ML20034G284
| ML20034G284 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 03/03/1993 |
| From: | Simpkin T COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20034G285 | List: |
| References | |
| GL-83-37, NUDOCS 9303090285 | |
| Download: ML20034G284 (12) | |
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a gAN Commonwealth Edison e i 1400 Opus Place
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Downers Grove, Illinois 60515 March 3, 1993 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Attn: Document Control Desk
Subject:
Zion Station Unit 1 Application for Amendment to Facility Operating License DPR-39 Appendix A, Technical Specifications NRC Docket No. 50-295
References:
(a) November 22, 1991, letter from S.F. Stimac to T.E. Murley (b) January 27, 1993 letter from T.E. Murley to T.J. Kovach (c) February 26, 1993 letter from S.F. Stimac to T.E. Murley
Dear Dr. Murley:
Pursuant to 10CFR50.90 Commonwealth Edison (CECO) proposes to amend Appendix A, Technical Specifications, of Facility Operating License DPR-39. The proposed amendment requests a change to the " Accident Monitoring Instrumentation" Technical Specification to defer the next calibration of the Unit 1 Containment Recirculation Sump Level (CRSL) instrumentation until the end of the next refueling outage.
Reference (a) provided a propo, sed amendment to incorporate Generic Letter 83-37 Accident Monitoring Instrumentation requirements.
Reference (b) provided the NRC's approval of the proposed amendment.
The amendment, in part, reduced the calibration interval for the CRSL instrumentation from 3 years to every refueling outage (nominally every 18 months).
The last time the CRSL instrumentation was calibrated was in March of 1991.
The issuance of reference (b) with the reduced calibration interval placed the Unit 1 CRSL instrumentation outside of its required calibration frequency.
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ZNLD/1344 9303090285 930303 b
PDR ADOCK 05000295
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Dr. T.E. Murley March 3, 1993 l
l Reference (c) documented CECO's request for a Temporary Waiver of Compliance for the affected Technical Specification to allow sufficient time to process an amendment request.
This waiver was granted on I
February 26, 1993, to expire at 5:00 p.m. on June 30, 1993. CECO requests review and approval of this amendment prior to June 30, 1993 in order to prevent the unit shutdown that would be required upon expiration i
of the waiver.
i If Unit 1 experiences a forced outage requiring a shutdown to Mode 3 i
i or below prior to the next scheduled refueling outage, ZlR13, the l
instrumentation will be calibrated prior to unit restart.
If no shutdown is experienced, the instrumentation will be calibrated prior to the completion of the next scheduled refueling outage.
i Attachment A contains a detailed description and justification for the proposed amendment.
Included as Attachments B and C are a No Significant Hazards Consideration Evaluation and an Environmental i
Assessment, respectively. Attachment D provides the marked up and typed versions of the affected Technical Specification pages.
l This proposed amendment has been reviewed and c roved by both On-site and Off-site Review in accordance with Commonn. tith Edison procedures.
1 Commonwealth Edison is notifying the State of Illi,ois of our' i
application for amendment by transmitting a copy of t.41s letter and its i
attachments to the designated State office.
l To the best of my knowledge and belief, the statements contained herein are true and correct.
In some respects, these statements are not l
based on my personal knowledge but upon information received from other
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Commonwealth Edison and contractor employees.
Such information has been reviewed in accordance with Company practice and I believe it to be reliable.
l Please direct any questions you may have regarding this matter to i
this office.
Respectfully, T.H. Simpkin Nuclear Licensing Administrator 1
ZNLD/1344 l
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Dr. T.E. Murley March 3, 1993 Attachments: A) Justification for the Proposed Change B) Evaluation of Significant Hazards Consideration C) Environmental Assessment D) Revised Technical Specification Pages cc:
A. Bert Davis, Regional Administrator - RIII J.D. Smith, Senior Resident Inspector - Zion C.Y. Shiraki, Project Manager - NRR Office of Nuclear Facility Safety - IDNS State of Illinois, County of Cook Signed before me on this 3// day of
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, 1993.
BY:
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ATTACHMENT A ZION NUCLEAR GENERATING STATION DESCRIPTION AND SAFETY ANALYSIS OF THE SPECIFIC PROPOSED TECHNICAL SPECIFICATION CHANGES FOR LICENSE AMENDMENT REQUEST NO.
93-02 ZNLD/2532/1
9 DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGES TO APPENDIX A TECHNICAL SPECIFICATIONS OF FACILITY OPERATING LICENSES DPR-39 AND DPR-48 l
A. DESCRIPTION OF THE PROPOSED CHANGE j
l A one time extension of the 18 month CHANNEL CALIBRATION surveillance for the Unit 1 Containment Recirculation Sump Level (CRSL) instrumentation has been i
specified until the end of the Unit 1 13th refueling outage, presently scheduled to commente on October 22, 1993. Approval of an extended i
surveillance interval until June 30, 1993 was previously granted by the Nuclear Regulatory Commission in response to Commonwealth Edison Company's (CECO) request for a Nuclear Reactor Regulation (NRR) Temporary Waiver of Compliance (THOC) concerning Unit 1 surveillances required by Technical Specification Surveillance Requirement 4.8.9 dated February 26, 1993.
In addition, the footnotes contained in Accident Monitoring Instrumentation i
Tables 3.8.9-1 and 4.8.9-1 which provide provisions associated with refueling outage Z1R12 for Unit 1 and Z2R12 for Unit 2 have been deleted.
Both Zion Unit 1 and Unit 2 have completed their 12th refueling outage.
Deletion of f
these footnotes is considered editorial in nature since the specified interval for these allowances which were previously approved by the staff has expired.
B. CURRENT REQUIREMENT Technical Specification Table 3.8.9-1 specifies the accident monitoring.
l instrumentation which shall be OPERABLE to ensure sufficient information is l
available on selected plant parameters to monitor and assess these variables l
during and following a design basis accident.
Technical Specification Table l
l 4.8.9-1 specifies the surveillance requirements necessary to ensure continued l
operability of the Post Accident Monitoring instrumentation. Two channels of CRSL instrumentation are required to be OPERABLE in MODES 1,2,3, and 7.
With i
less than the required numbers of channels OPERABLE (2), but not less than the minimum OPERABLE number (1), operations may continue for a period of time.not to exceed 7 days.
With less than the minimum OPERABLE channels (1),
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operations may continue for a period of time not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
If the minimum OPERABLE channels or the required number of channels are not restored within the required time frames, the unit must be placed in MODE 4 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
l The CRSL instrumentation provides indication in the main control room by i
energizing two channels of lights when the level in the sump is approximately 8 inches, 48 inches, Ill inches, 123 inches and 135 inches respectively.
In the event of a design basis loss of coolant accident, spilled reactor coolant i
and injection water would be collected in the containment recirculation sump i
following the injection phase and would be recirculated back to the RCS by the I
residual heat removal (RHR), centrifugal charging, and safety injection pumps.
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I The recirculation phase begins before the Refueling Hater Storage Tank (RHST) l is completely emptied such that all pipes are kept filled with water. Hater 1
level indication and alarms on the RHST are provided to inform the operator that sufficient water has been injected into the containment to allow manual initiation of recirculation with the RHR pumps and to provide ample warning to terminate the injection phase while the operating pumps still have adequate net positive suction head (NPSH). The CRSL instruments provide backup indication that injection can be terminated and recirculation initiated and help ensure core cooling can continue to mitigate the accident consequences during the recirculation phase. The CRSL instruments do not provide a safety function actuation.
l C. REQUESTED REVISION The proposed change allows a one time extension in the performance of the CHANNEL CALIBRATION surveillance requirements of Specification 3.8.9 for the i
Unit 1 CRSL instrument channels until the end of the 13th refueling outage for Unit 1.
The 13th refueling outage for Unit 1 is presently scheduled to commence on October 22, 1993. Upon entry into MODE 4 during the scheduled Unit 1 outage, the unit will be outside the mode of applicability for the CRSL i
instruments. Calibration of the CRSL instruments will be performed prior to entry into MODE 3 following completion of 13th refueling outage, tentatively scheduled to end in March, 1994.
Technical Specification Table 4.8.9-1 has been modified to include a footnote which states "the specified 18 month frequency for Containment Recirculation Sump Level instrumentation may be extended for Unit I until the end of refueling outage Z1R13."
The two Unit 1 CRSL instruments have not been calibrated within the Technical Specification surveillance frequency of 18 months.
In order to perform the
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calibration, a plant shutdown would be required due to the adverse radiological conditions in the area of the containment recirculation sump during plant operation.
The containment recirculation sump is located on the 568' elevation of the containment building inside the missile barrier.
In order to calibrate the CRSL instruments, personnel must enter this area.
Radiation dose rates in 4
this area are approximately:
o 4 to 5 R/HR at 60% Rated Thermal Power, 4
o 200 mR/HR at 5% Rated Thermal Power, o 100 mR/HR during MODE 3, and o 100 mR/HR during MODE 5.
Approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is required in this area in order to complete calibrations of these instruments channels.
To adhere to the As Low As Reasonable Achievable (ALARA) philosophy, it is not prudent to perform these calibrations during power operation.
However, Specification 4.0.3 requires that, in the event a required surveillance is not performed within the j
required frequency, the affected channels be declared inoperable and the j
required actions of the affected LCO be taken.
ZNLD/2532/3 I
Actioa b of the affected LC0 requires that the unit be placed in Mode 4 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Therefore, to prevent the shutdown of Unit 1, which involves an undesirable transient on the unit, a one time extension of the CRSL CHANNEL CALIBRATION surveillance interval has been proposed.
D. IMPACT OF PROPOSED CHANGE i
Zion Station Technical Specification Amendments 141/130 for Units 1 and 2 respettively, incorporated the CRSL instrumentation into the Accident
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Honitoring Instrumentation table of Specification 3.8.9.
These amendments were approved by the NRC on January 27, 1993.
The amendments were issued as-immediately effective, to be implemented within 30 days (by February 27, 1993).
Prior to the issuance of amendments 141/130, calibration of the CRSL instrumentation was performed on a 3 year interval.
The last calibration of the Unit 1 CRSL instruments was performed on March 2, 1991. As such, these instruments would remain within their surveillance interval until March 1994.
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Surveillance Requirement 4.8.9 requires the CHANNEL CALIBRATION of the Accident Monitoring Instruments to be performed each refueling outage, (every
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18 months). Accordingly, the 18 month CHANNEL CALIBRATION surveillance
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interval, including to the 25% allowance provided by Specification 4.0.2, expired on January 17, 1993.
A review of calibration data and work requests for the past surveillance intervals since 1977 for both Unit 1 and Unit 2 CRSL instruments has shown only 2 failures.
These failures were associated with the Unit 2 instruments and were determined to be the result of failed light bulbs. These light bulb failures would have been detected during the monthly CHANNEL CHECK, also required by Surveillance Requirement 4.8.9.
The CRSL instruments are now stSject to a monthly CHANNEL CHECK in accordance with Surveillance Requirement 4.8.9.
These CHANNEL CHECKS provide a periodic qualitative assessment regarding the OPERABILITY of these channels during the interval between l
channel calibrations.
1 The two CRSL instruments provide backup indication to ensure the containment i
recirculation sump contains an adequate volume of injection water following a design basis accident to allow the RHR pumps to switch over to the recirculation phase of cooling.
Extending the CHANNEL CALIBRATION l
surveillance interval for an additional 9 months does not prevent the CRSL instruments from indicating the level in the containment recirculation sump.
The majority of the calibrations of the CRSL instruments have demonstrated these instruments will provide the necessary backup indication to allow the operators to assess the status of containment recirculation sump.
Since the CHANNEL CALIBRATIONS have been successfully performed on the Unit 1 CRSL instrumentation within the previous intervals, it is primarily a question of OPERABILITY that has not been verified within the last 18 months.
In this case, the two Unit 1 CRSL instruments would be considered OPERABLE unless it is known that the CHANNEL CALIBRATION can not be satisfactorily performed (then the associated CRSL channel will be considered inoperable).
In addition, the Refueling Hater Storage Tank level instruments and the Containment Water Level (wide range) instruments are required to be OPERABLE per Specification 3.8.9.
These instruments provide alternate indication of
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'the status of the water level in the containment following a design basis I
accident.
ZNLD/2532/4
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ATTACHMENT B ZION NUCLEAR GENERATING STATION SIGNIFICANT HAZARDS CONSIDERATION EVALUATION j
FOR LICENSE AMENDMENT REQUEST NO.
93-02 l
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ZNLD/2532/5 l
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SIGNIFICANT HAZARDS CONSIDERATXON EVALUATION 9
Commonwealth Edison has evaluated this proposed amendment and has determined
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that it involves no significant hazards considerations. According to 10CFR 50.92(c), a proposed change to an operating license involves no significant hazards considerations if operation of the facility in accordance with the l
proposed change would not:
i 1)
Involve a significant increase in the probability or consequences of an accident previously evaluated; or i
2)
Create the possibility of a new or different kind of accident from any accident previously evaluated; or l
3)
Involve a significant reduction in a margin of safety.
The following evaluation is provided for the three categories of the significant hazards consideration standards.
1 1.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change does not result in any hardware or operating procedure changes.
The frequencies for surveillances are not assumed in the initiation of any analyzed events.
This change allows a one time delay in the performance of the CHANNEL CALIBRATION required by i
Surveillance Requirement 4.8.9 for the CRSL instruments.
It would be overly conservative to assume the two Unit 1 CRSL instruments are inoperable when the CHANNEL CALIBRATION has not been performed within the 18 month frequency.
Since the CHANNEL CALIBRATIONS for these instrument channels have been successfully performed within the previous interval, it is primarily a question of OPERABILITY that has not been verified by performance of the surveillance withir the new required frequency.
In addition, alternate indication of containment water level is available from the RHST level instrument channels and the containment water level (wide range) instrument channels.
Therefore, the censequences of an accident previously evaluated are not significantly increased since the most likely outcome of performing the CHANNEL CALIBRATION would demonstrate the CRSL instruments are OPERABLE.
2.
Does the change create the possibility of a new or different kind of accident from any previously analyzed?
The proposed change does not result in plant operations or configurations that could create a new or different type of. accident.
i No new equipment is being introduced, and installed equipment is_not being used in a new or different manner.
No plant configuration changes are being made as a result of this amendment request.
Additionally, this request deals with instrumentation that performs a monitoring function. There is no active interface between the subject instrumentation and the installed equipment whose failure would initiate a transient event.
Therefore, the change will not
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create a new or different type of accident.
ZNLD/2532/6
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i 3.
Does the change involve a significant reduction in a margin of safety?
The increased time allowed for the performance of the CHANNEL CALIBRATION of the CRSL instruments is acceptable based on the small probability of an event requiring these instruments to function.
Granting a one time extension to the 18 month CHANNEL CALIBRATION for the Unit 1 CRSL instruments is acceptable considering the historical reliability.of'these instrument channels.
Without this extension, a l
unit shutdown would be required to perform the surveillance or to comply with the actions for inoperable instrument channels which cannot be restored. As such, any reduction in a margin of safety will be insignificant and offset by the benefit gained in plant safety due to the avoidance of a plant shutdown transient.
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ATTACHMENT C ZION NUCLEAR GENERATING STATION ENVIRONMENTAL ASSESSMENT FOR LICENSE AMENDMENT REQUEST NO.
93-02 l
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ENVIRONMENTAL ASSESSMENT 1
The proposed changes of this license amendment request have been evaluated against the criteria for and identification of licensing and regulatory actions requiring environmental assessment in accordance with 10CFR51.21.
It has been determined that the proposed changes meet the criteria for i
categorical exclusion as provided for under 10CFR51.22(c)(9).
The following I
is a discussion of how the proposed change meets the criteria for categorical exclusion:
10CFR 51.22(c)(9): Although the proposed change involves changes to the installation or use of facility components or to Surveillance Requirements.
(1)
The proposed change involves no significant hazards considerations (refer to the significant hazards consideration j
section of this license amendment request).
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i (ii)
There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, since the proposed changes do not affect the generation of any radioactive effluent nor do they affect any of the permitted release paths, and l
(iii)
There is no significant increase in individual or cumulative occupational radiation exposure.
i Accordingly, the prop > sed changes meet the eligibility criteria for i
categorical exclusion set forth in 10CFR51.22(c)(9).
Based on the aforementioned and pursuant to 10CFR51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with issuance of a license amendment incorporating this proposed change.
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