4.15 prior to implementation of Improved Standard Technical Specifications and due to alignment with R~gulatory Guide 1.45,

. Revision 0, position C.3. Based on TSTF-513-A, Revision_ 3,..the devi~tion from the standard LCO 3.4.15 'is no Jonger valid.

The current Technical ~pecification. proposed to pe changed is Limiting -

Condition for Operation (LCO), 3.4.15, RCS-Leakage* Detection Instrumentation. Following approval of this license amendment CPNPP will be aligned with.other Westinghouse plants regarding LCO 3.4.'15, RCS Leakage Detection Instrumentation.-

- 2.3 Reason for Proposed *ch~nge Th_is,change is requested to implement TSTF-513-A, Revision 3 tq clarify LCO 3.4.15, RCS Leakage Detection* Instrumentation OPERABILITY as

found in the Bases, add a new* Conditio'n when tlie containmen_t -

atmosph~re g~s.eous radioactivity monitor is-the orily OPERABLE monitor, and correct usage of arequired'- with regard to containment air cooler condens~te flow ~te monitor.'

This license amendment requires addressing the difference between CPNPP current LCO 3.4.15 anp the NUREG-1431 LCO 3.4.15 plus the changes_due to TSTF-513-A, Revis.ion 3: The end ggal is to ~ave

- CPNPP LCO 3.4.15 final TS in full alignment with TSTF-513-A, Revision

3. TSTF-5-13-A, Revision 3 groups the instrum~ntation such that level OR flow may.be used to ensure OPERABILITY for the containment sump monitor. - It also groups monitors s_uch that particulate* OR gaseous channels may be used to-ensure OPERABILITY for ttie cor:itainment atmosphere radioactivity monitor. And finally it tias the containment air CPNPP LAR 19-001 Page 14 of 21 cooler condensate flow rat~ monitor as a stand-alone leakage detection monitor.

Wrth changes to the applicabl,e TS Bases it will clarify what is required to determine OPERABILITY for each of the three monitors. This wiil enable

. the operators to clearly determine the status of each monitor and identrfy any applicable actions:

This proposed technical specificatiqn chang~ is acceptable because, it..

implements changes to LCO 3.4.15, RCS Leakage Detection Instrumentation that have been previously approved by the NRC in the

.implementation of *ISTSs and in TSTF-513-A, Revision 3.

2.4 Description o~ Proposed Change

,Specification 3.4.15, "RCS Leakage*Detection Instrumentation," is revised to add a new Condition. New Condition D is applicacle when the containment atmosphere gaseous radioactivity monitor'is the only -

Operable monitor_(i.e., all other monitors are.inoperable). The Required

Action~ require analyzing grab samples of the containment-atmosphere ev~ry 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and restoring another monitor within 7 days. The subsequent Conditiohs are renumbered to reflect in addition of the:new

- _Condition.

The_ Bases are revised to clearly define*the RCS leakage detection

. instrumentation Qperability-requiremerits in.t_he Leo Bases and to*

_ -eliminate discussion from the Bases that could be erroneously-construed as Operability requirements. The Bases are also revised to reflect the

~hanges to tlie Technical Specifications and to more accurately reflect the

_ existing Jechnical Specifications.

Three corrections are made:

In s~veral locations in**a*11 three N.UREGs, the specifications incorrectly refer to a.'.'required" containment sump monitor or* "required" containment ~ir cooler flow rate monitor when the LCO does not prov.ide for mqre th~n one monitor. The _term "required" is _reserved:for situations in which_ there are multiple ways to meet the LCd, suet, as the requirement for either a 'gaseous or particulate radiation monitor.

The inC9rrect L:J$e of the term "required" is removed.

The Note, "Not required until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishment of.steady

. state operation, is currently incorrectly placed on Required Action C.1 (Perform SR 3.4.1-5.-1, Channel Check) instead of Required Action C.2 (Perform SR 3.4.13.1, RCS mass balance) as in the other ISTS.

NUREGs. The Note is moved to'Required Action C.2. The Bases correctly ~tate that the Note applies to performance of SR 3.4.13.1.

In NUREG-1431, the containment air cooler condensate flow rat~

monitor is plant-specific.

CPNPJJ I.AR 19-001 Page 15 of 21

.. The proposed change will align CPNPP ISTS with NUREG-1431, Standard Technical Specification for Westinghouse Plants and TSTF-513-A, Revision 3.

. The proposed change to Technical Specification ~ases for LCO 3.4.15; RCS Leakage Detection Instrumentation is provided "For Information Only."

The retyp_ed pages for;ihe proposed change to Technical Specification, LCO 3.4.15, RCS Leakage De.tection Instrumentation are provided for review.

The retyped,pages forlhe proposed change to Technical.Specification

. Bases, LCO 3.4.15 are provided "For lnform?-tio"n 011ly. ~

3.0 TECHNICAL EVALUATION

This change will reduce the number of unnecessary MODE changes and requests for enforcement disc-retion by_ clarifying the Operability requirements for the RCS leakage detection instrumentation and by allowing a limited time to

.

repair one or more of the inoperable monitors. A plant shut down solely as a result of the loss of the preferreq TS monitoring capability could be avoided*.

The use of alternate leakage detection monitoring for a limited time is an

~ppropri~te response to this* condition.

The propos_ed Bases changes will clarify the Operability requirements of the RCS leakage detectiori instrumentation. Phrases that are not consistent with RG 1.45, Rev: 0, such*as "a high degree of confidence" and "extremely small leaks" are eliminated or replaced witti terminology that accurately describes the design assumptions of the. system. -All reference to RG 1.45 are revised to reference.

Revision O of the RG. lnfomiation in the Background arid Applicable Safety Analysis sections of the 'Base~ th~t could ~e construed as Operability requirements is deleted: The LCO section of the Bases.is expanded to provide:a detailed discussiorfof the Operability.requirements for.each of the required instruments. For the containment abnosphere *radioactivity menifors, the Bases clearly relate Operability to the design assumptions and licensing basis for the plant and a reference to the Final Safety Analysis Repo*rt description of the design basis of the monitors is included.

As described in 10 CFR 50.36(c)(2)(i),_the Limit_ing Condition for Operation.and

. associated Operability requirements represent the lowest functional capability or perforryfance levels of equipment required.for safe operation of the facility-. _In..

practice, the leakage monitoring instrumentation is typically set to provide the

. most sensitive response without distracting.the reactor operators with unnecessary alarms.

Wh*en the containment atmosphere gaseous t:adiation monitor is the only Operable monitor, the current Technical Specifications require performance of CPNPP LAR 19--001 Page 16 of 21 SR 3.4.13.1 (mass balance) once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and restoration of the inoperabl~

sump.monitor within 30 days. The proposed change requires analyzing grab samples from the containment atmosphere and restoration of at least one

_ additional monitor within 7 days. The RCS mass balance is sensitive enough to detect a one gptn leak rate in one ho*ur and 1s the primary method used to verify compliance with the RCS leakage limits. However, an Res* mass balance calculatio_n requires a relatively lengthy period of steady state operation to

provide accurate results. The ability to perform grab sampling during periods of power change is desirable and pr:ovides an additional compensatory method to the currently required RCS n:iass bala.nce. A Gontainment grab sample is comparable to the.containment particulate radiation mo*n_itor with respect 1o the

ability*to detect RCS leakage. Due to the time to take and analyze the grab.

sample, this is not a continuous monitoring method: However, by reducing the time between grab samples.there will be no significant loss of monitoring

_capability during the limited time period allowed by the proposed change. The.

12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (once per shift) performance of containment grab samples is reasonable given the availability-ofthe containment atmosphere ga~eous radiation monit6'r.

°the 7-day Comp.letion Time*to restore another monitor is reason.able given the diverse methods available to detect an RCS leak and the low probability of a l_a~ge RCS leak during, this pe_riod.

Most licensees have been licensed for Leak-Before-Break (LBB). The basic concept of lea~-before-break (LBB) is that certain piping material has sufficient fracture tough'ness (i.e., ductility) to resist rapid flaw propagation. A postulated.

flaw in such piping would not lead to pipe rupture and po_tentia*1 damage to adjacent safety related systems, structures and components before the plant could be pl~ced in a safe, shutdown condition. Before pipe *rupture, the postulated flaw would lead to limited but detect.able leakage which would be identified by the leak detection systems in time for. the operator to take act1orL The NRC staff reviews the application of LBB methodology to primary system piping to ensure that certain safety margins are satisfied to assure the *

. structural integrity 6f the pipe. There is significant conservati~rn in this. -.

evalup_tion. SRP Section 3.6.3 $pecifies a margin of the *square-root_ 9f 2 b,e

applied to the loads to assure that teakage-size flaws are stable at the normal lqad plus safe-shutdown earthquake load. A margin o(10 is to be applied to leakage so that detection ofleakage from the postulated*flaw size is ensured..

when the pipe is subjected to normal operational loads. In ~dditioh, the critical flaw size should be twice as large as the.lea_kage flaw size (i.e., a margin of 2 on leakage flaw size). The proposed actions for inoperable RCS leakage*detection fnstrurnentation* maintain* st1ffiQi~rit continuity and diyersity of RCS lea)<age de.tection capability that an e?(tremely 1.ow-probcibility of undetected RCS leakage leading to pipe rupture is maintained. *.

For these reasons, Vistra OpCo concludes that the proposed change will provide

. clarified information to the_ operators {or determining monitor OPERABILITY and required actions bases 0~ what monitor is inoperable..

In summary, the proposed technical sp.ecification change wili eliminate confusion regarding what monitors are require~ for OPE~ABILITY and will provide.better CPNPP LAR 19-001 Page 17 of 21 infonnation to the operators regarding what is required for each monitor to be considered OPERABLE.

4.0 REGULATORY EVALUATION

. 4.1 Applicabie Regulatory Requirements General Design Criterion (GDC) 30-of Appenqix A to tb CFR 50 require*s

means for detecting and, to the extent practical, identifying the location of the.source of RCS Leakage. Regulatory Guide (RG) 1.45, Revision 0,

.. "Reactor Cool.ant Press_ure Boundary Leakage Detection Systems*," May 1973, describes acceptable methods for selecting leakage detection Systems.. Revision 1 of R~ 1.45 was issued in May 2Q08.

However, operating nuclear power plants are not committed to Revision 1 of RG 1.45.

NRC lnfonnation Notice (IN) 2005-24, "Non-conservatism in Leakage

_ Detection Sensitivity," (ADAMS A~ssion No. ML051.780073) pointed qut

_ that the reactor coolant activity ass_umptions used for designing the containment radiation*gaseous. radiation monitor may be greater than the RCS radioactivity level present during nonnal operation. As a result, the.

containm'ent gas channel niay not be able to'. detect a 1 gprry leak within 1

~our at the current RCS radioactivity level.

RG 1.45,, R~v. 0, -Regulatory Position C.2 state!;lhat "Leakage to the primary_reactor containment from ~hidentified sour~s shoLi!d be collected and the flow rate monitored with an acc_uracy of one gallon 'per min_ute (gpm) or better." Regulatory Position C.3 states, "At least three separate

detection methods should*be employed and two of these methods should be (1) sump level and flow monitoring and (2) airborne particulate Radioactivity monitoring. The third m~thod may be selected from.the following: a. monitoring* of condensate flow rate from air coolers,

b. monitoring of atrborrie !:faseous *radioactivity. Humi_dity, temperature; or pressure monitoring of the cor:itainment atmosphere should be considered as alanns-or'indirect indication *of leakage to the containment."

. 'Regulatory Position C.5 states, "The sensitivity and response time of each leakage detection system in regulatory position [C.]3. above employed fo~

unidentified:leakage should be-adequate to detect a leakage rate, or its equivalent, of one gpm in less than one hour.-" RG 1.45, Rev. 0, states, "In analyzing the.sensitivity of leak detection systems using airborne particulate or gaseou~ radioactivity, a realistic primary coolant radioactivity concentration assumption should be used. The expec;ted values used in * *

."the plant environmental report would be acceptable." Many plants~

pre-date t~e issuance of RG 1.45 and their plant-specific licensing basis i~

described-in their UFSAR.

rn either case, the appropriate*sensitivity of the atmospheric radiation monitors is dependent on the design assumptions and the plant licensing basis of each licensee."

~*

CPNPP LAR 19-001 Page 18 of 21 The ISTS Specification 3.4.15 Bases do not clearly define the basis for Operability for the RCS Leakage Instrumentation. Operability requirements should be defined in the LCO section of the Bases:

However, the current Bases contain information that could be construed as Operability requirements in.the Background, Appli~able Safely Analysis, and LCO sections. In addition, the cur:rent Bases do not accurately describe the Operability of a detector as being based oh the design assumptions and licensing basis for the plant.

Because the containm~nt atmosphere gaseous radiation monitor cannot always detect an RCS leak at a rate of 1 gpm ~ithin 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , some.plan.ts

.have removed.the monitor*from the Technical Specifi~tion-list of required monitors. However, experience has shown that tne containment atmosphere gaseous radiation monitor is usefut to detect an increase in RCS lea_~ rate and provides a dive~e means to confirm ari RCS leak

- .*exists when other monitors* detect an increase in RCS leak rate.

Therefore, the preferred solution is to retain th~ containment atmosphere gaseous radiation monitor in th*E;l LCO ~A.15 list. of required equipment,_

and to revise the Actions to require additional monitoring and to provide

less time befqre a plan~ shutdown is* required when the con~airiment atmosphere gaseous radiation monitor is the only Operable mon_itor.

1 O CFR *so, Appendix A, "General Design Criteria for. Nuclear P*ower Plants," Criterion 30, "Quality of reactor coolant pressure boundary," **

requires that means pe provided for deJecting anc!, to the ~xtent practical,

. identifying the location _of the* source of reactor coolant leakage. The specific attributes of the reactor coolant 1e*akage d~tection systems are outlined in Regulatory_:Positions 1 through 9 of Regulatory Guide 1.45, Rev.*O.

10.CFR 50, Appendix A, "General Design Criteria for N~clear Power Plants," Criterion 4, .Environmental and Dyna*mic Effects Design Bases,"

requires components to be designed to accommodate-'dynamic effects.

associated w~h postulated pipe ruptures. However, these dynamic effects may be excluded if. the Commission approves analyses deinonstratfng that the probability of fluid system piping rupture is extremely low under.

- conditions consistent with.the design basis for the piping. Mqst licensees have been licensed for Leak-Before-Break (LBB). The NRG staff reviews the applicatio*n of LBB methodology to primary system piping to ensure that cerj:~in safety margins are sati'sfied to assure the structu1ql 'integrity of the pipe. The proposed actions for inoperable RCS-leakage detection instrumentation maintain sufficient continuity and diversity of RCS leakage detection capability that an_ extre!'Tlely low probability.of undetected RCS leakag~ l_eading to pipe rupture is maintained.

1.0- CFR 50.36, Tectiriical Specifications," paragraph (c)(2)(ii)(A), specifies that a Limiting Condition for Operation be established for installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure CPNPP LAR 19-001 Page 19 of 21 boundary. This instrumentation is required by Specification 3.4.1 ff, "RC$

Leakage Detection Instrumentation." The modification of the Actions in Specification 3.4: 15 is not in conflict with the 1 O CFR 50.36 requirements.

The proposed changes do not adversely impact the ability of the Reactor Coolant System leakage detection system to function as designed and do not impact conformance to the applicable GDCs. Therefor~. the proposed changes ar~ consistent with all applicable regulatory requirements or criteria.

Based on the considerations discussed above, (t) the~ is reason~ble -

assurance that the health and safety ofthe public will not be endangered

by operation in the proposed mann.er, (2) such activities will be condl,lcted in compliance with the Commission's regulations,.and (3) the approval.

of the proposed change will not be inimical to the common defense and

_security or to the health an~ safety of the public.

4.2 - Precedent

-Several operating.facilities have, implemented TSTF.:513-A, Revision 3.

These facilities in'clude; Braidwood Units 1 and 2 Byron-Units ;1 and 2 Farley Units 1 and 2 Seabrook Unit 1' Arkansas Nuclear On_e. Unit 1

Vogtle ~nits 1 and ?

North Anna Units 1* and 2 D.C. c*ook Units 1 and 2:

4.3 No Significant Hazards Consideration Determination.

The Technical Specification Task Force (TSTF) has evaluated whether or

_

not a sigl)ificant hazards consideration is involved with the prqp*osed

- generic change by focusing on the three.standards set forth iff 10 CFR 50J)2, "Issuance of amendment," as*piscussed below:..

1. Does the proposed change involve a significant increase iri the probability or consequences of an accident previousiy evaluated?

Response:.No.

The proposed change clarifies the Operability requirements for the Reactor C9ol~nt System (RCS) l~akage detection :instrumentatior, a11d reduces the time allowed for the plant to *operate when the :only Operabl~ RCS leijkage 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 ofHCS leakage is* not us~d to mitigate the consequei:,ces of any accident previously evaluated.

CPNPP LAR 19-001 Page 20 of 21 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 possibili_ty of a new or diff~rent kind of accident from any accident previously _evaluate.ct?

Response: No.

The proposed change clarifies the Operability requirements for. the Reactor Coolant System (RCS) leakage detection instrumentation ar:id reduces the time allowed for the plant to operate when the.only Operable-RCS leakage instrumentation monitor is the containment atm_osphere gaseous radiation monitor. The proposed change *does

not i!"}volve a physical alteration of the plant (no new or different typ~ of equipment will be installed) or a change*in the methods governing

normal pJant operation.

Therefore, it ls concluded that this chc;mge does not create the possibility' of a new or different kind of accident from any accident previously ev~luated.

3. Does the proposed change involve a significartt reduction in a margin of safety?

Response: No.

The *proposed change clarifies the Operability requirements.for the Reactor Cool;mt System (RCS) leakage. detection instrumentation and redu*ces the time alloweq for the plant to operate when the only Operable: RCS leakage instrumentation monitor is the containment atmosphere gaseous ra*diatiqn m*onitor.. Reducing the am~:>unt of time, the plant is allowed to operate with orily th~ containment atmospt,ere gaseous-radiation.monitor Operable increase$ the margin of safety by increasing the.likelihooq that an increase in RCS l~akage will be detected before it potentially results in gross failure.

Therefore; it is concluded that this change does not involve a significant red.uction in.-a margin bf safety..

_

Ba$ed on the above, the TSTF and Vistra OpCo concludes that the propqsed change presents -no significant hazards con$iderations under., *

-the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration." is justified.

4.4 Conclusions The requirements of GDC 30, and GDC.4 continue to be met since'.no CPNPP LAR 19-001 Page 21 of 21 changes are being proposed which would affect the design capability, function, *operation, or method of testing the*RCS Leakage Detection Instrumentation. Therefore, the applicable guidance in IN 2005-24, and RG 1.45, Revision O _continue to be met.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be

.endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the i~suance of the_ amendmenf will not qe adverse to the common.

defense and security*or to the* health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

S Vistra OpCo and the TSJF has g~tertnined that the proposeg change ~ould change a requirement with respect to installation or use of a facility component'

.. located within the restricted area*, as defined in. 10 CFR 20, or would change a*n inspection or suryeillance requirement. However, the proposed. change does not involve {i) a-significant hazards consideration, (ii) a significant change in Jhe types or*significan*t increase in t~e amounts of any effluent that'. may :be

- released offsite, or (iii) a signfficant increase in individual or cumylative*

occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth.in 1 O CF:R 51.22(.c)(9).

Therefore, pursuant fo 10 CFR 51.22(b), no environmental impact statement or.

. environmental assessment need be prepared.in connection with'the proposed change.

. 6.0 R_EFERENCES 6.1 6.2 6.3

'6.4 6.5

CPNPP FSAR Section 5.2.5, "Detection 0f Leakage Through Reactor.

Coolant Pressure Boundary" General Design Criteria (GDC) of 10 CFR 50 Appendix A, GDC 4

"Environmental and dynamic effects design bases"-

General Design Criteria (GDC) of 10 CFR 50 Appendix A, GDC 30 "Qualicy*of reactor coolant pressure bounc;lary" NRC Information Notice 2005-24 "Non-conservatism in Leakage Detection

. Sensitivity" NRC Regulatory Guide 1.45, Revision 0, "Guidance on M9nitoring 1;1nd Respond_ing to R~actor Coolant System Leakage" CPNPP I.AR *19-001 Page 1 of27

Attachme,nt 2 to TXX-19067 LAR 19-001 Cornanch~ Peak Technical Specifications, LCO 3.4..15, RCS Le~kage Detection Instrumentation * :

1.

CPNPP:TECHNICAL SPE.CIFICATtONS,

LCO 3.4.15'~ MARKUP 2-.

TSTF-513-A REV-3 TECHNICAL SPECIFICATIONS_,

LC0.3.4;15-MARKUP

~

3.

CPNPP TECHNICAL SPECIFICATIONS BASES,

. LCO 3.4.1.5 :- MARKUP [FOR INFORMATION ONLY]*.

~

4.. rsTp~513-A REV 3 TECtlNICAL SPECIFICATIONS-BASES,

.

LC0.3.4.15.MARKU_P [FOR INFORMATION ONLY]

CPNPP LAR 19-001 Page 2 of 27 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.

b.

C.

One containment sumP. (level or discharge flow) monitor, 0Ae GoAtaiAR'leAt SUR'IJ3 Level and Flow Monitoring SystoA'I; One,COl)tai(lmen~atmosphere p~i8~~i~il~8rnt9if/~<twa8~5aRtt part1cu1ateJ, anu One containment air cooler condensate flow rate monitor gr gne eonteinffieAt BtffiOSJ3Aere radioactivity ffiORitor (!:'J8Seous).

APPLICABILITY:

MODES 1, 2, 3, and 4 ACTIONS CONDITION A. Required Cont8inment S1::1FRp Level ans P:low Monitorin!:'J SysteA'I ingporalalo.

Required containment sump monitor inoperable.

REQUIRED ACTION COMPLETION TIME A.1 -------------------NOTE-------------------

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

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND A.2 Restore GoAteiAR'lent Sump Le*,el ai:id Flow Moi:iitorii:ig System to OPERABLE st8tus.

Restore required containment sump monitor to OPERABLE status.

30 days COMANCHE PEAK - UNITS 1 AND 2 3.4-37 Amendment No.

CPNPP LAR 19-001 Page 3 of27 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION B. Required containment atmosphere particulate radioactivity monitor inoperable.

REQUIRED ACTION B.1.1 Analyze grab samples of the containment atmosphere.

OR B.1.2 ------------------NOTE------------------

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

Perform SR 3.4.13.1.

COMPLETION TIME Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B.2.1 ~

Restore required containment 30 days atmosphere ~artis1:1late radioactivity monitor to OPERABLE status.

OR B.2.2 Verify containment air cooler condensate flow rate monitor is OPERABLE.

COMANCHE PEAK - UNITS 1 AND 2 3.4-38 30 days Amendment No.

CPNPP LAR 19-001 Page 4 of 27 ACTIONS (continued)

CONDITION C Reeiuireel eer,teir,mer,t etmes13l=lcrc geseeus radioaQtivit;y rrionitor iAe13eFable.

A~m Containment Req1:1irea oontainFRent air cooler condensate flow rate monitor inoperable.

inoperable.

Insert A here RCS Leakage Detection Instrumentation 3.4.15 REQUIRED ACTION COMPLETION TIME C.1 Perform SR 3.4.15.1 8

G.1.1 /\\Aalyzm grab s0FA13lcs ef tl'le Once per 2:4-hours oontainFRent atr:Ros13l=lere.

OR C.2 tr.+.r ------------------NOTE------------------

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

Perform SR 3.4.13.1.

QOoler oonc:lensate flow rate FRonitor to OPeRAQU: stat1:1s.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months COMANCHE PEAK - UNITS 1 AND 2 3.4-39 Amendment No.

CPNPP LAR 19-001 Page 5 of 27 RCS Leakage Detection Instrumentation 3.4.15 SURVEILLANCE REQUIREMENTS SR 3.4.15.1 SR 3.4.15.2 SR 3.4.15.3 SR 3.4.15.4 SR 3.4.15.5 SURVEILLANCE FREQUENCY Perform CHANNEL CHECK of the required containment In accordance with atmosphere particulate and gaseous radioactivity monitors. the Surveillance Frequency Control Program.

Perform COT of the required containment atmosphere particulate and gaseous radioactivity monitors.

Perform CHANNEL CALIBRATION of the required Containment Sump Level and Flow Monitoring System.

Perform CHANNEL CALIBRATION of the required containment atmosphere particulate and gaseous radioactivity monitors.

Perform CHANNEL CALIBRATION of the required containment air cooler condensate flow rate monitor.

In accordance with the Surveillance Frequency Control Program.

COMANCHE PEAK - UNITS 1 AND 2 3.4-40 Amendment No.

CPNPP LAR 19-001 Page 6 of 27 Insert A

NO TE-------------

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

D.

Required containment sump monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

E.

Required containment atmosphere radioactivity monitor inoperable.

AND Containment air cooler condensate flow rate monitor inoperable.

F. Required Action and associated Completion Time not met.

G. All required monitors inoperable.

D.1 Analyze grab samples of Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the containment atmosphere.

AND D.2.1 Restore required containment sump monitor 7 days to OPERABLE status.

OR D.2.2 Restore containment air cooler condensate flow rate 7 days monitor to OPERABLE status.

E.1 Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

OR E.2 Restore containment air 30 days cooler condensate flow rate monitor to OPERABLE status.

F.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND F.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months G.1 Enter LCO 3.0.3.

Immediately CPNPP LAR 19-001 Page 7 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 APPLICABILITY:

ACTIONS CONDITION The following RCS leakage detection instrumentation shall be OPERABLE:

a.

One containment sump (level or discharge flow) monitor,

b.

One containment atmosphere radioactivity monitor (gaseous or particulate), and

[ c.

One containment air cooler condensate flow rate monitor. ]

MODES 1, 2, 3, and 4.

REQUIRED ACTION COMPLETION TIME A. Required containment sump monitor inoperable.

A.1

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

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

WOG STS AND A.2 Perform SR 3.4.13.1.

Restore required containment sump monitor to OPERABLE status.

3.4.15-1 Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 30 days Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 8 of 27 ACTIONS (continued)

CONDITION B. Required containment atmosphere radioactivity monitor inoperable.

C. [ Req1:1irod oContainment air cooler condensate flow rate monitor inoperable.

WOG STS B.1.1 OR B.1.2

~AND B.2.1 OR LB.2.2 C.1 OR C.2 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation 3.4.15 REQUIRED ACTION COMPLETION TIME Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

NO TE--------------

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

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

Verify containment air 30 days]

cooler condensate flow rate monitor is OPERABLE.

Perform SR 3.4.15.1.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

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

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

Perform SR 3.4.13.1.

Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ]

3.4.15-2 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 9 of 27 ACTIONS (continued)

CONDITION

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

Onl~ a1212licable when the containment atmos12here gaseous radiation monitor is the only OPERABLE monitor.

D. Reguired containment sum12 monitor inoperable.

AND

[ Containment air cooler condensate flow rate monitor inoperable.]

G.!;,.[ Required containment atmosphere radioactivity monitor inoperable.

AND LRequired cContainment air cooler condensate flow rate monitor inoperable.}

fe. Required Action and associated Completion Time not met.

GF.AII required monitors inoperable.

WOGSTS D.1 AND D.2.1 OR

[ D.2.2 G.!;,.1 OR LG.l;,.2 Ee.1 AND Ee.2 GF.1 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation 3.4.15 REQUIRED ACTION COMPLETION TIME Analyze grab sam12les of Once 12er 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months the containment atmosphere.

Restore reguired 7 days containment sum12 monitor to OPERABLE status.

Restore containment air 7 days J cooler condensate flow rate monitor to OPERABLE status.

Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

Restore required 30 days]

containment air cooler condensate flow rate monitor to OPERABLE status.}

Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Enter LCO 3.0.3.

Immediately 3.4.15-3 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 10 of 27 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 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.

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. Regulatory Guide 1.45~

ef. 2) describes acceptable methods for selecting leakage detection syste~

, Revision O.

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

___ -.!:p_ro::...'.p.er evaluation of all unidentified LEAKAGE. ?l the containment Other indications may be used to detect an increase in unidentified LEAKAGE; however, they are not required to be OPERABLE by this LCO.

IAdustr)' 19raetiee 19as sl9ewA tl9at water flew el9aAges ef 0.§ ta 1.0 Qf:lA'! eaA be readily detected iA eeAtaiAed veluA'les ey A'!eAiteriAg el9aAges iA water level, iA fiow Fate, OF iA tl=le 013eFatiAg fFeeiueAey of a J3UA'!J3. The containment sump used to collect unidentified LEAKAGE anc:Miir cooler condensate fl~

above rate monitor are instrumented to alarm for increases ef 0.§ to 1.0 QJ3A'! iM he normal flow rates. Tl=lis seAsitivity is asse13table foF detesting insFeases in unidentified LEAKAGE The reactor coolant contains radioactivity that, when released to the containment, g1;iW be detected by radiation monitoring instrumentation.

Reseter eeelaAt radieaetivit)' levels will ee le'fv duriAg iAitial reseter staFtu19 aAd fer a few weelcs tl9ereafter, uAtil aetivated eerresieA pFeduets 19ave eeeA ferA'led aAd fissieA pFeduets 8f:lf:)ear freA'! fuel eleA'leAt eladdiAg contamination er cladding defects. lnstr1::1ment sensitivities of 1 g-9 l:lCiJcc radieastivity for 13artic1::1late monitoring and ef 1 g-6 l=l:Ci/cs radioactivity for gasee1::1s monitoring are ~rastisal for these leakage detection systems.

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.

~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. A 1 °F iAerease iA dew 19eiAt is well witl9iA tl9e seAsitivity raAge ef available iAstruffieAts.

Since the humidity level is influenced by several factors, a quantitative evaluation of an indicated leakage rate by this means may be questionable (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-75 Revision 76 CPNPP LAR 19-001 Page 11 of 27 RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

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.

APPLICABLE SAFETY ANALYSES 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 by this LCO.

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 4

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.

Tl=le asyFAFAotrio loads 13rod1::1ood by 13ost1::1lated breaks are the result of ass1::1FAed 13ress1::1re iFAbalaAoe, both iAterAal aAEI ex-terAal to tl=le RCa. Tl=le i1 rter, 1al asy1,,n 1etrie loads result f1'011, a, apid deeo111pressio11 ti 1at causes laFge tFBASieAt pFeSStJFe eli#ereAtials aeFess t1=1e eeFe B0FFel 0Ael fuel asseFAblies. Tl=le extemal asyFAmetris loaEls res1::1lt from tl=le ra13id depr:essuri,;i:atioi:r of the ai:ri:rulus re9ioi:rs, such a& th& ai:ri:rulu& bet.weei:r the reaotor *10ssel and tl=le sl=lield wall, aAd oa1::1s0 large traAsieAt 13ress1::1r0 eli#eFeAtials te aet eA tl=le *,essel. Tl=lese eli#eFeAtial pressuFe leaels eeuld daFAage RCS s1::11313orts, sore oooling e1:11::1i13FAent or sore internals. This ooAoern was first identified as M1::1lti13lant Aotion (MP.A.) D 1Q and sybse~uei:rtly as Unresolved Safety Issue (USI) 2, "Asym1+10tris I...OCA l...oaEls" (Ref. 4).

Tl=le resol1::1tioA of USI 2 for Vl/estiAgl=lo1::1se PWRs was the 1::1s0 of frast1::1r0 meehanies teehnology for RCS piping >10 inehes diameteF (Ref. 6). This teel=lnelogy beoaFRe known as leal< eefore ereak (LBB). lneluded witl=lin tl=le LBB ffietRedele~y was tt,e requireffient te Ra'fl'e leak eleteetier, systems sa13able of EletestiAg a 1.Q g13m leak witl=liA fo1::1r 1=!01::1rs. Tl=lis leakage Fate is desi9Aod to eASl::lFe that ade1:11::1at0 FAargiAs e:><ist to detest leaks iA a tiFAely FAaAAer E11::1riA9 AOFFflal operating sonditions. Tho 1::1se of tho u:rn 1+1ethodology is described ii:r ~eferei:rce 6 The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary. The system response tiffies and sensitiuities tue (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-76 Revision 76 CPNPP LAR 19-001 Page 12 of 27 RCS Leakage Detection Instrumentation B 3.4.15 BASES APPLICABLE SAFETY ANALYSES (continued)

LCO small amounts of unidentified LEAKAGE desorieed iA tl:le FSAR (Ref. 3). Multiple iAstruA'leAt looatioAs are utili;zed, if needed, to onsblro that tho transport delay time ef the leaka9e fr:em its souroe to an instruFReAt looation yields aA aooeptaele overall response tiFRe.

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 1 of 1 OCFR50.36(c)(2)(ii).

One FRethod of prnteotinJ aJainst large RCS leakage derives ffoFR the aeility of instnimonts to rapidly detest e><troFfloly sFflall leaks. This LCO requires instruments of diverse monitoring principles to be OPERABLE to provide a-

~wh degree ~ confidence th~

K!reFflely SFflall leal~s are detected in time to a ow actions o place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

Insert B ----------:;l:le LGO is satisfied wl:len monitors of diverse FReasureFRent FReans are a'failaele. Thbls, the Containment 5blmp be>.<<el and Flew Meniterin9 System,

,:r 11 u di act" ity.

it r lld *tw r 4 t.

t...

lei

--~

;;

;

r:;a':S:sr::::;:~~:~;:e'fide an Insert C APPLICABILITY ACTIONS aooeptaele 1+1ini1+1u1+1 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.

A.1 and A.2 containment sump monitor With the required ContainFflent a1::1mp Lei/el and flew Monitoring System inoperable, no other form of sampling can provide the equivalent information; (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-77 Revision 76 CPNPP LAR 19-001 Page 13 of 27 RCS Leakage Detection Instrumentation 83.4.15 BASES containment atmosphere radioactivity monito;,

A.1 and A.2 (continued)

ACTIONS Insert D however, the containment atmosphere radioactivity monitor will provide ~

indications of changes in leakage. Together with the atFRospRere ffieAiter, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequenmt~ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage. A O e is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (as defined in the Bases of SR 3.4.13.1 ). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process necessary data after stable plant conditions are established.

containment sump monitor Restoration of the required ContainFRent al:IFRP Level ane Flow Monitoring SysteFR 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, ane B.2 B.1.1, B.1.2, B.2.1, and B.2.2

'th the particulate containment atmosphere radioactivity monitoring instr entation channel inoperable, alternative action is required.

er grab sa s of the containment atmosphere must be taken an nalyzed or water invento balances, in accordance with SR 3.4.13.1 st be performed to prov alternate periodic information.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provi periodic inform

n that is adequate to detect leakage. A note is ad a allowing that SR 3.4.1. *s not required to be performed until 1 ours after establishing steady state eration (as defined in the Bases R 3.4.13.1 ). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provi sufficient time to colle nd process necessary data after stable plant conditi are est 1shed. The 30 day Completion Time recognizes at least one rm of leakage detection is available.

C.1.1, C.1.2, G.2.1 BAd G.2.2

~

'.tVitR tRe reqliired eoAteiAffieAt etffiospi'ler-e gaseous raelioaeti\\'ity monitor Insert E aAd ti'le required eeAtaiAffieAt air eeoler eoAdeAsete flew rate ffiOAitor inoperable, tRe FReans of eeteoting leakage are tRe ContainFRent SliFRP Level ang Flgw Mgnitgring System and the cgntainment atmgsphere partim.,ilate (continued)

COMANCHE PEAK - UNITS 1 AND 2 8 3.4-78 Revision 76 CPNPP LAR 19-001 Page 14 of27 RCS Leakage Detection Instrumentation B3.4.15 BASES ACTIONS Insert F --:>

SURVEILLANCE REQUIREMENTS

.1.1 C.1.2 C.2.1 and C.2.2 (continued) radio tive monitor. This Condition does not provide all the required erse means o akage detection. With both gaseous containment at sphere radioactivity nitoring and containment air cooler condensa ow rate monitoring instr entation channels inoperable, alternati action is required. Either gra am pies of the containment atm phere must be taken and analyzed or water I entory balances, in ace ance with SR 3.4.13.1, must be performed to provi alternate perio

information.

A note is added al ing that SR 3.4.13.1 is not requi to be performed er establishing steady state operation (s le RCS

pressure, perature, power level, pressurizer and makeup make and letdown, and RCP seal injection and return flows).

ance provides sufficient time to collect and process necessary er stable plant conditions are established.

D.1 aflel D.2 1

onitors/systems inoperable n eans of monitoring leakage are av diate plant shutdown in O 3.0.3 is required.

SR 3.4.15.1 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 (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-79 Revision 76 CPNPP LAR 19-001 Page 15 of 27 RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE REQUIREMENTS REFERENCES SR 3.4.15.1 (continued)

Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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. The test verifies the alarm setpoint and relative accuracy of the instrument string. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.3, SR 3.4.15.4, and SR 3.4.15.5 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 Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

2.

3.

4.

5.

6.

10 CFR 50, Appendix A, Section IV, GDC 30.

R:

I t G *d 1 45 Regulatory Guide 1.45, Revision 0, "Reactor Coolant ego a 01 y m e.

. Pressure Boundary Leakage Detection Systems," May 1973.

FSAR, Section 5.2.

PWREG-609, "As~n,n,etrie BlovVdO\\'vn Loads on PWR Primary Systti~s." 1 QS1.

Generio Letter ~4 Q4, "aafety evah,1ation of Westingho1,1se Topioal Re19efts DealiA~ witl=I ElimiAatieA ef Pesttllateel Pi19e Breaks iA PWR P, i11,a, y Mai11 Loops."

FSAR, SeetieA 3.68.

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-80 Revision 76 CPNPP LAR 19-001 Page 16 of 27 Insert B The LCO requires three instruments to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE. The containment sump consists of the normal sump and the emergency sump. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in the sump. The monitor on the containment sump detects level or flow rate or the operating frequency of a pump and is 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 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 3).

An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. Condensate flow from air coolers 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 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate flow rate monitor OPERABILITY.

Insert C 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 and a containment air cooler condensate flow rate monitor, provides an acceptable minimum.

CPNPP LAR 19-001 Page 17 of 27 Insert D 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken or water inventory balances performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (as defined in the Bases of SR 3.4.13.1). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 leakage detection is available.

Insert E C.1 and C.2 With the containment air cooler condensate flow rate monitor inoperable, alternative action is again required. Either SR 3.4.15.1 must be performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information. Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reactor operation may continue while awaiting restoration of the containment air cooler condensate flow rate monitor to OPERABLE status.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady state operation (as defined in the Bases of SR 3.4.13.1 ). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established.

Insert F D.1, D.2.1, and D.2.2 With the required containment sump monitor and the containment air cooler condensate flow rate 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 radiation 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

CPNPP LAR 19-001 Page 18 of 27 Insert F (continued)

E.1 and E.2 With the required containment atmosphere radioactivity monitor and the containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monitor. This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors 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 reduced configuration for a lengthy time period.

F.1 and F.2 If a Required Action of Condition A, B, C, D or E 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

CPNPP LAR 19-001 Page 19 of 27 TSTF-513, Rev. 3 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 WOG STS GDC 30 of Appendix A to 1 O CFR 50 (Ref. 1) requires means for detecting and, to the extent practical, identifying the location of the source of RCS LEAKAGE. Regulatory Guide 1.45. Revision 0. (Ref. 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. [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.]

Industry prastice has shown that water flo'N changes of 0.5 to 1.0 gpm can be readily detected in contained volumes by monitoring changes in water level, in flow rate, or in the operating frequency of a pump. The containment sump used to collect unidentified LEAKAGE [is] [(or) and the containment air cooler condensate flow rate monitor] [are] instrumented to alarm for increases of 0.5 to 1.0 gpm inabove the normal flow rates. +ms sensitivity is acceptable for detecting increases in unidentified LEAKAGE.

The reactor coolant contains radioactivity that, when released to the containment, GaR-may be detected by radiation monitoring instrumentation. Reactor coolant radioacti*,*ity levels will be low during initial reactor startup and for a few *....-eeks thereafter, until activated corrosion products have boon formed and fission preducts appear from fuel element cladding contamination or cladding defects. Instrument sensitivities of 1 O...g µCi/cc radioactivity for particulate monitoring and of 4-0-$ µCi!cc radioactivity for gaseous monitoring are praetical for these leakage deteetion systems. Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.

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. A 1 °F increase in do*,y point is well within tho sensitivity range of a*,ailable instruments.

83.4.15-1 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 20 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 BASES BACKGROUND (continued)

APPLICABLE SAFETY ANALYSES LCO WOGSTS 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 by this LCO.

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 afe-is 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.l 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.]

The need to evaluate the severity of an alarm or an indication is important to the operators, and the ability to compare and verify with indications from other systems is necessary. The system FOsponse times and sensitivities are described in the FSAR (Ref. 3). Multiple instrument locations are utilized, if needec:I, ta ensuFO that the transpert delay time ef the leakage from its source to an instrument losatien yields an acceptable everall FOsponse time.

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 1 of 10 CFR 50.36(c)(2)(ii).

One methed of protestin9 against laF§e RCS leakage deri'les from the ability ef instruments to rapidly detest e~remely small leaks. This LCO B 3.4.15-2 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 21 of27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.1 5 WOGSTS requires instruments of diverse monitoring principles to be OPERABLE to provide a high degree of confidence that small amounts of unidentified LEAKAGE extremely small leaks are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates possible RCPB degradation.

B 3.4.15-3 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 22 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 BASES LCO (continued)

WOGSTS The LCO requires [three] instruments to be OPERABLE.

The containment sump is used to collect unidentified LEAKAGE. [The containment sump consists of the normal sump and the emergency sump. The LCO requirements apply to the total amount of unidentified LEAKAGE collected in [thel[bothj sump[s].j The monitor on the containment sump detects [level or flow rate or the operating frequency of a pump) and is instrumented to detect when there is [leakage of) [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 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to that assumed in the design calculations for the monitors (Reference 3).

[An increase in humidity of the containment atmosphere could indicate the release of water vapor to the containment. Condensate flow from air coolers 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 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This sensitivity is acceptable for containment air cooler condensate flow rate monitor OPERABILITY.]

The LCO is satisfied when monitors of diverse measurement means are available. Thus, the containment sump monitor, in combination with a B 3.4.15-4 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 23 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 APPLICABILITY ACTIONS WOGSTS gaseous or particulate radioactivity monitor [and a containment air cooler condensate flow rate monitor], provides an acceptable minimum.

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 s 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.

A.1 and A.2 With the required containment sump monitor inoperable, no other form of sampling can provide the equivalent information; however, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the containment atmosphere radioactivity monitor, 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 3.4.15-5 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 24 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

WOG STS B.1.1, B.1.2, B.2.1, and B.2.2 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. [Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken or water inventory balances performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .}

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 leakage detection is available.

[ C.1 and C.2 With the req1,1ireEI containment air cooler condensate flow rate monitor inoperable, alternative action is again required. Either SR 3.4.15.1 must be performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

Provided a CHANNEL CHECK is performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or a water inventory balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reactor operation may continue while awaiting restoration of the containment air cooler condensate flow rate monitor to OPERABLE status.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect RCS LEAKAGE. A Note is added allowing that SR 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process all necessary data after stable plant conditions are established. ]

8 3.4.15-6 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 25 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS (continued)

WOG STS D.1. D.2.1. and D.2.2 With the required containment sump monitor [and the containment air cooler condensate flow rate 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 radiation 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

[ GE.1 and GE.2 With the required containment atmosphere radioactivity monitor {and the roql:lireEI containment air cooler condensate flow rate monitor} inoperable, the only means of detecting leakage is the containment sump monitor.

This Condition does not provide the required diverse means of leakage detection. The Required Action is to restore either of the inoperable required monitors 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 reduced configuration for a lengthy time period. ]

Fe.1 and Fe.2 If a Required Action of Condition A, B, [C],..I.Qlor [G§ 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

B 3.4.15-7 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 26 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation 8 3.4.15 SURVEILLANCE REQUIREMENTS WOG STS 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.

SR 3.4.15.1 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 Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is based on instrument reliability and is reasonable for detecting off normal conditions.

8 3.4.15-8 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 27 of 27 TSTF-513, Rev. 3 RCS Leakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.4.

15.2 REFERENCES

WOG STS 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 the 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 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 other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. 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, [SR 3.4.15.4, and SR 3.4.15.5]

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 [181 months is a typical refueling cycle and considers channel reliability. Again, operating experience has proven that this Frequency is acceptable.

1.

10 CFR 50, Appendix A, Section IV, GDC 30.

2.

Regulatory Guide 1.45, Revision 0, "Reactor Coolant Pressure Boundary Leakage Detection Systems," May 1973.

3.

FSAR, Section [ ].

B 3.4.15-9 Rev. 3.0, 03/31/04 CPNPP LAR 19-001 Page 1 of 12 to TXX-19067 LAR 19-001 Comanche Peak Technical Specifications, LCO 3.4.15; RCS Leakage Detection Instrumentation

1.

CPNPP. TECHNICAL SPECIFICATIONS, LCO 3.4.15 - RETYPE

2.

CPNPP TECHNICAL SPECIFICATIONS BASES, LCO 3.4.15 - RETYPE [FOR.INFORMATION ONLY]

CPNPP LAR 19-001 Page 2 of 12 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 detectJon instrumentation shall be OPERABLE:

a One containment sump (level or discharge flow) monitor,

b.

One containment atmosphere radioactivity monitor (gaseous or particulate), and C.

One containment air cooler condensate flow rate monitor.

APPLICABILITY.

MODES 1, 2, 3, and 4 ACTIONS CONDITION A. Required containment sump monitor inoperable.

. REQUIRED ACTION A.1 NOTE-----*-

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

Perform SR 3.4.13.1.

A.2 Restore required containment sump monitor to OPERABLE status.

COMANCHE PEAK - UNITS 1 AND 2 3.4-37 COMPLETION TIME I I Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 30 days Amendment No.

CPNPP LAR 19-001 Page 3 of 12 RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION

-REQUIRE;D ACTI_ON COMPLETION TIME S: Required containm~nt

atmosphere radioactivity monito[ inoperable.

8.1 :1 Analyz;e grab samples of tl)e

_Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months c.* Containment air C9oler-condensate flow,rate mo_nitor inoperable.

co_ntainment atmosphere:*

DR B.1.2 _........:_ __ NQTE---~---

Not req~ir~ until 12)10urs after establi$hment of steady state op_eration.

Perfoflll SR 3.4.13.1.

AND B.2.2 Restore required containment atmosphere radioactivity mbnitor*

tc:5 OPERABLE statrni;':.

B.2.2 Verify'.containment air cooler condensat~ *flow r~te monito_r i~

OPERABLE.

Q.1 Perform SR 3.4.15.1 cbntainment atmosphere.

C.2 Not required untit 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s:"after establishment of steady state operation.

Perform SR 3.4*.'13.1.

COMANCHE PEAK - UNITS 1 AND 2 3.4--38 Once per 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s_

30 days_.

}O days_

Once per 8 hows*.".

Once per 24 hqurs Amen.dment No*.

CPNPP LAR 19-001 Page 4 of 12 ACTIONS (continued)

CONDITION

-NOTE-----

D.1 Only applicable when the containment atmosphere AND gaseous radiation monitor is the only OPERABLE D.2.1 monitor.

D. Required containment sump monitor OR inoperable.

AND D.2.2 Containment air cooler condensate flow rate monitor inoperable.

E. Required containment E.1 atmosphere radioactivity monitor inoperable.

AND OR Containment air cooler E.2 condensate flow rate monitor inoperable.

F. Required Action and F.1 associated Completion Time not met.

AND F.2 G All required monitors G.1 inoperable.

COMANCHE PEAK - UNITS 1 AND 2 RCS Leakage Detection Instrumentation 3.4.15 REQUIRED ACTION COMPLETION TIME Analyze grab samples of the Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment abnosphere.

Restore required containment 7 days sump monitor to OPERABLE status.

Restore containment air 7 days cooler condensate flow rate monito~ to OPERABLE status.

Restore required 30 days containment atmosphere radioactivity monitor to OPERABLE status.

Restore containment air 30 days cooler condensate flow rate monitor to OPERABLE status.

Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Enter LCO 3.0 3.

Immediately r

3.4-39 Amendment No.

. Attachment 3 CPNPP LAR 19-001 Pag*e 5 of 12 RCS Leakage Detection Instrumentation 3.4.15 -

SURVEILLANCE RE:QUIREMENTS SURVEILLANCE FREQUENCY SR.3.4.15.1 Perform CHANNEL CHECK of the required containment.

In accorqance with atmosphere partic1:1late and gaseou*s. radi_oactivity monitors. the Surveillance F~equer:icy Control Program.

SR 3.4.15.2 Perform_ COT of tt)e required containment atmosphere

.

particulate and gaseou15 ~dioactivity monitors.

SR '3.4.15_.3 Perform CHANNEL CALIBRATION of the r-equired.

Containm~nt Sump Level and Flow Monitoring System.

SR 3.4.15.4 Perform CHANNEL CA~IBRATlON of th~ required containment atmosphere particulate:~nd gase'ous

. radioactivity. m.onitors. *

SR 3.4.15.5

Perform CHANNEL 9All BRA Tl9N of the required -

coritainment,air cooler condensate *flo,w rate monitor.

COM}\\NCHE PEAK - UNITS 1 ANq 2 3.440 In accordance with

the Surveillanqe Frequency Control Program.

lr\\accordar:t_ce with the Surveillance Frequency c.ontro'I Program.

In' ace0rdance with the surveillance Frequer:icy Control Program..

In' accordance with

the Sur;veillance Frequency Cootrol Program.

AmendmenJ *No.

CPNPP LAR 19-001 Page 6 of 12 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. Regulatory Guide 1.45, Revision O (Ref. 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. 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.

The containment sump used to collect unidentified LEAKAGE and the containment air cooler condensate flow rate monitor are instrumented to alarm for increases above normal flow rates.

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

Radioactivity detection systems are included for monitoring both particulate and gaseous activities because of their sensitivities and rapid responses to RCS LEAKAGE.

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 by this LCO.

{continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-75 Revision 76 CPNPP LAR 19.:001 Page 7 of 12 RCS Leakage Detection Instrumentation B 3A.15 BASES BACKGROUND (continued)

Air temper~ture and pressure monitoring methods may also be used to -infer unidentified LEAKAGE to.the containment. Containment temperature and pressure fluctuate sligh~y during plant operation, but a dse abov~ the normally indicated range of values may indicate RCS leakage into the *

. containment. The relevance of temperature and pressure measurements is aff~ted by*containm.ent free volume and, for temperature, detector location. Alai:m 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 LC.O.

The above-mentioned LEAKAGE detection methods or systems differ in sensitivity and response time. Some of these system's could serve as early alarm syste.ms signaling the operators that closer examination of other detection system~ is necessary to determine tt,e extent qf any corrective actjon that may be required.

APPLICABLE The need to ev~luate the severity of an alarm or an indication is important to.

SAFETY ANALYSES the operators, and the ability to compare and verify with indications from LCO 1,:

other sxstems is necessary.

The safety significance of RCS LEAKAGE.. varies widely depending on. its source, rate, and duratiOn. Therefore, detecting and monitoring RCS

. LEAKAGE into the containment ~rea. is necessary. Quickly separating the identified LEA.KAGE from the unidentified LEAKAGE provides quantitative inf9rmation to the Qperatoi"s, allowing them to take cprrective action should a leakage occur detrimental to.th,e*safety of the unit and the public.. *.

RCS leakage detection instrumentati*on satisfies Criterion 1 of 10~FR5o:3~(c)(2)_(ii)..

Thi~ LCO requires instruments of diverse monitoring principles to be OPERABLE to provide confiqence that smalt amou11ts of unidentified LEAKAGE are detected in time to allow actions to place the plant in a safe condition, when RCS LEAKAGE indicates po~sible RCPB degradation.

. The LCO requires three instruments to be OPERABLE.

The containment sump is used to: collet unidentified LEAKAGE." Th13 containment sump consists of the normal sump and emergency sump. The LCO requirements apply to the total amot,1nt of unic;tentified. LEAKAGE.

collected in the sump. The monitor on the containment sump (continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-76

Revision 76

C.PNPP LAR:19--001 Pag*e 8 of 12 RCS L'eakage Detection Instrumentation 83.4.15 BASES

'Leo (continued) c;ietects lev~I or flow rate or the_ operating frequency of a pump and is 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 LEAKAGI:: to travel to the containment sump and it may take longer ttian 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*

o'PERABILITY.'

'The reactor coolant contains radioactivity that, when released to the containment, can be detected by the gaseous or particu*late containment :

abnospJ,er~ radiq~ctivity monitor. Only one df the two detectors* is,required to be OPERABLE. Radioactivity.detection systems are included for monitoring

both partiGUlate and gaseous activities hecause of their sensitivities and rapid responses to RCS LEAKAGE, b.ut have recognized limitations. Reactor coolant radioactivity levels will be low during initial reactor startup and*for a --

few weeks thereafter, unm'aciivated corrosion_ products have been formed and fission products appear from fuel element cladding.contamination or cladding defects. l.f there are f~w fuel element cladding defects and low levels of activation products, it may.n_ot be possible for the gaseous or particulate co~tainment atn:iosphere radioactivity monitors to detect a 1 gpm incre*ase within-1 hour cJ.urlng 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 LEA~GE with_in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months given an RCS activity equivalent to-that ass~med in the design calculation~.

for the mon_itors (Reference 3).

An increase in humidity of the containment abnosphere could indicate the relea$9 of water-vapor to _the cobtainment. Condensate. flow from air cooler:s is instrumented to detect*when there Is an-increase above the normal value by 1 gp*m. 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 ~our. This:sensitivlty.is accep~ble for co*n.tainm*ent*air cooler condensate flow rate monitor OPERABILITY..

L j

The*LCO is satisfied when monitors of diverse measurement means are available. Thus; the ~ntairimentsump monitor, in combination with a gaseous or' particulate radioa.ctivity monitor and a containnieht air cooler condensate flow rate.monitor, provides an acceptable minimum.. -

(continued)

COMANCHE PEAK - UNITS 1 AND 2

.. Revision 76 CPNPP LAR 19--001 Page 9 of 12 RCS Leakage Detection Instrumentation 83.4.15 BASES APPLICABILITY ACTIONS 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 a-nd pressure is maintained low or at atmospheric pressure. Since the temper~tures 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.

A.1 and A.2 With the required containment sump monJtor inoperable, no other fom, of sampling can provide the equivalent infom,ation; however, the containment atmosphere radioactivity monitor will provide indications of changes in leakage. Together with the containment atmosphere radioactivity monitor, the periodic surveillance-for RCS water inventory balance, SR 3.4.13.1, must be perfom,ed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage. A Note is added allowing that S-R 3.4.13.1 is not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing steady ~tate operation (as defined in the Bases of SR 3.4.13.1). The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance provides sufficient time to collect and process necessary data after stable plant conditions are established.

Restoration of the required containment sump monitor to OPERABLE status within a Completion TI me 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, 8.21, and B.2.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is requi_red. 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 infom,ation.

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

Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken or water inventory balances performed every 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

(continued)

COMANCHE PEAK - UNITS 1 AND 2 B 3.4-78 Revision 76 CPNPP LAR 19-001

~age 10 of 12 RCS Leakage Detection Instrumentation

B 3.4.15 BASES ACTIONS B.1.1, B.1.2, B.21, and B.2.2 (continued)

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. A Nqte is added allowing that SR 3.4.13.1 Is not req~ired to be performecfuntil 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after establishing s_teady state operation (as defined in the Bases of SR 3.4.13.1 ). The 12 hour*allowance provides sufficient time to collect and process alt necessary data after*stable plant.

conditions are established. The 30 day Completion Time recognizes at

1east one other form of leakage detectron is available.

C.1 and C.2 With the containment air.cooler condensate flow rate rnonitor inoperable, alternative action is again required: Either SR 3.4.15.1 must be P.erformed dr water inventory balances, in-accordance with SR ':3.4.13._1, must be performed to provid~* alternate periodic information. Provided*a CHANNEL CHECK is. performed every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months or a water inventory.

balance is performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , reactor* operation may co_ntinue while awa_iting restoration _of the contair:iment air*~oler condensate flow rate mor'litor to OPERABLE status.

~ r

~

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information _thaf is adequate to

detect RCS LEA_KAGE. ANote is added allowing that SR 3:4.13.1 is.not required'to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after_ establishing steady state operation (as defined in the Bases of SR 3.4.13.1 ). The 12 hou~

_allowance provides sufficient time*to collect and process all_ necessary

data after-stable plant conditions are established*.

o: 1,* D.2.1, and D.2.2 *

With th& required con°lQinment sump monitor and the containmen_t air cooler condensate flo_w rate monitcir ino~raple, the only means of.

detecting LEAKAGE is the required containment atmosphere radiation monitor. A Note clarifies tha~ _this Condition is applicable: when the: only OPERABLE monitor.is the containment atmosphere g1::1seous radiation 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 leaka*ge detectioh. Indirect methods of monitorihg RCS

1e*akage must be implemented, Grab samples of the containment

atinosphere must be taken to provide alternate periodic information. The

12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months interv~I is sufficient to detect increasing RCS leakage. The

Reguired Act1on provides 7 days to restore another RCS leakage (continued)_

COMANCHE PEAK - UNIJ"S 1 AND 2 B 3.4-79 Revision 76 CPNPP LAR 19-001 Page 11 of 12 RCS Leakage Detection lr:istrumentation B 3.4.15 BASES ACTIONS SURVEILLANCE REQUIREMENTS 0.1, D.2.1, and D.2.2 (continued) monitor to OPERABLE status to regain the intended leakage detection diversity. The 7 day Completion Time ensures thatthe plant will not be

_operated in a degraded configuration for a lengthy time perjod.

E.1 and E.2 Wrth the re/quired containment atmosphere radiqaetivity'mpnitor and.the containment air cooler condensate flow rate monitor inoperable, the only means of detecting leakage is the containment sump monito_r. This Condition does not provide the required diverse r:neans of leakage detection. Th~ Required Action is to restore either-of th~ inoperable :

required monitors to OPERABLE status withjn 30 days to regain the intended leakage detection diversity. The 30 day Completion llme ensures that the plant will not be operated in a reduced configuration for a lengthy time period.

- F,.1 and F:2 If a Required Action of Condition A, B, C, D or E cannot be met, the plant.

niust'be brought to a MODE in Which the requi~menf.does not apply. To*

achieve this status, the plant must be brought to at least MODE'3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . 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.

Wrth ~II required monitors inoperable, no automatic means.of monitoring leakage are available*, and immediate plant -shutdown in accordance with*

LCO 3.0.3 is required.

SR 3.4.15.1 SR 3.4.15.1 requires the perfom,ance of a CHANNEL CHECK of the required containment atmosphere radioactivity monitor. The check gives

~easonable-confidence that the channel _is.operating properly:. The Surveillance Frequency is controlled under the Surveillance Frequency Control' Program.

(continued)

COMANCHE PEAK - UNITS 1 AND:2 13 3.4-80

Revision 76 CPNPP LAR 19-001 Page 12 of 12

RCSleakage Detection Instrumentation B 3.4.15 BASES SURVEILLANCE REQUIREMENTS REFERENCES SR 3.4.15.2 SR 3.4.15.2 requires the performance of a COT on the required containment atmosphere radioactivity monitor. Ttie 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 Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.4.15.3, SR 3.4.15.4, and*SR 3.4.15.5 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 Surveillance Frequency is controlled u-nder the Surveillance-Frequ~ncy Control.Program.

1.

. 1 O CF:R ~O, Appendix A,Section IV, GDC 30.

2.

Regulatory Guide 1.45,_Revision 0, "Reactor Coolar:it:Pressure _

Boundary Leakage Detection Systems," May 197'.3:

3.

FSA~, Section_ 5.2 COMANCHE PEAK-UNITS 1 AND.2 B 3.4-81 Revision 76

v t e Letter Sequence Request
EPID:L-2018-LLA-0259, TSTF-513, TSTF-5 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance Administration Questions 9 January 2019 Answers Results Approval Other: ML20015A054
MONTHYEAR2019-11-07 [Table View]

CP-201900393, License Amendment Request (LAR) 19-001, Application to Adopt TSTF-513-A, Revision 3, PWR Operability Requirements and Actions for RCS Leakage Instrumentation

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SUBJECT:

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SUMMARY

3.0 TECHNICAL EVALUATION

SUMMARY

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4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

15.2 REFERENCES

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CP-201900393, License Amendment Request (LAR) 19-001, Application to Adopt TSTF-513-A, Revision 3, PWR Operability Requirements and Actions for RCS Leakage Instrumentation

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SUBJECT:

Dear Sir or Madam:

SUMMARY

3.0 TECHNICAL EVALUATION

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

15.2 REFERENCES

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